United States Government Accountability Office

GAO Testimony 

Before the Subcommittee on National 

Parks, Forests and Public Lands, 

Committee on Natural Resources, 

U.S. House of Representatives 

YELLOWSTONE 

NATIONAL PARK 

Preliminary Observations 

on the Implementation of 

the Interagency Bison 

Management Plan 

Statement of Robin M. Nazzaro, Director 

Natural Resources and Environment 

For Release on Delivery 

Expected at 10:00 a.m. EDT 

Tuesday, March 20, 2007 

 

GAO-07-638T
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

March 20, 2007

YELLOWSTONE NATIONAL PARK

Preliminary Observations on the 

Implementation of the Interagency Bison

Management Plan

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

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. 

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 threestep 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.

Bison in Yellowstone National Park 

Source: GAO .

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.
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

Page 1 GAO-07-638T 
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. 

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 

Summary 

Page 2 GAO-07-638T 
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. 

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. 

Background 

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. 

Page 3 GAO-07-638T 
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 longterm 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 longterm 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 

Page 4 GAO-07-638T 
are captured or lethally removed. Generally, captured bison are tested for 

brucellosis exposure.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 

 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. 

Page 5 GAO-07-638T 
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.2

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. 

Implementation of the 

IBMP Remains in Step

One Because Cattle 

Continue to Graze on

RTR Lands 

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 reengaged 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 

 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. 

Page 6 GAO-07-638T 
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 Rev ew

of Adapt ve 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. 

i

i

 

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.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. 

Federal Land and 

Easement

Acquisitions Sought 

to Provide Critical 

Habitat for Many 

Species, But Bison 

Access to These

Lands Remains

Limited 

3

The Forest Service and the Church chose not to complete the land-for-land exchanges

proposed in the conservation project. 

Page 7 GAO-07-638T 
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 

Page 8 GAO-07-638T 
pleased to answer any questions that you or other Members of the 

Subcommittee may have at this time. 

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.

GAO Contacts and 

Staff 

Acknowledgments 

Page 9 GAO-07-638T 
Page 10 GAO-07-638T 

Related GAO Products 

Wi d fe Management: Negot a ons on a Long Term Plan or Managing 

Yellowstone B son Still Ongoing. 

l li i ti - f

i

l li i i

i ll i

l li l t tl

GAO/RCED-00-7. Washington, D.C.: 

November 1999. 

Wi d fe Management: Issues Concern ng the Management of B son and 

Elk Herds n Ye owstone Nat onal Park. GAO/T-RCED-97-200. 

Washington, D.C.: July 1997. 

Wi d fe Management: Many Issues Unresolved in Yel ows one Bison-Cat e

Brucellosis Conflict. GAO/RCED-93-2. Washington, D.C.: October 1992. 

(360813)
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