In developing a range of alternatives for people to consider, evaluate and disclose an alternative for:

• Managing wild buffalo like wild elk on public lands in Montana, i.e., subsistence hunting of sustainable populations.
• Making an expanse of habitat available for each genetically distinct subpopulation or buffalo herd to adapt and thrive over the long-term.
• Designating refuges to provide security from overhunting and permit dispersal across public lands.
  
  

In developing the alternative, please review BFC’s proposal detailing the four corners of a respectful wildlife management plan:
Managing Wild Buffalo Like Wild Elk in Montana Proposal (PDF)

In recognizing buffalo as a wild species and honoring their freedom to roam public lands, evaluate and disclose the benefits and costs of managing wild buffalo like wild elk in Montana, including:

• No trapping or capturing for slaughter.
• No commercial privatization or domestication via quarantine.
• No “hazing” unless there is an imminent threat to safety, e.g., buffalo on a blind-curve highway.
• No exclusionary management zones or boundary lines preventing natural migrations to range and habitat.
• No vaccinating.
• No permanent tagging, marking, or inserting microchips to identify individuals.
• No population control experiments, e.g., fertility or birth-control agents.
  
  

Actions common to all alternatives, and for each alternative, evaluate and disclose:

• Managing cattle in Designated Surveillance Areas in Montana, Idaho, and Wyoming as concurrent management actions.
• Costs and cost effectiveness of managing cattle in the States as concurrent management actions.
• How managing cattle, buffalo and elk biology, the biological role of predators and scavengers, and environmental conditions prevent disease risk and transfer.
• A fact-based quantitative risk management assessment for wild buffalo, elk, and cattle at local scales.
  
  

In managing wild elk in Designated Surveillance Areas in Montana, evaluate managing wild buffalo similarly by:

• Limiting actions to adjust buffalo distribution away from cattle ranches at local scales.
• Limiting actions to adjust buffalo distribution when a localized risk is greatest to cattle ranches.
  
  

Actions common to all alternatives, and for each alternative:

• Adapt a long-term minimum viable population size for each genetically distinct population or herd for Yellowstone buffalo. Conservation biologists recommend a census of 2,000–3,000 for each herd to “avoid inbreeding depression and maintain genetic variation.” (Hedrick 2009). “[B]oth the evolutionary and demographic constraints on populations require sizes to be at least 5000 adult individuals. . . minimum viable population size in many circumstances will be larger still.” (Traill et al. 2010).
• Incorporate a safety-net halting lethal management actions if buffalo in the Northern or Central herds or both are below the conservation biology threshold.
• Incorporate a conservation biology action plan for increasing genetic diversity and protecting the integrity of each herd, and the Yellowstone buffalo population.
  
  

Actions common to all alternatives, and for each alternative, evaluate and disclose:

• Projected impacts of rapid climate change on buffalo and the ecosystem buffalo depend upon for survival. Include adaptability of buffalo (body mass or size, heat stress or thermoregulation, fitness, life history traits such as age of maturity, reproduction, and growth), availability and quality of forage, and access to water, across meaningful time scales, i.e., over the next century or longer.
  
  

Actions common to all alternatives, and for each alternative, evaluate and disclose how Yellowstone National Park will use the best available science for:

• Protecting the long-term viability and evolutionary potential of Yellowstone buffalo.
• Protecting genetically distinct subpopulations or herds of buffalo in the wild.
• Retaining migratory behavior for each genetically distinct subpopulation or herd and the Yellowstone buffalo population.
• Making future “adaptive management” decisions.
  
  

For each alternative, evaluate and disclose:

• Impacts to genetically distinct subpopulations or herds, and the Yellowstone buffalo population.
• How management actions alter, adversely effect, or artificially select against wild traits and genetic diversity.
• How management actions alter, adversely effect, or artificially select against natural selection, natural disease resistance and immunity.
  
  

Actions common to all alternatives, and for each alternative, identify and evaluate:

• Measures for protecting and restoring migration corridors and connectivity to habitat for wild buffalo.
• Cattle grazing allotments suitable for closure, buy-out, or permanent retirement.
• Acquiring habitat to reduce local conflicts with cattle ranchers.
• Acquiring habitat to restore migration corridors and connectivity to habitat for wild buffalo.
  
  

Actions common to all alternatives, and for each alternative, evaluate and disclose:

• Ecological sustainability, the capacity of wild buffalo in providing for biological diversity, resilience of native species, and healthy grasslands in the Yellowstone ecosystem.
• Opportunities for developing wildlife safe passages and measures for increasing awareness of, and safety for, buffalo crossing highways in the region.
  
  

Actions common to all alternatives, and for each alternative, evaluate and disclose:

• Costs and cost effectiveness, and address accountability. The public should not have to guess where and how much public funds are being spent or what it costs for managing wild buffalo.
• Commit to annually disclosing total costs, and what, if any, outcomes were achieved or not, and why.

Download a copy of the Buffalo Field Campaign Scoping Comments on the Yellowstone Bison Management Plan (PDF)

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