[CH] Last Chance for Yellowstone's Wild Buffalo--Support Plan B
Meghan Fay (meghan@wildrockies.org)
Thu, 23 Jul 1998 10:46:04 -0600
We need some intelligent, well thought out comments sent in.
Thanks- sg
The Ecology Center, Inc.
801 Sherwood, Suite B
Missoula, MT 59802
(406) 728-5733
(406) 728-9432 fax
ecocenter@wildrockies.org
Ecology Center Position Paper on the DEIS for Buffalo Management
July 22, 1998
Dear Friends of the Buffalo:
The Ecology Center, through its analysis of the Interagency Bison
Management Plan for the State of Montana and Yellowstone National Park
(released June 5), has concluded that the DEIS is fatally flawed.
Unfortunately, the lead agencies (State of Montana, US Forest Service,
National Park Service and the Animal Plant and Health Inspection Service
[APHIS], a cooperating agency), chose to prefer a harsh management plan
that jeopardizes the buffalo.
First off, our criticism centers around basic issues of noncompliance with
NEPA:
* the DEIS's failure to properly address purpose and need;
* lack of a true "no-action alternative";
* lack of presentation of the full range of reasonable alternatives.
The DEIS's alternatives all are unacceptable because they all:
* restrict buffalo from their traditional habitat and winter range;
* contain extreme management techniques that ultimately will result in the
domestication of this herd;
* serve to placate the cattle industry's single-minded drive to decimate
the buffalo--an animal they see as symbolic of everything wrong with the
federal government.
Our criticisms extend to other issues:
* the plan's inhumane treatment of buffalo--treating them as livestock, not
wildlife;
* expense --the DEIS throws millions of dollars at a problem, that could be
addressed by much more cost effective means, created by the cattle, and
will further grease the "welfare cowboys'" pockets at the expense of the
buffalo and the taxpayer;
* lack of conclusive research surrounding the brucellosis issue. There has
been no risk assessment or cost benefit analysis completed by the DEIS
Inter-Agency Team.
* impacts on threatened, endangered, and sensitive species, and other wildlife;
Please look through the following material that expands on our criticisms
of the DEIS. Our hope is that the DEIS's authors will return to the
drawing board and write a final EIS and an Alternative that the public will
support, and the courts uphold--a Plan that puts the interests of the
buffalo first. We currently support the development of an Alternative that
incorporates the elements of Plan B, the Buffalo's Alternative. This
Alternative is not included in the DEIS but is in compliance with the
purpose and need of the DEIS unlike the other alternatives.
We need all the support we can get to ensure that the future of the
Yellowstone buffalo will remain the wild free-ranging herd for generations
to come.
Sincerely,
Meghan Fay
Ecosystem Defense
Ecology Center
meghan@wildrockies.org
Analysis of the DEIS
DEIS's Failure to Properly Address Purpose and Need
If the purpose of DEIS is to "address the risk of the brucellosis
transmission," then the agencies first need to stop focusing on buffalo and
address all species that carry this disease. The actions that the DEIS
takes to address the risk of brucellosis does not fit the purpose
statement. The actual risk of brucellosis is scientifically unknown. The
DEIS also plans for strict control over the buffalo in all alternatives,
using hazing, marking, capture and quarantine facilities, and
inoculation--all management techniques at odds with the DEIS's stated
purpose of "maintaining a wild bison herd." The inter-agency team even
defined "wild bison herd" as one that is not routinely handled by humans.
This goes against management techniques which the government proposes.
Lack of No-Action Alternative
The no-action alternative, which basically implements the Interim Bison
Management Plan (revised in 1996), is not a true no-action alternative.
The Interim Plan was responsible for the death of over 1,084 buffalo during
the winter of 1996-97, in addition to natural deaths. The winter of
1988-89 also proved to be an unfavorable year for buffalo with a death toll
of 569. 1994-95 and 1995-1996 followed with a total of 860 buffalo killed.
