Please Request a National Academy of Sciences Review of
Wildlife Brucellosis in the Greater Yellowstone Area

To:
Sue Masica, National Park Services, Intermountain Regional Director
Please Request the National Academy of Sciences conduct a scientific review of Wildlife Brucellosis in the Greater Yellowstone Area.

The issue of brucellosis in the Greater Yellowstone Area States, has severe implications for our livestock industries, as well as our treasured public wild bison and elk. We recognize that our elected officials in Washington D. C., the Greater Yellowstone Area States of Montana, Wyoming and Idaho, in addition to various agencies within the U.S. Departments of Interior and Agriculture, share a need for responsible, peer reviewed science to base their wildlife management decisions on.

"The National Academy of Sciences charter commits the Academy to provide scientific advice to the government 'whenever called upon' by any government department." To ensure that science, not politics and special interests, drive the public discussion and foundation of brucellosis disease management policy in the Greater Yellowstone Area wildlife, we are humbly writing to request that you call upon the National Academy of Sciences to conduct a thorough scientific review of brucellosis disease management, concerning wildlife (predominately elk and bison), in the Greater Yellowstone Area.

Historically, a number of policies involving brucellosis management have not been rooted in responsible science, rather assumptions. For years, the Federal Animal and Plant Health Inspection Service has been promoting an agenda of brucellosis eradication from the Greater Yellowstone Area, a position which is not socially, humanly, economically and scientifically supported. As a result, by their own statements, millions of federal taxpayer dollars (other sources cite billions) have been spent, targeting Yellowstone National Park bison, on an assumption that the wild bison were the major vector of brucellosis transmission, which actually resides with the elk. Now that the special interest groups and agencies responding to the APHIS brucellosis eradication in wildlife agenda are aware it is the elk genotype, which is a small transmission risk threat to cattle, that machinery is now turning it's sights to the elk populations.

Science, not politics, needs to address the following questions:

1. What is the actual zoonotic transmission risk of Brucella abortus to humans from brucellosis exposed wildlife?(accounting for the fact that many involved with livestock and wildlife vaccines are the major source of accidental Brucella abortus infections in humans)
2. What is the actual transmission risk to livestock from brucellosis exposed wild bison or wild elk in the Greater Yellowstone Area?
3. What is the environmental impact of the APHIS agenda of eradication of brucellosis in the wildlife, on the GYA states, to the habitat, as well as the genetics of the bison and elk populations?
4. Additionally, are the goals and practices of agriculture livestock management compatible with the goals and evolving practices of the conservation sciences that protect and promote ecological integrity of the GYA states for future generations?
5. Finally, what are the economics of the livestock management model for brucellosis eradication, within the wildlife populations of the GYA states??

Here is some background prompting this request:
Eradication involves capture test and slaughter of wildlife simply showing antibodies to exposure, which can also represent natural and acquired immunities, not only infection/infectious.

The science being produced today reports that the transmission risk from wild YNP bison to cattle is 0.0-0.3%, elk representing 99.7%-100% of the risk. No documented case of wild bison to cattle transmission has ever occurred in the wild. The genetics show that the Brucella abortus of wild bison differs from that of elk and cattle, which is almost identical, which affects species transmission. "Our results indicate that elk and cattle isolates are virtually identical genetically, differing by only one to two mutational steps. On the contrary, bison B. abortus differed from cattle and elk by 12-20 mutational steps."- DNA Genotyping Suggests that Recent Brucellosis Outbreaks in the Greater Yellowstone Area Originated from Elk, 2009. Molecular Epidemiology of Brucella abortus Isolates from Cattle, Elk, and Bison in the United States, 1998 to 2011, 2012.

Of the 99.7%-100% of the risk that elk pose, that risk is 0.00024% chance that any one Montana cattle will become infected from elk. Percentages that can be reduced by recommended mitigation methods such as later cattle turn out dates on public lands, running only spade heifers and steers on public lands, transmission risk methods of stack fencing, etc. Not all cases of brucellosis infections in cattle, since 2008, in the GYA states have been from elk, some have been cattle vaccine blooms and cattle infections.

Science, not politics should be managing our wildlife, so I ask you to please request a thorough scientific review by the National Academy of Sciences.

Public citizens of the United States, are owed nothing less, in the stewardship, policies and management of our public trust resources, on behalf of this generation and future generations, than the knowledge and ethical principles of peer-reviewed science.

Thank you

Sincerely,

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