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Bovine Brucellosis Program
*Comments due by December 4, 2009*
Buffalo Field Campaign Comments | Gallatin Wildlife Association Comments
The government is considering a new Bovine Brucellosis Program that continues to cater to livestock interests and again fails wild bison and elk. One of the Interagency Bison Management Plan partners, USDA Animal & Plant Health Inspection Service (APHIS) has put forth a concept paper, which they intend to turn into a regulatory program.

YOUR COMMENTS ARE NEEDED to help wild bison and elk in the Greater Yellowstone Ecosystem. APHIS is accepting comments through December 4, 2009, but please be sure to send yours as soon as possible and encourage your friends to join us in this effort.

HERE'S THE SCOOP: The US Dept. of Agriculture's Animal and Plant Health Inspection Service (APHIS), one of the agencies behind the slaughter of more than 3,600 wild bison in the past 10 years, is planning to create a new set of rules for brucellosis, the cattle disease upon which the bison slaughter is blamed. APHIS is accepting public comments until December 4th, 2009.

A Concept Paper for a New Direction for the Bovine Brucellosis Program outlines the thinking of the ranching industry and animal health bureaucracy on eradicating brucella abortus from native bison and elk populations in the Greater Yellowstone area (GYA). APHIS also aims to update its brucellosis rules for cattle ranchers within a yet to be drawn "designated surveillance area" in Idaho, Montana, and Wyoming. Surveillance boundaries will be set by each state and part of its purpose is "surveillance, prevention, and disease management in elk and bison."

As APHIS lacks legal authority over wildlife it seeks to "partner" with states and federal land management agencies like the U.S. Department of Interior to potentially vaccinate and deliver contraceptives to reduce the "prevalence" of brucellosis in elk and bison.

APHIS states: "Eradication depends on finding the last remaining brucellosis-reactor animal, the last remaining brucellosis-affected herd, and eliminating the disease from wildlife reservoirs. All potential risks for exposure and transmission of brucellosis from infected wildlife populations must be mitigated and eliminated as well. Currently, the last known reservoir of disease is the wildlife populations in the GYA."

There is currently no way to eradicate brucellosis without killing tens of thousands of elk and America's last wild bison that inhabit millions of acres in the ecosystem. And there is no future guarantee that cattle or another source could re-infect native wildlife again.

Entirely missing from the livestock industry's narrative is the fact that brucellosis originated in European and African livestock imported into the United States that eventually spread to and infected native elk and America's last remaining wild bison.

BFC reviewed APHIS' concept paper and we have put together suggested talking points to your government.

You should be sure to personalize and elaborate to make them your own:
* Remaining wild elk and and native bison populations in the Greater Yellowstone ecosystem are irreplaceable. These native wildlife species belong to the American people and are part of our cultural heritage. The public trust responsibility for protecting native wildlife must *not* be compromised for the sake of disease eradication programs that are costly, intrusive and likely to fail.

* Protecting native wildlife species as wild, native species needs to come first. Vaccination, capture, blood testing, and slaughter are techniques developed in and for the livestock industry and are *not* acceptable management practices for native wildlife.

* Natural resistance to brucellosis in native bison and elk is poorly understood by scientists. Nutrition is key to wildlife's natural resistance to disease infection. A high priority for funding should be placed on habitat conservation and acquisition to meet the foraging needs of native wildlife including protection of migration corridors permitting free dispersal of migratory species across the landscape.

* The U.S. government must impose a ban on the artificial or supplemental feeding of native elk and bison by state wildlife agencies and stop its complicity in permitting these activities on National Forest and Bureau of Land Management lands. These taxpayer funded practices unnaturally congregate wildlife and are widely viewed by scientists as vectors for disease including Chronic Wasting Disease for elk and deer.

* Given the profound ecological damages caused by grazing livestock on public lands, the U.S. government should phase-out and retire cattle grazing allotments in known elk and bison ranges to provide habitat for native wildlife and reduce co-mingling with cattle that harbor diseases dangerous to native wildlife.

* Current vaccines including RB 51 were designed for domesticated cattle and *not* for native wildlife species. Hence, current vaccination programs of elk and bison is ineffective at conveying immunity. Furthermore, no effective field delivery system exists resulting in native wildlife being captured for vaccination and subject to stress, injury, and death.

* Brucellosis in cattle is a localized issue. Properly fencing and vaccinating cattle is a prudent step for ranchers to implement in known elk and bison ranges. Depopulating entire cattle herds is an inappropriate APHIS requirement when individual cattle are found to be infected with the disease.

Read a list of citations BFC used for supporting information.

You can read the document online here. Please feel free to email us with any questions, comments, or suggestions you have.

TAKE ACTION: APHIS will accept public comments online here.


You can mail your comments through the postal service. APHIS requests that you send two copies. If you choose this route, please mail your comments to:

Docket No. APHIS-2009-0006
Regulatory Analysis and Development
Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238.

*Please state that your comment refers to Docket No. APHIS-2009-0006.

Unfortunately, APHIS is not providing an email address to send comments to, nor even a contact person. It would be a good idea to mention your frustration with this, and you might want to mention to APHIS that they need to inform the public of the designated personnel in charge of the comment process, which they have failed to do

FOR FURTHER INFORMATION CONTACT: Dr. Lee Ann Thomas, Director, Ruminant Health Programs, VS, APHIS, 4700 River Road Unit 43, Riverdale, MD 20737-1231; (301) 734-6954.

Thank you so much for taking the time to make your voice heard for our last wild buffalo herds!

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