| Buffalo Field Campaign- Science
|
Montana
Department of Livestock Plan to Vaccinate Wild Bison
12/05/04-
Livestock department proposes vaccinating bison that leave
Yellowstone
See News Article 12/10/03-
U.S. proposes plan to vaccinate bison
See Update from the Field 12/12/03-
Agencies Plan Intrusive Vaccination Program
|
| Vaccination
Program | Talking points |
Environmental Assessment (PDF) | BFC
Comments |
The
Montana Department of Livestock (DOL) released an Environmental
Assessment (EA) (Click here to read the EA,
it's a PDF) for brucellosis vaccination of captured calf and
yearling buffalo. The DOL plans to hold the buffalo in their
capture facilities and inject them with RB51, a vaccine designed
for domestic cattle and proven ineffective in buffalo.
The DOL claims that the vaccination program will help reduce
the risk of brucellosis transmission by reducing brucellosis
exposure in the buffalo. However, even by their own best
estimates, vaccination will only result in reducing exposure
rates from 45 percent to around 30 percent after 15 years of
the program.
The DOL has been clear in stating that as long as any brucellosis
is found in the Yellowstone buffalo, they will not be welcome
in Montana. So we begin to wonder, who will benefit from
the vaccination program? Certainly not the buffalo.
They rarely suffer the consequences of brucellosis. They
will continue to be slaughtered as they search for food in the
winter and spring, and will continue to suffer the consequences
of capture and torture even when they test negative for brucellosis.
Wild buffalo that are eventually released will be pinned with
permanent metal ear tags. All of these actions seriously
degrade their wild character, and none of these actions are
to benefit the buffalo.
DOL's vaccination program is nothing more than a smoke-screen
for the continued, perpetual capture and slaughter of America's
last wild buffalo as they migrate across the invisible and arbitrary
boundaries of Yellowstone National Park. Vaccination of
the wild Yellowstone buffalo serves only to benefit the livestock
industry and their foot-soldiers from the Montana Department
of Livestock who will carry out the program.
Please take the time to send your comments to the DOL and urge
them to choose the "no action" alternative.
Written comments are due by Jan. 5, 2005.
Comments can be mailed, faxed or emailed to Karen Cooper, Information
Officer, Montana Department of Livestock, PO Box 202001, Helena,
MT 59620-2001, fax number 406-444-4316, email address Livcomments@state.mt.us.
We encourage you to include the
following points in your comments,
and please speak from your heart.
* The Department of Livestock should focus their time
and energy on cattle, as is their mandate. The vaccine
they propose to inject buffalo with was developed for use in
cattle, not wild buffalo. Further, the vaccine does not
work, and the Interagency Bison Management Plan, which the DOL
helped to write, states that vaccination will not be used until
a "safe and effective" vaccine is available.
* The DOL has stated in their EA that their main focus
is to reduce the risk of brucellosis transmission. To
date, there has never been a documented case of wild buffalo
transmitting brucellosis to domestic cattle. Further,
elk and other wildlife also carry brucellosis, yet they are
not targets of such cruel harassment. If the DOL wants
to further reduce the risk, it should focus management on cattle.
Two simple suggestions include fencing in cattle and grazing
steers instead of cows where buffalo are known to roam.
* Vaccinating wild buffalo drastically degrades their
wild character. Visitors to the Yellowstone area will
be none-too pleased with the DOL when they see these wild animals
marked with ear tags. Yet these markings will not prevent
the DOL from capturing the same buffalo again - vaccination
will not prevent buffalo from being hazed or captured.
* RB51 is not effective in preventing either miscarriage
or infection in buffalo. Based on the rarity of brucellosis-related
abortions and the low rate of actual brucellosis infection in
Yellowstone buffalo, how effective will the vaccine actually
be in reducing the risk of brucellosis transmission? Ask
the DOL to provide some real numbers about how the vaccine will
reduce the risk of brucellosis transmission.
* Ask the DOL to provide a cost-benefit analysis that
includes the costs of implementing the entire vaccination program
(research, environmental analysis, operations, and follow-up
over the ten years of the program) and the benefits (expected
reductions in bison management expenditures), tourism revenue
due to the presence of free-ranging buffalo in Montana?)
Ask the DOL in detail how the buffalo will benefit from vaccination.
* The EA is inadequate in that there are only two alternatives
analyzed: action and no action. The EA should include
an analysis of alternative means to achieve the goal of reducing
the risk of transmission between bison and cattle. In
fact, the EA contends that the only reason to initiate the program
is that it will potentially reduce the risk of transmission.
