Yellowstone Bison: Interagency Plan and Agencies' Management Need Improvement to Better Address Bison-Cattle Brucellosis Controversy
Published: 2008-03-07T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Federal and Montana state agencies have long been entangled in controversy over bison leaving Yellowstone National Park. Some of these bison, as well as elk and other wildlife, have a contagious disease called brucellosis, which can cause pregnant animals to abort. Montana livestock owners and government officials fear that if bison are allowed to leave the park, the disease could spread to cattle, potentially threatening the economic health of the state's livestock industry. To help manage this issue, three federal and two state agencies have been implementing a bison management plan that they agreed to in 2000. This report discusses (1) the progress made in implementing the bison management plan and (2) the plan's soundness and the effectiveness of the agencies' implementation of it for managing bison-related issues in and near Yellowstone National Park. GAO reviewed documentation and research on bison and brucellosis and interviewed federal and state officials and key stakeholders.
section_title: What GAO Found
paragraphs: The federal and state agencies implementing the interagency bison management plan have made less progress than they originally anticipated. These agencies--the U.S. Department of Agriculture's Animal and Plant Health Inspection Service and Forest Service; the Department of the Interior's National Park Service; Montana Fish, Wildlife and Parks; and the Montana Department of Livestock--had expected to progress to step two of the three-step plan by winter 2002-2003. Each of the plan's three successive steps for managing bison is intended to incrementally increase tolerance of bison roaming outside the park. As of late 2007, however, the agencies remained in step one because they have yet to meet two important conditions for moving to step two--first, that no cattle graze on a ranch north of the park, and second, that a safe and effective remote brucellosis vaccine-delivery system be available for bison. Nevertheless, the agencies have completed a number of other tasks called for in the plan, including maintaining the separation of bison and cattle in space and time and conducting some scientific research. Combined, the agencies have spent more than $2 million annually implementing the plan, with the federal government and state agencies funding about 95 percent and 5 percent of these expenditures, respectively. The agencies have no estimate regarding how long it will take to meet the conditions for starting step two, nor have they revised their estimated dates for reaching step three, which was expected by winter 2005-2006. Key deficiencies in the plan, and the agencies' implementation of it, limit their effectiveness with regard to managing bison-related issues. The plan has two broadly stated goals: to "maintain a wild, free-ranging population of bison and address the risk of brucellosis transmission." The plan, however, contains no clearly defined, measurable objectives as to how these goals will be achieved, and the partner agencies have no common view of the objectives. As a result, the agencies have no way to determine the effectiveness of the plan or of their management efforts. Also, in developing the plan, the agencies adopted an adaptive management approach that promotes flexible decision making in the face of uncertainties as outcomes from management actions and other events become better understood. But the agencies have not adequately implemented adaptive management, in that they (1) have not established critical linkages among clearly defined objectives (which are absent from the plan), information about the impacts of their management actions obtained through systematic monitoring, and decisions regarding adjustments they make to the plan and their management actions; (2) have continued to act more as individual entities, rather than as a cohesive interagency group; and (3) have not adequately communicated with or involved key stakeholders, such as conservation groups, livestock industry groups, and private landowners. Consequently, their decision making more often resembles trial and error than adaptive management and also lacks accountability and transparency.

section_title: Letter
paragraphs: Long symbolic of the vastness of North America’s plains, American  buffalo, or bison, today roam freely only in a few places, including  Yellowstone National Park. The park lies at the heart of the Greater  Yellowstone Area, which overlaps portions of Idaho, Montana, and  Wyoming and encompasses two national parks, six national forests, and  several national wildlife refuges and wilderness areas. Outside the two  national parks, privately owned lands are interspersed throughout these  federal lands, including the Royal Teton Ranch, which, as we previously  reported, has been a focus of federal land conservation efforts near the  park since the late 1990s. The park’s herd—which has grown from fewer  than 25 bison in 1901 to nearly 5,000 animals as estimated in late summer  2007—is the largest free-ranging bison herd in the United States and one of  the few U.S. herds that show no evidence of genetic mixing with cattle. As  their population has grown and they have roamed beyond the park’s  boundaries onto surrounding private and public lands in Montana,  Yellowstone bison have been at the center of a controversy that has raged  for more than two decades.
Throughout the winter and early spring, tens, sometimes hundreds, of  bison move naturally between Yellowstone National Park and adjacent  public and private lands, some of which may also be used by livestock  owners to graze cattle. Some of the bison, as well as elk and other wildlife  in and around the park, harbor a contagious and untreatable disease,  brucellosis, which can cause pregnant animals to abort their calves. Fears  of this disease and differing wildlife management philosophies have  contributed to the long-running controversy. Specifically, many ranchers  and some of the federal and state officials responsible for brucellosis  management believe that if wildlife poses a disease transmission risk to  cattle, it is the diseased wildlife that should be the focus of management  efforts. Some conservationists, in contrast, argue that ranchers and  government agencies should strengthen disease mitigation and  management efforts within the livestock industry, such as limiting  livestock grazing on national forest lands near the park, vaccinating cattle,  or improving fencing of cattle herds. Moreover, while brucellosis-infected  bison and elk in Montana both present a risk to the cattle industry, bison  have historically been subject to strict disease-control measures, including  slaughter when they attempt to leave the national park, whereas elk— which have a lower incidence of brucellosis but are more numerous than  bison—are allowed to roam with relatively few restrictions. No known  cases of brucellosis transmitted from bison to cattle have been  documented in the wild and some conservationists point to this fact to  suggest that current bison management actions are unnecessary. In  contrast, Montana’s State Veterinarian maintains that this absence of  documentation does not indicate a low risk of transmission, but rather  provides evidence that the various park boundary control programs to  manage Yellowstone bison have been effective. Furthermore, Montana  livestock owners and government officials fear that if such a transmission  did occur, the economic consequences to the state’s livestock industry  could be devastating. A brucellosis infection identified in a single cattle  herd in Bridger, Montana, in May 2007 underscored rancher’s fears. While  the source of the infection has not been determined, the Montana  Department of Livestock indicated that the infection was unlikely to have  come from bison.
In an effort to begin defusing this controversy, five federal and state  agencies—the Forest Service and the Animal and Plant Health Inspection  Service (APHIS), within the U.S. Department of Agriculture; the National  Park Service (Park Service), within the Department of the Interior; and  Montana Fish, Wildlife and Parks as well as the Montana Department of  Livestock—agreed in the early 1990s to develop a joint, long-term bison  management strategy. Under different mandates and authorities, these  agencies all have some jurisdiction over the bison management effort. The  Park Service is responsible for resources—both habitat and wildlife— within the park’s boundaries. Outside the park in Montana, the Forest  Service manages habitat on national forest lands, while the state’s Fish,  Wildlife and Parks is responsible for managing habitat on some state- owned lands and wildlife on all lands, including national forest lands. In  addition, because of concern over the risk that brucellosis-infected bison  may pose to the livestock industry, the Montana state legislature in 1995  granted the Department of Livestock the authority to take certain actions  on public or private land with respect to bison originating from the park,  including removing or destroying them. APHIS is responsible for  controlling and preventing the spread of communicable and contagious  diseases of livestock, including brucellosis. Since APHIS first instituted a  national brucellosis control program in 1934, billions in federal, state, and  industry funds have been spent trying to eradicate the disease from cattle  across the nation. As of February 2008, APHIS announced that for the first  time in the 74-year history of the brucellosis control program, all 50 states  have been declared brucellosis free.
