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Implementation of the Interagency Bison Management Plan' which was 
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Testimony: 

Before the Subcommittee on National Parks, Forests and Public Lands, 
Committee on Natural Resources, U.S. House of Representatives: 

United States Government Accountability Office: 

GAO: 

For Release on Delivery Expected at 10:00 a.m. EDT: 

Tuesday, March 20, 2007: 

Yellowstone National Park: 

Preliminary Observations on the Implementation of the Interagency Bison 
Management Plan: 

Statement of Robin M. Nazzaro, Director: 
Natural Resources and Environment: 

GAO-07-638T: 

GAO Highlights: 

Highlights of GAO-07-638T, a testimony before the Subcommittee on 
National Parks, Forests and Public Lands, Committee on Natural 
Resources, U.S. House of Representatives 

Why GAO Did This Study: 

Yellowstone National Park, in northwest Wyoming, is home to a herd of 
about 3,600 free-roaming bison. Some of these bison routinely attempt 
to migrate from the park in the winter. Livestock owners and public 
officials in states bordering the park have concerns about the bison 
leaving the park because many are infected with brucellosis—a 
contagious bacterial disease that some fear could be transmitted to 
cattle, thus potentially threatening the economic health of the states’ 
livestock industry. Other interested groups believe that the bison 
should be allowed to roam freely both within and outside the park. 

In an effort to address these concerns, five federal and Montana state 
agencies agreed to an Interagency Bison Management Plan (IBMP) in 
December 2000 that includes three main steps to “maintain a wild, free-
ranging population of bison and address the risk of brucellosis 
transmission to protect the economic interest and viability of the 
livestock industry in Montana.” 

This testimony discusses GAO’s preliminary observations on the progress 
that has been made in implementing the IBMP and the extent to which 
bison have access to lands and an easement acquired for $13 million in 
federal funds. It is based on GAO’s visit to the greater Yellowstone 
area, interviews with federal and state officials and other interested 
stakeholders, and review of related documents. 

What GAO Found: 

More than 6 years after approving the IBMP, the five federal and state 
partnering agencies—the federal Department of the Interior’s National 
Park Service and Department of Agriculture’s Animal and Plant Health 
Inspection Service and Forest Service, and the state of Montana’s 
Departments of Livestock and of Fish, Wildlife and Parks—remain in step 
one of the three-step plan primarily because cattle continue to graze 
on certain private lands. A key condition for the partner agencies to 
progress further under the plan requires that cattle no longer graze in 
the winter on certain private lands north of Yellowstone National Park 
and west of the Yellowstone River to minimize the risk of brucellosis 
transmission from bison to cattle; the agencies anticipated meeting 
this condition by the winter of 2002/2003. Until this condition is met, 
bison will not be allowed to roam beyond the park’s northern border in 
this area. While a prior attempt to acquire grazing rights on these 
private lands was unsuccessful, Montana’s Department of Fish, Wildlife 
and Parks is currently negotiating with the private land owner to 
acquire grazing rights on these lands. 

Yellowstone bison have limited access to the lands and conservation 
easement that federal agencies acquired north of the park. In 1998 and 
1999, as part of a larger conservation effort to provide habitat for a 
variety of wildlife species, protect geothermal resources, and improve 
recreational access, federal agencies spent nearly $13 million to 
acquire 5,263 acres and a conservation easement on 1,508 acres of 
private lands north of the park’s border—lands towards which bison 
frequently attempt to migrate in the winter. The conservation easement 
prohibits development, such as the construction of commercial 
facilities and roads, on the private land; cattle grazing rights were 
retained by the land owner. The Yellowstone bison‘s access to these 
lands will remain limited until cattle no longer graze on the easement 
and certain other private lands in the area. 

Figure: Bison in Yellowstone National park: 

[See PDF for Image] 

Source: GAO. 

[End of figure] 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-638T]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Robin M. Nazzaro at (202) 
512-3841 or nazzaro@gao.gov. 

[End of section] 

Mr. Chairman and Members of the Subcommittee: 

I am pleased to be here today to discuss our preliminary work on issues 
related to managing bison in the Yellowstone National Park area. Bison 
lived in this area long before the park was established in 1872, and 
have been under some form of human management since the early 1900s. In 
1901, after years of hunting and poaching, the Yellowstone herd had 
been reduced to about 25 bison. For nearly the next six decades, bison 
management in the park emphasized reestablishing the bison herd and 
controlling the size of the population. Through a policy of natural 
regulation adopted by the park in the 1960s, the bison population has 
increased, and about 3,600 bison roam the park and surrounding areas 
today. 

