| Endangered
Species Act Talking Points & Supporting Science to List
Yellowstone Bison as an Endangered Population in their Native
Range:
U.S. Fish & Wildlife Service's finding
does not consider how and by what migratory routes bison originally
occupied the Yellowstone Plateau. This is a critical discussion
- missing from their finding - regarding the native range
of wild bison in the Greater Yellowstone ecosystem. Without
this discussion, the American people have no way to independently
judge whether bison are endangered within all or a significant
portion of their native range.
Dr. Mary Meagher, Yellowstone National Park's bison biologist
for more than 30 years, believes that 10,000 years ago at
the end of the last Ice Age, glacial retreat opened up range
for bison migrating from surrounding river valleys who followed
plant green up to the Yellowstone Plateau (Gates et
al. 2005). Yellowstone's unique geothermal features
opened winter range for bison to occupy habitat year round
(Meagher 1973).
Archeological investigations suggest large numbers of bison
occupied the Greater Yellowstone region (Cannon 2001)
and that climatic regimes played an important role in bison
distribution, seasonal migration and abundance (Cannon
1997).
From Yellowstone's gateway community in Gardiner to Livingston
Montana, Paradise Valley is one of several river valleys with
documented bison jumps and other archaeological evidence of
bison inhabiting range that the U.S. Fish & Wildlife Service
did not consider as historic range in its finding:
"The Lamar Valley and the Yellowstone River Valley north
of the park (Figure 4.1) to Livingston and beyond was an important
area for bison and Native peoples throughout the Holocene.
This system can be considered the original Northern Range
for Yellowstone bison, functioning as an ecological continuum
of grasslands that likely supported seasonal migrations by
bison as far south as the high elevation ranges in the Upper
Lamar Valley. Davis and Zeier (1978:224)
described the lower Yellowstone Valley as an exceptional area
for Native people to gather, drive and kill bison. Eight bison
jumps and three kill sites have been documented south of Livingston.
The closest jump site to YNP is 25 km north of the park boundary.
It was used during the late prehistoric period between 1,700
and 200 b.p. (Cannon 1992). There is evidence
of a human use corridor from the Gallatin and Madison River
drainages into the interior Yellowstone National Park. Several
major bison kill sites are located in the Gallatin Valley
outside of Bozeman Montana." (Gates et al. 2005)
U.S. Fish & Wildlife Service's finding
fails to consider the biology and natural ecology of bison,
their nomadic nature and migratory instinct, knowledge and
memory of destination, and the evolutionary significant characteristics
of a wild bison herd.
The bison is a land-intensive species that once roamed over
great distances (Boyd and Gates 2006). Long
distance migration, what defines wild bison as a nomadic,
herd animal that once thundered across the plains, is in danger
of being lost forever.
Berger (2004) examined the
"ecological phenomena" of accentuated treks of native
ungulates in Yellowstone and found that 100% of historic and
current routes for bison have been lost.
Bison corridors and habitat on National Forest lands in the
Madison, Gallatin and Yellowstone river valleys exist (Jourdonnais
2006; Lemke 1997; Lemke 2006) but the US Forest Service
does not manage habitat for wild bison despite its stated
forest plan goal of providing “habitat for viable populations
of all indigenous wildlife species…” (Gallatin
National Forest Land and Resource Management Plan, PAGE II-1,
1987).
For bison migrating onto Gallatin National Forest lands from
Yellowstone National Park, the State of Montana’s hunt,
capture and slaughter regime awaits them (Bison Management
Plan for the State of Montana and Yellowstone National Park
2000; Interagency Bison Management Plan 2000).
Migratory corridors and natural selection of habitat is critical
to maintaining the bison herd’s habitat and genetic
fitness, and making a sound determination on the bison's native
range in Yellowstone.
The U.S. Fish & Wildlife Service
also fails to consider that wild bison as a native wildlife
species are at risk of genomic extinction.
Greater than 95% of the 500,000 bison in North America today
reside in private ownership (Boyd 2003).
Less than 1.5% of bison are genetically Bison bison
(Freese et al. 2007). Forced cattle-bison
breeding experiments to commercially exploit survival attributes
of wild bison resulted in widespread introgression of cattle
genes in private and public bison herds (Polziehn
et al. 1995; Ward et al. 1999; Schnabel et al. 2000; Halbert
2003; Halbert and Derr 2007).
Current genetic studies identified only 3 genetically pure
bison populations: Yellowstone, Wind Cave and Grand Teton
(Halbert 2003). In the United States, only
one wild bison population has continuously occupied their
native range since prehistoric time: the Yellowstone bison
(Gates et al. 2005).
