Appendix 1 Combined data for Alkali, Patrol Cabin, and Fish Creek feedgrounds, 1975-76 through 2011-12.
YEAR # ELK TONS DAYS DEAD COST/ELK TONS/ELK LBS/ELK/DAY 1975-76 1713 671 101 8 $25 0.39 7.7 1976-77 0 0 0 0 $0 0.00 0.0 1977-78 1735 659 91 13 $27 0.38 8.3 1978-79 1854 745 98 17 $26 0.40 8.2 1979-80 2007 626 90 11 $22 0.31 6.9 1980-81 0 0 0 0 $0 0.00 0.0 1981-82 2099 945 113 19 $37 0.45 8.0 1982-83 1437 548 97 11 $35 0.38 7.8 1983-84 1584 538 98 7 $44 0.34 7.0 1984-85 1338 413 75 8 $33 0.31 8.2 1985-86 1671 554 77 12 $34 0.33 8.6 1986-87 1225 479 80 6 $39 0.39 9.8 1987-88 1567 539 81 2 $34 0.34 8.5 1988-89 2550 948 117 80 $38 0.37 6.4 1989-90 1979 649 83 8 $38 0.33 7.9 1990-91 1469 477 102 15 $40 0.32 6.4 1991-92 1186 426 70 6 $44 0.36 10.3 1992-93 1688 799 96 11 $55 0.47 9.8 1993-94 1507 421 71 0 $31 0.28 7.9 1994-95 2186 757 113 11 $37 0.35 6.1 1995-96 1770 710 93 7 $47 0.40 8.6 1996-97 2260 963 105 53 $52 0.43 8.1 1997-98 1940 802 99 13 $64 0.41 8.4 1998-99 2325 1002 89 10 $51 0.43 9.7 1999-00 2462 688 80 18 $43 0.28 7.0 2000-01 2658 981 84 6 $64 0.37 8.8 2001-02 2621 985 64 49 $50 0.38 11.8 2002-03 2195 414 71 5 $34 0.19 5.3 2003-04 2839 967 80 30 $52 0.34 8.6 2004-05 2941 568 81 8 $48 0.19 4.7 2005-06 3221 917 62 57 $37 0.28 9.2 2006-07 2922 867 79 20 $77 0.30 7.5 2007-08 2279 1017 88 6 $64 0.45 10.1 2008-09 1200 143 30 4 $14 0.12 11.9 2009-10 1880 212 30 0 $44 0.11 16.7 2010-11 2546 1254 97 48 $77 0.49 10.0 2011-12 2602 415 63 6 $39 0.16 5.1 1975-2012 Avg. 1931 651 80 16 $40 0.32 8.0
Data for Alkali feedground, 1975-76 through 2011-12.
YEAR # ELK TONS DAYS DEAD COST/ELK TONS/ELK 1975-76 608 269 106 3 $29 0.44 1976-77 0 0 0 0 $0 0 1977-78 349 170 91 4 $34 0.49 1978-79 660 271 99 8 $27 0.41 1979-80 542 185 89 1 $23 0.34 1980-81 0 0 0 0 $0 0 1981-82 724 350 119 6 $40 0.48 1982-83 375 139 93 6 $36 0.37 1983-84 437 236 107 3 $46 0.54 1984-85 223 73 77 1 $35 0.32 1985-86 466 173 78 1 $36 0.37 1986-87 325 118 84 1 $42 0.36 1987-88 336 100 80 $36 0.3 1988-89 450 204 118 5 $47 0.45 1989-90 480 138 83 5 $36 0.29 1990-91 432 183 140 3 $53 0.42 1991-92 225 115 71 0 $60 0.51 1992-93 482 218 107 1 $56 0.45 1993-94 800 240 104 0 $32 0.3 1994-95 407 121 90 2 $38 0.3 1995-96 380 106 82 0 $36 0.28 1996-97 800 319 82 7 $47 0.4 1997-98 930 342 119 5 $53 0.37 1998-99 939 315 90 3 $41 0.34 1999-00 1140^(46) 142^ 92 7 16^ 0.12^ 2000-01 853^(8) 126^ 70 2 21^ 0.15^ 2001-02 1188^ 389^ 90 16 47^ 0.38^ 2002-03 2100^(1650) 320^ 101 1 28^ 0.15 2003-04 1214 417 72 16 $41 0.33 2004-05 0 0 94 0 $0 0 2005-06 675 55 47 11 $14 0.08 2006-07 55 46 72 1 $168 0.84 2007-08 12 222 87 0 2008-09 1200 143 20 4 $14 0.12 2009-10 1700 86 29 0 $9 0.05 2010-11 412 323 123 25 0.78 2011-12 2345 132 63 0 $14 0.06 1975-99 Avg. 473# 183# 83 4 37# 0.36# *Number in ( ) indicates the number counted when the elk were classified. ^ Wolves chased the elk among the three Gros Ventre feedgrounds altering these values and making comparisons with other years meaningless. # Average values refer to years prior to 1999-2000.
Data for Patrol Cabin feedground, 1975-76 through 2011-12.
YEAR # ELK TONS DAYS DEAD COST/ELK TONS/ELK 1975-76 525 149 98 1 $18 0.28 1976-77 0 0 0 0 $0 0 1977-78 627 195 92 3 $22 0.31 1978-79 594 226 94 5 $24 0.38 1979-80 831 237 92 5 $20 0.29 1980-81 0 0 0 0 $0 0 1981-82 548 234 113 6 $35 0.42 1982-83 342 126 90 2 $34 0.37 1983-84 147 66 81 1 $50 0.45 1984-85 240 76 61 2 $35 0.32 1985-86 480 121 71 1 $23 0.25 1986-87 300 100 72 2 $33 0.33 1987-88 388 100 79 0 $29 0.26 1988-89 1000 279 114 33 $27 0.28 1989-90 538 163 75 0 $37 0.3 1990-91 443 126 77 3 $34 0.28 1991-92 808 262 60 3 $36 0.32 1992-93 280 134 105 2 $54 0.48 1993-94 477 123 49 0 $30 0.26 1994-95 644 155 122 5 $28 0.24 1995-96 477 221 93 1 $52 0.46 1996-97 330 169 113 1 $62 0.51 1997-98 281 134 88 0 $73 0.48 1998-99 605 318 90 1 $58 0.53 1999-00 2500^(2140) 466^ 73 10 19^ 0.19^ 2000-01 2650^ 483^ 91 2 21^ 0.18^ 2001-02 2600^(823) 512^ 73 27 86^ 0.62^ 2002-03 1200^(411) 74^ 64 3 28^ 0.18^ 2003-04 1300^(379) 253 90 12 87^ 0.67^ 2004-05 1635 292 87 4 $22 0.18 2005-06 1998 592 89 27 $36 0.3 2006-07 2845 361 87 6 $17 0.13 2007-08 2251 597 88 6 2008-09 0 0 0 0 $0 0 2009-10 180 126 30 0 $122 0.7 2010-11 2122 584 70 10 2011-12 231 194 63 4 $193 0.84 1975-99 Avg. 448# 148# 77 5 33# 0.32# *Number in ( ) indicates the number counted when the elk were classified. ^ Wolves chased the elk among the three Gros Ventre feedgrounds altering these values and making comparisons with other years meaningless. # Average values refer to years prior to 1999-2000.
Data for Fish Creek feedground, 1975-76 through 2011-12.
YEAR # ELK TONS DAYS DEAD COST/ELK TONS/ELK 1975-76 580 253 100 4 $28 0.44 1976-77 0 0 0 0 $0 0 1977-78 759 294 91 6 $26 0.39 1978-79 600 248 101 4 $28 0.41 1979-80 634 204 89 5 $24 0.32 1980-81 0 0 0 0 $0 0 1981-82 827 361 106 7 $35 0.44 1982-83 720 283 109 3 $35 0.39 1983-84 1000 236 105 3 $36 0.24 1984-85 875 264 88 5 $29 0.3 1985-86 725 260 81 10 $43 0.36 1986-87 600 261 84 3 $41 0.44 1987-88 843 339 83 2 $37 0.4 1988-89 1100 465 118 42 $39 0.42 1989-90 961 348 90 3 $41 0.36 1990-91 594 168 89 9 $32 0.28 1991-92 153 49 79 3 $36 0.32 1992-93 926 447 77 8 $54 0.48 1993-94 230 58 59 0 $30 0.25 1994-95 1135 481 126 4 $46 0.42 1995-96 913 383 104 6 $52 0.42 1996-97 1130 475 119 45 $47 0.42 1997-98 729 326 89 8 $66 0.45 1998-99 781 369 87 6 $53 0.47 1999-00 1500^(276) 80^ 76 1 8^ 0.05^ 2000-01 2000^(0) 372^ 90 2 22^ 0.19^ 2001-02 610^ 84^ 28 6 18^ 0.14^ 2002-03 134^ 20^ 47 1 36^ 0.15^ 2003-04 1246 297 77 2 $29 0.24 2004-05 1306 276 63 4 $26 0.21 2005-06 548 270 50 19 $62 0.49 2006-07 22 460 77 13 $2,722 543 2007-08 16 198 86 0 2008-09 0 0 0 0 $0 0 2009-10 0 0 0 0 $0 0 2010-11 12 347 98 13 2011-12 26 89 62 2 $910 3.42 1975-99 Avg. 697# 270# 76 7 35# 0.35# *Number in ( ) indicates the number counted when the elk were classified. ^ Wolves chased the elk among the three Gros Ventre feedgrounds altering these values and making comparisons with other years meaningless. # Average values refer to years prior to 1999-2000.
Appendix 2 Elk Feedgrounds in Wyoming
August 30, 2004
Contributing Authors:
Ron Dean, Jackson/Pinedale Feedground Supervisor, WGFD Mark Gocke, Jackson/Pinedale Information and Education Specialist, WGFD Bernie Holz, Jackson/Pinedale Regional Wildlife Supervisor, WGFD Steve Kilpatrick, Jackson Habitat Coordinator, WGFD Dr. Terry Kreeger, DVM, Wildlife Veterinarian, WGFD Brandon Scurlock, Jackson/Pinedale Brucellosis Biologist, WGFD Scott Smith, Jackson/Pinedale Wildlife Biologist Coordinator, WGFD Dr. E. T. Thorne, DVM, Wildlife Veterinarian (retired WGFD) Scott Werbelow, Jackson/Pinedale Game Warden Coordinator, WGFD
Table of Contents
Introduction ………………………………………………………………2
History of Feedgrounds in Wyoming …..………..………………………2 • Wyoming Game and Fish Feedgrounds …………………………...4 • National Elk Refuge vs. State Feedgrounds ……………………….5
Elk Population Dynamics ………………………………………………...6
Disease …………………………………………………………………….8 • Brucellosis …………………………………………………………9 • Chronic Wasting Disease …………………………………………10 • Tuberculosis ………………………………………………………11 • Other Diseases …………………………………………………….13
Brucellosis and Livestock ………………………………………………..13
Brucellosis-Feedground-Habitat (BFH) Program ……………………..15 • Elk Vaccination ……………………………………………………15 • Brucellosis Serology ………………………………………………17 • Elk/Cattle Separation ……………………………………………...18 • Habitat Enhancement ……………………………………………...20 • Information and Education ………………………………………...23
Interagency Coordination ……………………………………………….23
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Introduction
Elk management in northwestern Wyoming has been challenging since Europeans first settled the area in the late 1800s. Even prior to any significant settlement of elk wintering areas like Jackson Hole, there were reports of thousands of elk starving to death during hard winters, and with the first settlers came reports of elk raiding ranchers’ haystacks. The early settlers didn’t want to see the elk die, but at the same time, they could not afford to lose precious hay needed to carry livestock through the winter. The obvious solution was to create areas where elk could be fed, thus avoiding large-scale die-offs while keeping the animals out of ranchers’ hay. This is precisely what took place with the first and largest elk feedground, the National Elk Refuge, created in 1912.
Early wildlife managers did not foresee the consequential problems elk feedgrounds would create. While the creation of feedgrounds addressed the problems of elk die-offs and damage to stored hay crops, it exacerbated the problem of disease transmission. What started as a logical solution to some very real problems, has become one of the most complex and controversial wildlife management challenges of the 21st century.
The purpose of this paper is to provide factual information on the many different facets of elk feedgrounds in northwest Wyoming. There have been volumes written on the various issues involving elk feedgrounds over the years. This document is not intended to cover every aspect of every issue, but rather provide a well-rounded discussion on the topic as a whole, providing key, factual information on what we believe to be the most important issues surrounding elk feedgrounds.
History of Feedgrounds in Wyoming
The National Elk Refuge was the first elk feedground in Wyoming, created in 1912. By the late 1880s, human settlement and conversion of historic elk winter range to use by domestic livestock had already begun to compromise elk habitat and their migration routes to wintering areas. However, even before extensive settlement of Jackson Hole, early hunters and settlers noted unusually heavy snows resulted in the death of thousands of elk. Severe winters in 1909, 1910, and 1911 reportedly took a heavy toll on elk numbers. In 1910, the Wyoming legislature appropriated $5,000 to purchase all available hay in the Jackson Hole valley to feed elk. Thus began the first government-subsidized feeding of wildlife in northwest Wyoming. The supply of hay was inadequate and elk raided ranchers’ haystacks. Despite these early efforts, many elk starved to death.
The first official suggestion for a permanent elk refuge was by Wyoming State Game Warden, D.C. Nowlin, in 1906. After retiring as State Game Warden, Nowlin became the first manager of the National Elk Refuge. In 1911, the Wyoming legislature requested a Congressional appropriation for “…feeding, protecting, and otherwise preserving the big game which winters in great numbers within the confines of the State of Wyoming.” One month later, Congress appropriated $20,000 for feeding, protecting, and transplanting elk and ordered an investigation
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of the elk situation in Wyoming. Following this assessment, Congress appropriated $45,000, on August 10, 1912, for the purchase of lands and maintenance of a refuge for wintering elk.
By 1916, a combination of public and private lands formed the 2,760-acre National Elk Refuge. Several additions have been made since then, increasing the total acreage to nearly 25,000 acres today. Due to the location of the town of Jackson and other development in the Jackson Hole Valley, it is estimated that only one-quarter of the historic elk winter range remains.
The Jackson elk herd is one of the largest elk herds in the world, with a 2004 winter population estimated at 13,500. The population objective for the Jackson elk herd is 11,029, established by the Wyoming Game and Fish Commission in 1987. Annually, 45-65% of the Jackson elk herd winters on the National Elk Refuge. A 1974 Memorandum of Understanding (MOU) between the Wyoming Game and Fish Commission and National Elk Refuge calls for a maximum of 7,500 elk on feed in any given winter on the refuge. Each year, forage conditions are monitored regularly by Game and Fish and National Elk Refuge personnel. The decision of when to start and stop feeding is typically made jointly.
The elk on the National Elk Refuge are annually counted and classified through a group effort by local representatives from the various natural resource management agencies. The fewest elk ever fed on the refuge was 3,110 during the winter of 1930-31. The highest recorded number was in 1996, when 10,736 elk were counted. The average number of elk fed on the refuge from 1999-2003 is just over 6,000 elk. Elk are typically on the refuge for about six months, from November through April of each year. On average, the elk are fed for about 2.5 months from late January until early April. There have been nine winters since the refuge was created when the elk were not fed at all.
In 1975, the National Elk Refuge made a change from feeding baled hay to pelleted alfalfa. Managers determined that pelleted alfalfa was easier to distribute in large quantities and maintained its quality better while in storage. Currently, feeders use mechanized equipment to lay down lines of alfalfa pellets at four different locations on the refuge.
Annually, the cost for the alfalfa pellets to feed the refuge elk is about $300,000. This cost is split equally between the Wyoming Game and Fish Department and National Elk Refuge. Additionally, local Boy Scouts collect the elk antlers shed on the refuge and sell them at the annual antler auction in Jackson. This typically generates approximately $80,000 each year. The Boy Scouts keep 20% of the proceeds and the remainder goes to help fund feeding of the elk.
In 1958, the Cooperative Elk Studies Group was formed, composed of representatives of the Wyoming Game and Fish Department, National Elk Refuge, Bridger Teton National Forest, and Grand Teton National Park. All four agencies have legal responsibilities pertaining to the management of the Jackson elk herd. The group meets annually to share information and coordinate management and research of elk.
More recently, the Jackson Interagency Habitat Initiative (JIHI) was formed during fall 2001 by several wildlife biologists from the above agencies. The goal of JIHI is to maximize
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effectiveness of native winter and transitional range for ungulates and a diversity of species indigenous to this region through identification of habitat enhancement opportunities. The group is focusing on habitat enhancements in Buffalo Valley and the Gros Ventre River drainage.
Wyoming Game and Fish Feedgrounds
In 1929, supplemental feed was left in metal sheds in the drainages of the Upper Green River, Gros Ventre, and Greys River by the Game and Fish Department in an effort to prevent large scale die-offs of elk during severe winters. It was understood that during severe winters someone would snowshoe to these sheds and put out hay in an attempt to reduce winter losses. This marked the beginning of supplemental winter-feeding of elk by the Game and Fish Department (Dean, et. al. 2003).
Wyoming’s first damage law was enacted in 1939, imposing limited liability on the Game and Fish Commission to pay for damages to crops caused by big game animals. This legislation created a significant financial burden to the Game and Fish Commission and largely contributed to the establishment of elk feedgrounds in Wyoming. Wildlife managers found it was easier and less expensive to feed elk in key problem areas rather than continually try to keep elk out of haystacks.
Elk were fed at many different locations during the 30-plus years following the creation of the damage law, primarily to prevent damage to stored and fed hay and growing crops. Many sites were temporary and only small amounts of hay, or cake, were fed. The Game and Fish Department has fed elk in at least 51 different locations since 1948. Many of the present feeding sites were started in the late 1940s and early 1950s. By the early 1960s, the present elk feedground system was mostly in place, with the last two feedgrounds started in the 1970s.
Currently, the Game and Fish Department manages 22 state-operated elk feedgrounds. In addition, the National Elk Refuge is managed by the U.S. Fish and Wildlife Service. In 2004, the annual cost to the Game and Fish Department for managing its entire feedground program was approximately $1.36 million.
The 22 state feedgrounds are located in Teton, Lincoln, and Sublette counties on BLM, Forest Service, state, and private land holdings. Annually, the average number of elk fed on all 22 state feedgrounds (not including the National Elk Refuge) since 1975 is approximately 13,000 elk. The highest number recorded was in 1988-89, when the Game and Fish Department fed a total of 16,967 elk. Conversely, the lowest number of elk fed since 1975 occurred during the winter of 1976-77, when only 4,964 elk were fed.
Elk are typically fed with a team of draft horses and a sleigh. Elk are fed seven days a week, with most feedgrounds starting in late November and ending in mid April. Small square bales of grass or alfalfa hay are generally used. Feeders try to disperse elk as much as possible and feed on clean snow each day.
The Game and Fish Department purchases between 6,000-9,000 tons of hay annually, with the majority of the hay being small square bales. The Department prefers certified weed-free hay
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and makes every effort to purchase only certified hay. Most hay is purchased from Teton, Lincoln and Sublette County ranches, with some hay coming from Idaho each year. The Department contracts the hauling, which typically takes about four months to complete. Each feedground has several sheds where the hay is stored.
Elk feeders are contracted seasonally by the Game and Fish Department and may feed at one or more feedgrounds each year. Individual elk are generally fed between eight and ten pounds of hay per day. The feeding season ranges from 70 to 160 days, depending on severity of the winter and location of the feedground. The average length of the feeding season is 127 days. This equates to approximately 0.5 ton of hay per elk each year.
The Game and Fish Department has experimented with feeding one-ton bales with tractors on several different feedgrounds, but has encountered problems with getting tractors started during cold spells. Consequently, the majority of the feeding is still being done with teams of draft horses pulling a sleigh or wagon.
Just as there are population objectives set for each elk herd, there are also numerical quotas set for each feedground within those herds. Both herd objectives and feedground quotas are established by the Wyoming Game and Fish Commission. It would require Commission approval to initiate a new elk feedground or terminate an existing feedground. At times, the Game and Fish Department has deemed it necessary to implement emergency temporary feeding under unique circumstances. This action requires approval by the Game and Fish Commissioner for that region.
National Elk Refuge vs. State Feedgrounds
There are significant differences between the feeding operations on the National Elk Refuge and the 22 state elk feedgrounds. The size of the National Elk Refuge, at nearly 25,000 acres, and its reduced amount of snow, are probably the biggest differences. Most of the state-operated feedgrounds are approximately 75 acres and are typically located on transitional range or at an elevation higher than traditional winter range. Additionally, state feedgrounds are often close to private land damage situations with no fence to prevent elk from moving from the feedground.
While the elk refuge has to accommodate a higher number of elk (7,500 vs. an average of 600 on each state feedground), the National Elk Refuge has a much higher ratio of land per elk. This, combined with less snow cover, allows the elk refuge to feed fewer days per year and less per elk. The refuge feeds approximately 3-5 pounds of pellets per elk per day, versus 8-10 pounds of hay per elk per day on state feedgrounds.
The Game and Fish Department experimented with feeding alfalfa pellets at the Greys River feedground, but the elk caused extensive damage to woody plants, and even wooden corrals, in an attempt to find necessary roughage. One consequence of feeding alfalfa pellets was the elk tended to spend less time on the feedline when they dispersed to find roughage. Thus, they tended to have a greater impact on woody vegetation than they otherwise would if fed baled hay.
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Elk Population Dynamics
There are eight elk herd units managed by the Game and Fish Department’s Jackson/Pinedale Region. Elk in seven of the eight herd units are supplementally fed during the winter months. Herd units are defined as populations with less than 10% interchange with adjacent herd units. Naturally, elk populations fluctuate from year to year. Table 1 presents the results from the 2004 winter elk counts as well as the long-term average (27 years) and individual feedground quotas. The winter of 2004 was average to above-average for snow accumulation. Subsequently, feedground attendance was above the long-term average for many feedgrounds. Over the past 27 winters, an average of 20,500 (including the National Elk Refuge) elk per year have been provided supplemental winter feed.
Table 1. Elk Herd Units and Feedgrounds in western Wyoming.
Elk Trend Count Data Feedground Herd Unit Feedground 2004 1976-2002 Ave. Objective
Afton Greys River 810 853 1000 Forest Park 771 696 750
Fall Creek Camp Creek 1004 754 900 Dog Creek 1214 766 800 Horse Creek 1346 1064 1250 South Park 1401 984 1000
Hoback Dell Creek 230 253 400 McNeel 680 574 600
Jackson Alkali 1246 454 800 Fish Creek 379 697 1000 Patrol Cabin 1214 448 650 Natl. Elk Refuge 5876 7436 7500
Pinedale Fall Creek 547 648 700 Muddy Creek 486 600 600 Scab Creek 710 488 500
Piney Bench Corral 813 390 250 Finnegan 205 333 400 Franz 428 397 450 Jewett 750 590 650 North Piney 0 388 400
U. Green River Black Butte 423 493 500 Green River Lakes 356 510 675 Soda Lake 355 727 800
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Winter feedgrounds support the majority of elk in the Jackson/Pinedale Region (Table 2). Annual elk survey data comparing elk on feed versus elk on native winter range over the past 5 years (2000-2004) indicates 80% of all elk winter at designated feedgrounds. Feedground attendance over the last 5 years has varied from 71% in the Jackson Herd Unit to 96% in the Fall Creek Herd Unit (Table 2). Options for elk utilizing native ranges vary greatly among the 7 elk herd units.
Table 2. Percent of elk on feedgrounds (FG) compared to native winter range (NWR), 2000-2004.
2000 2001 2002 2003 2004 5 Yr. Ave. Herd Unit FG NWR FG NWR FG NWR FG NWR FG NWR FG NWR
Afton 88 12 86 14 87 13 69 31 81 19 82 18
Fall Creek 95 5 96 4 97 3 93 7 96 7 96 4
Hoback 90 10 97 3 94 6 82 18 87 13 90 10
Jackson 61 39 71 29 74 26 74 26 72 28 71 29
Pinedale 86 14 96 4 99 1 81 19 96 4 92 8
Piney 74 26 88 12 86 14 88 12 83 17 83 17
U. Green River 84 16 65 35 94 6 79 21 87 13 81 19
Total 89 11 79 21 85 15 79 21 82 18 80 20
During winters with less than average snowfall, a portion of elk will remain on native ranges as long as forage is available. This varies greatly among the various feedgrounds and native range complexes. For example, 35%, or more than 800 elk in the Upper Green River Herd Unit wintered on native habitat during the winter of 2001 (Table 2). Snow accumulations were far below normal and native forage was available throughout the winter months. Conversely, the winter of 2004 was average to above-average and elk correspondingly left winter habitat in favor of supplemental hay at feedgrounds. The 2004 surveys indicate that 13%, or approximately 250 elk, foraged during the winter months on native habitat in the Upper Green River Herd Unit (Table 2).
Nearly all of the 22 state-operated feedgrounds were established to prevent elk damage to stored hay crops and prevent co-mingling with livestock on private lands. One additional outcome of the supplemental feeding program has been the near elimination of natural over-winter mortality for elk populations in northwest Wyoming. Regardless of the severity of winter weather, elk that attend feedgrounds experience only 1-2% mortality during the winter months. Feeding has led to productive herds and enabled local populations to be maintained at levels commensurate with summer habitats, but at levels larger than the native winter habitats could support.
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It should be noted there is an estimated 7-12% loss in overall production for feedground elk as a result of abortions and births of non-viable calves due to brucellosis. However, this loss of calf production is offset by the higher over-winter calf survival that is a result of supplemental feeding. This point can be seen by comparing the five-year average calf production for two adjacent elk herds, one with brucellosis and the other without brucellosis. The West Green River elk herd, near Kemmerer, which is not supplementally fed and has shown only 1% seroprevalence of brucellosis, has 37 calves : 100 cows. The Piney elk herd, located immediately to the north, is supplementally fed with a brucellosis seroprevalence of 30%. Despite the loss of calves due to brucellosis, the five-year average calf production for the Piney elk herd is also 37 calves : 100 cows, presumably due to the lack of winter mortality.
Table 3 presents population trends and productivity ratios (calves : 100 cows) for all seven herd units with winter feeding programs. As of 2004, five of seven herd units exhibit a declining population trend, which is a direct result of hunting seasons the past several years. Liberal harvest has been necessary as calf elk production and survival has been good, indicating future recruitment of elk will be more than adequate to maintain these populations.
Table 3. Elk herd units and population trends, 1999-2003
Post-Season Classification Population Estimates Herd Unit Ratios (Juveniles:100 Females) Herd Unit 2003 1999-2003 Ave. Trend Objective 2003 1999-2003 Ave.
Afton 2270 2620 Decrease 2200 34:100 33:100
Fall Creek 5450 4880 Increase 4392 41:100 33:100
Hoback 1080 1040 Stable 1100 40:100 37:100
Jackson 13730 15880 Decrease 11029 28:100 20:100
Pinedale 1950 2140 Decrease 1900 24:100 24:100
Piney 2840 2800 Decrease 2424 33:100 37:100
U. Green River 2150 2740 Decrease 2500 23:100 28:100
Disease
Artificial feeding of wildlife, be it birds or bison, is a two-edged sword. Most wildlife disease professionals consider artificial feeding a potential health threat to the fed animals due to the belief that prolonged congregation of animals around a feeding site increases the probability of disease transmission. This increased probability is generally irrespective of how the disease is transmitted, i.e., direct contact, aerosol, environmental contamination, or infected feces and urine.
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Positive benefits of feeding include: increased winter survival, increased disease resistance (an increased plane of nutrition enhances the immune system), and increased production (less offspring lost in utero as a result of malnutrition).
The elk feedgrounds in northwest Wyoming encompass benefits and detriments. Following are examples of current and potential diseases that impact, or could impact, elk maintained on winter feedgrounds.
