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

******************************************************************
** This file contains an ASCII representation of the text of a  **
** GAO report.  Delineations within the text indicating chapter **
** titles, headings, and bullets are preserved.  Major          **
** divisions and subdivisions of the text, such as Chapters,    **
** Sections, and Appendixes, are identified by double and       **
** single lines.  The numbers on the right end of these lines   **
** indicate the position of each of the subsections in the      **
** document outline.  These numbers do NOT correspond with the  **
** page numbers of the printed product.                         **
**                                                              **
** No attempt has been made to display graphic images, although **
** figure captions are reproduced.  Tables are included, but    **
** may not resemble those in the printed version.               **
**                                                              **
** Please see the PDF (Portable Document Format) file, when     **
** available, for a complete electronic file of the printed     **
** document's contents.                                         **
**                                                              **
** A printed copy of this report may be obtained from the GAO   **
** Document Distribution Center.  For further details, please   **
** send an e-mail message to:                                   **
**                                                              **
**                                            **
**                                                              **
** with the message 'info' in the body.                         **
******************************************************************

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. ***