Further use of this plan only would slaughter more and more buffalo each
year. The proposed no-action alternative does not uphold the purpose and
need of this DEIS, and does not offer the public a true no-action
alternative. A true no-action alternative would allow buffalo to occupy
traditional grazing land undisturbed by agency actions.
Buffalo Management
Buffalo have always roamed Yellowstone National Park undisturbed, and this
is largest and oldest free-ranging population of buffalo in the United
States. The Montana Department of Livestock (DOL) has been the main
authority in charge of the management of the Yellowstone buffalo for too
long. From the management techniques that the DOL uses, the buffalo have
been captured, corralled, shocked with cattle prongs, and loaded on trucks
to be taken to slaughter houses. This inhumane treatment causes injuries
to the buffalo and sometimes death while being handled and transported.
Continuing the DOL's management of buffalo will eventually domesticate
them, killing off the oldest remaining populations of wild buffalo. The
Yellowstone buffalo are wildlife and should be treated like all other
wildlife in the Greater Yellowstone Ecosystem (GYE). The DEIS states that
in each alternative the buffalo would be continued to be managed by the
DOL, a serious conflict of interest. The management needs to be turned
back over to the Montana Department of Fish, Wildlife, and Parks. The
buffalo need to be treated and classified as wildlife in the state of
Montana. Buffalo are NOT cattle.
The DEIS must look at plans that have minimal impacts on buffalo and other
wildlife. If the Yellowstone buffalo are to remain a dynamic population,
then protective measures need to be taken that will ensure that the herd's
wildness is protected.
Quarantining Buffalo
The Inter-Agency Buffalo Management Team thinks that the quarantine of
Yellowstone Buffalo will only affect "individual buffalo." Not true--the
whole buffalo herd would be affected if quarantine is approved. "By
quarantining, family members will be separated. Social structures will be
destroyed or severely disrupted. Natural patterns of land use may be
broken. And, knowledge that is normally passed on from generation to
generation within the herd may be lost," states Virginia Ravndal, wildlife
biologist. Some buffalo would be held in quarantine for up to four years,
breaking their wild spirit. The State of Montana claims that the
quarantine will be one of the disease management tools. The real purpose
of quarantining the Yellowstone buffalo is to ensure that buffalo do not
roam free so they won't cause problems for livestock grazing on public
lands bordering the park. The quarantine facilities used would be nothing
more than a feed lot.
Definition of Risk
The DEIS claims that because the Yellowstone buffalo carry brucellosis,
cattle are at risk of contracting the disease. The DEIS presents no
conclusive scientific research that determines exactly what the risk is,
and there haven't been any documented cases of transmission between cattle
and buffalo in the wild. How can the agencies manage the risk of disease
transmission when they don't even know what level of risk, if any, there
is.
All the management tools in each alternative have not been approved yet by
the agencies and never may be. The DEIS assumes that these actions will be
approved. Quarantine facilities require that an Environmental Assessment
be released for public comment, this would be delayed of course (it took
the Inter-Agency eight years to put out the DEIS).
Effects on Endangered, Threatened, Sensitive, and other Wildlife Species
The DEIS states that the preferred alternative would have adverse impacts
on buffalo, as well as wildlife species including the grizzly bear and gray
wolf. The Stephens Creek buffalo capture facility, located at the northern
entrance to Yellowstone National Park, already has caused adverse impacts
to the pronghorn antelope population, blocking migration patterns and
causing confusion when they flee from predators. This facility would still
be used in the preferred alternative, causing further disturbances in the
pronghorn antelope population.
The methods for keeping buffalo in the designated special management areas
(SMA's) would include hazing by the use of helicopters, cracker barrels, or
horseback. The use of helicopter hazing this last spring violated bald
eagle closure areas, and nesting areas were disturbed. These methods have
and will impact bald eagles and other endangered, threatened, or sensitive
species.