Brucellosis
Brucellosis is a highly contagious bacterial disease of both animals and humans recognized since the 19th century. Brucellosis is a disease of concern for wildlife, cattle, and humans. A Cooperative State- Federal Brucellosis Eradication Program has existed for over 70 years to eradicate brucellosis because of its economic impact on cattle and because it can be a serious human disease. This generally successful program has nearly eliminated brucellosis in domestic livestock, but the disease still exists in free-ranging elk and bison in the Greater Yellowstone Area (GYA) in the northwest portion of Wyoming and in adjacent portions of Idaho and Montana (see Figure 1). Brucellosis is not known to exist in wildlife at any other locations in these states. Figure 1. Map of GYA
Brucellosis may have been introduced into the GYA from infected bison that were transplanted into Yellowstone National Park from a brucellosis-infected cattle ranch. In addition, elk may have contracted brucellosis when they fed on cattle feedlines in the early 1900s.
There are several Brucella species. Brucella abortus is the bacterium that infects elk, bison, and cattle. The current taxonomic scheme recognizes 8 biovars. B. abortus types 1 and 4 are probably the most common isolates from elk and bison in the GYA.
Infection of the female reproductive tract results in abortion. Cows usually abort their first calf following infection. A few cows will continue to abort their second, or even third, calf. Fetuses delivered near term often are stillborn or fail to thrive due to an overwhelming Brucella infection. The male reproductive tract (testes, seminal vesicles, prostate) can also be infected. Infection of the bone or joint membranes results in lameness that may make the animal more susceptible to predation.
The most common route of transmission is thought to be oral as a result of an animal licking or ingesting infected fetuses, placentae, fetal fluids, or vaginal exudates. Under cool, moist conditions, Brucella bacteria can persist for more than 100 days in the environment and transmission may occur by animals grazing on contaminated pasture or consuming other feedstuffs contaminated by discharges or fetal membranes. Treatment of brucellosis in animals
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is generally unsatisfactory because it requires multiple drugs administered daily for several weeks.
The Game and Fish Department vaccinates elk against brucellosis on 21 of its 22 feedgrounds. The Dell Creek feedground is maintained as an unvaccinated control with which to compare efficacy of vaccination on other feedgrounds. A more thorough discussion of the Game and Fish Department elk vaccination program can be found under the section on the Brucellosis- Feedground-Habitat Program.
The Game and Fish Department tests elk for brucellosis at many of its feedgrounds. It also gathers blood samples from hunter-killed elk, which are thought not to winter regularly on feedgrounds. Seroprevalence data collected from 12 feedgrounds where elk have been vaccinated averaged 23.6% (range: 13-30%); the average seroprevalence of elk from the unvaccinated Dell Creek feedground has been 32%. The seroprevalence of elk not frequenting feedgrounds has averaged 2.3%. These data support the contention that feedgrounds increase the probability of disease transmission. Conversely, feedgrounds provide the only opportunity to effectively vaccinate elk and are one of the best methods to prevent co-mingling of elk and livestock during winter months.
Chronic Wasting Disease
Chronic wasting disease (CWD) is a fatal disease of the central nervous system of mule deer, white- tailed deer, and Rocky Mountain elk. Chronic wasting disease has been found in primarily central and southeastern Wyoming (see Figure 2). Chronic wasting disease is one of a group of diseases called transmissible spongiform encephalopathies that are thought to be caused by abnormal proteins or “prions.” These prions are unlike viruses or bacteria in that they contain no DNA and, thus, are not living organisms. Figure 2. Deer Hunt Areas with CWD
Affected animals experience progressive loss of body condition, reluctance to move unless approached closely, increased drinking, depression, and eventually death. Many animals are seen near water and are reluctant to leave such areas. All animals showing clinical signs of CWD eventually die; however, it is not known if just being infected with the prion always results in disease and death.
The mode of transmission of CWD has not been identified. Evidence suggests the disease can pass directly from infected animal to uninfected animal; by contact with soil, plants, or feed contaminated with the prion; or by direct or indirect contact with the carcass of an animal that has died from CWD. There currently is no evidence that CWD can be transmitted to humans or domestic livestock.
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The Game and Fish Department has conducted systematic surveillance for CWD since 1997 by examining hunter-killed deer and elk. Biologists remove lymph nodes from the head that are located just behind the curve of the jawbone. These lymph nodes are tested by an enzyme-linked immunosorbent assay (ELISA) test similar to one of the tests used for brucellosis. This test is highly accurate and can be conducted quickly. The overall CWD prevalence of deer found in the endemic area (shaded area on map) is 7.7% (range: 0.5-28.0%) whereas the prevalence for elk is 3.4% (range: 1.0-9.3%). It is unknown why more deer than elk are found to have the disease. Also, a higher percent of buck deer test positive for CWD compared to does; it is unknown if more bull elk get CWD than do cow elk. In addition, 1,095 elk from the Jackson herd have been tested since 1997 and none were found to be infected.
The prevalence of CWD in captive elk or deer has been found to be much higher (59-85%) than for free-ranging animals. This is thought to be due to an increased opportunity for animal-to- animal transmission and/or exposure to an increasingly contaminated environment. Mathematical models have been developed based on free-ranging and captive animal data. These models predict that over a period of several decades CWD prevalence rates will increase with a concomitant decrease in population. Some assumptions of this model have been called into question by scientists and, thus far, there is no proven example of a wild population declining due to CWD.
Many people are concerned that elk on feedgrounds may mimic the circumstances of elk in captivity and suggest that feedgrounds will result in high CWD prevalence resulting in drastic population declines as implicated by the disease models. Although this may happen, a perfectly acceptable alternative hypothesis is that CWD will have little or no impact on elk populations based on the known low prevalence rates for CWD in wild elk. Although there are many opinions, no one knows what will happen if elk on feedgrounds become infected with CWD.
The only tool wildlife managers have employed to slow the spread of CWD is increasing the hunter harvest or otherwise culling deer in a CWD area. This increased killing does result in decreased prevalence simply because decreased numbers of deer result in decreased opportunities for disease transmission. Nonetheless, all attempts at culling have only resulted in lower deer numbers. As of August 2004, culling has not stopped the spread of the disease. Many wildlife disease professionals believe that CWD cannot be stopped from spreading in the wild in the foreseeable future. If true, CWD will likely eventually infect elk in the GYA.
The only way humans have ever been able to control any disease is by developing a thorough understanding of the disease agent, the pathophysiology of the disease it causes, and its mode of transmission. Today, hundreds of research experiments are being conducted around the world to understand diseases like CWD. This research takes time, but eventually we will likely learn how to slow or stop the spread of CWD, how to protect animals from contracting CWD, or even how to cure animals already infected with the disease.
Tuberculosis
Tuberculosis (TB) is a worldwide disease affecting domestic and wild animals, birds, and humans. Tuberculosis is caused by bacteria of the genus Mycobacterium. Bovine TB, caused
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by Mycobacterium bovis, is of most concern to elk and bison in the GYA. Tuberculosis causes lesions in the lungs and elsewhere, resulting in emaciation and oftentimes death. Infections can be unapparent for years.
Bovine TB is not presently found anywhere near the GYA, but there have been cases of TB in game farms in Montana and Colorado. Currently, there are focal areas of bovine TB in free- ranging white-tailed deer in Michigan and bison in Canada. Domestic cattle are capable of harboring TB and transmitting it to wildlife, but the disease has been nearly eradicated in cattle and is highly regulated to prevent its spread.
The disease is usually spread through inhalation of the bacteria by a susceptible host. High densities or artificial concentration of animals are thought to exacerbate the spread of TB. Although TB vaccines exist, none have been proven effective in preventing the disease in wildlife. Like brucellosis, individual animal treatment would be difficult in wild animals due to the need for long-term antibiotic treatment. Testing for TB in free-ranging animals is difficult because animals have to be held for three days to finish the testing process.
The WGFD has sampled 2,532 elk in the GYA since 1992 and found no cases of TB. Today, TB surveillance is conducted in conjunction with CWD sampling because the lymph nodes examined provide evidence of either disease.
Table 4. Jackson Elk Bovine TB/CWD Surveillance, 1992 - 2002
SAMPLE % OF TOTAL YEAR SIZE HARVEST
1992 120 3% 1993 312 12% 1994 302 7% 1995 260 8% **1996 339 (*104) 11% 1997 310 (*243) 9% 1998 393 (*317) 19% 2000 262 (*197) 20% 2002 234 (*234) 10%
Total 2532 (*1095) *Number of CWD samples collected and tested. **CWD surveillance started in 1996.
Prevention is the most rational management strategy for TB. This is being accomplished by continuous surveillance and examination of hunter-harvested wildlife. The nearly successful TB eradication program for cattle, and the recently implemented TB eradication program for farmed elk and deer, make it unlikely that TB will be introduced into wildlife of northwest Wyoming. Reduction or elimination of feedgrounds would not prevent the introduction of TB into the GYA, but feedgrounds could contribute to the maintenance and spread of TB should it arrive.
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Other Diseases
There are other diseases to which elk are susceptible. Diseases such as pasteurellosis, necrotic stomatitis, and psoroptic mange (scabies) have been documented in elk both on and off feedgrounds. Pasteurellosis appears to be a function of animal densities, which cannot be reduced when animals are being fed. That is, the density (number of animals per given area) doesn't change greatly with the total number of animals being fed. Elk are somewhat resistant to this disease and outbreaks are sporadic and mortalities relatively low. Necrotic stomatitis, primarily a disease of feedground elk, has been managed by good feeding management, such as moving feedlines daily, feeding on clean snow, and using high quality forage. Scabies is a parasitic disease primarily of adult bull elk and its prevalence may be a function of animal condition; however, animals in good health and nutrition may be less susceptible to this parasite. High animal densities may exacerbate the parasite's spread. Feedgrounds both hinder (by providing good nutrition) and maintain (by increasing animal densities) this disease.
There are other North American and foreign diseases that are always a potential threat to the elk of the GYA. Paratuberculosis (Johne's disease), meningeal worm, anthrax, malignant catarrhal fever, and foot and mouth disease could be of serious concern to elk managers should they become endemic in the GYA.
Brucellosis and Livestock
The bacterium responsible for brucellosis was first isolated from cattle in the United States in 1910, and by 1934, 33 states had regulations requiring negative blood tests on imported cattle. Because of the widespread occurrence of bovine brucellosis in the U.S. and its importance as a disease of humans, the Cooperative State-Federal Brucellosis Eradication Program was initiated by an act of Congress in July 1934. In addition to costs of human health care associated with brucellosis, the disease was estimated to be costing the livestock industry $50 million annually.
The brucellosis eradication program is based on three components common to all disease eradication programs: 1) Surveillance to locate reservoirs of brucellosis; 2) Control to prevent spread of the disease; and 3) Eradication or elimination of all infected herds, individuals, and reservoirs. Surveillance techniques evolved and improved over time, and they are largely based on tests of milk or blood to detect antibodies against the causative organism. Control involves quarantine of infected and exposed animals and restrictions on movements of high risk animals. Vaccination is an important tool of control that reduces spread within affected herds and minimizes introduction of infection from outside a herd. Eradication has largely been based on test and slaughter of infected cattle. Depopulation is the preferred method in the late stages of an eradication program.
Cattle in Wyoming were certified as brucellosis free in 1985, culminating significant expense and effort on the part of Wyoming cattle producers and federal and state livestock health regulatory officials. Montana and Idaho cattle were certified brucellosis free in 1985 and 1990, respectively. Wyoming lost its brucellosis-free status in February 2004 because of a bovine brucellosis outbreak that was likely due to transmission from elk wintering on a feedground.
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Currently, only Texas and Wyoming do not have brucellosis-free status. Nationwide costs of the eradication program have exceeded $4 billion, but savings once brucellosis is eradicated are expected to far exceed costs of eradication.
Wyoming and federal livestock health officials have identified seven occurrences of bovine brucellosis outbreaks they believe were transmitted from elk or bison in Wyoming since the early 1960s. Prior to the 1970s there was not a great deal of effort put into identifying sources of bovine brucellosis because the disease was relatively common in cattle. As the eradication program progressed in Wyoming, increasingly extensive efforts were made to identify sources of bovine brucellosis outbreaks, largely because of the importance of identifying all brucellosis- affected cattle herds. During the five-year period 1980-1984 there were three bovine brucellosis outbreaks attributed to elk and in the period 1985-1989 there were three additional outbreaks in cattle for which elk or bison were believed to be the likely sources.
The Parker Land and Cattle outbreak in Fremont County occurred in February 1989, after Wyoming was declared brucellosis-free. The Parker Land and Cattle brucellosis outbreak was identified and contained, and Wyoming did not lose its brucellosis-free status. However, this outbreak attracted considerable local and national attention and resulted in formation of a Governor’s Brucellosis Task Force, the Greater Yellowstone Interagency Brucellosis Committee, two reviews of Wyoming’s brucellosis eradication program by USDA/APHIS/Veterinary Services, and development of the Game and Fish Department’s Brucellosis-Feedground-Habitat Program. There was no bovine brucellosis outbreak during the period from 1990 through 2002. A bovine brucellosis outbreak was discovered in Sublette County in November 2003. This was in a cattle herd that adjoined an elk feedground and is likely due to cattle contact during winter with reproductive products from a brucellosis-infected elk from the feedground during the winter of 2002-03 or 2001-02. In June of 2004, a single cow from another cattle herd, in Teton County, was confirmed positive for brucellosis. In July of 2004, one more cattle herd, in Campbell County, was confirmed positive for brucellosis. To date, this cattle herd is not known to have a history of co-mingling with elk or bison in the Greater Yellowstone Area.
The 2003 Sublette County bovine brucellosis did spread to a second cattle herd; and, according to rules of the eradication program, Wyoming lost its brucellosis-free status in February 2004. This loss of brucellosis-free status has impacts on the livestock industry throughout Wyoming and the nation. Marketability of cattle in Wyoming is negatively impacted, and there will be a continuing focus on the cattle industry of the Greater Yellowstone Area by other states and brucellosis-free countries.
Under the rules of the brucellosis eradication program, the status of Wyoming’s cattle was down- graded from Free to Class A, which has certain requirements that affect all cattle producers in Wyoming. All test-eligible cattle must be tested and demonstrated to be free of brucellosis within 30 days prior to interstate movement or change of ownership. This may cost $3-10 per head, which is a significant added cost to producers. Because of the reservoir of brucellosis in elk and bison of the GYA, producers in Wyoming, Idaho, and Montana will continue to have to vaccinate their cattle and participate in surveillance programs indefinitely. These activities are expensive for producers and are not necessary in states where there is no reservoir of brucellosis.
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The 2004 Sublette County bovine brucellosis outbreak demonstrated the risk to cattle associated with proximity to elk feedgrounds. There also are risks to cattle if elk traveling to or from feedgrounds must pass within proximity of cattle, especially in spring, when infected elk are likely to abort. On the other hand, elk feedgrounds are an important tool available in the effort to eradicate brucellosis from elk. Elk on feedgrounds are trapped and tested for antibodies against Brucella abortus, allowing the Game and Fish Department to monitor the prevalence of brucellosis and progress of the Brucellosis-Feedground-Habitat Program. In addition, feedgrounds play an important role in reducing co-mingling of elk and cattle, thereby lowering the risk of transmission of brucellosis to cattle. Presence of elk on feedgrounds provides accessibility to elk to vaccinate them against brucellosis, thus reducing transmission of brucellosis among elk and the risk of transmission to cattle.
Brucellosis–Feedground–Habitat (BFH) Program
The Wyoming Game and Fish Department developed an integrated program in an attempt to control brucellosis in free-ranging elk associated with feedgrounds in the late 1980s. This integrated approach, called the Brucellosis-Feedground-Habitat (BFH) Program, combines ongoing Game and Fish Department programs (feedground elk vaccination, feedground management, habitat enhancement, elk/cattle separation, education) with the goal of eliminating brucellosis in elk and keeping elk and cattle separated during potential brucellosis transmission periods. This BFH program is currently staffed with one permanent and three contract biologists. Staff support for several of the BFH program activities comes from inter- and intra- agency personnel. Additional support for the program comes from the USDA Animal and Plant Health Inspection Service (APHIS), and the Greater Yellowstone Interagency Brucellosis Committee (GYIBC) provides some technical and policy advice.
Elk Vaccination
The Game and Fish Department began vaccinating elk using remote delivery biobullet technology in 1985 at the Greys River Feedground. The Game and Fish Department currently vaccinates elk against brucellosis on 21 of its 22 feedgrounds while maintaining the Dell Creek feedground as an unvaccinated control with which to compare vaccine efficacy.
Vaccination is typically conducted on feedgrounds in January and February, after elk counts have been performed to estimate populations. Feedground operators and/or BFH personnel deliver biobullets from hay sleds, while also marking animals on one side with oil-based paintball markers to make sure animals only receive one dose.
During the first two years of a previously non-vaccinated feedground, or a feedground where adequate coverage has not been achieved in the recent past, all calves and all females are vaccinated. Calfhood vaccination only occurs after this period. Nearly 62,000 doses of vaccine have been administered using these technologies since 1985 (Table 5).
Elk are vaccinated with the strain 19 vaccine, a modified living bacterium that is less pathogenic than Brucella abortus (also referred to as "field strains"). The vaccinated elk is transiently
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infected with strain 19, which stimulates the immune system to ward off the most deleterious effects of actual infection caused by the more virulent field strain.
The biobullet is fired from an air-powered rifle capable of accurately administering the vaccine at distances of up to 150 feet. The bio-bullet and its contents completely dissolve in the muscle tissue within several hours of implantation.
In controlled studies, Brucella abortus strain 19 vaccination was shown to reduce abortion rates in elk (Thorne et al., 1981). Research has demonstrated that the newer strain RB51, the preferred vaccine for cattle, provides no protection against abortion in elk, even when administered more than once.
The strain 19 vaccine is designed to prevent abortion, but not infection by field strain Brucella. Thus, vaccinated elk may contact and become infected by Brucella abortus, but not abort their calves. Strain 19 protects about 30% of the elk (about the same as for cattle) from abortion, which is the desired goal of vaccination in order to prevent disease transmission. Even though the strain 19 vaccine is not 100% effective, vaccinating all the calves over several years develops a "herd immunity", which is effectively higher than a single year's 30% efficacy.
Table 5. Wyoming elk feedground vaccination summary 1985-2004 Strain 19 Vacination Summary Feedground Year Initiated Total Doses Alkali 1991 2453 Bench Corral 1997 1768 Black Butte 1989 3343 Camp Creek 1989 3933 Dell Creek* ---- 0 Dog Creek 1990 4127 Fall Creek 1994 2700 Finnegan 1996 903 Fish Creek 1993 1598 Forest Park 1988 4066 Franz 1997 1228 Greys River 1985 5119 Patrol Cabin 1991 2174 Horse Creek 1989 5480 Jewett 1997 1917 McNeel 1992 2596 Muddy Creek 1995 1940 NER 1989-91, 03-04 5020 North Piney 1995 156 Scab Creek 1995 2553 Soda Lake 1992 1945 South Park 1990 4227 Upper G.R. 1986 2691
Totals 61937 * Dell Creek has never been vaccinated (control)
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A presumptive diagnosis of brucellosis in wild animals can be made through a variety of serologic (blood serum) tests. It is "presumptive" because these tests only detect antibodies made by the animal when it becomes infected with the Brucella bacteria. The tests cannot determine if an animal is actually infected with bacteria and is capable of transmitting brucellosis. For example, Brucella can be cultured from only 25% of bison having antibodies to the organism. Because the vaccines comprise living bacteria, they also induce an antibody response.
Older tests could not distinguish between antibodies caused by vaccination and those caused by actual infection. Thus, seroprevalence data (the percent of animals testing positive in a given sample) measured by these older tests over-represented the number of animals actually infected with field strain Brucella. Today, the WGFD uses a validated serology test (competitive ELISA or cELISA) that does distinguish between antibodies induced by vaccination from those induced by actual exposure to the field strain bacteria. All seroprevalence data now reported by the WGFD are from tests conducted with the cELISA and presumably indicate the percent of animals exposed only to field strain Brucella.
Brucellosis Serology
The Game and Fish Department initiated brucellosis surveillance in elk on the Greys River Feedground and National Elk Refuge in 1971 to monitor the distribution and prevalence of the disease. Currently, Game and Fish personnel trap, bleed, and test elk on four to five feedgrounds annually. To date, 3,705 yearling and adult female elk trapped on 19 different feedgrounds have been tested. It is important to remember seropositivity only indicates the animal has been exposed to Brucella and has formed an antibody response, but does not determine presence (or infection) of Brucella within the animal.
Serologic data (Table 6) indicate Brucella seroprevalence averages 32.4% (+/- 13.9 ) on Dell Creek feedground, which serves as a control and has never been vaccinated, and has fluctuated from 8% in 2004 to 50% in 1999. All vaccinated feedgrounds combined average 23.6% (+/- 15.9), and vary from 0% at Greys River in 1994, to 59% at Greys River in 2004. A 2-tailed paired sample t-test reveals mean seroprevalence at Dell Creek compared with all vaccinated feedgrounds is not significant (P= 0.27).
However, due to the complexity of factors involved in brucellosis transmission and the high variance in seroprevalence among years and feedgrounds, direct comparisons of mean seroprevalence may not accurately assess strain 19 program efficacy. Additionally, prevalence comparisons between Dell Creek and vaccinated feedgrounds within years assumes all transmission factors are equal excepting protection afforded by strain 19 vaccine in prior years on vaccinated feedgrounds. Thus, these data indicate strain 19 vaccination may have influenced declines in seroprevalence on several feedgrounds assuming all transmission factors are equal with Dell Creek, but are to be interpreted with caution.
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Table 6. 1993 – 2004 Brucellosis seroprevalence (%) by feedground as determined by 4 standard and cELISA tests. Year Dell NER Dog Horse S. F. Alpine Finnegan Franz Black Upper Fall Muddy Cr.* Cr. Cr. Park Park B. GR Cr. Cr. 1993 11 29 1994 0 15 1995 13 37 1996 13 9 24 1997 13 33 3 1998 26 15 43 14 1999 50 13 9 2000 45 19 26 9 2001 26 7 26 54 18 2002 35 18 33 50 2003 37 17 26 51 37 15 2004 8 20 59 27 Mean 32.4 14.7 29.7 19.0 26.0 29.5 24.9 18.0 37.0 9.0 15.0 22.0 29.3 *Dell Creek Feedground is a control; elk have not been vaccinated on this feedground
Elk/Cattle Separation
Preventing elk from establishing feeding patterns in cattle wintering areas greatly decreases the potential for brucellosis transmission to cattle. Each year, Game and Fish Department personnel employ a variety of techniques designed to keep elk and cattle separated. Techniques used include: 1) feedgrounds; 2) providing stackyard materials; 3) hazing elk; and 4) lethal take of elk.
The Game and Fish Department provides game-proof fencing to prevent elk from depredating stored hay crops. Since the inception of the BFH program in 1991, elk-proof fencing materials for 175 haystacks have been provided to cattle producers in three counties in western Wyoming.
In some situations elk are actually hazed away from hay crops using pyro techniques. Often elk have to be physically moved or herded from cattle feedlines, typically through the use of snowmobiles or helicopters. In more severe damage situations where elk cannot be readily moved to a proper wintering area, some elk are shot. Elk may be harvested by hunters through late season depredation hunts on private lands or in extreme cases, by Game and Fish personnel through the use of kill permits.
The amount of time spent implementing management actions varies with the severity of the winter, but the long-term trend would show a dramatic increase in such activities over the past 20 years. A review of Daily Activity Reports for Wildlife Division employees in the Jackson/Pinedale Region from fiscal year 2000 through fiscal year 2004, show a total of 6,067 person hours, or 758 person days, have been spent to prevent elk damage and elk/cattle co- mingling. This would equate to an average of 152 days/year.
Given the average daily cost (salary only) of $176 per game warden, this equates to $26,752 per year spent addressing elk damage. There are additional costs for equipment such as trucks, snowmobiles, and aircraft charter. The Game and Fish Department has spent between $1,000 and $10,000 in most years using helicopters to haze elk. Annual snowmobile operation costs routinely exceed $10,000. When conflict prevention efforts fail, emergency elk feeding has
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been used to manage elk. This involves additional hay purchase, numerous additional days worked, hotel, and vehicle costs for persons from outside the region. Emergency feeding costs in 2003-04 exceeded $8,000.
These figures do not include considerable time spent by BFH and Habitat personnel who also contribute regularly to such activities. Also, this does not include other activities indirectly related to elk damage, such as processing damage claims, initiating feedgrounds, and administering Hunter Management Areas for hunts designed to alleviate elk damage.
It is important to note that the Department’s considerable effort to manage damage conflicts and maintain elk and cattle separation occurs with an average of only 20% of the elk wintering away from feedgrounds. This workload frequently exceeds the workforce assigned to the region.
Given the combination of deep snow, present land ownership patterns, land use, and resource allocation, it is doubtful the Department could adequately address damage and separation issues with less elk feeding. If no circumstances changed, it would take a reduction in elk numbers or elimination of livestock use to eliminate feeding as a management tool.
Wolves create an additional feedground management dynamic (Werbelow, 2003). In early winter, wolves often disrupt feeding operations and increase the potential for elk damage and co- mingling with cattle. During spring, wolves may improve management by moving elk away from feedgrounds to spring transitional ranges.
In addition to winter activities, BFH personnel have been monitoring areas since 1999 where elk parturition and cattle turnout dates overlap. During the elk calving period, from late May to mid June, there is a potential risk for brucellosis transmission to cattle on overlapping ranges. Twenty public land grazing allotments in three counties have been identified as potential risk areas (See Fig. 3). Monitoring efforts to date have not revealed co-mingling in the majority of these allotments. Coordination and education efforts with land managers and grazing operators will be continued to resolve elk/cattle interaction if and when conflict areas are identified.
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Fig. 3. Overlaps in elk parturition and public land grazing allotments where livestock grazing begins prior to June 15th
Habitat Enhancement
A variety of habitat enhancement techniques have been employed to manipulate vegetation and promote a more desirable assortment of plants or plant communities. These habitat enhancement techniques include prescribed fire, mechanical treatments, and herbicide application. Game and Fish Department BFH and Habitat biologists typically prefer to use prescribed burning as the
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primary tool, as it most closely mimics natural disturbances and is the most cost effective enhancement method per acre.
Elk habitat and forage have been significantly modified through human control of wildfire. Fire suppression over the past century, along with a general reduction of ground cover by domestic livestock, have significantly reduced fire on the landscape (DeByle and Winokur, 1985; Baker, 1925). Fire has historically been responsible for creating a mosaic of diverse age classed vegetation for all habitat types throughout the mountain West and rejuvenating plant communities dependent upon disturbance. Ecotones between plant community successional stages produce a combination of forage and cover highly preferred by elk (Skovlin, 1982).
Forage within burned areas frequently possesses elevated nutritional values, especially crude protein and digestibility, for 5-10 years post-fire. Moreover, fire-induced changes in vegetation species composition generally benefit free-ranging ungulates and are long-term, lasting 25-100 years. Historically, approximately four percent of the landscape in the West was burned each year by wildfire. Less than one fourth of this amount has burned annually within the past several decades, leaving a disproportionate amount of the landscape in advanced successional stages. Human controlled (prescribed) fire is used to reintroduce fire to the landscape to promote a balance of diverse plant communities and age classes across the landscape.
Mechanical treatments are a tool used to improve habitat for elk and other wildlife. There are numerous mechanical devices that can be used to manipulate vegetation. Most include varieties of modified farm equipment designed to disturb the vegetative cover, setting back natural succession of plant communities. Pulling a disc, half-round drum, ripper, mower, or enormous chain behind a tractor are some techniques used to promote herbaceous production, species diversity, and reduce competitive plants in shrub, grass, and small tree vegetation types. Thinning and harvesting using chainsaws or the forward harvester (mechanical vehicle used to cut and move trees) can also be used as a vegetation management technique to rejuvenate stands, increase production, and eliminate undesirable species.