Efforts to develop a long-term bison management strategy in the early  1990s were slow, largely because of the five agencies’ differing wildlife  management philosophies. The Park Service opposed efforts to manage  bison in any way that would restrict the animals’ ability to roam freely and  thereby go against the park’s policy to manage wildlife by natural  regulation—a policy that allows factors such as climate, food supply, and  predation to regulate most wildlife populations in the park. During that  period, however, APHIS, which is committed to eradicating brucellosis in  the United States, argued that wildlife should be tested for exposure to the  disease and, if infected, slaughtered to prevent its spread. In 1995,  Montana sued the Park Service and APHIS, fearing that the federal  agencies’ conflicting wildlife management policies might cause APHIS to  downgrade the brucellosis classification of Montana’s livestock, which has  been certified since 1985 to be free of brucellosis. Under APHIS’s  brucellosis eradication program, a classification downgrade could result in  significant economic consequences to both individual herd owners and the  state. For example, a downgrade could restrict the state’s livestock  producers’ access to interstate and international markets. To settle  Montana’s lawsuit, the federal and state governments agreed to develop  interim bison management procedures and an environmental impact  statement for managing bison long term. In 1996, the agencies began  implementing an interim bison management plan, which resulted from the  settlement agreement. After four more years of mediated negotiations— nearly a decade after joint planning efforts began—an interagency bison  management plan for the Yellowstone bison was agreed upon by the five  federal and state partner agencies in December 2000.
The agreed-upon plan includes three successive steps for managing bison  on the northern and western boundaries of Yellowstone National Park in  areas to which some bison typically attempt to migrate in the winter and  early spring. The plan’s two stated purposes, or goals, are 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 runs throughout the bison management  plan and the plan’s outlined management actions demonstrate the  agencies’ long-term commitment toward eventually eliminating brucellosis  in Yellowstone bison, the plan itself does not seek to eliminate brucellosis  in bison. Instead, through its successive management steps, it aims to  create and maintain separation between bison and cattle in space and time  that is sufficient to minimize the risk of brucellosis transmission.  Ultimately, each step of the plan is intended to incrementally increase  tolerance for bison to roam outside the park. For example, under step two,  up to 100 bison testing negative for exposure to brucellosis will be allowed  to migrate to a bison management zone outside the park’s northern  boundary, where they are prohibited before step two is reached. When  step three is fully implemented, the same number of bison will be allowed  to pass into this same zone but will not have to be tested beforehand. Even  under step three, however, the plan calls for management actions,  including driving bison toward the park’s interior (hazing), and capturing  those that do not remain inside to prevent more than 100 bison from  exiting the park into this bison management zone. The captured bison  testing positive for brucellosis would be sent to slaughter while the bison  testing negative may be returned to the park, sent to a bison quarantine  facility, sent to slaughter, or removed for approved research.
Given the uncertainties regarding brucellosis and bison behavior at the  time that the partner agencies were crafting their bison management plan,  the agencies adopted an adaptive management approach—one that would  allow them to modify the plan as better information became available  through scientific research and operational experience. According to  adaptive management experts, this approach enables managers to operate  in the face of uncertainty and to learn by doing, thereby leading to  improved understanding and more-effective management over time. In  principle, learning in an adaptive management setting involves  systematically testing—either operationally, scientifically, or both— different management alternatives to gain knowledge. The alternatives are  developed on the basis of the best information available at the time, and,  as management proceeds, techniques that do not work are modified or  replaced by others. Adaptive management shares a number of key features  with best management practices—such as those articulated in the  Government Performance and Results Act of 1993 and the Comptroller  General’s 2004 forum on high-performing organizations—including  identifying clearly defined, measurable, and results-oriented management  objectives; designing and implementing a monitoring plan; making  decisions based on management objectives; effectively managing  partnerships while maintaining accountability to Congress and the public;  and actively involving key stakeholders over time to engender public  support.
In this context, this report discusses (1) the progress made in  implementing the interagency bison management plan and (2) the  soundness of the plan and the effectiveness of the agencies’  implementation of it with regard to managing bison-related issues in the  Greater Yellowstone Area.
To address these objectives, we interviewed officials from the Park  Service; Forest Service; APHIS; Montana Fish, Wildlife and Parks; and the  Montana Department of Livestock to obtain information about the  progress the agencies have made in implementing the interagency bison  management plan. We collected and reviewed available documentation of  agency management practices, accomplishments, and expenditures related  to bison and brucellosis management and recent scientific research on  various topics related to brucellosis and wildlife, including the safety and  effectiveness of brucellosis vaccines and available tools for diagnosing the  disease. To obtain a wide range of perspectives on the federal and state  agencies’ implementation of the plan, we also interviewed numerous  individuals from key stakeholder constituencies, including  conservationists, livestock industry representatives, local ranchers,  permittees of public livestock grazing allotments, Native American tribes,  hunting enthusiasts, lessees of private land, and other private landowners.  Appendix I presents a more detailed description of our objectives, scope,  and methodology. We conducted this performance audit from January  2007 through March 2008 in accordance with generally accepted  government auditing standards. Those standards require that we plan and  perform the audit to obtain sufficient, appropriate evidence to provide a  reasonable basis for our findings and conclusions based on our audit  objectives. We believe that the evidence obtained provides a reasonable  basis for our findings and conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: The greater Yellowstone region covers about 20 million acres overlapping  Idaho, Montana, and Wyoming. Commonly called the Greater Yellowstone  Area, Greater Yellowstone Ecosystem, or just Greater Yellowstone, the  region is home to numerous species of wildlife, including bison. It  encompasses two national parks—Yellowstone and Grand Teton—as well  as several other federally managed areas, including the Gallatin, Custer,  Shoshone, Bridger-Teton, Caribou-Targhee, and Beaverhead national  forests; the National Elk Refuge; and the John D. Rockefeller, Jr.,  Memorial Parkway. Privately owned lands, including the Royal Teton  Ranch north of Yellowstone National Park and west of the Yellowstone  River, are interspersed throughout these federal lands, and a number of  towns dot the landscape (see fig. 1). The Greater Yellowstone Area has  also earned the distinction, according to APHIS, of being the nation’s last  known reservoir of the brucellosis bacterium, Brucella abortus, which is  present in the region’s bison and elk populations.
Bison, which are native to the Greater Yellowstone Area, were observed  by early travelers both before and after Yellowstone National Park was  created in 1872. Bison hunting and poaching in the late 1800s substantially  diminished the Yellowstone herd, and, by 1901, fewer than 25 animals  remained (see fig. 2). To save this wild herd from extinction, park  managers in 1902 imported 21 bison from captive herds in Texas and  Montana. Although the wild and captive herds were initially kept separate,  they began to intermingle between 1915 and 1920, and after the 1920s, little  or no effort was made to keep the two populations separate. By the 1930s,  the park’s wintering bison had increased to more than 1,000 head, and the  park began managing the herd by shipping animals to public parks, zoos,  and privates estates around the country. From the 1920s through the late  1960s, the bison herd was managed through culling, supplemental feeding,  and other activities until the park instituted a policy of natural regulation  of wildlife populations, whereby a species’ population size is left to  respond to environmental conditions like climate or food supply without  human interference. By the early 1980s, the bison herd had grown to more  than 2,300 head, and bison were increasingly reported moving beyond the  park’s boundaries into Montana. During the mid-1980s through 1999, a  total of 3,176 bison that crossed outside the park’s northern or western  boundaries were killed, under a series of park boundary area management  approaches implemented by the Park Service and Montana. Since 2000,  boundary area management action by federal and state agency officials  have lethally removed more than 1,900 bison, but the herd has continued  to grow, with nearly 4,700 head counted in late summer 2007.
