At the Interagency Bison Management Program on November 21, 2013, MT DOL's State Veterinarian stated, during the Brucellosis Seroprevalence discussion, that they would be conducting a capture, test, slaughter and vaccination program with the wild bison exiting Yellowstone National Park, beginning this February. Familiar with the academic papers on the unrealistic and uneconomical subject, as well as the 0.0-0.3% risk that wild bison could possibly transmit the livestock disease brucellosis, back to domestic cattle (no documented case of wild bison to domestic cattle transmission has ever occurred in the wild), I emailed Governor Bullock, to share the science with him, in hopes that he would stop the DOL's 2014 slaughtering of thousands of bison as they exited the Park, as they did in the winter of 2005/2006 and again in 2008. The reply I received, which turned out to be canned, was such a factual, politicized disappointment involving elk and bison, I had to write a rebuttal to correct all the literal bullshit. Below is my reply, with Governor Bullocks email following. I have also included my original bison vaccination citations email below his. So if you like to read in chronological order, start at the bottom. I have received no reply from the Governor's office from this Dec. 26th rebuttal email.

Additional notes, I have repeatedly requested Montana's official position on brucellosis in wildlife, including the Governor's office, and received no such policy statement. I have also researched and uncovered documents that show the State has signed onto USDA APHIS's Brucellosis Management Plan (posted soon) with APHIS, whose current mission statement is the eradication of brucellosis in wildlife - the elk and bison (as well as other cervids) of the the GYA.

Montanan's public and our public trust wildlife deserve better!

Subject: Re: Thanks for your email
From: Kathryn QannaYahu <kathryn@emwh.org>
Date: 12/26/2013 4:56 PM
To: Governor Bullock <governor@mt.gov>

Governor Bullock, I don't know if you actually wrote this reply email (below my reply) or if you authorized others to send canned replies, but your name is signed on this email, therefore, I am going to address it as being authored by you. Your reply email is loaded with scientific and factual inaccuracies, and thus writing makes you look ignorant of a very controversial issue here in Montana, not becoming to a person in your position, with the resources at your disposal.

As the governor, I hold you to a higher caliber on these matters. If you did not actually read my email, sent on November 24, 2013, with the current science, or that of others that I know have written to you, and if your advisers are not getting the responsible scientific data to you, then I suggest firing them and hiring some responsible science advisers onto your staff so you dont lose more credibility on this issue.

My email of Nov. 24 was not a complaint based on emotionalism (I've attached my email, just in case you didn't actually read it the first time), I addressed the science of bison vaccination and brucellosis risk transmission, of which your state DOL veterinarian, Dr. Marty Zaluski, was involved with and cited himself, when he was defending Montana livestock to the Texas Animal Health Commission in September.

Y'all cant play this both ways - using real science to defend MT cattle to Texas or any other state, while simultaneously fabricating MT livestock propaganda here in Montana to gain control over FWP, sportsmens dollars and our "treasured wildlife" - a public trust. You are being found out and will be held accountable before the people of Montana by researchers like myself.

Below is a list of the factual inaccuracies obvious in your email.
Your statements are in red, my response plus documented citations follow. Academic sources in green. Please note dates on publications, I am citing current science as published in peer reviewed professional literature.

"The Montana Department of Livestock, the State Veterinarian and the Interagency Bison Management Plan have informed the process of bison vaccination in Montana, which has been in place since 2000."
The IBMP is woefully outdated. The IBMP "informing" was based on an assumption, not science. The assumption was that bison were the transmitters of the livestock bacteria Brucella abortus, simply because bison and domestic cattle are both bovines. It was part of the APHIS/DOL eradication agenda, not based on science.

"Frustrated by the agencies' handling of the issue and believing their interests were not being addressed, a group of ranchers, conservationists, and hunters in Jackson Hole, Wyoming, wrote a letter to the Clinton administration in January 1997, in the midst of the crisis. They requested that APHIS stop threatening to downgrade the state's brucellosis-free status. Ranchers in Jackson Hole, they noted, had been running cattle next to bison for more than thirty years with no outbreaks of brucellosis." - Finding Common Ground, pg. 138, letter being foia'd.

- More importantly, no documented case of bison to cattle transmission in the wild has ever occurred, so the whole IBMP is a taxpayer funded political sham not based on science, which they have known about for years.