Herbicide application to reduce specific plants, while increasing the quantity and quality of other plants, can also help create diverse plant communities. The herbicide “Spike” can be used to reduce the density of sagebrush, promoting increased herbaceous production. Targeted application of various herbicides can also help control noxious weeds and reduce competition with more desirable and palatable natives.
Game and Fish Department personnel, with various partners, have treated over 67,000 acres of habitat over the last 12 years in the Jackson/Pinedale Region with the primary goal of enhancing the quality and quantity of elk ranges (See Figure 4). There are three BFH project biologists working in different geographic areas within the Jackson/Pinedale Region. These areas include the Pinedale, Big Piney, and Jackson BFH projects areas. Listed below are completed habitat treatments for each BFH project area.
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Pinedale BFH Area Vegetation Treatment Summary
15 projects completed from 1993-2004 10 prescribed burns = 12,860 2 herbicide (Spike) = 620 3 mechanical (aspen cutting) = 110 TOTAL 13,590
Piney BFH Area Vegetation Treatment Summary
13 projects completed from 1992-2004 3 mechanical (various) = 4,476 5 prescribed burns = 3,540 3 herbicide (Spike) = 1,355 TOTAL 9,371
Jackson/Afton BFH Area Vegetation treatment Summary
28 projects completed from 1990-2004 23 prescribed burns = 43,200 5 mechanical (mostly cutting) = 1,100 TOTAL 44,300
Figure 4. Number and location of habitat enhancements and wildfires within the Jackson/Pinedale Region.
Habitat improvements to increase forage quality and quantity can reduce dependence on feedgrounds, in terms of days of use and/or amount of feed consumed, but their effectiveness is currently limited and quite variable for several reasons. Elk generally move to supplemental feed when native forage becomes limited due to ungulate consumption or snow depth, which varies from year to year. If the potential for damage on private lands exists, elk are either moved to adjacent feedgrounds and/or feeding is initiated early to attract elk away from potential damage/co-mingling conflicts. Thus, the need to prevent damage to stored crops and co-mingling of elk and livestock and variable winter conditions reduce the overall effectiveness of habitat improvement efforts.
Habitat improvements are an important part of the multi-faceted approach to managing brucellosis, and provide benefits to many wildlife species, but habitat improvements alone are not likely to solve the problem or allow phasing out of elk feedgrounds. However, habitat improvements in conjunction with other management actions such as conservation easements, land acquisitions, and forage allocations for wintering elk on public lands may allow phasing out certain feedgrounds.
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Information and Education
Game and Fish Department personnel regularly inform and educate various public factions about wildlife diseases, including brucellosis and chronic wasting disease. Educational outreach efforts have included multi-agency symposiums, group presentations, videos, news releases, interpretive signs at feedgrounds and crucial winter ranges, and a number of brochures and publications. The importance of quality wildlife habitat and the significant role fire plays in natural ecosystems is also stressed throughout these efforts. Game and Fish Department field personnel make numerous contacts with private landowners regarding habitat improvement projects, wildlife-friendly management techniques, or ways to prevent co-mingling of elk and livestock. Additional efforts are focused on youth education at events such as the Game and Fish Department’s annual Youth Conservation Camp at Dubois and the annual Hunting and Fishing Expo in Casper to inform kids, and their parents, on the vaccination program and brucellosis management.
The BFH program is an effective integrated management approach addressing brucellosis and elk management. Surveillance has indicated remote delivery of strain 19 vaccine has reduced opportunities for brucellosis transmission in elk through enhanced immunity. Techniques employed to maintain elk/cattle spatial and temporal separation have been effective. Thousands of acres of habitat enhancement projects coupled with modified feedground management practices have maximized elk use of spring and fall habitats, potentially decreasing the average time elk occupy feedgrounds and the associated density dependent rate of disease transmission. These enhancements have also benefited numerous other wildlife species and have restored ecosystems to a more properly functioning condition.
Although the BFH approach has demonstrated its effectiveness in reducing opportunities for brucellosis transmission and reducing elk/cattle conflicts while enhancing habitat for numerous wildlife species, this approach alone will not likely eradicate the disease from the GYA. However, until a more efficacious vaccine is developed and/or the various elk/livestock/habitat conflicts are resolved, the BFH program may be the only practical approach currently available to control brucellosis in elk at a manageable level.
Interagency Coordination
Brucellosis and elk feedgrounds have a long history in Wyoming. Brucellosis was probably introduced as an exotic disease of elk around 1900 and elk have been fed since 1910. Although brucellosis was known to be present in elk and bison of the GYA in 1934, when the Cooperative State-Federal Brucellosis Eradication Program was adopted, little or no thought was given to its presence in wildlife and future problems it would eventually present to complete eradication of the disease. Brucellosis and wildlife related issues in the 1960s and 1970s were largely focused on bison of Yellowstone National Park.
Brucellosis was first identified in elk in 1930 at the National Elk Refuge and at Greys River Feedground in the 1940s. The scope of brucellosis in elk as a problem began to be recognized in the 1970s when the Game and Fish Department began testing large numbers of elk for antibodies
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against Brucella abortus at Greys River Feedground, the National Elk Refuge, and other elk feedgrounds. Also during the 1970s, livestock health officials dealt with persistent brucellosis problems in a herd of cattle adjacent to the Greys River Feedground. The Game and Fish Department began controlled research on brucellosis in elk at the Sybille Wildlife Research and Conservation Education Center in 1971-72.
By the late 1970s, research at Sybille and testing on elk feedgrounds demonstrated brucellosis was an important disease in elk, causing approximately 50 percent of infected females to abort their first calf following infection. Brucellosis was present on all elk feedgrounds and research into the possibility of vaccinating elk against brucellosis was appropriate. By 1985, the Game and Fish Department, with concurrence of USDA/APHIS/Veterinary Services, concluded Strain 19 vaccine was safe in elk and about as effective in elk as it is in cattle at preventing abortion when a vaccinated elk becomes infected.
In 1985, the same year Wyoming’s cattle were declared free of brucellosis, the Game and Fish Department initiated vaccination of feedground elk with a ballistic bio-bullet system on a trial basis at Greys River Feedground. During this time, increasing regional and national attention was being paid to brucellosis in elk and bison of the GYA. In order to encourage inter-agency communication, the Tri-State Brucellosis Technical Committee was formed in 1988 and held its first meeting in October in conjunction with a meeting of the U.S. Animal Health Association. The Technical Committee met one or two times a year, but it had no authority and served only to establish dialogue and understanding among agencies and parties.
In response to the Parker Land and Cattle bovine brucellosis outbreak, Wyoming Governor Mike Sullivan established the Wyoming Brucellosis Task Force in May 1989. The Task Force established a goal to “Protect the integrity of Wyoming’s free-ranging bison and elk populations and livestock industry by eradicating wildlife brucellosis by the year 2010.” The Task Force recognized a number of problems stood in the way of achieving this goal and that the brucellosis problem involved all the GYA, not just Wyoming. And, it recognized cooperation and coordination of all state and federal wildlife management, land management, and livestock health agencies, along with stock grower and conservation organizations, in the three affected states was needed to eliminate brucellosis in wildlife in the GYA. The Task Force made numerous recommendations, many of which have been implemented, while others have not been accomplished. A key recommendation was to establish a multi-agency, tri-state brucellosis committee to address brucellosis in wildlife in the GYA.
In 1995, an MOU establishing the Greater Yellowstone Interagency Brucellosis Committee (GYIBC) was signed by the Governors of Wyoming, Montana, and Idaho and the Secretaries of Agriculture and Interior. The MOU contained a goal, mission, and ten objectives that would guide the GYIBC in its activities. With establishment of GYIBC, the Tri-State Brucellosis Technical Committee was disbanded. The GYIBC has established and maintained communications, understanding, dialogue, and cooperation among member agencies that was not previously possible. The GYIBC has sponsored two symposiums on brucellosis in the GYA, written an informative white paper on brucellosis, adopted a resolution recommending against new feedgrounds in the GYA, prepared an Information and Education Plan for Citizen Participation and a video on brucellosis in GYA, and written technical reports on male
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transmission of brucellosis, brucellosis in horses, vaccine safety and efficacy, a bison quarantine protocol, etc. The GYIBC’s commitment to respect and honor mandates and responsibilities of member agencies prevents unilateral initiation of management actions, which has led many people to conclude it “moves with glacial speed.”
In response to the November 2003 bovine brucellosis outbreak in Sublette County and loss of Wyoming’s brucellosis-free status in February 2004, Governor Dave Freudenthal established the Wyoming Brucellosis Coordination Team. It is charged to develop best management practices and specific recommendations related to four topics: 1) Reclaim Wyoming’s brucellosis-free status and improve surveillance in cattle and work to end transmission between cattle and wildlife; 2) Develop a road map of what to do in the event of a new brucellosis outbreak in cattle; 3) Address human health concerns associated with brucellosis; and 4) Reduce, and eventually eliminate, brucellosis in wildlife. Four committees were formed to address these topics: 1) Human health issues; 2) Cattle issues; 3) Regulatory issues; and 4) Wildlife issues. The Brucellosis Coordination Team has established an ambitious meeting schedule and intends to present its report and final recommendations to the Governor in late 2004, in time to prepare legislation for the 2005 legislative session, if necessary.
Literature Cited
Baker, F.S. 1925. Aspen in the Central Rocky Mountain Region. U.S.D.A. Bulletin 1291.
Dean, R., et.al. 2003. Proceedings of the 5th Deer and Elk Workshop.
DeByle, N.V., and R.P. Winokur. 1985. Aspen: Ecology and Management in the Western United States. U.S.D.A. Forest Service General Technical Report RM-119.
Skovlin, J. M. 1982. Habitat Requirements and Evaluations. Pages 371-374 in Thomas, J. W. and D. E. Toweill, editors. Elk of North America: ecology and management. U.S.D.A. Forest Service. Stackpole Books.
Thorne, E. T., T. J. Walthall, and H. A. Dawson. 1981. Vaccination of elk with strain 19. Proceedings of the United States Animal Health Association 82:359-374.
Werbelow, S., R. Dean. 2003. Proceedings of the 5th Deer and Elk Workshop.
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Appendix 3 WYOMING GAME AND FISH DEPARTMENT CHRONIC WASTING DISEASE MANAGEMENT PLAN February 17, 2006
EXECUTIVE SUMMARY
y It is the purpose of this plan to provide flexible and adaptable direction for management of Chronic Wasting Disease (CWD) in mule deer (Odocoileus hemionus), white-tailed deer (Odocoileus virginianus), elk (Cervus elaphus) and moose (Alces alces). y The plan will be reviewed and updated as the CWD situation in Wyoming changes and additional information becomes available. y The plan consists of four components: Disease Management, Applied Research, Public Information and Funding. y Based upon the known epidemiology of CWD in free-ranging deer, elk and moose, eradication is currently not a realistic disease management objective. y The Wyoming Game & Fish Department (WGFD) will work to minimize the spread of CWD and coordinate CWD management with other state, federal and tribal agencies. y The WGFD will conduct surveillance to determine spatial distribution and prevalence of CWD, and coordinate CWD research with other state, federal and tribal agencies. y The WGFD will provide timely, complete, and accurate information about CWD. y Although there are concerns or perceptions by some people that CWD could be a livestock or human health threat, there currently is no credible supporting evidence of such a threat; consequently, this plan addresses CWD as a disease of deer, elk and moose. y The WGFD will continue to work cooperatively with the Wyoming Department of Health and other human health organizations worldwide to monitor current research on CWD and human health and to provide up-to-date information to the public. y Many very expensive CWD management, research, and public outreach activities are driven by the consideration of CWD as an international disease of concern; therefore, federal funding is appropriate for implementation of this plan.
INTRODUCTION
Chronic wasting disease is a transmissible spongiform encephalopathy (TSE) of deer, elk and moose that may constitute a health threat to mule deer, white-tailed deer, elk and moose populations in Wyoming and elsewhere. CWD is a wildlife disease that has generated tremendous concern, both in Wyoming and throughout North America. The CWD zone in Wyoming is currently defined as those hunt areas where CWD has been found. The CWD Zone, as presented on the WGFD web site (http://gf.state.wy.us), will be continually updated as new information becomes available. The WGFD is responsible for managing Wyoming’s wildlife. Management of disease in wildlife is an important responsibility of the WGFD. It is the purpose of this plan to provide flexible and adaptable direction for management of CWD in Wyoming. The plan will be reviewed and updated as the CWD situation in Wyoming changes and additional information becomes available. The plan consists of four components:
I. Disease Management II. Applied Research
III. Public Information IV. Funding
COMPONENT I. DISEASE MANAGEMENT
Based upon the current scientific information about CWD in free-ranging deer, elk and moose, eradication is not a realistic disease management objective. Through adoption of this plan, Wyoming has chosen an adaptive management strategy allowing flexibility to alter disease management activities depending on future research results. Currently, the Disease Management component addresses 11 objectives. The WGFD will use the best scientific information available and will take necessary and reasonable steps to achieve these objectives:
1. Manage Dispersal of CWD.
A. Management of New Foci of CWD
Surveillance data indicate that animals infected with CWD are not distributed evenly. Rather, infected animals are often found in groups or clusters. Currently, there is no management action proven to prevent the spread of CWD once established. However, CWD experts have suggested that aggressively culling animals near a newly discovered cluster is a worthwhile management exercise with three main goals. The first goal is to possibly eliminate new infection in a localized area. The second goal is to reduce the prevalence in the new area and slow the spread of the disease. The third goal is to determine prevalence in the immediate area of a new case. Future management actions, if any, would be based on this determined prevalence. Management of CWD will have to be adaptive in nature. In other words, the WGFD will try some management actions and assess the results. These results will determine subsequent management actions.
If a positive animal is found in a hunt area with a low incidence rate or a new hunt area, WGFD personnel will make a decision as to what management actions to take based on the location of the positive animal relative to the CWD zone. If warranted and appropriate, the WGFD will implement the following management actions intended to prevent dispersal of CWD.
Hunter surveillance in the area will be intensified. If hunter samples are unavailable, if warranted and feasible the WGFD will attempt to collect and test up to 50 cervids in a five- mile radius of the index case. For each subsequent cervid that tests positive for CWD, if warranted and feasible the WGFD will attempt to collect and test up to 50 cervids in a five- mile radius of the positive animal. The results of these collections will determine subsequent management actions.
B. Management of CWD via movement of carcasses.
There is a concern that CWD may be moved to new areas by the transport of certain animal parts. To minimize this possibility, the Wyoming Game and Fish Commission (WGFC) regulates what harvested animals and animal parts may be transported from the
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CWD zone to other parts of the state or out of the state. Likewise, the WGFC prohibits the importation of animals or animal parts taken from any state, province or country within areas designated by the appropriate jurisdictional agency as positive for CWD in deer, elk or moose.
C. Restrict translocation of deer, elk and moose.
Live deer, elk and moose from the wild will not be moved to other locations within the state without review and prior approval by the WGFD.
2. Remove deer, elk and moose suspected of being affected by CWD.
Removal of deer, elk and moose displaying symptoms of CWD may reduce spread of CWD and will contribute to statewide targeted surveillance and provide necropsy and/or research material. When and where possible WGFD personnel will lethally take and necropsy all animals suspected of having CWD.
3. Discourage private feeding of deer, elk and moose.
Based on experience with captive deer and elk, there is evidence that CWD is more efficiently transmitted when animals are concentrated. Private feeding may lead to localized concentrations of environmental contamination with the CWD agent. The WGFD will seek legislation prohibiting intentional private feeding of big game animals, including deer, elk and moose and will continue to educate the public on the unintended consequences of intentional private feeding through television, press releases, radio, presentations to the public and personal contacts.
4. Appropriate WGFD personnel will participate in intra- and interdepartmental, intra- and interstate CWD coordination meetings.
Sharing research results and coordination among state, federal and tribal agencies is important in the management of CWD. WGFD administrators, managers, veterinarians, and researchers will participate in appropriate meetings on CWD. Information will be shared with WGFD personnel. The WGFD will coordinate and collaborate with state, federal and tribal agencies on all relevant CWD management issues.
5. Maintain the ban on statutory prohibition of captive deer, elk and moose ownership and facilities in Wyoming and the effectiveness of the WGFC Chapter 10 regulation.
WGFC Chapter 10 Regulation, “Regulation for Importation, Possession, Confinement, Transportation, Sale and Disposition of Live Wildlife,” addresses CWD in relation to the only privately owned elk facility permitted in Wyoming by statute. Any captive cervid imported into Wyoming must originate from facilities certified to be free of CWD for the five years previous to the requested date of importation. This restriction is intended to prevent spread of CWD. There are no other captive, privately owned deer, elk or moose within Wyoming. Future establishment of captive, commercial native cervid facilities in Wyoming is prohibited by statute.
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6. Hunting will continue to be the primary management tool for management of CWD in deer, elk and moose.
The flexibility inherent in Wyoming’s hunting regulations allows the WGFD to modify seasons to meet specific needs. This flexibility, combined with the long and rich hunting heritage the State of Wyoming enjoys, makes the use of hunter harvest the preferred tool in managing CWD.
Testing of deer, elk and moose provides two primary benefits. First, testing provides critical data for management and research. Second, when the hunter provides a sample and accurate and legible contact information, testing allows a hunter to choose whether or not to consume an animal that has tested positive for CWD. Both of these are important, yet distinct, benefits.
Hunters who participate in the WGFD’s CWD surveillance program by providing deer, elk or moose samples for this research and who provide adequate information, can obtain test results through the WGFD's web site (http://gf.state.wy.us/services/education/cwd). If a sample submitted to the WGFD’s CWD surveillance program tests positive and adequate contact information is provided, the hunter will be notified of the positive test result via mail.
Other than the WGFD surveillance program, WGFD will not be responsible for the testing of individual hunter’s animals. The WGFD will provide information regarding public testing facility locations and costs for hunters who choose to have their animals individually tested at their own expense. If hunters wish to have their results handled individually, they may submit their sample to the Wyoming State Veterinary Diagnostic Laboratory in Laramie for a fee.
The WGFD may donate deer, elk and moose carcasses acquired from the CWD zone to individuals after the animal has been tested with no evidence of CWD being found and the recipient signs an affidavit of informed consent. The WGFD will not donate meat from deer, elk and moose killed within the CWD zone to organizations or entities for redistribution. The WGFD cannot, however, guarantee that no risk exists relative to human consumption of deer, elk and moose.
The State of Wyoming does not guarantee the meat quality of wild animals; therefore, the WGFD will not re-issue a hunting license, issue a refund for any deer, elk or moose license, nor reimburse for processing charges if an animal tests positive for CWD. Hunting licenses provide the holder the opportunity to pursue and take an animal in accordance with state statutes and WGFC regulations. A hunting license is not a guarantee or bill of sale for edible meat.
7. Use WGFD targeted and/or hunter-killed surveillance to identify new foci of CWD.
Surveillance using WGFD targeted and/or random, hunter-harvest methods will be conducted outside the CWD zone to identify any new focus of CWD. A new focus of infection will be considered a location outside the zone where one or more test-positive deer, elk or moose are located.
8. Consideration will be given to efforts to reduce prevalence of CWD.
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Large-scale culling to reduce prevalence of CWD could have more severe effects on deer, elk and moose populations than CWD. When and where possible and appropriate, the WGFD will implement management actions intended to reduce or stabilize the prevalence of CWD.
9. Feedgrounds.
Elk have been fed in northwest Wyoming since the early 1900s. Originally, elk feedgrounds were designed to mitigate loss of winter range, reduce human/elk conflicts and maintain a traditional population of elk. More recently, elk feedgrounds have continued to address those issues as well as facilitating separation of elk and cattle to prevent the potential spread of brucellosis. Elk feedgrounds are a complex biological, social, economic and political issue. Wildlife disease adds to this complexity. There has been increased concern CWD will eventually infect elk frequenting the state and federal elk feedgrounds in Lincoln, Sublette and Teton Counties in northwestern Wyoming. Although the prevalence of CWD in free-ranging elk is only 2-3% (approximately an order of magnitude less than that found in deer), the cumulative prevalence of CWD in captive elk has been higher. Elk densities on feedgrounds may result in prevalence levels found in captive elk. It is unknown at this time what impact prevalence’s exceeding 2 – 3% will have on free ranging populations. This does not imply that deer, elk and moose in northwestern Wyoming are more important than deer, elk and moose in the rest of the state, only that they may be more at risk due to winter concentration of elk on feedgrounds.
It should be noted that the prevailing opinion of professionals experienced with CWD epidemiology and current methods available to control this disease in the wild is that the spread of CWD, at best, can be slowed but not prevented. With this in mind, the WGFD will implement the following actions for managing CWD, in the event it occurs, in elk herd units E-102, Jackson; E103, Fall Creek; E104, Hoback; E105, Afton; E106, Piney; E107, Green River; and E108, Pinedale; in Lincoln, Sublette and Teton Counties.
A. Intervention
The best way to deal with the concern of CWD reaching feedgrounds is to establish proactive measures elsewhere in the state in an attempt to slow the spread of the disease. If warranted and feasible, the WGFD will deal with any new foci of CWD that is discovered. Management actions outlined in Section 1 of the Disease Management portion of this plan will be implemented in an effort to eradicate CWD from the new area or substantially slow the spread of the disease before it reaches Teton, Sublette or Lincoln Counties.
B. Surveillance
There are two types of CWD surveillance: targeted and hunter harvest. Targeted surveillance is the harvesting and testing of any cervid displaying symptoms consistent with clinical CWD. This surveillance method occasionally detects CWD cases in new areas. Hunter harvest surveillance is a systematic sampling and testing of deer, elk and moose harvested by hunters. This method provides potentially large numbers of samples representing broad geographical areas. Hunter harvest surveillance is a valuable tool for determining disease prevalence as well as finding cases in new geographical areas.
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The WGFD will continue to emphasize having its personnel and contract elk feeders look for, remove and sample deer, elk or moose exhibiting signs consistent with CWD. In addition, the WGFD will continue its public information program asking the public to report sick deer, elk and moose to aid in CWD monitoring efforts. Harvesting such animals may identify a new case of CWD and, in doing so will result in the removal of a potential source of infection and decrease the probability of transmission.
Hunter harvest surveillance for cervids will be expanded in NW Wyoming. When possible, elk that die or are killed on any of the 22 WGFD feedgrounds will be tested for CWD. Deer, elk and moose samples will be collected and tested for CWD by WGFD personnel when an opportunity to collect such samples is available during and outside the regular CWD surveillance program in Teton, Sublette and Lincoln Counties. The WGFD will attempt to sample, in two-year intervals, at a level sufficient to have a 95% probability of detecting CWD at 1% prevalence.
C. Feedground Management
If CWD is detected in elk inhabiting state feedgrounds, WGFD personnel will monitor the population intensively and remove any elk showing clinical signs of CWD. The WGFD will attempt to: 1) maximize the area of feeding to decrease animal-to-animal contact; 2) decrease days of feeding to disperse the elk; 3) take any other actions to decrease elk concentration provided such actions are consistent with other necessary wildlife management and feedground practices. Large-scale culling of elk is not anticipated.
The WGFD will communicate and coordinate with the U. S. Fish and Wildlife Service's National Elk Refuge on strategies for surveillance and management of CWD on the National Elk Refuge.
COMPONENT II. APPLIED RESEARCH
Management of CWD will require a more thorough understanding of the disease, how it is spread among cervids, how it affects cervid population dynamics, the relationship between CWD, bovine spongiform encephalopathy (BSE), scrapie and other transmissible spongiform encephalopathies, whether the disease has the capability to penetrate species barriers and other critical components.
The WGFD will support and conduct, on a priority basis, applied research that will facilitate continued expansion of knowledge of CWD. The WGFD will continue monitoring research that is occurring throughout the world on CWD and TSE to ensure the WGFD has the most current and comprehensive data and scientific information available.
In addition to involvement in ongoing collaborative CWD research, the WGFD, in cooperation with the Wyoming Wildlife/Livestock Disease Research Partnership, has identified research priorities and will seek funding to initiate these studies, which may be conducted in collaboration with other researchers. A mechanism has been established, through the Wyoming Wildlife/Livestock Disease Research Partnership, so money specified for CWD research can be
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received, matched, and used for collaborative research. The current Applied Research component includes:
1. Determine spatial distribution of CWD in Wyoming.
The WGFD has been monitoring CWD since 1983 using targeted surveillance and hunter harvested game animals to determine distribution and prevalence. Ongoing surveillance will be integrated with expanded studies using GIS technology and intensive sampling to monitor the distribution and prevalence of CWD in Wyoming. Hunter-harvest and/or targeted surveillance statewide will be planned yearly to better define boundaries of the CWD zone and identify new focus areas.
2. Dynamics of CWD in free-ranging white-tailed deer.
The WGFD is financially and materially supporting a multi-year study of the epidemiology of CWD in white-tailed deer. For a variety of reasons, white-tailed deer may be more susceptible to CWD. Movement patterns of white-tailed deer from the CWD zone are being monitored using telemetry. Telemetry will also provide data on survival and, thus, potential impact on the population. These data would be used to estimate the risk of CWD moving into new areas via white-tailed deer, to evaluate the need for different management strategies in mule deer and white-tailed deer and to evaluate strategies to prevent spread of CWD.
3. Appropriate WGFD personnel will participate in intra- and interdepartmental, intra- and interstate CWD research meetings.
Sharing research results among state, federal and tribal agencies is important in understanding and management of CWD. WGFD administrators, managers, veterinarians and researchers will participate in appropriate meetings on CWD. Research information will be prioritized, shared and, where practicable, incorporated into CWD plans.
4. Experimental CWD infection of moose.
The WGFD is conducting research at the Sybille Wildlife Research Unit to assess the susceptibility of moose to CWD infection and to document the pathogenesis of this disease in moose.
5. Predicted population effects on free-ranging elk based on captive elk chronically exposed to the CWD prion.
Forty-three female elk calves were trapped at the National Elk Refuge and transported to Sybille in February 2002. Elk were housed in pens, assumed to be environmentally contaminated with the CWD prion. Elk will be held throughout their lifetimes. Elk dying will be examined and cause of death determined. From these data, it will should be possible to model free-ranging elk mortality and population dynamics under extreme circumstances of CWD prion exposure and transmission. As of December 2005 (46 months post capture), 11 of 43 elk have died due to
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CWD. This compares to 100% mortality in less than 25 months in elk orally inoculated with different dosages of the CWD prion.
6. Epidemiology of CWD: detection, shedding, and environmental contamination.
Thirty elk were orally inoculated with elk CWD prion in May 2005. Every six weeks, elk are individually housed in metabolic cages for three days. Feces, urine, saliva, and blood are collected. These samples are used to develop and validate an assay capable of detecting minute concentrations of the CWD prion in a variety of substrates. Additional samples for testing are collected from insects, rabbits, rodents, and soil where the CWD-infected elk are housed. This study could determine: 1) how the CWD prion is shed from infected animals; 2) the temporal pattern of such shedding; and 3) the degree and extent of environmental contamination with the CWD prion.
COMPONENT III. PUBLIC INFORMATION
Chronic Wasting Disease is of interest locally, nationally and internationally. As the public agency charged with managing CWD in Wyoming’s wildlife populations, the WGFD has an obligation to provide timely, complete and accurate information about all facets of the disease to the public in Wyoming and throughout the United States. Ongoing and effective communication is paramount to any plan to manage CWD. It is challenging to provide accurate and up-to-date information regarding this rapidly changing issue. The lack of information available, and the incorrect information being distributed by others, creates an increased need for timely and accurate communication from the WGFD. The public receives mixed messages about this issue. Therefore it is incumbent on the WGFD to provide accurate, unbiased information.
A top priority is effective communication with the general public, constituent groups and the media about CWD. The WGFD will use a variety of communication tools to provide timely, complete, and accurate information about CWD.
