Most people outside of Wyoming would agree that the 23 elk feedgrounds in Wyoming are disease breeding grounds and need to be closed. They unnaturally congregate elk and are a perfect recipe for diseases, any diseases, to spread from animal to animal. We're talking wildlife here, migratory, free roaming wildlife, not livestock. This is not just a problem for brucellosis, but also Chronic Wasting Disease, also known as CWD which was documented about 5 miles away from the feed grounds this last winter. But this focus is on brucellosis and the Department of Livestocks intentional avoidance of preventing, actually encouraging, of this "elk feedground" situation existing, contrary to their mandate and the laws.

Let's look at the basics and break this down into manageable pieces.

1. How is brucellosis transmitted?
2. Unnatural congregations during late winter and spring, involving any infected animals.
3. Natural elk and bison brucellosis transmission possibilities.
4. Unnatural concentrations of abortions/possibly infected birthing materials in small area, wildlife corridor, causing increased interspecies brucellosis transmissions - Wyoming feedground mimicry.

How is brucellosis transmitted?
To begin, there's a lot of misinformation floating around on how brucellosis is transmitted from animal to animal, species to species. It is not just proximity or commingling. So here are a few quotes from the academic papers regarding brucellosis transmission to help clear things up (note, we are not focusing on vertical transmission from mother to offspring through milk). The transmission vector for brucellosis is an aborted fetus or infected birthing materials, which curious ungulates will naturally investigate, sniffing, licking or ingesting nearby plant material with the infected material/fluids.

• "Horizontal transmission (disease transmission to other herdmates, as opposed to vertical transmission which is from mother to offspring only) may occur when B. abortus is ingested from contaminated reproductive products associated with abortions, births, or vaginal discharges." - Disease and Winter Feeding of Elk and Bison: A Review and Recommendations Pertinent to the Jackson Bison and Elk Management Plan and Environmental Impact Statement, pg. 5, 2005
• "Brucella abortus causes abortions and is transmitted within and among wildlife and livestock when individuals investigate or feed near infected fetuses, placentas or birthing fluids." - Probable causes of increasing brucellosis in free-ranging elk of the Greater Yellowstone Ecosystem, pg. 279, 2010
• "For B. abortus transmission to occur from wildlife to cattle, the following requirements must be met: (1) the wildlife must be infected; (2) infected wildlife must be on allotments or private land where cattle are grazed outside of the National Park; (3) pregnant wildlife must shed Brucella into environment (through abortion, birth fluids, or post-partum via placenta); and (4) B. abortus must persist on the landscape long enough for grazing cattle to come into contact with bacteria." - A Risk Analysis of Brucella abortus Transmission Among Bison, Elk, and Cattle in the Northern Greater Yellowstone Area, pg. 45, 2010
• "A susceptible animal can become infected by licking, sniffing, or ingesting contaminated material." - Brucellosis in the Greater Yellowstone area: disease management at the wildlife–livestock interface, pg. 48, 2012
• "Transmission occurs within and among wildlife (bison [Bison bison], elk [Cervus elaphus]) and cattle populations when individuals come into contact with infected fetuses, placentas, or birthing fluids." - Bovine brucellosis in wildlife: using
  adaptive management to improve understanding, technology and suppression, pg. 263, 2013

Unnatural congregations during late winter and spring, involving any infected animals
In Wyoming, there are 23 elk feedgrounds that unnaturally congregate by feeding wilk elk during winter like livestock. One of these elk feedgrounds is the National Elk Refuge, nationally run, while the other 22 are Wyoming state run. Even though the evidence has been overwhelming that these feedgrounds are breeding disease in our wildlife, due to the special interests of private landowners, outfitters and farmer/ranchers, the feedgrounds remain open to the detriment of wildlife. Dr. Bruce Smith who worked for the US Fish and Wildlife Services at the NER stated, "As a general model, infectious disease transmission and prevalence are a function of 1) the number and density of infectious animals, 2) the number of susceptible hosts, and 3) conditions which facilitate contact and exposure of susceptible hosts to infectious individuals."