Brucellosis--a contagious bacterial disease that can infect domestic 
animals, wildlife, and humans--was first found in the Yellowstone bison 
herd in 1917 and is believed to have been transmitted from livestock. 
Livestock owners and public officials in the states bordering the park 
are concerned about brucellosis in the bison herd because of the risk 
of bison transmitting the disease back to cattle and the economic 
impact such an occurrence could have on the livestock industry. The 
state of Montana and its livestock industry, in particular, have been 
active in protecting the brucellosis-free status that the state has 
held since 1985 by advocating for limits on bison migration. These 
efforts have been opposed by advocacy groups working to expand bison 
habitat and protect the wild free-roaming character of the bison, and 
who assert that there has never been a documented case of brucellosis 
transmission from bison to cattle in the wild. Many years of public 
controversy over the management of bison in the Yellowstone National 
Park area have ensued as a result of these competing concerns. 

In an effort to address these concerns in the early 1990s, the 
Department of the Interior's (Interior's) National Park Service, the 
Department of Agriculture's (USDA's) Animal and Plant Health Inspection 
Service and Forest Service, and Montana's Departments of Livestock and 
Fish, Wildlife and Parks agreed to develop a joint long-term bison 
management strategy. This joint planning effort ultimately resulted in 
a three-step, Interagency Bison Management Plan (IBMP) that was agreed 
upon by the five federal and state partner agencies in December 2000. 
Concurrent with the development of a bison management strategy, the 
Forest Service was also pursuing the acquisition of certain private 
lands and conservation easements near the northern boundary of the park 
to expand critical migration and winter range habitat for a variety of 
wildlife species, protect geothermal resources, and improve 
recreational access. 

My testimony today summarizes work performed to date that GAO began in 
mid-January 2007 at the request of the Chairman of the House Committee 
on Natural Resources and Congressman Maurice D. Hinchey. GAO previously 
reported on the bison management issue and development of the IBMP in 
the 1990s. A list of related GAO products is provided in appendix I. 
Our current work is focused on determining: (1) the progress that has 
been made in implementing the IBMP and the associated costs and 
challenges; (2) what lands and easements north of Yellowstone National 
Park, acquired for $13 million in federal funds, have been made 
available to bison and other wildlife; and (3) what advances have been 
made in developing a brucellosis vaccine and remote delivery method for 
bison. To begin addressing these objectives, we visited the Yellowstone 
National Park area to attend an interagency sponsored public meeting on 
the IBMP, tour the bison management areas near Yellowstone National 
Park, interview federal and state agency officials as well as members 
of interested stakeholder groups, and review relevant documentation. We 
have conducted our work to date in accordance with generally accepted 
government auditing standards. 

Over the next several weeks, we will continue to collect and analyze 
information to refine our approach for completing the review. To date, 
our efforts have focused mostly on the first two broad objectives. 
Thus, my remarks today will provide our preliminary findings on the 
first two objectives. 

Summary: 

In summary, more than 6 years after approving the IBMP, the five 
federal and state partnering agencies remain in step one of the three- 
step plan because cattle continue to graze on certain private lands. A 
key condition for the partner agencies progressing further under the 
plan requires that cattle no longer graze in the winter on certain 
private lands adjacent to the north boundary of Yellowstone National 
Park and west of the Yellowstone River to minimize the risk of 
brucellosis transmission from bison to cattle. The agencies anticipated 
meeting this condition by the winter of 2002/2003. Until this condition 
is met, bison will not be allowed to roam freely beyond the park's 
northern border, west of the Yellowstone River. The Forest Service has 
been successful in purchasing certain private lands and continues its 
vacancy of national forest grazing allotments in the area; however, the 
partner agencies have yet to acquire cattle grazing rights on other 
private lands adjacent to the north boundary of Yellowstone National 
Park and west of the Yellowstone River. While a prior attempt by 
Interior was unsuccessful, Montana's Department of Fish, Wildlife and 
Parks is currently negotiating with the private land owner to acquire 
these grazing rights. 

Yellowstone bison have limited access to the lands and conservation 
easement that federal agencies acquired north of the park. In 1998 and 
1999, as part of a larger conservation effort to provide habitat for a 
variety of wildlife species, protect geothermal resources, and improve 
recreational access, federal agencies spent nearly $13 million to 
acquire 5,263 acres and a conservation easement on 1,508 acres of 
private lands north of the park's border, lands towards which bison 
frequently attempt to migrate for suitable winter range. While the 
conservation easement prohibits development, such as the construction 
of commercial facilities and roads, on the private land, the land owner 
retained cattle grazing rights. The Yellowstone bison's access to these 
lands will remain limited until cattle no longer graze on the easement 
and other private lands in the area. 