Bison, as well as wildlife such as elk, may carry the bacterial disease  brucellosis, which is also contagious to humans and domestic animals.  Known in humans as undulant fever, brucellosis can be hard to diagnose  because early symptoms, such as intermittent fever and joint pain, are  shared with several other diseases; although rarely fatal, the disease can  be debilitating. However, thanks to widespread pasteurization of dairy  products since the early twentieth century, very few cases of undulant  fever have occurred in the United States, and the disease today poses a  risk mainly to hunters, large-animal veterinarians, and ranchers. In some  animals, including cattle, the disease can cause abortions, infertility,  reduced milk production, lameness, and swollen joints. In the Yellowstone  area, bison and elk are the disease’s principal wildlife hosts. Results of  blood tests done by the Park Service over the past several decades  indicate that about half of the Yellowstone bison have been exposed to  brucellosis. Some bison may develop immunity or have a natural  resistance to the disease, while other animals may develop recurrent  infections and remain carriers and a source of exposure and possible  infection for other animals.
The first known case of brucellosis in Yellowstone bison was reported in  1917 and is believed to have been transmitted from domestic cattle.  Transmission occurs primarily through ingestion of infected products of  birth or abortion. As a result, the risk of transmission is greatest if cattle  and bison are in each other’s presence immediately after birthing.  Although vaccinating cattle provides some protection, it does not  eliminate the infection risk, as evidenced since 2004 by instances of  brucellosis transmission from infected wildlife to vaccinated cattle in  Idaho and Wyoming. Within the scientific community and among people  interested in bison management, opinions differ about whether it is most  appropriate to control or to eradicate the disease. Within the regulatory  community, however, APHIS officials remain committed to establishing  the means to suppress and eliminate contagious livestock diseases,  including brucellosis.
Although both bison and elk carry brucellosis, the two species are  managed differently by federal and state agencies. Yellowstone bison are  subject to strict disease-control measures, ranging from capture and  vaccination to slaughter, whereas elk herd movements are not restricted.  Agency officials indicate that this difference in management approach  stems largely from the lower prevalence of brucellosis in elk than in bison,  combined with the tendency of elk to feed at higher elevations than bison  and to calve in isolation, thereby lessening the risk of transmission. This  difference in management remains even though there have been multiple  suspected elk-to-cattle transmissions in recent years in Idaho and  Wyoming, some of which have been detected through DNA testing; the  National Research Council reported in 1998 that the risk of transmission  from bison to cattle was low; and there have been no known cases of  brucellosis transmitted from bison to cattle in a wild, uncontrolled setting.  APHIS scientists note, however, that although transmission in the wild is  difficult to document—particularly given the decades-long effort to  maintain separation between bison and cattle—controlled tests have  proven that it is possible for bison to transmit the disease to cattle. We  reported in 1997 that the extent to which domestic cattle risk infection  through exposure to diseased bison and elk—either from mingling directly  with infected wild animals or from using rangeland where infected wild  animals had previously grazed—was the subject of the bison management  controversy between the federal and state agencies because the risk of  such transmission had not been quantified. Scientists and researchers  disagreed on even the most basic factors influencing the risk of  transmission, such as whether studies on cattle are applicable to bison.  Ten years later, such debates continue.
To keep bison away from cattle and mitigate the risk of brucellosis  transmission, the interagency bison management plan describes agency  activities to restrict bison movement to or through bison management  zones within or just beyond the park’s boundaries near Gardiner, Montana,  on the north, and near West Yellowstone, Montana, on the west (see fig.  3). During step one of the three-step plan, bison attempting to leave the  park on the north side are to be hazed, captured, or killed, and a limited  number of bison on the west side of the park—as many as 100 animals— that test negative for brucellosis exposure are allowed to roam in bison  management zones outside the park. Once this limit on the west side is  reached, additional bison crossing beyond the western boundary are also  to be hazed, captured, or killed. The plan states that all captured bison are  to be tested for brucellosis exposure at capture facilities located on the  park’s northern and western boundaries. Partner agency officials may  take a variety of actions with captured bison testing negative for exposure  to the disease, including vaccinating and temporarily holding them in the  northern capture facility for release back into the park or removing them  for research. Bison that test positive for brucellosis exposure are generally  to be sent to slaughter.
Under both steps two and three of the plan, the majority of bison must be  prevented from leaving the park, and the few bison that are allowed to  leave are generally to be restricted and monitored within the bison  management zones and other management areas. Step two on the park’s  north side will allow up to 100 bison testing negative for brucellosis to be  released into these bison management zones; pregnant females are to be  monitored using radio telemetry, and all bison are to be hazed back into  the park or otherwise removed by April 15 of each year. Under step two,  on the park’s west side, up to 100 bison that have not been tested will be  allowed to exit the park, and officials are required to vaccinate these bison  remotely; May 15 is the deadline for all bison to be back in the park.  Similarly, in step three, an effective remote vaccination program must be  operating in the park before up to 100 untested bison will be allowed out  of the park into the bison management zones on both the north and west  sides. However, except in a few locations, if more than 100 bison attempt  to migrate beyond the park’s northern and western boundaries, under step  three they are to be hazed, captured, or killed. Many of the management  actions specified in step one are to continue indefinitely, even when step  three is fully implemented.
A brucellosis outbreak among domestic cattle in Montana would likely  have the following direct effects: (1) abortion of calves, (2) decreased  weight gain by calves, (3) delays in calf production, (4) increased rates of  culling and replacement, and (5) increased testing and vaccination costs.  Furthermore, the presence of the disease could also restrict access by the  state’s livestock producers to interstate and international markets,  resulting in potentially severe economic impacts, particularly for  producers of breeding stock. Under APHIS’s brucellosis eradication  program, if a single herd of livestock becomes infected, the infected  animals are to be slaughtered, the herd quarantined or slaughtered, and  the herds in the surrounding area tested to ensure that the disease does  not spread. If no additional infections are found within 24 months, the  state may retain its brucellosis-free status. If, however, an additional herd  were found to be infected with brucellosis, the state’s classification would  be lowered, and additional interstate testing requirements would be  imposed statewide. Because of the increased movement of potentially  exposed or infected bison out of Yellowstone National Park, some states  have threatened to require additional testing of any cattle entering their  states from Montana and Wyoming. Such actions could have significant  economic consequences to Montana’s livestock industry if downgrading  occurred, similar to those experienced by Idaho and Wyoming when their  brucellosis certifications were downgraded after outbreaks in 2004 and  2005, respectively. By one calculation, Montana officials estimated that a  downgraded status would have an annual economic impact on the state of  at least $4 million. However, these officials noted that this estimate was  likely to be low because they considered only the cost of additional testing  required for cattle—not other factors, such as increased operating costs,  impacts on agricultural markets, or direct effects on producers. A more  complex economic analysis conducted for the partner agencies showed  potential annual economic impacts of the increased testing as high as  $16.3 million and, with a potential decrease in out-of-state demand, an  estimated $9.8 million to $38.8 million decrease in the price of cattle.
Faced with complex issues like the bison-cattle brucellosis controversy,  wildlife and natural resource managers have been increasingly encouraged  to use an adaptive management approach as a way to work within a  dynamic natural environment that has become complicated by people  moving into and development within or near these areas. In addition, a  move toward accountability and transparency in natural resource  management, demanded by the general public, has led to a growing need  for collaborative, structured approaches to decision making. Adaptive  management emerged in the late 1970s and 1980s as one such approach,  rooted in parallel concepts found in business and science best- management practices. In 2004, the National Research Council defined  adaptive management as a process that promotes flexible decision making  in the face of uncertainties, as outcomes from management actions and  other events become better understood. This approach (1) emphasizes  collaboration among resource managers, researchers, and stakeholders  and stakeholder involvement and (2) encompasses several closely linked  steps, including assessing the problem, designing a plan that includes  measurable management objectives and exploring alternative ways to  meet them, predicting the outcomes of alternatives and implementing one  or more of them, monitoring the impacts of the selected management  actions, and evaluating and using the results to adjust management actions  (see fig. 4).
