T h e B u f f a l o P e o p l e


When you mix livestock with wildlife, you end up treating wildlife like livestock.

Lethal removal of migrating wild bison by the Interagency Bison Management Plan is causing irreparable genetic harm to this historic herd.

Wild bison are caught in an extinction vortex.

A PICTORIAL HISTORY OF BISON from the Old World to the New, including a view of Yellowstone National Park few visitors see.

A MIGRATING WILD BISON plows his way through the snow. To escape the deep snow packs that bury the grass, he is headed for the lower altitudes for forage. He has a big surprise awaiting him.

This herd is rare and distinct behaviorally, genetically and historically, being the only bison herd in the nation that is wild, still migrates, has not been extirpated and has no cattle genes. This should qualify members of the herd as an endangered species, but so far has not.

See 90-Day finding on a petition to list the Yellowstone National Park bison herd as endangered.




December 20, 2000

U.S. Department of the Interior
National Park Service

U.S. Department of Agriculture
U.S. Forest Service
Animal and Plant Health Inspection Service

THE BIG SURPRISE for wild bison. This legal document authorizes the state of Montana and two federal agencies to restrict a bison's movements outside the park by lethal control, hazing or capture, making them the only animals that are confined to the park. The Bison Management Plan is the result of a lawsuit filed by the state of Montana in 1995 challenging the Department of Interior's and the NPS's management of bison because it allegedly "causes diseased and disease-exposed bison to enter the state of Montana," which it claimed could spread brucellosis to cattle, revoking Montana's brucellosis-free status.

ZERO TOLERANCE for bison movement north of Gardiner Basin toward Paradise Valley is the proposed rule, an adjustment to the plan above. Leave the basin--demarked by the red dotted line on the map above--and bison will be immediately removed lethally. Gardiner Basin is less restrictive. However, Gardiner Basin's zones and corridors make movement so regulated that lethal removal is highly probable within this supposedly more "bison tolerant" area.

"IT'S A NO-SECOND-CHANCES PLAN, so there's no herd memory of getting out," Christian Mackay, executive director of the Montana Department of Livestock said, at left. The agency's stated objective is to lethally select out from this wild species those animals expressing the instinct to migrate. In the name of brucellosis mitigation, the new plan also involves increased use of capture facilities, an environment that promotes rather than mitigates brucellosis.

Bison, along with other megafauna and early
man, came here over
10,000 years ago.

HOW IT ALL BEGAN--Early man along with numerous species of animals, including megafauna such as bison, migrated from the Old World to the New World over the Bering Land Bridge when the ice-sheet began to melt. About this time, a mass extinction of megafauna species began.

WHAT IS THE LARGEST MEGAFAUNA species in North America to survive this great extinction, called the Holocene extinction? The American bison. After being on earth millions of years, mammoths became extinct 10,000 years ago, possibly due to hunters pouring into America after the ice age. Along with them giant species of beavers, sloths, bears, lions, condors, saber-toothed cats, horses and mastodons also went extinct here.

FOUND AT GARDINER, Montana, during the construction of the post office in the 1950s is this obsidian projectile point dating from approximately 11,000 years ago, made by Paleo-Indians of the Clovis culture.

THE IDENTITY OF EARLY MAN AND BISON appears to be fused in this petroglyph resembling a buffalo-headed man scratched thousands of years ago on sandstone at Legend Rock in the Greater Yellowstone Ecosystem, Thermopolis, Wyoming. "One carved figure includes a feature common at the site, a head topped by a "U" shape, possibly the horns of a spirit combining man and beast," notes the Wall Street Journal.

BISON'S IMPORTANCE to early man is also evident in this petroglyph of a hunter and a bison drawn on a canyon wall in the Horseshoe Canyon Unit, Maze District, Canyonlands National Park, Utah.

MORE THAN 30,000 YEARS AGO cavemen drew this running bison on the walls of Chauvet Cave, France. Bison came to America from the Old World about 10,000 years ago across the Bering Land Bridge.

DOMESTIC CATTLE'S ANCESTORS, called Aurochs, are now extinct. They were huge wild cattle that inhabited Europe, Asia and North Africa. The last one died in Poland in 1627. This drawing was found in the Chauvet Caves. Selective breeding over the years left us with only tame, un-wild survivors, while their wild ancestors were drawn into an extinction vortex.

PAINTED ON LIMESTONE 13,000 YEARS AGO in the Lascaux Caves, France, is the drawing of a human with a bird head and a bird-headed stick, lying by a wounded and disemboweled bison, a spear laying across its hindquarters. This is one of the first drawings of a human being.

Following the instinct
of migration means hazing, capture or death for bison.

HEADING OUT, wild bison often leave the park through the north entrance, which serves as a "Checkpoint Charlie" for the animals. The park's man-bade boundary is unobserved by a bison's migratory instinct. Unknown to the bison, they are headed into killing fields, zones established for their lethal removal because of a perceived brucellosis risk. See videos from various perspectives: Errol Rice, executive vice president, Montana Stock Growers Association and two Buffalo Field Campaign volunteers Goodshield Aguilar and Andrea Abrams.

KILLING FIELDS--A pair of bison graze in Gardiner Basin, wild bison's historic winter grounds and spring calving range. Under the plan, some bison are allowed here as long as they keep within various zones. Progressing from zone one to zone three ends up with their lethal removal. A recent modification of that plan allows them additional movement within a restricted corridor, but wander off, which many do, and such animals are also subject to slaughter. Even if bison remain in the right zone, they must leave by May 1 and go back to the park or be subject to removal.
Paradise Valley. Retrieved from http://www.nps.gov/features/yell/slidefile/gatewaycommunities/north/Page.htm
BANNED from their historic winter range in Paradise Valley just outside the park, bison are restricted to park boundaries. Instead, cattle graze here. While elk are permitted here, millions of dollars are being spent to keep wild bison from this region in the heart of the Greater Yellowstone Ecosystem.
Paradise Valley. Retrieved from http://blog.julielubick.com/2010/10/29/paradise-valley-montana/
ELK GRAZE WITH HORSES here in Paradise Valley, even though 20 percent of such free-range elk herds have brucellosis, as reported by a team head by P.C. Cross, U.S. Geological Survey, Northern Rocky Mountain Science Center, in Probable causes of increasing brucellosis in free-ranging elk of the Greater Yellowstone Ecosystem.

THE MIGRATORY PATH OF THE BISON herd in Yellowstone National Park, as shown by this image created from NASA Landsat satellite data. Their journey ends in a capture facility.
North entrance of Yellowstone National Park
THEIR MIGRATORY PATH is diverted into the Stephens Creek capture facility, located within park, in violation of the Yellowstone National Park Act of 1872, which set the land aside to provide for the preservation of its natural resources "in their natural condition," as well as forbidding the "wanton destruction of the fish and game found within said park, and against their capture or destruction for the purposes of merchandise or profit." Their destruction and capture is clearly for the profit of the cattle industry.

WILD BUFFALO CALF in a squeeze chute at Stephens Creek capture facility--wildlife traumatized in the name of testing for brucellosis. See video BFC: Hazing Operations & the Stephens Creek Capture Facility.

Studies find crowding animals together artificially by feeding or in pens promotes transmission of brucellosis.

WHY THE BRUCELLOSIS SCARE? At Texas A&M University researchers led by Donald S. Davis demonstrated, as reported in Brucella abortus in captive bison, that in close confinement, the species barrier can be jumped. Researchers placed several disease-free cattle with bison injected with massive doses of Brucella abortus. Half the cattle came down with the disease, because the risk for a pathogen to cross the species barrier depends on the rate of contacts between the species. Crowding increases contacts.

DUE TO THE "SPECIES BARRIER," Brucella abortus is rarely transmitted between species. Transmission from bison to cattle has never been recorded in the wild, but it has occurred in the laboratory. The most probable reason for this is the different conditions in the laboratory and in the field, such as routes of exposure (injection versus oral) and the quantity of bacteria present (massive overdose when injected experimentally, as opposed to oral ingestion). See Brucellosis in captive bison, Journal of Wildlife Diseases.
  DONALD S. DAVIS, associate professor, veterinary pathobiology, Texas A&M University and (kneeling) Rick L. Wallen, lead wildlife biologist for the bison program at Yellowstone National Park. See video of Wallen at Stephens Creek capture facility: Yellowstone National Park admits increase risk of brucellosis transmission. BRUCELLOSIS INFECTED COYOTES held in captivity with disease-free cattle, just like bison held in captivity with cattle, can transmit the disease to cattle, as reported in a study by Donald S. Davis et al. in Interspecific transmission of Brucella abortus from experimentally infected coyotes to parturient cattle.
YET IN THE WILD in the YNP, no coyotes had serologic evidence of exposure to brucellosis, either Brucella abortus or Brucella canis, as reported in "Serological survey for diseases in free-ranging coyotes (Canis latrans) in Yellowstone National Park, Wyoming."

How can coyotes in the wild feed on birthing materials infected with brucellosis, as well as carcasses, but not get the disease? Because of the "species barrier" and because conditions are different in the wild than in the lab.

Above a coyote in the YNP scavenge a bison that became stuck in the mud and perished. Several bison huddled around their fallen comrade. Bison are able to recognize their own even long after death.

DEMONSTRATING CLOSE PROXIMITY causes transmission of brucellosis from elk to cattle, researchers at the Sybille Wildlife Research Unit, Wheatland, Wyoming, penned eight pregnant cow elk artificially-infected with brucellosis together with eight disease-free domestic cows in a 3.2 acre enclosure, mimicking the crowded conditions on a feeding ground. Half of the cattle contracted brucellosis.