Brucellosis Science Review Workshop Panelists Report 2013."To date, no documented transmission of brucellosis from Yellowstone bison to cattle has occurred." "The organizers' intent was that conclusions and recommendations from the panel would be considered by the National Park Service in decision-making on the potential implementation of future vaccination programs, and that the workshop report also would inform short- and long-term adaptive management decisions on and strategies for disease management activities associated with the IBMP."
https://www.emwh.org/pdf/wildlife%20disease/brucellosis/Brucellosis%20Science%20Review%-
20Workshop%20Report%202013.pdf

In September, MTDOL's Dr. Marty Zaluski publicly testified in Texas, "Montana's DSA includes 282 operations with 73,200 cattle and domestic bison. This fiscal year, 42,025 of the 73,200 animals have been tested to achieve a 99% confidence that the disease (if it exists) is present at a rate of less that 0.008%. The chance that any one Montana animal is brucellosis positive is 0.00024%." "So really the DSA in the state of Montana is in southwest Montana. And it is designed to identify the cattle at risk from brucellosis positive elk. So we know that brucellosis positive elk are in southwest Montana, they can potentially expose cattle and so the key to identifying the cattle at risk is to identify where the brucellosis positive elk are." - no mention of bison, because bison don't transmit to cattle.
https://www.emwh.org/issues/brucellosis/livestock%20tahc.htm

"As you may know, brucellosis can cause animals to prematurely abort their young, so eliminating the disease is important."
The key problem in this statement of yours is your use of the word: 'eliminating.' Are you advocating the slaughtering of all bison, elk, moose, and deer from Montana and the rest of the GYA? The only known method of 'eliminating/eradicating' brucellosis in wildlife is by capture, test and slaughter of all seropositive wildlife.

Brucella abortus can cause abortions of firstborns. Wildlife have been adapting to this livestock introduced disease and their populations continue to grow despite the possibility of some abortion events of firstborns. What is important, for the peace of mind of the livestock community, is for taxpayer dollars to fund a better cattle vaccine (currently about 65% effective), rather than the fruitless waste of dollars trying to eliminate it from the wildlife, which is impossible without "sterilizing" (eradicating) all wildlife that can contract this bacteria, which here in the GYA includes cervids (elk, deer, moose), and wild bovines (bison).

An Ecological Perspective on Brucella abortus in the Western United States, 2013. Taxonomy of Brucella, 2010.
"...in some systems there may be more than one host species that is capable of independently maintaining brucellosis. As a result, if eradication is the goal, then it would have to be coordinated across all reservoir hosts. If brucellosis reduction is the goal then it would need to be maintained over time to control against spillover from alternative hosts."

If you are advocating the appalling test and slaughter of so many of our treasured wildlife for a small transmission risk (0.00024%) from elk that can be mitigated, you would also be committing to a massive long term economic hemorrhage for taxpayers, for what? So is this the Montana policy on brucellosis in wildlife that I have been calling and emailing your office and FWP concerning, and have yet to received a response stating what Montana's position is? Eradication of our elk, deer, moose and bison?

"Brucellosis has been eradicated nationwide, except in and around Yellowstone National Park. There, brucellosis persists in bison and elk."
False! Brucellosis is a disease, which can be caused by 10 different species of Brucella (bacteria) based on host preference, of which Brucella abortus (bovine brucellosis bacteria) is just one, the one dominant to cattle. So your statement that brucellosis has been eradicated nationwide, except the GYA, is inaccurate on both the general Brucella level and on the Brucella abortus level. Brucella taxonomy and evolution, 2010. Taxonomy of Brucella, 2010. Brucellosis in the Greater Yellowstone Area: disease management at the wildlife-livestock interface, 2012.

Brucella abortus brucellosis routinely crops up in Texas (last one 2011) and has occurred in other states that have no genetic relationship to the GYA elk or bison. Yes, the GYA is a major reservoir in the US, partly because major amounts of wildlife were eradicated in other parts of the US. Is this what you are proposing, eradication of all wildlife, to achieve total eradication of Brucella abortus in wildlife?