Are there other programs the DOL could develop that would be
more cost-effective in reducing the risk of brucellosis transmission
(How about adapting the herd management plans for the cattle
that graze near Yellowstone by making them "brucellosis
proof")
Thank you for taking the time to make your voice heard! |
Buffalo
Field Campaign Vaccination Comments
Josh Osher
Buffalo Field Campaign
P.O. Box 957
W. Yellowstone, MT 59758
January 4, 2005
Karen Cooper, Information Officer
Montana Department of Livestock
PO Box 202001
Helena, MT 59620-2001
RE: Bison Vaccination Environmental Assessment
Ms. Cooper:
Please accept these comments on the proposed bison vaccination
plan on behalf of myself and the Buffalo Field Campaign. Please
include these comments in the public record and keep me informed
of any action on this and other proposals pertaining to bison
management by the Department of Livestock.
Please choose the “no action” alternative.
1. Vaccination of bison calves and yearlings captured
in the Western Boundary Area is not likely to result in the
reduction of the exposure rate to brucella bacteria in wild
bison originating from Yellowstone National Park (YNP):
The Department’s analysis fails to show any conclusive
data to relate the studies of potential efficacy conferred by
the RB51 vaccine in laboratory studies to the wild bison that
migrate into Montana from YNP. The laboratory studies did not
include bison that exhibit similar characteristics to Yellowstone
bison. Based on evidence from culture tests conducted on slaughtered
Yellowstone bison that tested positive for exposure to brucella
bacteria, it is clear that only a small percentage of the test
positive animals were actually infected with brucella. The Department
claims that vaccines can “enhance the immune response
capability to ward off and infection when the animal is exposed
and thereby increase the level of bacteria required for an infective
dose.” What is the natural “immune response capability”
of Yellowstone bison? What is the level of bacteria of a typical
exposure in Yellowstone bison? How does this compare to the
challenge strain in the laboratory studies? What is the primary
means of exposure between bison in YNP? Do Yellowstone bison
have a genetic characteristic that confers immunity to a portion
of the population? The Department continues, “Because
abortion is the major mechanism for transmitting brucellosis,
the use of vaccines can also decrease the frequency of abortion
and thereby reduce the potential for transmission.” Based
on historical evidence, abortion is an extremely rare event
in the Yellowstone bison herd. What is the rate of abortion
in Yellowstone bison? What evidence does the Department have
to indicate that Yellowstone bison abort and shed brucella bacteria?
Has the Department developed a realistic model to indicate what
the reduction in the risk of transmission will be given the
small number of bison vaccinated, the relative inefficacy of
the vaccine and the demonstrated characteristics of the Yellowstone
bison herd with relation to natural immunity, low bacteria levels
and low rates of abortion? Has the Department conducted a cost-benefit
analysis of implementation of the vaccination program with the
current levels of information and the currently available vaccine
versus definitive research on the method of exposure between
Yellowstone bison and the development of alternative strategies
to reduce the rate of exposure?
2. The vaccination plan as proposed by the Department
is unlikely to reduce the risk of transmission of brucellosis
between bison originating in YNP and domestic cattle in the
Western Boundary Area:
The Department’s analysis of the cattle that graze in
the Western Boundary Area is lacking one key piece of information
that relates directly to the risk of brucellosis transmission
from bison originating in YNP. Stocking dates in the area begin
in mid-June. If necessary, herd management plans could delay
stocking dates even later. Studies conducted by Montana Fish,
Wildlife and Parks (FWP) and the USDA’s Animal and Plant
Health Inspection Service (APHIS) of fetal disappearance and
bacterial persistence rates indicate that brucella bacteria
are not likely to persist in the environment beyond mid-May.
Based on the methodology of the studies (human handling of carcasses,
undisturbed bacteria in metal cages, etc.) it is likely that
even mid-May is a conservative estimate of bacterial persistence
in the environment. After mid-May, even if bacteria were shed
into the environment, it would not last more than a few hours
and the possibility that bacteria would persist by mid-June
is statistically zero. Therefore, based on the current herd
management plans and stocking dates for cattle in the Western
Boundary Area, the risk of transmission between bison and cattle
is also statistically zero. If the Department disagrees with
this assessment, then perhaps stocking dates for brucellosis
susceptible cattle should be changed to July 1 to further guarantee
that brucellosis transmission will not occur. In any case, if
spatial and temporal separation between bison and cattle can
confer a zero risk of transmission, then vaccination is unnecessary
and incapable of further reducing the risk. What is the Department’s
current assessment of the necessary spatial and temporal separation
between bison and cattle? Has the Department conducted a cost-benefit
analysis of revising stocking dates to reduce risk of transmission
versus implementation of the vaccination program? Has the Department
conducted a cost-benefit analysis of revising the IBMP through
the adaptive management process based on the fetal disappearance
and persistence study results to allow more tolerance for unvaccinated
bison and progression to stage 2 of the IBMP versus implementing
the vaccination plan and continuing the current strategy?
3. The Department’s analysis of secondary impacts
is insufficient and ignores comments received by the Department
in the scoping process relating to the identification of vaccinated
bison:
In the section titled “Issues Identified by the Public
that are Within the Scope of the EA”, the Department states,
“The EA should evaluate the appropriate identification
of vaccinated bison, with consideration for the fact that these
animals will be observed by park visitors (emphasis added).”
