Wildlife Management: Negotiations on a Long-Term Plan for Managing
Yellowstone Bison Still Ongoing (Letter Report, 11/30/1999,
GAO/RCED-00-7).
Pursuant to a congressional request, GAO reviewed the governmental and
nongovernmental plans for managing the Yellowstone National Park bison
herd, focusing on the: (1) key elements of the five nongovernmental
plans and the government's preferred alternative; (2) strengths and
weaknesses of the economic analyses used to support each of these six
plans; and (3) status of efforts to issue the environmental impact
statement (EIS) on the government's plan.
GAO noted that:(1) the proposed plans for managing the Yellowstone bison
all have same the basic purpose, which is to maintain a wild,
free-ranging population while protecting Montana's cattle from
brucellosis infection; (2) however, the specific objectives and
management actions identified to achieve that purpose differ
significantly among the plans; (3) of the six different bison management
plans GAO reviewed, only the interagency team's draft EIS included an
analysis of the net benefits associated with its seven bison management
alternatives; (4) consequently, GAO was unable to compare the potential
economic effects of the plans; (5) moreover, the scope of the
interagency team's analysis of the benefits and costs is limited, and
some of the data used in the analysis is subject to considerable
uncertainty; (6) because of time constraints, the interagency team's
contractor used data on other wildlife species to approximate the
bison-related benefits; (7) the interagency team stated that it plans to
improve the precision of the benefit estimates in the final EIS by using
bison-specific data that is being collected; (8) approximately 70
percent of the public comments received by the interagency team opposed
the preferred alternative presented in the draft EIS; (9) on the basis
of the public comments and the findings of additional research completed
after the draft statement's issuance, the interagency team is
considering modifying the preferred alternative for the final EIS; (10)
on November 5, 1999, the federal lead agencies sent the latest proposal
for modifying the preferred alternative to Montana for its review; and
(11) according to Department of the Interior staff, the proposal would
rely on the vaccination of both bison and cattle, as well as their
separation, to minimize the risk of brucellosis transmission.
--------------------------- Indexing Terms -----------------------------
REPORTNUM: RCED-00-7
TITLE: Wildlife Management: Negotiations on a Long-Term Plan for
Managing Yellowstone Bison Still Ongoing
DATE: 11/30/1999
SUBJECT: Federal/state relations
Economic analysis
Environmental impact statements
Cattle
Animal diseases
Infectious diseases
National parks
Wildlife management
IDENTIFIER: Montana
Yellowstone National Park(WY)
USDA Brucellosis Eradication Program
Interagency Bison Management Plan
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Cover
================================================================ COVER
Report to Congressional Requesters
November 1999
WILDLIFE MANAGEMENT - NEGOTIATIONS
ON A LONG-TERM PLAN FOR MANAGING
YELLOWSTONE BISON STILL ONGOING
GAO/RCED-00-7
Managing Yellowstone Bison
(141310)
Abbreviations
=============================================================== ABBREV
APHIS - Animal and Plant Health Inspection Service
EIS - environmental impact statement
NEPA - National Environmental Policy Act of 1969
NRC - National Research Council
Letter
=============================================================== LETTER
B-283638
November 30, 1999
The Honorable Tom Campbell
The Honorable Christopher Shays
House of Representatives
Yellowstone National Park has the largest concentration of
free-roaming bison in the lower 48 states. Throughout the winter and
early spring, the bison periodically move back and forth across the
park boundary seeking food that is not covered by hardened or deep
snow. Because some Yellowstone bison have brucellosisa disease that
can cause cattle to abort during pregnancylivestock owners and
public officials in the bordering state of Montana fear that the
bison will transmit the disease to domestic cattle. The federal
government and states have been attempting to eradicate the disease
in cattle nationwide for over 65 years. If two of Montana's cattle
or commercial bison herds were found to have brucellosis, the state
would lose its federal brucellosis-free certification, jeopardizing
its right to freely transport cattle across state lines and creating
potentially significant economic hardship for its livestock industry.
In July 1990, the Department of the Interior's National Park Service;
the Montana Department of Fish, Wildlife and Parks; and the
Department of Agriculture's Forest Service formed an interagency team
to examine various alternatives for the long-term management of the
Yellowstone bison herd. The purpose of the action was to develop a
management plan that would ensure the viability of Yellowstone's wild
and free-ranging bison herd while at the same time protecting
Montana's domestic cattle from the risk of contracting brucellosis.
Later, the interagency team was expanded to include the Montana
Department of Livestock and Agriculture's Animal and Plant Health
Inspection Service (APHIS). All of these agencies have some
jurisdiction over the bison management effort. In June 1998, on
behalf of the interagency team, the Park Service released a draft
environmental impact statement (EIS) for public review and comment.
The draft assessed the environmental impact of seven alternatives,
including a preferred alternative, for managing the bison. The
interagency team plans to issue a final EIS in late 2000.
Afterwards, a final decision will be made on how the Yellowstone
bison will be managed in the future.
Dissatisfied with the preferred alternative chosen from the seven
alternatives analyzed by the interagency team in the draft EIS,
various nongovernmental organizations--including environmental
groups, conservation groups, animal protection groups, Native
American organizations, and a national animal health
association--submitted five new plans for the interagency team to
consider in its final decision-making process. These plans vary
considerably in how they would manage the Yellowstone bison.
Concerned about which plan was the most cost-effective, you asked us
to identify (1) the key elements of the five nongovernmental plans
and the government's preferred alternative and (2) the strengths and
weaknesses of the economic analyses used to support each of these six
plans. We are also providing you with information on the current
status of the effort to issue the final EIS.
RESULTS IN BRIEF
------------------------------------------------------------ Letter :1
All the proposed plans for managing the Yellowstone bison have the
same basic purpose. Specifically, they strive to maintain a wild,
free-ranging population of bison and address the risk of brucellosis
transmission to protect the economic interest and viability of
Montana's livestock industry. However, the specific objectives and
management actions identified to achieve that purpose differ
significantly among the plans. For example, although all the plans
aim to maintain a wild, free-ranging herd of bison, two of the
nongovernmental plans say that the herd should have no restrictions
on where it goes and should be treated like any other wildlife
outside the park. In contrast, other plans, including the
government's preferred alternative, would allow the bison to range
only within certain boundaries. Beyond these boundaries, the bison
would be herded back into the park, captured, or killed.
Furthermore, to protect Montana's cattle from the risk of contracting
brucellosis, two of the nongovernmental plans would emphasize
managing the cattle to keep them away from the bison. In contrast,
the other plans, including the government's preferred alternative,
would emphasize managing the bison within specific boundaries to keep
them away from the cattle.
Of the six different bison management plans we reviewed, only the
interagency team's draft EIS included an analysis of the net benefits
(benefits minus costs) associated with its seven bison management
alternatives. Benefits include such items as the existence of bison,
opportunities for visitors to view bison, and the attraction of
tourists to the park. Costs include such items as the cost of
managing the bison. Consequently, we were unable to compare the
potential economic effects of the various plans. Moreover, the scope
of the interagency team's analysis of the benefits and costs is
limited, and some of the data used in the analysis are subject to
considerable uncertainty. For example, a primary motivating factor
for developing a long-term bison management plan is to avoid
widespread economic hardship for Montana's livestock industry if
brucellosis is transmitted from wild bison to cattle. However, the
draft EIS does not estimate the economic effects of a potential
outbreak. Without such information, the public and interagency final
decisionmakers may have difficulty assessing whether the economic
consequences of an outbreak justify incurring the costs of
undertaking a particular management action. In addition, because of
time constraints, the interagency team's contractor used data on
other wildlife species to approximate the bison-related benefits.
These estimates, however, are subject to considerable uncertainty,
which substantially limits the usefulness of the estimated net
benefits in assessing which management alternative would likely
provide the greatest net benefits. The interagency team stated that
it plans to improve the precision of the benefit estimates in the
final EIS by using bison-specific data that are currently being
collected.
Approximately 70 percent of the public comments received by the
interagency team opposed the preferred alternative presented in the
draft EIS. On the basis of the public comments and the findings of
additional research completed after the draft statement's issuance,
the interagency team is considering modifying the preferred
alternative for the final EIS. On November 5, 1999, the federal lead
agencies sent the latest proposal for modifying the preferred
alternative to the state of Montana for its review. According to
Department of the Interior staff, the proposal would rely on the
vaccination of both cattle and bison, as well as their separation, to
minimize the risk of brucellosis transmission. The proposal also
recognizes the need for flexibility and allows for further
modification of the bison management plan if future monitoring and/or
research results indicate a need for change. As of November 10,
1999, negotiations among the members of the interagency team were
ongoing.
BACKGROUND
------------------------------------------------------------ Letter :2
The National Park Service manages bison only within the borders of
Yellowstone National Park. Outside the park, neighboring states,
such as Montana, manage wildlife not only on their own lands but also
on other federal lands, such as those owned by the Forest Service.
According to the National Park Service, as of August 17, 1999, there
were 2,444 bison in Yellowstone National Park. Although millions of
bison once ranged from the Appalachian Mountains through the Great
Plains, Yellowstone is the only place in the lower 48 states where
bison have existed since prehistoric times, although only 23 native
bison remained in Yellowstone in 1902. For thousands of years,
bison, nomadic by nature, have routinely migrated in and out of what
is now the park to seek food. Such migration occurs especially in
severe winters and early spring, when available forage is covered by
hardened or deep snow.
Bison migrate into Montana across the northern and western boundaries
of the park.\1 In the north, when bison exit the park, they move onto
adjacent national forestland or onto private land around the
community of Gardiner, where several hundred cattle are present
almost year-round. In the west, when bison leave the park, they move
onto national forestland and private land around the community of
West Yellowstone. Up to a few hundred cattle may occupy select
public and private lands in the West Yellowstone area in the summer
months, but no cattle are present in the winter. Depending on the
time of year and the size of the cattle herds, over 2,000 cattle can
occupy public and private land in the Montana portion of the Greater
Yellowstone area.
