Comment from Council on Wildlife and Fish

Council on Wildlife and FishSupportAdvocacy

Summary: The Council on Wildlife and Fish, along with the Alliance for the Wild Rockies and the Native Ecosystems Council, argues that the Yellowstone bison are being subjected to excessive killing and habitat loss due to commercial interests and poor management. They support the ESA listing as a necessary measure to protect migratory routes, end illegal fencing and hazing, and preserve the cultural significance of the bison.

Council on Wildlife and Fish comments, Page 2 of 2 (due to 5,000 word limit) Regulatory Mechanisms Department of Livestock, who manages buffalo as livestock, is in charge, not Montana Fish Wildlife and Parks (FWP). FWP manages every other huntable and non-game species in Montana. See: MCA 81-2-120, which authorizes Montana Department of Livestock management over buffalo and FWP. Excessive killing obstructs migration to preferred historic habitat. Even pregnant females are being slaughtered, their unborn babies are left in gut piles. Montana and Wyoming have reverted back to the late 1800s, with no end in sight if ESA protection does not come in time to reverse the killing spree (genocide). State, Indian nations, and federal managers do not give due consideration to the buffalo’s perspective. Management decisions always sacrifice buffalo life in favor of commerce, industry, agency budgets, realpolitik and money, money and more money. The current regulatory environment resembles an ‘Old West’ death cult that worships the ‘Golden Calf’ at the altar of the God of Mammon. The Custer Gallatin National Forest denied wild buffalo Species of Conservation Concern status in its 2022 Revised Forest Plan and has no protections for buffalo or a single acre of secure buffalo habitat-- none. Habitat Wild, native migratory bison now survive on less than 1% of their historic ancestral home ranges. The State of Montana refuses to permit buffalo to migrate onto non-discriminatory private landowners’ property who readily accept wild buffalo as equals to any other wildlife species. This malpractice leads to habitat fragmentation and habitat loss. Historic migratory routes have been fragmented, severed and lost to rapid, recent growth in residential and commercial real estate development. Commercial recreational development, including mountain biking, cross country skiing, snowmobiling, E-bike, snow-motorcycles, the clearing and maintaining of agri-business lands, logging and associated roadbuilding and road maintenance all contribute to habitat degradation as well. Habitat connectivity is being lost at an exponential pace. Wild, migratory buffalo are denied access to ancestral home ranges north of the Park. A huge, fortified (illegal) fence and cattle guard at Yankee Jim Canyon, north of the Gardiner Basin, block passage beyond that point. There is not a single acre of ‘secure habitat’ in Montana or Wyoming on private or publicly-owned land adjacent to Yellowstone National Park – none, nada! Semi-truck traffic and heavy tourist traffic runs 24/7 on U.S. Hwy. 191, through the Park, severing a critical migration corridor in Montana’s Madison-Hebgen Basin. Collisions with buffalo are deadly; it’s getting less safe each passing year for all wildlife. Conclusion Empire only wants to promote war and chaos, not peace, so it can continue its hegemonic ways. - Anonymous ESA listing will move wild, migratory buffalo one step closer to surviving the last days of the century-and-a-half-old range wars, where buffalo and their ancestral lands come into direct conflict with greedy, private commercial interests, and die en masse for no good reason. Listing will begin to reverse the evisceration of a free indigenous peoples and culture and the wild, free-roaming buffalo that coexisted with indigenous nations for millennia. Listing will end the hazing, fencing and shooting of Montana’s wild buffalo on public and private lands, including all deeded and leased property with a conservation easement issued to enhance and protect wildlife winter range. It’s time for the land, and wild, free-roaming, wild buffalo populations to heal. For the reasons we’ve presented above the listing of Yellowstone buffalo cannot come soon enough. Sincerely, Steve Kelly, Director Council on Wildlife and Fish P.O. Box 4641, Bozeman, Montana 59772 406.920.1381; and for Michael Garrity, Exec. Director Alliance for the Wild Rockies P.O. Box 505 Helena, Montana 59624 406-459-5936; and for Sara Johnson Native Ecosystems Council P.O. Box 509 Three Forks, Montana 59752 406-579-3286

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