Background: 

Yellowstone National Park is at the center of about 20 million acres of 
publicly and privately owned land, overlapping three states--Idaho, 
Montana, and Wyoming. This area is commonly called the greater 
Yellowstone area or ecosystem and is home to numerous species of 
wildlife, including the largest concentration of free-roaming bison in 
the United States. Bison are considered an essential component of this 
ecosystem because they contribute to the biological, ecological, 
cultural, and aesthetic purposes of the park. However, because the 
bison are naturally migratory animals, they seasonally attempt to 
migrate out of the park in search of suitable winter range. 

The rate of exposure to brucellosis in Yellowstone bison is currently 
estimated at about 50 percent. Transmission of brucellosis from bison 
to cattle has been documented under experimental conditions, but not in 
the wild. Scientists and researchers disagree about the factors that 
influence the risk of wild bison transmitting brucellosis to domestic 
cattle and are unable to quantify the risk. Consequently, the IBMP 
partner agencies are working to identify risk factors that affect the 
likelihood of transmission, such as the persistence of the brucellosis- 
causing bacteria in the environment and the proximity of bison to 
cattle, and are attempting to limit these risk factors using various 
management actions. 

The National Park Service first proposed a program to control bison at 
the boundary of Yellowstone National Park in response to livestock 
industry concerns over the potential transmission of brucellosis to 
cattle in 1968. Over the next two decades, concerns continued over 
bison leaving the park boundaries, particularly after Montana's 
livestock industry was certified brucellosis-free in 1985. In July 
1990, the National Park Service, Forest Service, and Montana's 
Department of Fish, Wildlife and Parks formed an interagency team to 
examine various alternatives for the long-term management of the 
Yellowstone bison herd. Later, the interagency team was expanded to 
include USDA's Animal and Plant Health Inspection Service and the 
Montana Department of Livestock. In 1998, USDA and Interior jointly 
released a draft environmental impact statement (EIS) analyzing several 
proposed alternatives for long-term bison management and issued a final 
EIS in August 2000. In December 2000, the interagency team agreed upon 
federal and state records of decision detailing the long-term 
management approach for the Yellowstone bison herd, commonly referred 
to as the IBMP. 

The IBMP is a three-step plan for managing bison on the northern and 
western sides of Yellowstone National Park, areas to which bison 
typically attempt to migrate for suitable winter range. The stated 
purpose of the IBMP is to: 

"maintain a wild, free-ranging population of bison and address the risk 
of brucellosis transmission to protect the economic interest and 
viability of the livestock industry in Montana." 

Although managing the risk of brucellosis transmission from bison to 
cattle is at the heart of the IBMP, the plan does not seek to eliminate 
brucellosis in bison. The plan instead aims to create and maintain a 
spatial and temporal separation between bison and cattle sufficient to 
minimize the risk of brucellosis transmission. In addition, the plan 
allows for the partner agencies to make adaptive management changes as 
better information becomes available through scientific research and 
operational experience. 

Under step one of the plan, bison are generally restricted to areas 
within or just beyond the park's northern and western boundaries. Bison 
attempting to leave the park are herded back to the park. When attempts 
to herd the bison back to the park are repeatedly unsuccessful, the 
bison are captured or lethally removed. Generally, captured bison are 
tested for brucellosis exposure.[Footnote 1] Those that test positive 
are sent to slaughter, and eligible bison--calves and yearlings that 
test negative for brucellosis exposure--are vaccinated. Regardless of 
vaccination-eligibility, partner agency officials may take a variety of 
actions with captured bison that test negative including, temporarily 
holding them in the capture facility for release back into the park or 
removing them for research. In order to progress to step two, cattle 
can no longer graze in the winter on certain private lands north of 
Yellowstone National Park and west of the Yellowstone River. Step two, 
which the partner agencies expected to reach by the winter of 2002/ 
2003, would use the same management methods on bison attempting to 
leave the park as in step one, with one exception--a limited number of 
bison, up to a maximum of 100, that test negative for brucellosis 
exposure would be allowed to roam in specific areas outside the park. 
Finally, step three would allow a limited number of untested bison, up 
to a maximum of 100, to roam in specific areas outside the park when 
certain conditions are met. These conditions include determining an 
adequate temporal separation period, gaining sufficient experience in 
managing bison in the bison management areas, and initiating an 
effective vaccination program using a remote delivery system for 
eligible bison inside the park. The partner agencies anticipated 
reaching this step on the northern boundary in the winter of 2005/2006 
and the western boundary in the winter of 2003/2004. 