According to the Park Service, it is important to note that only a
portion of these 2,000 cattle actually occupy lands where bison are
most likely to move. Specifically, on the north side of the park,
approximately 300 cattle occupy private lands and about 80 cattle
occupy public lands where bison are likely to move during the winter
and early spring. On the west side of the park, approximately 350
cattle occupy lands where bison are likely to be found. However,
these cattle are not grazed year-round and are not present when bison
are actually in the area. As a result, only about 730 of the 2,000
cattle in the Greater Yellowstone area actually occupy lands that
bison generally use when they leave the park. Montana officials
noted, however, that if the Yellowstone bison were left uncontrolled,
they would likely continue to migrate farther north along the
Yellowstone River valley and northwest along the Madison River
valley, to where more cattle are maintained year-round on extensive
private lands. Figure 1 provides an overview of the Greater
Yellowstone area and the routes that bison have generally taken when
migrating out of the park.
Figure 1: Winter Ranges and
Migration Routes of the
Yellowstone National Park Bison
Herds
(See figure in printed
edition.)
Source: Spatial Analysis
Center, Yellowstone National
Park, National Park Service,
1997.
(See figure in printed
edition.)
Blood tests indicate that about half of the Yellowstone bison have
been exposed to brucellosis. However, as the Park Service noted,
recent research indicates that substantially fewer are actually
infected with the disease. Because these bison, if uncontrolled,
could interact with cattle either directly or indirectly, by sharing
range where cattle will graze, they pose a risk of infecting cattle
with brucellosis.
Brucellosis is a contagious bacterial disease that infects domestic
animals, wildlife, and humans. In the Yellowstone area, elk and
bison are the principal wildlife hosts for the disease. Transmission
occurs primarily through the ingestion of infected milk or the
products of birth or abortion. As a result, the risk of transmission
is greater if cattle and bison interact during, or immediately after,
the bison give birth. In cattle, the disease can cause abortions,
infertility, reduced milk production, lameness, and swollen joints.
In humans, brucellosis is known as undulant fever. Although rarely
fatal, the disease can be debilitating. Symptoms include recurring
fever, muscle and joint aches, headaches, and nausea. Today, there
are very few cases of undulant fever in the United States. According
to the Park Service, only three cases were reported in Montana during
the past 10 years, and none was attributed to wild bison in the
Greater Yellowstone area.
Because of the potential for brucellosis to be transmitted, APHIS and
its state counterparts have a strong interest in the management of
the Yellowstone bison. APHIS is responsible for eradicating
brucellosis from cattle and commercial bison herds in the United
States. Since a national brucellosis control program was first
instituted in 1934, more than $3.5 billion in federal, state, and
industry funds has been spent trying to eradicate the disease from
cattle across the nation. Because federal statutes on controlling
the disease in livestock preempt the states' authority only when
cattle and commercial bison are moving in interstate commerce, states
have enacted their own statutes to supplement federal regulatory
efforts and comply with national brucellosis eradication standards.
According to APHIS, as of August 31, 1999, nationwide there were only
five domestic cattle herds and one commercial bison herd affected by
brucellosis. APHIS also reported that it had certified that Montana
and 43 other states had no cattle or commercial bison that were
infected with brucellosis, as of the same date. APHIS'
brucellosis-free certification is required to export cattle to
markets outside the state without incurring the expense of additional
brucellosis testing.
The consequences of cattle being infected with brucellosis could be
significant under the requirements of APHIS' eradication program. In
a state that has been certified as brucellosis free, if a single herd
of cattle or commercial bison becomes infected, the infected animals
must be slaughtered, the herd quarantined, and the herds in the
surrounding area tested to ensure that the disease does not spread.
This action could have significant economic consequences to
individual livestock operators. However, if no additional infection
is found, the state can remain certified as brucellosis free. If an
additional herd is found to be infected with brucellosis, the state's
classification will be lowered and additional interstate testing
requirements will be imposed across the state. This action could
have significant economic consequences to the state's livestock
industry.
A state with infected cattle or bison may also be subject to
restrictions imposed by other states. For example, because of the
increased movement of brucellosis-infected and -exposed bison out of
Yellowstone National Park, Oregon announced in March 1997 that it
would protect the interests of its cattle industry by immediately
requiring the testing of any cattle entering the state from Montana
and Wyoming. However, this requirement was dropped before being
implemented. Other states have imposed, or threatened to impose,
similar restrictions, but the costs of such actions have not been
determined. Currently, there are no restrictions on the interstate
movement of Montana cattle.
--------------------
\1 Although some bison also migrate east into Wyoming, they are not
covered by the draft EIS addressing bison migration into Montana.
BISON MANAGEMENT
CONTROVERSY ONGOING FOR
YEARS
-------------------------------------------------------- Letter :2.0.1
For years, federal, state, and local government officials; private
landowners; scientists; and researchers have disagreed on how to
manage Yellowstone's free-ranging bison. Opinions differ over the
appropriateness of or need for a management emphasis that would
eliminate brucellosis in the bison; the environmental consequences of
actions needed to eradicate the disease; and the consequences of not
eradicating the disease. The need to develop a long-range plan for
managing the Yellowstone bison was formally recognized in July 1990,
when the Park Service, Montana, and the Forest Service filed a notice
of intent in the Federal Register to prepare an EIS examining
alternatives for such a plan. Later, APHIS was added as a
participant. The first goal of this effort was to issue the EIS by
December 1991. However, as negotiations continued on ways to better
manage brucellosis in bison, many deadlines for completing the effort
came and went.
In January 1995, Montana filed a complaint in federal district court
contending that the conflicting bison management policies of the Park
Service and APHIS threatened Montana's brucellosis-free
certification. At the time, the park allowed natural processes to
control wildlife populations and opposed efforts to manage wildlife
in a way that would conflict with natural regulation or restrict wild
animals' free-roaming nature.\2 APHIS, however, committed to
eradicating brucellosis in the United States, believed that wildlife
should be tested and, if infected, slaughtered to prevent the disease
from spreading further. To settle the lawsuit, Montana and the
federal government agreed to develop interim bison management
procedures and an EIS for the long-term management of bison. In
August 1996, the Interim Bison Management Plan was implemented.
Generally, the plan does not allow the Yellowstone bison to migrate
into Montana except in designated areas. As a result, since the
notice of intent to prepare an EIS was issued, over 2,300 bison have
been destroyed after leaving the park, including a record 1,084 bison
that were shot or captured and slaughtered in the particularly harsh
winter of 1996-97.
--------------------
\2 Under the Park Service's natural regulation policy, the size of
the bison herd was regulated by natural forces, such as climate, food
supply, and predation.
PROGRESS FINALLY MADE
TOWARD COMPLETING DRAFT
EIS
-------------------------------------------------------- Letter :2.0.2
Between July 1990, when the EIS process started, and the spring of
1997, little progress was made toward completing a draft EIS that was
acceptable to all the participants. The interagency team had
developed several alternative plans for managing the bison, but
because of conflicting missions and objectives, the agencies could
not agree on any one as a preferred alternative. In March 1997, in
an attempt to break this deadlock and meet a court deadline for
issuing a long-term bison management plan, the Park Service committed
staff from its Denver Service Center to facilitate the process. With
this assistance, in June 1997, Montana, APHIS, the Forest Service,
and the Park Service were able to negotiate a new seventh alternative
as the preferred alternative for the draft EIS. Table 1 outlines the
seven alternatives presented and analyzed in the draft EIS.
Table 1
Seven Alternatives Analyzed in the Draft
EIS
Alternative's number and name Theme
---------------------------------------- ----------------------------
1. No action This alternative is a
continuation of the 1996
Interim Bison Management
Plan without more recent
modifications. The interim
plan relies on strictly
enforcing boundaries to keep
bison and cattle separate
and has no provision for
quarantining bison.
2. Minimal management This alternative focuses on
changes in cattle operations
outside the park and on
minimal, nonlethal methods
to ensure separation and
minimize the risk of disease
transmission between bison
and cattle.
3. Management with emphasis on public This alternative relies on
hunting hunting to regulate the
number and distribution of
bison outside the park and
separation to preclude
contact between bison and
cattle.
4. Interim plan with limited public This alternative is similar
hunting and quarantine to the Interim Bison
Management Plan, but it
includes quarantine and
hunting as additional bison
management tools.
5. Aggressive brucellosis control within This alternative would
the park through capture, testing, and implement an aggressive 3-
removal year capture and testing
program for all bison in the
park. Bison testing negative
would be released in the
park, and those testing
positive would be shipped to
slaughter.
6. Aggressive brucellosis control within This alternative is a
the park through vaccination variation of No. 5 because
it, too, focuses on
eliminating brucellosis from
the bison herd. However,
parkwide capture, testing,
and slaughter would not
begin until a safe and
effective vaccine had been
applied to the entire herd
for a number of years.
7. Preferred alternative manage for a The preferred alternative
specific bison population range departs from all other
alternatives in that it
would focus on the
population of the bison
herd, and specific
management scenarios would
be put in place as the herd
approached the upper or
lower end of a population
range. Agencies' controls
would decrease as the bison
population approached the
lower end. Additional
measures to remove
increasing numbers of bison
would be implemented near
the upper end.
----------------------------------------------------------------------
Source: Draft EIS for the Interagency Bison Management Plan for the
State of Montana and Yellowstone National Park, National Park
Service, June 1998.
In June 1998, the draft EIS was released for public review and
comment. Written comments were accepted until November 1998. Public
meetings were also held in the Greater Yellowstone area and in major
cities throughout the United States. In addition, the executive
summary for the draft and a public comment form were posted on the
Internet at the Park Service's Web site. Subsequently, the
interagency team had the content of the comments analyzed for the
team to consider in preparing a final EIS. The final EIS is to be
issued in late 2000, according to the latest estimate by the
interagency team. Afterwards, on the basis of the findings,
conclusions, and recommendations that will be made in the final EIS
and other relevant information, agency decisionmakers will issue
federal and state records of decision on how the Yellowstone bison
will be managed in the future.
In commenting on the draft EIS, various nongovernmental organizations
provided five new plans or options for the interagency team to
consider before it issues a final EIS. The interagency team is
currently evaluating these plans, and the Park Service noted that an
analysis of the feasibility and legal implications of these plans has
not yet been completed. Table 2 provides the names of the plans,
their sponsors, and summaries of their proposed approaches to
ensuring the survival of a viable herd of bison and protecting
Montana's cattle from the risk of brucellosis transmission.