"These transmission studies demonstrate that brucellosis will spread from elk to cattle under conditions of close association. The probability of interspecific transmission increases in the presence of abortion and close contact." From "Brucellosis, its effect and impact on elk in Western Wyoming" by E. Tom Thorne, et al. (1979).

NINE CAPTIVE ROCKY MOUNTAIN BIGHORN sheep contracted brucellosis as a result of exposure to an aborted elk fetus found next to the fence line adjacent to where the bighorn sheep were being fed. It is possible that one or more bighorn sheep came in contact with either the fetus or infected birth fluids from the dam and subsequently spread the disease throughout the flock, according to a study by Terry J. Kreeger, et al. Brucellosis in captive Rocky Mountain bighorn sheep (Ovis canadensis) caused by Brucella abortus biovar 4.

ANOTHER POSSIBILITY for the transmission of brucellosis from elk to bighorn sheep was that the disease was spread by birds, particularly black-billed magpies that could have scavenged the fetus as well as frequented the food bunks of the bighorn sheep, Keeger et al. speculated in the above study.

According to the Center for Food Security and Public Health, B. abortus is usually transmitted between animals by contact with the placenta, fetus, fetal fluids and vaginal discharges from an infected animal, but some Brucella species have been detected in urine, feces, saliva, and nasal and ocular secretions. Brucella can be spread on fomites, including feed and water, hay and manure. See Brucellosis.

FEEDING THE PROBLEM--Since the early 1900's, hay has been spread by state officials on the winter range of elk to prevent them from foraging in areas devoted to cattle production. The result? Elk Brucellosis Infection may be increasing in the Greater Yellowstone Ecosystem.

See video Feeding the Problem by Montana PBS. Also see Debate rages over elk feeding and Appeals court rules in case challenging elk feed grounds.

CAPTIVITY INCREASES BRUCELLOSIS transmission risk, yet wild bison are routinely penned up within the park and immediately outside. Here Yellowstone Park employees use tractors to feed wild bison being held at the Stephens Creek holding facility.

SUSCEPTIBILITY TO BRUCELLOSIS besides bison and elk has been documented in rats, rabbits, hares, mink, foxes, coyotes, dogs, guinea pigs, sparrows, magpies, crows, pigeons, pheasants, chickens, turkeys, geese, fleas, house flies, mosquitoes, bedbugs and ticks, according to F.A. Hayes in "Report from the committee on wild and marine life diseases of the United States Animal Health Association" (1977).

THINKING LIKE MAD SCIENTISTS, researchers concluded that because brucellosis can jump the species barrier under laboratory conditions, namely, close confinement, that therefore brucellosis poses a risk outside the laboratory. The correct conclusion is that because brucellosis can spread from one species to another under captive conditions, such animals should not be artificially crowded, such as in capture facilities or on feeding grounds.

One-way migration: destination--the slaughterhouse.

AS THOUGH IN ANOTHER WORLD, some of Yellowstone's wild bison wade in the waters of Grand Prismatic Spring, the rings of green and yellow painted by algae growth. Out of millions of buffalo destroyed by settlers, the Yellowstone bison are descendents of a miniscule herd of 25 that survived because they could winter here without detection.

SOAKING UP THE WARMTH of a geothermal pool, this bison is relaxes in his winter spa. Only heavy snows will force him to leave this unique bison paradise.

HERDS GRAZE BY THE THERMAL POOLS in winter because the snow-pack is light here due to the higher water temperatures. Herd density increases as members congregate here. Would it not make sense to allow these buffalo to migrate, especially when you consider that brucellosis is a disease promoted by captivity and herd density? See video Bison rest near geothermal pools in Yellowstone.

WILD BISON BEGIN THEIR MIGRATION in winter from the high elevations and descend to areas of less snow to find forage.

MONTANA DEPARATMENT OF LIVESTOCK agents and park officials are in the lower elevations in and outside the park to meet them and drive them into corrals by means of a funnel of fencing. See video. Photo and video by Buffalo Field Campaign.

DRIVEN ONTO THIN ICE, these two drowned. In the chase, bison are killed, injured and separated from family members. Bison have close family ties, helping injured herd members. See video. Photo and video by Buffalo Field Campaign.

SOMETIMES BISON ARE SHOT in the field by Department of Livestock officials or on controlled hunts when they enter a kill zone outside the park. Photo by Buffalo Field Campaign.

BISON CACASS strapped to backhoe is transported to a truck for shipment to a slaughterhouse. Photo by Buffalo Field Campaign.

BISON DEATH MARCH--More often, migrating buffalo are rounded up and herded in droves into a capture facility by government officials. Photo by Buffalo Field Campaign.

PARK RANGERS on horseback and in vehicles pushing bison into a pen, January 1997.

THE HERD IS CROWDED into the capture facility, with officials monitoring the bison's movements from walkways overhead.

A LONG LINE of stock trailers awaits them. See video 'Yellowstone bison being shipped to slaughterhouse.'

A WILD-EYED BISON stares out from inside a stock trailer. More than 60 bison that day were loaded into it to be sent to slaughter, as reported for The New York Times by Jim Robbins March 23, 2008. This went on through April. Photo by Anne Sherwood.

INDUSTRIALIZED KILLING of wildlife should not be permitted, critics argue. Photo: wild buffalo being processed at a slaughter house in Sheridan, Montana. From left, stripped pelts drying outdoors, heads stacked against the wall, while remaining wild bison await slaughter.
A herd of bison heads in the snow.
Oh, oh what has become of us?
It looks like we lost our heads, you know.
They cut us off on the Yellowstone.
All we wanted to do was roam."
From "Song of the decapitated buffalo." Photo of bison heads stacked on the snow after processing at a slaughterhouse.

KILL BISON PARENTS THAT MIGRATE and you destroy the genetic information of how to migrate. A gene is a section of a DNA molecule that holds information for a particular trait, such as migration. Individual living things do not synthesize their own genes. Rather, they inherit them from their parents. As a result, individuals are genetically constrained by the genetic makeup of their parents. Individuals have no choice in the matter.

"There is strong evidence that genetics plays a large role in migratory behavior and that animals inherit migratory routes from their parents genetically," according to "Migrations Basic" by the National Park Service.

FOR THOSE THAT SURVIVE the winter, in the spring just after calving, helicopters haze the remaining bison and calves back into the park. National Park Service officials and agents of the Montana Department of Livestock routinely use helicopters to haze bison in and out of capture facilities. See video Montana Department of Livestock chasing baby buffalo with broken leg.

THIS HERD OF WILD BISON is being hazed off Horse Butte in the Greater Yellowstone Ecosystem back into the park by a Montana Department of Livestock helicopter. Assisting in the operation May 2009 were DOL agents on horseback and an ATV, accompanied by a Forest Service law enforcement officers. Photo by Lance Koudele, Buffalo Field Campaign.

HIGH FENCING surrounds a bison sterilization project at Corwin Springs, Montana. APHIS developed an immunocontraceptive vaccine called Gonacon that sterilizes pests. It is being tested at the holding facility on bison. GonaCon causes an animal’s body to make antibodies that bind to gonadotropin-releasing hormones (GnRH), a hormone in an animal’s body that signals the production of sex hormones (e.g., estrogen, progesterone, and testosterone). By binding to GnRH, the antibodies reduce GnRH’s ability to stimulate the release of these sex hormones. Photo by Buffalo Field Campaign.

GONACON SIDE EFFECTS. In a study Effects of Gonadotropin-Releasing Hormone Immunization on Reproductive Function and Behavior in Captive Female Rocky Mountain Elk, GonaCon was associated with abscesses at the injection site and "prolonged reproductive behaviors during the breeding season, a finding that has potential ecological effects that require further study."

Photo above of a wild captive bison with two red ear-tags feeding on hay by Buffalo Field Campaign.

FOR VARIOUS EXPERIMENTS, bison are outfitted with collars, red ear-tags, vaginal transmitter to detect births, forced into squeeze chutes or physically restrained in the alleyways leading to the chutes where they are subjected to blood withdrawals and/or sterilized by hand injection with a pesticide specially developed by APHIS scientists. See Comment 1 and Comment 3.

AT THE NATURAL BOTTLE-NECK in Yankee Jim Canyon cattleguards have been installed, as well as fencing. Bison can go no further north into Paradise Valley, but must stay in Gardiner Basin. Being that this is now the case, why haze bison back into Yellowstone over a few hundred cattle? Why not ban cattle from the Gardiner Basin and save taxpayers millions of dollars each year and end the hazing and killing of bison here? Photo by Buffalo Field Campaign.

Solution: ban cattle from the Greater Yellowstone Ecosystem and encourage wolf predation.

PARADISE VALLEY, as seen from Yankee Jim Canyon. Here the Yellowstone River is one of the nation's most productive trout streams. Why not allow bison to proceed beyond Yankee Jim Canyon into this valley? While a part of the Greater Yellowstone Ecosystem, bison are banned from here, as well as much of Gardiner Basin, their historical winter range.

THE GREATER YELLOWSTONE ECOSYSTEM (GYE) should serve as a "cordon sanitaire" in which no invasive species, such as cattle, are permitted. Cattle originally spread the disease of brucellosis to bison. The broken red line demarks the boundary of the GYE, one of the last remaining large, nearly intact ecosystems in the northern temperate zone of the earth. The GYE is one of the world's foremost natural laboratories in landscape ecology and geology and is a world-renowned recreational site. It covers about 28,000 square miles.

