Comment from Council on Wildlife and Fish

Due to your 5,000 word limit, this is Page 1 of 2.<br/><br/>June 3, 2023<br/>Public Comments Processing<br/>Attn: FWS-R6-ES-2022-0028<br/>U.S. Fish and Wildlife Service<br/>MS: PRB/3W<br/>5275 Leesburg Pike<br/>Falls Church, VA 22041-3803<br/>Public comments submitted electronically to:<br/>https://www.regulations.gov/commenton/FWS-R6-ES-2022-0028-0001<br/>Dear USFWS ESA (listing) officials: <br/>Please accept the following public comments on behalf of the Council on Wildlife and Fish, Native Ecosystems Council and Alliance for the Wild Rockies relating to threats to sole, remnant populations of wild buffalo present in the Greater Yellowstone Ecosystem (GYE). Threats to the continued existence of wild buffalo are significant and overwhelming, both in number and in adverse impact (direct, indirect and cumulative). <br/>Much has happened since publication of the 90-day finding on June 6, 2022 in the Federal Register. From a buffalo&rsquo;s perspective, it&rsquo;s getting worse, not better. Our comments reflect additional, new information concerning the status, threats and (inadequate) regulatory mechanisms affecting Yellowstone bison, including recent adverse modification to its habitats. All these recent developments are a turn for the worse, and further overwhelming evidence of the dire need for endangered species protection. We strongly urge you to employ whatever emergency (expedited) listing provisions of the ESA that may apply. The situation is now a legitimate emergency. <br/>Status <br/>The status of Yellowstone buffalo, from the perspective of the Montana Dept. of Livestock and the cattle industry operating in the states of Montana and Wyoming, is generally undefined, a non-specific category considered, and managed as, &lsquo;non-wildlife.&rsquo; &ldquo;Vermin&rdquo; would describe the perception among the anti-bison crowd. In this socio/cultural group, the levels of intolerance and discrimination against native wild buffalo ranges between viscous hatred, violence and deadly force. There is an unregulated war raging against wild, native buffalo, the breadth and depth of which generally goes unrecognized and underreported. This is not an overstatement. Wild, Yellowstone buffalo are not livestock.<br/>Threats<br/>The programmatic Interagency Bison Management Plan (IBMP), a joint state/tribal/federal plan, destroys wild, migratory buffalo. The IBMP implements the following kill and torture methods: 1) capture-for-slaughter, 2) capture and hold in quarantine (domestication), 3) abusive scientific experimentation, 4) unnecessary excessive hunting and hazing (harassment) and 5) acts of perpetual harassment, with no benefit to buffalo, or wild buffalo habitat. Qui bono? All benefit flows to Montana&rsquo;s livestock industry.<br/>Hunting along Yellowstone&rsquo;s North and West boundaries is totally out of control. It&rsquo;s no hunt at all, it&rsquo;s slaughter.<br/>The false issue of brucellosis transmission in the multi-state, Greater Yellowstone Ecosystem is misused and abused to privatize Montana&rsquo;s public wildlife and further degrade wildlife habitat on private and public lands. There is no transmission from buffalo to livestock. <br/>APHIS-USDA has consistently misled states in the GYE in pursuit of its obsession with brucellosis eradication nationwide and in the Greater Yellowstone Ecosystem. Thousands of Yellowstone buffalo and millions of federal tax-payer dollars have been wasted on the erroneous presumption that the wild buffalo were responsible for brucellosis transmission to livestock. APHIS and state agencies are quite aware that the elk (brucella) genotype, not buffalo, represents an infinitesimally small transmission risk threat to livestock.<br/>Buffalo live in an &lsquo;open-air prison,&rsquo; where they are abused and killed just like Palestinians in Gaza Strip. No living thing should be treated so poorly. <br/>