If Alternative 6 was used by the agencies, there would be construction of a
capture/quarantine facility in a trumpeter swan nesting area. The DEIS
claims that "this species may be affected by the location and operation of
buffalo management facilities..." Trumpeter swans are a sensitive species,
and there has been a decrease in population due to the amount of habitat
available to these birds. There would be a disturbance of habitat and the
agencies should not risk putting these birds under stress by taking their
critical habitat.
If the Inter-agency DEIS team truly believes that their plan would be
likely to adversely affect the grizzly bear, then they should request a
formal consultation from the US Fish and Wildlife Services. The proposed
buffalo management project is located within the Greater Bear Recovery
Zone. The area is located almost entirely within management area
Management Situation 1 (MS1), which contains grizzly population centers.
"MS1 are areas key to the survival of grizzlies where seasonal and year
long activity, under natural, free-ranging conditions... [containing]
habitat components needed for the survival and recovery of the species or a
segment of its population." This statement in the DEIS does not justify
how the inter-agency team is able to go on with any of the proposed plans
when grizzly bear habitat is being disrupted.
The potential land acquisition, exchange and conservation easement package
has been jointly developed by the Rocky Mountain Elk Foundation, the Forest
Service, and the Church Universal and Triumphant. This area proposed for
exchange is located near the Northern entrance to Yellowstone National
Park. The Forest Service would give the Church Universal and Triumphant
1,000 acres in exchange for 1,850 acres of conservation easement property.
The area that the Forest Service is considering for exchange is located
next to Mol Heron Creek, which is prime grizzly bear habitat. This land
swap will destroy critical habitat for the grizzly bears that make the
Greater Yellowstone Ecosystem their home.
What about the "Citizen's" Alternative?
Management techniques that the DEIS mandates would domesticate the buffalo
and cause genetic loss to the herd. Alternative 3 in the DEIS, known as
the "citizen's alternative," was developed by representatives from hunting
and livestock interests, with input from a few conservation groups and the
Inter Tribal Buffalo Cooperative (a tribal organization concerned with
repopulating buffalo herds on tribal lands). This "citizen's alternative"
is a combination of capture, test, slaughter, quarantine, creation of
"special management areas", and hunting--all management techniques at odds
with the purpose of action "to maintain a wild, free-ranging population of
buffalo."
The agencies' preferred alternative states that it "involves many unknowns
and assumptions about future conditions and available tools to manage the
buffalo population." This "preferred alternative" makes it difficult to
understand exactly what kind of management operations could take place.
Both of these plans are not acceptable and would be worse than the current
Interim Buffalo Management Plan. All the management plans in the DEIS
would put a population limit on the amount of buffalo allowed in
Yellowstone National Park. The purpose of the DEIS was not to decide
population limits, and this type of a management tool will not ensure that
the buffalo are a wild free-ranging population. This population cap
presently is not used in the Buffalo Interim Plan, so the effects are
unknown, but would prove to be deadly.
The Welfare Cowboy
"The federal government charges the bargain rate of $1.35 per animal unit
month, as opposed to $15 for grazing on nearby private lands. The
remainder of the costs to administer the grazing program are borne by
federal taxpayers," states Christian Sinderman with Taxpayers for Common
Sense. He also goes on to add, "This frank assessment leads to questions
about why the government is spending millions slaughtering wildlife to
protect subsidized cattle that are exposed to little risk...taxpayers pay
to herd and corral wildlife, while domestic cattle enjoy their subsidized
home on the range."
Use of Inappropriate Management Tools
The management techniques mentioned below are used in the various
alternatives in the DEIS. We think that the following management tools are
unnecessary or unethical when used on buffalo:
* quarantine facilities--buffalo would be kept in facilities for up to four
years and then hopefully released to designated tribal members;
* visual impacts--buffalo would be tagged and marked with a peroxide strip;
* capture facilities--buffalo would be lured with hay to the facility and
hauled off to slaughter houses for the sale of the meat, hides, heads, etc.