Loss
of genetic diversity stemming from the near extinction of
the species (Boyd and Gates 2006) coupled
with extreme loss of historic bison range (Hornaday
1889; Boyd 2003), raises the risk of ecological extinction
for wild bison (Freese et al. 2007).
The extensive prevalence of cattle genes in bison populations
(Polziehn et al. 1995; Ward et al. 1999; Halbert 2003),
habitat fragmentation, loss of natural habitats and isolated
populations (Boyd 2003), limited range and
population sizes, artificial selection, intensive management,
unnatural confinement to fenced ranges, absence of predators,
introduction of non-native disease (Freese et al.
2007) are some of the risk factors of ecological
extinction that the U.S. Fish & Wildlife Service failed
to consider in its finding.
Curtis Freese along with several scientists write: "Small
herd size, artificial selection, cattle-gene introgression,
and other factors threaten the diversity and integrity of
the bison genome. In addition, the bison is for all practical
purposes ecologically extinct across its former range, with
multiple consequences for grassland biodiversity. Urgent measures
are needed to conserve the wild bison genome and to restore
the ecological role of bison in grassland ecosystems."
(Freese et al. 2007)
"Today, the plains bison is for all practical purposes
ecologically extinct within its original range." (Freese
et al. 2007)
The U.S. Fish & Wildlife Service
utterly failed to discuss the ecological importance of bison
and the vital, keystone role they play in maintaining ecosystem
health and function. Congress had intended that the Endangered
Species Act protect not only endangered species but the ecosystem
they reside in: "to provide a means whereby the ecosystems
upon which endangered species and threatened species depend
may be conserved."
http://www4.law.cornell.edu/uscode/html/uscode16/usc_sec_16_00001531----000-.html
Extirpation of bison from their native range is an indicator
that the prairie ecosystem they played a part in forming is
also at risk of extinction (Knapp et al. 1999).
“Knowledge
of the bison’s role in tallgrass prairies is lacking
because the extent of this grassland and the abundance of
its dominant ungulate have declined dramatically and in tandem
over the last 150 years.” (Knapp et al. 1999)
"Bison were a keystone species of the prairie ecosystem;
significantly affecting the way the prairie grassland ecosystem
evolved and playing an important role in maintaining it. Wild
bison remain ecologically extinct in Montana. The State of
Montana Department of Livestock has prevented the natural
dispersal of wild bison into Montana from Yellowstone National
Park because of disease issues while no attempts are underway
to restore the species outside of this controversial region.
Current management of private, state and Federal bison herds
is leading towards domestication of bison that threatens their
wild character and limits important natural selection processes."
(Wildlife Society 2000)
Grazing
by bison can reverse the loss of native grassland species
and the disruption of grassland ecosystem structure and function
caused by their extirpation (Collins et al. 1998).
The U.S. Fish & Wildlife Service
puts great faith in the "contingency measures" of
the Interagency Bison Management Plan and its "successful
management" to prevent the loss of the Yellowstone bison
population.
The on-going slaughter of large numbers of wild bison by the
state of Montana and U.S. National Park Service may threaten
the genetic viability and integrity of the Yellowstone bison
herd's subpopulation structure (Halbert 2003).
Scientists have identified distinct breeding grounds that
help maintain genetic diversity within the Yellowstone bison
herd (Gardipee 2007; Olexa and Gogan 2007).
However, there is no evidence that the interagency plan has
considered bison subpopulation structure in its management
decisions and actions.
"The current practice of culling bison without regard
to possible subpopulation structure has potentially negative
consequences of reduced genetic diversity and alteration of
current genetic constitution both within individual subpopulations
and the overall YNP bison population." (Halbert
2003)
"Since bison are known to naturally assemble in matriarchal
groups including several generations of related females and
the most recent calf crop (Seton 1937; Haines 1995), it is
possible that the culling of bison at the YNP boundaries is
non-random with respect to family groups, a practice that
over sufficient time may lead to systematic loss of genetic
variation." (Halbert 2003)
"The caveat, however, is that caution must be practiced
in the management of populations with substructure to ensure
the maintenance of both subpopulation and total population
variation. The YNP bison population has not previously been
managed with this consideration in mind. For example, 1,084
bison were removed from YNP in the winter of 1996-97, representing
a 31.5% decrease in total population size. Even more troubling,
however, is the inequality in the reductions across the Northern
and Central herds. While the Northern herd suffered a loss
of approximately 83.9% (726/825), the Central herd was reduced
by only around 13.9% (358/2,571; Peter Gogan pers. comm.).
If in fact the Yellowstone bison population is represented
by 2 or 3 different subpopulations, disproportionate removals
of bison from various subpopulations might have detrimental
long-term genetic consequences." (Halbert 2003).
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