UP! COMMENT TO HELP YELLOWSTONE'S WILD BISON & ELK!
Bovine Brucellosis Program
due by December 4, 2009*
Field Campaign Comments | Gallatin
Wildlife Association Comments
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
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
* 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
* 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.
APHIS will accept public comments online
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
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!
|FAQ about the yellowstone buffalo slaughter