A Public Comment
by Glenn Hockett, Volunteer President, Gallatin Wildlife Association
Regarding the December 2011 Adaptive Management Adjustments to the Interagency Bison Management Plan Draft Joint Environmental Assessment
As submitted to Montana Fish, Wildlife & Parks, and to Montana Department of Livestock
Jan. 10, 2012
Montana Fish, Wildlife & Parks
Montana Department of Livestock
Sent Via Email: IBMPadjustments@mt.gov
Subject: Comment to the December 2011 Adaptive Management Adjustments to the Interagency Bison Management Plan Draft Joint Environmental Assessment
The Gallatin Wildlife Association (GWA) is a non-profit wildlife conservation organization representing concerned hunters and anglers in Southwest Montana and elsewhere. The GWA is an affiliate of the Montana Wildlife Federation, which is an affiliate of the National Wildlife Federation. We are volunteers working to protect habitat so fish and wildlife populations and hunting and fishing opportunities can be conserved for future generations. GWA supports sustainable management of fish and wildlife populations through fair chase regulation of public hunting and fishing opportunities. Please consider these comments to the draft joint EA regarding adaptive management adjustments to the IBMP.
First we appreciate the Montana Fish, Wildlife & Parks and Department of Livestock working together to allow bison access to additional habitat within the Greater Yellowstone Area while addressing the reasonable concerns of local landowners. We continue to contend there are many opportunities to improve bison conservation practices on both public and private lands in southwest Montana by incorporating additional minimal conflict habitat solutions as the foundation. We also suggest public hunting is the best long term population management alternative that also recognizes bison as a valued, native big game species. However, there is a lack of analysis and public disclosure in the EA on the current conservation status of wild bison in Montana. Are there any viable and sustainable year round populations of free-ranging wild bison anyway in Montana? We contend it is critical that FWP and DOL work together to establish viable year round populations of this magnificent native wild animal in Montana before we embark on intensive measures aimed at controlling bison numbers.
In this particular case, we support the adjustment to allow bison access to additional lands north of Yellowstone Park, both on public and private lands where conflicts are minimal. This is a principle we hope all IBMP partners will enthusiastically embrace and adhere to in the future. And while we support the installation of the bison/cattle guard and drift fence at the mouth of Yankee Jim Canyon to specifically influence bison movements to areas of less conflict we do not support the failed concepts of merely expanding zone 2 (an area of limited time, space and numbers for bison in SW Montana) and maintaining zone 3, which declares all other lands beyond zone 2 off limits to bison. Perpetuation of the zone 3 concept or a shoot-on-sight drop dead zone for bison regardless of landowner tolerance or degree of conflict is failed policy and unacceptable.
For example, we see no reason for any National Forest Service public lands, FWP Wildlife Management Areas (such as the Dome Mountain WMA in this area) or other public lands (BLM, DNRC, USFWS, etc.) to be off limits to public trust bison at any time. In fact, Mary Erickson Supervisor for the Gallatin and Custer National Forests has said from a Forest Service perspective she sees no reason that wild bison should be prevented from accessing National Forest Service Lands (Personal Communication with Mary Erickson). It is indeed part of the U.S. Forest Service mission and legal mandate to provide habitat for viable populations of public fish and wildlife (see the National Forest Management Act). As well, we contend it is well established in law that wildlife generally comes with the land and private landowners also have a responsibility to allow for free ranging wildlife within reason (State ex rel. Sackman v. State Fish & Game Comm’n, 151 Mont. 45, 438 P.2d 663 (1968)).
However, we recognize bison provide a significant management challenge for the FWP and DOL as well as private landowners. In the particular case of bison in the Greater Yellowstone Area the EA should mention that for those private landowners concerned about bison on their property and threatening their livestock, MCA 81-2-121 empowers them or their agent to take said bison if their concerns are not addressed in a timely fashion by the DOL. We believe this principle – addressing specific points of conflict with bison and livestock on private lands (or public safety issues where they exist) - is a much better policy/barometer to guide the need for agency intervention. Thus, we support the concept as proposed/applied in the draft EA (top of page 6) to address specific potential bison conflicts associated with the two small year round cattle operations and specific public safety/private property concerns such that private landowner-bison conflicts are minimized.
In contrast, we do not support the arbitrary and overreaching drop dead line for bison as proposed in the draft EA on page 4 (first bullet point) and as outlined on the map on page 13 (Map #2). Nor do we support the arbitrary haze back date of May 1 as outlined on the top of page 6. Both of these proposals (arbitrary drop dead line and haze back date) perpetuate the expensive and failed policies of zone 2 & 3 which prevents bison from being conserved, managed and respected like elk as a valued big game species, native year round residents and free-ranging wildlife in Montana. Abandoning the zone 2 & 3 concepts is warranted because of new information and changed circumstances since 2000. The agencies should consider all the new information and circumstances while considering a change in management like these adaptations, because it calls into question some basic premises of the IBMP itself and whether habitat and tolerance should be limited at all, in particular on public lands.