The livestock conditions which created brucellosis in the first place, still exist and in light of their over-antibiotic use, drug resistant superbug creation, you will probably be seeing a worse situation shortly (CDC, USDA, USAHA, NIAA and other industry websites and publications). Also, cases of brucellosis can occur from the cattle vaccines blooming (as in the MT domesticated bison in Madison County 2011, the Texas case in 2011 and an Idaho case in 2010 - the other Montana case confirmations from 2008 and 2010 awaiting HOOF-Print tests), which again, has nothing to do with the GYA elk or bison. Since the elk and the cattle biovar 1 (includes RB 51 and Strain 19 cattle vaccinations) are almost identical, you need to get into the HOOF-Prints tests to see whether it is an elk strain, cattle strain or cattle vaccine strain.

"Our results indicate that elk and cattle isolates are virtually identical genetically, differing by only one to two mutational steps. On the contrary, bison B. abortus differed from cattle and elk by 12-20 mutational steps."- DNA Genotyping Suggests that Recent Brucellosis Outbreaks in the Greater Yellowstone Area Originated from Elk, 2009. Molecular Epidemiology of Brucella abortus Isolates from Cattle, Elk, and Bison in the United States, 1998 to 2011, 2012.
https://www.emwh.org/resources/maps%20charts/aphis%20vs%20map%20brucellosis%20years.png

"In fact, about fifty percent of bison have brucellosis, and even more troubling, about 70 percent of calving-age female bison do."
Your statement is a scientific speculation based on modeling that an average 50% of the YNP bison population are seropositive. By your saying, 'have brucellosis' rather than 'are seropositive' you officially sanction an egregious falsehood.

Brucellosis is the disease, which cannot be diagnosed unless the animal is killed and a culture grown from their lymph glands or abortion/birthing materials. Seropositive, on the other hand, simply means that in a blood test, they show the antibody markers for having at one time come in contact with the disease, not that they are currently infected, nor infectious. Seropositive can also represent immunity. The seroprevalence of bison is immaterial, since they have not spread it to the elk, nor cattle. Genetic Natural Resistance to Brucellosis in Yellowstone National Park Bison (Bison Bison), 2013. Diagnosis of Brucellosis in Livestock and Wildlife, 2010.

"Only about 15-20 percent of elk have brucellosis in Montana."
I am curious where you got this figure from. Until you respond with a citation, I'm going to believe that this statement is simply a fearmongering statement to further inflame the unfounded fears of Montanan's that are not familair with the science involved with brucellosis. I scoured FWP papers, a number of independent papers and FWP Neil Anderson's elk brucellosis reports and could not find this statistic. Based on the FWP 2013 Montana elk winter count numbers, there are an estimated 120,470 elk in all 7 regions of Montana. If we were to take your upper 20% figure, that would be 24,094 elk in Montana that would be infected with brucellosis - based on your statement. And again, brucellosis is the infection; seropositive just indicates presence of antibodies, not necessarily current infection or infectious. It can represent immunity. Y'all need to get that fact straight and stop equating seropositive with infected/infectious. Within the whole Designated Surveillance Area of Montana, which comprises 14 Elk Hunting Districts and parts of 3 others, there are an estimated 22,266 elk based on the 2013 elk winter count. All of the elk in the DSA are 1828 LESS elk than what your 20% of infected Montana number would be. First, this should not read "brucellosis", rather seroprevalence. This should probably read DSA, not Montana. Even the whole of the DSA is not 15-20% seroprevalent based on charts from FWP. So, again, where did you get this statistic from?

Regardless of the lower elk seroprevalence (again, not all cases are brucellosis infection/infectious), it is the elk biovar that are nearly identical to that of domesticated cattle and is responsible for the transmission from wildlife to domesticated cattle. Also, according to the science, of which DOL's Dr. Marty Zaluski has been a contributor to and a testifier to, the risk that any one Montana cattle could become infected with brucellosis from elk is 0.00024%. Bison are not even a factor here and a 0.00024% elk transmission chance is not worth the slaughter of mass amounts of "our treasured wildlife".

In addition, "...vaccination of elk with Brucella Strain 19 has been conducted on feedgrounds in Wyoming since 1985 with no effect on seroprevalence and limited effect on abortion." - An Ecological Perspective on Brucella abortus in the Western Untied States, 2013. DNA Genotyping Suggests that Recent Brucellosis Outbreaks in the Greater Yellowstone Area Originated from Elk, 2009. https://www.emwh.org/issues/brucellosis/livestock%20tahc.htm A Risk Analysis of Brucella abortus Transmission Among Bison, Elk and Cattle in the Greater Yellowstone Area, 2010. An Ecological Perspective on Brucella abortus in the Western Untied States, 2013.