Table 2
Bison Management Plans Proposed by
Nongovernmental Organizations
Summary of plan's overall management
Plan Sponsor(s) approach
--------- ---------------------------- ---------------------------------------
The Bison The Fund for Animals, an The plan would allow bison to roam
Alternati animal protection advocacy freely and would regulate the size of
ve group, and other the herd naturally. To minimize the
organizations, including the possibility of disease transmission, it
Humane Society of the United would alter cattle operations on
States and the Earth Island private and public lands, require the
Institute. vaccination of all cattle, and
eliminate the use of snowmobiles in
Yellowstone.
Plan B Written and submitted by an The plan aims to ensure a free-roaming
independent wildlife herd whose size would be regulated like
biologist and endorsed by that of other wildlife. It would
various environmental, minimize the risk of brucellosis
political, taxpayer, and transmission by vaccinating bison and
Native American cattle, removing cattle from public
organizations. lands used by bison, and requiring
changes in cattle operations.
Alternati The Fort Belknap Indian The plan wants bison to remain free
ve 8 Community Tribal Government ranging and retain their status as
of Montana, representing the wildlife but would establish population
Assiniboine and Gros Ventre limits. The plan would control disease
Tribes. by separating bison and cattle, giving
highest priority to removing live bison
through capture, testing, and
quarantine.
Citizens' Organizations including the The plan would limit the size of the
Plan Greater Yellowstone herd to the park's ecological carrying
Coalition, Defenders of capacity and would allow bison outside
Wildlife, the Intertribal the park only in special management
Bison Cooperative, the areas. Disease transmission would be
National Parks and minimized through changes in cattle
Conservation Association, operations on public lands and the
the National Wildlife acquisition of land or easements. The
Federation, the Natural herd's size would be regulated through
Resources Defense Council, public harvest or live removal to
and the Wilderness Society. quarantine for later disposition to
tribal or other public lands.
USAHA The U.S. Animal Health The plan would reduce the size of the
Plan Association (USAHA), an herd from the present population and
organization of state animal not allow bison outside the park. The
health officials, producers, plan would eradicate brucellosis from
researchers, and others the Yellowstone bison by using the same
interested in animal disease management tools used on cattle:
prevention and control. vaccination, quarantine, testing, and
removal.
--------------------------------------------------------------------------------
Source: GAO's analysis of the nongovernmental organizations' bison
management plans.
KEY ELEMENTS OF THE VARIOUS
BISON MANAGEMENT PLANS DIFFER
------------------------------------------------------------ Letter :3
The sponsors of the interagency team's preferred alternative and the
nongovernmental organizations responsible for the five alternative
plans each believe their plan will meet the overall purpose set out
in the EIS--that is, to maintain a wild, free-ranging population of
bison and address the risk of brucellosis transmission to protect the
economic interest and viability of Montana's livestock industry.
Differences in how these plans define a free-ranging herd and how
they deal with the risk of brucellosis transmission demonstrate how
little agreement there is on these issues. Under most of the plans,
the bison would be free to range only as far as a designated
boundary. Under a few plans, however, the bison could roam as freely
as any other wildlife, both inside and outside the park. In
addition, some nongovernmental sponsors believe that the risk of
transmission from bison to cattle is so small that it can be managed
by keeping the two species separate. In contrast, other sponsors
believe the economic consequences of such transmission are so great
that, however small the risk, bison and cattle must not only be kept
separate but the bison must also be vaccinated, tested for the
disease, and slaughtered if they test positive or quarantined for a
time if they test negative. Appendix I compares each proposed
management plan by key element.
INTERAGENCY TEAM
ESTABLISHED PURPOSE AND
OBJECTIVES OF THE EIS
-------------------------------------------------------- Letter :3.0.1
The National Environmental Policy Act of 1969 (NEPA)\3 and its
implementing regulations set forth the requirements for preparing an
EIS. Among other things, the regulations require a statement to
explain why the document is being developed. This statement is to
include information on why the action is required and identifies the
specific purpose, objectives, and constraints in taking the action.
In preparing the EIS, the interagency team said that the purpose of
the proposed action was to maintain a wild, free-ranging population
of bison and address the risk of brucellosis transmission to protect
the economic interest and viability of Montana's livestock industry.
The team defined a wild and free-ranging population of bison as one
that is not routinely handled by humans and can move without
restrictions within specific geographic areas. Furthermore, the team
agreed that the economic interest and viability of Montana's
livestock industry is tied directly to maintaining the state's
brucellosis-free certification from APHIS.
The interagency team then elaborated on the purpose statement,
establishing nine specific objectives for use in determining the
reasonableness of each alternative and in selecting a preferred
alternative. These objectives are as follows:
-- Address the size and distribution of the bison population; have
specific commitments relating to the size of the bison herd.
-- Clearly define a boundary beyond which bison will not be
tolerated.
-- Address the risk to public safety and the threat of damage to
private property posed by bison.
-- Commit to the eventual elimination of brucellosis in bison and
other wildlife.
-- Protect livestock from the risk of brucellosis transmission.
-- Protect Montana from the risk of a reduction in its
brucellosis-free certification.
-- At a minimum, maintain a viable population of wild bison in
Yellowstone National Park, as defined in biological, genetic,
and ecological terms.
-- Base each alternative on factual information, with the
recognition that the scientific database is changing.
-- Recognize the need for coordination in managing the natural and
cultural resource values that are the responsibility of
signatory agencies.
The interagency team agreed that any alternative unable to meet one
or more of these nine objectives to some degree would be regarded as
unreasonable and eliminated from detailed consideration in preparing
the draft EIS.
According to the interagency team, agreement on these specific
objectives was needed to help resolve policy conflicts among the
various agencies participating in the development of the EIS. For
years, these conflicts had blocked progress toward completing the
EIS. For example, the policies of the National Park Service direct
that native populations of wildlife be managed by natural processes
in a relatively undisturbed setting to the maximum extent possible.
Therefore, inside the park, weather, winter snow depths, competition
for forage, predation, and other environmental conditions would
determine the size of the bison population. However, since the risk
of transmission from bison outside the park conflicts with APHIS'
policies on the eradication of brucellosis and Montana's concerns
about the loss of its brucellosis-free certification, each new
alternative developed includes measures to control the bison
population and set boundaries beyond which bison will not be
tolerated. Cooperation among the agencies is necessary because the
bison migrate between jurisdictions with these very different
management objectives--the park seeking to protect and preserve the
bison through natural regulation and the state aiming to safeguard
its brucellosis-free certification through zero tolerance for
transmission of the disease to its cattle. The Park Service has
other objectives, such as providing for the public's enjoyment of
natural and cultural resources, that are also affected.
The specific objectives agreed to by the interagency team did,
however, limit the range of alternatives considered in the draft EIS.
For example, the draft EIS states that a segment of the public asked
for an alternative that used no lethal controls and allowed the bison
to exist with no restrictions on their distribution or on the size of
their population. The interagency team eliminated this alternative
from full-scale analysis because it would not meet the objectives of
the plan. Interagency team members said that taking no action to
manage the bison was not a feasible alternative because of public
safety concerns, the risk of brucellosis transmission, and the
possibility that bison would tend to repopulate the public and
private land outside the park.
--------------------
\3 42 U.S.C. 4321 et seq.
MANAGEMENT ACTIONS NEEDED
TO IMPLEMENT PLANS VARY
SIGNIFICANTLY
-------------------------------------------------------- Letter :3.0.2
Although the purpose of all the plans is to maintain a wild,
free-ranging population of bison and address the risk of brucellosis
transmission, the preferred alternative and the plans proposed by
nongovernmental organizations would achieve this purpose in different
ways. For example, most plans call for specific limits on the size
of the bison herd, while one plan would let nature regulate the
herd's size. Furthermore, to control the risk of brucellosis
transmission, one plan would change only cattle operations, while the
majority of the plans would require a combination of management
actions that would affect both cattle and bison.
The interagency team's preferred alternative focuses on controlling
the size of the bison herd to achieve the purposes of the EIS.
Specifically, the plan establishes a range of 1,700 to 2,500 animals.
As the size of the herd approached the top of the range, agency
control measures would be implemented to remove bison if they left
the park or designated special management areas. As the total
population approached the low end of the range, such control measures
would be decreased. Agency control measures include hunting and the
capture, testing, slaughter, and quarantine of bison. Hunting would
be kept at low levels and allowed only in one or more of the special
management areas. Facilities to capture bison (capture facilities)
would also be located just inside the park boundary or in the special
management areas. All captured bison would be tested for
brucellosis. Bison testing positive for the disease would be
slaughtered. Bison testing negative would be quarantined to ensure
that they would continue to test negative over a period of time.
Eventually, bison clearing the quarantine process would be placed
with disease-free herds outside the park. To further reduce the risk
of brucellosis transmission, the preferred alternative would haze
(use nonviolent means, such as noise, to encourage movement) bison
from areas where they were not wanted and vaccinate bison at capture
facilities when a safe and effective vaccine became available.
According to APHIS, the development of a safe and effective vaccine
and delivery system should be completed by the winter of 2003-04.
Free-ranging bison would also be vaccinated when an effective
delivery system became available. In addition, the preferred
alternative would encourage the vaccination of all of Montana's
cattle calves. While cattle vaccination is common in Montana, the
state's Department of Livestock does not currently require it. In
the long term, the preferred alternative also proposes to complete
the acquisition of additional winter range for the bison north of the
park boundary in the Royal Teton Ranch. The majority of this
acquisition has already been completed.