GRASSLANDS, SIMILAR TO PARADISE VALLEY, are available to the world's largest herd of wild, unfenced wood bison at the Wood Buffalo National Park, Canada. The park is an outstanding example of ongoing ecological and biological processes, encompassing some of the largest undisturbed grass and sedge meadows left in North America. Such expanses of critical range are not available to the only wild herd of bison left in the United States, but could be.

WOLVES ARE A NATURAL PREDATOR of bison. Here a massive pack of 25 timberwolves are hunting bison on the Arctic circle in northern Canada. In mid-winter in Wood Buffalo National Park temperatures hover around 40C. The wolf pack, led by the alpha female, travel single-file through the deep snow to save energy. The size of the pack is a sign of how rich their prey base is during winter when the bison are more restricted by poor feeding and deep snow. The wolf packs in this national park are the only wolves in the world that specialize in hunting bison ten times their size. They have grown to be the largest and most powerful wolves on earth.

WOOD BUFFALO NATIONAL PARK, located in northeastern Alberta and southern Northwest Territories, is the largest national park in Canada at 17,300 square miles. The park was established in 1922 to protect the world's largest herd of free roaming Wood Bison, currently estimated at more than 5,000.

GREY WOLVES surround a lone bison in Yellowstone. Several environmental organizations believe that the predator and prey relationship should be what governs bison populations in the Greater Yellowstone Ecosystem, calling on government agencies to stop involving themselves in the predator relationship against the wild bison.

"PREDATION ON BISON BY WOLVES can also be an important limiting factor for bison populations and is the subject of current research in the central and northern portions of the park and the Pelican Valley... Predation is a significant limiting factor for bison in Wood Buffalo National Park in the presence of tuberculosis and brucellosis. Wolves attack bison calves preferentially over older age classes of this species." From The ecology of bison movements and distribution in and beyond Yellowstone National Park--A critical review with implications for winter use and transboundary population management, by C. Cormack Gates, associate professor of environmental science at the University of Calgary, Canada (pictured above) et al.

From the Smithsonian Magazine Wolves and the balancer of nature in the Rockies:

ON THE WESTERN BORDER OF THE YNP "Roger Lang looked at two black wolves looking back at him. 'I knew they wouldn't get them all,' he said, steadying his binoculars on the steering wheel of his pickup truck. 'Some of them were trapped. Some were shot from helicopters. They culled nine and actually thought they got the whole pack. But you can see they didn't.'

Sloping down to the Madison River, Lang's 18,000-acre Sun Ranch in southwest Montana is an Old West tableau of rippling prairie, plunging streams, ghostly bands of elk, browsing cattle—and, at the moment, two wolves poised like sentinels on a knoll beneath the snowy peaks of the Madison Range. About 25 miles west of Yellowstone National Park, the ranch straddles a river valley that is part of an ancient migration corridor for elk, deer, antelope and grizzly bears that move seasonally in and out of Yellowstone's high country.

CONTINUED. "Lang has a close-up view of one of the most dramatic and contentious wildlife experiments in a century—the reintroduction of wolves to the northern Rocky Mountains, where they were wiped out long ago. Caught in Canada and flown to Yellowstone, 41 wolves were released in the area between 1995 and 1997, restoring the only missing member of the park's native mammals. Since then, wolves have begun migrating in and out of the park, their howls music to ears of wilderness lovers and as chilling as war whoops to many ranchers.

"Wolves from Yellowstone were on Lang's property by the time he acquired it in 1998. A former Silicon Valley entrepreneur who amassed a fortune in the software business, he seeks to breach a gap between people—including many transplanted urbanites—who would grant wolves unconditional amnesty and others who would exterminate them. 'Wolves were here before we were and deserve a place,' said Lang. 'But that doesn't mean some of them aren't going to die if they misbehave.'

"After wolves killed five of his cows, he consulted with federal wildlife officials, who pass sentence on incorrigible wolves. 'The feds proposed taking out the whole pack and we acquiesced,' he said."

SOME 166 WOLVES WERE KILLED in 2011, short of the state's 220-wolf quota, leaving an estimated population of 653 in Montana in the state's first hunting season since federal protection of the species was lifted last year. Wolves were put on the endangered list in 1974.

Over the last two decades, state and federal agencies have spent more than $100 million on wolf restoration programs across the country. The Northern Rockies is now home to more than 1,700 wolves in Montana, Idaho and Wyoming. Wolf hunts have killed more than 500 wolves across the Northern Rockies in recent months.

AFTER AFFIXING A COLLAR on a tranquilized wolf in Hayden Valley in the YNP, identified as Gibbon Meadows pack wolf 687F, National Park Service staff biologist Rebecca Raymond prepares to process the animal.

An objective of the Yellowstone Wolf Project is to document the behavioral interactions between wolves, bison, and grizzly bears to: (1) identify patterns of wolf predation on bison; (2) determine how the risk of wolf predation influences bison foraging behavior, movement, and habitat use; and (3) assess the importance of wolf-killed ungulates for grizzly bears emerging in early spring. See Yellowstone wolf project: annual report 2010, p. 23.


The beef culture or the buffalo culture?

Members of the Montana Department of Livestock and APHIS have proven to be wildlife sadists operating as pseudo-scientists, putting in peril the last migratory, pure-blood herd of wild bison in the nation. Their input--essentially anti-wildlife--should either be entirely eliminated or significantly reduced from decisions concerning the Greater Yellowstone Ecosystem. Instead those who have a heart for wildlife should be in charge.

CITIZEN ACTION GROUPS, tribal represent-atives of First Nation cultures, elected officials and those interested in the preservation of wildlife meet together for conflict resolution. Concensus is critical in resolving conflicts over bison, wolves and land use, for they involve core beliefs about wildness, the role of predators and our role as human beings. Photo by Buffalo Field Campaign.

At the root of the brucellosis hysteria are collective delusions fostered by groupthink.

GROUPTHINK is defined as “a pattern of thought characterized by self-deception, forced manufacture of consent, and conformity to group values and ethics." It is contributory to a number of organizational meltdowns resulting in disaster. Its cause can be traced to "information avoidance, repainting red flags green and overriding alarms," according to Roland Bénabou's Groupthink: collective delusions in organizations and markets. Roland Bénabou is Professor of Economics and Public Affairs at Princeton.

COLLECTIVE DELUSIONS have many forms, such as the mass hysteria that swept across the United States following Orson Welles' broadcast of a fictitious attack by creatures from Mars.

"The persons who were frightened by the broadcast were, for this occasion at least, highly suggestible, that is, they believed what they heard without making sufficient checks to prove to themselves that the broadcast was only a story," noted Hadley Cantril, chairman of the Princeton University Department of Psychology, in his study The invasion from mars. In sum, he said, such persons lacked "critical ability."

"WE WERE FED UP with the way everything that came over this new magic box was swallowed. When the radio came, and now television, anything that came through this new machine was believed. So in a way our broadcast was an assault on the credibility of that machine. We wanted people to understand that people shouldn't take an opinion predigested and that they shouldn't swallow everything that came through the tap, whether it was radio or not." Quote from video: Orson Welles on War of the Worlds.

MASS HYSTERIA was promoted by a local physician's diagnosis that the strange behavior of two girls was the result of an "evil hand," culminating in the Salem Witch Trials, where a number of citizens were accused of witchcraft and hung.

Historians trace the cause of the outbreak of hysteria to a rivalry between two Puritanical families, with the accused being outcasts, outsiders and those who questioned the evidence and testimony of the proceedings. Several girls claimed they had been visited at night by ghostly apparitions resembling the accused. When those charged with witchcraft entered the court room, the afflicted girls invariably collapsed into traumatic fits of hysteria that only ceased when the accused began to confess. See West's encyclopedia of American law: Salem witch trials.

WILLFUL BLINDNESS. Bénabou observed that after the Columbia mission sustained a large foam strike to its wing’s thermal shield, a collective form of "willful blindness" set in. "[M]ounting warning signals were system-atically ignored or met with denial, evidence avoided, cast aside or selectively reinter-preted, dissenters discouraged and shunned," he observed. “At every juncture of [the mission], the Shuttle Program’s structure and processes, and therefore the managers in charge, resisted new information."

"THEY KNEW on the second day of the mission that a piece of foam hit the wing leading edge and that it was the size of a small briefcase and probably weighed two pounds. They knew this. So I said, 'Let's do some simple high school physics. Check my numbers.' And Doug said, 'Yup. If the foam hit at a relative velocity of 500 miles an hour, it would impart a force of about 3,000 pounds—roughly a ton of force.'

"Yet we had people in the shuttle program saying, 'Oh, these guys are 'foamologists'!' They would hold a piece of foam up on national TV and ask, 'How could anything this light do any damage?'

...And they somehow didn't do the simple calculation to understand the foam's impact." Quote by Scott Hubbard, director of NASA's Ames Research Center, Silicon Valley. See Investigating a shuttle disaster. Photo above: putting the shuttle pieces back together, debris is seen covering the floor of a hanger during reconstruction of the fallen orbitor.

PILE OF AMERICAN BISON SKULLS waiting to be ground for fertilizer circa 1870s. Aimed at destroying the food supply of the Great Plains Indians so as to make way for the trans-continental railroad and placate investors, who saw Indian nations as a threat, the greatest force of extinction every mounted by humans was unleashed, resulting in the destruction of 30 million buffalo in a few years.

