Public Comments Needed to Stop Intrusive Vaccination
Animal and Plant Health Inspection Service (APHIS) has
recently released an Environmental Assessment (EA) regarding
its intrusive and unnecessary plans to vaccinate members
of the Yellowstone herd with RB51, a livestock vaccine
that has been demonstrated to be ineffective in buffalo.
Under the proposed plan, yearlings and calves who leave
the park will be vaccinated.
The USDA has already determined that no significant
impacts will result from this intrusive government action,
but you still have time to comment.
A copy of the Finding of No Significant Impact (FONSI)
and EA can be found on the Internet at:
or you can contact the USDA and ask to be on the mailing
list for "Docket no. 03-112-1". You can request
copies of the EA and FONSI by email at: email@example.com
Because the public comment period is so short (comments
must be submitted by January 5, 2004) it is imperative
that buffalo supporters from around the world rally
today and write letters.
Write to APHIS and ask them to choose the no
To assist you in preparing comments we have compiled
the following list of talking points:
1. The Yellowstone herd is a cultural
and biological treasure, being the only herd to continuously
occupy its native range in the wild. Vaccines, including
RB51, are a tool designed for use in livestock, not
wildlife. Rather than focusing on Yellowstone's wild
bison, efforts should be directed at cattle herds. The
process of subcutaneously injecting yearlings and new-born
calves with the RB51 strain of brucellosis--and the
attendant stress such procedures will have on the animals--will
further erode the wildness of the Yellowstone herd at
a tremendous cost.
2. The EA ignores the latest science
to hide the fact that the RB51 vaccine is not effective
in bison. According to a recent peer-reviewed study*,
"It was determined that RB51 did not confer significant
protection in the vaccinated animals. In terms of abortions
and infections, the RB51 bison vaccinated with three
injections did not differ significantly from the non-vaccinated
The authors of the EA admit as much on page 9 when they
write, "efficacy [of RB51] in bison has not been
*Davis, D.S. and Elzer, P.H., 2002, Brucella Vaccines
in Wildlife, Veterinary Microbiology (90):533-544.
3. The vaccination of buffalo outside
the park with an ineffective vaccine will not eliminate
brucellosis from the herd. Because the disease has little
effect on buffalo and because wild buffalo have never
transmitted brucellosis to livestock, efforts should
be focused on cattle.
4. Bison yearlings and calves are generally
only present outside the western boundary of Yellowstone
in the spring during calving season. The EA does not
discuss the efficacy or impacts of vaccinating newly
born bison within hours, days or weeks of birth. Neither
does the EA address the impact of capturing newborn
calves, vaccinating them, and releasing them without
5. The EA fails to adequately address
the proposal's impact on Native Americans, who have
an age-old and complex relationship with buffalo. Many
Native American individuals and organizations consider
the buffalo as kin, and find the repeated capturing,
testing, vaccinating, and tagging of bison unacceptable.
Such intrusive measures affect the sacredness of buffalo
by treating them as livestock.
6. Yellowstone buffalo are not domestic
animals. Because neither APHIS nor Montana Department
of Livestock personnel are trained in wildlife management,
they have no place meddling with the fate of the Yellowstone
herd and eroding their wildness through vaccination.
Comments may be sent through the postal service or email.
If you submit them through the mail, please send four
copies (an original and three copies) to:
Docket No. 03-112-1
Regulatory Analysis and Development, PPD
APHIS, Station 3C71
4700 River Road, Unit 118
Riverdale, MD 20737-1238.
Please state in the body of your comments that they
refer to Docket No. 03-112-1.
If you email your comments, send them to <firstname.lastname@example.org>.
Comments must be contained in the body of your message;
do not send attached files. Include your name and address
in your message and "Docket No. 03-112-1"
in the subject line.
Update From the Field
the killing of the bull buffalo by DOL agent Shane Grube
on November 24, most of our buffalo friends have been
staying within the boundaries of Yellowstone National
Park. BFC patrols on Fir Ridge have counted as many
as 32 buffalo in the meadows adjacent to the Park boundary
and the Duck Creek capture facility. We have also continued
to see and hear evidence of wolves in the area. Several
mornings ago, our Fir Ridge patrol noticed several sets
of buffalo tracks leading into Dale Koelzer's property
where the trap sits. The tracks entered through the
gate and went about ten feet down the fence line to
where the buffalo had been shot only two weeks ago.
Blood still stains the snow on the spot where he fell.