1. Messages - The main messages the Department will communicate include the following:
A. General information about CWD.
The WGFD will provide general information about the disease, its history, the wildlife it affects, and other basic information.
B. Management of CWD.
The WGFD will provide information about the steps it is taking to manage CWD in Wyoming, including surveillance, various activities to slow the spread of the disease and research to understand more about the disease. The WGFD will also provide updated information about where CWD occurs in the state.
C. Human health issues.
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Though there is no evidence that CWD has been transmitted to humans, the WGFD will communicate information to hunters and others provided by disease experts such as the World Health Organization and the Wyoming Department of Health. The WGFD will also provide information on reasonable precautions hunters and others can take when handling game and transporting and disposing of carcasses.
D. Testing.
The WGFD will provide information on how hunters can get their animals tested for CWD.
2. Target Audiences
Target audiences are identified to allow the WFGD to determine the best methods of providing accurate, timely information to interested individuals. The target audience consists of groups and individuals the WGFD believes will be most interested in or potentially impacted by CWD and management of deer, elk and moose herds in Wyoming. y Those who hunt deer, elk and moose in Wyoming – residents, non-residents, and their families y Landowners y Local and national media y WGFD personnel y Public health professionals y Meat processors and taxidermists y Non-consumptive wildlife users and associated businesses (antler hunters, photographers, license selling agents, landfill operators) y State and local officials, policy makers, and communities, including WGFD Commissioners, Wyoming Department of Agriculture, the Governors office y Wyoming Board of Outfitters and Professional Guides, licensed outfitters and professional guides. y Other state, federal and tribal agencies
3. Objectives
A. Inform target audiences of Wyoming’s CWD research, management and regulations as well as the availability of testing.
Inform target audiences of a variety of CWD-related issues using brochures, articles, video, paid advertisements and a variety of other communication tools. This could include presenting information to license selling agents at meetings or through a newsletter, public presentations, displays at events where target audiences will be present, direct mail, putting information on the website and other methods identified throughout this process.
B. Inform hunters, meat processors, taxidermists and others of potential human health issues related to CWD.
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Public opinion surveys reveal that human health issues related to CWD are an identified concern among hunters. Many hunters are still unsure about the potential risks of handling carcasses and eating meat from CWD infected animals. Using information from health experts such as the World Health Organization, the Centers for Disease Control and the Wyoming Department of Health, the WGFD will provide accurate information to hunters and others about any potential risks to humans, including meat processing information and recommendations.
C. Maintain and make information available on peer-reviewed scientific studies related to CWD.
Part of the concern about CWD stems from the unknown aspects of this disease. Maintaining information on accepted scientific studies that can be shared with concerned citizens can increase their knowledge level and decrease their concerns. A synopsis of applicable Wyoming studies will be provided to target audiences via the website and other identified methods. A synopsis of studies from other states will be requested, and provided if possible. A link to official research-oriented websites in addition to our current link with the CWD Alliance website will be used to make sure this information is readily available.
D. Clarify the details of this complicated issue by making scientific information user friendly for interested publics.
Many times the scientific jargon associated with a disease makes it difficult for those not working in that specific field to comprehend. Relating accurate information in a format that is easily understood by our target audiences will allow us to better reach our communications goals. The media is trained to put technical information in a form the public can understand. If we want the public to come to the WGFD for accurate, complete, and up-to-date information, we must provide it in a format that is useable. Using layman’s terms when publishing articles, doing presentations, and communicating with our constituents can accomplish this objective.
E. Coordinate with other individuals, state, federal and tribal agencies involved in CWD public information efforts.
CWD has been discovered in wild deer, elk and moose populations in other states. Each state is conducting efforts to inform their publics about CWD and the potential effects on wildlife populations. Wyoming, federal and tribal agencies are also involved in some aspects of CWD. Coordinating with other individuals and agencies could prevent the public from getting different messages from different places, further confounding an already complicated issue. The WGFD will participate in multi-agency meetings to share information. We coordinate efforts with other state wildlife agencies through the Association for Conservation Information. We will continue to work with the CWD Alliance to disseminate information and to routinely visit other state websites to monitor what CWD information is available to the public.
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F. Provide the media with timely and accurate CWD information.
Providing timely, complete and accurate information lends to the WGFD’s credibility and is the mission of most media professionals. Working together to meet the collective goal of providing the public with important information will help build professional relationships. The WGFD will attempt to be the first to publicize any new developments related to CWD. WGFD personnel will also respond to interview requests in a timely fashion. Putting the scientific jargon aside will lead to more accurate news reports. Developing and sharing a consistent message will also be of benefit. Continuing our follow-up on reporting that is not accurate will help media professionals better understand this complicated issue.
COMPONENT IV. FUNDING
Full implementation of this plan will be expensive and will exceed the WGFD’s current financial capability.
CWD management, research, and public information activities are expensive, and the WGFD’s current financial status will not allow complete implementation of this plan without additional funding. Additional funding specific for CWD will be sought.
ACKNOWLEDGEMENTS
Portions of this plan were liberally copied or patterned after the Colorado Division of Wildlife’s “Chronic Wasting Disease in Colorado Deer and Elk: Recommendations for Statewide Monitoring and Experimental Management Planning” by M. W. Miller and R. H. Kahn and the Colorado Wildlife Commission’s Policy on Chronic Wasting Disease approved September 13, 2001; we appreciate their generosity and their efforts on CWD. Many elements of this CWD Plan would not be possible without the cooperation of sportsmen, landowners, game meat processors, taxidermists, scientists, and professional wildlife managers; we appreciate their interest and help. Scientists worldwide are conducting research on CWD and other transmissible spongiform encephalopathies that helps to understand CWD and, hopefully, will lead to its future eradication.
Adopted by the Wyoming Game and Fish Commission on February 17, 2006.
Signed: ______Linda L. Fleming, President
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Appendix 4
Alkali Creek Feedground with Corral and Hay Shed
Elk on Feedground
2
Facilities on Alkali Creek Feedground
Tool Shed Hay Shed
Feeding Structure
Trash Barrel Hay Wagon Hay Sled
3
Gravel Piles in Hay Barn Wilderness Boundary
Elk Trails
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The following matched photo pairs (Figures 1 through 6) compare the Alkali Creek feedground wetlands in 2007 and 2011. The feedground was visited in September for the initial visit and in July for the more recent one, but conditions did stay moist through most of the summer in 2011. The photo pairs show the wide variability in conditions on the feedground and in the potential wetlands that may exist from year to year.
Southern Wetland in Good Condition, Figures 1 and 2
Figure 1 September 2007
Figure 2 July 2011
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Northern Wetland, Figures 3 through 6
In 2011, rushes (juncus) were growing in the water along the edge of the northern pond, seen in Figures 3 through 6, and timothy was growing along the outer edge of the pond.
Figure 3 September 2007
Figure 4 July 2011
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Figure 5 September 2007
Figure 6 July 2007
Dry Depression
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Over-browsed Aspen within Analysis Area
Wilderness boundary Vegetation/soil impacts from hay wagon or hay sled use
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Wet Area within the Feedground
Wet Area within the Feedground
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Appendix 5 ALKALI CREEK FEEDGROUND – TABLE OF CUMULATIVE ACTIONS IN THE GROS VENTRE WATERSHED
Resources Affected Location
Type Time Action Wilderness/WSR
WithinPermit
Within1 Mile
Vegetation Watershed (PAST, Hydrology
Wildlife
Within
Area
Fish PRESENT Soils FUTURE)
Livestock Grazing on the Upper Gros Ventre Grazing P/PR/F x x x x x x x x x Allotment
Livestock Grazing on the Big Cow, Miners Creek, , Redmond Bierer Allotments and on-off permits on P/PR/F x x x x x x x Grazing Lower Slide Lake, Red Rock, Robinson, and Taylor Ranches.
Livestock P/PR/F Livestock trailing to or from their allotments x x x x x x x
Elk travelling between feedgrounds on NFS lands and Elk Trailing P/PR/F x x x x x x x x to/from the National Elk Refuge Prescribed Vegetation alteration, aerial ignition, construction of P/PR/F x x x x x x Fire fire line, and other fire management activity Vegetation alteration, aerial ignition and aerial Wildfire F application of fire retardant, construction of fire line, x x x x x x x x x and other fire suppression activity Road maintenance and general public use of existing roads and motorized trails in the watershed from 5/1 Roads P/PR/F thru 12/14 and use by permit during shoulder x x x x x x x x seasons (see MVUM for actual open routes, seasonal restrictions, and vehicle class) ALKALI CREEK FEEDGROUND – TABLE OF CUMULATIVE ACTIONS IN THE GROS VENTRE WATERSHED
Resources Affected Location
Type Time Action Wilderness/WSR
WithinPermit
Within1 Mile
Vegetation Watershed (PAST, Hydrology
Wildlife
Within
Area
Fish PRESENT Soils FUTURE)
Roads Past Gunsight Bridge Replacement near Patrol Cabin x x x
Roads Future Crystal and Dew Place Bridge Replacements x x x x
Resource Harvest and removal of firewood, plants, berries, P/PR/F x x x x x x Use mushrooms, antlers, fish and wild game Motorized and non-motorized recreation travel/use and maintenance on system and non-system trails Recreation P/PR/F and off-trail travel/use (including antler hunting) x x x x x x x x x from 5/1 to 12/14; Includes Special Use Permitted Activity Trail grooming and motorized/non-motorized recreation travel/use on system and non-system Recreation P/PR/F x x x x x x x x x trails and off-trail travel/use from 12/1 to 4/30; Includes Special Use Permitted Activity Travel Management Decision limited motorized Recreation P/PR/F x x x x x x x x x travel to designated routes from 5/1 thru 11/30. Picnicking, day use, and camping at designated Recreation P/PR/F recreation sites (Gros Ventre Overlook, Atherton Crk, x x x x x x x x x Red Hills, Crystal Crk) and in dispersed areas Permits for private business operation and Land Uses P/PR/F x x x x x x x x occupancy on NFS lands (Outfitters, pastures, etc.) ALKALI CREEK FEEDGROUND – TABLE OF CUMULATIVE ACTIONS IN THE GROS VENTRE WATERSHED
Resources Affected Location
Type Time Action Wilderness/WSR
WithinPermit
Within1 Mile
Vegetation Watershed (PAST, Hydrology
Wildlife
Within
Area
Fish PRESENT Soils FUTURE)
Land Uses P/PR/F Permit for elk feedground at Fish Creek x x x x x x x
Tree mortality from natural disturbances such as Natural P/PR/F insect and disease, invasive species and diseases, x x x x x x x Disturbances wind-throw, floods, landslides, avalanches, wildfire
Invasive Change in species distribution and abundance due to P/PR/F x x x x x x x Species invasive plants, animals, and diseases Invasive Introduction of chemicals or biological control agents P/PR/F x x x x x x x x x Species to control invasive species Agricultural and residential use and livestock (horse Ag. and and cattle) grazing on private land inholdings and at P/PR/F x x x x x x Residential Patrol Cabin and Goosewing Guard Station; Includes elk feeding at Patrol Cabin Mountain Lion, Grizzly Bear, Antelope, and Bighorn Research P/PR/F x x x Sheep research activity
Wildlife P/PR/F Reintroduction of wolves and subsequent predation x x x x x x
Wildlife Past Wolf relisting x x x x x
Designation of the Pronghorn Migration Route and Wildlife Past x x x x x establishment of Forest Plan standards ALKALI CREEK FEEDGROUND – TABLE OF CUMULATIVE ACTIONS IN THE GROS VENTRE WATERSHED
Resources Affected Location
Type Time Action Wilderness/WSR
WithinPermit
Within1 Mile
Vegetation Watershed (PAST, Hydrology
Wildlife
Within
Area
Fish PRESENT Soils FUTURE)
Recreational gold panning and dredging and Minerals P/PR/F x x x x x x x removal of common materials Predator Removal of bears, wolves, coyotes, and other P/PR/F x x Control predators
Water In channel, floodplain, or riparian restoration and P/PR/F other treatments on private lands primarily, but x x x x x x x Projects possibly also on NFS lands
Recreation P/PR Decommissioning of user-created motorized trails x x x x x x x
Recreation PR Closure of Red Hills Campground x x x x x x
Appendix 6 uthorization ID:JAC100232 FS-2700-4 (v.09/i21 Contact Name: WYOMINGGAMEANDFISH COMMISSION 0MB 0596-008 Expiration Date: 12/31/2015 Use Code: 221, 232, 931
U.S. DEPARTMENT OF AGRICULTURE FOREST SERVICE
SPECIAL USE PERMIT
Authority: ORGANIC ADMiNISTRATION ACT June 4, 1897, FEDERAL LAND POLICY AND MGMT ACT, AS AMENDED October 21, 1976 NYOMING GAME AND FISH COMMISSION of 5400 BISHOP BLVD., CHEYENNE, WY UNITED STATES 82006 (hereinafter “the holder”) is authorized to use or occupy National Forest System lands in the Bridger-Teton National Forest r Jackson Ranger District unit of the National Forest System, subject to the terms and conditions of this special use permit (the permit).
rhis permit covers 91 acres in Sec. 23, T. 42 N., A. 113 W., 6TH PRINCIPAL MERIDIAN , (“the permit area”), as shown on the map attached as Appendix A. This permit issued for the purpose of:
Mkali Feedground: Use and occupancy of National Forest System lands within the permit area indicated on ppendix A on the Jackson Ranger District for the purpose of operating and maintaining a feedground for elk containing one elk tagging corral, one horse corral, one tack shed, one hay stack-yard containing two haysheds, nd a water facility.
In addition, the following will apply:
1. Access to the feedground includes, but is not limited to, feeding, trapping, maintenance, and ha hauling. Administrative access is allowed throughout the winter range closure area when performing duties associated with operating and maintaining the feedgrounds. Permittee vehicular access behind locked gates on closed roads must be approved by the Authorized Officer in advance.
2. If requested by the Forest Service, the Permittee will complete a self-inspection form to report the statur of teedground compliance with the terms of the permit.
3. Permittee will attend any meetings with the Authorized Officer scheduled by the Forest Service to revie and approve any matters pertaining to the administration of the Permit.
4. Any hay or straw used in association with this permit will be certified and tagged as noxious weed o noxious weed seed free (Order 04-00-056, 02-96-02) Documentation of certification will be provided annually. Permittee will be responsible for the monitoring and treating of noxious and invasive weedr within the permit area. Treatment methods will meet Forest Service specifications and monitoring will occur annually.
5. Permittee will avoid feeding in areas within 200 feet of perennial stream banks whenever possible and especially in the early and late season of feeding when the ground is not frozen. Feeding operations will be conducted over frozen ground as much as possible to reduce the potential for soil compaction from equipment and hoofed animals.
6. Feeding is not authorized to take place on the mapped wetland areas, as per the attached Appendix B, o: within 100 ft. from the outer edge of the wetlands and the channel that connects them.
7. Permittee and Forest Service will reduce stream bank damage by identifying specific locations for stream crossings for feeding operations.
8. Permittee shall inspect the permit area prior to use each year and make necessary repairs. Work othe than routine maintenance and/or minor repairs shall be discussed in advance with the Authorized Office in order to obtain pre-approval.
9. Permittee shall immediately cease all activities that may disturb archaeological, paleontological, o historic (but not limited to historic or prehistoric artifacts, structures, monuments, human remains and funerary objects) and notify the Authorized Officer per the Archaeological Resources Protection Act o 1979.
10. Food and refuse storage provisions identified in the Bridger-Teton National Forest Food Storage Ordei
(#04-00-104) are required to be followed year-round. ‘
11. Permittee must keep dogs under voice control to prevent wildlife harassment. Offending dogs must bE removed or restrained when in the permit area.
12. Permittee must contact the Authorized Officer or designee (Jackson District Ranger at 307.413.21361 when an emergency situation occurs that requires immediate action that is outside of the scope of thi permit. If contact and approval cannot be made prior to action, a report of the action must be made a soon as possible after the emergency is addressed.
13. Permittee and their contractors are not authorized to access closed designated winter wildlife ranges to any activity that is not directly related to feedground operations.
14. Feeding or any other feedground-associated activities outside of the permit area are not authorized a any time.
ERMS AND CONDITIONS
I. GENERAL TERMS
.AUTHORITY. This permit is issued pursuant to ORGANIC ADMINISTRATIONACT June 4, 1897, FEDERAL LAND POLICY AND MGMTACT, AS AMENDEDOctober 21, 1976 and 36 CFR Part 251, Subpart B, as amended, and is ‘3ubjectto their provisions.
B. AUTHORIZEDOFFICER. The authorized officer is the Forest or Grassland Supervisor or a subordinate officer with lelegated authority.
. TERM. This permit shall expire at midnight on 12/31/2015, approximately 1 year from the date of issuance.
D. RENEWAL. This permit is not renewable. Prior to expiration of this permit, the holder may apply for a new permit that ouId renew the use and occupancy authorized by this permit. Applications for a new permit must be submitted at least 6 nonths prior to expiration of this permit. Renewal of the use and occupancy authorized by this permit shall be at the sole liscretion of the authorized officer. At a minimum, before renewing the use and occupancy authorized by this permit, the -iuthorized officer shall require that (1) the use and occupancy to be authorized by the new permit is consistent with the standards and guidelines in the applicable land management plan; (2) the type of use and occupancy to be authorized by he new permit is the same as the type of use and occupancy authorized by this permit; and (3) the holder is in ompliance with all the terms of this permit. The authorized officer may prescribe new terms and conditions when a new jermit is issued.
E. AMENDMENT.This permit may be amended in whole or in part by the Forest Service when, at the discretion of the authorized officer, such action is deemed necessary or desirable to incorporate new terms that may be required by law, egulation, directive, the applicable forest land and resource management plan, or projects and activities implementing a and management plan pursuant to 36 CFR Part 215.
F. COMPLIANCE WITH LAWS, REGULATIONS. AND OTHER LEGAL REQUIREMENTS. In exercising the rights and privileges granted by this permit, the holder shall comply with all present and future federal laws and regulations and all present and future state, county, and municipal laws, regulations, and other legal requirements that apply to the permit area, to the extent they do not conflict with federal law, regulation, or policy. The Forest Service assumes no responsibility ro enforcing laws, regulations, and other legal requirements that fall under the jurisdiction of other governmental entities.
G. NON-EXCLUSIVEUSE. The use or occupancy authorized by this permit is not exclusive. The Forest Service reserves he right of access to the permit area, including a continuing right of physical entry to the permit area for inspection, monitoring, or any other purpose consistent with any right or obligation of the United States under any law or regulation. rhe Forest Service reserves the right to allow others to use the permit area in any way that is not inconsistent with the holder’s rights and privileges under this permit, after consultation with all parties involved. Except for any restrictions that he holder and the authorized officer agree are necessary to protect the installation and operation of authorized temporary improvements, the lands and waters covered by this permit shall remain open to the public for all lawful purposes. H. ASSIGNABILITY.This permit is not assignable or transferable.
I. TRANSFER OF TITLE TO THE IMPROVEMENTS.
1 Notification of Transfer. The holder shall notify the authorized officer when a transfer of title to all or part of the authorized improvements is contemplated.
2. Transfer of Title. Any transfer of title to the improvements covered by this permit shall result in termination of the permit. The party who acquires title to the improvements must submit an application for a permit. The Forest Service is not obligated to issue a new permit to the party who acquires title to the improvements. The authorized officer shall determine that the applicant meets requirements under applicable federal regulations.
II. IMPROVEMENTS
.LIMITATIONS ON USE. Nothing in this permit gives or implies permission to build or maintain any structure or facility r to conduct any activity, unless specifically authorized by this permit. Any use not specifically authorized by this permit must be proposed in accordance with 36 CFR 251.54. Approval of such a proposal through issuance of a new permit or ermit amendment is at the sole discretion of the authorized officer.
B. PLANS. All plans for development, layout, construction, reconstruction, or alteration of improvements in the permit -rea, as well as revisions to those plans must be prepared by a professional engineer, architect, landscape architect, or ther qualified professional based on federal employment standards acceptable to the authorized officer. These plans and )lan revisions must have written approval from the authorized officer before they are implemented. The authorized officer may require the holder to furnish as-built plans, maps, or surveys upon completion of the work.
. CONSTRUCTION. Any construction authorized by this permit shall commence by n/a and shall be completed by n/a.
III.OPERATIONS.
. PERIOD OF USE. Use or occupancy of the permit area shall be exercised at least 30 days each year.
B. CONDITIONOF OPERATIONS. The holder shall maintain the authorized improvements and permit area to standards of repair, orderliness, neatness, sanitation, and safety acceptable to the authorized officer and consistent with other provisions of this permit. Standards are subject to periodic change by the authorized officer when deemed necessary to meet statutory, regulatory, or policy requirements or to protect national forest resources. The holder shall comply with nspection requirements deemed appropriate by the authorized officer.
C. INSPECTION BY THE FOREST SERVICE. The Forest Service shall monitor the holder’s operations and reserves the right to inspect the permit area and transmission facilities at any time for compliance with the terms of this permit. The riolder’s obligations under this permit are not contingent upon any duty of the Forest Service to inspect the permit area or ransmission facilities. A failure by the Forest Service or other governmental officials to inspect is not a justification for noncompliance with any of the terms and conditions of this permit.
IV. RIGHTS AND LIABILITIES
.. LEGAL EFFECT OF THE PERMIT. This permit, which is revocable and terminable, is not a contract or a lease, but rather a federal license. The benefits and requirements conferred by this authorization are reviewable solely under the procedures set forth in 36 CFR 251, Subpart C and 5 U.S.C. 704. This permit does not constitute a contract for purposes of the Contract Disputes Act, 41 U.S.C. 601. The permit is not real property, does not convey any interest in real property, and may not be used as collateral for a loan.
B. VALIDOUTSTANDING RIGHTS. This permit is subject to all valid outstanding rights. Valid outstanding rights include hose derived under mining and mineral leasing laws of the United States. The United States is not liable to the holder for he exercise of any such right. . ABSENCE OF THIRD-PARTY BENEFICIARY RIGHTS. The parties to this permit do not intend to confer any rights on ‘nv third party as a beneficiary under this permit. D. SERVICES NOT PROVIDED. This permit does not provide for the furnishing of road or trail maintenance, water, fire )rotection, search and rescue, or any other such service by a government agency, utility, association, or individual.
E. The holder assumes all risk of loss to the authorized improvements. •:•,;,
- -.:. ‘ F. Subject only to the limits of the insurance policy which the holder is required to purchase under clause lV.H,the holder shall indemnify, defend, and hold the United States harmless for any violations incurred under any such laws and regulations or for judgments, claims, or demands assessed against the United States in connection with the holder’s use r occupancy of the property. The holder’s indemnification Qfthe United States shall include any loss by personal-injury, loss of life or damage to property in connection with the occupancy or use of the property during the term of this permit. Indemnification shall include, but is not limited to, the value of resources damaged or destroyed; the costs of restoration, cleanup, or other mitigation; fire suppression or other types of abatement costs; third party claims and udgments; and all administrative, interest, and other legal costs. This paragraph shall survive the termination or revocation of this authorization, regardless of cause.
. Clause IV.F shall not be interpreted to limitany of the holder’s liabilityfor, or prevent the United States from taking any iction to address, injury, loss, damages, or costs associated with environmental contamination, injury to natural resources, or other cause of action that arises under other law, including the Resource Conservation and Recovery Act, is amended, 42 U.S.C. 6901 et seq., the Comprehensive Environmental Response, Compensation, and LiabilityAct, as imended, 42 U.S.C. 9601 et seq., and the Clean Water Act, as amended, 33 U.S.C. 1251 et seq., in connection with the holder’s use and occupancy of Federal lands, or to diminish any independent obligation of the holder to indemnify the United States with respect to the same.
H. The authorized officer has determined through a risk assessment that the potential liability of the United States for property damage and personal injury or death arising from the holder’s use and occupancy authorized by this permit is no more than $1 000,000 per incident and $2,000,000 in the aggregate. The holder shall maintain commercial general liability(CGL) combined single limitprocured insurance covering property damage and personal injury or death for ii ,000,000 per incident and $2,000,000 in the aggregate. Ifthe aggregate coverage limit in the procured insurance policy is reached or exceeded during the policy period, the holder shall obtain an increase in the aggregate coverage limitor rocure an additional insurance policy to restore the aggregate coverage to what it was when the policy was issued. Ifthe ggregate coverage limit is reached or exceeded and the holder fails to obtain an increase in the aggregate coverage limit )r to procure additional insurance, this permit shall terminate. The holder shall provide notice within 48 hours to the Director of Lands, Intermountain Region, (801) 625-5150, if the aggregate coverage limit in the procured insurance olicy is reached or exceeded during the policy period. The CGL insurance shall be written on ISO occurrence form CG 100112 07 (or a substitute form providing equivalent coverage) and shall cover liability arising from premises, operations, independent contractors, personal and advertising injury, and liability assumed under an insured contract (including tort liabilityof another assumed in a business contract). Specifically, the coverage under the insurance policy shall extend to 2rOperty damage and personal injury or death arising from the holder’s activities under the permit, including use and occupancy of National Forest System lands and the construction, maintenance, and operation of the structures, facilities, r equipment authorized by the permit. The United States shall be named as the insured under the CGL policy. The insurance policy shall specify that the Forest Service shall be given 30 days prior written notice of cancellation or any iiodification of the procured insurance policy. The holder shall pay the premiums for the insurance procured under this lause and shall pay the United States the deductible under the insurance policy for any covered claim.
I. Notwithstanding clause lV.F of this permit, any limitation on the holder’s liabilityunder State law, including but not imited to the holder’s sovereign immunity and the Wyoming Governmental Claims Act, Title 1, Chapter 39, of the Vyoming Codified Laws, section 3-39-1 18, shall not be construed in any way to impinge upon the ability of the United tates to recover under the insurance policy. Nothing in this clause precludes the holder or the insurer from asserting any lefense that may be available to the holder, including sovereign immunity, in an action brought against the holder by a hird party.
I. The Forest Service reserves the right to review and approve the insurance policy. The holder shall send an authenticated copy of the insurance policy to the Forest Service immediately upon issuance.
K. Ifa claim is submitted to the United States for property damage and personal injury or death arising from the holder’s se and occupancy authorized by this permit, the Forest Service shall tender the defense of the claim to the respective epresentatives of the insurer. The holder understands that tort claims against the United States are governed by the ederal Tort Claims Act, which may result in the administrative denial of a claim. The holder further understands that in itigation the United States is represented by the United States Department of Justice (DOJ) and agrees that ‘epresentatives of the insurer willcoordinate the defense with DOJ, ifa claim is litigated. L. The holder has an affirmative duty to protect from damage the land, property, and interests of the United States.
til. In the event of any breach of the conditions of this authorization by the holder, the authorized officer may, on reasonable notice, cure the breach for the account at the expense of the holder. Ifthe Forest Service at any time pays ny sum of money or does any act which will require payment of money, or incurs any expense, including reasonable attorney’s fees, in instituting, prosecuting, and/or defending any action or proceeding to enforce the United States rights hereunder, the sum or sums so paid by the United States, with all interests, costs and damages shall, at the election of he Forest Service, be deemed to be additional fees hereunder and shall be due from the holder to the Forest Service on he first day of the month following such election.
N. With respect to roads, the holder shall be proportionally liable for damages to all roads and trails of the United States pen to public use caused by the holders use to the same extent as provided above, except that liabilityshall not include reasonable and ordinary wear and tear.
). The Forest Service has no duty to inspect the permit area or to warn of hazards and, ifthe Forest Service does inspect he permit area, it shall incur no additional duty or liabilityfor identified or non-identified hazards. This covenant may be enforced by the United States na court of competent jurisdiction.