This same systematic effort is being directed against the wild bison leaving Yellowstone National Park to placate the owners of 2,000 cattle (out of 2.5 million in Montana) who graze their animals on public and private lands just outside the YNP, creating the potential for the collapse of the herd or the genetic destruction of the last migrating bison in the nation.

DR. RALPH MAUGHAN, professor of political science at Idaho State University and president of the Wolf Recovery Foundation in a video The Montana Conflict between Cattle and Bison, states: "Bison...by Montana state law are confined to the boundaries of Yellowstone Park and it has been the policy of Montana that if bison leave...then they will be shot or hazed back into the park... and this controversy has been going on about 20 years...

"There seems to be a prejudice against bison, particularly in Montana. Oddly enough, there doesn't seem to be a prejudice in Wyoming. It is probably a prejudice of a few important decision makers in certain agencies. On close inspection it turns out to be a purely cultural issue.

"It is the Montana Department of Livestock and certain politicians pushing us around and showing us their power by killing the bison that leave Yellowstone. It is a clash of cultural values and they kill bison to show who is really in charge in this area."

CASH COWS $1,500 A HEAD. The government is spending over $3 million a year to protect 2,019 cow-calf pairs grazing immediately outside Yellowstone National Park in Gallatin and Park counties (comprising less than 4 percent of the cattle population of the two counties) from the remote threat of contracting brucellosis from park bison. That turns out to be $1,500 a head just in government costs related to bison and cattle interaction on the borders of the YNP so that ranchers can make $50 a head profit (in a good year) for grazing stock on public lands, the low grazing fees representing a subsidy to these ranchers.

"Despite the cowboy's image as a rugged, independent individual, a host of government subsidies keep him propped up in the saddle. The western rancher is dependent on what is, in essence, a welfare program. The much-publicized low fees paid by ranchers to graze federal lands are only the beginning." Quote from Welfare ranching: The subsidized destruction of the American West, part V, Ranching economics and livestock subsidies: The true cost of a hamburger.


What it all boils down to is hoodwinking. Statements by APHIS demonstarate duplicity when it contends that 1. it intends to work with the cooperating agencies to develop a plan to eliminate brucellosis from the GYA while ensuring a wild, free-roaming, and viable bison herd in Yellowstone, that 2. similar eradication efforts have been successful in other parks, including Wind Cave National Park and Custer State Park in South Dakota and Wichita Mountain Wildlife Refuge in Oklahoma and that 3. APHIS officials are confident, based on experience in other public and private bison and elk herds and on other successful disease eradication programs, that use of a combination of disease-eradication and herd-management measures will lead to the successful elimination of brucellosis from bison and elk in the Yellowstone ecosystem. See Brucellosis and Yellowstone bison.This view is mirrored by the IBMP.

Brucellosis can only be controlled by separation, such as fencing. All three parks mentioned have fences, which keep cattle out and bison in. Just take a look below:

Fencing at Wind Cave National Park, bison being herded into stockade by helicopter.
Fence dividing Wind Cave National Park from Custer State Park.
Fences above, Custer State Park and below Wichita Mountains Wildlife Refuge.

Items 1, 2 and 3 are self-contradictory and as a unit impossible to implement successfully. IBMP is engaging in a mission impossible, and they know it. Their only mission is to kill bison. And in that they are succeeding. Forget genetics. Lethal removal is their fence. It is idiotic.

Montana's cattlemen are on
a brucellosis witch-hunt



In response to Montana Fish, Wildlife & Parks' invitation for public comment:


Due: January 13, 2012, 5 p.m.
Email address: IBMPadjustments@mt.gov

The stock growers of Montana are on a witch-hunt and the name of the witch is Brucellosis. They believe she will come riding into their herds on wild bison migrating from Yellowstone National Park (YNP) and infect their stock.

But is this dread based on scientifically valid evidence? The answer is no. In the wild bison have never infected cattle with brucellosis. Not one such outbreak has been recorded. Only in the laboratory under artificial conditions has transmission occurred.

And will the government solution--shooting, slaughtering or caging bison that migrate out of the park--solve the problem they claim exists? The answer again is no. In fact, it will increase the risk.

Montana Fish, Wildlife & Parks is seeking public comment on a draft environmental assessment proposing to expand the bison-tolerant area in the Gardiner Basin just north of the park as part of adjustments to the Interagency Bison Management Plan (IBMP) for the wild bison of the YNP.

Specifically, the proposed adjustments would allow bison on U.S. Forest Service and other lands north of Yellowstone Park and south of Yankee Jim Canyon--with the northernmost tolerance boundary being the ridge-tops separating Paradise Valley from the Gardiner Basin.

Further, it would transport up to 300 bison cows and calves that test negative for brucellosis from the Stephens Creek capture facility inside the park to the Corwin Springs quarantine facility in the basin so they can be held and released back into the park in the spring.

Instead of being an increase of tolerance for wild bison, however, it is a codification of the no-tolerance for that species that already exists there. It is based on an obsessive and irrational fear of brucellosis.

This mass hysteria, as some would call it, is costing taxpayers millions upon millions of dollars annually and puts in jeopardy of extinction the last wild herd of bison in the United States. The focus is primarily on Gardiner Basin, an area just outside the northern park entrance.

Out of 2.5 million cattle in Montana, how many cattle are involved in this boondoggle? About 700 are trucked in every year to graze on public and private lands in the basin between May and October. A few more head graze there year-round. Profit to the cattle ranchers? A total of 1,000 head at $50 profit per head would net $50,000.

Horseback riders, helicopters, all-terrain vehicles, law-enforcement SUV's with lights flashing and sharpshooters are involved in this 21st century roundup aimed at hazing migrating bison back into Yellowstone National Park at an annual cost to taxpayers of $3 million.

One can ask the legitimate question that if taxpayers are being required to spend millions so a few cowboys can make $50,000 a year, would it not be more economical just to pay them off and ban cattle from the region, which comprise a few square miles of grazing land, instead of spending those millions on emergency responders?

All the forces of government are united against this unique bison herd that number between 3,000 and 4,000 animals: at the federal level, the National Park Service, the Forest Service and the Animal and Plant Health Inspection Service (APHIS); and at the state level, Montana's Department of Livestock and Department of Fish, Wildlife and Parks.

The rationale for governmental control of the Yellowstone bison comes under the rubric of "Final Environmental Impact Statement (FEIS) for the Interagency Bison Management Plan (IBMP) for the state of Montana and Yellowstone National Park" instituted in 2000.

Why this interagency effort? Because of witch Brucellosis. The only trouble is her spell is virtually non-existent. In the words of the FEIS:

"Commentors are correct that available evidence indicates the risk of transmission under natural field conditions is extremely low. However, because transmission between bison and cattle has occurred under experimental conditions and on ranches with privately owned bison and cattle, the risk of transmission is not zero."

We are about to lose a national, as well as an international treasure over a risk that is "extremely low" but "not zero."

But the risk of losing a link to the wild heritage of America is very real, a heritage that dates back to the Pleistocene and the era of megafauna. No other bison herd in the United States is wild, unfenced and migratory. All other bison in the nation have been extirpated. The Yellowstone bison are descendants of the same bison that wandered into the park region 10,000 years ago over the Bering land bridge and have continuously lived there. They are also one of the few genetically pure herds without cattle genes.

However, government actions and plans indicate that preserving the last remnant of wild bison is of less importance than preserving the rights of a few stock growers to graze domestic cattle in one of the world's preeminent ecosystems devoted to the preservation of wildlife.

Government agencies are on a systematic quest to eliminate those bison that still possess the instinct to migrate. When members of the herd express that instinct by crossing the park boundaries, they are either shot or shipped to slaughter. A few are put into corrals like cattle.

The migratory herd's collective goal is to escape the harsh winters in the park and find forage at lower altitudes. Following an ancient migration corridor along Yellowstone River, members of the herd leave the park at the north entrance, heading through Gardiner Basin to Paradise Valley, a region of lush meadows through which the Yellowstone River winds, historically visited by migrating wildlife coming down from the high elevations of the Greater Yellowstone Area.

Since 1985, almost 7,000 buffalo in the park have been slaughtered by agents from the Montana Department of Livestock [and other governmental officers] because they have attempted to migrate out of the park.

In the last few years, authorities have been allowing some bison to migrate out of the park into three management zones within Gardiner Basin. It is like going from the frying pan into the fire. As they progress north toward Paradise Valley, each zone becomes less tolerant, with the last zone entered requiring a bison's lethal removal. Three strikes and the migrating bison are out.

Last year, 75,000 acres in the northern sector of the basin in the Gallatin National Forest were set aside for habitation by bison during the winter. While much of the area is comprised of mountainous regions, the refuge contains Cutler Meadows, a grassland of several thousand acres. Here they are allowed to give birth in the spring, and then they are hazed back into the park to make way for cattle being shipped into the region.

To get to this safe zone each winter, however, the bison must cross a sprawling piece of private property called the Royal Teton Ranch, owned by the Church Universal and Triumphant (CUT). To facilitate this migration, government agencies and private conservation groups paid more than $3 million for a 30-year lease of a narrow bison migration corridor of several miles through the ranch.

The corridor follows a dirt road paralleling the Yellowstone River and is lined with an electric fence. Stray from the corridor into no-tolerance zones and a bison is faced with a gauntlet of emergency responders and law-enforcement officials representing a multitude of government agencies.

Last year about 700 bison started heading out of the park toward the Gardiner Basin. They were all hazed into the Stephens Creek capture facility, essentially a stockyard.