"A collective effort—like what is currently being done—has the potential to significantly reduce brucellosis, helping preserve our treasured wildlife and livestock."
According to the science and history, no collective effort of slaughtering bison to eradicate brucellosis will have any significant effect on the elk population seroprevalence, nor reduction of brucellosis risk transmission to cattle. The bison dont transmit to the elk (another unscientific rancher fable). - Brucellosis Science Review Workshop, Panelist Report 2013. Cost-Benefit Analysis of a Reduction in Elk Brucellosis Seroprevalence in the Southern Greater Yellowstone Area, 2013. A Risk Analysis of Brucella abortus Transmission Among Bison, Elk and Cattle in the Greater Yellowstone Area, 2010. Using Test and Slaughter to Reduce Prevalence of Brucellosis in Elk Attending Feedgrounds in the Pinedale Elk Herd Unit of Wyoming; Results of a 5 Year Pilot Project (for the elk).

In addition, the IBMP has been operating in this non-"collective" fashion since 2000. After the last major bison slaughter created such a public outcry, resulting in a Congressional Oversight Hearing on the matter, the GAO report stated of the IBMP agencies,
"(2) have continued to act more as individual entities, rather than as a cohesive interagency group; and (3) have not adequately communicated with or involved key stakeholders, such as conservation groups, livestock industry groups, and private landowners. Consequently, their decision making more often resembles trial and error than adaptive management and also lacks accountability and transparency."
https://www.emwh.org/pdf/wildlife%20disease/brucellosis/gao-08-291Yellowstone%20Bison%20IBMP%20Plan.pdf

"That’s exactly why bison vaccination is part of the management plan."
Bison vaccination is a part of the IBMP because APHIS/DOL demanded it as a test and slaughter method of removing a competing ungulate from the landscape, not because it is scientifically viable or achievable. They had no science to back it. But for Montana to regain the APHIS regulated Brucellosis Class Free Status for their cattle, Montana capitulated to the agreement. The current "collective effort" is not helping to preserve either our wildlife or livestock, it is wasting taxpayer dollars for false hope and misdirection, when the real efforts could be directed on a more effective cattle vaccine for livestock, realistic dialogue and real facts in this brucellosis issue. Again, here are the academic paper quotes on bison vaccination. that I submitted to you before, that elicited this reply and the Brucellosis Science Review Workshop Panelists Report 2013.
https://www.emwh.org/issues/brucellosis/bison%20brucellosis%20vaccination.htm
https://www.emwh.org/pdf/wildlife%20disease/brucellosis/Brucellosis%20Science%20Review%
20Workshop%20Report%202013.pdf

So of your letter, only your opening statement. "Bison are a treasured wildlife species and play an important role in Montana’s history and the cultures of the people who have called this land home for 400 generations." is accurate. We have a phrase for that, back in Texas. To be a wee bit more politically correct and put a bow on it - Male Bovine Blossoms! I expect better from your office - "on behalf of all Montanans."

MCA 2-3-201. Legislative intent -- liberal construction. The legislature finds and declares that public boards, commissions, councils, and other public agencies in this state exist to aid in the conduct of the peoples' business. It is the intent of this part that actions and deliberations of all public agencies shall be conducted openly. The people of the state do not wish to abdicate their sovereignty to the agencies which serve them.

Thank you,
Kathryn QannaYahu
406-579-7748
www.emwh.org

On 12/18/2013 11:28 AM, Governor Bullock wrote:
> December 18, 2013
>
> Dear Kathryn:
>
> Thanks for writing to me with your concerns on vaccinating bison outside of Yellowstone National Park. Bison are a treasured wildlife species and play an important role in Montana’s history and the cultures of the people who have called this land home for 400 generations.
>
> Montana needs to rely on various partners, including the federal government and the tribal nations, to properly manage our bison. The Montana Department of Livestock, the State Veterinarian and the Interagency Bison Management Plan have informed the process of bison vaccination in Montana, which has been in place since 2000. As you may know, brucellosis can cause animals to prematurely abort their young, so eliminating the disease is important.
>
> Brucellosis has been eradicated nationwide, except in and around Yellowstone National Park. There, brucellosis persists in bison and elk. In fact, about fifty percent of bison have brucellosis, and even more troubling, about 70 percent of calving-age female bison do. Only about 15-20 percent of elk have brucellosis in Montana. A collective effort—like what is currently being done—has the potential to significantly reduce brucellosis, helping preserve our treasured wildlife and livestock. That’s exactly why bison vaccination is part of the management plan.
>
> Nonetheless, I appreciate you writing to share your concerns with me. I will certainly keep them in mind as I continue to work hard on behalf of all Montanans.
>
> Sincerely,
>
>
>
> STEVE BULLOCK
>
> Governor