I. RESOURCE PROTECTION
. COMPLIANCE WITH ENVIRONMENTALLAWS. The holder shall in connection with the use or occupancy authorized by this permit comply with all applicable federal, state, and local environmental laws and regulations, including but not limited to those established pursuant to the Resource Conservation and Recovery Act, as amended, 42 U.S.C. 6901 et seq., the Federal Water Pollution Control Act, as amended, 33 U.S.C. 1251 et seq., the Oil Pollution Act, as amended, 33 U.S.C. 2701 et seq., the Clean Air Act, as amended, 42 U.S.C. 7401 et seq., CERCLA, as amended, 42 U.S.C. 9601 et seq., the Toxic Substances Control Act, as amended, 15 U.S.C. 2601 et seq., the Federal Insecticide, Fungicide, and Rodenticide Act, as amended, 7 U.S.C. 136 et seq., and the Safe Drinking Water Act, as amended, 42 U.S.C. 300f et seq.
B. VANDALISM. The holder shall take reasonable measures to prevent and discourage vandalism and disorderly conduct ‘md when necessary shall contact the appropriate law enforcement officer.
. PESTICIbE USE. Pesticides may not be used outside of buildings to control undesirable woody and herbaceous ‘egetation (including aquatic plants), insects, rodents, fish, and other pests and weeds without prior written approval from he authorized officer. A request for approval of planned uses of pesticides shall be submitted annually by the holder on he due date established by the authorized officer. The report shall cover a 12-month period of planned use beginning 3 ‘months after the reporting date. Information essential for review shall be provided in the form specified. Exceptions to this chedule may be allowed, subject to emergency request and approval, only when unexpected outbreaks of pests or veeds require control measures that were not anticipated at the time an annual report was submitted. Only those rnaterials registered by the U.S. Environmental Protection Agency for the specific purpose planned shall be considered for se on National Forest System lands. Label instructions and all applicable laws and regulations shall be strictly followed in he application of pesticides and disposal of excess materials and containers.
D. ARCHAEOLOGICAL-PALEONTOLOGICAL DISCOVERIES. The holder shall immediately notify the authorized officer f all antiquities or other objects of historic or scientific interest, inciuding but not limited to historic or prehistoric ruins, ossils, or artifacts discovered in connection with the use and occupancy authorized by this permit. The holder shall leave hese discoveries intact and in place until directed otherwise by the authorized officer. Protective and mitigative measures pecified by the authorized officer shall be the responsibility of the holder.
E. NATIVEAMERICAN GRAVES PROTECTION AND REPATRIATION. In accordance with 25 U.S.C. 3002(d) and 43 )FR 10.4, ifthe holder inadvertently discovers human remains, funerary objects, sacred objects, or objects of cultural atrimony on National Forest System lands, the holder shall immediately cease work in the area of the discovery and shall ‘nake a reasonable effort to protect and secure the items. The holder shall immediately notify the authorized officer by elephone of the discovery and shall follow up with written confirmation of the discovery. The activity that resulted in the nadvertent discovery may not resume until 30 days after the authorized officer certifies receipt of the written confirmation, resumption of the activity is otherwise lawful, or at any time if a binding written agreement has been executed between he Forest Service and the affiliated Indian tribes that adopts a recovery plan for the human remains and objects. . PROTECTION OF HABITATOF THREATENED, ENDANGERED, AND SENSITIVE SPECIES. The location of sites ithin the permit area needing special measures for protection of plants or animals listed as threatened or endangered nder the Endangered Species Act (ESA) of 1973, 16 U.S.C. 1531 et seq., as amended, or identified as sensitive or therwise requiring special protection by the Regional Forester under Forest Service Manual (FSM) 2670, pursuant to onsuItation conducted under section 7 of the ESA, may be shown on the ground or on a separate map. The map shall be Lttached to this permit as an appendix. The holder shall take any protective and mitigative measures specified by the ‘iuthorized officer. Ifprotective and mitigative measures prove inadequate, ifother sites within the permit area containing hreatened, endangered, or sensitive species or species otherwise requiring special protection are discovered, or if new pecies are listed as threatened or endangered under the ESA or identified as sensitive or otherwise requiring special rotection by the Regional Forester under the FSM, the authorized officer may specify additional protective and mitigative rrieasures. Discovery of these sites by the holder or the Forest Service shall be promptly reported to the other party. . CONSENT TO STORE HAZARDOUS MATERIALS.The holder shall not store any hazardous materials at the site vithout prior written approval from the authorized officer. This approval shall not be unreasonably withheld. Ifthe authorized officer provides approval, this permit shall include, or in the case of approval provided after this permit is ssued, shall be amended to include specific terms addressing the storage of hazardous materials, including the specific ype of materials to be stored, the volume, the type of storage, and a spill plan. Such terms shall be proposed by the iolder and are subject to approval by the authorized officer.
I. CLEANUP AND REMEDIATION
1. The holder shall immediately notify all appropriate response authorities, including the National Response Center and the authorized officer or the authorized officer’s designated representative, of any oil discharge or of the release of a hazardous material in the permit area in an amount greater than or equal to its reportable quantity, in accordance with 33 CFR Part 153, SUbpart B, and 40 CFR Part 302. For the purposes of this requirement, “oil”is as defined by section 311 (a)(1) of the Clean Water Act, 33 U.S.C. 1321 (a)(1). The holder shall immediately notify the authorized officer or the authorized officer’s designated representative of any release or threatened release of any hazardous material in or near the permit area which may be harmful to public health or welfare or which may adversely affect natural resources on federal lands.
2. Except with respect to any federally permitted release as that term is defined under Section 101(10) of CERCLA, 42 U.S.C. 9601(10), the holder shall cleanup or otherwise remediate any release, threat of release, or discharge of hazardous materials that occurs either in the permit area or in connection with the holders activities in the permit area, regardless of whether those activities are authorized under this permit. The holder shall perform cleanup or remediation immediately upon discovery of the release, threat of release, or discharge of hazardous materials. The holder shall perform the cleanup or remediation to the satisfaction of the authorized officer and at no expense to the United States. Upon revocation or termination of this permit, the holder shall deliver the site to the Forest Service free and clear of contamination.
I. CERTIFICATIONUPON REVOCATIONOR TERMINATION.Ifthe holder uses or stores hazardous materials at the site, upon revocation or termination of this permit the holder shall provide the Forest Service with a report certified by a professional or professionals acceptable to the Forest Service that the permit area is uncontaminated by the presence of hazardous materials and that there has not been a release or discharge of hazardous materials upon the permit area, into surface water at or near the permit area, or into groundwater below the permit area during the term of the permit. This ertification requirement may be waived by the authorized officer when the Forest Service determines that the risks posed by the hazardous material are minimal. Ifa release or discharge has occurred, the professional or professionals shall ocument and certify that the release or discharge has been fully remediated and that the permit area is in compliance vith all federal, state, and local laws and regulations.
Il. LANDUSE FEE AND ACCOUNTING ISSUES
. LANDUSE FEES. The use or occupancy authorized by this permit is exempt from a land use fee or the land use fee has been waived in full pursuant to 36 CFR 251.57 and Forest Service Handbook 2709.11, Chapter 30. fII. REVOCATION. SUSPENSION, AND TERMINATION
. REVOCATION AND SUSPENSION. The authorized officer may revoke or suspend this permit in whole or in part:
1. For noncompliance with federal, state, or local law.
2. For noncompliance with the terms of this permit. 7 3. For abandonment or other failure of the holder to exercise the privileges granted.
4. With the consent of the holder. . .• ‘N .. 5 For specific and compelling reasons in the public interest
Prior to revocation or suspension, other than immediate suspension under clause Vl.B, the authorized officer shall give he holder written notice of the grounds for revocation or suspension. In the case of revocation or suspension based on lause Vll.A.1, 2, or 3, the authorized officer shall give the holder a reasonable time, typically not to exceed 90 days, to ure any noncompliance.
B. IMMEDIATE SUSPENSION. The authorized officer may immediately suspend this permit in whole or in part when necessary to protect public health or safety or the environment. The suspension decision shall be in writing. The holder may request an on-site review with the authorized officers supervisor of the adverse conditions prompting the suspension. Fhe authorized officer’s supervisor shall grant this request within 48 hours. Following the on-site review, the authorized officer’s supervisor shall promptly affirm, modify, or cancel the suspension.
C. APPEALS AND REMEDIES. Written decisions by the authorized officer relating to administration of this permit are ubject to administrative appeal pursuant to 36 CFR Part 214 as amended. Revocation or suspension of this permit shall not give rise to any claim for damages by the holder against the Forest Service.
0. TERMINATION.This permit shall terminate when by its terms a fixed or agreed upon condition, event, or time occurs vithout any action by the authorized officer. Examples include but are not limitedto expiration of the permit by its terms on a specified date and termination upon change of control of the business entity. Termination of this permit shall not require notice, a decision document, or any environmental analysis or other documentation. Termination of this permit is not subject to administrative appeal and shall not give rise to any claim for damages by the holder against the Forest Service.
E. RIGHTS AND RESPONSIBILITIES UPON REVOCATION OR TERMINATIONWITHOUT RENEWAL. Upon revocation or termination of this permit without renewal of the authorized use, the holder shall remove all structures and mprovements, except those owned by the United States, within a reasonable period prescribed by the authorized officer -md shall restore the site to the satisfaction of the authorized officer. Ifthe holder fails to remove all structures and mprovements within the prescribed period, they shall become the property of the United States and may be sold, Iestroyed, or otherwise disposed of without any liabilityto the United States. However, the holder shall remain liable for all :osts associated with their removal, including costs of sale and impoundment, cleanup, and restoration of the site.
(III.MISCELLANEOUS PROVISIONS
A. MEMBERS OF CONGRESS. No member of or delegate to Congress or resident commissioner shall benefit from this permit either directly or indirectly, except to the extent the authorized use provides a general benefit to a corporation.
B. CURRENT ADDRESSES. The holder and the Forest Service shall keep each other informed of current mailing ddresses, including those necessary for billingand payment of land use fees.
. SUPERSEDED PERMIT. This permit supersedes a special use permit designated WYOMING,STATE OF, GAME ND FISH COMMISSION, JAC100231, dated 12/23/2013.
D. SUPERIOR CLAUSES. Ifthere is a conflict between any of the preceding printed clauses and any of the following lauses, the preceding printed clauses shall control.
E. Grizzly Bear Protection (R4-D5). This special use authorization includes land which is part of the habitat of the grizzly bear. Therefore, in compliance with Forest Service responsibilities under the Endangered Species Act of 1973, 16 U.S.C. 1531, the following conditions apply to this special use authorization:
‘3. The Forest Service Authorized Officer may order an immediate temporary suspension of all human activities permitted by this authorization and, if needed, revoke the special use authorization when, in his/her judgment, such action is necessary in order to prevent confrontation or conflict between humans and grizzly bears. The holder shall immediately omply with such order. The United States shall not be liable for any consequences from such a suspension or revocation. Suspension or revocation, may be appealed to the next higher level, as provided in Secretary of Agriculture Regulations. 0
The holder, his/her agents, employees, contractors, and subcontractors willcomply with the requirements of the attached Grizzly Bear Management and Protection Plan dated current in the conduct of any and all activities authorized. TheForest Service Authorized Officer may review and revise the plan as needed.
The holder assumes full responsibility and shall hold the United States harmless from any and all claims by him/her or by third parties for any damages to life or property arising from the activities authorized by this special use authorization nd encounters with grizzly bears, or from suspension or revocation of activities authorized by this special use authorization.
I. Intentional or negligent acts by the holder, his/her agents, employees, contractors, and subcontractors that result in njury or death of a grizzly bear willbe cause for revocation of this authorization in whole or in part.
Failure to comply with provisions a, b, or c may result in suspension or revocation, of this authorization in whole or in art, and may cause criminal action to be taken against the holder under provisions of the Endangered Species Actof 1973, as amended, or other applicable authority.
TheGrizzlyBear Management and Protection Plan provided for in paragraph b above will,as a minimum,address the ollowing:
i. Camp locations and period of time each location is to be used. ii.Areas to avoid or enter, by type of activities, schedule. iii.Seasonal or other human activitylimitations. iv. Livestock and Pets: 1) by location;2) numbers: 3) types (horses, dogs, and so forth);and 4) treatment of carcasses. v. Food Storage: 1) livestock and pets; and 2) human. vi. Food preparation and cleanup. vii.Garbage and Refuse Disposal: 1) livestock and pets; and 2) human. viii.Storage of game meat, ifapplicable. ix.Suggestions for minimizingdirect conflict. x. Human safety.
F. Ground Surface Protection and Restoration (D-9).. The holder shall prevent and control soil erosion and gullying on National Forest System lands in and adjacent to the permit area resulting from construction, operation, maintenance, and ermination of the authorized use. The holder shall construct authorized improvements so as to avoid accumulation of xcessive amounts of water in the permit area and encroachment on streams. The holder shall revegetate or otherwise ;tabilize (for example, by constructing a retaining wall) all ground where the soil has been exposed as a result of the iolder’s construction, maintenance, operation, or termination of the authorized use.
G. Noxious Weed and Exotic Plant Prevention and Control (D-1O).The holder shall be responsible for the prevention and control of noxious weeds and exotic plants arising from the authorized use. For purposes of this clause, noxious eeds and exotic plants include those species recognized as such by the Bridger-Teton National Forest. The holder shall ollow prevention and control measures required by the Bridger-Teton National Forest. When determined to be necessary by the authorized officer, the holder shall develop a plan for noxious weed and exotic plant prevention and control. These plans must have prior written approval from the authorized officer and, upon approval, shall be attached to this permit as n appendix.
1. Herbicide and Pesticide Use (D-18). Herbicides and pesticides may not be used outside of buildings to control undesirable woody and herbaceous vegetation, aquatic plants, insects, rodents, or fish without the prior written approval )f the authorized officer. A request for approval of planned uses of pesticides shall be submitted annually by the holder on he due date established by the authorized officer. The report shall cover a 12-month period of planned use beginning 3 months after the reporting date. Information essential for review shall be provided in the form specified. Exceptions to this schedule may be allowed, subject to emergency request and approval, only when unexpected outbreaks of pests require ontrol measures which were not anticipated at the time an annual report was submitted. Only those materials registered by the U.S. Environmental Protection Agency for the specific purpoe planned shall be authorized for use on National Forest System lands. Label instructions and all applicable laws and regulations shall be strictly followed in the application of pesticides and disposal of excess materials and containers.
• Water Facilities and Water Rights (D-24).
1. Water Facilities. No ditch, reservoir, well, spring, seepage, or other facility to pump, divert, store, or convey water hereinafter “water facilities”) for which the Dointof diversion, storaae. or withdrawal is on National Forest System lands may be initiated, developed, certified, or adjudicated by the holder unless expressly authorized in this permit. The 3uthorization of any water facilities in the permit area is granted to allow use of water only in connection with the recreation residence, resort, marina, or other use] authorized by this permit. Ifthe use of any water facilities in connection withthis [recreation residence, resort, marina, or other use] ceases, the authorization to use any associated water facilities also ceases. The United States may place conditions on installation, operation, maintenance, and removal of water acilities that are necessary to protect public property, public safety, and natural resources on National Forest System lands in compliance with applicable law. Any change in a water facility, including a change in the ownership or beneficial use of water or location of use of water from a water facility, that is not expressly authorized in this permit shall result in ermination of the authorization for that water facility.
2. Water Rights. This permit does not confer any water rights on the holder. The term “water rights” includes all ‘authorizations, such as certificates, reservations, decrees, or permits, for water use issued under state, local, or other law and all water rights otherwise recognized under state law. Any necessary water rights must be acquired and maintained by the holder in accordance with State law and the terms of this permit. After this permit is issued, all water rights obtained by the holder for facilities that divert or pump water from sources located on National Forest System lands for use on National Forest System lands, whether authorized or unauthorized, are for the benefit of the United States and shall be icquired in the name of the United States. Any expenses for acquiring water rights shall be the responsibility of the holder nd not the responsibility of the United States. THISPERMIT IS ACCEPTED SUBJECT TO ALL ITS TERMS AND CONDITIONS.
BEFORE ANY PERMIT IS ISSUED TO AN ENTITY,DOCUMENTATIONMUST BE PROVIDED TO THE AUTHORIZED OFFICER OF THE AUTHORITYOF THE SIGNATORY FOR THE ENTITYTO BIND IT TO THE TERMS AND DONDITIONSOF THE PERMIT.
CCEPTED:
JOHN KENNEDY. Deputy Directo HOLDER NAME SI NATURE DATE
PPROVED:
KATHRYNJ. CONANT, Acting Forest Supervisor \‘* -J “ NAMEAND TITLE OF AUTHORIZED OFFICER SIGNATURE DATE
ccording to the Paperwork Reduction Act of 1995, an agency may not conduct or sponsor, and a person is not required o respond to a collection of information unless it displays a valid 0MB control number. The valid 0MB control number for his information collection is 0596-0082. The time required to complete this information collection is estimated to average one hour per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information.
Ihe U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, olor, national origin, gender, religion, age, disability, political beliefs, sexual orientation, and marital or family status. (Not 311prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of rogram information (Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at 202-720-2600 (voice and TDD). lo file a complaint of discrimination, write USDA, Director, Office of Civil Rights, 1400 Independence Avenue, SW, Nashington, DC 20250-9410 or call (800) 975-3272 (voice) or (202) 720-6382 (TDD). USDA is an equal opportunity provider and employer
The Privacy Act of 1974(5 U.S.C. 552a) and the Freedom of Information Act (5 U.S.C. 552) govern the confidentiality to e provided for information received by the Forest Service. Alkali Ci qround
Appendix A
Permittee: WYGF Permit #: iAC100232
Legend
AIkaHCreek Feedground 7/Y/ Gros Ventre Wilderness Alkali Feedground Wetlands and Infrared Imagery Permittee: WYGF Permit #: JAC100232
0 L.-.
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Appendix 7 Tyler Johnson June 2014 Abstract
Chronic wasting disease is an invariably fatal prion disease of cervids. There has been a recent increase in studies regarding the transmission and impacts of CWD in free-ranging and artificially contained elk and deer. Research indicates that CWD is easily transmitted between and among cervid species, can contaminate the environment and subsequently infect new individuals, and can impact cervid populations. Population level impacts have been noted in free-ranging elk and deer after a time lag. Such population level impacts arise from alterations in reproduction rates, increases in individual mortality from CWD, and increased susceptibility to other agents of mortality. CWD is lethal across all age groups. Management options for controlling CWD arrival and spread are very limited, and a review of relevant literature indicates that congregating elk at very high densities at feedgrounds is likely to increase the spread of the disease because of an increased number and rate of potentially infectious contacts with infected individuals and an infected environment.
Introduction
Chronic wasting disease (hereafter CWD) is an incurable, invariably fatal neurological disease of cervids (deer, elk, and their relatives) caused by a misfolded version (PrPCWD) of the normal prion protein (PrP). PrPCWD are believed to propagate by inducing the formation of more PrpCWD from PrP. The abnormal or misfolded form of the prion protein converts the normal prion protein into the infectious form. During the 19-40 month course of CWD the prions cause lesions in central nervous system (CNS) tissues thereby producing visible behavioral and physiological alterations in the last months before death from CWD.
CWD is highly transmissible via multiple direct and indirect pathways between and among cervid species. Infected animals can directly infect nearby animals by contaminated nasal or oral secretions. Additionally, prions that are shed into the environment from infected animals in bodily fluids and soft tissues before and after death can infect other animals well after the infected animal has moved or died. It is likely that an animal infected with CWD would have been exposed to the infectious agent through more than one pathway. CWD can persist in the environment well after the infected animal has died. In this way, CWD differs from most other wildlife diseases in that environmental transmission plays an important role in the dynamics of the disease, something that isn’t common for bacterial or viral diseases, which tend not to persist in the environment.
The typical course of CWD from infection to death in elk involves 2 stages, incubation and clinical (Argue et al. 2007, Figure 1 below). During the incubation stage the animal appears to be behaviorally and physiologically normal, once the animal becomes visibly affected the clinical stage begins. The change in behavior is associated with physiological changes in the CNS of the animal, most notably the
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Tyler Johnson June 2014 brain. The length of the incubation stage can vary from 20-36 months based on the genetics of the infected elk (Hamir et al. 2006) and the exposure dose. Published and unpublished data indicates that depending on the genetics of an infected elk the incubation period can last for years or be very short (Williams et al. 2014 and reference therein). The incubation period is broken into two parts. During the latent period the animal is acting normally and is not shedding prions. At some point, typically around 6 months prior to clinical onset, the animal begins to shed prions in saliva, nasal mucous, urine, feces, and milk (Argue et al. 2007, Saunders et al. 2012). Prions shed in this manner are able to infect both nearby animals and the environment. Some animals perish as soon as the clinical stage begins, while others last for 12 or more months before death (Miller et al. 1998). It is possible for an infected animal to die from CWD infection alone. However, CWD infections that have become clinical have been shown to increase an animal’s susceptibility to other agents of mortality including those from predators (Miller et al. 2008, Krumm et al. 2009), vehicle collisions(Krumm et al. 2005), stochastic events (extreme weather and inability to find food)(Williams 2005), and other diseases. Animals that are in the clinical phase are still shedding prions. During the clinical phase prions also accumulate in muscle, CNS, and other soft tissues (including skin and antler velvet) (Saunders et al. 2012). After a clinical or preclinical CWD infected animal dies the carcass can be a significant source of prion infection to other animals and can contaminate the environment for many years (Miller et al. 2004) (see discussion of environmental transmission below).
Figure 1 from Argue et al. 2007. Proposed progress of CWD in farmed elk
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Tyler Johnson June 2014 CWD has been discovered in wild cervids in 19 U.S. States and 2 Canadian provinces, and exists in captive cervids in the US, Canada and South Korea (CWD-info.org). CWD is thought to have arisen in northern Colorado and spread to Wyoming, South Dakota, Nebraska, Kansas, and Utah. The movement of game farmed and hunter killed animals is thought to have introduced the disease to areas that are now satellite infection areas in New Mexico and Texas, Wisconsin and Illinois, Alberta and Saskatchewan, and the Northeast (Figure 2). The number of states and provinces where CWD is known has increased over time, even though funding for surveillance has decreased in recent years, indicating that the disease is spreading, albeit relatively slowly.
Figure 2 From CWD-info.org
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Tyler Johnson June 2014 Horizontal Transmission
Horizontal transmission of CWD is a highly efficient means of disease transmission between and among elk and deer (Miller and Williams 2003, Sigurdson and Aguzzi 2007). Maternal transmission (from mother to offspring via a reproductive interchange (being in the womb, birthing fluid, milk etc.)) is possible, but appears to be much less important than horizontal transmission from mother to offspring (Miller et al. 2004). Studies indicate that elk of both sexes spend a considerable amount of time within one body length of each other in the wild and in artificial environments. Such proximity likely exposes animals to horizontal transmission of disease from oral and nasal secretions (Mathiason et al. 2006), particularly where animals are artificially congregated and their contact rates increase significantly (Cross et al. 2013, Creech et al. 2012).
Environmental Transmission
CWD can be transmitted solely by environmental contamination (Miller et al. 2004, Mathiason et al. 2009, Williams et al. 2014) and this likely helps explain the spread and maintenance of disease (Gough and Maddison 2010). Several studies have demonstrated actual environmental transmission from decomposed carcasses and fecal material (Miller et al. 2004), as well as saliva, blood, and inanimate objects like feed buckets, bedding, and water (Mathiason et al. 2006, 2009). Suspected sources of environmental contamination with subsequent transmission include bodily fluids at elk wallow sites and mineral licks (VerCauteren et al. 2007), and the presence of CWD in soft tissues, blood, skin, antler velvet (though not the antlers themselves), urine, milk, nasal secretions, saliva, and placenta (Gough and Maddison 2010, Saunders et al. 2012). Annual antler velvet shedding represents an instance where potentially infected soft tissue is shed while the animal is still alive. Most other instances of potentially infected soft tissue contaminating the environment arise from the death of the animal. It has been estimated that the amount of CWD prion shed during the progression of the disease and the amount contained in a carcass of an animal killed by CWD is roughly the same because CWD prions become systemic and are concentrated in the CNS and muscle tissues as the disease progresses (Saunders et al. 2012). As a result, carcasses represent a large source of prions to the surrounding environment. Decomposing carcasses often induce a flush of vegetative growth, which may attract susceptible cervids. Because CWD remains infectious for at least 2 years in the environment (Miller et al. 2004) and possibly quite a bit longer (Georgsson et al. 2006) the presence of carcasses and their attractiveness may result in environmental transmission of CWD.
Carcasses in the environment also attract scavengers (Jenelle et al. 2009a). Research has demonstrated that scrapie, a prion disease of sheep and goats similar to CWD, can remain infectious after
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Tyler Johnson June 2014 passage through avian digestive systems (VerCauteren et al. 2012) and that CWD is likely infectious after avian passage and the dispersal of CWD prions in avian feces may in some way facilitate the spread of the disease (Fischer et al. 2013). Prions are likely to be denatured to a large degree in the digestive tract of mammalian scavengers (Jeffrey et al. 2006 - scrapie study) and CWD prions consumed by mammalian scavengers do not result in infection of the scavenger (Jenelle et al. 2009b). Plants may uptake the prions into their plant structure, but evidence for this is only circumstantial at this point (mid-2014) and has not yet been published, this is different than prions simply existing on plants (Gough and Maddison 2010) and may represent yet another source of environmental contamination.
The importance of environmental transmission in the spread, persistence, and impact of CWD infection in deer and elk has been suggested in numerous modelling studies (Miller et al. 2006, Almburg et al. 2011, O’Hara Ruiz et al. 2013, Storm et al. 2013, Jenelle et al. 2014). Specifically, work by Almburg et al. 2011 showed that the longer that CWD is infectious in the environment the more influential it becomes on disease prevalence and transmission, owing to an increased pool of environmental sources of infection over time. The fact that the infectious agents of CWD likely outlive their hosts in the environment indicates that the distribution, concentration, and infectivity of CWD in the environment will play an important role in the ultimate course that CWD takes in quasi-free ranging elk in western Wyoming.
Elk congregate naturally on winter range and wallows, and artificially at feedgrounds in Wyoming. Should CWD arrive, the areas where elk naturally and artificially congregate could become continuous sources of disease transmission from animal to environment and back to animal. The environmental pool of infectious prions would thus likely increase with time with repeated use at such locations because prions persist in the environment and are essentially impossible to remove from areas where infected animals have lived.
Disease Transmission
In the early stages of a disease outbreak, the density of infectious and susceptible individuals drives the course of the disease. Owing to highly efficient direct transmission of CWD among cervids the number, duration, and frequency with which infectious individuals encounter susceptible ones is likely to drive early density dependent transmission of CWD. Several studies have examined how coarse and fine scale elk behaviors change with increasing population density. These studies and have shown that in general, elk in higher density populations contact other elk more frequently and for longer durations, although there are some differences in how males and females respond to higher densities.
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Tyler Johnson June 2014 As elk population density increases the average group size increases but the mechanism of those increases differs between females and males, where females aggregate into larger groups that are more dispersed from other groups, while males cease to be solitary and form small groups (VanderWal et al. 2013a). Additional research has shown that as population density increases the frequency and duration of contacts between individuals and gender groups increases, but does so differently for females vs. males. VanderWal et al. 2012 showed that as population density increases the interaction rate of males increases, but the duration of those interactions decreases. The same study found that both the rate and duration of female interactions increases with increasing density, but both saturate at moderate population density. This is because female elk tend to form small familiar groups of at least 5 individuals within the larger group and that most contacts occurred within that small group, a finding supported by VanderWal et al. 2013a, 2013b, 2014. At higher population density the overlap of individual female elk home range is greater than for lower population density. As the overlap of home ranges increase so does the rate of interactions, such that there are more interactions at higher density, this relationship does however, saturate at high range overlap. The frequency and duration of within- and among-sex interactions not only changes with population density but also with season. Female-female dyads interact 4 times more frequently than male-male dyads do, but male-male dyads interact for 1.5times longer than female-female dyads (VanderWal 2013b). The frequency and duration of interactions was higher for all groups in winter and lowest in summer. Cross et al. 2013 demonstrated that in areas where elk are artificially congregated at feedgrounds per capita rates of contact and duration of contact were more than twice as high as groups not receiving supplemental feed. The same study showed that supplemental feeding can increase contact rates beyond that which a larger group size will incur on its own.