In January of last year a test herd of 25 bison were released from the facility and allowed to travel this corridor, herded ten miles by park employees and state livestock agents on horseback. Pronghorn antelope and mule deer scattered to avoid the procession. It took about three hours to reach the open meadow.

This test herd was outfitted with radio collars to keep track of them. The females were fitted with vaginal transmitters to allow rangers to pinpoint where they gave birth. As they traveled down the electrified corridor, it was a scene more befitting a science fiction horror film. Welcome to the Brave New World for wildlife.

However, numerous animals refused to go where they were supposed to go. Instead of going to Cutler Meadows, 15 of the 25 animals headed to the Yellowstone River, swimming across to gather on the banks where their favorite forage, sedge, grows. But this was private property and a no-tolerance zone. Wranglers tried to haze them back to where they belonged. One aggressive female bison was shot because she wanted to stay on the river bottom meadow.

Following instincts developed over 10,000 years, the bison apparently just couldn't get with the government's plan for them.

"They're like little kids, they do just the opposite of what you tell them," Ken McDonald, Montana's chief of wildlife, said, as reported by Reuters Jan. 25, 2011. "A bison has a mind of its own at times."

He said it is possible managers will replace the uncooperative bison with others quarantined on the edge of the park.

This means these wild bison are being selected for cooperative traits, as opposed to aggressive ones--and selective breeding is the death knell for wildness. Europe's wild and aggressive auorchs, the ancestor of domestic cattle, were selectively bred for docility. Now they are extinct.

Because of this failed effort, the state of Montana is proposing "adaptive management adjustments" to the Interagency Bison Management Plan. The changes involved a "drop-dead" boundary that stretches in an arc along the mountain ranges dividing Gardiner Basin from Paradise Valley further north. Go past that line and all bison will be lethally removed.

The last checkpoint into the prohibited region of Paradise Valley is located in a narrow gorge called Yankee Jim Canyon. This is a natural bottleneck in the terrain. Steep canyon walls, fencing and cattle guards prohibit bison from going any further into their historical migrating grounds, now inhabited by movie stars and millionaires.

Going through that gorge means death for bison, but staying south in Gardiner Basin is no picnic, either. According to the proposed new rules, bison who don't walk the line, who veer off the Corridor to Nowhere--as some critics call it--into no-tolerance zones, will be hazed back to the Stephens Creek capture facility.

Here each animal will be forced into a squeeze chute, with its head protruding like a prisoner in stocks, stabilizing it with a ring fastened through the membrane of its nose and attached to a rope. Agents on platforms above them will oversee the operation, much like guards in a penitentiary. Agents on the ground will subject the animals to blood tests for brucellosis, as well as perform pregnancy tests. A select few bison will be affixed with ear-tags, radio collars and vaginal telemetry devices.

Those that test negative for brucellosis will be put into one pen and those testing positive into another. Of those testing negative, 300 will be herded into trailers and shipped to a double-fenced quarantine facility in Corwin Springs for holding until release back into the park in spring.

All this effort is supposedly because bison pose the threat of infecting cattle with brucellosis. But what is the reality of the situation? Setting hysteria, distorted scientific findings and bias aside, what do we know?

About half of the park's bison test positive for the bacterial disease and of that half, about half actually have the disease, while the others have immunity. Brucella abortus, as it is also called, causes a bison cow to abort its first calf. After that, it usually acquires immunity. The disease also causes beef and milk cows to abort.

But is transmission of this disease from bison to cattle probable? Interspecies transmission is rare due to the "species barrier." So why are cattlemen so spooked by brucellosis in bison? Because under laboratory conditions cattle came down with the disease when confined in close proximity with buffalo artificially infected with a high dose of laboratory cultured Brucella abortus bacteria.

In a research paper published in 1990 titled "Brucella abortus in captive bison: serology, bacteriology, pathogenesis and transmission to cattle," Dr. Donald S. Davis and his colleagues at Texas A&M University put six cattle into a 2.7 acre paddock with six bison that had been inoculated with a massive dose of brucellosis. After a period of time, half of the cattle became infected with Brucella abortus.

What does Davis derive from this experiment? Pointing his finger at the free-ranging elk in Wyoming and bison herds in Yellowstone National Park he concludes: "These migratory herds are heavily infected with B. abortus and as such will pose a continuing threat to the brucellosis-free livestock industries and associated human populations."

But what does this experiment actually prove? Just what the title suggests: that interspecies transmission of brucella abortus in captive bison is possible under certain artificial conditions. The paper demonstrates that brucellosis is a disease promoted by captivity, as opposed to free-range conditions.

Let us take a look at a similar experiment involving the captivity of diseased coyotes with disease-free cattle. This investigation was done again by Dr. Davis. In four separate trials, 10 coyotes were individually fed bovine placental and fetal tissue experimentally inoculated with Brucella abortus. The coyotes were then placed together with six pregnant heifers in 2.5 acre fenced isolation areas, as described in a paper titled "Interspecific transmission of Brucella abortus from experimentally infected coyotes to parturient cattle."

Out of the four trials, only one group of cows contracted Brucella abortus. That group was from heifers penned with the coyotes that ate tissue with the highest dose of brucellosis. In that trial, half the cows came down with the disease. In the other three trials where coyotes were fed lower doses of infected tissue, none of the cows contracted brucellosis.

How was the disease transmitted? The study made no conjectures. Most researchers believe oral transmission is the most common route. In the trial that caused the infections, Brucella abortus was isolated from fecal samples collected from two of the 10 coyotes, but from none of the coyotes in the other three trials. Possibly, in this experiment, heifer ingestion of contaminated hay from coyote fecal material was the route of transmission.

The two experiments have similarities. In both investigations, half of the cows contracted Brucella abortus and in each case, the dose of the infectious agent was massive and delivered in a captive setting.

What does Davis conclude from the coyote experiment? If he were consistent, he would warn that coyotes pose a threat to the brucellois-free status of Montana.

But here is what Davis says: "The epidemiologic significance of the transmission of B. abortus from coyotes to cattle should not be overstated. The animals in the investigation were in an artificially crowded situation by experimental design (six cattle and 10 coyotes in a 1 ha area) that would be unusual in nature."

Plus, in the only trial that caused the transmission of Brucella abortus from coyotes to cows, the bacterial count of the inoculated tissue fed to the coyotes was the highest of the group.

So, what would these findings mean if applied to a wild setting?

If aborted tissue from free-range bison in the Yellowstone National Park had bacterial levels high enough to infect coyotes, then coyotes and other scavengers that share the same range also should be highly infected. But is this the case--do coyotes in Yellowstone National Park have brucellosis?

No, they do not. Despite their potential to contract brucellosis, in one study 70 blood samples of coyotes from Lamar Valley in YNP were negative. In another study of the YNP by E.M Gese, no coyotes had serologic evidence of exposure to Brucella abortus.

What do these studies prove? According to Davis, in his discussion of the results of his coyote and cattle experiment, earlier researchers have stated that Brucella onganisms are not readily transmitted from the preferential host to dissimilar hosts due to the species barrier. Davis noted that "The present study does support this conclusion but it also indicates that transmission from 'dissimilar hosts,' such as predators to the 'preferential host,' [such as cattle] is possible under certain conditions."

Those "certain conditions" are captivity of two species in close proximity to one another and administration of massive doses of the Brucella abortus bacteria. These conditions do not mimic conditions in the field. Further, depending on the species involved, the route of exposure can have a profound influence on the outcome of exposure. In the Davis study, the means of transmission to infect an animal was not by the oral route, but by injection.

However, "a well designed experiment should have included additional groups of bison given an exposure orally to imitate exposure as it occurs in nature," according to Mary Meagher, a leading biologist with Yellowstone National Park, in a letter to the editor in the Journal of Wildlife Disease.

What experiments have proved is that brucellosis is a disease promoted by captivity and other stresses inherent in non- natural settings, such as feeding grounds and stockyards.

For instance, it is known that the elk feeding grounds in Wyoming, such as the National Elk Refuge, promote such diseases as brucellosis. It is feared that it may also promote chronic wasting disease. The elk are fed by the state to keep grazing pressure off cattle in the area.

"This biological experiment has created a Petri dish for wildlife disease, and is now one of the most contentious and fiercely debated issues in the Greater Yellowstone Ecosystem," according to an episode called "Feeding the Problem," aired July 2011 by Montana PBS.

"If you were to ask me to design a system to maximize and amplify transmissible infectious disease, I would tell you to go out there and crowd them together during the maximum stress period of winter and draw them there and probably the easiest way to draw them in there is just feed [them]," observed Dr. Thomas Roffe, chief of wildlife, US Fish and Wildlife Service.

"We look at the feeding grounds and the thousands of animals we crowd into a small area and that is possibly the best wildlife scenario for exacerbating wildlife disease," he said.

Rick Wallen, Yellowstone National Park bison biologist, in an interview by Stephany Seay, Buffalo Field Campaign's media coordinator, confirmed that holding bison in pens, as they are currently doing, increases the risk of brucellosis transmission among bison.

As shown on YouTube, the following exchange took place on March 8, 2011 in front of the Stephens Creek capture facility:

Seay: "I have a question. This is a holding pen of the animals, of the pregnant females, females giving birth. All this mismanagement, I am going to call it, against wildlife, is supposedly due to brucellosis. Don't you feel that holding these animals during their calving, having abortions, causing abortions, giving birth in close proximity, don't you feel you are exacerbating any potential of risk?

Wallen: "The risk to transmission among the bison?"

Seay: "Among the buffalo."

Wallen: "Yes, that is correct."

