As we reviewed the seven alternatives of the DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR THE INTERAGENCY BISON MANAGEMENT PLAN FOR THE STATE OF MONTANA AND YELLOWSTONE NATIONAL PARK, it became clear that the basis of the problem is that Yellowstone National Park is an arbitrary chunk of a larger ecosystem with boundaries that are meaningless to wildlife.

The problem is compounded by the fact that (1) cows are allowed to graze on public land;  (2) snowmobile trails encourage bison to migrate out of the park; and (3) privately-owned land is interspersed with public land.

     (1) It should not be difficult to eliminate grazing on public lands, which has been conducted with fees below market value as a subsidy for the cattle industry at public expense.  In many cases, the land leased for grazing has suffered erosion and destruction of riparian habitat and other plant life and is therefore detrimental to wildlife in general, not just bison.

     (2) It should be a lot easier not to groom snowmobile trails than to groom them.  It will be harder to discourage off-road snowmobile use, but it can be done.  Snowmobiles
         a) interfere with wild animals' ability to conserve fat for surviving
              the winter
         b) cause serious air and noise pollution and
         c) should not be allowed in the park anyway.  There is no lack of           
             other territory for them to use outside park boundaries.  (It is   
             high time the park service took a stand against harmful off-road
             vehicles and watercraft anyway.)

(3) Private land is a knottier problem. There should be a policy in place of acquiring for addition to the park any adjacent and even nearby land in the ecosystem that becomes available.  People fortunate enough to live near the park need to recognize that visits from wildlife come with the territory.  If they fear brucellosis transmission to their private cows,
there are a number of measures they can take.
        a) Vaccinate all their female cows.
        b) Raise steers and/or sell heifers before they are impregnated.
        c) Fence their pastures to keep bison out.

It would not be out of line for public agencies to help with some of the expenses these measure will entail, which would probably be less costly than present measures to confine, quarantine, and otherwise manage the movements of the bison herd as a whole.

As we reviewed the DEIS and its seven alternatives, we kept thinking that the bogeyman of brucellosis transmission from bison to domestic cattle is just that.  Because brucellosis is a bovine disease that affects both species, the fear is not without logic, but there is no evidence that brucellosis can be, or has ever been, transmitted from bison to cows.  In other words, state and federal agencies are going to great lengths to cope with a problem that doesn't exist.

The response of state and federal agricultural agencies lacks logic when it hysterically guns down or sends to slaughter male and young bison who do not harbor brucella abortus.  The bogeyman could be banished by simply vaccinating  all the domestic cows although there has been no scientific indication that this is necessary.

Elk, too, carry the brucellosis organism, but nobody seems concerned that they might transmit the disease to domestic cows.  We know of no evidence that brucella abortus causes bison to abort their calves, an indication that bison have adapted to it differently from cows.  The fact that the vaccine for cows does not work in bison is another indication that bison respond differently to the organism.

Conclusion:

The National Park Service has a mandate to preserve natural ecosys-tems and wildlife populations for the benefit of all Americans living now and in the future and, perhaps to a lesser extent, the citizens of other countries as well. This needs to take precedence over private interests like driving or renting out snowmobiles and raising cows to sell.

Killing bison interferes with the process of natural selection, which is especially critical in a herd that originates from such a limited number of animals.

Executing bison, just because they have migrated beyond park boundaries, offends people's sensibilities and should be stopped.

Bison would be less likely to migrate out of the park if snowmobile trails did not provide easy egress, and there wouldn't be a problem,
real or imaginary, if the entire ecosystem were federal land.

We recommend that the National Park Service be given full jurisdiction over the bison to eliminate competition between public agencies representing private interests and that the bison be granted the right to self determination in accordance with the usual park policy.