The role that artificially congregating elk at feedgrounds will play in the arrival of CWD is unclear. On one hand, elk feedgrounds attract elk from large catchments and congregate elk that might not otherwise contact each other, thereby increasing the chance that an infected elk from a distant locale would be the one to introduce the disease to a new herd area. On the other hand, most elk feedgrounds are strategically placed on the landscape to interrupt migration corridors (the purpose of feedgrounds is to spatially confine the elk so that private hay and cattle do not contact elk). And as such, serve to isolate herds from each other, thereby possibly limiting inter-herd transmission of CWD. There has been no research that has addressed this issue. As a result, it is unknown if the presence of one or many feedgrounds will alter the arrival of CWD.
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Tyler Johnson June 2014 Prevalence and population level impacts
Studies on naturally occurring populations of elk have shown that mortality from chronic wasting disease by itself can exceed natural rates of mortality and reduce the overall survival of free roaming cow elk below 85% (Monello et al. 2014). Raithel et al. 2007 showed that cow elk survival less than 85% induced herd declines in most elk populations in North America. In addition, CWD mortality has been associated with a reduction in survival rates, alteration of reproductive success (Dulberger et al. 2010), and a stagnation in population growth (Sargent et al. 2011, Monello et al. 2014). CWD can also compound other agents of mortality by increasing the susceptibility of infected elk and deer to vehicle collisions (Krumm et al. 2005), predation (Miller et al. 2008, Krumm et al. 2009, Sargeant et al. 2011), and stochastic mortality (severe weather and other random events Williams 2005). Studies conducted on free-ranging elk populations indicate a time-lag between introduction of CWD and population level impact of between 10 (Sargeant et al. 2011) and 25 years (Monello et al. 2014) is possible. This time lag is likely due to the extended incubation period where diseased elk are still able to reproduce, while the disease prevalence builds in the population. Modelling studies indicate that genetics may influence the length of the incubation period and play a role in the progress and ultimate outcome of the disease, but field based studies have yet to show such influence (discussed in Williams et al. 2014). Field based studies have indicated that population level impacts can happen at prevalence levels from 5-13% ((Miller et al. 2000 (deer), (Monello et al. 2014 (elk)), depending on reproductive success and the importance of other agents of mortality in the population.
Taken together, studies on free-ranging and farmed elk and deer are clear in showing that population level impacts are to be expected from the introduction and spread of CWD in elk on the Bridger-Teton National Forest and nearby areas. What is less clear is the role that artificial grouping of elk at feedgrounds, the influence of predators, and the difference in sex-specificity and genotypes (in terms of prevalence and mortality) will play in the spread and impact of the disease in elk in western Wyoming. Indeed a modelling study by Williams et al. 2014 showed that mortality from CWD and hunting could act in concert to impact elk populations in western Wyoming, but that the genetic makeup of that herd could moderate those effects.
The impact of wolves on CWD dynamics has only been explored in modelling exercises based on data from a National Park that is absent of wolves (Wild et al. 2011, Hobbs 2006), and as such the role that wolves will play is largely unexplored. What is known is that presence of wolves influences elk behavior, and some generalizations can be made about the impact that those changes in behavior might have on disease transmission. At the landscape scale, the presence of wolves can simultaneously decrease
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Tyler Johnson June 2014 population densities (by removing individuals) and increase herd densities and group sizes (Hebblewhite and Pletscher 2002, White et al. 2012), since the presence of wolves tends to turn small groups of elk into large herds or move elk from one habitat to another (White et al. 2012). Other studies have shown that there is no change in group size (Creel and Winnie 2005) or that changes in elk behavior are habitat- specific (Proffitt et al. 2009). Research on free ranging elk without wolf pressure has shown that elk in larger groups tend to have higher rates of contact and that contact lasts longer.
It has been shown that deer killed by mountain lions have a higher CWD prevalence than non-killed deer, suggesting that lions select for CWD affected deer. It stands to reason that mountain lions would similarly select for affected elk and that an elk clinically affected by CWD would be targeted by wolves. Typically, wolves target young and old elk from herds. It remains to be seen if this pattern holds for CWD affected elk or if wolves will take prime aged elk that have CWD. This is important for population level impacts because CWD kills across age groups and prevelance tends to be highest in prime breeding age (3-8 year old) and the age selection of wolves could amplify this.
When a new agent of mortality is introduced into an ecosystem the resulting mortality for a wildlife population can be additive to other sources of death, or can compensate for them. Additive mortality occurs when the new agent increases the total number or rate of mortality. Compensatory mortality does not increase the total number or rate of mortality because it replaces an existing cause of mortality. New sources of mortality may be completely compensatory, or may also be partially compensatory to existing sources of death.
Herd densities
Because so much of the literature and discussion about the arrival, spread, and impact of wildlife disease focuses on the density of the herds in question it is worth noting how congregating elk at feedgrounds alters the herd density. As previously discussed, research has shown that in general as herd densities increase, the frequency and duration of potentially infectious contacts (with infected individuals and infected environment) also increases. Free-ranging elk herds in Wyoming (Cross et al. 2013, Williams et al. 2014) and Canada (Vander Wal et al. 2013, 2014) have herd densities ranging from .21 to 1.2 elk/km2 (Table 1). Elk at Wind Cave National Park have densities between 2.1 and 7.1 elk/km2 and elk at Rocky Mountain National Park have densities between 15 and 100 elk/km2. Elk at the National Elk Refuge in Jackson average 59.3 elk/km2 (6000 elk on 25000 acres). Elk density at the average state feedground in Wyoming is 1976.6 elk/km2, based on the reported average of 600 elk on 75 acres.
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Tyler Johnson June 2014 These elk herds can of course have much higher densities when they are congregated on winter range, feeding lines, or at natural bottle-necks. For instance, elk in the western part of Wyoming average densities of .26 to .31 elk/km2 when considered at the herd unit scale, which includes 3 feedgrounds (Williams et al. 2014). However, that same herd can reach densities of 25,300 to 238,000 elk/km2 when the elk are feeding on the feedlines (derived from proximity logging collars in a herd of 550-650 elk at one feedground) (Creech et al. 2012). Population level impacts have been documented in both the Wind Cave and Rocky Mountain National Park elk herds which have lower densities than are present at the feedgrounds in Wyoming.
Summary
The role that CWD has played in population level impacts to free ranging elk populations has been demonstrated in the literature and it stands to reason that similar impacts will be expected when CWD arrives in the proximity of the Bridger-Teton National Forest. There are many unknowns with regard to how disease progress will translate to population impact in western Wyoming, especially with an active predator guild, the presence of feedgrounds, rate of human harvest, the genetic makeup of the herds, and reproductive rates of elk. The onset and potential rate of spread of CWD in western Wyoming is similarly unknown. What is certain is that political, economic, and ecological conditions will change continuously once the disease is detected.
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Tyler Johnson June 2014
Table 1 Reported or derived density of study or feedground elk herds
Author / Year Density (elk / km2) Study Type Cross et al. 2013 .21 - .28 Wyoming Free Range Vander Wal et al. 2014 .22 - .42 Canada Free Range Williams et al. 2014 .26 - .31 Wyoming Free Range Vander Wal et al. 2013 .67 - 1.2 Canada Free Range Sargeant et al. 2011 2.1 - 7.1 Quasi-natural population Wind Cave NP (fenced) Monello et al. 2014 15 - 100 Natural Population Rocky Mtn NP National Elk Refuge 59.3 Very Large Feedground (6000 elk on 25000 ac) Vander Wal et al. 2012 71 - 149 Experimental in Large Cages WY State Feed Grounds 1976.8 Based on reported average of 600 elk on 75 acres Creech et al. 2012 25,300 - 238,000 Wyoming at Soda Lake Feed Ground
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Miller, Michael W., et al. "Lions and prions and deer demise." PLoS one 3.12 (2008): e4019.
Monello, Ryan J., et al. "Survival and population growth of a free‐ranging elk population with a long history of exposure to chronic wasting disease." The Journal of Wildlife Management 78.2 (2014): 214-223.
O’Hara Ruiz et al. “Influence of landscape factors and management decisions on spatial and temporal patterns of the transmission of chronic wasting disease in white-tailed deer.” Geospatial Health (2013):215-227
Proffitt, Kelly M., et al. "Contrasting effects of wolves and human hunters on elk behavioral responses to predation risk." The Journal of Wildlife Management73.3 (2009): 345-356.
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Raithel, Jarod D., et al. "Impact of spatial and temporal variation in calf survival on the growth of elk populations."The Journal of wildlife management 71.3 (2007): 795-803.
Sargeant, Glen A., et al. "Implications of chronic wasting disease, cougar predation, and reduced recruitment for elk management." The Journal of Wildlife Management 75.1 (2011): 171-177.
Saunders, Samuel E., et al. "Occurrence, transmission, and zoonotic potential of chronic wasting disease."Emerg Infect Dis 18.3 (2012): 369-376.
Sigurdson, Christina J., and Adriano Aguzzi. "Chronic wasting disease."Biochimica et Biophysica Acta (BBA)- Molecular Basis of Disease 1772.6 (2007): 610-618.
Storm, Daniel J., et al. "Deer density and disease prevalence influence transmission of chronic wasting disease in white-tailed deer." Ecosphere 4.1 (2013): art10.
Vander Wal, Eric, Michel P. Laforge, and Philip D. McLoughlin. "Density dependence in social behaviour: home range overlap and density interacts to affect conspecific encounter rates in a gregarious ungulate." Behavioral Ecology and Sociobiology (2013): 1-8.
Vander Wal, E., et al. "Effects of phenology and sex on social proximity in a gregarious ungulate." Canadian Journal of Zoology 91.9 (2013): 601-609.
Vander Wal, E., et al. "Density-dependent effects on group size are sex-specific in a gregarious ungulate."PloS one 8.1 (2013): e53777.
Vander Wal, E., et al. "Sex-based differences in density-dependent sociality: an experiment with a gregarious ungulate."Ecology 93.1 (2012): 206-212.
VerCauteren, Kurt C., et al. "Elk use of wallows and potential chronic wasting disease transmission." (2007).
VerCauteren, Kurt C., et al. "Prion remains infectious after passage through digestive system of American crows (Corvus brachyrhynchos)." PloS one 7.10 (2012): e45774.
White, P. J., et al. "Changes in elk distribution and group sizes after wolf restoration." The American Midland Naturalist 167.1 (2012): 174-187.
Wild, Margaret A., et al. "The role of predation in disease control: a comparison of selective and nonselective removal on prion disease dynamics in deer."Journal of Wildlife Diseases 47.1 (2011): 78-93.
Williams, E. S. "Chronic wasting disease." Veterinary Pathology Online 42.5 (2005): 530-549.
Williams, A. L., T. J. Kreeger, and B. A. Schumaker. "Chronic wasting disease model of genetic selection favoring prolonged survival in Rocky Mountain elk (Cervus elaphus)." Ecosphere 5.5 (2014)
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Appendix 8 Response to Comments
Response to Comments on the Draft Supplemental EIS for WGFD’s Winter Elk Management Activities at Alkali Creek Feedground
Table of Contents New Mitigation Measures or Other Alternatives...... 1 Vegetation ...... 8 Wetlands and Riparian Areas ...... 15 Wilderness/Wild and Scenic Rivers ...... 20 Grazing ...... 20 Fish ...... 26 Soils ...... 28 Errors ...... 28 Planning Process/Forest Plan ...... 29 Climate Change ...... 45 Wildlife ...... 46 Disease ...... 71 Support for Alternative 1 – No Action ...... 115 Support for Alternative 2 – Proposed Action ...... 151
Due to last minute format changes in the FSEIS, page numbers in this appendix referring to changes in the FSEIS are approximate. New Mitigation Measures or Other Alternatives 1. Comment: Alkali Creek is a sweet little drainage with habitat for amphibians and songbirds. It would be ideal for a habitat protection project such as partial fencing. Response: Fencing would alleviate the localized impact of cross-country trailing and herbivory by elk and other ungulates along Alkali Creek, a stream located near the feedground, and improve habitat for amphibians and songbirds. However, it would also create environmental impacts. It would be difficult and costly to construct and maintain such a fence, and the impacts of the animal migration would merely be shifted upstream or downstream of the fenced area. Animals would also trail along the fence, creating new impacts wherever the fence line was located. Permanent fencing would preclude use by pronghorn and mule deer that water along Alkali Creek during the non-winter season; a "let-down" fence would be needed to accommodate these animals for non-winter use but would still preclude use of the enclosed habitat by moose and other large mammals during the winter. In short, fencing would move existing ungulate impacts to a new location, affect other species, or create new impacts where none currently exist.
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Response to Comments
A Multiple Indicator Monitoring survey along Alkali Creek in 2013 indicated that adequate cover is present for amphibian habitat during the spring/summer period. No amphibians have been found in Alkali Creek. However, they are present in adjacent drainages and it is likely they use the area in the summer. While trailing, trampling, and grazing impacts may locally affect individual amphibians, this is not expected to contribute towards loss of population viability (pages 77-79, FSEIS).
2. Comment: Under either alternative, measures could be included to protect what willow remains – keeping up the fence around the spring and providing some rehab (physically protected) areas in the wetlands within the feedground. Response: Forest Service resource specialists noted in June 2013 that the previous year's growth on willows and roses in the feedground was heavily browsed. There is no recruitment of new shrubs. This occurred despite the 100-foot feeding buffer around the wetlands. Although browsing on willows and roses has been heavy, the specialists expect the shrubs can tolerate such browsing and still maintain themselves. Most of the shrubs in and around the feedground have the architecture of heavily browsed shrubs (i.e. diminished stature and leaves grown inside a protective skeleton of dead branches), and are presently persisting but not reproducing. The fence around the spring is in good condition. If approved, the new permit for Alkali Creek Feedground would include a requirement to maintain the fence. Physical protection for wetlands within the permit area is not planned, however, feeding would not be authorized to take place on the mapped wetland areas or within 100 feet from the outer edge of the wetlands and the channel that connects them. This requirement is stated in the description of Alternative 2 in Chapter 2 of the FSEIS (page 16).
3. Comment: It is incorrect to state that elk feedgrounds "have become an effective tool in reducing damage to haystack yards and winter pastures on private lands," (DSEIS: 2), and "feedgrounds have been very effective in preventing elk depredating private crops," (Ibid: 5) The first statement (and perhaps the second since it follows a few pages later) is attributed to the WGFD 2007 report, but it is incorrect for the Gros Ventre Valley and probably elsewhere. Numerous elk have wintered away from the elk feedgrounds in the Gros Ventre Valley over the years and, because there are still a few private lands locations where hay is spread out for horses and cattle each winter's day and there are not elk-proof fences, free-ranging elk chronically come into the winter livestock feeding lines. The WGFD is repeatedly called out to address the conflict using a variety of labor intensive methods (e.g., repeated hazing with snowmachines and cracker shell guns), but the agencies and landowner still have not erected elk-proof fences around livestock feedlines which would, indeed, solve the comingling and damage problems. Just as livestock owners have done throughout the Rocky Mountains where elk free range. Despite the feedgrounds in the Gros Ventre Valley there are still these issues of damage and conflicts with area livestock. The BTNF has not done any analysis to determine whether there are fewer or more conflicts as a result of elk feedgrounds, nor whether a certain number of comingling events are better from a disease transmission risk than more or less than that number, therefore these statements are incorrect. Response: The Wyoming Game and Fish Department has successfully used elk feedgrounds to prevent and/or reduce damage to private property for decades. Please refer to Appendix 2, specifically pages 18-19 for additional information. Constructing elk proof fencing on private property is outside the
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Response to Comments jurisdiction of the U.S. Forest Service. This suggested mitigation action would be at the discretion of individual landowners.
4. Comment: If the desired aquatic resource and vegetative conditions are not achieved through the 100 foot buffer BMP, it may be necessary to consider additional measures such as exclusion of feedground activities where wetlands or riparian areas, including streambanks, remain adversely impacted. Response: Monitoring for effectiveness of the 100-foot buffer near wetlands or riparian areas has been added to the description of the proposed action on page 16 of the FSEIS. The revised text is: 5) Feeding is not authorized to take place on the mapped wetland areas or within 100 feet from the outer edge of the wetlands and the channel that connects them. The Forest Service and WGFD will monitor the condition of the aquatic resources and vegetative conditions within the 100-foot buffer area approximately every 5 years. If the desired conditions are not achieved, appropriate analysis and additional measures will be considered and applied according to the requirements of the National Environmental Policy Act.
5. Comment: The Environmental Protection Agency (EPA) recognizes the challenges facing the USFS in managing wetland resources and streambank conditions on elk feedgrounds, and encourages the use of mitigation to avoid or reduce water resource impacts. To reduce water resource impacts, the USFS has identified and committed to a mitigation measure that restricts distribution of hay for feeding to at least 100 feet from the outer edge of the wetlands and channel that connects the two areas. The Draft SEIS states that although the mitigation measure would reduce direct impacts to the wetlands, and other water resources in the Feedground, indirect impacts would likely continue due to elk congregation and trailing through the area. The EPA supports the minimum 100 foot hay distribution buffer, and encourages the USFS to utilize other available BMPs as management tools to mitigate damage to streambanks and riparian areas when they are most vulnerable to trampling damage (e.g., increased buffer zones for feeding, fencing, etc.). Response: The wetlands are protected by the 100-foot buffer mitigation measure. There are no streambanks or other riparian areas in the project area. Other mitigation measures/Best Management Practices for the proposed action are detailed under the description of Alternative 2 in Chapter 2 of the FSEIS, page 16.
6. Comment: Because the 100-foot buffer may not result in adequate protection or the full restoration of stream and riparian areas to desired conditions, we recommend including additional discussion in the Final SEIS on monitoring and adaptive management for impacts related to aquatic and vegetation resources. Specifically, a monitoring schedule would assure that the effectiveness of the BMP measure will be tracked to inform future decisions. We also suggest that an adaptive management strategy be developed in the Final SEIS to assure additional management action if monitoring does not indicate progress toward the desired conditions of stream health and vegetation. We recommend the Final SEIS identify the features of an effective adaptive management plan, including the following: 1. Decision tree with achievable and measurable objectives to provide accountability and guide future decisions. 2. Specific decision thresholds with identified indicators for each impacted resource. 3. Targets that specify a desired future condition. 4. Firm commitment to implement and fund a monitoring plan with protocols to assess whether thresholds are being met. 5. Firm commitment to use monitoring results to modify
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Response to Comments management strategies such as BMPs as necessary. We also recommend discussion of the general timing of adaptive management implementation and effectiveness monitoring. A firm commitment to effectiveness monitoring is desirable given that adaptive management cannot be employed without the full implementation of its associate monitoring schedule. Response: Feeding would not be authorized to take place within the mapped wetland or within 100 feet from the outer edge of the wetlands and the channel that connects them. This requirement would be specified in the WGFD special use permit. The edge of the wetlands is readily apparent, even in winter. If WGFD foresees that they will not be able to determine the edge of the wetlands or the connecting channel, they must mark the edge of the features or the feeding boundary when the features are visible so they do not violate the mitigation measure. Temporary measures such as posts may be used to mark the boundary. We have added the requirement that the Forest Service Special Use Permit Administrator would conduct an inspection of the feedground annually after snowmelt to see if any hay remnants lie within the 100-foot buffer. Text concerning the timing and frequency of this monitoring has been added to the FSEIS on page 16. Other monitoring timing and frequency are also listed on page 16 of the FSEIS. Annually, monitoring would occur concerning weeds within the permit area and cheatgrass adjacent to the permit area. Throughout each winter feeding season, Forest Service patrollers would monitor the operation for compliance with the Food Storage Special Order. Effectiveness monitoring would occur every five years and consists of Forest Service evaluation of the condition of soils, as described by the Soil Scientist, and an evaluation of the condition of wetland vegetation within the 100-foot buffer area, particularly the condition of palatable shrubs (rose and willow), as determined by the Vegetation Resource Specialist. The Forest Service does not intend to use adaptive management in this decision process. Other measures are in place that allow the Forest Service to regularly review the use of NFS lands for feeding elk at Alkali Creek Feedground. The Operating Plan for the Feedgrounds on the Jackson Ranger District has the following provision which enables the Forest Service to make changes annually as needed to the feedground operation: "The Operating Plan will be reviewed annually, and the amendments to the Operating Plan would document those changes. Changes will be considered which may be necessary to improve the ability of the Permittee to improve feeding operations or for the Forest Service to meet management objectives and direction. If it is determined that changes are needed to the operation that require environmental analysis, additional analysis would be performed and documented according to the National Environmental Policy Act; and consequently, a new decision would be made concerning this Special Use authorization.
7. Comment: The DSEIS is rated as Environmental Concerns - Adequate Information (EC-1). EC: The EPA review has identified environmental impacts that should be avoided in order to fully protect the environment. Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce these impacts. Category 1: Adequate. EPA believes the draft EIS adequately sets forth the environmental impact(s) of the preferred alternative and those of the alternatives reasonably available to the project or action. No further analysis or data collection is necessary, but the reviewer may suggest the addition of clarifying language or information.
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Response to Comments
Response: Thank you for providing your review of the DSEIS. We have made changes to the mitigation measures and monitoring requirements between the draft and final Supplemental EIS's in response to your (Environmental Protection Agency) advice. See our response to your other comments for details about the changes that were made. We look forward to receiving the results of your review of the FSEIS.
8. Comment: Finally, we recommend that extension of the Alkali Creek Feedgrounds be coordinated with other agencies who share management responsibilities for the North Jackson Elk Herd. We recommend that the USFS conduct a review of elk management practices for Alkali Creek every five years with participation by the GTNP, Yellowstone National Park and the NER. This review should attempt to identify changing conditions, threats and corresponding management alternatives that could be used to compliment and support efforts to achieve the goals outlined in the Bison and Elk Management Plan and maintain a healthy, viable North Jackson Elk Herd. Response: The Forest Supervisor considered your recommendation that agency coordination should occur every five years concerning Alkali Creek Feedground management. Please see page 4 of the Draft Record of Decision for his response to your comment. Elk management coordinated efforts have been occurring for many years. In 1958, the Cooperative Elk Studies Group was formed, composed of representatives of the Wyoming Game and Fish Department (WGFD), National Elk Refuge (NER), Bridger Teton National Forest, and Grand Teton National Park (GTNP). All four agencies have legal responsibilities pertaining to the management of the Jackson elk herd. The group meets annually to share information and coordinate management and research of elk. The Jackson Interagency Habitat Initiative (JIHI) was formed during fall 2001 by several wildlife and habitat biologists from the above agencies. The goal of JIHI is to maximize effectiveness of native winter and transitional range for ungulates and a diversity of species indigenous to this region through identification of habitat enhancement opportunities. The group focuses on habitat enhancements in Buffalo Valley and the Gros Ventre River drainage. The Operating Plan for the Feedgrounds on the Jackson Ranger District of the Bridger-Teton has the following provision which enables the BTNF to make changes annually as needed to the feedground operations: The Operating Plan will be reviewed annually, and the amendments to the Operating Plan would document those changes. Changes will be considered which may be necessary to improve the ability of the Permittee to improve feeding operations or for the Forest Service to meet management objectives and direction. Additionally, the Greater Yellowstone Coordinating Committee (GYCC), an interagency committee comprised of the federal land management agencies within the Greater Yellowstone Ecosystem (GYE), which includes the BTNF, NER, Yellowstone National Park, and GTNP, formed a wildlife subcommittee in the fall of 2012. This subcommittee's focus is to work on wildlife issues common to the federal agencies within the GYE. This will give these land management agencies another opportunity to coordinate elk management and respond to changing conditions and threats.
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Response to Comments
9. Comment: Due to population goals and disease concerns, we recommend USFS incorporate conditions in the permit that will 1) reduce long-term reliance on supplemental feed to support wintering elk and 2) incorporate a more coordinated response when CWD is found in the feedground. Elk exchange between these two feedgrounds can also play a role in spreading diseases from one site to another. Elk infected with chronic wasting disease (CWD) have the potential to contaminate a feedground in the long-term with prions, which could transmit the disease to elk using that site in the future. Should either the Alkali Creek Feedground or the NER become contaminated with CWD prions, transportation of this disease or other diseases could occur between feedgrounds and impact wintering elk at both sites. Response: Although the Forest Service has the authority to authorize or not authorize use of NFS lands for the supplemental feeding of elk, incorporating conditions into the permit to reduce reliance on feeding would not be effective because WGFD operates seven other feedgrounds on NFS lands and fourteen other feedgrounds on state, private or other federal lands (FSEIS, page 17). Appendix 3 in the FSEIS is the Wyoming Game and Fish Department (WGFD) Chronic Wasting Disease (CWD) Management Plan. In this plan, WGFD states they intend to coordinate CWD management with other state, federal and tribal agencies. This plan describes actions planned if/when CWD is observed in feedgrounds (pages 5-6). If CWD is detected in elk inhabiting feedgrounds, WGFD will monitor the population intensively and remove any elk showing clinical signs of CWD. WGFD will attempt to 1) maximize the area of feeding to decrease animal-to-animal contact; 2) decrease days of feeding to disperse the elk; and 3) take any other actions to decrease elk concentration provided such actions are consistent with other necessary wildlife management and feedground practices.
10. Comment: A negative to Alternative 1 is the possibility of elk mixing with domestic stock in transmitting brucellosis. This could be mitigated by working with livestock producers in the area to build elk proof fencing. The money saved by closing the feedground could be used to help offset the cost of this fencing and benefit all parties. Response: The Forest Service does not have the authority to erect fences on private land near National Forest lands. As described in the FSEIS (page 17—Alternatives Considered but Eliminated from Detailed Study), we dismissed an alternative that included elk-proof fencing on Forest Service lands that are adjacent to private land in the Gros Ventre Valley. The Forest Service rejected a “fences” alternative, primarily due to its implausibility: (1) this approach would not necessarily preclude the movement of elk to the NER, at least in the absence of installing other large ungulate-proof fences that span the width of the Gros Ventre River corridor, (2) when consulted, several of the key Gros Ventre landowners did not support Forest Service construction of fences around their property because of the difficulty fences often create for managing wintering livestock distribution and human access to federal lands; (3) fencing out Gros Ventre Valley bottomlands would create barriers to free movement by wildlife such as bighorn sheep, mule deer, and moose, and exclude their use of important riparian habitats for foraging and cover; (4) fencing leads to soil erosion and establishment of weeds along new, adjacent foot trails created by livestock and wild ungulates; (5) being unnatural, fences are used advantageously by large predators to kill livestock and wild ungulates, and cause lethal strikes to in-flight birds; (6) installation of elk-proof fencing on National Forest System lands (around private lands and across the Gros Ventre River corridor) would likely be inconsistent with our Forest Plan amendment that prohibits Forest
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Response to Comments
Service activities that impede migration of pronghorn through the Pronghorn Migration Corridor; (7) fencing is likely inconsistent with Forest Service requirements to maintain or enhance the values of the (Scenic) Gros Ventre River corridor that is part of the Snake Headwaters Wild and Scenic River system; and (8) fencing may not be consistent with requirements in the Teton County Land and Development regulations. “Take-down”, seasonal fences might alleviate several of the above concerns, at least for part of the year, but the Forest Service does not have the financial resources to annually erect and dismantle large distances (miles) of take-down fence that would be required to effectively preclude elk movement on to private lands and to the NER.