Seay: "So you do feel you are increasing the risk?"

Wallen: "Yes."

Given all this evidence against the present plan, what is the solution? Mary Meagher, the renowned Yellowstone National Park biologist, advocates creating a "cordon sanatire" around the park which would be free of cattle.

Instead of creating no-tolerance zones for bison in the Gardiner Basin, all of Gardiner Basin should be a no-tolerance zone for cattle. This would assure that brucellosis would not be transmitted to cattle. It would allow bison to migrate unmolested at least up to the natural bottleneck of Yankee Jim Canyon. It would preserve the gene purity of the last wild herd of bison, preventing them from mating with cattle that now graze year around in the basin. And it would save taxpayers $3 million annually.

It would also allow closure of the Stephens Creek capture facility. The wildlife park should not function as a stockyard. At present, every day when the facility is occupied, a green tractor rumbles through the fenced pasture, spreading hay from round bales as hundreds of wild bison run after it, pausing to catch mouthfuls of straw. This is wilderness?

No, because wildlife disease is promoted by captivity and the stresses of confined conditions, this is a breeding ground for brucellosis.

# # #

[Automatic reply:
IBMP comment
Friday, January 13, 2012 4:02 PM
To: "James Horsley"
Thank you for your interest in the Draft Joint Environmental Assessment on the Adaptive Management Adjustments to the Interagency Bison Management Plan. Your comment has been received.
Montana Fish, Wildlife & Parks]


South Fork and Watkins Creek Allotments Management Plan Update
Environmental Assessment USDA-Forest Service
Gallatin National Forest-Hebgen Lake Ranger District
West Yellowstone, Montana
Gallatin County

FROM: James Horsley
Fargo, ND

TO: Cavan Fitzsimmons
Hebgen Lake Ranger District
Gallatin National Forest
West Yellowstone, MT 59758


DATE: January 20, 2012


Following an environmental analysis (EA), the Hebgen Lake Ranger District of the Gallatin National Forest is requesting comments on a proposal to continue livestock grazing on the Watkins and South Fork Allotments near West Yellowstone, Montana.

A major issue pertains to the management of wild bison that are theoretically capable of transmitting brucellosis to cattle. This region is visited by several hundred wild bison during the winter as they migrate from the high elevations to more protected regions in search of forage. These animals are members of the last wild herd in the United States. The migrating animals are subject to hazing and slaughter each year as they wander out of the park.

Critics reason that bison have never transmitted brucellosis to cattle in a wild setting and reason that if the cattle are on the allotments then the Department of Livestock may continue to haze and slaughter wild bison.

According to the environmental assessment concerning the South Fork and Watkins Creek allotment management plan:

"Some believe that if the cows are not in the Hebgen Basin then the IBMP [Interagency Bison Management Plan] would allow for free roaming bison in this area. The current IBMP would not allow for free roaming bison after May 15 in zone 3 (west side of South Fork Madison River), regardless of the presence or absence of cows on the Forest lands. However, the IBMP allows for the management plan to be modified based on science and management directions set by Animal Plant Health Inspection Service (APHIS) and by State Department of Livestock. APHIS recently published new management guidelines for managing the spread of Brucella abortus in the Federal Register ... Given the recent changes in how Brucella abortus is being managed it is impossible to know what future bison management direction will involve."

At issue is about 140 acres of livestock grazing on the South Fork Allotment and 490 acres of livestock grazing on the Watkins Creek Allotment. The project area is on National Forest System lands, but has interspersed private lands in the immediate vicinity. Between 1992 and the present, there has been an average of 15 cow/calf pairs on the South Fork Allotment and 55 cow/calf pairs on the Watkins Creek Allotment from July 1 to September 30 each year.

In sum, the proposal involves 630 acres and 70 cow/calf pairs. If the market value of 70 head of cattle provides a profit of $50 per head, total profit would be $3,500.

The Department of Interior spends $1,200,000 annually for buffalo management in and around Yellowstone National Park. Buffalo management related expenditures for the Gallatin National Forest, including hazing and capture operations, are up to $150,000 annually. The Montana Department of Fish, Wildlife and Parks receives $75,000 annually from the Montana Department of Livestock for support of buffalo management operations. Total public expenditures, including special appropriations, are estimated to be as much as $3 million per year.

It does not represent justice that taxpayers be required to provide government support of several million dollars so that several cattle operations can make a profit of several thousand dollars. Such cattle operations should be obligated to provide the funding for these government emergency responders that come to their aid. While government may be required to pay for emergency situations such as forest fires, migrating wild bison is an annual, predictable occurrence and can be planned for. It thus should be paid for by those taking advantage of government grazing allotments.

I support Alternative 1, namely, no cattle grazing. This plan would significantly decrease the cost of bison management for the various agencies involved. This is the least expensive plan and would encourage more bison on the allotments, providing increased usage by elk, as elk avoid cattle-populated ranges. This in turn has the potential of increasing the wolf populations, as bison are their preferred prey. Further, it would reduce the chances of stray cattle mating with wild bison, preserving the genetic purity of that herd. At present, only a few herds do not carry cattle genes. Moreover, by not allowing grazing of cattle on land where bison are also present, the state would be more assured of not having cattle contract brucellosis from the wild herd.

Importantly, since the EA states that "it is impossible to know what future bison management direction will involve," the most prudent direction would be to not obligate Gallatin National Forest to another 20 years of cattle allotments in this contentious and sensitive region.

[Your email was received by FS-comments-northern-gallatin@fs.fed.us
Friday, January 20, 2012 9:28 PM
From: "FS-comments-northern-gallatin"
To: "James Horsley"
Your email was received by FS-comments-northern-gallatin@fs.fed.us]

# # #

Note: James Horsley, a resident of Fargo, North Dakota, is the author of a petition to list the YNP bison herd as endangered and to designate critical habitat in and adjacent to YNP. See http://www.fws.gov/mountain-prairie/pressrel/07-52.htm and http://www.peasantpress.com.



The U.S. Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service (APHIS) is making available to the public an environmental assessment for a proposed study to evaluate whether GonaCon™, an immunocontraceptive vaccine, would be effective as a non-lethal method of decreasing the prevalence of brucellosis in the Yellowstone National Park bison population. This proposed action is planned for locations on private ranch land near Gardiner, Montana. The environmental assessment, “Evaluation of GonaCon™, an Immunocontraceptive Vaccine, as a Means of Decreasing Transmission of Brucella abortus in Bison in the Greater Yellowstone Area,” is available online at http://www.aphis.usda.gov/animal_health/animal_diseases/brucellosis/ and http://www.ibmp.info. Paper copies may be obtained by contacting USDA APHIS, Veterinary Services Area Office, 208 North Montana Avenue, Suite 101, Helena, MT 59601 or (406) 449-2220.

Comments may be submitted via email to EAComments2012@aphis.usda.gov or by mail to the VS Area Office listed above. Comments must be received by February 25, 2012. For more information about the study, please contact the VS Area Office at (406) 449-2220.

* * * *

Subject: Public comment APHIS proposal
Friday, February 24, 2012 11:59 PM
From: "James Horsley"
To: EAComments@aphis.usda.gov

TO: Dr. Donald E. Herriott
USDA-APHIS Veterinary Services
ATTN: Evaluation of GonaCon EA
208 North Montana Avenue
Suite 101
Helena, MT 59601

FROM: James Horsley, 3431 15th Ave. S., Fargo, ND 58103

DATE: February 24, 2012


Millions of dollars are being spent annually on hazing, capturing, shooting and slaughtering members of the last wild herd of bison in the United States as they migrate from Yellowstone National Park into areas of Montana comprising a few square miles immediately adjacent to the park.

The park and its environs is where a few wild bison hid themselves to escape the massive slaughter of bison that occurred in the late 1800s at the time of the European settlement of the Midwest, which reduced the herds of buffalo from an estimated 30 million animals to a thousand. This remnant wild herd was able to survive in this remote hideout because of the geothermal pools, which offered protection during the winter. The Greater Yellowstone Ecosystem has been their home since they migrated here from the Old World to the New World 10,000 years ago.

Now the Animal and Plant Health Inspection Service (APHIS) is studying the feasibility of adding yet another weapon to its arsenal in the federal and state range war against bison, namely, the use of a new vaccine that would sterilize wild bison, treating them with GonaCon, a contraceptive developed by APHIS as a pesticide for the control of animal pests. It is designed to be administered by manual interjection with a syringe animal by animal after they have been corralled and tested in capture facilities. It would sterilize wild bison for several years.

The rationale for the use of this pesticide on bison is to protect grazing interests on public land surrounding Yellowstone National Park. Up to 40 percent of this herd is suspected to have the disease of brucellosis, which causes abortions in both bison and cattle. Cattlemen fear that brucellosis, although never transmitted in the wild from bison to cattle, may someday infect their herds.

This is just another needless expenditure of public monies. In addition, this new study and the eventual general use of GonaCon on bison has the potential of domesticating this last wild herd, taming this species into extinction, such as were aurochs, the wild ancestors of all cattle. As domestic cattle increased, the last remaining aurochs in Europe could not compete for grazing land with their fence-protected and selectively-bred progeny. The wild aurochs ended up being hunted and starved into extinction. This has left us with cattle which today no longer possess the physical qualities, such as size (they were six feet tall), nor the same instincts as their ancestors, such as aggressiveness and the instinct to migrate.