Furthermore, the agencies have learned that some significant private landowners willingly embrace and would welcome bison as a valuable asset on their land. A case in point in this area is the 5,000 acre Dome Mountain Ranch, which runs no cows and lies outside the proposed bison habitat expansion area outlined in the draft EA (Map #2, page 13). This private landowner currently protects and conserves critical big game habitat for elk and other wildlife and abuts thousands of acres of both Gallatin National Forest and Dome Mountain WMA public lands, which are also outside the current habitat expansion area. All these lands, both public and private provide a huge opportunity for conflict-free habitat for free-ranging bison and subsequent hunting opportunity, which the draft EA fails to recognize.
Jim Klyap the ranch manager for the Dome Mountain Ranch publicly testified at the November 30th 2011 IBMP meeting about his desire to see bison managed as wildlife across a landscape that includes their private property. As well, these lands were recognized as important habitat areas for bison by the Bison Citizens’ Working Group. Specific suggestions regarding the Dome Mountain WMA, Dome Mountain Ranch and the surrounding area are addressed in the consensus recommendations provided to the IBMP partners at the November 30, 2011 meeting at Chico (page 11, #3cii). Furthermore, lethal removal by government agents was discussed only as a last resort within the BCWG consensus recommendations (page 7, last sentence of #3). Thus, we disagree with perpetuating the concept of a drop dead line for bison in the face of this local input and knowledge. We suggest the BCWG consensus recommendations be considered official comment to this draft EA as well as any other official IBMP agency partner work related to bison management in the future (copy attached).
This leads us to the next important point regarding capturing, testing, hauling, confining and feeding bison in government pens as proposed in the second bullet point on page 4 of the draft EA. This is quite simply a terrible idea. Imagine applying that concept to elk, mule deer, antelope, grizzly bears or other wildlife migrating into Montana from Yellowstone National Park. In our opinion, that flies directly in the face of sound wildlife habitat and population management principles, as well as one of the major goals of the IBMP, which is to provide habitat for wild free-ranging GYA bison. Furthermore, the perceived need by the agencies to capture, test, haul, confine and feed bison “as necessary” perpetuates the largely failed IBMP concepts of zone 2 and 3, which artificially and overwhelmingly limits the time, numbers and habitat available for bison in southwest Montana. Such practices also dramatically increase costs, stress animals, create dependence on human interventions, facilitate transmission of diseases (Smith 2012) and weaken or replace natural selection that should be operating to maintain wildness in our bison.
We suggest if any IBMP partner will not allow or encourage bison movements to habitat with minimal conflicts that any bison captured at Stephens Creek or other IBMP sanctioned capture facilities be trans-located ASAP to historic habitat within the Upper Gallatin watershed or other suitable habitat within the Designated Surveillance Area within southwest Montana. Again, we refer you to the November 30th 2011 consensus recommendations of the BCWG that encourage the movement of bison, if necessary, “to nearby appropriate available lands” (page 8, #6b) including reviewing the opportunities for bison in the Upper Gallatin (page 11, #3di) and which discourage “the artificial concentration of animals (elk or bison) that may be exacerbating transmission” (page 4, #7). And on page 10 under Guiding Principles, f) “We believe the agencies should acknowledge their responsibility to allow bison on State and Federal lands managed as wildlife habitat” and g) “We believe that feed grounds are not legitimate alternatives to wildlife habitat.”
In this regard, the negative impacts of capturing, hauling, confining and feeding additional bison in Montana were not adequately reviewed in the draft EA. These include but are not limited to costs of the operation, loss of hunting and viewing opportunity, increased human induced stress, domestication, habituation and dependence on human handling as well as increased risk of disease transmission beyond just brucellosis. Thus, we do not believe the EA has adequately analyzed the negative aspects of this part of the proposed action or adequately reviewed the positive habitat alternatives that exist, including translocation and reintroduction to historic bison habitat in the Upper Gallatin both inside and outside the Park. The EA also fails to adequately review the costs, both to tax payers and the environment, of the status quo situation.
Once again, we appreciate the FWP and DOL working together to provide additional areas for bison in southwest Montana while addressing the reasonable concerns of local landowners and other citizens. We see this proposal as a step in the right direction, but we encourage both agencies to incorporate some of the suggestions provided here into the final EA and decision.
Glenn Hockett, Volunteer President, Gallatin Wildlife Association
Smith, B.L. 2012. Where the elk roam - conservation and biopolitics of our national elk herd. Lyon Press. 266 pp.