It is not just unnatural congregations of wildlife that breed disease, but specifically those where they will be feeding and those that are during the late winter and spring when abortions and birthing materials will be in the congregated areas. This is the brucellosis transmission vector. It is not the feeding or numbers that is causing the brucellosis spread, it is the abortion and birthing materials in an unnaturally congregated area providing the brucellosis transmission vector to be increased to a larger numbers of animals. Click this document for more information on seroprevalence and the difference between seropositive and infected.

• "The high densities of elk that congregate on the NER and the 3 Gros Ventre feedgrounds perpetuate the disease by exposing large numbers of animals on feedgrounds to B. abotus contaminated tissues during the peak period of abortion – February through May...However, the winter feeding program at the NER probably contributes to the exceptionally high (77 - 84%) seroprevalence among the Jackson bison." "Brucellosis has elevated the [wildlife] feeding issue to a new level of public awareness. More citizens question the justification for feeding when the practice is responsible for the spread and maintenance of the disease in elk." - Disease and Winter Feeding of Elk and Bison: A Review and Recommendations Pertinent to the Jackson Bison and Elk Management Plan and Environmental Impact Statement, pg. 5,6, 2005
• "Elk are supplementally fed at 23 sites in Wyoming resulting in dense aggregations at the time when elk are likely to transmit the infection via abortion events in late winter and early spring. Historically, the brucellosis seroprevalence in elk was 10-30% at these feeding grounds, but only 2-3 % in other elk populations around the GYE...The elevated seroprevalence of brucellosis in elk of the southern GYE is almost certainly due to the presence of artificial feeding grounds that aggregate elk during the winter and spring and facilitate brucellosis transmission." - Probable causes of increasing brucellosis in free-ranging elk of the Greater Yellowstone Ecosystem, pg. 279, 2010
• "The authors found that feedgrounds with feeding periods extending later into spring had higher seroprevalence in elk. In that analysis, the end of the feeding season explained 59% of the variation in seroprevalence among sites and suggested that, if causal, a shortening of the feeding season by a month may result in a reduction in seroprevalence of around two-thirds." - An ecological perspective on Brucella abortus in the western United States. pg. 82, 2013

Natural elk and bison brucellosis transmission possibilities

As shown, the brucellosis transmission vector requires congregations of animals > contacting abortion events or birthing materials, which occur in the late winter to spring > ingesting or inhaling brucellosis infected material. But, under natural conditions the chance of bison brucellosis to transmit to elk, or for elk to elk, is limited. Additionally, natural abortion or birthing materials in the broader landscape are frequently removed by predators, lessening or removing the opportunity of brucellosis transmission to elk and bison.

• "The probability of B. abortus transmission between elk (or from elk to cattle) is likely low during calving (May through June) because pregnant dams isolate themselves while giving birth and meticulously clean the birth site. Thus, birth sites are dispersed, and the likelihood of other elk encountering infected birth tissues and fluids is low. However, transmission risk is likely higher during brucellosis abortion period from February through April when many elk aggregate in larger groups on lower-elevation winter ranges that sometimes include ranch areas with cattle." - A Risk Analysis of Brucella abortus Transmission Among Bison, Elk, and Cattle in the Northern Greater Yellowstone Area, pg. 45, 2010
• "In contrast to elk, bison are gregarious during partuition, and pregnant females have been observed to nuzzle newborn calves. Mobbing events of a newborn calf or aborted fetus could contribute to intra-species transmission of B. abortus if the dam were infected." - A Risk Analysis of Brucella abortus Transmission Among Bison, Elk, and Cattle in the Northern Greater Yellowstone Area, pg. 15, 2010
• "This study found that minimal opportunity exists for B. abortus transmission from bison to elk under natural conditions in the northern GYA. The reasons for this lower probability of adequate contact for B. abortus transmission, even when spatiotemporal overlap occurred, are likely immunological or behavioral... Also, anecdotally, bison are more dominant than elk and may drive elk off grazing areas, increasing their opportunity for exposure to elk infectious material but decreasing the opportunity for elk to be exposed to bison infectious material." - A Risk Analysis of Brucella abortus Transmission Among Bison, Elk, and Cattle in the Northern Greater Yellowstone Area, pg. 79, 80, 2010

Unnatural concentrations of abortions/possibly infected birthing materials in small area, wildlife corridor, causing increased interspecies brucellosis transmissions - Wyoming Feedground mimicry

This unnatural, increased abortion/birthing materials on the landscape in late winter and spring is occurring right here in Montana, just like a Wyoming feed ground, but without the wildlife feeding. This is taking place just north of the Yellowstone National Park in Gardiner, Montana.