This study seeks to continue a practice of providing grazing land on national forest land. This practice should be retired, not encouraged. Domestic livestock grazing is the most pervasive and damaging use of federal public lands. On public land across the West, millions of non-native livestock remove and trample vegetation, damage soil, spread invasive weeds, despoil water, deprive native wildlife of forage and shelter and accelerate desertification. This is especially unacceptable in the Greater Yellowstone Ecosystem, which is one of the last remaining large, nearly intact ecosystems in the northern temperate zone of earth and serves as a wildlife laboratory.

Publicly and privately grazed cattle to the north and west of Yellowstone that could be directly affected by bison with brucellosis are estimated to total about 2,019 cow-calf pairs. They comprise less than 4% of the cattle population of both Gallatin and Park Counties, the two counties in Montana that surround the northwestern corner of Yellowstone National Park, according to "Impacts on Livestock Operations" by the National Park Service (Yellowstone National Park, 2012). These two areas contain public cattle grazing allotments just outside the park to the north in Gardiner Basin and to the west in the West Yellowstone area.

Not only does livestock grazing in wildlife areas degrade these preserves, but they cost the taxpayer millions of dollars. The Government Accountability Office reported that the Bureau of Land Management and Forest Service annually spend $132.5 million on grazing management, but collect only $17.5 million in grazing fees for a net loss to taxpayers of $115 million.

Within the Greater Yellowstone Area (GYA) alone, federal and state governmental agencies annually spend millions of dollars on the management of these grazing areas that comprise a few square miles of territory. Because bison migrate to these areas when winters are severe and because their instincts heed no boundaries, they routinely enter these killing fields, their historic winter ranges, being decimated often at the rate of 1,000 animals a year.

Public grazing is in conflict with the National Park Service's emphasis on preserving such ecosystems for present and future generations. As the nation's human population continues to grow, more fish and wildlife species have been put at risk by loss and fragmentation of critical habitat, disturbance and introduction of non-native species.

It is in further conflict with new rules instituted by the National Forest Service, which include an emphasis on the need to restore NFS land and waters and provide for ecosystem integrity and diversity. This effort includes the identification of "species of conservation concern" other than federally-listed threatened or endangered species, where substantial concern exists about the species’ capability to persist over the long term in the plan area. The new rules would include the development of a plan for their conservation.

Encouraging cattle growers to graze their stock on forest service allotments by offering government-subsidized grazing allotments at relatively low fees to ranchers is not encouraging preservation of the ecological integrity of the GYA In fact, the government is making every effort to set in motion processes that could lead to the genetic extermination of this last wild segment of the American bison here in the United States.

The major objectives of the proposed study are to evaluate GonaCon in B. abortus-infected female bison regarding its use as an immunocontraceptive vaccine, its effect on the shedding of the disease and its long-term survivability.

The hypothesis of the study is that the use of an effective immunocontraceptive such as GonaCon would prevent pregnancy, eliminate the potential for abortions by infected bison and break the cycle of transmission of brucellosis. If female bison infected with B. abortus do not become pregnant, they would not abort, so the reasoning goes. Exposure of non-infected animals to the infected tissues and fluids from aborted fetuses would therefore be reduced.

APHIS claims need for the proposed study is to provide information that would be used to evaluate the use of GonaCon as a nonlethal method of decreasing or controlling the risk of transmission of B. abortus in the YNP bison population. Brucellosis is spread within the animal population primarily through contact with infected birthing tissues or aborted fetuses and through the milk of infected cows, according to APHIS.

The agency reasons that if GonaCon can effectively render brucellosis-infected female bison temporarily infertile, the primary routes of disease transmission would be blocked. In combination with other appropriate disease mitigation activities, the use of GonaCon may be an effective tool to assist in eliminating brucellosis from the YNP bison herd over time, the agency said.

According to researchers Andres Dobson and Mary Meagher in a report published in Ecology (1996) titled "The population dynamics of brucellosis in the Yellowstone National Park," removal of bison is not a scientifically valid solution to the brucellosis problem in the park. The authors stated regarding their study that: "This analysis suggests one would need to almost eradicate the bison before one could produce significant reduction of prevalence. More significantly the levels of removal required to eradicate Brucella may be sufficient to drive the bison to extinction."

Further, according to the authors, "there is no guarantee that Brucella would not re-establish unless the bison population were kept at a very low level (<200). This is unlikely to be acceptable on ecological, ethical, or aesthetic grounds."

In addition, there is no direct knowledge of how brucellosis is in fact spread. In the study that triggered the brucellosis scare, its authors Donald S. Davis, et al. in “Brucella abortus in captive bison: serology, bacteriology, pathogenesis, and transmission,” the researchers did not identify the method of transmission of Brucella abortus-infected bison when penned with non-infected heifers, of which about half came down with the disease in that captive, non-wild setting, only saying that the animals were fed a common feed, as well as hay.

It could be anything, such as the bacteria present in the air or transmitted from fecal matter, bodily discharges on the common ground or in the food, licking of the infected placenta or vaginal areas, sniffing the infected fetus, nose to nose transmission or from the high concentration of the experimentally-injected bacteria in the host animal at a level not present in the wild.

APHIS is making an assumption that a reduction in contact with birthing fluids, due to a reduction in the number of births because of an increased rate of sterility among the herd, would correlate to a reduction of the disease.

Moreover, regarding vaccination in general, in the same study by Dobson and Meagher, the authors stated: "As brucellosis is likely to have a basic reproductive rate of around unity in Yellowstone, slightly more than 50 percent of the bison would have to be effectively innoculated if the Brucella is to be eradicated by vaccination. The low vaccine efficacy in bison and the logistics of having to treat this many animals suggest that it is unlikely that this level of vaccination coverage will be achieved."

According to APHIS, the proposed study would include capturing bison in the late winter and spring of each year up to 2014, transporting them by stock trailer to APHIS' bison facilities in Gardiner, Montana, collecting and evaluating blood samples to determine brucellosis infection status, housing and tagging the animals, injecting one group of seropositive female bison with GonaCon beginning in the spring of 2012, comingling uninfected bulls with females during breeding season, documenting breeding behavior, and testing for pregnancy for five calving seasons, monitoring pregnant bison with transmitters and daily observing them for abortions, labor and births, collecting and testing blood, milk and vaginal swabs from female bison that give birth, testing for brucellosis infection status, monitoring exposure to aborted fetuses by other bison, evaluating fetuses collected during the study and evaluating data collected from the study to determine whether GonaCon decreases the shedding of B. abortus in bison.

Bison for the proposed study would be acquired during the winter when they exit YNP. The capture of bison would be conducted by hazing or using hay as bait to move them to a capture facility. Approximately 104 adult bison would be used in the proposed study: 24 female bison that are seronegative for brucellosis, 72 female bison that test seropositive for brucellosis and 8 male bison that test seronegative for brucellosis.

Female bison would be yearlings, two-, and three-year-olds. If temporary chemical immobilization of any animal is needed, opioid narcotics and alpha-2-adrenergics would be used. All bison used in the study would be identified with numbered ear tags and microchip identification.

The proposed study would take place on several double-fenced pastures at facilities in the Gardiner, Montana area: the Brogan Bison Facility in Corwin Springs (60 acres), the Slip ‘n Slide pasture (25 acres), and the Rigler pasture (32 acres), all of which are located north of Gardiner, Montana. All sites are within the GYA and along Highway 89.

According to APHIS, the study design is as follows: In spring 2012, animals would be randomly selected to go into groups of 16 to18 seropositive cows, four to six seronegative cows, and two bulls. After three to four weeks of acclimation in the test pastures, B. abortus-infected female bison in one of the pastures would receive GonaCon™ vaccine delivered into the muscle on each side of the neck or hip. The sites of injection would be tattooed.

Bulls would be separated from the cows outside of the breeding season from October to July. Prior to exposure to bulls, cows would have breeding tags attached to them to document if bulls have mounted them to breed. Following first exposure of cows to bulls in 2012, five calving seasons would be observed (2013-2017). In February of each year, cows would be pregnancy-tested and fitted with vaginal transmitters to alert investigators to abortion or calving events.

During the abortion/calving seasons (from February until August of each year), daily observation for abortions, labor and calving events would be conducted by study investigators. Within five days of abortion or calving, the cow would be immobilized and blood, milk and vaginal swabs would be collected for testing. If possible, the calf would also be captured and eye swabs and blood would be collected for testing.

Following an abortion, the fetus would be left at the abortion site for 24 hours to monitor exposure to other bison. The fetus would then be collected, tested and incinerated at the Montana Veterinary Diagnostic Laboratory (MVDL) in Bozeman, Montana.

Blood testing of cows, bulls and calves would be conducted three times a year: in February, calving time, and in the fall. Blood would be analyzed at the MVDL and/or the National Veterinary Service Laboratories in Ames, Iowa throughout the study to determine B. abortus infection status of each animal.

Handling and physical restraint of bison for tagging or blood collection would take place in alleyways leading to standard bison manual squeeze chutes. Injection of the study animals with GonaCon would be done by study personnel experienced in administering intramuscular vaccines.

When the study is completed, all seropositive animals would be euthanized following American Veterinary Medical Association-approved guidelines, and specimens would be collected from each animal for laboratory analysis. In addition, eggs and semen would be collected from these animals, including vaccinated animals, and frozen for genetic conservation.

These animals would be disposed of by incineration or landfill burial.

At all three locations, the pastures are double-fenced with an 8-foot woven wire fence and an electric high tensile fence to contain the study bison.