The buffalo, seemed to pay homage to their fallen brother,
then turned around and went back into the Park.
the smell and awareness of the fate of this buffalo
bull may keep the others at bay for a while, it will
only be a matter of time before many of them will wander
west in search of easier forage. Just today, the DOL
has began plowing Forest Service Road 610 that leads
to where the Horse Butte capture facility will soon
be erected. Both the DOL and the Park Service are gearing
up for a big year of killing buffalo as the animals
search for food outside of the Park's borders.
As of today, we are running a bare-bones operation here
at camp. Twelve or so volunteers have been tirelessly
going out to defend the buffalo every day while also
keeping up with all of the other tasks we need to do
to sustain ourselves from day to day. If you have been
thinking of coming to join us, now is a great time to
do it. For more information on volunteering with BFC,
please call 406-646-0070 or e-mail Amy buffaloatwildrockies.org.
For the buffalo,
Hosts Denver School Group
The BFC recently had the privilege to introduce twelve
students and five teachers from Denver's PSI school
to the Yellowstone buffalo. The students, ranging in
ages from eleven to eighteen, came to Montana for an
educational field trip. For all of these kids, coming
to the wilderness of Montana was a first that they will
remember for years to come. Their teacher had heard
about the buffalo issue and decided it would be a great
learning experience for the kids and adults. In August,
the BFC road show visited PS1 in Denver where we gave
them an introduction to the buffalo issue and were their
guests on a field trip through downtown Denver.
The students arrived Monday evening. They checked out
the Montana stars and tried to prepare themselves for
their three days at the Buffalo Field Campaign. The
kids woke up early Tuesday morning and got ready for
patrol. BFC volunteers accompanied PS1 on Fir Ridge
patrol. We hiked along the park boundary looking for
buffalo and viewed the Duck Creek capture facility.
Upon returning to camp they watched some video footage
of hazing operations and bison in the capture facility.
The morning patrol and the video filled them all with
questions and concerns.
The PS1 crew and BFC volunteers traveled to Gardiner,
MT on Wednesday morning. There we met with our friends,
Dave and George. On our drive into the Park, two wolves
crossed the road in front of us. Bighorn sheep were
rutting high up on the ridge and herds of buffalo and
elk were plentiful on our drive out to the Lamar Valley.
We ended our amazing day in the Park with a soak in
the Boiling River.
Thursday was the students' last day in Montana. They
had prepared questions for Park and Forest Service officials
after going on patrol and viewing the video footage.
They met with officials from both agencies and experienced
some of the frustration that we all feel when asking,
"Why is this happening?" The kids had some
great questions and more than once the left the rangers
speechless. That evening we all gathered around a campfire
to share stories and eat s'mores.
PS1's visit was a positive experience for everyone involved.
It was wonderful to empower these kids to do something
about the things they feel are unjust. They left with
a new understanding of how their actions, even in far
away Denver, can have a positive impact. PS1's visit
marks the second year in a row that BFC has hosted public
school kids at camp. Last February, the Sojourner school
from Boulder, Colorado, arrived just in time to witness
the capture of 10 bull buffalo by the DOL and a school
from Seattle, Washington, were witness to DOL hazing
operations on Horse Butte last April. We hope to have
many more students visit the BFC both for their benefit
and for the future of the buffalo. For more information
or to set up a trip for your school, please contact
Amy here at camp by phone (406) 646-0070 or e-mail buffaloatwildrockies.org
DOL and Local Law Enforcement Criminalize Good
Citizenship of the West.
On Thursday, December 4, 2003, a BFC volunteer and a
woman on a research study mission from Austria were
arrested and charged with criminal trespass. The two
are accused of closing a cattle gate that borders National
Forest lands adjacent to Yellowstone National Park.
The gate belongs to Dale Koelzer, who leases land to
the DOL for operation of the Duck Creek Capture Facility.
Upon arriving to the area, DOL officer Shane Grube noticed
that the gate had been closed. He called in the cavalry
to investigate this "crime," bringing in law
enforcement agents from Gallatin County, the National
Park Service, and the U.S. Forest Service. The agents
allegedly matched footprints found near the fence with
the Austrian woman and the BFC volunteer. Both were
subsequently arrested by Gallatin County Sheriff, Rob
Burns, and taken to the West Yellowstone police station.
In a statement made to the police, the Austrian woman
said that she did in fact close the gate, but that the
BFC volunteer was not there at the time and was unaware
of her action. She told Burns that it is customary and
expected of people in Austria to close open livestock
gates. There were horses in the adjacent pasture at
the time. Burns still insisted that both still be charged
with criminal trespass. A preliminary hearing has been
set in the Gallatin County Justice Court for Friday,
December 12. We will keep you updated as to how these
"criminals" fare in the Montana "justice"
"Yellowstone is not a ranch. It was never intended
by Congress to be a ranch."
--Mike Finley, former Superintendent, Yellowstone National