Although adaptive management has been widely discussed in academic  literature for decades and has been called for in many resource-planning  documents and cited by resource managers, it has rarely been  implemented effectively in practice, according to some experts. In the  early 1990s, for example, in a plan intended to defuse a bitter controversy  over the need for habitat for the threatened spotted owl and the desire to  log old-growth forests in the Pacific Northwest, the Forest Service  attempted to shift its forest management practices toward an adaptive  management paradigm, with mixed results. Still, adaptive management  continues to be viewed as a potentially useful decision-making approach  for engaging partners collaboratively in managing shared natural  resources. As recently as 2007, for example, the Department of the Interior  produced guidelines for adaptive management and developed a training  program to acquaint its staff with its practice and implications.
section_title: Agencies Have Made Less Progress Than Anticipated in Implementing the Interagency Bison Management Plan
paragraphs: The partner federal and state agencies have made less progress in  implementing the interagency bison management plan than they originally  anticipated. When the agencies agreed to the plan in December 2000, they  expected to progress to step two by winter 2002–2003; as of December  2007, however, they remain in step one. Specifically, the agencies have not  yet met two significant conditions for moving into step two: first, that no  cattle graze on the Royal Teton Ranch north of Yellowstone National Park  and, second, that a safe and effective remote vaccine-delivery mechanism  be available. The agencies have, however, completed a number of other  tasks called for in the plan, including management actions to keep bison  and cattle separate in space and time; some scientific research, such as  investigating the persistence of the Brucella abortus bacterium in the  environment; and additional measures to prevent the spread of the disease  to livestock. The agencies have spent in excess of $2 million annually on  plan implementation since 2002, with the federal government funding at  least 95 percent of these costs and the state agencies funding the  remainder. As of December 2007, the agencies had no estimate for how  long it will take to complete the conditions for moving to step two, nor do  they have plans to revise their estimated dates for reaching step three.
subsections: section_title: Agencies Remain in Step One of a Three-Step Plan
paragraphs: Although the federal and state partner agencies had anticipated  progressing to step two on the north and west sides of the park by winter  2002–2003, they have not yet met the following two significant conditions  necessary for doing so:    On the park’s north side, the remaining condition for moving to step  two is that cattle no longer graze on the Royal Teton Ranch north of  the park. A lease agreement to graze cattle on the ranch was set to  expire in 2002, and when the plan was written, the partner agencies  expected that no cattle would remain on the ranch after that date. In  1999, the federal government sought to acquire the ranch’s grazing  rights in perpetuity to keep the land cattle-free, but negotiations  between the government and ranch owners failed in early 2000  because of irreconcilable differences of opinion over the monetary  value of those rights. Nevertheless, when the plan was finalized later in  2000, the requirement that no cattle graze on the ranch remained in the  plan as a condition for moving to step two. Meanwhile, the ranch  owners continued to graze cattle on the ranch, and negotiations over  removal of these cattle did not resume until 2005, when the ranch  owners agreed to discuss with Montana Fish, Wildlife and Parks a  possible deal for the grazing rights. According to a Montana Fish,  Wildlife and Parks official, the parties have tentatively reached  agreement on a 30-year grazing lease that would remove cattle from  the property and provide a corridor for a limited number of bison to  travel across the ranch in winter to access national forest system land  north of the ranch. As of December 2007, issues needing to be resolved  in order for the agreement to be finalized included obtaining funding  commitments from various sources for the tentatively negotiated lease  price and determining which entity would be responsible for the  installation and maintenance of the infrastructure, such as fencing and  cattle guards, to delineate the bison corridor.
On the park’s west side, progressing to step two is contingent on  meeting another key condition, the development of a safe and effective  remote vaccine-delivery mechanism. The Park Service moved toward  this goal in January 2004, when it established that RB51, a brucellosis  vaccine originally developed for cattle, was also safe for bison calves  and yearlings. Once a safe vaccine was identified, the Park Service  began developing a draft environmental impact statement evaluating  remote delivery alternatives for a parkwide vaccination program. For  example, Park Service worked with Colorado State University  researchers to develop an improved way to encapsulate the brucellosis  vaccine in a special biobullet that could be remotely administered to  bison using air rifles. Park Service officials expect to release their draft  environmental impact statement for public comment in summer 2008.
section_title: Agencies Have Completed a Number of Plan Tasks
paragraphs: As of December 2007, the agency partners had completed a number of  other tasks called for in step one of the plan. For example:  In 2002, the agencies established interagency operating procedures  outlining their respective roles and responsibilities for restricting bison  to areas generally within or just beyond the park’s boundaries. Outside  the park, the Montana Department of Livestock has the lead  responsibility for all bison management actions and may request  assistance from Montana Fish, Wildlife and Parks; the Forest Service;  APHIS; and the National Park Service. Inside the park, Park Service  has the lead responsibility for all bison management actions. In  November 2007, the agencies updated these procedures, providing  greater details regarding responsibilities related to law enforcement,  private property protection, and media relations, among others.
The agencies have also conducted scientific research, such as  investigating the persistence of the brucellosis-causing bacteria in the  environment, to better understand transmission risks. Agency officials  have determined that their findings on the amount of time the bacteria  remained viable in the environment validated the amount of time  required by the plan to separate bison and cattle grazing on the same  lands. Other agency research has included extensive testing to identify  a safe vaccine for bison and to evaluate the vaccine’s risk to wildlife  other than bison. The results of this research enabled the agencies to  verify the safety of RB51 for delivery by injection to bison calves, and  the agencies vaccinated a limited number of calves and yearlings  (about 120) in 2004 and 2005. According to a park official, a team of  Park Service researchers also annually collect a variety of bison data,  including data on survival (especially the survival of females and  calves), movement patterns on the landscape, and estimated  population.
Two of the partner agencies—APHIS and the Montana Department of  Livestock—have implemented additional risk mitigation measures  identified in the plan to prevent the spread of the disease to livestock.  These measures include ensuring that all vaccination-eligible cattle  (calves and yearlings) within specific bison management zones on the  north and west sides of the park have been vaccinated and annually  testing cattle that graze seasonally in these management zones to help  monitor and prevent the spread of the disease. According to APHIS  officials, all ranchers with cattle in the bison management zones are in  compliance with the vaccination risk mitigation measure, and Montana  Department of Livestock officials ensure that annual testing is  completed on cattle that graze seasonally in these zones.
section_title: Partner Agencies Have Spent More Than $2 Million Annually to Implement the Plan
paragraphs: Since 2002, the partner agencies have spent more than $2 million annually  implementing plan activities, including bison management actions and  research (see table 1). Federal funding has exceeded 95 percent of these  annual expenditures and state funding has composed the remainder (see  fig. 5). National Park Service and APHIS expenditures make up most of the  federal spending. APHIS provides nearly $1 million annually to the  Montana Department of Livestock for bison operations and research  activities, in addition to what APHIS spends on its own operating costs.