Wilderness has a dignity similar to mankind. Wild animals resist domination. They thrive on freedom. We humans identify with wildlife in that regard and can find clues to our own nature in studying them, not only concerning their organic and chemical reactions, but also their emotional and behavioral components. We identify with animals, and wonder at the family relationships displayed by animals such as bison, who will not leave a fallen member of a herd as though in mourning and will nudge and try to revive them.

But do we have moral obligations to animals? Emmanuel Kant in Lecture on Ethics thinks that we do, at least indirectly:

"If a man shoots his dog because the animal is no longer capable of service, he does not fail in his duty to the dog, for the dog cannot judge, but his act is inhuman and damages in himself that humanity which it is his duty to show towards mankind. If he is not to stifle his human feelings, he must practice kindness towards animals, for he who is cruel to animals becomes hard also in his dealings with men. (Kant, LE, 240)"

There is thus something Nazi-esque--smacking of Josef Mengele's medical experiments at Germany's death camps--when one reads this proposal by APHIS.

A bison entering an APHIS capture facility is reminiscent of an entrance into a concentration camp, where the animals are corralled into 8-feet high, electrified double-fenced facilities, forced into squeeze chutes and tested, with females having vaginal swabs collected, tattooed, separated into separately penned areas, later allowed to comingle with bulls, observed and tagged for mounting, exposing and later evaluating collected fetuses, physically restrained in alleyways, where blood samples are taken, and finally euthanized.

One of the most alarming aspects of the study is the claim by APHIS that the animals would be collected randomly. This is a false assertion. Only those animals crossing the boundary of Yellowstone National Park would be collected for this study, that is, those bison who possess the migratory trait. APHIS is selecting out those with the gene to migrate, those bison who possess the requisite aggressiveness to protect themselves from starvation. In other words, the experiment by APHIS is putting the nation's last wild herd of bison on the same road to extinction that was followed by aurochs, where only the docile survived, that is, our cattle today.

The only sensible and tenable solution is to draw a cordon sanitaire around the Greater Yellowstone Area and ban the non-native cattle from this wildlife ecosystem.

Note: James Horsley, a resident of Fargo, North Dakota, is the author of a petition to list the YNP bison herd as endangered and to designate critical habitat in and adjacent to YNP. See http://www.fws.gov/mountain-prairie/pressrel/07-52.htm and peasantpress.com


FREE RANGE ELK, which have a brucellosis infection rate of up to 20 percent in the Greater Yellowstone Ecosystem, graze with horses here in Paradise Valley and other areas immediately outside Yellowstone National Park, yet only bison are banned from their historic migration range.

Originally, the boundaries of Yellowstone National Park were drawn to protect the geothermal pools, but as the two habitat maps below show, park borders do not contain most of the grazing land critical to sustaining large wild animals such as bison and elk during the winter months within the GYE. In heavy winters these animals have no other choice but to migrate to these lower range lands for forage. (shown in yellow).

Conclusion: the public should allow bison to return to their pre-settlement distribution range, which includes Paradise Valley and the GYE, and ban cattle from these wildlife areas to meet the demands of the cattle growers, namely, zero risk of burcellosis transmission.

Figure 1. Potential bison habitat in the Greater Yellowstone Area (GYA). Habitat class codes are described in Figure 2 below. Figures 1 to 3 from C. Cormack Gates, et al.,The ecology of bison movements and distribution in and beyond Yellowstone National Park: a critical review with implications for winter use and transboundary population management.

Figure 2. Habitat color codes used in Fig. 1 and 3.

Figure 3. Location of bison winter ranges and winter movement conditions in Yellowstone National Park. Habitat class codes are described in Figure 2. Red line indicates bison ranges and corridors. Figure 4. Map depicting Yellowstone National Park and the pre-settlement (area within broken line), mid-20th Century (light grey area), and current distribution (dark grey area) of Yellowstone bison. Pre-settlement distribution based on archived reports and journals of expeditions through area. From Glenn E. Plumb, P.J. White and Rick L. Wallen, National Park Service, and Michael B. Coughenour, Natural Resource Ecology Laboratory, Colorado State University, Carrying capacity, migration, and dispersal in Yellowstone bison. Biological Conservation 142 (2009) 2377-2387.
Figure 5. Map showing known locations of bison movement across boundaries of Yellowstone National Park. From The bison of Yellowstone National Park, Margaret Mary Meagher, 1973. Figure 6. Map showing principle known bison trails in the Wood Buffalo National Park, Canada (dotted lines). From History, Range, and Home Life of the Northern Bison, J. Dewey Soper, Ecological Monographs, Oct., 1941. Figure 7. THE CORRIDOR TO NOWHERE--Yellowstone National Park agreed April 19, 2008, to a down payment of $1.8 million to the Church Universal and Triumphant, plus additional payments of $76,500 per year for 20 years, totaling $3.3 million, for a 30-year narrow bison corridor easement (outlined in orange) and the removal of CUT’s small, recently acquired herd of cattle, according to the Yellowstone Buffalo Foundation. See Potential range of northern Yellowstone bison.This would allow 25 bison, tested and fitted with neck and vaginal electronic transmitters, to walk the easement. The animals must obey the strictures of the Interagency Bison Management Plan (IBMP) and stay within the boundaries of zones 1, 2 and 3, or be subject to lethal removeal. The corridor easment has been dubbed by some opponents as the "Corridor to Nowhere." EXTINCT PLEISTOCENE ANIMALS once roamed North America 11,000 years ago. Pictured from left are the mastodon Mammut americanum; Castoroides, a giant beaver the size of a modern black bear; the giant bird Teratornis; the wooly mammoth, Mammuthus primigenius; the woodland musk ox Bootherium; the extinct bison Bison crassicornis; Smilodon, a saber-toothed cat; a dire wolf, Canisdirus; horses of the modern genus Equus; Megatherium, a giant ground sloth; an armored glyptodont, Glyptodon; and the extinct American camel Camelops. From Rudolph F. Zallinger’s mural “The Age of Mammals,” showing reconstructions of Pleistocene mammals.

Brucellosis in elk

Figure 8. Map showing the boundaries of the Wyoming and Montana, USA, elk (Cervus elaphus) herd units (gray polygons), supplemental elk feeding grounds (circles), Greater Yellowstone Ecosystem (GYE, light gray), and the area occupied by the Idaho Sand Creek elk herd.

According to Probable causes of increasing brucellosis in free-ranging elk of the Greater Yellowstone Ecosystem by P.C. Cross, et al.:

Bison in Yellowstone National Park (YNP) tend to have high seroprevalence, roughly 50%..., and to prevent the spread of brucellosis to cattle approximately 40% of the Yellowstone bison population was lethally removed in 2008. Data on the recent cattle infections are scarce, but elk are considered the most likely source due to the lack of contact between the infected cattle herds and bison. Elk are supplementally fed at 23 sites in Wyoming [Figure 7] resulting in dense aggregations at the time when elk are likely to transmit the infection via abortion events in late winter and early spring. Historically, the brucellosis seroprevalence in elk was 10–30% at these feeding grounds, but only 2–3% in other elk populations around the GYE. Brucellosis is not known to persist in elk populations outside the GYE.

According to , Mapping Brucellosis Increases Relative to Elk Density Using Hierarchical Bayesian Models, also by Cross:

In the southern portions of the GYE, elk are supplementally fed during winter at 23 feeding grounds. Brucellosis seroprevalence in elk using supplemental feeding grounds in winter varies from 10–35% while unfed elk populations around the GYE historically had brucellosis seroprevalence values of 2–4%, and brucellosis was not known to persist in elk populations outside the GYE. The supplemental feeding grounds are intended to prevent the movement of elk onto agricultural land and thus minimize contact between elk and cattle during winter. A by-product of this management activity is increased aggregation of elk between November and April. Until recently, there was a consensus that B. abortus is not self-sustaining in unfed elk populations, but recent research suggests that some unfed elk populations now maintain brucellosis at a seroprevalence of greater than 10%.

PUBLIC LAND GRAZING FEES--10 TIMES CHEAPER THAN PRIVATE LAND. The fee for grazing the 234 million acres of public lands in the West, such as the National Forests and the Bureau of Land Managment lands, was $1.35 per cow, per month--also know as per animal units month (AUM). If the fee had been adjusted for inflation, the rate would be $5.94 per cow. Further the average weight per cow increased between 1984 and 2004 by 23 percent, representing an increase in forage consumption. A report by the Government Accountability Office in 2005 showed that BLM and Forest Service grazing receipts fell short of their expenditures on grazing by almost $115 million. See Federal government releases public-lands grazing fee for 2008.

On the other hand, private grazing rates across the Western U.S. climbed more than 5% for the 12 months through January to $14.50/animal unit month (AUM). See Where will it end?

Ranchers with permits to graze cattle on Federal land (permittees) enjoyed higher net earnings than ranchers without such permits (nonpermittees), both per cow and per hundredweight (cwt) of cattle sold. Much lower permittee costs for harvested forages and rented pasture accounted for the overall lower cash costs, according to the US Department of Agriculture's Economic Research Service report Cow/Calf Ranching in 10 Western States.
PERCENTAGE OF BEEF produced from federal rangelands is less than 3 percent, according to P. Rogers' "Cash cows," San Jose Mercury News (Nov. 7, 1999).

TAX-PAYERS ARE BEING ASKED TO PAY MILLIONS OF DOLLARS to force wild bison off their historic migratory ranges so that a few head of cattle can graze here, instead. The black shadded areas represents the few square miles outside the park into which bison move during winter and calving seasons. For a keyed color-coded table of the area refer to private and public lands with cattle north and west of the Yellowstone National Park boundary.