In 1997, as part of a larger land conservation effort in the greater 
Yellowstone area, the Forest Service partnered with the Rocky Mountain 
Elk Foundation--a nonprofit organization dedicated to ensuring the 
future of elk, other wildlife and their habitat--to develop a Royal 
Teton Ranch (RTR) land conservation project. The ranch is owned by and 
serves as the international headquarters for the Church Universal and 
Triumphant, Inc. (the Church)--a multi-faceted spiritual organization. 
It is adjacent to the northern boundary of Yellowstone National Park 
and is almost completely surrounded by Gallatin National Forest lands. 
The overall purpose of the conservation project was to preserve 
critical wildlife migration and winter range habitat for a variety of 
species, protect geothermal resources, and improve recreational access. 
The project included several acquisitions from the Church, including 
the purchase of land and a wildlife conservation easement, a land-for- 
land exchange, and other special provisions such as a long-term right 
of first refusal for the Rocky Mountain Elk Foundation to purchase 
remaining RTR lands. The project was funded using fiscal years 1998 and 
1999 Land and Water Conservation Fund appropriations totaling $13 
million.[Footnote 2] 

Implementation of the IBMP Remains in Step One Because Cattle Continue 
to Graze on RTR Lands: 

Implementation of the IBMP remains in step one because cattle continue 
to graze on RTR lands north of Yellowstone National Park and west of 
the Yellowstone River. All Forest Service cattle grazing allotments on 
its lands near the park are held vacant, and neither these lands nor 
those acquired from the Church are occupied by cattle. The one 
remaining step to achieve the condition of cattle no longer grazing in 
this area is for the partner agencies to acquire livestock grazing 
rights on the remaining private RTR lands. Until cattle no longer graze 
on these lands, no bison will be allowed to roam beyond the park's 
northern border, and the agencies will not be able to proceed further 
under the IBMP. 

Although unsuccessful, Interior attempted to acquire livestock grazing 
rights on the remaining RTR lands in August 1999. The Church and 
Interior had signed an agreement giving Interior the option to purchase 
the livestock grazing rights, contingent upon a federally approved 
appraisal of the value of the grazing rights and fair compensation to 
the Church for forfeiture of this right. The appraisal was completed 
and submitted for federal review in November 1999. In a March 2000 
letter to the Church, Interior stated that the federal process for 
reviewing the appraisal was incomplete and terminated the option to 
purchase the rights. As a result, the Church continues to exercise its 
right to graze cattle on the RTR lands adjacent to the north boundary 
of the park, and the agencies continue operating under step one of the 
IBMP. 

More recently, the Montana Department of Fish, Wildlife and Parks has 
re-engaged Church officials in discussions regarding a lease 
arrangement for Church-owned livestock grazing rights on the private 
RTR lands. Given the confidential and evolving nature of these 
negotiations, specific details about funding sources or the provisions 
being discussed, including the length of the lease and other potential 
conditions related to bison management, are not yet available. 

Although the agencies continue to operate under step one of the plan, 
they reported several accomplishments in their September 2005 Status 
Review of Adaptive Management Elements for 2000-2005. These 
accomplishments included updating interagency field operating 
procedures, vacating national forest cattle allotments within the bison 
management areas, and conducting initial scientific studies regarding 
the persistence of the brucellosis-causing bacteria in the environment. 

Federal Land and Easement Acquisitions Sought to Provide Critical 
Habitat for Many Species, But Bison Access to These Lands Remains 
Limited: 

The lands and conservation easement acquired by the federal government 
through the RTR land conservation project sought to provide critical 
habitat for a variety of wildlife species including bighorn sheep, 
antelope, elk, mule deer, bison, grizzly bear, and Yellowstone 
cutthroat trout; however, the value of this acquisition for the 
Yellowstone bison herd is minimal because bison access to these lands 
remains limited. The Forest Service viewed the land conservation 
project as a logical extension of past wildlife habitat acquisitions in 
the northern Yellowstone region. While the Forest Service recognized 
bison as one of the migrating species that might use the habitat and 
noted that these acquisitions could improve the flexibility of future 
bison management, the project was not principally directed at 
addressing bison management issues. 

