September 5, 2023

Cameron Sholly, Superintendent
Attn: Bison Management Plan
P.O. Box 168
Yellowstone National Park, WY 82190

Subject:  Comments on Draft Environmental Impact Statement for Bison Management

Dear Superintendent Sholly:

I am writing on behalf of more than 2,500 members of the Coalition to Protect America’s National Parks (Coalition), who collectively represent more than 45,000 years of national park management experience. The Coalition studies, educates, speaks, and acts for the preservation of America’s National Park System. Among our members are former NPS directors, regional directors, superintendents, resource specialists, park rangers, maintenance and administrative staff, and a full array of other former employees, volunteers, and supporters.

Our members and supporters appreciate the long-term challenges of managing bison in Yellowstone National Park. Some of us previously worked in the park and are familiar with bison management in the 1980s and 1990s. While some constituents may wish the proposal provided for greater changes, we recognize the considerable progress that has been made over the past several decades in bison science and management.

The draft environmental impact statement is a thorough yet concise and readable summary of concerns for the potential risk of bison transferring brucellosis to neighboring cattle and other issues associated with a large migrating ungulate herd. We compliment you and your staff for preparing a draft plan that considers several new options based on updated research, changing conditions, experience gained from previous actions and adaptive management, and robust discussions with cooperators and park neighbors.

We believe that both Alternatives 2 and 3 would provide Yellowstone managers and staff with increased flexibility to respond to lessons learned from the past twenty-plus years of bison management. We especially support Alternative 3, which would prioritize treating bison more like the ecosystem’s other wild ungulates, especially elk. This proposal is a reasonable and practical response to the recognition that there have been no documented cases of bison transmitting brucellosis to livestock, while the National Academies of Science found at least 27 instances of elk transmitting the disease to livestock since 1998. Based on the success of already-implemented actions, such as the Bison Conservation Transfer Program (BCTP) involving Fort Peck and other tribal lands and the tribal and public hunting outside the park, Alternative 3 would achieve bison population goals that would benefit or at least not adversely affect other natural or cultural resources.

It is apparent that in this century, the park has significantly strengthened its working collaborations with numerous tribes and with the InterTribal Buffalo Council, to the benefit of bison management, the NPS, and those traditional users of bison. Actions common to all alternatives as well as proposed Alternatives 2 and 3 have been made possible due to the increased cooperation and tolerance by APHIS, the Custer-Gallatin National Forest, and the State of Montana for Yellowstone bison outside park borders. This no doubt reflects years of interagency communication and relationship-building for which park and partner staffs are to be commended. And it is imperative that such cooperation across agencies and border continue into the future, to achieve bison management and many other park and ecosystem objectives.

We are pleased that Alternative 3 proposes to immediately cease captures of bison for shipment to slaughter. The draft environmental impact statement nicely explains the evolving science on how many bison Yellowstone can support based on plant productivity, summer and winter conditions, migration patterns, and hunting outside the park. It appears that you have carefully considered the potential for bison numbers to increase under each alternative and provided that, if bison exceed desired conditions for numbers and/or the bounds of tolerance zones outside park boundaries, the NPS could reinstitute such capture and control. We appreciate tying such an intensive population management action more closely to desired conditions and encourage continued monitoring and adaptive management to reduce the likelihood that bison would need to be captured for slaughter in the future.

We note that the NPS has not identified a preferred alternative in the draft environmental impact statement, which is an exception to guidance in the NPS NEPA Handbook 2015, Section 4.3 C, and in the DOI NEPA implementing regulations at 43 CFR § 46.425. We suggest that NPS include in the final environmental impact statement an explanation for not identifying a preferred alternative in the draft EIS.

In closing, bison management in Yellowstone has a long and storied history, from the time when the park preserved the last few wild bison to the present day, when you face struggles of managing a burgeoning herd of migratory giants. We know that your program has and will continue to require considerable time and attention by the park as well as partner tribes, individuals, and agencies. Nevertheless, it is marvelous to consider the success of bison recovery in the park, a recovery that contributes to the integrity of the ecosystem’s natural and cultural resources while providing for countless visitor experiences. We appreciate the opportunity to provide comments on this plan.


Michael B. Murray
Chair of the Executive Council
Coalition to Protect America’s National Parks