Subject: Re: Thanks for your
From: Kathryn QannaYahu <email@example.com>
Date: 12/26/2013 4:56 PM
To: Governor Bullock <firstname.lastname@example.org>
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
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The IBMP is woefully outdated.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."
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.
"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
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
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.
"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,
"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.
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
"A collective effort—like
what is currently being done—has the potential to significantly
reduce brucellosis, helping preserve our treasured wildlife and
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
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
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.
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.
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.
> STEVE BULLOCK