The Bison Alternative plan would focus on the natural regulation of
the bison herd. To address the risk of brucellosis transmission, the
plan proposes a change in cattle operations. With natural
regulation, no limit would be imposed on the size of the bison
population. Rather, forces such as climate, food supply, and
predation would serve as controls. A key provision of the Bison
Alternative is the elimination of snowmobile trails and the use of
snowmobiles within the park. The plan's sponsors believe that the
groomed snowmobile trails maintained in Yellowstone allow more bison
to survive the winters and/or provide the bison with an easier
pathway to migrate out of the park. The plan would not have any
special management areas, capture facilities, quarantine operations,
or vaccination of bison. It does raise the possibility of purchasing
land or easements for additional bison range. To protect Montana's
cattle industry, the Bison Alternative emphasizes risk management
rather than the eradication of brucellosis and the active management
of cattle rather than of bison. Management actions include requiring
the vaccination and annual testing of all cattle and giving bison
priority over cattle on public lands. The Bison Alternative proposes
closing cattle grazing allotments\4 on public lands adjacent to
Yellowstone, which bison are known to use in the winter. For cattle
on private land, the Bison Alternative would offer ranchers three
options, all to be paid for by public funds. First, if ranchers
could eliminate their cattle-grazing operations, they would be
offered fair market compensation for the value of their cattle herds
annually for 5 years. Second, if ranchers were willing to modify the
type of livestock grazedby, for example, changing from cow-calf
operations to operations with a lower risk of contracting
brucellosis, such as steer or spayed heifer herds\5 --any losses
resulting from the change would be reimbursed. Finally, if ranchers
would agree to construct bison-proof fences around their cattle
pastures, vaccinate all their cattle, and establish annual
brucellosis testing for the cattle, their costs would be fully
reimbursed. The Bison Alternative prohibits hunting but would allow
humane hazing to move bison from areas where they are unwelcome.
Plan B would manage bison like all other wildlife except that it
would control the risk of brucellosis transmission by vaccinating all
bison. Other than vaccination, no management actions would be used
to regulate the bison population within the park. Outside the park,
bison would be managed like all other wildlife in Montana.
Specifically, the state would determine the land's carrying capacity
and the bison population would be limited to that level through
hunting. However, instead of the public, only Native American tribes
would do the hunting, and they would hunt only outside the park. To
manage the risk of brucellosis transmission, the plan emphasizes the
vaccination of all bison and changes to cattle operations. While the
plan does not call for the capture, testing, and slaughter or
quarantine of bison, it would separate cattle and bison, vaccinate
all cattle, remove cattle from public lands used by bison, and offer
ranchers on private lands compensation for switching from cow-calf
operations to lower-risk operations, such as steer-only herds. Plan
B also calls for actions such as urging all states to respect the
brucellosis classifications of the federal government and modifying
Montana's zero-risk policy to a policy accepting scientifically and
economically based levels of risk.
Fort Belknap's Alternative 8 aims to protect and preserve the bison
as a wild, free-ranging species and reaffirm the trust relationship
between the bison and Indian tribes. Bison would be allowed to use
all public lands outside the park and would have priority over
cattle. The size of the herd would be scientifically established on
the basis of the land's carrying capacity. The plan also calls for
acquiring additional land to provide winter range and migration
routes for bison. Excess bison would be captured and tested for
brucellosis. Bison testing positive would be held for tribal
harvest. Bison testing negative would be placed in quarantine using
the same protocol as the preferred alternative. The live removal,
quarantine, and preservation of all bison that tested negative for
brucellosis would be the alternative's highest priority. The
quarantine facility would be located at Fort Belknap. The plan would
also address the risk of brucellosis transmission by offering
incentives to ranchers to change their livestock operations, giving
bison priority in the use of public land by modifying grazing permits
and requiring the vaccination of cattle at no expense to the
ranchers.
The Citizens' Plan is most similar to the preferred alternative in
the EIS. According to the plan's sponsors, the biggest difference is
that there is no testing and slaughtering of bison for disease
control. Bison would be removed only to control populations. Limits
on the size of the herd would be scientifically established for both
the special management areas and the park. Inside the park, bison
would not be shot or captured. The plan would manage bison using
special management areas with flexible boundaries on public land
outside the park on its north and west sides. Traditional public
harvest (hunting) and capture facilities established outside the park
on the north and west sides would be used to regulate excess numbers.
To control disease, the plan focuses on eliminating the opportunity
for transmission rather than eradicating the disease. Specifically,
the plan would keep cattle and bison separate through changes to
private cattle operations, including changes in the timing or
location of cattle grazing on public land used by bison. The plan
would also give bison priority in the use of public land outside the
park. If separation could not be achieved, public grazing allotments
would be eliminated. The plan encourages vaccinating cattle and all
bison when a safe and effective vaccine and a nonintrusive delivery
system are available. Hazing would be used to move bison endangering
persons or private property, and compensation would be available to
cover private property losses. In addition, a revised, more humane,
quarantine protocol and facility would be used for bison testing
negative for brucellosis. Bison clearing quarantine would be turned
over to tribes or released on other public lands. The plan also
calls for acquiring land or easements from willing sellers for key
additional winter range north and west of the park. A unique element
of the Citizens' Plan is the establishment of a long-term advisory
team consisting of staff from involved agencies, tribes, and the
public for consultation on bison management issues.
The focus of the U.S. Animal Health Association Plan, which modifies
one of the draft EIS alternatives, is to eradicate brucellosis from
wild bison. Basically, the plan, which the sponsors see as an
extension of the national effort to eradicate brucellosis in cattle,
proposes to use the same tools to eliminate the disease in bison as
the national eradication program has used for cattle. These tools
include capturing and testing animals and slaughtering those that
test positive and quarantining those that test negative. In
addition, the plan imposes strict controls on the movement of bison
at the borders of the park to prevent brucellosis-exposed bison from
leaving. The plan has two phases. Phase I would vaccinate all bison
to reduce the number testing positive. Bison calves would be
vaccinated immediately, and adults would be vaccinated with a reduced
dose until a safe and effective vaccine became available. Phase II
would capture and test every bison remaining within the park. Bison
testing positive would be slaughtered with the goal of eradicating
the disease. The plan would reduce the size of the special
management area on the north side and would have none on the west
side. It would limit the population to a maximum of 1,800 bison
within the park and the small special management area until a
scientific evaluation of these areas' carrying capacity is done.
Bison that left the park would be hazed back into the park or shot.
A unique characteristic of this plan would be the number of
activities taking place in the park, especially during phase II,
including the plowing of more park roads for winter access to bison
management facilities. The plan does not call for changes to cattle
operations on public or private land, apart from some testing and
vaccination of cattle. According to the sponsors, their plan is the
only one that would eliminate the disease from bison and the only one
that could be implemented without changes to existing federal or
state laws, rules, or regulations.
--------------------
\4 Grazing allotments are permits granted to ranchers by land
management agencies, such as the U.S. Forest Service, that allow
seasonal use of the public range by domestic livestock.
\5 Steers and spayed heifers are non-breeding cattle that would not
transmit the disease if infected by bison. Cow-calf operations are
breeding cattle that are capable of transmitting the disease through
birthing events.
ECONOMIC ANALYSES OF BISON
MANAGEMENT PLANS ARE LIMITED
------------------------------------------------------------ Letter :4
Of the six different bison management plans we reviewed, only the
interagency team's draft EIS included an analysis of the net benefits
(benefits minus costs) associated with its bison management
alternatives. Consequently, we were unable to compare the potential
economic effects of the various plans. Although the interagency team
analyzed the benefits and costs, the scope of their analysis is
limited, and some of the data used in the analysis are subject to
considerable uncertainty. For example, although the draft EIS states
that a primary motivating factor for the bison management plan is the
potential for widespread economic consequences to Montana's livestock
industry if brucellosis is transmitted from wild bison to cattle, the
draft EIS does not estimate the economic effect of a potential
outbreak. Without such information, the public and, ultimately, the
final decisionmakers may have difficulty assessing whether the
economic consequences of an outbreak justify the cost of undertaking
a particular management action. In addition, because of time
constraints, the interagency team's contractor used data on other
wildlife species to approximate the bison-related benefits, such as
the value the public assigns to the species' existence and the value
visitors place on increased or decreased viewing opportunities.
Although the draft EIS acknowledges that these estimates are subject
to considerable uncertainty, the range of uncertainty is so wide as
to substantially limit the usefulness of the results. Without more
precise information, it is difficult to assess which alternative
would likely provide the greatest net benefits. Members of the
interagency team stated that they plan to improve the precision of
the benefit estimates in the final EIS by using bison-specific data
that are currently being collected.
ONLY DRAFT EIS INCLUDED
AN ECONOMIC ANALYSIS
-------------------------------------------------------- Letter :4.0.1
While the interagency team included an analysis of the net benefits
associated with all seven alternatives analyzed in the draft EIS, the
sponsors of the nongovernmental plans stated that they did not have
the technical expertise or the resources needed to conduct
benefit-cost analyses of their plans. According to one of these
sponsors, the nongovernmental plans were created to provide the
federal government with additional alternatives to consider in its
analysis and final decision-making process. The nongovernmental
plans did qualitatively describe some of the benefits and costs that
would be realized upon implementation. However, without a measure of
each plan's benefits and costs in comparable terms (for example,
dollars), the net benefits of the plans cannot be compared.
Although none of the nongovernmental plans included a benefit-cost
analysis, a consultant to the sponsors of Plan B assessed the
cost-effectiveness of Plan B, the Citizens' Plan, and the interagency
team's preferred alternative. Cost-effectiveness analysis is a
technique for comparing the costs of achieving specified goals under
alternative plans. On the basis of this analysis, the consultant
reported that Plan B would accomplish the same purpose as the
preferred alternative but at substantially less cost. The
consultant's analysis is, however, of limited use because it is based
on questionable assumptions. For example, under Plan B, the bison in
Yellowstone National Park would be vaccinated. Even though a safe
and effective vaccine for adult bison and a method for delivering the
vaccine have not yet been developed, the consultant assumed that the
risk of brucellosis transmission from wild, free-ranging bison to
cattle is zero. However, members of the interagency team stated that
the risk is not zero; that is, over time there is a chance that wild,
free-ranging bison will infect cattle because, as the chances for
interaction increase, so do the chances for transmission. In
addition, APHIS noted that the current cattle vaccinations are only
about 65 to 80 percent effective. The consultant's analysis does not
account for the costs that cattle producers would incur under Plan B
if wild, free-ranging bison transmitted brucellosis to cattle.
To estimate the benefits and costs of the alternatives proposed in
the draft EIS, the interagency team used the Water Resources
Council's principles for evaluating alternative plans for water and
related land resources as guidance.\6 The guidance sets forth
practices for assessing and assigning dollar values to both the
beneficial and adverse effects of alternative plans on the national
economy. We found that the economic analysis that was completed for
the draft EIS generally follows the practices set forth in the
guidance. For example, the guidance states that economic effects are
to be measured in terms of the direct net benefits that accrue to the
planning area and the rest of the nation. In addition, an evaluation
of alternatives should be based on the conditions most likely to
exist in the future with and without the plan. In the draft EIS'
economic analysis, the interagency team used the Interim Bison
Management Plan as the first alternative, or baseline condition, and
the six other alternatives as potential future plans.
