Comment from Dieterich, Michele

<br/><br/>To the United States Fish and Wildlife Service<br/>Thanks very much for considering these comments concerning initiating Endangered Species protections for wild bison. The Endangered Species Act (ESA) is the gold standard of protection for animals dwindling in numbers and habitat in the West.<br/>Wild bison exist on less than 1% of their historic range and the Montana legislature and influential livestock owners have way too much power to keep it that way. The American Prairie Reserve applied for and was granted permission by the Bureau of Land Management (BLM) to graze bison on allotments near their holdings and the Charlie Russell Wildlife Refuge. The State of Montana under Governor Gianforte has appealed this decision. MCA 81-2-120 gives the Montana Department of Livestock jurisdiction over wild, migratory bison. Why do livestock owners have such power over the existence of an iconic animal. And why is the state not allowing migration to private lands that welcome the presence of bison?<br/>There are many bison ranches, but these are domesticated bison and cannot be counted in the numbers used to quantify wild bison. The domesticated bison ranches must not be a part of the discussion of historical range. These are not migratory bison nor are they wild.<br/>There are many more obstacles to wild bison using and migrating throughout their historical range. The fencing and cattleguards in Yankee Jim Canyon bar bison movement. Highways and the lack of crossing structures to allow movement over these barriers. For example: Montana Department of Transportation (MDOT) just proposed a massive fencing project called the Jens Project. This fencing would prevent animals from crossing highway 90. This project was proposed instead of a crossing structure for which MDOT claims there is no funding available. Another very important migration zone crosses US Highway 191 in the Hebgen Basin of Montana. There are no structures there nor is there funding available. Lack of funding in Montana for crossing structures is yet another lack of regulatory mechanism to protect wild bison.<br/>The recent Custer Gallatin National Forest (CGNF) plan revision is another obstacle. First, the CGNF reduced Wilderness designations especially in low elevation locations that would facilitate bison movement. They also refused to consider wild bison as a species of conservation concern on the forest. So, no standards have been established to protect bison and facilitate migration.<br/>Human development that is rapidly expanding in Montana is another obstacle. Not only is human development expanding, it is doing so without zoning and now little oversight thanks to new legislation in Montana. SB158, HB211, and SB152 are just a few. The Legislature has also enacted laws to prevent local municipalities from enacting zoning laws and provisions for subdivisions.<br/>The Interagency Bison Management Plan does not consider bison biology, only social concerns, mostly those of the livestock industry. It has an extensive plan to slaughter, quarantine, hunt, and haze bison. A shocking example of this is the recent slaughter of bison along the Yellowstone border. Where a large percentage of bison were killed by hunters waiting just outside the boundary. Pregnant bison were killed in this deluge and gut piles were left along the border. These gut piles were cleaned up using taxpayer dollars, because they were unsightly and would have attracted wolves and grizzlies from the park. This is a loss of grizzly and wolf food sources which further exacerbates their livestock depredation.<br/>Grazing allotments on public lands especially those near Yellowstone (new ones were proposed in the East Paradise grazing allotment project) are another hazard to bison. Cattle carry diseases that they can pass to bison. The livestock industry claims that brucellosis is the reason they work with the Montana government to prevent bison from leaving the park. But to my knowledge, there has never been a documented case of bison passing brucellosis to cattle. <br/>Climate change is yet another factor. It will change their range, their food sources, and their very survival. The ability to move around will be imperative to the survival of bison, yet so many factors that could be alleviated are preventing the natural movement of wild bison.<br/>These factors are just a few of the challenges bison face today. Please consider them for listing under the ESA and determine critical habitat for these iconic animals. You have the important task of curbing this mass extinction. As Rachel Carson put it so aptly, &ldquo;Man&#39;s attitude toward nature is today critically important simply because we have now acquired a fateful power to alter and destroy nature. But man is a part of nature, and his war against nature is inevitably a war against himself. [We are] challenged as mankind has never been challenged before to prove our maturity and our mastery, not of nature, but of ourselves.&quot;<br/>Thanks for your time and consideration.<br/><br/>