In addition to these annual costs, the Forest Service and the Department  of the Interior also spent nearly $13 million in the late 1990s to purchase  land and a conservation easement just north of the park. The land was  acquired to protect geothermal resources; improve recreational access;  and provide habitat for a variety of wildlife species, including bison. The  conservation easement was purchased to prohibit development on the  private land, such as the construction of commercial facilities and roads.
section_title: Agencies Have Not Revised Plan Timeline Estimates
paragraphs: The agencies have no estimate for how long it will take to complete the  remaining two conditions for moving to step two, nor do they have plans  to revise their estimated dates for moving to step three, which they had  expected to reach by winter 2005–2006. According to agency officials with  whom we spoke, they have not completed the requirements in step one as  quickly as they had expected, in part, they said, because the original  estimates in the plan were overly optimistic. Neither have they revised  their estimated timelines for reaching steps two and three because,  according to a Forest Service official, such efforts would not be the best  use of their time, given the number of variables beyond the agencies’  control. For example, the agencies have limited control over when, or  even if, cattle will no longer graze on the Royal Teton Ranch.  Consequently, partner agency officials have discussed, but have no plans  for, revising the estimated completion dates as stated in the plan, leaving  the expected date for reaching step three uncertain.
section_title: Key Deficiencies in the Plan, and the Agencies’ Implementation of It, Limit Their Effectiveness with Regard to Managing Bison-Related Issues
paragraphs: Key deficiencies in the bison management plan, and the agencies’  implementation of it, limit their effectiveness with regard to managing  bison-related issues. The plan lacks clearly defined, measurable objectives  against which actual outcomes can be compared to guide the agencies’  decision making and to measure the effectiveness of their actions. Without  such objectives, the agencies lack a sound basis for selecting and  monitoring their management actions, triggering adjustments to those  actions, and determining the plan’s effectiveness. In addition, the agencies’  failure to adequately implement an adaptive management approach has  limited the effectiveness of their bison management efforts. The agencies  adopted an adaptive management approach in the plan so that they could  continue to address uncertainties related to bison and brucellosis, while  still taking actions to manage bison. But their efforts to implement an  adaptive management approach have been undermined because all  components of adaptive management—from collecting information about  their management actions through a systematic monitoring program to  adjusting their management actions—should flow from clearly defined  objectives, which are absent from the plan. In addition, while adaptive  management principles emphasize effectively managed partnerships and  active involvement of stakeholders, the agencies have acted more as  individual entities than as a cohesive interagency group, and they have not  adequately communicated with or involved stakeholders. Consequently,  the agencies’ decision making lacks accountability and transparency, more  often resembling trial and error or crisis management, rather than adaptive  management.
subsections: section_title: The Plan Lacks Clearly Defined, Measurable Objectives
paragraphs: The interagency bison management plan lacks clearly defined, measurable  objectives against which actual outcomes can be compared to guide the  agencies’ decision making and to measure the effectiveness of their  actions. Objectives in adaptive management plans should specify desired  measurable outcomes, be achievable given the capacities of the natural  resource system being measured and the political or social system within  which management occurs, and indicate the time frame for achievement.  Explicit articulation of measurable objectives helps to distinguish adaptive  management from trial and error, because the objectives direct and justify  the exploration of specific management options over time.
The interagency bison management plan does not have clearly defined,  measurable objectives, and the partner agencies share no common view of  the objectives. Consequently, the agencies have no sound basis for making  decisions or measuring the success of their efforts. Although the plan  includes a section titled “Objectives,” this section does little more than  state the plan’s overall goals to maintain a free-ranging bison herd and to  address the risk of brucellosis transmission to protect the livestock  industry. When we asked officials of the five partner agencies to refer us to  the specific objectives by which they are managing, their responses varied.  Some agency officials referred to the overall goals, others directed us to 14  tasks the agencies identified in a 2005 status review, still another cited 9  objectives from the final environmental impact statement that preceded  the adopted plan, and one official could not recall any objectives. Although  the items they referred to were not completely distinct from one another,  they were not included in the plan as objectives and lacked the specificity  and metrics needed to provide a sound basis for making decisions about  management actions and measuring the effectiveness of those actions. The  plan specifically states that it does not identify how the agencies will  measure success or failure. In fact, several agency officials acknowledged  that they had not identified metrics or parameters for measuring how well  they are meeting the plan’s stated goals.
Absent explicitly stated, clearly defined, measurable objectives, the  agencies share no common view regarding how they are assessing the  effectiveness of the bison management plan. For example:    Most of the agency officials referred to the overarching dual-purpose  statement—“to maintain a wild, free-ranging population of bison and  address the risk of brucellosis transmission to protect the economic  interests and viability of the livestock industry in Montana”—as their  guide for measuring the plan’s effectiveness. Yet this statement leaves  much to interpretation. For example, to describe how the partner  agencies intend to “address” the risk of brucellosis transmission, the  plan interchangeably uses the terms “minimize” and “reduce,” despite  the different meanings of these words, and the plan does not define  either of these terms. The terms also imply that there is a recognized  baseline risk from which to measure, but despite a general agreement  among resource managers and scientists that the risk brucellosis- infected bison pose to domestic cattle is low, but greater than zero, the  agencies have not conducted a risk assessment to better quantify the  risk of brucellosis transmission and establish a baseline.
Some agency officials noted that any risk of brucellosis transmission to  cattle greater than zero is unacceptable, and that a better measure for  assessing the plan’s effectiveness is the extent to which the disease is  becoming less prevalent. Disagreement remains, however, among  professionals in wildlife science, disease, and management and in  livestock disease and management on some central issues relating to  brucellosis in Yellowstone bison, including brucellosis prevalence. The  disagreement persists because, as agency officials noted, the method  currently used to determine prevalence—a blood test indicating  exposure to the bacterium, rather than the presence of the bacterium  itself, which is the best diagnostic tool available at present—is a poor  indicator of the actual percentage of infectious animals in the  population. Long-term averages of opportunistically, rather than  systematically, collected data from Yellowstone bison indicate that the  fraction of bison that have been exposed to the bacterium falls  between 40 and 50 percent, and limited testing of bison captured  during management actions from 2001 to 2006 showed an exposure  rate generally between 35 and 55 percent. Within a herd, however, the  number of animals capable of transmitting the bacterium is generally  fewer than the number of animals with positive blood tests. Data  suggest that the percentage of infected animals—those capable of  transmitting the bacterium—may be as low as 2 percent or as high as  46 percent of animals testing positive for exposure. Further  complicating the agencies’ ability to determine the actual prevalence of  the disease within the population is that, according to brucellosis  experts, some animals can test negative for exposure and still be  infected, while the age and sex of the animal can also influence test  results. Researchers have developed a new method that specifically  tests for the presence of the brucellosis bacterium rather than the  antibodies to the bacterium, offering a potential new management  tool. This test, however, has not yet been validated for field use with  bison.