For each of its six alternatives, the interagency team quantified and
assigned dollar values to the changes in benefits and costs from the
baseline conditions. In terms of costs, the interagency team
identified the direct costs to the government, such as the costs to
construct and operate facilities to capture and quarantine bison and
to acquire land for special management areas. The benefits measured
include those from the recreational viewing of bison and from their
existence. Recreational viewing benefits are defined in the draft
EIS as the value that visitors to Yellowstone National Park might
place on increased or decreased opportunities to view bison.
Existence benefits are defined as the value that U.S. citizens
collectively might place on government actions to improve the habitat
and sustain the population of bison. For example, as indicated in
table 3, the interagency team estimated that implementing the
preferred alternative between 1997 and 2011 would provide net
benefits ranging from about -$25 million (that is, negative $25
million) to $112 million. The second alternative in the draft EIS,
which assumes a larger bison population and the acquisition of more
land for winter range than the preferred alternative, would provide
net benefits ranging from about -$27 million to $153 million over the
15-year life of the plan. The fifth alternative, which among other
things would prevent the wild bison from moving beyond the park's
boundaries, would provide net benefits of about $83 million over the
life of the plan.
Table 3
Projected Economic Effect of
Alternatives in the Draft EIS, 1997-
2011
(Dollars in 1997 millions)
Estimated net
Estimated benefits benefits
------------------ ------------------
Estimate
Alternative d costs Low High Low High
-------------------- -------- -------- -------- -------- --------
1\a $0 $0 $0 $0 $0
2 29 2 182 -27 153
3 23 12 168 -11 145
4 0.7 0.1 0.1 -0.5 -0.5
5 2 -79 -81 -82 -83
6 3 3 -6 -5 -8
7\b 23 -2 135 -25 112
----------------------------------------------------------------------
Note: Numbers may not add to totals because of rounding. Estimated
costs, benefits, and net benefits are changes from the baseline,
alternative 1, the Interim Bison Management Plan, and represent
annual values discounted to 1997 dollars using the 7-percent real
discount rate recommended by the Office of Management and Budget.
\a Baseline.
\b Preferred alternative.
Source: Draft EIS for the Interagency Bison Management Plan for the
State of Montana and Yellowstone National Park, National Park Service
(June 1998).
--------------------
\6 Economic and Environmental Principles and Guidelines for Water and
Related Land Resources Implementation Studies, U.S. Water Resources
Council (Mar. 10, 1983), 137 pp.
SCOPE OF ECONOMIC
ANALYSIS CONDUCTED FOR
DRAFT EIS IS LIMITED
-------------------------------------------------------- Letter :4.0.2
Although the draft EIS states that a primary factor motivating the
development of a bison management plan is the potential for
widespread economic consequences to Montana if brucellosis is
transmitted from bison to cattle, the draft EIS does not estimate the
risk of such transmission or the economic consequences of an outbreak
of the disease. Without this more comprehensive information, the
public and, ultimately, interagency decisionmakers may have
difficulty assessing whether the economic consequences of an outbreak
justify the costs of undertaking a particular preventive management
action.
According to the draft EIS, the risk of transmitting brucellosis from
wild bison to cattle cannot be estimated because there are no
available data. Park Service officials said that the scientific
literature includes no documented instance of brucellosis
transmission from bison to cattle in a wild, uncontrolled setting.
However, if the risk were known or could be approximated, the
expected value of the costs of any alternative could be estimated and
incorporated into a benefit-cost analysis to assess whether the
alternative was worth doing.
In a recent report on brucellosis in the Yellowstone National Park
area, the National Research Council found that the risk that wild,
free-ranging bison would transmit brucellosis to cattle is small, but
not zero.\7 In other words, according to the Council's study, there
is a small chance that over time cattle would become infected with
brucellosis if wild bison were allowed to range outside the park.
The economic consequences of such an event are also not identified in
the draft EIS. Members of the interagency team told us that they did
not estimate the economic consequences because the agencies agreed
that all of the draft EIS' alternatives would prevent transmission
between wild bison and cattle and, as a result, would preclude
economic effects on the livestock industry. Nonetheless, in
justifying the purpose of and need for action, the draft EIS states
that Montana's cash receipts for sales of cattle and calves equaled
some $656 million in 1996. However, the economic consequence of an
outbreak, if it were to occur, would depend on a number of factors,
including whether APHIS, which regulates the interstate shipment of
cattle, downgraded Montana's brucellosis-free certification. For
example, in response to public comments on the draft EIS, an APHIS
economist recently estimated that if an outbreak were to occur and
APHIS downgraded Montana's certification from brucellosis free to
class A, the state's cattle producers might incur additional testing
costs ranging from about $5 million to $16 million per year (1997
dollars) over several years. Under its current policy, APHIS would
downgrade a state's brucellosis-free certification if two or more
cattle herds were found to be infected with brucellosis during any
2-year period. In general, breeding cattle shipped interstate from a
brucellosis-free state are not required to be tested for the disease.
However, under class A, breeding cattle being shipped must be tested
for brucellosis. In addition to the testing costs, APHIS estimated
that Montana's cattle producers might forgo income of about $5
million to $23 million per year over several years because prices
would decrease if buyers reduced their demand for Montana's cattle.
Out-of-state buyers might be less willing to buy Montana's cattle if,
despite testing, they perceived a risk of disease. APHIS stated,
however, that the impact on prices is difficult to assess and, as a
result, the estimate of forgone income is subject to uncertainty.
Under certain conditions, APHIS may downgrade only the affected area
within a state, such as a county. For example, the agency may divide
a state into two brucellosis classification areas if the state has
met certain requirements, including one for committing sufficient
resources to enforce the different testing requirements in each area.
APHIS stated that under these conditions, the additional costs of
testing for brucellosis and of forgone income would be much lower
because fewer cattle producers would be affected. For example, APHIS
estimated that if just two counties neighboring the park were
downgraded to class A, the counties' livestock producers might, over
several years, incur additional testing costs ranging from about
$169,000 to $536,000 per year and forgo income ranging from about
$156,000 to $741,000 per year.
--------------------
\7 Brucellosis in the Greater Yellowstone Area, National Research
Council (Washington, D.C.: National Academy Press, 1998), 186 pp.
LACK OF ORIGINAL DATA
SUBSTANTIALLY LIMITS
USEFULNESS OF ESTIMATED
NET BENEFITS
-------------------------------------------------------- Letter :4.0.3
According to the interagency team, because of court-imposed time
constraints, its contractor was given only several weeks to assess
the economic benefits associated with the alternatives presented in
the draft EIS. These time constraints were part of a settlement
agreement, approved by a federal district court, resolving a lawsuit
that Montana brought against the Park Service and APHIS in 1995.
Consequently, the contractor was unable to collect original data and
relied instead on published studies of grizzly bears and wolves to
approximate some of the benefits that would result from the various
bison management plans.\8 According to the contractor, the economic
data on grizzly bears and wolves represented the best available
information for estimating the benefits of the bison herd's
existence; that is, the amount of money individuals in the United
States would be willing to pay to acquire land to improve the habitat
and sustain the population of bison. The contractor chose the
grizzly bear and wolf for comparison with the bison because, in an
assessment of the preferences of visitors to Yellowstone National
Park, visitors indicated that among these three species, they most
often preferred viewing grizzly bears, then bison, and then wolves.
To approximate a low-value benefit for the existence of bison, the
contractor used an estimate of the dollar amount that individuals
would be willing to pay to ensure the existence of wolves.
Similarly, to approximate a high-value estimate, the contractor
used an estimate of the dollar amount people would be willing to pay
to preserve grizzly bears. In applying the data for grizzly bears
and wolves to bison, the contractor used professional judgment to
calibrate the original estimates. In addition, to derive the total
amount the U.S. population would be willing to pay to acquire
habitat and sustain the bison population, the contractor multiplied
the low- and high-value estimates for bison by the number of
households, about 75 million, in the United States. Consequently,
the contractor estimated that the amount of money the U.S.
population would be willing to pay under the preferred alternative
would range from about $10 million to about $147 million. The second
alternative, which would provide for acquiring a larger winter range
area than the preferred alternative, is estimated to provide somewhat
higher existence benefits, ranging from about $16 million to about
$223 million. By adding in the other benefits and subtracting the
estimated costs of implementing each alternative, the interagency
team derived the benefit and cost estimates shown in table 3. For
example, as indicated in table 3, the Interim Bison Management Plan
(the baseline) would provide the greatest net benefits ($0) under the
low-value scenario, while the second alternative would provide the
greatest net benefits ($153 million) under the high-value scenario.
Typically, in conducting a benefit-cost analysis, an economist will
provide information on the most likely (the mean) net benefit for
each alternative, as well as information on how the estimate could
change if actual events differed from key assumptions. This type of
information can give final decisionmakers greater confidence as to
which alternative is likely to provide the greatest net benefits to
society. However, because of the imprecision associated with
applying the data on grizzly bears and wolves to bison, the
interagency team's contractor did not estimate the most likely
values. Although the draft EIS acknowledges that these estimates are
subject to considerable uncertainty, the range of uncertainty is so
wide that it substantially limits the usefulness of the estimates.
Without more precise information, the public and the interagency
final decisionmakers may have difficulty assessing which alternative
would likely provide the greatest net benefits.
The economic analysis presented in the draft EIS was not used to
select the preferred alternative because the interagency
decisionmakers selected the preferred alternative before the analysis
was completed. However, the final decisionmakers will have access to
the analysis presented in the final EIS. Members of the interagency
team said they plan to improve the precision of the benefit estimates
in the final EIS by using bison-specific data that are currently
being collected. Improving the precision of these estimates will
enhance the usefulness of the economic information for the final
decision on how the Yellowstone bison will be managed in the future.
--------------------
\8 The Reintroduction of Gray Wolves to Yellowstone National Park
and Central Idaho, Final EIS, U.S. Department of the Interior
(1994) and Grizzly Bear Recovery in the Bitterroot Ecosystem, Draft
EIS, U.S. Department of the Interior (1997).