The revenue from this would go back to the DOL;
* hazing--the use of cracker barrels (shooting firecrackers out of a rifle)
and helicopters would be used to move buffalo long distances in a short
amount of time. Used mostly during spring time, this has an adverse impact
on pregnant females that are ready to birth. Disturbs grizzly bears in the
spring when they are emerging from hibernation;
* hunting--there is no such thing as a "fair chase" buffalo hunt. Hunting
is not the issue here;
* population control--the amount of buffalo in Yellowstone National Park
alone would be limited to an arbitrary number far below the natural
carrying capacity, threatening the genetic diversity of the herd;
* adverse impacts on wildlife--this includes all endangered, threatened, or
sensitive species: grizzly bears, wolves, ungulates, bald eagles,
trumpeter swans.
What can we do?
Support Plan B, the Buffalo's Alternative
The Ecology Center supports Plan B, the Buffalo's Alternative. Plan B is a
biologist's alternative that preserves the genetic diversity of the herd,
treats them as wildlife, puts them under the management of wildlife
experts, and gives the buffalo priority over cattle on public lands. This
plan will ensure that the future of the herd as the nation's last remaining
free-roaming herd is not put in jeopardy. This is not just a plan to
compromise and watch the cattle industry once again win the battle over
wildlife. Plan B:
* obviates any killing or confining of buffalo.
* allows for buffalo to roam freely in the Greater Yellowstone Ecosystem.
* does not limit the size or movement of the buffalo herd.
* does not accept that the livestock industry has the expertise or the
directive to manage the nation's wildlife-Buffalo.
* is based on science, not politics.
* advocates scientific risk management.
* respects the cultural concerns of Native Americans with strong ties to
buffalo.
* insists on taking only those actions demonstrated to be cost-effective.
* ensures that buffalo receive preference over livestock on public lands.
If conflict exist between wildlife and livestock on these lands, remove
livestock, not buffalo, from these areas.
* modifies Montana's "zero tolerance" policy to one more consistent with
modern disease management, i.e., adopt scientifically-based levels of risk.
**Please contact us if you would like a complete copy of Plan B or
information to distribute on Plan B**
**Check out the website at: http://www.wildrockies.org/PlanB/
**Send your written comments on the DEIS that will be accepted until
October 16, 1998. Request a summary of the DEIS to Sarah Bransom,
Interagency Bison Management Plan, DSC-RP, P.O. Box 25287, Denver, CO
80225-0287 (303)969-2310. Also submit your comments on line and view a
summary of the DEIS at: http://www.nps.gov/planning/yell/eis/summary.htm
Talking Points
… Allow bison to roam free
… This is the largest and longest free-roaming buffalo herd in North America
… Allow buffalo to occupy their traditional winter ranges outside Yellowstone
… No quarantine facilities
… No Special Management Areas (SMAs)
… Manage brucellosis, not buffalo
… Vaccinate cattle first.
… Study brucellosis in all Greater Yellowstone Ecosystem wildlife populations
… Accept scientifically based risk-management of brucellosis instead of
zero tolerence and eradication
… Allow natural processess to control herd size
… No artificial population caps
… Hunting is not necessary
… Treat buffalo like wildlife, not cattle
… Buffalo have complex social and family structures
… Traditional knowledge of migration and winter feeding grounds are lost
when buffalo are confined
… Shift management of buffalo in Montana from the Department of Livestock
to the Department of Fish Wildlife and Parks
… Give preference to buffalo over cattle on public grazing lands outside
Yellowstone.
… Acquire critical buffalo winter range
… manage existing grazing allotments for wildlife, not cattle
… Redo the DEIS, or issue a Supplemental EIS
… Its actions do not follow its purpose and need
… has flawed assumptions
… does not have a true no-action alternative
… does not have a full range of alternatives
… The management tools proposed in the DEIS would domesticate the
Yellowstone Buffalo.
meghan fay
p.o. box 7941
missoula, montana 59807
(406)327-1209 phone/fax
meghan@wildrockies.org
Stop the slaughter of the Yellowstone Buffalo,
submit your comments on the DEIS now!!
Sign on to the BUFFALO ALTERNATIVE
http://www.wildrockies.org/PlanB/