Still other agency officials believe the plan has been effective because  under the plan, they have prevented commingling of bison and cattle,  no proven transmission of brucellosis from bison to cattle has  occurred, and agency cooperation has improved.
section_title: Agencies Have Not Adequately Implemented an Adaptive Management Approach
paragraphs: The partner agencies have not adequately implemented an adaptive  management approach, which is the management strategy the agencies  specified in the plan. In principle, adaptive management distinguishes  itself from simple trial and error by its structured decision-making  approach, which emphasizes accountability and transparency. Adaptive  management is defined in the bison management plan as testing and  validating the proposed risk management and other management actions  with generally accepted scientific and management principles.  Nevertheless, several agency officials told us that the agencies interpret  the definition differently with respect to its operational implications under  the plan. Yet while different philosophies exist about how adaptive  management can be implemented, certain essential characteristics  transcend them. These characteristics include (1) linkages among key  steps, such as identifying clearly defined, measurable management  objectives; designing and implementing a monitoring program to  systematically obtain information—either operationally, scientifically, or  both—about the impacts of management actions and to reduce  uncertainties; and making decisions about adjustments to management  actions based on what is learned; (2) collaborating with agency partners;  and (3) communicating with and engaging key stakeholders.
subsections: section_title: Agencies’ Plan Implementation Lacks Linkages among Critical Steps within Adaptive Management
paragraphs: The first essential component of adaptive management—linkages among  management objectives, information obtained through a systematic  monitoring program, and decisions regarding adjustments to the plan and  their management actions—is impaired, in part, because the plan itself  lacks clearly defined, measurable objectives. Additionally, the agencies  have not designed a monitoring program to systematically collect data  from their management actions, nor have they set forth a coordinated  research agenda to resolve remaining critical uncertainties related to bison  and brucellosis-related issues. A Park Service official acknowledged that  the agencies have not designed or implemented an evaluation approach to  validate or modify the bison management plan, as needed, but said that  each agency has its own monitoring efforts, and these results are brought  to the interagency partner meetings. He said, for example, that the Park  Service conducts surveillance for all wildlife species and has developed a  long-term bison monitoring program. The data collected on bison include  population size, survival rates, and movement patterns. Another Park  Service official said that officials conducting bison management  operations use this information, but the agencies need a better focus on  what factors to monitor and what their decision thresholds should be for  management actions under the bison management plan. In contrast,  according to a Montana Fish, Wildlife and Parks official, this state agency  is not monitoring any specific variables related to the bison management  plan. Park Service, APHIS, and Montana Department of Livestock officials  also told us that they are not testing any hypotheses or the assumptions on  which the plan is based. Furthermore, the agencies have no process to  collectively review new scientific information related to brucellosis, much  less to assess how the plan may need to be changed to reflect the latest  information. A Park Service official acknowledged that within the intent of  the plan, the agency partners probably need to revisit new science as part  of adaptive management.
In the absence of a systematic monitoring program, the agencies have lost  opportunities to collect data that could help resolve important  uncertainties. The plan states that all captured bison are to be tested for  exposure to brucellosis, but fewer than half of those captured since 2001  have been tested. For example, in early winter 2006, the agencies lost an  opportunity to collect scientific data on about 900 bison. Park Service  officials captured these bison as they attempted to leave through the  park’s northern boundary. The bison were consigned to slaughter without  being tested at the capture facility because the Park Service determined  that they would not be used for research and could not be held in the  capture pens until the spring for release back into the park. The Park  Service and APHIS had instead made arrangements to collect and test  samples from the bison upon slaughter. According to APHIS officials,  however, Montana’s governor prohibited Montana Department of  Livestock officials, who are responsible for hauling captured bison to  slaughter under a federally funded cooperative agreement, from  transporting the bison in this case, primarily to avoid negative press for  the state. As a result, APHIS was left to arrange for hauling the bison to  slaughter, and the officials who were to collect and test samples from the  bison were instead reassigned to assist with the transportation efforts.
The agencies cite the following actions as examples of how they have used  adaptive management, but because their decision making lacks linkages to  clearly defined, measurable objectives and information gained through a  systematic monitoring program or research, the actions more closely  resemble trial and error than adaptive management:    The agencies made three formal management changes in November  2006. In a memorandum to the administrative record, the agencies  formally documented three changes to their 2006–2007 operating  procedures. These changes included modifying hazing operations to  allow bison to remain in certain areas outside the park, increasing  tolerance for bull bison under certain conditions, and clarifying that a  reference in the bison management plan to a population size of 3,000 is  not a target for population adjustment, but rather a population  indicator to guide implementation of risk management activities. It is  not clear, however, what objectives these changes were intended to  serve or how the agencies planned to assess whether the effects of  these changes aligned with a desired outcome. For example, with  regard to hazing, rather than push bison outside the park back into it,  where they were unlikely to remain, the agencies agreed to haze the  bison from areas of high transmission risk—where cattle would graze  in the spring—to areas of lower transmission risk—such as public  lands surrounding the park where cattle do not graze. In making this  change, however, the agencies did not articulate the basis for it or what  they hoped the outcome would be. In addition, the memorandum  stated that the reference in the plan to a population size of 3,000 bison  was a management threshold, not a population target. Yet this  statement is incongruous with several statements throughout the plan  and record of decision specifying that the agencies will control the  population size as a brucellosis risk mitigation measure.
The agencies have observed effects of their management actions.
Most agency officials with whom we spoke noted that they are not  testing specific hypotheses or assumptions on which the plan is based,  but are instead observing the effects of their management actions and  then making changes they believe are necessary. Yet, without desired  outcomes expressed in clearly defined, measurable objectives, it is  unclear how the agencies assess whether and how to change their  management. For example, when revising their operating procedures  for 2007–2008 in November 2007, agency officials reconsidered the  hazing approach they applied in spring 2007 that was outlined in the  November 2006 memorandum to the record because of the unusual  number of bison—several hundred—that remained outside the park  beyond the May 15 deadline. Agency officials indicated that if the  extent of bison migration from the park is similar to or more severe  than last year, they are prepared to haze more aggressively, hazing  earlier and pushing bison deeper into the park, despite no identified  transmissions of brucellosis from bison to cattle. The agencies have  not issued a subsequent memorandum to the administrative record to  document this change, nor do the 2007–2008 operating procedures  specify the conditions that would trigger such aggressive hazing. With  no connection to a clear management objective, the agencies’ decision  to modify their management approach on the basis of an  unprecedented situation—as the events of spring 2007 were  characterized by one Park Service official—seems little more than a  reaction to avert recurrence of a politically charged situation. In fact,  some agency officials admitted that they generally operate in a  reactive, crisis-management mode when dealing with spring bison  migrations from the park.
The agencies have conducted research on some critical uncertainties  related to bison and brucellosis. When the agencies developed the  bison management plan, several questions lacked answers, such as  how long brucellosis-causing bacteria could survive in the  environment, the likelihood that a pregnant female testing negative for  exposure to the bacteria could shed the bacteria, and how to best  diagnose the disease. Beyond identifying and conducting the following  research projects in the plan, the agencies have no coordinated  research agenda to address other uncertainties. APHIS and Montana  Fish, Wildlife and Parks staff conducted studies during 2001 to 2003 to  learn more about how long the bacteria would survive under certain  environmental conditions. In 3 of the past 7 years, the agencies have  also monitored 39 pregnant females that initially tested negative for  exposure to brucellosis to determine if they shed the bacteria into the  environment during abortion or birth. Regarding bacterial survival in  the environment, the agencies used the study results to validate  specifications in the plan related to the required separation in time  between bison and cattle—a process that aligned with adaptive  management principles. In the absence of a systematic program to  collect information through monitoring and research for use in  decision making, however, it is not clear how the agencies have used  the results of monitoring pregnant females or weighed relevant science  conducted by other researchers when considering changes to the plan.
