Montana State Bison Plan EIS comment submitted September 2015
Dear Jeff Hagener and EIS Team,
Marias River Livestock Association agrees with and advocates for Alternative #1 No Action
MRLA has concerns about each County’s ability to be involved through regulation as stated on pg 61 of the Draft Plan. Though the FWP state they are willing to involve and work with counties MRLA feels counties should have the final say in the whether they wish to be involved in bison reintroduction. While the FWP does have the authority in wildlife management they themselves state that bison management is different and they are not the same as elk or deer.
Economic funding needs to be approved for more than 5 years (more like a hundred years). The hidden costs are a huge concern. There is concern that NGO could provide money to get a bison herd started as we have seen with the wolves and grizzly bears the money from those organization can also go away leaving management and mitigation costs unfunded unless picked up by the tax payers.
There is deep concern that exit strategies were not as strongly defined and what is the assurance that if a exit need is triggered that there would actually be a removal of a herd. There is concern that NGO law suits could prevent the removal of the bison herd should an need for the exit strategy to be triggered due to drought, fire, escape, property damage, disease, or other unforeseen issues or events. We have seen lawsuit prevent everything from logging to population control on wolves. Even the best management plan can be prevented or harmed by the lawsuits brought on by NGO’s.
There is concern that as the Designated Surveillance Area (DSA) expands due to elk carrying Brucellosis that this disease could infect a new “wild” herd of bison. With Domestic herds the animals would be tested and culled. In a wild herd we would simply have a second Yellowstone Park Issue. Because wildlife in the GYA is the last reservoir of Brucella Abortus in the US and the prevalence and area coved is expanding we pose this as a very valid concern to both animal, human and economic health in Montana.
There are already domestic bison herds in Montana. Per Capita fee was paid on 8368 head of domestic bison in 2014. There is debate as to the importance or value of the “unique” or “pure” genetics contained in some of herds.
In the past Grazing allotments for Cattle and Sheep have been lost in the GYA due to the disease issues there. Also different NGO have been purchasing Grazing Allotment from ranchers. Though it may be said rancher sold or gave them up willingly it ends the opportunity for future agricultural use in the future. These losses make it harder for families to pass the ranch from generation to generations. Neglecting the fact that there are many studies that correct grazing by cattle and sheep can improve the landscape, and reduce fire hazard.
Lack of confidence that FWP will comply with parameters set by Citizens Working Group (pg 66 & 69). MRLA is also concerned about the formation, participation and decision making process used in these groups. Rules formed by consensus are not always the best practice or most effective ways of management.
MRLA is also concerned with the statement that the Tribe or FWP (see last line in first paragraph pg 67 FWP) is only liable for damage when all efforts to follow a management plan endorsed by the local citizens working group have not been made. Again the reliance on such a group of people who are unknown and changing to make decisions that protect private property is concerning. While we would like to think a citizens working group would be in the best interest of all, it’s would effectiveness and decision making would be very dependent on the diligence, education and values of the individual in the group. We have also seen where Elk/Brucellosis Citizens Working Groups decisions were met with lawsuits by NGO. Again we are afraid that lawsuits would not allow for affective management, private property protection, and exit plans or disease control if needed.
There is Concern that there would be allowance for domestic livestock to become wildlife (Genetic pg 63). This would cause the loss of Per Capita Fee paid to the Department of Livestock . Domestic bison should not be managed as wildlife.
MRLA does not support Alternative #2 for the following reasons:
Public wildlife should not be managed by private entities or individuals. The uses, management and ownership of private land can change, therefore depending on private land for habitat there is no assurance of stable habitat. We think that leasing private property is a temporary, very expensive and unstable move which also causes competition with livestock for grazing purposes. The President of The Gallatin Wildlife Association, Glen Hockett, stated in the April 10, 2008 article titled Yellowstone Bison and the Fate of the Royal Teton Ranch Lease “We are being told by the promoters of this deal that this is a ‘huge step forward’. Rather, it appears to be a very temporary, bureaucratic and very expensive baby step funded in part with public dollars” as pertaining to the lease deal with Royal Teton ranch.
We currently see where private lands are causing issues with uncontrolled elk populations that then cause damage to neighboring grounds. MRLA would not support the use of private land for public bison herd but if that should come to pass any agreement would need to contain very strong population control measure, disease testing on a regular basis with plans to eliminate any disease that could be transmitted to livestock.
The use of Private lands for bison also brings in the concern of loss of revenue for the county due to loss of income from agriculture uses and per capita fee on the livestock that could be run there. Just as we do not advocate for feral horses from BLM running on ranch land MRLA does not condone the livestock producer having to compete with the state or federal government for private grazing leases lost to public bison.
MRLA does not support Alternative #3 for the following reasons:
While we agree that the Tribes have a right to bison wild or domestic on Tribal Trust Land where the Tribe holds the sole beneficial interest, the Tribal Restricted Fee lands, and Tribal Fee land, we are unsure how those who own privately own, Individual Trust Land, Individual Restricted Fee Land and Non-Indian Fee Land on the Reservation will be affected. Our number one priority is Private Property rights. MRLA is does not see how Montana Fish Wildlife and Parks will be able to protect private property owners within the exterior boundaries of the Reservation. In our meeting with FWP Staff member, Laurie Brown Chief of Non Game Wildlife and Commissioner Richard Stuker on August 11, 2015 they both reported that they do not have the authority to enforce the MOU that would be required (page 68 & 88 of the EIS) with the Tribes once the bison are on the reservations.
The Tribes would be under no obligation to keep bison as wildlife off of private property. IF the Tribe or State of Montana were to re-introduce bison on the reservation, MRLA asks that the Tribe recognize and protect private property rights. This would include fencing bison out of the lands upon which individuals are utilizing for ranching or other agricultural endeavors. Also, if the Tribe and/or State choose to re-introduce bison, adequate measures and funds need to be in place to fully protect the herd health of the livestock industry on the reservation and off.
The Iinnii Initiative will continue (check pg 55 of EIS) to go forward with or without the FWP intervention and there is a probability that the Blackfeet will not wish to cooperate with public access for viewing the wild bison and public hunting (pg 67) and other stipulations designed by FWP and citizens working group. Our non-support again does not hinder Tribes from obtaining and maintaining bison herds as indeed many tribes already have herds on Tribally owned land (as referred to above). If they choose to, they are able to replace them with bison that they consider to have desired genetics.
MRLA is also concern that the Tribes will receive “Landowner Incentives” pg 72 for having wild herd of bison. Unless there is complete public access for viewing and hunting we would find this disagreeable. If the bison were used as a commercial meat source being butchered and the meat or any other parts sold, then Tribes should not receive public money for their keep or habitat.
Just has the MFWP does not have authority over the Tribes, MRLA has concern that Tribes would not comply with parameters set by Citizens Working Group (pg 66 & 69).
MRLA does not support Alternative #4 for the same reasons that were sited on Alternative #1 and #2. By definition of the large land mass required it would be devastating to the local economies. The economic impact of competition with traditional agricultural uses and natural resource based industries as seen by the loss of Yellowstone grazing leases and the possible withdrawal of gas and oil development leases. This would also devastate historic rural communities. The concerns with alternatives on page 105 of EIS. Ranching is a long term, year round agriculture business. The threat of changing to a tourism based economy which is seasonal and low pay for the workers is not appealing. Rural communities are often treasured because they are small, have low crime rates, long term residents with multigenerational connections, and close knit ties.
This comment on the Bison EIS is presented for the Membership and Board of Directors of the Marias River Livestock Association.
72 Sweetgrass Hills Rd
Sweetgrass MT 59484