Through the RTR land conservation project, the federal government 
acquired from the Church a total of 5,263 acres of land and a 1,508- 
acre conservation easement using $13 million in Land and Water 
Conservation Fund appropriations.[Footnote 3] As funding became 
available and as detailed agreements could be reached with the Church, 
the following two phases were completed. In Phase I, the Forest Service 
used $6.5 million of its fiscal year 1999 Land and Water Conservation 
Fund appropriation to purchase Church-owned lands totaling 3,107 acres 
in June and December 1998 and February 1999. Of these lands, 2,316 
acres were RTR lands, 640 acres were lands that provided strategic 
public access to other Gallatin National Forest lands, and 151 acres 
were an in-holding in the Absaroka Beartooth Wilderness area. 

In Phase II, BLM provided $6.3 million of its fiscal year 1998 Land and 
Water Conservation Fund appropriations for the purchase of an 
additional 2,156 acres of RTR lands and a 1,508-acre conservation 
easement on the Devil's Slide area of the RTR property in August 1999. 
In a December 1998 letter to the Secretary of the Interior from the 
Chairs and Ranking Minority Members of the House and Senate Committees 
on Appropriations, certain conditions were placed on the use of these 
funds. The letter stated that "the funds for phase two should only be 
allocated by the agencies when the records of decision for the 
'Environmental Impact Statement for the Interagency Bison Management 
Plan for the State of Montana and Yellowstone National Park' are signed 
and implemented." The letter also stated that the Forest Service and 
Interior were to continue to consult with and gain the written approval 
of the governor of Montana regarding the terms of the conservation 
easement. Under the easement, numerous development activities, 
including the construction of commercial facilities and road, are 
prohibited. However, the Church specifically retained the right to 
graze domestic cattle in accordance with a grazing management plan that 
was to be reviewed and approved by the Church and the Forest Service. 
The Church's grazing management plan was completed in December 2002, 
and the Forest Service determined in February 2003 that it was 
consistent with the terms of the conservation easement. The Church 
currently grazes cattle throughout the year on portions of its 
remaining 6,000 acres; however, as stipulated in the conservation 
easement and incorporated in the grazing management plan, no livestock 
can use any of the 1,508 acres covered by the easement between October 
15 and June 1 of each calendar year, the time of year that bison would 
typically be migrating through the area. 

While purchased for wildlife habitat, geothermal resources, and 
recreational access purposes, the federally acquired lands and 
conservation easement have been of limited benefit to the Yellowstone 
bison. As previously noted, under the IBMP, until cattle no longer 
graze on private RTR lands north of the park and west of the 
Yellowstone River, no bison are allowed to migrate onto these private 
lands and the partner agencies are responsible for assuring that the 
bison remain within the park boundary. 

Mr. Chairman, this concludes my prepared statement. Because we are in 
the very early stages of our work, we have no conclusions to offer at 
this time regarding these bison management issues. We will continue our 
review and plan to issue a report near the end of this year. I would be 
pleased to answer any questions that you or other Members of the 
Subcommittee may have at this time. 

GAO Contacts and Staff Acknowledgments: 

For further information on this testimony, please contact me at (202) 
512-3841 or nazzaror@gao.gov. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this statement. David P. Bixler, Assistant Director; Sandra 
Kerr; Diane Lund; and Jamie Meuwissen made key contributions to this 
statement. 

[End of section] 

Related GAO Products: 

Wildlife Management: Negotiations on a Long-Term Plan for Managing 
Yellowstone Bison Still Ongoing. GAO/RCED-00-7. Washington, D.C.: 
November 1999. 

Wildlife Management: Issues Concerning the Management of Bison and Elk 
Herds in Yellowstone National Park. GAO/T-RCED-97-200. Washington, 
D.C.: July 1997. 

Wildlife Management: Many Issues Unresolved in Yellowstone Bison-Cattle 
Brucellosis Conflict. GAO/RCED-93-2. Washington, D.C.: October 1992. 

FOOTNOTES 

[1] If the Yellowstone bison herd exceeds a target population size of 
3,000 bison as set forth in the IBMP, other management actions, such as 
removing the captured bison to quarantine or slaughter, may be taken to 
reduce the size of the herd. 

[2] The Land and Water Conservation Fund Act of 1965 was enacted to 
help preserve, develop, and assure access to outdoor recreation 
resources. Among other purposes, appropriations from the fund may be 
used for federal acquisition of land and waters and interests therein. 
Pub. L. No. 88-578, 78 Stat. 897. 16 U.S.C. §460l-4, et seq. 

[3] The Forest Service and the Church chose not to complete the land- 
for-land exchanges proposed in the conservation project. 

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