In the Interagency Bison Management Plans 2008-2009 Annual Report, page 16, it states that utilizing Montana hunters to reduce the numbers of YNP bison that might want to migrate into Montana (a goal of DOL and USDA's APHIS) was not sufficient, because the Montana genreal hunting season occurred before bison were exiting out of the Park and therefore could not be hunted. Montana does not have a bison hunting season that would kill a bison cow in her third trimester when a calf is due to be born.

So the IBMP decides to bring in the Native American hunters into the IBMP process and utilize their treaty hunting rights which do not have those prohibitions, hoping to secure greater bison kill numbers. This has increased each year. Last year, in 2013, over 100 bison were killed in a 1/4 mile area just as they exited the YNP by Beatti Gulch. Some were too anxious to shoot and did not wait until they were fully over the line, causing injured bison to fall back into the YNP to die, which could not be retrieved. This is in a residential and commercial area. I will not discuss ethical fair chase hunting here, nor hunting safety of shots in the night or shooting from the road or the private property tresspass. What I want to draw attention to are the hundreds of gut piles, a number of which included nearly born bison calves. Below is a Montana Cadastral image of where the killing took place with small red bison to show approx. locations of bison kills. Not all 100+ are represented by red bison or it would be too crowded. For further details of the 2013 hunt and gut piles, with photo essay, please see the Beatti Gulch Points PDF.

Now the seroprevalence (blood antibodies only) of the YNP bison population is said to be about 50%. Of those that are culture positive, they estimate that to be about 30%. So with 2013's 100+ YNP bison gut piles on the landscape in about a 1/4 mile area, harvested during the third trimester of a bison, when brucellosis is the worst, you are going to have alot of potential infected material lying on the ground. Additionally, this is a bottleneck area that is also a migration corridor for wildlife, meaning as bison and elk come through this corridor the ungulate curiostity will draw them to the gut piles where they naturally sniff, lick, graze on plants with these birthing fluids on the ground. This is the exact scenario of the Wyoming feedgrounds, minus the feeding.

Due to landowner complaints, the 2014 hunt was moved a wee bit north of the boundary to avoid the private property tresspass that occurred immediately north of the fence, so it occurred west of the private property around the Old Yellowstone Trail, with over 200 bison killed in this area. They are projecting more next year. The situation on the west side of Yellowstone is a wee bit different, not a bottle neck, more spread out, but still quite a number of bison killed and the resulting gut piles. While the Umatilla were the only tribe to remove the gut piles more into the forest away from the road, that will only address part of the social factor and none of the disease factor. Just for the record, I am an ethical hunter and I respect the Native American rights and their sovereignty. What I am objecting to is an increase in brucellosis on the landscape, infecting our wildlife, making them further socially unacceptable to some and possibly threatening the livestock industry and that backlash against our wildlife.

While academic papers speak of abortions and birthing materials on feedgrounds, none of them that I am aware of, have addressed the Native American hunts and these gut piles in the growing seroprevalence in southern Montana. It is being ignored. This increased seroprevalence is going to affect our northern Yellowstone bison and elk populations. While bison are being predominately kept in the YNP, elk are migratory and do come in contact with cattle in the DSA. While the cattle brucellosis infections in Paradise Valley from 2007 forward have been cattle transmissions, not elk, with a Wyoming feedground growing seroprevalence that could grow to 30%, we could begin to see elk transmissions to cattle, which will be a threat to the livestock industry and a threat to our wildlife populations.

So why has the DOL and APHIS preferred to whack bison to focus on population reduction while ignoring the brucellosis transmission threat which in contradictory to the twin goals of the IBMP of addressing the risk of brucellosis? Why is the Department of Livestock state veterinarian not managing bison for disease control as stated in 81-2-120 ignoring the threat these gut piles present?

We have a Wyoming feedground situation here in Montana, increasing brucellosis and the agencies are ignoring the threat this poses to Montana.