11. Comment: Coupled with reduced supplemental feeding, we also recommend USFS explore measures to reduce the need for elk feeding as a means to prevent commingling with livestock. Under the BEMP, for example, FWS and the NPS will be working with private and agency partners to minimize bison and elk conflicts with adjacent land owners (e.g. by providing human and/or financial resources to manage commingling and reduce crop depredation by elk and/or bison on private lands). Specifically, these measures could involve establishing goals to fence elk out of livestock feed areas and stock yards in cooperation with the WGFD and adjacent livestock producers. Response: Feedgrounds on NFS lands are operated by the Wyoming Fish and Game Commission (WGFC) to accomplish their agency mission. It would be within WGFC's purview, not the Forest Service's, to consider transitioning elk to natural forage instead of feeding them in the winter. The WGFC and the Forest Service have separate missions, but have agreed to work in harmony for the common purpose of maintaining, developing, and managing the fish and wildlife populations and habitat on National Forest System lands (FS Agreement 00-MU-11020000-052). The Forest Service recognizes WGFC as the agency with the authority, jurisdiction, and responsibility to manage, control, and regulates fish and wildlife populations in NFS lands unless federal law specifically supersedes such authority (Ibid.). In this project, it is within WGFC's jurisdiction to decide whether or not to feed elk in western Wyoming and it is within the Forest Service's jurisdiction to decide whether or not to authorize WGFC to use NFS lands for feedground purposes. It would also be within WGFC's jurisdiction to assist private landowners in effort to protect their livestock and crops from effects of elk foraging in stockyards.
12. Comment: If Alternative 2 is adopted by the Bridger-Teton National Forest, it should not be for 15 years. If Alternative 2 is adopted, the Wyoming Chapter of the Sierra Club wants to propose a graduated decrease in feedground operations with the financial savings going to mitigate the impact of elk population on livestock. A decrease in supplemental feeding over a five year period should be sufficient and give time to measure the impacts on elk and livestock producers. Response: The Forest Supervisor considered your recommendation that a permit should be issued for no more than a five year term. Please see the Draft Record of Decision to see her response. Measures are in place that allow the Forest Service to regularly review the use of National Forest Service lands for feeding elk at Alkali Creek as well as other feedgrounds. First, the Operating Plan for Feedgrounds on the Jackson Ranger District gives both the Forest Service and Wyoming Game and Fish Commission an annual opportunity to amend the permit operations. Overall feeding operations are reviewed at yearly meetings and changes can be made as needed. Next, the Cooperative Elk Studies
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Response to Comments
Group, which was formed in 1958, meets annually to share information and coordinate management and research of elk. This group is composed of representatives of the Wyoming Game and Fish Department, National Elk Refuge, Bridger Teton National Forest, and Grand Teton National Park. Finally, the Jackson Interagency Habitat Initiative (JIHI), which formed in 2001, has as one of its goals to maximize the effectiveness of native winter and transitional range for ungulates and a diversity of species indigenous to this region through identification of habitat enhancement opportunities. The Forest Service does not have the authority to dictate the use of the financial savings that Wyoming Game and Fish Commission would gain from reducing the feeding of elk; therefore we could not require them to use the savings on mitigation actions. Vegetation 13. Comment: “Use of Alkali Creek Feedground concentrates the elk, which could result (does already result) in impacts to vegetation from browsing and trampling causing changes in vegetation type and condition, especially in sagebrush, aspen, and willow stands (this contradicts statements elsewhere that say willows are not being affected) associated with riparian/wetlands. Response: A correction has been included in the FSEIS. No notable impacts to willows are currently occurring within the permit area for Alkali Creek Feedground (FSEIS, Table 4, page 20); however effects to willows have been observed in the riparian areas adjacent to Alkali Creek (FSEIS, pages 57-57).
14. Comment: I think it’s great that the FS is committing to cheatgrass treatment but if the cheatgrass is being encouraged as a result of the feedground being where it is, shouldn’t the permittee be covering this cost? Response: Prevention and control of cheatgrass, a noxious species of concern, as well as all noxious weeds and exotic plants that occur within the special uses permit area are the responsibility of the permit holder (in this case, Wyoming Game and Fish Commission). This is a condition of their current special use permit and if a new permit were to be issued, it would also be a condition of their new special use permit. This clause is as follows (taken directly out of their permit): G. Noxious Weed and Exotic Plant Prevention and Control (D-10). The holder shall be responsible for the prevention and control of noxious weeds and exotic plants arising from the authorized use. For purposes of this clause, noxious weeds and exotic plants include those species recognized as such by the Bridger-Teton National Forest. The holder shall follow prevention and control measures required by the Bridger-Teton National Forest. When determined to be necessary by the authorized officer, the holder shall develop a plan for noxious weed and exotic plant prevention and control. These plans must have prior written approval from the authorized officer and, upon approval, shall be attached to this permit as an appendix. In areas adjacent to the permitted area, the Forest Service would treat cheatgrass invasions. The Wyoming Game and Fish Department would not have the authority to manage weeds outside their permitted area.
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Response to Comments
15. Comment: The presence of Astragalus bisulcatus (commonly called two-grooved milkvetch, here after called ASBI) is a concern because it accumulates selenium. The accumulated selenium has permanently poisoned areas of the upper Gros Ventre which have selenium in their geologic structures. The selenium accumulated in these areas is taken into other plants making them poisonous. ASBI is not native to the Upper Gros Ventre area; plants typically associated with ASBI are not present. Historical plant collections of the upper Gros Ventre do not contain ASBI and ASBI only appears in plant collections late in the 20th century. Sediment studies support this. Response: Astragalus bisulcatus (ASBI) is a selenium accumulator. The species is not listed as noxious in Wyoming or as a priority species by Teton County (WY) Weed and Pest, nor is it listed for conservation or management by the Forest Service or any other federal agency. As a poisonous plant, increasing the density of ASBI may become a public or rangeland health issue. Neither the proposed nor the no action alternatives will create more or less ASBI habitat since the species is not necessarily a disturbance adapted species and the presence of elk in the winter and a supplemented and concentrated population in general won't create more or less habitat for this species.
16. Comment: Forest Service employees have mis-identified Pinus flexilus (limber pine) as Pinus albicaulis (whitebark pine). Response: We recognize that differentiating whitebark and limber pine can be difficult, especially in the absence of cones which are usually necessary for positive identification. Forest Service records show approximately 52 acres of whitebark pine vegetation type within the analysis area considered for this project (page 44, FSEIS). While no on-the-ground verification of the acres mapped as whitebark pine occurred for this analysis, the determination regarding the potential impact of the proposed and no-action alternatives on whitebark pine is accurate. This is because both limber pine and whitebark pine share similar habitats and would be similarly impacted by the alternatives. Whitebark pine is a sensitive species. Neither alternative would push whitebark pine in a trend toward listing of lead to a loss of either species on the planning unit. The effects to whitebark pine and other sensitive plant species are disclosed in the FSEIS on pages 49-59.
17. Comment: Conservation of Aspen are considered a Management Indicator Species (MIS) on the Bridger-Teton National Forest (Figure 10, page42), and the BTNF is required to protect aspen. Forest-wide Resource Management Prescriptions, Standards, and Guidelines: (LRMP: 121) "Aspen Management Guideline: Aspen sites should be managed for aspen-type perpetuation. The loss of aspen stands due to old age, conifer encroachment, and possible overgrazing should be prevented. Priority areas for aspen treatment should be big-game winter ranges, calving areas, and stands where type loss or conversion is imminent. " (BTNF 1990 LRMP: 132) Despite the requirement to protect aspen that is listed several times in the 1990 BTNF LRMP, the operation of elk feedgrounds has harmed and virtually eliminated younger aged class aspen from a broad area. "Shrubs . . . and trees . . . of greater palatability are often stunted or killed from intense browsing and trampling." (DSEIS: 35) "Field study indicates that there is "low regeneration (of aspen)" two kilometers and less from the Alkali Feedground area.” (DSEIS: 37) "In the immediate area where feeding takes place more stems are browsed than are grown anew each year . . . . . and the aspen are thus dying back. (WGFD 2011)" (DSEIS: 45) If no feedground is operated at Alkali Creek, "vegetation would increase in diversity and shrub densities." (DSEIS: 48) If no
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Response to Comments feeding were to occur at Alkali Creek "the elk herd would likely continue to move around the Gros Ventre area responding to wolf pressure and feeding." There would thus be an increase in elk mobility. It is the policy of the BTNF that they are to implement "suppression of natural fire in the vicinity of feedgrounds." (DSEIS: 45) "Aspen is also in decline due in part to fire suppression in the past.” If no feeding at Alkali Creek and the infrastructure removed, it would "increase the chances that a naturally occurring wildfire would be allowed to run its course on National Forest System land at Alkali Creek Feedground and in the area as a whole." (DSEIS: 50) Allowing a more natural fire regime would benefit aspen and other plants that evolved with fire, but how telling and unfortunate that while describing an area where feeding no longer takes place and structures removed, the BTNF still calls the area a "feedground". "(A)spen are dying back (as a result of feeding operations), which is contrary to the Aspen Management Guideline in the BTNF LRMP which says that aspen should be sustained. Elimination of elk management activities at Alkali Creek Feedground would improve aspen health and be consistent with the Aspen Management Guideline. "(DSEIS: 51 parentheses added) The DSEIS errs when the map on page 34, Figure 7: Distribution of Certain Vegetation Types within the Analysis Area does not indicate the aspen stands at FS Road 30400 (aka, the Gros Ventre Road) above and below where it crosses Alkali Creek. We include a photo of a portion of those aspen stands in these comments. Because of such errors, the DSEIS further errs when it lists the acreage of aspen in the corridor analysis area as only 642 acres. (Table 8, page 43) The DSEIS says that 388 acres of aspen are affected by excessive elk browsing, but it errs by omission when it fails to describe additional acreage similarly affected outside Wilderness. For example, the aspen stands, such as remain, in the Alkali Creek bottom near the Forest Road 30400 are severely harmed by maintaining excessive numbers of elk during winter nearby, as are aspen stands both east and west of the site of the elk feedground. Overbrowsed aspen and other plants at Alkali Creek along FS Road 30400. L. Dorsey, 5-5-13 The BTNF offers a specious argument when it makes a case for more elk feedgrounds being ecologically beneficial compared to fewer elk feedgrounds. "The concentration of elk between the three feedgrounds and the cessation or lessening of downstream migration would reduce the number of acres of aspen that are subject to elk browse." (DSEIS: 53) This is hardly true. Allowing elk to range free in accordance with the carrying capacity of the available habitat is the healthiest model that the BTNF must ascribe to and, just as elk and aspen evolved together, allow both species to prosper. The scope of analysis and focus should not be so narrow that alleged benefits of more feedlots versus fewer is an actual standard used by the BTNF. Impacts arising from the operation of elk feedgrounds radiate outward across vast landscapes which can be very far from the actual feedlot sites. Furthermore, such a limited scope does not follow the BTNF Vision Statement nor their Mission Statement (below) to manage for "world-class wildlife" and use "progressive leadership in natural resource management". USFS management using elk feedgrounds just doesn't fit or follow from these statements. Response: The direction in the Bridger-Teton National Forest Land and Resource Management Plan (LRMP) to manage aspen is in the form of a Forest-wide Aspen Management Guideline (AMG) on page 132 of the LRMP and several resource area specific AMGs. As described in the LRMP on page 3, a guideline is stated as a "should be" or "may be" statement which is flexible and occasionally optional. As such, the proposed action not meeting the Aspen Management Guideline does not violate required direction set forth in the LRMPAGE. The area of mapped acres of aspen that would not meet the
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Response to Comments forest-wide AMG under either alternative is small compared to the spatial distribution of aspen on the Bridger-Teton National Forest. Thank you for your comment pointing out the discrepancies with the acres of aspen in and around the analysis area. We have added text that will make it clear that the number of acres discussed in the DSEIS is the mapped acres of each vegetation type. The acres of each vegetation type that were mapped are subject to the protocols of the mapping program. In the case of a forest type, trees must account for greater than 60% of the canopy cover to count as a forested vegetation type. For aspen, a stand of aspen was mapped as such if the canopy cover was greater than 60% aspen. The photo included in the comments appears to show an aspen stand which does not exceed 60% of the total canopy cover for that area, as a result the stand would have been mapped as a shrub land. We have added language to the DSEIS and other specialist reports stating that the amount of acres of each vegetation type is the mapped acres. The vegetation map used for this project is the best available science to determine the spatial distribution of vegetation on the Bridger-Teton National Forest. The number of acres that would be indirectly affected by the proposed action is fewer than the number of acres indirectly affected by no action. The stated purpose of the Alkali Creek Feedground is to prevent the down valley movement of elk during the winter. The Alkali Creek Feedground is generally successful in accomplishing this. As a result, the aspen stands which are down valley of the Alkali Creek Feedground are less likely to receive elk browsing in the winter under the proposed action. The fact that feeding at Alkali likely supplements the elk population during the winter and allows more elk to survive does have impacts to aspen in the Gros Ventre area as a whole, which are disclosed in both the FSEIS (pages 81-84, 110-111) and the Botany Biological Evaluation Report. The contribution of a single feedground (such as Alkali Creek) to the general condition of aspen in the Gros Ventre area is too nebulous to attribute to one feedground. As a result, the effects of winter elk feeding in the Gros Ventre area are disclosed and described in the cumulative effects section of the FSEIS and Botany Biological Evaluation Report. The Forest Service agrees with the commenter that allowing elk to range free in accordance with the carrying capacity of the available habitat would result in healthier aspen stands.
18. Comment: Table E-1 MIS plant species – Aspen – The table and analyses reference the Aspen Management Guideline in the BTNF 1990 Forest Plan but not specifically which guideline. The Vegetation General guideline states “For aspen, priority is placed on perpetuating stands being invaded by conifers.” Several of the management area guidelines state that aspen should be managed for big game species browse and cover, habitat for MIS species, and seasonal colors. There is a general guideline, a Gros Ventre guideline, and a wild and scenic river guideline, which may be eliminated with the current wild and scenic planning process. The SEIS should be more specific about which aspen guideline the analysis area is subject to and why both Alternative 1 and 2 would be contradictory to this guideline. Response: The Aspen Management Guideline (AMG) that was used in the DSEIS was the Forest-wide AMG found on page 132 of the Forest Plan. We have added text in the FSEIS on page 46 to ensure that this is clearer. That AMG states that: Aspen stands should be managed for aspen-type perpetuation. The loss of aspen stands due to old age, conifer encroachment, and possible overgrazing should be prevented. Priority
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Response to Comments areas for aspen treatment should be big-game winter ranges, calving areas, and stands where type loss or conversion is imminent. The rationale for determining that both alternatives will have some contradictions of the AMG is discussed in both the FSEIS (pages 51 and 54) and Botany Biological Evaluation. In brief, both alternatives fail to completely meet the Forest-wide AMG because they do not perpetuate aspen in all places. The No Action Alternative does not perpetuate aspen in all places because in the absence of Alkali Creek Feedground the elk will be more widely dispersed and thus the impact to aspen will be more wide-spread. The Proposed Action Alternative does not perpetuate aspen in all areas because aspen dieback has been noted at Alkali Creek Feedground due to the feedground operation there and Alternative 2 will maintain that impact.
19. Comment: Veg Resources Noxious Weeds – It should be noted that WGFD pays for weed treatments at Alkali. Response: The Wyoming Game and Fish Department is responsible for weed treatments within the permit area.
20. Comment: Veg Resources Species Richness and Diversity – The analysis states “Shrubs of low palatability are typically killed and excluded from feedgrounds by repetitive crushing or trampling from trucks/trailers, horses/feed sleighs, and/or elk.” It should be noted that this area is used by the public as a trail head. Response: Table 6 on page 33 of the FSEIS states that there is a lightly used trailhead near Alkali Creek Feedground. The presence of a trailhead in the vicinity of the feedground is unlikely to contribute significantly to the shrub mortality because motorized vehicles are not permitted to travel off of established roads. This trail head serves a wilderness area and the trail is non-motorized. Recreationists at the trailhead on foot or horseback may travel cross-country across the feedground area, causing a small percentage of the shrub mortality. The majority of the mortality observed is due to repetitive crushing or trampling from elk and horses with feed sleighs.
21. Comment: Veg Resources Aspen – MIS – The first sentence of this paragraph should be reworded to read “The No Action alternative would likely increase the number of acres of aspen susceptible to elk browsing, since the elk herd in the Gros Ventre area would likely be more mobile throughout the drainage.” Additionally, this analysis should consider factors other than elk browsing that impact aspen stands and lead to aspen loss in the Gros Ventre drainage. Response: The text concerning aspen has been changed in the FSEIS on page 51. The other factors that impact aspen are disclosed and considered in the Cumulative Effects section as well as the Affected Environment section.
22. Comment: Veg Resources Determinations – The second paragraph refers to the Aspen Management Guideline in the 1990 Forest Plan. The SEIS should be more specific about which aspen guideline it is referring to (e.g., general, Gros Ventre, or WSR). The aspen guidelines in the Forest Plan recommend aspen are managed for several things (e.g., browse, cover, habitat, colors, etc.), but none simply say that aspen should be sustained. Also, the SEIS should acknowledge that the Preferred Alternative for the
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Response to Comments
Snake River Headwaters WSR Amendment would effectively remove the aspen guideline for this segment of the Gros Ventre and the 1/4mi corridor, which encompasses a portion of the feedground. Response: The AMG (aspen management guideline) referred to in the FSEIS and Botany Biological Evaluation Report is the Forest-wide AMG found on page 132 of the Forest Plan. The forest-wide AMG states that aspen should be perpetuated and overgrazing prevented. It also states that priority areas for treatments (and by inference, a lack of treatments (i.e. No Action Alternative)) to perpetuate aspen are big game winter range. The words “Forest-wide” have been added to any mention of the AMG and the word “sustained” has been replaced with “perpetuated” in the FSEIS to avoid further confusion. The Snake River Headwaters Wild and Scenic River amendment does not remove or supersede the Forest-wide AMG.
23. Comment: Veg Resources Cumulative Effects – This analysis should note the allotment boundary in the area and that livestock are trailed through the feedground. It is unclear whether the feeding area is part of the annual operating plan for the allotment. Additionally, the analysis discusses suppressed willow plants in the corridor analysis area, but it was previously stated that there are no notable impacts to willows in the feedground area. The cumulative effects analysis should consider that much of the Gros Ventre drainage is native winter range for big game species and vegetation utilization on winter range may be naturally high. Response: The information the commenter provided has been added to the Vegetation Resources cumulative effects section in the FSEIS. In addition, the FSEIS states that Alkali Creek Feedground is within the Gros Ventre Allotment and that the feedground is not fenced and is available for use by livestock. The elk feeding area is available for summer grazing use by livestock. The FSEIS also includes a revised description of the impact of elk browsing on willow shrubs in the feedground area in the Hydrology Resources section, page 69. Heavy browsing was observed on current year growth within the project area during a field visit in 2013. The cumulative effects analysis is limited to human-directed actions that could combine with the proposed action to result in a cumulative effect. The existing condition of the affected environment is the baseline from which potential cumulative effects are estimated. The Forest Service agrees with the commenter that vegetation utilization on winter range in the Gros Ventre drainage is high.
24. Comment: Veg Resources Cumulative Effects – Bullet #1 – States, “Cattle grazing in the general area may interact with a supplemented elk population…” It is unclear if the feeding area is part of the annual operating plan for this allotment. Response: Cattle and elk interact in the analysis area; this interaction is disclosed in the FSEIS in the Vegetation Resources section, Affected Environment (page 37) and the Cumulative Effects section (page 47). The presence of an allotment is discussed in the Affected Environment section (page 37). The feedground is not fenced and is available for use by livestock.
25. Comment: Over-browsing of the winter range will result if feeding elk is reduced or eliminated. Subsequent erosion of the soils and increases in weed species will result. Response: The effects of feedground elk herbivory on elk native range, mule deer, moose, and pronghorn under Alternative 1 (no feeding at Alkali Creek Feedground) in the immediate vicinity of the Alkali Creek Feedground and on native winter ranges in the Gros Ventre watershed are addressed in the
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Response to Comments
FSEIS (pages 81-84 and 114-116). Modifications to text to incorporate this and similar comments by the Wyoming Game and Fish Department were made in the analogous sections of the FSEIS and the revised wildlife specialist report. Because the same elk use all the feedgrounds in the Gros Ventre watershed, not feeding elk at Alkali Creek Feedground would likely increase elk herbivory pressure on vegetation in the immediate vicinity of the Patrol Cabin and Fish Creek feedgrounds. Closing Alkali Creek Feedground might also increase forage competition between elk and moose, bighorn sheep, and mule deer on native range, as some elk that currently use Alkali Creek Feedground might elect to forage on native range some or part of the winter if the Alkali Creek Feedground were to close. As discussed in the FSEIS for vegetation resources (page 49), elk mobility among the two remaining feedgrounds and the National Elk Refuge in Jackson Hole is expected to increase, potentially increasing herbivory pressure in the river corridor and on native ranges used by other ungulates. Overall, a broadening of areas that receive herbivory impacts during the winter and a lessening of local impacts (Alkali Creek Feedground) are expected to occur under Alternative 1. However, because we lack quantitative assessments of herbivory effects under current conditions and under closure of Alkali Creek Feedground, it is speculative to conclude that closing Alkali Creek Feedground would cause severe over-browsing, increased erosion and increased frequency of weeds in the river corridor.
26. Comment: A site visit to Alkali Feedground on May 13, 2012, and a follow up visit in May 2013, revealed extensive habitat degradation within the site and for up to 1 mile beyond the feeding operation. The “over-browsed and de-barked trees” mentioned in the Environmental Impact Statement (EIS) and Wyoming Game and Fish Department data do not adequately describe the lack of regeneration of aspen stands in that area. Response: The existing condition of aspen in the area is disclosed in the FSEIS on page 46 and in the Vegetation Report in the project record. In the immediate vicinity where feeding takes place, more aspen stems are browsed than are grown anew each year and the aspen are thus dying back. Between 500 and 750 meters from feeding areas, each year's growth exceeds that which is browsed, and as a result there is a net growth. Photographs showing the aspen condition are found in Appendix 4 of the FSEIS. Concentration of elk at the feedground does result in localized impacts on vegetation in the Gros Ventre Wilderness. However, vegetation monitoring has found that overall plant species composition has not been altered, aspen is persisting, there is no evidence of noxious weeds and natural processes still operate freely (FSEIS page 158) at the scale of the entire Gros Ventre area. Therefore, the analysis concluded that Forest Plan direction for DFC 6 and Wilderness Act requirements would be met if continued use of Alkali Creek Feedground was authorized.
27. Comment: “Portions of the project area, analysis area and Corridor Analysis Area would be in contradiction of the Aspen Management Guideline.” The proposed action should include measures to reduce or eliminate this contradiction. Response: The direction in the Bridger-Teton National Forest Land and Resource Management Plan (LRMP) to manage aspen is in the form of a Forest-wide Aspen Management Guideline (AMG) on page 132 of the LRMP and a resource area specific AMG for DFC 12 on page 245. As described in the LRMP on page 3, a guideline is stated as a "should be" or "may be" statement which is flexible and,
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Response to Comments occasionally, optional. Thus, there is no requirement for a proposed action to meet a guideline. As such, the proposed action not meeting the Aspen Management Guideline does not violate the direction set forth in the LRMPAGE. The mapped acres of aspen that will not meet the forest-wide AMG under either alternative are small compared to the spatial distribution of aspen on the Bridger-Teton National Forest. Wetlands and Riparian Areas 28. Comment: Page 14, mitigation with proposed action: The EIS states that under Alternative 2 “Feeding is not authorized to take place on the mapped wetland areas or within 100 ft. from the outer edge of the wetlands and the channel that connects them” but gives no guidance on how those wetlands would be protected from trampling by elk and vehicles (or cattle attracted to residual hay). Response: Based on visits to the feedground in 2007 and 2011, it appeared that elk and cattle were impacting the wetlands. As a result, a 100-foot feeding buffer was added to the operation plan for the existing permit to protect these areas from such impacts (by not drawing animals into the wetlands). During a field visit on June 24, 2013, staff observed that trampling or use on summer-growing herbaceous vegetation was not evident and the wetlands had not been impacted by vehicular use. A mitigation measure such as a fence was considered but rejected. Fences would lead to trails along the fence (from wildlife and livestock movements) and would displace herbivory impacts to other locations rather than solving problems. Also, a fence would have to be a lay-down fence so that this habitat could be accessible to large mammals during the non-winter season. However, a lay-down fence that is upright during the winter would also preclude use of the enclosed area by other large mammals such as pronghorn, moose or the occasional bighorn sheep. After further discussion among members of the ID team, it was decided that cattle were probably attracted to water and riparian vegetation in the wetlands, and the hay was likely not the attractant after all. Text in the FSEIS has been amended to reflect this. Cattle may have been attracted to hay in the sheds, however, and this has been noted in the FSEIS on page 69.
29. Comment: Page 250: Unavoidable Adverse Effects - "Water quality would be affected by wetland and stream bank damage, erosion and sedimentation in both alternatives. (Rather contradictory to earlier statements that suggest minor or no impacts to stream banks, soil, or the Gros Ventre River. Response: The effects to water quality have been clarified in the FSEIS on pages 65, and 68-69. The new text states: "Water quality would be affected by feedground practices. Elk trailing to and from the feedground across Alkali Creek would destabilize streambanks resulting in sedimentation. Although no feeding would occur within 100 feet of the wetlands, elk fecal material would still contribute nutrients and bacteria to the wetlands within the feedground." This is an unavoidable effect in both alternatives because, even if Alkali Creek Feedground were closed, it is likely that, more down drainage movements would occur and large groups of elk would still move through, crossing streams in the area.
30. Comment: Isn’t specific enough about how some of these measures would be effectively implemented.
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Response to Comments
Response: In Alternative 2, feeding would not be authorized to take place within the mapped wetland or within 100 feet from the outer edge of the wetlands and the channel that connects them (FSEIS, page 16). This requirement would be specified in the WGFD special use permit. The edge of the wetlands is readily apparent, even in winter. If WGFD foresees that they will not be able to determine the edge of the wetlands or the connecting channel, they must mark the edge of the features or the feeding boundary when the features are visible so they do not violate the mitigation measure. Temporary measures such as posts may be used for marking the boundary. The Forest Service Special Use Administrator will conduct an inspection of the feedground after snowmelt to see if any hay remnants lie within the 100-foot buffer. This will constitute implementation monitoring.
31. Comment: Wetlands The Alkali Creek area contains wetlands (DSEIS: 61) that are adversely affected by feeding elk. "If the Alkali Creek Feedground was no longer authorized, an improvement in riparian vegetation would occur on a 1.2 acre portion of the site that is currently trampled during times when wetlands have bare soil exposed, (Ibid:64). "Cumulative impacts by cattle as seen in the feedground via the copious amounts of cattle feces and apparent grazing in the vicinity of remnant hay bales and around the hay barns would be reduced by implementation of the No Action alternative." (Ibid: 65) "Under this alternative, WGFC would rehabilitate impacts at the Alkali Creek Feedground site. (Ibid: 64) Not issuing a permit to feed elk at Alkali Creek "would comply with all pertinent laws, regulations, policies, and plans described in the Hydrology Resources Specialist Report. It would protect water quality, wetlands, and riparian vegetative communities." (Ibid: 66) Issuing a permit to feed elk at Alkali Creek would result in "adverse impacts . . . . . greater than under Alternative 1," because of concentrated use by elk and cattle. (Ibid: 67) To protect wetlands and comply with law, the BTNF cannot issue a permit to feed elk at Alkali Creek.
Response: Wetlands are proposed to be protected under Alternative 2 by implementation of a buffer zone as described in the Mitigation and Monitoring section on page 16 of the FSEIS. Applicable laws do not require that Deciding Officials choose the alternative with the least impact to wetlands. The FSEIS discloses the effects of the alternatives. The Forest Supervisor will determine which alternative best meets the purpose and need, taking the type and magnitude of described impacts (with the implementation of mitigation measures) and other legal considerations into account. Please see the Reasons for My Decision section of the Draft Record of Decision for the Forest Supervisor's rationale concerning wetlands.
