Yellowstone National Park has produced an DEIS on bison management. The Park Service is accepting comments until September 25th. You can read the DEIS and make your own comment here: Attached are the detailed comments of the Wild Bison Restoration Council, however, if you want to make your own comments here are some brief points.
- Yellowstone Bison are unique and of international significance.
- Alternative 3 is the best option, but it has numerous problems.
- The transfer of brucellosis to livestock from bison is exaggerated.
- The removal of bison by hunting, test and slaughter and transfer to tribal lands has real ecological and evolutionary impacts on Yellowstone Bison.
- The underlying assumption of the management proposal rests on the assertion of treaty rights by tribes. This assertion has not been independently verified by the NPS, but a reading of treaties suggests there is NO LEGAL RIGHT to kill bison north of Yellowstone Park in Beatty Gulch.
- Yellowstone bison belong to all Americans, and it behooves the NPS to manage bison for all Americans. If bison are transferred from Yellowstone they should be sent to other public lands like the Charles M. Russell NWR, and other locations under federal management.
- The current proposals all manage bison for the benefit of tribal hunters, not the bison. What is good for bison should be the main focus of any decision.
We, the Montana Wild Bison Restoration Coalition (WBRC), offer the following comments on Yellowstone’s DEIS on bison management.
We commend Yellowstone NP for recognizing the unique character of Yellowstone bison.
We support Alternative 3 as a step in the right direction, but we have many concerns about the underlying assumptions of the document, and the lack of full ecological and evolutionary accounting that bison removal has on the Yellowstone herd and its impacts on the Greater Yellowstone Ecosystem.
The Yellowstone bison are the least manipulated remnant of wild bison that once roamed much of the West. They have been largely influenced by natural evolutionary processes like harsh weather, predation, natural breeding selection, and climate variability.
They are a globally significant population where protection and preservation should be given priority in any decision. Any management default position should be in the bison’s favor.
We recognize that bison management is political and the difficult political situation the NPS must negotiate. Nevertheless, the legislation that created Yellowstone provides a clear statement of the NPS mission to preserve and protect the park’s wildlife, including bison.
To quote Yellowstone Protection Act, the NPS “shall provide for the preservation, from injury or spoliation, of all timber, mineral deposits, natural curiosities, or wonders within said park, and their retention in their natural condition.” And leave them unimpaired for the enjoyment of future generations.”
By last count 1471 Yellowstone bison were culled or killed during 2023. However as reported in the DEIS, the tribes do not consistently report numbers, ages, and sexes of ungulates harvested under these permits to federal and state biologists so this should be considered a minimum count of tribal kill.
When transfers and slaughters are considered, the number rises to 1781 or approximately 40% of the northern herd was removed from the Yellowstone Park ecosystem. Approximately 64 were killed by Montana hunters, but the majority of all bison kill (1059) was due to tribal members. It should be noted there is no final 2023 count that we are aware of, so totals could be higher.
We believe this has serious implications for the ecological integrity of the bison and the Yellowstone Ecosystem, which by law the NPS must prioritize in all decisions.
While this loss of bison occurred primarily outside of Yellowstone NP, it behooves the Park Service, in its obligation to “preserve and protect” Yellowstone to bison at least object to such losses. According to NPS Chris Geremia during the NPS zoom August 28th 2023 noted that no more than 400 bison could be removed without affecting the herd’s biological viability.
The management proposal is based on the premise that tribes have treaty rights to hunt near Gardiner. The NPS has never investigated these claims. Instead, it has deferred to the state of Montana, which also has not fully investigated claims, relying primarily on tribal assertions of treaty rights, instead of independently validating these claims.
BISON DEMISE
While it may not be critical to the issue of Yellowstone bison management, the common “story” repeated by the DEIS under its American Indian Tribes and Ethnographic Resources section that white commercial hunting led to the demise of western bison is at best an exaggeration. Assuming that tribal hunters will practice “conservation” in hunting is not supported by historical or even present day behavior.
By the 1840s bison were essentially extirpated from Idaho, northern Utah, SW Montana and Wyoming west of the Continental Divide. By 1850 they were gone from Manitoba, Saskatchewan and North Dakota. This was all before there was any significant white settlement or bison hunting.
Indeed, most commercial hunting by white people did not occur until the 1870s and later after the railroads enabled easy transport of hides. By that time, bison were extirpated from much of their historic range in the western US.
There is abundant evidence that tribal hunting was a leading cause of bison extirpation, particularly after the advent of the horse and gun. The idea that somehow tribal people are “conservationists” is not supported by the evidence.
Source: The Wildlife News