Subject: Dol bison slaughter and vaccination plan
From: Kathryn QannaYahu <kathryn@emwh.org>
Date: 11/24/2013 11:35 PM
To: Governor Bullock <governor@mt.gov>, <tbaker@mt.gov>, <livemail@mt.gov>

Governor Bullock, Tim Baker, Board of Livestock, I am writing to protest the the plans of the DoL to begin a test, slaughter and vaccination campaign on the YNP bison that exit the Park this winter, or in the future. I was at the IBMP meeting on Nov. 21st and heard the numerous and repeated objections of the other IBMP partners. I also am a constant researcher of the issues and science involving brucellosis, the livestock and our wildlife. From a technical report that Dr. Marty Zaluski was a contributing author, it states, "The estimated percentage of cattle exposure risk from the Yellowstone bison herd is small (0.0 - 0.3% of total risk)." The .3% is added simply "in case". There has not been a documented case of bison to cattle transmission. Zaluski also stated at the Texas Animal Health Commission hearing, "This fiscal year, 42,025 of the 73,200 animals have been tested to achieve a 99% confidence that the disease (if it exists) is present at a rate of less that 0.008%. The chance that any one Montana animal is brucellosis positive is 0.00024%." That is from the 99.7-100% risk of transmission from the elk. This elk risk of transmission is a very rare occurrence, one that other Montana cattle organizations and ranchers also openly stated to Texas. Certainly not warranting the obscene eradication measures that keep targeting the wildlife. More cattle die in vehicular accidents each year in Montana than in many years ever contract brucellosis. Is that going to begin a crusade to eradicate vehicles? That would be just as absurd as the current campaign against the bison and elk.

On top of these statistics are the facts of the bison vaccine. 1. Bison vaccine is disputed, 2. Does not prevent brucellosis infection, only marginally protects from abortion, and is not longterm, 3. Single shot vaccine showed no difference with non-vaccinated, 4. Commitment to booster vaccinations and long term programs (30 years) would be necessary and would be at great cost and manpower hours with limited results, 5. Vaccinated bison would still contract field strains of Brucella abortus, requiring slaughter and loss to program, 6. Vaccination during mid-gestation induces greater abortions, 7. Bison vaccination, in an attempt to lower seroprevalence, will have no effect on reducing seroprevalence in the elk population currently the primary transmission risk vector to the cattle, 8. Efficacy of RB51 vaccine has not been tested in field conditions, 9. Test and slaughter/vaccine programs are not efficient or socially acceptable management tools for wildlife.
https://www.emwh.org/issues/brucellosis/bison%20brucellosis%20vaccination.htm

The negative publicity the 2005-2006 slaughters reflected so poorly on Montana that a Congressional Oversight Hearing was held. The internet and its networks are far more sophisticated than they used to be, this will not be kept quiet. In addition, I have been researching the economics of the eradication campaign, the funding that is legislatively sponsored from Montana and the other two GYA states, funneled through APHIS back to the state, through a defunct organization, all for the purpose of eradicating brucellosis in wildlife with taxpayers dollars for something that will have minimal effect for an outrageous expense, due to politics, not sound science. More of the Montana, as well as the US public and organizations will become armed with this data, to defend the wildlife. It would be far more prudent for those monies and energies to be applied in a constructive manner to benefit the livestock industry, such as a more effective cattle vaccine for cattle, rather than a nefarious campaign against wildlife. Raul M. Grijalva (Chairman of the Subcommittee in the Oversight Hearing) stated, "Any legitimate threat of disease must be managed effectively but of equal importance - the slaughter of bison needs to stop... Effective disease control and free-roaming bison are not mutually exclusive. Given the enormous scientific and financial resources of the Departments of Interior and Agriculture, along with the resources and expertise of Montana, Wyoming and Idaho, I am confident that bison and cattle can be managed in a way that is not a death sentence for either species." His words would serve us well.

I would ask that you abandon the lethal political campaign against our wildlife.

Thank you,
Kathryn QannaYahu
406-579-7748
Bozeman, MT