A MODIFIED PREFERRED
ALTERNATIVE IS CURRENTLY BEING
NEGOTIATED
------------------------------------------------------------ Letter :5
Given the lack of public support for the preferred alternative and
the additional research that was completed after the issuance of the
draft EIS, the interagency team is considering modifying the
preferred alternative for the final EIS. The team plans to publish
the final EIS in late 2000 and afterwards issue records of decision
on how the Yellowstone bison will be managed in the future.
From June 16 through November 3, 1998, the interagency team received
public comments on the draft EIS by letter and electronic mail and at
public meetings held in 13 cities across the United States. The team
received a total of 67,520 public comment documents containing
212,249 individual comments. The interagency team employed a
contractor to analyze the content of these comments and compile and
correlate similar comments into a format usable by the decisionmakers
and the interagency team. About 47,000 comments, or about 70 percent
of those received by the interagency team, opposed the draft EIS'
preferred alternative. The interagency team is currently determining
how the final EIS will be changed in response to these comments.
In addition to public comments, research that has become available
since the draft EIS was issued is being considered during the
development of the final EIS. This research includes a 1998 National
Research Council study that assessed the current state of knowledge
about brucellosis infection and transmission, made recommendations
for further research, and examined the implications of various
management options. In addition, research by the University of
Wyoming indicates that the brucellosis bacteria live in the
environment for a much shorter period than originally thought at the
time of year that cattle are moved back to public land used by bison
in the winter and early spring. Finally, the results of field tests
on a group of Yellowstone bison that were slaughtered this past
winter showed that, of those whose blood tested positive for
brucellosis, 86 percent tested negative in more extensive tissue
culture analyses.
The interagency team also pointed out that some concerns about bison
management have changed since the draft EIS was published. For
example, two phases of an agreement to acquire portions of the Royal
Teton Ranch, a 12,000-acre ranch adjacent to the north entrance of
the park, have been completed. This agreement, among the Forest
Service, the Rocky Mountain Elk Foundation, and the Church Universal
and Triumphant, involves the exchange or purchase of land and
easements. The Department of the Interior has also become a partner
in the project by contributing Land and Water Conservation Funds for
part of the acquisition. According to the interagency team, this
land provides a critical wildlife migration corridor and winter range
for many species, including bison.
In both May and July of 1999, the Park Service, APHIS, and the Forest
Service presented proposals to the Governor of Montana for modifying
the draft EIS' preferred alternative. In subsequent meetings,
facilitated by the Department of Justice, the three participating
federal agencies and the state have continued to negotiate the
specific elements of a modified preferred alternative that will be
acceptable to all of the parties and will address the concerns raised
in public comments.
On November 5, 1999, the federal agencies outlined their most recent
proposal to the state of Montana for a modified preferred alternative
to be included in the final EIS. This latest proposal emphasizes the
use of adaptive management in developing a long-term plan for bison
management. Adaptive management is a strategy that recognizes the
need for flexibility and allows for further modification of the bison
management plan if the results of the initial approach and/or future
research indicate a need for change. The federal agencies' latest
proposal for a modified preferred alternative includes, among others,
the following elements:
-- Bison population limits. The modified plan would increase the
overall limit on the bison population to 3,000 animals. This
limit could be adjusted, depending on the results of ongoing
studies of the park's carrying capacity, scheduled to be
completed in 2002-03. The draft EIS' preferred alternative
would have limited the bison population to 2,500 animals.
-- Bison vaccination. The modified alternative would phase in a
parkwide bison vaccination program. Initially, bison held in
capture facilities would be vaccinated when a safe vaccine
became availablea development expected by the winter of
2000-01. After a safe and effective mechanism was developed to
deliver a vaccine remotely (from a distance), all bison moving
out of the park in the West Yellowstone area would be
vaccinated. Such a delivery mechanism is expected to be ready
during the winter of 2002-03. The Park Service will not
vaccinate bison inside the park until a safe and effective bison
vaccine and a safe and effective remote delivery mechanism are
availablenow projected to be the winter of 2003-04. Montana
will not allow untested bison outside Yellowstone National Park
until the bison vaccination program has been initiated inside
the park. The untested bison outside the park would be managed
through the use of spatial and temporal risk management
approaches designed to prevent the transmission of disease.
Spatial (space) risk management involves keeping bison and
cattle physically separate by not allowing them to occupy the
same land at the same time. Temporal (time) risk management
separates the use of the same land by bison and cattle by a
period of time. The modified alternative would accelerate the
vaccination of bison. The draft EIS' preferred alternative
would not have allowed them to be vaccinated until all studies
of the vaccine's safety and effectiveness had been completed.
-- Bison management in the areas near the northern and western
boundaries of Yellowstone Park. The modified plan emphasizes a
regime, to be implemented immediately upon the plan's adoption,
that would manage risk with time and space. While the draft
EIS' preferred alternative proposed to separate bison and cattle
for variable periods of time only on the west side of the park,
the modified plan would ensure their separation in time and
space through the implementation of adaptive management steps.
These steps are tailored to land uses on the north and west
sides of the park that will change over time, as well as to the
status of the bison vaccination program. The modified plan
outlines steps to implement separation in space through the use
of management zones. Specifically, public land outside the park
would be divided into areas where bison would be subject to
different actions intended to limit their movement and enforce
boundaries. Separation in time would be maintained by hazing
bison back into the park and off land that cattle would occupy
on dates agreed to by the state and federal agencies. Any bison
that could not be moved by hazing would be captured and tested.
Bison testing positive for brucellosis would be sent to
slaughter, and those testing negative would be sent to
quarantine if a facility were available. Any bison that could
not be hazed back into the park by the agreed date would be
shot. Furthermore, under the most recent version of the
modified plan, cattle could not occupy public grazing land until
45 days after bison had ceased to occupy it. This 45-day period
of separation is based on APHIS' determination that the
bacterium that causes brucellosis would be highly unlikely to
survive in soil 45 days after the bison's departure.
-- Bison capture facilities. The modified proposal provides for
using the same three facilities to capture bison as the
preferred alternative. However, the modified proposal adds a
fourth facility, designed to prevent bison from leaving newly
acquired lands in the north. These facilities would be used to
capture bison when their numbers reached the agreed-upon limit
and when it was necessary to enforce the 45-day period of
separation between bison and cattle that the modified plan
proposes for both the north and west sides of the park.
-- Contingency plan for potential large movements of bison outside
park boundaries. The goal of the contingency plan is to provide
for a generally stable bison population by reducing the number
of bison killed outside the boundaries of Yellowstone National
Park while still preserving Montana's brucellosis-free
certification. The agencies would seek to reduce the number of
bison that would be shot or shipped to slaughter in the event
that extreme winter weather conditions, such as those that
occurred during the winter of 1996-97, caused large movements of
bison beyond the park boundaries. The agencies would implement
many of the contingency measures at the onset of winter so that,
if bison migrated from the park, the measures would be in place
and would provide maximum flexibility in reducing the number of
bison that the agencies needed to remove. Although the draft
EIS' preferred alternative addressed the movement of bison
outside the park, it did not establish a contingency plan for
minimizing the number of bison killed.
-- Cattle vaccination. Under the modified plan, Montana would
encourage the voluntary vaccination of cattle that graze in
areas outside the park where bison may range in the winter. If
100 percent of the cattle in these areas were not voluntarily
vaccinated by the fall of 2000, Montana would make vaccinations
mandatory, and the federal government would reimburse the state
for the direct cost of the vaccination. The draft EIS'
preferred alternative only encouraged the vaccination of cattle
inhabiting areas in Montana near the park.
-- Quarantine facility. The federal agencies would initiate a NEPA
analysis to determine the location, design, and operation of a
bison quarantine facility. APHIS would serve as the lead agency
in the design of the facility and would oversee its operation.
The facility would follow APHIS' quarantine protocol. Bison
that passed through the quarantine protocol could be transferred
to Indian reservations or other appropriate public lands. Bison
that tested negative for brucellosis would be sent to a
quarantine facility when (1) more than a fixed number of bison
occupied the northern and western management areas (expected to
be 100 in each), (2) the overall bison population was greater
than 3,000 animals, or (3) bison were being captured and tested
at the northern and western boundaries of the park to enforce
the 45-day period of separation between bison and cattle using
the same public lands in the northern and western areas of the
park. The draft EIS' preferred alternative did not propose that
APHIS would be the lead agency in the design of a quarantine
facility or that APHIS would oversee its operations.
-- Threats of state sanctions. If a state threatened to impose or
imposed sanctions on Montana for actions taken to conform with
the Interagency Bison Management Plan, APHIS would consult with
the state to convince its officials that such sanctions were not
necessary and were not supportable. If the state persisted and
imposed sanctions or refused to withdraw previously imposed
sanctions, APHIS would work with Montana to pursue all legal
remedies against that state, including seeking an injunction
against any such sanction. The draft EIS' preferred alternative
did not address the threat of other states' imposing sanctions
on Montana's cattle industry.
As of November 10, 1999, members of the interagency team from the
state and federal agencies said that negotiations on the latest
proposal for modifying the preferred alternative were ongoing. A new
bison management plan will not be completed until the final EIS is
published and the agencies issue records of decision.
AGENCY COMMENTS AND OUR
EVALUATION
------------------------------------------------------------ Letter :6
We provided copies of a draft of this report to the Department of
Agriculture, the Department of the Interior, and the state of Montana
for their review and comment. We received letters commenting on the
report from the Department of Agriculture's Forest Service, the
Department of the Interior, and the state of Montana. The Department
of Agriculture's Animal and Plant Health Inspection Service indicated
that it had no comments on the report.
Interior stated that the draft report accurately reflected the facts
surrounding the bison management issue and the ongoing planning
process. The Department also suggested technical clarifications to
the draft report that we incorporated as appropriate. The Forest
Service stated that the agency generally concurs and believes the
report accurately and fairly represents the information collected on
the environmental impact of the alternatives for managing bison.
Montana commented that the draft report was thorough and objective
but suggested that we either delete or update information on the
proposed modification of the preferred alternative. We agree with
the need to update information on the latest preferred alternative
and included information in our final report on the modification
proposed in November 1999. The agencies' and state's letters appear
in full in appendixes II (for the Department of Agriculture's Forest
Service), III (for the Department of the Interior) and IV (for the
state of Montana).
SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :7
To identify the key elements of each of the proposed plans for
managing the Yellowstone bison, we obtained and reviewed copies of
the draft EIS, the Interim Plan on Bison Management, and the
nongovernmental bison management plans. We also interviewed National
Park Service and Department of the Interior officials in Washington,
D.C. and in Yellowstone National Park; Forest Service officials in
Washington, D.C., and Gallatin National Forest; APHIS officials in
Washington, D.C., and the Bozeman field office; and officials from
the Montana Department of Livestock. We identified and interviewed
the authors of and substantive experts on the five nongovernmental
plans to learn about the development and objectives of the plans and
the management actions needed to implement them.
To identify the strengths and weaknesses of the economic analysis
used to support each plan, we used standard microeconomic principles
and the Water Resources Council's guidance for conducting economic
analysis. We interviewed the authors of the alternative plans about
the economic analyses presented in their plans. For the interagency
plan, we also interviewed the Park Service's economic consultant to
identify the analytical framework and the data and assumptions used
for the economic analysis presented in the draft EIS.
To determine the current status of efforts to issue the final EIS, we
obtained a copy of and analyzed the proposal to revise the draft EIS'
preferred alternative. We also interviewed headquarters officials at
the Department of the Interior, the National Park Service, and APHIS.
We conducted our review from March through November 1999 in
accordance with generally accepted government auditing standards.
---------------------------------------------------------- Letter :7.1
We are sending copies of this report to members of the Greater
Yellowstone area's congressional delegation: Senator Max Baucus of
Montana, Senator Conrad Burns of Montana, Senator Larry Craig of
Idaho, Senator Mike Crapo of Idaho, Senator Craig Thomas of Wyoming,
Senator Mike Enzi of Wyoming, Representative Rick Hill of Montana,
Representative Helen Chenoweth of Idaho, Representative Michael K.
Simpson of Idaho and Representative Barbara Cubin of Wyoming. We are
also sending copies of this report to the Honorable Bruce Babbitt,
Secretary of the Interior; the Honorable Robert Stanton, Director,
National Park Service; the Honorable Dan Glickman, Secretary of
Agriculture; the Honorable Mike Dombeck, Chief, Forest Service; the
Honorable Craig Reed, Administrator, Animal and Plant Health
Inspection Service; the Honorable Jacob Lew, Director, Office of
Management and Budget; the Honorable Marc Racicot, Governor of
Montana; the sponsors of the nongovernmental bison management plans;
and other interested parties. We will also make copies available to
others upon request.
If you have any questions or need additional information, please
contact me at (202) 512-3841. Key contributors to this report
include Timothy J. Guinane, John P. Scott, and Jim Yeager.
Barry T. Hill
Associate Director, Energy,
Resources, and Science Issues
COMPARISON OF THE KEY ELEMENTS OF
THE PROPOSED BISON MANAGEMENT
PLANS
=========================================================== Appendix I
1998 draft EIS'
Key alternative 7, the
element preferred alternative Bison Alternative Plan B Alternative 8 Citizens' Plan USAHA Plan
---------- ----------------------------- ---------------------- ---------------------- ---------------------------- ---------------------------- -----------------------------
Sponsor(s) Environmental impact The Fund for Animals; Written and submitted Fort Belknap Indian Greater Yellowstone U.S. Animal Health
statement (EIS) co-lead other organizations, by an independent Community of Montana. Coalition, Defenders of Association.
agencies: the Department of including the Humane wildlife biologist. Wildlife, Intertribal Bison
the Interior's National Park Society and the Earth Endorsed by Cooperative, National Parks
Service, the Department of Island Institute; and environmental, and Conservation
Agriculture's Forest Service, over 1,600 political, taxpayer, Association, National
and the state of Montana. The individuals. and Native American Wildlife Federation, and
Department of Agriculture's organizations, such as other organizations.
Animal and Plant Health the Montana Ecosystems
Inspection Service is a Defense Council, the
cooperating agency. Ecology Center, and
Taxpayers for Common
Sense.
Purpose --Maintain a wild, free- --Maintain a wild, --Maintain a wild, --Maintain a wild, free- --Maintain a wild, free- --Maintain a wild, free-
ranging population of bison. free-ranging free-ranging ranging population of ranging population of ranging population of bison.
--Address the risk of population of bison. population of bison. bison. bison. --Address the risk of
brucellosis transmission to --Address the risk of --Ensure that the --Address the risk of --Address the risk of brucellosis transmission to
protect the economic interest brucellosis Yellowstone bison do brucellosis transmission to brucellosis transmission to protect the economic interest
and viability of the transmission to not affect Montana's protect the economic protect the economic and viability of the
livestock industry in protect the economic brucellosis-free interest and viability of interest and viability of livestock industry in
Montana. interest and viability certification. the livestock industry in the livestock industry in Montana.
of the livestock --Protect the state Montana. Montana.
industry in Montana. against sanctions
imposed by other
states.
Objectives --Address bison population --Provide for a --Ensure that the --Protect and preserve the --Protect the largest free- --Meet the objectives set for
size and distribution; have naturally regulated, Yellowstone bison do bison as a free-ranging ranging bison herd in the the government's preferred
specific commitments relating protected bison not affect Montana's species of wildlife. United States. alternative with an emphasis
to the size of the bison population. brucellosis-free --Reaffirm the trust --Establish measures to on eradicating brucellosis
herd. --Restore Yellowstone certification. relationship between the protect private property and from bison and keeping
--Clearly define a boundary as a bison sanctuary. --Protect Montana from buffalo and the Indian livestock interests. exposed bison inside the
beyond which bison will not --Manage the risk of sanctions by other nations (tribes). --Manage Yellowstone as a park's boundaries.
be tolerated. brucellosis states. natural park.
--Address the risk to public transmission by Avoid the economic --Allow adequate habitat for
safety and the threat of emphasizing the active consequences wildlife while protecting
damage to private property management of cattle. associated with livestock from disease
posed by bison. --Manage bison like brucellosis. through separation.
--Commit to the eventual wildlife, not like --Manage risk in a --Manage bison to the
elimination of brucellosis in cattle. cost-effective and ecological carrying capacity
bison and other wildlife. --Protect Montana from reasonable way. of the park and special
--Protect livestock from the sanctions by other --Provide for wild, management areas.
risk of brucellosis states or the free-roaming --Give bison priority on
transmission. Department of populations of bison, public lands.
--Protect Montana from the Agriculture. maintained at levels
risk of a reduction in its consistent with the
brucellosis-free ecological carrying
certification. capacity of the
--At a minimum, maintain a Greater Yellowstone
viable population of wild area and of Montana,
bison in Yellowstone National wherever natural
Park, as defined in habitat exists for
biological, genetic, and them.
ecological terms.
--Base each alternative on
factual information, with the
recognition that the
scientific database is
changing.
--Recognize the need for
coordination in managing the
natural and cultural resource
values that are the
responsibility of the
signatory agencies.
Summary of Manage for a population of Allow bison to roam Adopt a cost- Allow bison to range freely Manage herd size to the Aim to totally eradicate
plan's 1,700 to 2,500 bison. freely and be effective approach to and retain their status as ecological carrying capacity brucellosis from the
overall Maintain the separation of regulated naturally. disease management by wildlife. Give bison of land both inside the park Yellowstone bison. Under
management bison and cattle. Use a Modify winter use addressing the priority over livestock in and within special phase I, reduce the number of
approach mixture of management tools management to restore underlying factors the use of all public lands management areas. Minimize bison testing positive
to meet the plan's natural regulation as that cause brucellosis outside the park. Make the disease transmission through through vaccination. Under
objectives, including the primary mechanism to be problematic. acquisition of land for separation, including phase II, capture and test
monitoring and hazing; for controlling Reduce the prevalence winter range and migration changes in cattle operations every bison within the park,
capture, testing, slaughter population. Alter of brucellosis in routes a priority. Assign on public lands and the slaughter those testing
or quarantine; vaccination of cattle operations on bison by nonintrusive, the highest priority to live acquisition of land or positive,and quarantine those
bison; acquisition of land or private and public remote vaccination. removals of bison through easements. Regulate herd testing negative.
easements from willing lands and require the Vaccinate and annually capture, testing, and sizes through public harvest
sellers north of the park; vaccination of cattle test the few cattle in quarantine. or live removal to
hunting, and agency shooting to reduce the risk of areas used by bison, quarantine for later
of bison. Encourage but not bacterial remove cattle from disposition to tribal or
require the vaccination of transmission. public lands used by other public lands.
cattle. Possibly change bison, and compensate
cattle grazing allotments ranchers who switch to
north of the park. no-risk operations.
Maintain bison
populations at
ecological carrying
capacities through
active management.
Use of Yes, on the north and west No. No. Yes, allow bison to use Yes, north and west of the No, on the west side. Limit
special sides of the park in Montana public lands outside the park in Montana, but keep the special management area
management park within broadly defined boundaries flexible, on the north side to the
areas special management areas. especially on west side Little Trail Creek/Eagle
public land. Creek area.
Areas Within the park or special Anywhere. Anywhere except on Within the park and broad Within the park. Manage Bison are confined and
where management areas. private property. special management areas. excess numbers in the managed in the park or in a
bison are special management area, small special management area
free to within flexible boundaries. on north side
range
Bison Manage herd within range of No set limit, Calculate the Establish population goals Establish ecological Limit the herd to a maximum
population 1,700 to 2,500 animals naturally regulated. ecological carrying for the herd on the basis of carrying capacities for the of 1,800 bison inside the
size capacity for bison in science, not politics, for park and special management park until an evaluation of
the Greater available habitat within and areas outside the park. the range's carrying capacity
Yellowstone area outside the park. is done.
(outside the park) and
manage bison to
maintain these
numbers.
Hunting On all public lands in No, prohibited. Hunting is one of the None. Yes, in special management Yes, in the Little Trail
special management areas if tools that could be areas, when the size of the Creek/Eagle Creek special
the Montana legislature used to limit the size herd reaches its upper management area if Montana
approves. of the bison herd to limit. approves hunting.
the ecological
carrying capacity of
land outside the park.
Winter Continue grooming roads for End grooming and Not addressed; Not addressed. Continue grooming roads for Plow more roads for access to
road snowmobiles. snowmobile use. considered a separate snowmobiles, but study their bison capture facilities.
grooming issue. impact and take action in
the future if warranted.