In the proposed action section, the Department states, “While
captured, each bison will be officially identified with an ear
tag and/or other permanent means of identification…Identification
will allow for the determination of vaccine effectiveness in
individual bison that are subsequently recaptured.” In
the section titled, Secondary and Cumulative Impacts, the Department
states, “Secondary impacts are those impacts to the human
environment that are indirectly related to agency action, i.e.
they are indicated by a direct impact and occur at a later time
or distance from the triggering action. The Department did not
identify any secondary impacts associated with the proposed
action.” Nowhere in the Department’s analysis is
the issue of the visual impact of permanently tagged bison discussed
in relation to the experience of park visitors.
4. The Department’s analysis of the impact of
the vaccination plan on calf and yearling bison when the overall
population is over 3000 is inadequate:
In the section titled, Proposed Action, the Department states,
“When the population exceeds the defined objective for
the Western Boundary Area for the whole bison herd, the Department
may exercise discretion in determining whether to vaccinate
and release otherwise eligible bison.” Has the Department
conducted any studies to determine the viability of bison calves
and yearlings that are released without adult females? If such
studies indicate that orphaned bison calves and yearlings are
not likely to survive until sexual maturity, then the Department’s
purpose in initiating the vaccination program is further compromised.
The only way that risk of exposure between bison and the risk
of transmission to cattle could be reduced is if vaccinated
calf and yearling bison successfully calve without shedding
bacteria. Research on vaccinated calves and yearlings that are
permanently tagged and subsequently recaptured will also be
compromised if the vaccinated bison do not survive until the
next winter/spring. The Department must provide a complete analysis
of how the vaccination program will be conducted if the population
of the whole bison herd exceeds the 3000 target level that includes
the issues stated above.
5. The Department failed to analyze the impacts on individual
calf and yearling bison that are vaccinated under the plan:
Each bison calf and yearling that is run through the squeeze
chute and subsequently tests negative for exposure to brucellosis
will then have to be run through the chute a second time. Based
on incontrovertible evidence from capture/test/vaccination operations
at the Stephen’s Creek facility in YNP, bison run through
the chute sustained significant injury and stress. Has the Department
developed a mechanism for testing and vaccinating bison that
will not cause injury and meets the standards of humane treatment
required of the Department? Further, if vaccinated bison sustain
injuries during the capture/test/vaccination process, what is
the impact of exposure to bacteria from the vaccine to other
bison or non-target species from open wounds or mortality caused
by injury?
6. The Department should include analysis of a remote
delivery vaccination plan:
In the section titled, Other Actions that were Considered but
not Analyzed, under the subheading, Remote Vaccination, the
Department states, “The Department is not prepared to
initiate an EIS at this time because there is uncertainty whether
a remote delivery system, sufficient to achieve the purposes
of the IBMP, is available for field application at this time.”
Based on the lack of research and understanding of the method
of brucellosis exposure between bison in the Yellowstone bison
herd, the lack of research and understanding of the pathology
of brucellosis in Yellowstone bison, the natural characteristics
of temporal and spatial separation between bison and cattle
in the Western Boundary Area, the recent research on fetal disappearance
and bacterial persistence, and the lack of research on the viability
of orphaned bison calves and yearlings to survive until sexual
maturity, there is significant uncertainty that subcutaneous
vaccination of calf and yearling bison will achieve the purposes
of the IBMP in reducing the risk of transmission of brucellosis
between bison originating from YNP and domestic cattle grazing
in the Western Boundary Area in the summer. Therefore, the standard
for refusing to analyze remote delivery is inadequate. Further,
the Record of Decision for the State of Montana and YNP states
that step 2 “begins when a safe and effective remote delivery
mechanism is available.” Because the IBMP is established
under an adaptive framework, there is no reason that subcutaneous
vaccination is a necessary precursor to the development of a
remote delivery system and the advancement to step 2 of the
IBMP even though the use of a safe vaccine is an available management
action in step 1. Has the agency conducted a cost-benefit analysis
of remote delivery vaccine and the advancement to step 2 in
the IBMP versus implementing the subcutaneous vaccination program
and remaining in step 1 of the IBMP?
In conclusion, based on the questions and concerns
raised in the preceding comments, the Department should choose
the “no action” alternative at this time. The proposed
subcutaneous vaccination plan for calf and yearling bison originating
in YNP is not likely to achieve the goals of reducing the exposure
rates among the bison or reducing the risk of transmission between
bison and domestic cattle. The Department should engage in further
research to determine by what mechanisms exposure would be reduced
among bison. The Department should also engage in the adaptive
management process to revise the IBMP so that it is consistent
with the latest available science on the necessary period of
temporal and spatial separation to achieve the goals of the
IBMP.
Respectfully submitted,
Josh Osher
Buffalo Field Campaign |
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