section_title: Partner Agencies Operate More as Individual Agencies Than as a Cohesive Interagency Group
paragraphs: The agencies recognized in the plan that a coordinated, cooperative  management effort—a second essential component of adaptive  management—was necessary for plan implementation. Nevertheless, they  operate more as independent entities within their respective jurisdictions  and authorities. Although all of the agency officials with whom we spoke  said that coordination and cooperation among the partners has improved  since the plan began, and some said that they seek interagency support  when making decisions within their respective jurisdictions, others said  that finger-pointing has been an issue when it comes to taking  responsibility; still others admitted that the agencies could be doing more  to portray a shared message. For example, Montana Department of  Livestock officials said that the agencies need a strategy that better  communicates to the public that decisions are made and supported by all  five agencies. In addition, the operating procedures specify that the Park  Service is the lead decision-making agency within park boundaries, while  the Montana Department of Livestock takes the lead on most issues  outside the park. But the plan and the operating procedures are silent on  where the responsibility lies for administrative duties of the interagency  group. To date, the agencies have shared responsibility for scheduling and  leading meetings. A Park Service official said, however, that it has been  difficult to coordinate both technical staff and decision makers from all  agencies for meetings and pointed out that bison management is an added  duty for most of the staff involved. APHIS officials said the lack of a lead  agency for administrative functions, such as scheduling and documenting  interagency meetings, has been a challenge to more coordinated efforts  and that having a single agency responsible for administrative functions  would help keep the group moving forward.
section_title: The Agencies Have Not Adequately Communicated with or Engaged Stakeholders
paragraphs: A third component essential to adaptive management is communication  with and involvement of key stakeholders. The agency partners generally  believe that they have engaged stakeholders and provided sufficient  opportunities for their involvement, but several of the stakeholders we  spoke with continue to have concerns about the agencies’ transparency  with the public.
Agency officials said that since the plan began, they have held multiple  public meetings related to bison management. Still, these meetings have  generally taken place during business hours, and the discussion topics and  decisions from these meetings have not been documented or kept in a  central location convenient for public access. As a more comprehensive  outreach effort, the partner agencies hosted two large-scale evening open  houses—one in January 2007 and another in December 2007—to inform  the public on a variety of bison management related topics. At the January  2007 meeting, the agencies solicited stakeholder views on several bison  management related topics, but until early December 2007, they had not  shared with the public a summary of the ideas expressed at the January  meeting or an explanation of how they intended to use the information  they gathered. At the second open house in early December 2007, the  agencies publicly reviewed the 2006–2007 operations; provided an  overview of plans for the upcoming 2007–2008 season; discussed the  feedback they received during the January 2007 open house; and  conducted discussion sessions about bison operations, brucellosis in  Montana, and progress made to date on the plan. These efforts  notwithstanding, the agencies also lack a mechanism, such as a  coordinated interagency annual report, by which to document for the  public their collective progress related to the plan. As a result, the  agencies lack accountability among themselves and to the public, and it is  difficult for the public to obtain information without attending the  meetings or contacting each individual agency.
Several of the conservation groups, livestock industry groups, ranchers,  and private landowners with whom we spoke expressed a common  concern about the agencies’ lack of transparency with the public. Some of  the stakeholders with whom we spoke attended the January 2007  interagency open house and thought it provided a good forum for  discussing ideas, but questioned how the stakeholders’ views expressed at  the meeting would be used. Similarly, one stakeholder shared his  frustration over the agencies’ failure to consider information he had  provided relevant to potential areas for expanded bison habitat. Others  cited a need for the agencies to obtain and present to the public more  factual, scientific research information to eliminate uncertainties and  reduce the amount of factual distortion that continues to perpetuate the  controversy related to bison management. A common concern expressed  among stakeholders—that the agencies were not adhering to certain plan  provisions—may also indicate that agencies’ communication efforts have  not been clear. Specifically, several stakeholders believe that the plan  specifies a population target of 3,000 bison that the agencies are failing to  maintain. In fact, the record of decision states that “as an additional risk  management measure, the agencies would maintain a population target for  the whole herd of 3,000 bison,” and that specific measures may be  undertaken to reduce the herd’s size when the estimated population  exceeds 3,000 animals. Park Service officials believe the November 2006  memorandum to the record clarified that this reference is not a target for  population adjustment, but rather a population indicator to guide  implementation of risk management activities; nonetheless, the difference  in understanding persists.
section_title: Conclusions
paragraphs: While the interagency bison management plan put an end to litigation  among the federal and state agencies and established a forum for  continued negotiations and more cooperative action, the decades-long,  bison-related controversies continue: bison are still hazed and slaughtered  every year, and livestock owners are still concerned about the significant  economic consequences if Montana’s cattle industry loses its brucellosis- free status. Even if the agencies improve their management and fully  implement the current plan through step three, we believe the  controversies will continue, in part because critical underlying differences  among agency mandates, management philosophies, and political interests  have not been resolved. In addition, the plan lacks clearly defined,  measurable objectives to guide the agencies’ bison management actions,  and the agencies are not adequately applying an adaptive management  approach in implementing the plan. Moreover, the agencies’  implementation of the plan has remained fragmented, because no single  entity is accountable for coordinating and steering the management,  research, and resolution of these bison-related issues. In addition, the  agencies’ management lacks the accountability and transparency expected  by the public and Congress. Meanwhile, the federal government continues  to spend millions of dollars on uncoordinated management and research  efforts, with no means to ensure that these efforts are focused on a  common outcome that could help resolve the controversies. Because the  plan is not a brucellosis eradication plan, concerns about brucellosis  transmission will still require the agencies to actively manage bison  moving from the park into Montana, even if they fully implement all steps  of the plan. Given these realities, improvements in the partner agencies’  implementation of the plan, including more systematic application of an  adaptive management approach, could contribute greatly to helping  address the larger brucellosis issue in the Greater Yellowstone Area.  Multiple recent suspected transmissions of brucellosis from elk to cattle in  the area have highlighted the importance of addressing this disease in its  broader wildlife and ecological context, and doing so could have  significant implications for the future management of Yellowstone bison.
section_title: Recommendations for Executive Action
paragraphs: We recommend that the Secretaries of Agriculture and of the Interior  direct the federal agencies to work with their state agency partners to take  the following five actions:  To improve the management of Yellowstone bison in the national park and  the state of Montana:    Clearly define measurable objectives to express desired outcomes and  refine, revise, or replace the plan and agency operating procedures as  needed to reflect these objectives.
Systematically apply adaptive management principles, including  defining specific scientific and management questions to be answered,  identifying the activities to be conducted to answer them, developing a  monitoring program to assess the impacts of those activities, and  incorporating the results into the bison management plan.
To enhance interagency collaboration, promote transparency, and  strengthen the agencies’ accountability to the American public:    Establish a single publicly available repository, on a Web site or at a  location easily accessible to the public that includes all documents  reflecting decisions made and actions taken with respect to plan  implementation.
Report annually to Congress on the progress and expenditures related  to the plan’s measurable objectives once these have been clearly  defined.
Appoint a group comprised of a representative from each of the  partner agencies or designate one of the five interagency partners  (perhaps on an annual rotating basis) as a lead entity for plan  oversight, coordination, and administration.
section_title: Agency Comments
paragraphs: We provided the federal departments of Agriculture and the Interior;  Montana Fish, Wildlife and Parks; and the Montana Department of  Livestock a draft of this report for review and comment. The Department  of Agriculture, the Department of the Interior, and the Montana  Department of Livestock generally agreed with our conclusions and  recommendations; their written comments and our response to the  Department of the Interior’s comments appear in appendixes II, III, and IV,  respectively. The federal departments and the state agency also provided  technical comments that we incorporated into the report as appropriate.  Montana Fish, Wildlife and Parks provided no comments on the report.
As agreed with your offices, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to interested congressional  committees; the Secretaries of Agriculture and the Interior; Montana Fish,  Wildlife and Parks; the Montana Department of Livestock; and other  interested parties. We will also make copies available to others upon  request. In addition, the report will be available at no charge on the GAO  Web site at http://www.gao.gov.