Hazing May be used to ensure that Use is generally May be used to keep May be used to move bison May be used if the The Park Service is
bison stay in special opposed but may be bison not classified from areas where they are population in an area is too responsible for hazing bison
management areas or move into acceptable if done as "low-risk" away not permitted. high or bison are on private back from the park's
the park 30 to 60 days before humanely at an from cattle when land where there is boundaries.
cattle occupy an area. appropriate time to owners have not potential for them to harm
move bison from areas changed to steer-only persons or property.
where they are operations.
unwelcome.
Facilities Three located as follows: (1) None. None. Within 18 months, construct Relocate outside the park to Nine facilities as follows:
to capture in the park at Stephens Creek facilities in appropriate regulate excess Stephens Creek on the north
bison (phase I) or north of park locations to capture bison. populationsone facility in and a new facility inside the
between Reese Creek and each special management area park on the west (phase I)
Yankee Jim Canyon (phase II) on the north and west sides and seven facilities
and west of the park (2) at of the park. throughout the park as
Duck Creek on private land described in alternative 6
and (3) at Horse Butte on (phase II).
public land .
Bison North side: Send to slaughter No testing or action. No action. Place in a quarantine Quarantine excess bison Return to the park or place
testing or quarantine if available. facility for eventual testing negative for live in a quarantine facility.
negative If population is low, hold relocation to tribal lands removal to tribal or other
for animals testing negative in coordination with the public lands.
brucellosi until spring. West side: Ship Intertribal Bison
s all to quarantine if Cooperative.
population is high or just
those that are pregnant if
population is lower; release
nonpregnant bison that test
negative to public lands,
using metal ear tags and
temporary visual markers to
indicate their status.
Bison Ship to slaughter. No testing or action. No action. Confine to a holding Not addressed; however, a Ship to slaughter or destroy
testing facility and notify tribal positive test would not and place carrion for use by
positive governments to use the result in removal unless the grizzly bears.
for animals to meet their needs. population was high.
brucellosi Where possible, use for
s research on brucellosis.
Monitoring Aerial and ground monitoring Continue agencies' Done by the Montana Not addressed. Expected to occur for use by Aerial and ground monitoring
of bison within and adjacent to the existing monitoring of Department of Fish, the proposed advisory group. within and adjacent to the
park. bison within and Wildlife and Parks for park.
adjacent to the park. bison as for other
species.
Quarantine Quarantine (1) all bison None. None. Quarantine animals that test Operate a facility away from Operate a facility within or
operations testing negative from the negative and are eligible the park and special adjacent to the park as soon
north capture facility and for live removal. management areas to reduce as possible rather than
(2) either all those testing its environmental impact; destroy bison that test
negative or only those modify the quarantine negative.
pregnant females testing protocol to make it more
negative from the west efficient and humane.
capture facility, depending
on the population.
Distributi After going through an APHIS- No animals should be No distribution. Work with tribal governments Transfer excess disease- Make bison available for
on of approved quarantine protocol, removed from the and the Intertribal Bison free bison to Native release outside the area if
excess bison could be (1) made ecosystem. Cooperative to implement a American tribes to they have successfully
live bison available to establish live removal relocation repopulate tribal lands or completed an APHIS-approved
populations on tribal lands option under the EIS' transfer such bison to other quarantine protocol.
or other appropriate public quarantine protocol. public lands where they
lands or (2) provided to would be accepted.
public institutions or
qualified recipients.
Control of Try hazing first; then hunt Avoid hazing unless it Use volunteers to haze Haze bison from private land Haze bison from private land Try to keep bison off private
bison on bison with the landowner's can be done humanely bison from private where they are not to avoid conflicts with lands. If they do get out of
private permission and remove at the at an appropriate time land upon request. permitted. human safety or property. the park and are unresponsive
lands landowner's request. Per to move bison from to hazing, shoot them at the
state law, the landowner can private lands where landowner's request.
also remove bison. they are unwelcome.
Land or Under phase II, acquire Acquire private None. Make the acquisition of Acquire key winter range Make no change in existing
easement additional winter range north grazing lands, if additional land from willing north and west of the park land use or ownership.
acquisitio of Reese Creek. available, as sellers for winter range and by purchasing land or
n additional winter migration routes a priority. easements from willing
range. sellers.
Changes in Make no changes. Mandate measures to Vaccinate all cattle Offer incentives to modify Provide incentives to modify Make no change, but encourage
private reduce risk: use and annually test livestock operations on the type, timing and vaccination and require
cattle public funds to modify herds where contact federal, state, or private location of cattle surveillance testing of
operations the type of cattle with bison is land so as to help maintain operations. cattle in high-risk areas.
operation, construct possible. a wild, free-ranging bison
fencing, and require herd.
vaccination and
testing.
Changes in Possibly change national Prohibit cattle Give bison preference In the use of public land, Change the type, timing, and Do not modify national forest
public forest grazing allotments grazing on affected over cattle on public give bison precedence over location of cattle grazing allotments.
cattle north of the park in phase public lands. The lands; remove cattle livestock that may remain on operations to accommodate
allotments II. Make no changes on the Forest Service could if there are the land under modified bison on public lands.
west side in either phase I provide alternative conflicts; limit permits that reduce or
or phase II. public lands. grazing permits to eliminate contact between
steer-only or other bison and livestock.
low-risk operations.
Surveillan Recommend testing of whole Federal and state Not addressed. Not addressed. Not addressed. Require testing of cattle in
ce testing herds within special agencies will use areas in near West
of cattle management areas if bison and testing in conjunction Yellowstone.
cattle intermingle. with fencing for
separation and
vaccination.
Cattle Encourage vaccination of all Require vaccination of Require vaccination of Vaccinate cattle at no Require vaccination within Encourage vaccination of
vaccinatio female calves within a 20- cattle. cattle where contact expense to the livestock and adjacent to the special female calves that may come
n mile radius of the park or with bison is producer. management areas. in contact with bison.
special management area. possible.
Bison Vaccinate bison at capture None. Vaccinate bison when a None. Allow vaccination of bison Immediately implement a calf
vaccinatio facilities when a safe and safe and effective in the special management and yearling vaccination
n effective vaccine is vaccine is available areas when a safe and program; vaccinate adult
available; vaccinate free- effective vaccine is bison with a reduced dose.
ranging bison remotely when available and can be
an effective delivery system administered with assurance
is also available. that elk will not reinfect
bison.
Reduction Negligible to minor decrease Not addressed. Not estimated. Not estimated. Not estimated. Under phase I, the number of
in the in the number of bison bison testing positive should
number of testing positive compared be reduced; under phase II,
bison with the results expected all bison testing positive
testing from the no action would be eliminated.
positive alternative.
for
brucellosi
s
Sponsor's Risk would be eliminated. Not addressed, but Risk would be managed Not estimated. Not estimated Risk would be eliminated
view of sponsors believe and reduced. under this plan.
risk to virtually all risk of
viability brucellosis
of state transmission would be
livestock eliminated.
industry
Extent of Highcapture, test, transfer None. Lowvaccination and Mediumcapture, test, and Medium--if the population Very highvaccinate, haze,
handling, to slaughter or quarantine some hazing. transfer bison testing level is high, test bison capture, test, and slaughter
manipulati facility; vaccination; negative to quarantine. Hold and transfer those testing or quarantine, mostly within
on of hunting. those testing positive and negative to quarantine. Also the park.
bison use for tribal needs. No harvest excess bison in
vaccination. special management areas. No
test and slaughter for
disease control.
Use of Yes, the phase I capture No, activities are No, with the possible No, activities are to be No, capture, testing, and Yes, capture, testing and
management facility on the north side is directed at cattle exception of located in special other activities are done quarantine facilities are
activities in the Stephens Creek area. outside the park. vaccination when management areas. only within the special located, and bison are
inside the Some hazing of bison is feasible. management areas and are not vaccinated, in the park, and
park allowed inside the park. visible to the public. park roads are plowed for
winter access.
Management None. None. None. Yes, meaningful consultation Establish an interagency, None.
changes with tribal governments and tribal, public advisory team
the Intertribal Bison as a communications tool to
Cooperative. They determine review conditions; continue
the distribution of live and cooperation; and make plans
harvested bison. for bison management.
Sponsor's Limited data suggest that Not addressed, but Not addressed. Not addressed. Would establish minimum Would not be an issue unless
view of genetic viability and eliminating nearly all numbers to maintain a wild, the population fell below 600
genetic diversity would not be human-caused mortality genetically diverse bison head. The population limit is
integrity limited if a population of would preserve the herd. set much higher.
more than 1,700 bison were diversity of bison.
maintained.
Cost to $1.8 million to $2.1 million, Not estimated, but Not estimated. Not estimated. Not estimated. Not estimated .
federal plus shared costs, estimated sponsor suggests that
government at $29.1 million to acquire this natural
land; costs to acquire regulation approach
easements and convert would be less
livestock operations not expensive than other
estimated. approaches.
Cost to $403,200 plus shared costs. Not estimated, but Not estimated. Not estimated. Not estimated. Not estimated.
state sponsor claims that
Montana's management
cost would be reduced.
Cost to No costs to livestock Not estimated, but the Not estimated. Not estimated. Not estimated, but includes Not estimated.
private operators for cattle private sector would a voluntary program to
sector vaccination or testing above be compensated for the compensate private property
the costs of the no action costs of mandated owners for damage caused by
alternative. changes. the natural movement of
bison.
Net The net present value range Not estimated because Not estimated. Not estimated. Not estimated. Not estimated.
benefits is estimated to be -$24.9 the plan is not
estimated million to +$112 million over intended to meet the
15 years, depending on the requirements of the
assumptions. National Environmental
Policy Act of 1969
(NEPA).
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Source: Interviews of and documents provided by the authors and/or
sponsors of the respective plans.
(See figure in printed edition.)Appendix II
COMMENTS FROM THE DEPARTMENT OF
AGRICULTURE'S FOREST SERVICE
=========================================================== Appendix I
(See figure in printed edition.)Appendix III
COMMENTS FROM THE DEPARTMENT OF
THE INTERIOR
=========================================================== Appendix I
(See figure in printed edition.)
(See figure in printed edition.)Appendix IV
COMMENTS FROM THE STATE OF MONTANA
=========================================================== Appendix I
*** End of document. ***