If you or your staff members have any questions regarding this report,  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 report. Key contributors are listed in appendix V.
section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: Our objectives were to determine (1) the progress made in implementing  the interagency bison management plan and (2) the soundness of the plan  and the effectiveness of the agencies’ implementation of it with regard to  managing bison-related issues in the Greater Yellowstone Area.
To address both of the objectives, we obtained and reviewed relevant  documentation, including the bison management final environmental  impact statement, record of decision, and interagency bison management  plan; interagency operating procedures; and the interagency status review.  We also interviewed officials from the Park Service; the Forest Service;  APHIS; Montana Fish, Wildlife and Parks; and the Montana Department of  Livestock. In addition, in January and February 2007, we conducted a field  visit to Yellowstone National Park and surrounding areas to gain a greater  understanding of bison management issues and activities performed by the  agencies under the interagency bison management plan. While we were  there, we visited the bison management zones identified in the plan, bison  capture facilities, and various private lands on the north and west sides of  the park. We also attended an interagency open house to hear public  concerns related to the agencies’ implementation of the bison  management plan and met with representatives of the Royal Teton Ranch  to understand their interests related to bison and bison management  activities on and around their private lands.
To enhance our understanding about the progress the agencies have made  in implementing the interagency bison management plan, we also obtained  and reviewed scientific research and reports on various topics related to  brucellosis and wildlife, including the safety and effectiveness of  brucellosis vaccines, vaccine delivery systems, and diagnostic tests for  brucellosis. In conjunction with this effort, we also interviewed  researchers with the U.S. Geological Survey Northern Rocky Mountain  Science Center, the APHIS National Wildlife Research Center, and the  Agricultural Research Service National Animal Disease Center. In addition,  we requested from the federal and state partner agencies expenditure data  related to bison management activities for federal fiscal years 2000  through 2007. The agencies were able to provide complete data only for  federal fiscal years 2002 through 2007, and most of these data were  estimated, rather than actual, expenditures. We assessed the reliability of  these estimates and found them to be sufficiently reliable for the purposes  of our work. We used these data to estimate the amount of money spent  annually on bison management activities and how the expenditures were  shared among the federal and state agencies.
In addition to the interviews, relevant documentation, and field visits that  we have previously discussed, we performed a number of other steps to  determine the soundness of the interagency bison management plan and  the effectiveness of the agencies’ implementation of it with regard to  managing bison-related issues in the Greater Yellowstone Area. We  assessed the plan and the agencies’ implementation of it against generally  recognized best management practices, including those contained in the  Government Performance and Results Act of 1993, the Comptroller  General’s 2004 forum on high-performing organizations, the Department of  the Interior Technical Guidance on Adaptive Management, and select peer- reviewed adaptive management articles. Such practices include clearly  defining measurable, results-oriented management objectives; designing  and implementing a plan to monitor management actions; making  decisions based on management objectives; effectively managing  partnerships while maintaining accountability to Congress and the public;  and actively involving key stakeholders over time to engender public  support. We also conducted semistructured interviews of partner agency  officials regarding their implementation and management of the  interagency bison management plan, focusing specifically on their  application of adaptive management principles, changes made to the plan,  views on the effectiveness of the plan, interagency cooperation and  coordination, and communication with and engagement of stakeholders.  In addition, we conducted semistructured interviews of a judgmental  sample of 30 local individuals and groups representing varied interests in  bison management activities, including conservationists, livestock industry  representatives, local ranchers, permittees of public livestock grazing  allotments, Native American tribes, hunting enthusiasts, lessees of private  land, and other private landowners. Our questions of these individuals and  groups focused on the partner agencies’ bison management activities and  communication with and involvement of the public. We selected these  individuals and groups from listings of those who provided written  comments on the draft environmental impact statement, attended the  interagency public meeting on January 31, 2007, or were identified to us as  interested parties.
We conducted this performance audit from January 2007 through March  2008 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.
section_title: Appendix II: Comments from the Department of Agriculture
section_title: Appendix III: Comments from the Department of the Interior
subsections: section_title: GAO’s Response to the Department of the Interior’s Comments
paragraphs: Our responses to the Department of the Interior’s comments are numbered  below to correspond with specific passages in the department’s comments  (reproduced on pp. 39-42).  1.  We emphasize that clearly defined, measurable objectives need to be  reflected in the bison management plan. We expect that the agencies  would subsequently make commensurate changes to the operating  procedures to ensure that their management actions are aligned with  these objectives. To the extent that the National Park Service, in  cooperation with the other partner agencies, can adequately  accomplish this alignment by refining or revising the existing bison  management plan and agency operating procedures, replacing the plan  may not be necessary.  2.  We believe it is essential that the partners incorporate adaptive  management principles into the bison management plan and  subsequently modify the operating procedures to ensure systematic  application of these principles to their management actions. In  addition, we believe that this recommendation should be implemented  by the entity we recommend, rather than by the IBMP Inter-Agency  Working Group referenced in the department’s response, as further  explained in comment 5.  3.  We believe that this recommendation should be implemented by the  entity we recommend, rather than by the IBMP Inter-Agency Working  Group referenced in the department’s response, as further explained in  comment 5.  4.  As we noted in comment 1, we expect that the measurable objectives  be clearly defined in the bison management plan and be used as  benchmarks for reporting the agencies’ progress to Congress. We  believe that this recommendation should be implemented by the entity  we recommend, rather than by the IBMP Inter-Agency Working Group  referenced in the department’s response, as further explained in  comment 5.  5.  The department states that it agrees with a recommendation to  continue the prevailing IBMP Inter-Agency Working Group and notes  that the department would accomplish a number of our  recommendations through participation in this group. We did not  recommend that the partner agencies continue the prevailing IBMP  Inter-Agency Working Group to implement this or any other of our  recommendations. As evident in our findings, we believe the agency  partners’ efforts to operate as a cohesive interagency group to oversee,  coordinate, and administer the bison management plan have been  inadequate to date, which led to our recommendation that a more  structured lead entity be appointed for such functions. Furthermore,  none of the partner agencies, including the Park Service, had identified  this group by name or referenced it as having responsibilities for these  functions during the course of our review, and only the Park Service  referenced it in commenting on our draft report. We envision that the  responsibilities of the lead entity we have recommended would  include, but would not be limited to, activities such as scheduling and  documenting interagency meetings, creating and maintaining a central  repository of information related to the bison management plan, and  coordinating the agency partner’s annual report to Congress. We do  not believe that this entity will interfere with the partner agencies’  ability to adhere to their respective mandates and policies.
section_title: Appendix IV: Comments from the Montana Department of Livestock
section_title: Appendix V: GAO Contact and Staff Acknowledgments
subsections: section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, David P. Bixler, Assistant  Director; Ellen W. Chu; Richard Johnson; Diane Lund; and Jamie  Meuwissen made key contributions to this report. Also contributing to the  report were Elizabeth Curda, Sandy Davis, Bernice Dawson, Timothy  Guinane, Carol Henn, Lynn Musser, Omari Norman, Kim Raheb, Jeremy  Sebest, and Jena Sinkfield.
section_title: Related GAO Products
paragraphs: Yellowstone National Park: Preliminary Observations on the  Implementation of the Interagency Bison Management Plan.   GAO-07-638T. Washington, D.C.: March 20, 2007.
Wildlife Management: Negotiations on a Long-Term Plan for Managing  Yellowstone Bison Still Ongoing. GAO/RCED-00-7. Washington, D.C.:  November 30, 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 10, 1997.
Wildlife Management: Many Issues Unresolved in Yellowstone Bison- Cattle Brucellosis Conflict. GAO/RCED-93-2. Washington, D.C.:   October 21, 1992.