32. Comment: Hydro Resources Alternative 2 – The analysis indicates that the conditions of Alkali Creek have been degraded as a result of elk trailing, but the SEIS has not presented data to confirm the amount or extent of degradation. In fact, it seems that the existing conditions on Alkali Creek are unknown. Cumulative Effects – See previous comments regarding Alternatives 1 and 2 and Alkali Creek. Response: A Multiple Indicator Monitoring (MIM) evaluation was conducted on a segment of lower Alkali Creek on June 24, 2013 to assess physical conditions along the stream. Current year streambank alteration was measured at 11%; streambank stability (long term) was 64%; and streambank cover was 94%. Details concerning this evaluation have been filed in the project record.
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Response to Comments
Based on observations along Alkali Creek, factors contributing to lowered stability include the influence of numerous springs along the stream, long-term impacts of animal trailing across the stream, and cumulative impacts from the 2011 Red Rock fire.
33. Comment: Table E-1 Stream bank alteration – Alternative 1 indicates that water quality and channel conditions would improve on Alkali Creek if the feedground permit were not reauthorized. Alkali Creek would likely be impacted by elk trailing regardless of the feedground operation as a result of winter migration patterns. Response: This comment points out the need for additional consideration of causation. Evidence of cattle in the feedground was pronounced in both 2007 and 2011, with evidence of heavy cattle use in the north (dry) wetland in 2007. It appeared that cattle also grazed the uplands around the wetlands that year. In 2011, conditions were considerably wetter and the Forest Service specialists visited the feedground in July. There was a great deal of fresh cow manure in the feedground at the time of the visit, including concentrations around the hay shed (Hydrology Specialist Report). These two observations indicate that cattle were attracted to water, riparian vegetation, or the hay shed, except that, in 2011, there was no obvious sign of cattle grazing on herbaceous vegetation around the wetlands. On June 24, 2013, A Multiple Indicator Monitoring survey was conducted along a reach of Alkali Creek within the area where heavy trailing is visible on the slopes adjacent to the stream. Very few cattle feces (old ones) were seen along the stream, indicating that cattle do not tend to linger along the channel in search of riparian vegetation (they had not been brought on the Forest yet that year). These observations indicate that cattle are not attracted to the area for riparian vegetation. Based on observations along Alkali Creek, factors contributing to lowered stability include the influence of numerous springs along the stream, long-term impacts of animal trailing across the stream, and cumulative impacts from the 2011 Red Rock fire. Streambank alteration, reduced channel function, and increased sediment delivery to the Alkali Creek channel from trails and trampled banks are impacts that result from this trailing. With regard to trails created by elk during migration as compared to those associated with the feedground, the multiple, adjacent trails evident on the hillside adjacent to Alkali Creek (within 400 meters of the feedground) are expected to be less under Alternative 1 as compared to Alternative 2 because elk would move through but would not be concentrated under Alternative 1. Scott Smith, Wyoming Game and Fish Department Biologist, confirmed this on the July 17, 2013, field trip to the site. Such trailing is not currently, and was not historically, evident on the elk migration route between the Teton Wilderness-Yellowstone Park and the National Elk Refuge which is (or was) the longest and most significant elk migration in North America. Also, we do not see multiple trails of elk (using feedgrounds or native range) at sites in the Gros Ventre watershed that are distant (> 750 meters) from the feedground. However, we do see them on hillsides adjacent to the feeding area on the National Elk Refuge. Thus, it is reasonable to conclude that the multiple trails as seen near Alkali Creek result primarily from feedground (concentrated) elk (Alternative 2) rather than trailing associated with a migration, and in the absence of a feedground (Alternative 1) such concentrated trailing would not be present.
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Response to Comments
34. Comment: Hydro Resources Environmental Consequences – Alternative 1 – The analysis indicates that riparian vegetation would improve under the No Action alternative and areas that were trampled both by elk and cattle would recover. If cattle are attracted to the site for reasons other than leftover hay (i.e., riparian vegetation) this analysis may not be accurate. The third paragraph indicates that stream channel conditions, sediments levels, and vegetation on Alkali Creek would improve under the No Action alternative due to decreased elk trailing. The SEIS should confirm that Alkali Creek is being impacted, and the analysis should acknowledge that trailing on this waterway would occur regardless of the feedground as a result of historic migration patterns. Response: This comment points out the need for additional consideration of causation. Evidence of cattle in the feedground was pronounced in both 2007 and 2011, with evidence of heavy cattle use in the north (dry) wetland in 2007. It appeared that cattle also grazed the uplands around the wetlands that year. In 2011, conditions were considerably wetter and the Forest Service specialists visited the feedground in July. There was a great deal of fresh cow manure in the feedground at the time of the visit, including concentrations around the hay shed (Hydrology Resources section). These two observations indicate that cattle were attracted to water, riparian vegetation, or the hay shed, except that, in 2011, there was no obvious sign of cattle grazing on herbaceous vegetation around the wetlands. On June 24, 2013, A Multiple Indicator Monitoring survey was conducted along a reach of Alkali Creek within the area where heavy trailing is visible on the slopes adjacent to the stream. Very few cattle feces (old ones) were seen along the stream, indicating that cattle do not tend to linger along the channel in search of riparian vegetation (they had not been brought on the Forest yet that year). These observations indicate that cattle are not attracted to the area for riparian vegetation. Based on observations along Alkali Creek, factors contributing to lowered stability include the influence of numerous springs along the stream, long-term impacts of animal trailing across the stream, and cumulative impacts from the 2011 Red Rock fire. Streambank alteration, reduced channel function, and increased sediment delivery to the Alkali Creek channel from trails and trampled banks are impacts that result from this trailing. With regard to trails created by elk during migration as compared to those associated with the feedground, the multiple, adjacent trails evident on the hillside adjacent to Alkali Creek (within 400 meters of the feedground) are expected to be less under Alternative 1 as compared to Alternative 2 because elk would move through but would not be concentrated under Alternative 1. Scott Smith, Wyoming Game and Fish Department Biologist, confirmed this on the July 17, 2013, field trip to the site. Such trailing is not currently, and was not historically, evident on the elk migration route between the Teton Wilderness-Yellowstone Park and the National Elk Refuge which is (or was) the longest and most significant elk migration in North America. Also, we do not see multiple trails of elk (using feedgrounds or native range) at sites in the Gros Ventre watershed that are distant (> 750 meters) from the feedground. However, we do see them on hillsides adjacent to the feeding area on the National Elk Refuge. Thus, it is reasonable to conclude that the multiple trails as seen near Alkali Creek result primarily from feedground (concentrated) elk (Alternative 2) rather than trailing associated with a
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Response to Comments migration, and in the absence of a feedground (Alternative 1) such concentrated trailing would not be present.
35. Comment: Unavoidable Effects Bullet #2 indicates that willow habitat could be impacted, but the SEIS already stated that observations indicated willows are not being impacted by the feedground. Bullet #3 indicates that stream bank damage will occur, but does not specify on which waterway. Stream bank damage on Alkali Creek should be measured and confirmed before this conclusion is made. Response: Willow, sedges, and grasses were in good condition at the time of the Forest Service's initial field visit in 2007, and again in 2011. A field visit on June 24, 2013 found that, even with the feeding buffer, willows in the southern wetland and along the channel connecting the wetlands had sustained heavy browsing pressure on previous year's leaders, presumably from elk in the feedground. No notable trampling or use on summer-growing herbaceous vegetation was evident. Members of the interdisciplinary team visited the feedground in July 2013 to evaluate and discuss impacts to the wetlands from feeding operations. Although browsing on willows and roses has been heavy (impacts are occurring to vegetation height and structure, mostly above 1.5 meters on the shrubs), the team determined that the shrubs are able to tolerate such browsing and still maintain themselves. However, the ID team noted that there is no recruitment of new shrubs. A Multiple Indicator Monitoring (MIM) evaluation was conducted on a segment of lower Alkali Creek on June 24, 2013 to assess physical conditions along the stream. Based on observations along Alkali Creek; factors contributing to lowered stability include the influence of numerous springs along the stream, long-term impacts of animal trailing across the stream, and cumulative impacts from the 2011 Red Rock fire. Changes were made to the FSEIS on pages 66-69 to reflect results of the 2013 monitoring.
36. Comment: Table E-1 Wetlands/riparian areas – Alternative 1 indicates that water quality would improve but does not specify what waterway is currently being impacted by the feedground. The area of the feedground is a closed basin system. Response: The text in Table E-1 concerning Alternative 1 wetlands/riparian refers to water quality in the area of the wetlands "New elk pellet concentrations would not accumulate on-site, reducing the potential for nutrient and bacteria enrichment in the 2.9 acres of feeding area wetlands." (page 65) and "there would be less potential for water quality degradation from livestock fecal matter in the vicinity of the wetlands (and in other areas of the feedground) due to direct fecal input and due to overland runoff of bacteria and nutrients.". It also refers to Alkali Creek, where "[s]tream channel conditions and elevated sediment levels would improve over a period of five to twenty years." It is relevant to consider water quality in the wetlands, even though they are a closed system. Under Executive Order 11990, Protection of Wetlands, "Section 1. Each agency shall provide leadership and shall take action to minimize the destruction, loss or degradation of wetlands, and to preserve and enhance the natural and beneficial values of wetlands in carrying out the agency's responsibilities for... (3) Conducting Federal activities and programs affecting land use, including but not limited to water and related land resources planning, regulating, and licensing activities." (Emphasis added). Further, "Sec. 5. In carrying out the activities described in Section 1 of this Order, each agency shall consider factors
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Response to Comments relevant to a proposal's effect on the survival and quality of the wetlands. Among these factors are: (a) public health, safety, and welfare, including water supply, quality, recharge and discharge; pollution; flood and storm hazards; and sediment and erosion;..." (emphasis added). Wilderness/Wild and Scenic Rivers 37. Comment: These vegetation impacts could affect wilderness character in the Gros Ventre Wilderness (does affect 388 acres in the wilderness), outstandingly remarkable values (ORVs) in the Gros Ventre Wild and Scenic River Corridor.” Response: The analysis in the FSEIS discloses the effects of each alternative on wilderness character and on outstandingly remarkable values for the Gros Ventre Wild and Scenic River (pp. 156-160 FSEIS). The Forest Service acknowledges that the concentration of elk at the feedground adjacent to the Wilderness does impact a localized area of vegetation within the Wilderness. Browsing effects are detectable within 750 meters of the feedground. A re-calculation of the acreage found this area to be approximately 350 acres. Despite these localized impacts on vegetation, the composition of plant communities has not been altered, aspen is still present, and native plant communities are still influenced primarily by the forces of nature rather than by human influence. The analysis also found that feedground operations were part of the baseline conditions identified in 2009 when the Wild and Scenic River was designated, thus the outstandingly remarkable values are still protected in the river corridor.
38. Comment: The presence of feedgrounds, besides impacting plant communities as described above, also causes unnaturally dense concentrations of elk - many of which are diseased or have a greater potential to contract disease as a result of this density. These concentrations of elk do not “protect or perpetuate natural biophysical conditions” as is required in the Forest Plan, nor do they allow “natural ecological succession . . . to operate freely” as required by Forest Service regulations. Unnaturally dense concentrations of brucellosis-exposed or infected elk associated with and caused by feedgrounds are not representative of natural population levels and distributions “affected by natural processes” as is mandated in the Forest Plan for DFC 6, Forest Service regulations and the Wilderness Act. Response: Although no feeding of elk occurs in the Wilderness, the Forest Service agrees that that the presence of the feedground does concentrate elk, not only within the feedground but within the area immediately surrounding the feedground, including within the Wilderness. The Forest Service also agrees that elk concentrated on or near feedgrounds have a greater potential to contract disease than elk that are more widely dispersed on native winter range. The number of elk counted on the Alkali Creek Feedground varies widely from year to year with some years having no elk and other years having as many as 2,845 elk. The locations where elk congregate in the Wilderness are closely tied to those areas where detectable browsing effects on vegetation occur, especially in the forested north-facing stands that provide shade on warmer days and protection from wind and driving snow during blizzards. This area extends approximately 750 meters from the feedground boundary (affecting approximately 350 acres within the Wilderness). Steep slopes and deep snow limit elk movement further south into the Wilderness. Section 2c of the Wilderness Act states that wilderness is partly defined to mean “an area of undeveloped Federal land retaining its primeval character and influence, without permanent
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Response to Comments improvements or human habitation, which is protected and managed so as to preserve its natural conditions and which (1) generally appears to have been affected primarily by the forces of nature, with the imprint of man’s works substantially unnoticeable…..” The use of words “generally appears” and “affected primarily” recognizes that, while managers must constantly strive to minimize human interference with natural processes, the requirement to do so is not absolute. The Bridger-Teton Forest Plan likewise recognizes that there is a gradient of human activity and impact evident within Wilderness, especially in those areas adjacent to the boundary. This recognition is noted in the classification of the area adjacent to the feedground as Desired Future Condition Class 6C where the management emphasis is to provide for the protection and perpetuation of “essentially” natural biophysical conditions, as opposed to more remote areas of the Wilderness where the emphasis is on protection and perpetuation of “pristine” biophysical conditions with essentially no perceptible evidence of human use (emphasis added) (Forest Plan pages 191-193). While there is a higher concentration of elk in the Wilderness adjacent to the feedground, this concentration is localized, confined to approximately 350 acres. “Natural conditions” for wildlife populations could be described to mean the distribution, movement patterns, and population dynamics that would likely occur without human interference. The presence of the feedground may have a minor effect on movement patterns from high elevation summer habitat to lower winter range habitat or on population dynamics such as survival rates. The feedground clearly affects distribution of elk for a limited time during the winter and the grouping of elk around the feedground extends into Wilderness. However, because this effect is very localized, has been occurring since 1976 prior to passage of the Wyoming Wilderness Act, and actions have been put into place to reduce the existing impacts, natural conditions and processes relative to elk in the Wilderness are relatively stable since passage of the Wyoming Wilderness Act.
39. Comment: The BTNF has the affirmative responsibility to protect forest resources within designated Wilderness and Wilderness Study Areas and to maintain- and where necessary restore the wilderness characteristics of those lands. The increasing densities of elk, the severe impacts on vegetation and habitat, the increasing occurrence of brucellosis-exposed elk, and the impending occurrence of CWD do not maintain the wilderness qualities that Congress directed to be protected in the Gros Ventre Wilderness. We do not find that the DSEIS adequately reflects how a feedground adjacent to the Gros Ventre Wilderness Area impacts all species and how continued permitting will conform to the 1964 Wilderness Act, Forest Service regulations, and the Bridger-Teton Forest Management Plan. [442-6] Response: The analysis in the FSEIS discloses the effects of each alternative on the Gros Ventre Wilderness (pp. 156-160 FSEIS). Please refer to the response above [38].
40. Comment: Table E-1 and the narrative later in the document (P 140) determine no effect on the Gros Ventre River corridor, but the feedground is partly within the corridor. Aspen, as explained on page 142 and the accompanying map, is affected for some distance from the feedground. Though a lot of what is said about effects on the Gros Ventre River is true, it is at least ‘slightly’ affected, as was said in regard to the wilderness. Response: Aspen may well be slightly affected from elk browsing within the Wild and Scenic River corridor. This slight effect was not highlighted in the analysis because the identified ecological
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Response to Comments outstandingly remarkable values in the river corridor are related more to landslides and slumps, nesting habitat for raptors, braided waterways, winter range for ungulates, and breeding habitat for sage grouse, not to aspen habitat per se.
41. Comment: Wilderness Alkali Creek Elk Feedground is directly adjacent to the Gros Ventre Wilderness and, in fact, "approximately 3,000 feet of the feedground boundary is concurrent with the Wilderness boundary." (DSEIS: 138) The operation of a feedground at Alkali Creek has unquestionably affected Wilderness qualities and characteristics in the Gros Ventre Wilderness in violation of the 1964 Wilderness Preservation System Act and the 1985 Wyoming Wilderness Act. As we wrote in 2008 we also include in these comments: The BTNF also has the affirmative responsibility to protect forest resources within designated Wilderness and Wilderness Study Areas. Section 4(b) of The Wilderness Act mandates that the USFS protect the wilderness character of Wilderness. As for DFC 6B, C, and D, the BTNF may not permit elk feedgrounds or facilities on USFS land adjacent to or in proximity to Wilderness or Wilderness Study Areas that adversely affect the Wilderness qualities in those Wilderness areas as expressed in the Wilderness Act and the LRMP. Courts have shown that Congressional intent and requirements for protection of Wilderness qualities is not intended to be discretionary as to allow the USFS to pick and choose whether to fulfill their duties or not. Unnaturally dense concentrations of elk - many of which are diseased as a result of congregating on feedgrounds - and harmed vegetation communities do not “protect or perpetuate natural biophysical conditions” as is required in the Forest Plan. Unnaturally dense concentrations of brucellosis-exposed or –infected elk associated with and caused by feedgrounds are not representative of natural population levels and distributions “affected by natural processes” as is mandated in the Forest Plan for DFC 6. Hundreds or thousands of elk loafing or milling about in dense groups on USFS lands after being fed baled hay are not examples of “Natural agents of ecological change operating freely,” nor are aspen stands that have been “over-browsed and debarked” to death. This all occurs within the Gros Ventre Wilderness and will occur to a greater extent if Yellowjacket Flat is turned into an elk feedground. Prescriptions, Standards, and Guidelines, for some areas of the BTNF may not be the same as those mandated for Wilderness; but Congress has been clear that designated Wilderness shall be managed to certain standards. The Wilderness Act requires the Forest Service to administer Wilderness Areas so they are “unimpaired for future use and enjoyment as wilderness.” 16 U.S.C. § 1131(a). If degraded conditions arising from elk feedgrounds exist in the Palisades WSA, the same protective Prescriptions, Standards, and Guidelines apply for the Gros Ventre Wilderness and the BTNF may not permit any feedground that causes noncompliances with the LRMP or other legal directives. The BTNF Forest Plan is also clear that certain standards that perpetuate “natural biophysical conditions” are required for Wilderness. It is also clear that actions that “tend to alter the natural behavior of wildlife” are prohibited by visitors and presumably by agencies as well. Therefore the BTNF may not continue to permit the Alkali elk feedground, or any elk feedground, . . . . () . . . whose operations would cause management of forest resources- including wildlife and habitat- to fall short of the Wilderness Standards, Guidelines, and Prescriptions. (NGO DEIS comments 2008: 23-24; the inclusion of Yellowjacket Flat and Palisades WSA is not germane to this DSEIS) If "a Term Special Use Permit would not be issued to the WGFC for use of the Alkali Creek feedground . . . . with the exception of the two feedgrounds in the upper Gros Ventre, elk would likely be more widely dispersed across crucial winter range and would likely spend less time in one location, thus the browsing effects on
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Response to Comments vegetation would be reduced. . . . Less browsing of herbaceous plants and aspen saplings on winter range in the Alkali Creek area would allow more aspen stems to grow to their full height potential. This would improve natural conditions in the Wilderness immediately adjacent to the feedground." (DSEIS: 143) We agree that if no feedground were allowed at Alkali Creek it would improve conditions in the Gros Ventre Wilderness in that area. The BTNF errs when it determines that the effects to aspen in Wilderness from decades of browsing elk "is within acceptable limits considering the overall natural quality of Wilderness." (DSEIS: 145) "Aspen is persisting as part of the plant community, even within the feedground, despite 42 years of elk browsing (WGFD 2007). How could aspen "persist" in or around the elk feedground, Wilderness or not, if it's been determined by the BTNF that there are zero new shoots of aspen to survive elk browsing within a large radius from the feedground? "Aspen are thus dying back." (DSEIS: 45) Is a "dying" plant community considered "persisting" by the BTNF and therefore these are acceptable consequences inside and outside of Wilderness of feeding elk? This is an arbitrary determination by the BTNF and does not serve the public's interest that, in the case of aspen, is better served by conserving aspen on all parts of the BTNF where they can naturally grow. Furthermore, the standard of protection of Wilderness characteristics is determined by Congress, not the BTNF. "(T)he balancing of competing interests . . . . (is) not the governing standards under the Wyoming Wilderness Act. Instead, Congress has directed the Forest Service to maintain the 1984 wilderness character of the area. That is the primary duty of the Forest Service, and it must guide all decisions as the first and foremost standard of review for any proposed action." (GYC et al. v. CTNF and BTNF Supervisors, decision by Hon. Judge B. Lynn Winmill, Nov 21, 2006: p. 15) Despite the fact that excessive browsing by elk promulgated by permitting and operating a winter feedground above Alkali Creek has cause the "dying back" of aspen communities inside and outside Wilderness, the BTNF concludes that that is alright because "Aspen is persisting as part of the plant community" and "there is no evidence that the presence of the feedground is altering the natural disturbance processes that shape plant communities at a landscape scale." (DSEIS: 145) The BTNF is once again using faulty reasoning to justify issuing Special Use Permits. Unfortunately, when aspen are essentially non-functional and "dying back" due to elk browsing that is certainly an interruption of natural processes at the scale of the aspen clone and the hundreds of acres radiating outward from the feeding site that are affected. This is the same creative reasoning and rationalization that was found to be faulty in the case cited above when the BTNF tried to rationalize an increase in heli-skiing in the Palisades WSA. The court disagreed that the BTNF had the choice to determine what scale permitted activities within Congressionally protected areas was appropriate; the BTNF does not have the discretion to pick and choose whether to fulfill their duties or not. Congress had already directed the USFS to maintain wilderness characteristics present upon passage of the 1984 act, and arbitrary boundaries or contexts were not available to the BTNF. Also required by the 1964 Wilderness Act is the restoration of wilderness characteristics where possible in designated Wilderness, which is very possible here. The evidence of elk browsing to the extent that it functionally eliminates aspen clones and other important plants across a wide swath should be evidence enough to the BTNF that their stewardship of any National Forest land and a Wilderness in particular falls far short of protecting and managing "so as to preserve its natural conditions." (DSEIS: 144 citing Sec 2a and 2b of The Wilderness Act.) In addition, thousands of elk concentrated in greater densities due to the proximity of elk feedgrounds "are not representative of natural populations levels and
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Response to Comments distributions "affected by natural processes" as is mandated by the Forest Plan for DFC 6. Hundreds or thousands of elk loafing or milling about in dense groups on USFS lands after being fed baled hay are not examples of "natural agents of ecological change operating freely," required in the Forest Plan." (NGO DEIS 2008 comments: 23-24) The operation of an elk feedground that results in such extensive damage violates the 1964 Wilderness Act, the 1984 Wilderness Act and the National Forest Management Act. Response: Although the southern boundary of the Alkali Creek feedground is contiguous with the Gros Ventre Wilderness, the feedground is wholly outside of wilderness. Section 504 of the Wyoming Wilderness Act states that Congress does not intend designation of wilderness areas to lead to the creation of protective perimeters or buffer zones around each wilderness area. The fact that non-wilderness activities can be seen or heard from within any wilderness should not preclude such activities or uses up to the boundary of the wilderness area. The Forest Service agrees that that the concentration of elk at the feedground does result in localized impacts on vegetation within the Gros Ventre Wilderness. However, localized impacts do not necessarily mean that overall natural conditions and processes are unacceptably impacted. With respect to aspen browsing, the monitoring transects found that aspen were dying back to ground level on the feedground (outside the wilderness) but adjacent to the feedground, aspen were being browsed back to the zone of mechanical protection but were still persisting. Beyond 750 meters from the feedground, aspen shoots were able to grow past browsing height. Thus, within Wilderness, aspen is not "dying back" (i.e. the live/dead ratio is not negative) and, despite the browsing effects, aspen is still present as part of the plant community. Please refer to responses above [37, 38 and 39] for more information.
42. Comment: As far as the wilderness line being close to the feedground and causing concerns because of it, one has to ask himself is there more being lost to wilderness values, versus the loss of a major tool for the Game and Fish to manage elk. Not to mention the problems that will occur trying to maintain the 1100 head herd objective. Response: The purpose of the analysis is to disclose the effects on various resources so the public and the decision-maker understand the trade-offs. To this end, the analysis discloses the effects on both wilderness and elk if feedground operations are continued (Alternative 2) or eliminated (Alternative 1). Please see the draft Record of Decision for the Forest Supervisor's reasons for the decision.
43. Comment: The weak argument of a little piece of North slope in the wilderness that bumps up against this half old century asset does not even come close to what will happen if Alkali will go away. I realize there are other issues besides the wilderness concern but in my opinion they are of even less. Response: Please refer to response above [42].
44. Comment: Table E-1 Wild and Scenic River – Alternative 1 should disclose the impacts of elk redistribution in the Gros Ventre corridor on ORVs. Response: Outstandingly remarkable values in the Gros Ventre River corridor include scenic, recreational, cultural, ecological/wildlife, fish and geologic values. Recreation values during the winter are associated with activities on the groomed snowmobiling trail. The ability to view wildlife is an important component of this experience, however, eliminating Alkali Creek Feedground would not
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Response to Comments measurably affect this recreational value since other opportunities to view wildlife exist and the feedground is not visible from the groomed trail due to the difference in elevation. Further information about the effects of Alternative 1 on outstandingly remarkable values in the Gros Ventre River corridor are disclosed in the FSEIS on pages 157-158. The ecological/wildlife values of the Gros Ventre River corridor include unique habitats associated with landslides and slumps, nesting habitat for raptors, the braided waterways that support birds, the pronghorn migration corridor, winter range for moose and bighorn sheep, and breeding habitat for sage grouse. The feedground does not directly overlap habitats such as water drainages and sage-grouse breeding areas. Additionally, the feedground structures and operations were part of the baseline conditions identified in 2009 when the river was designated, thus there is no change from a temporal context.
45. Comment: 143, 144 WSR Alternative 1 – WSR – direct and indirect effects – this analysis should consider the potential impacts, if any, of elk redistribution in the Gros Ventre scenic corridor as a result of the No Action alternative. Response: Please refer to response above [44]. Grazing 46. Comment: At page 36, it is incorrect that there are only 550 "animal unit months" permitted in the Upper Gros Ventre Allotment. I believe there are 550 cattle (mostly cow/calf pairs) permitted for that allotment during the summer months. Response: Thank you for calling this to our attention. There are up to 550 head (generally cow/calf pairs) permitted in the area during the summer months (generally mid-June to sometime in October). This has been corrected in the FSEIS on pages 37 and 119.
47. Comment: The DSEIS indicates that some "rare" cattle use of the "Winter Range Forage Reserve allotment" occurs (DSEIS: 65) and that if a permit to feed elk at Alkali Creek occurs, "cumulative impacts on the Winter Range Forage Reserve allotment from livestock use would be minor." (Ibid: 67) The BTNF should explain to the public what temporal period, frequency, and numbers and types of livestock this use consists of. The public went to great effort and financial cost to enable the permittee to waive their grazing permit in this area back to the USFS in 2007 and, to the best of our understanding, no permitted use of this area is currently allowed. Response: Forest Supervisor Hamilton closed portions of the Bacon and Fish Creek Allotments and established the Winter Range Forage Reserve (WRFR) in the remaining portions of the allotments in a letter dated January 22, 2007. The portions that were closed lie within the Primary Conservation Area (PCA) for grizzly bears as well as portions outside of critical elk winter range that are within ten miles of the PCA. This letter laid out the conditions under which the forage reserve could be used. These conditions stipulate that infrequent livestock grazing may occur only to the extent that it demonstrably benefits the winter range and only to the extent it does not result in conflict with grizzly bears and wolves. Measurable criteria to demonstrate benefit to winter range were to be developed in a Forage Reserve Management Plan (FRMP). Such a document has not been created and the definitions of
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Response to Comments beneficial use have similarly not been developed. As a result of not having a FRMP developed we cannot state, as requested, the frequency of use, duration of use, or type of use of the WRFR. There has been no permitted livestock use of the WRFR since its establishment. Without a FRMP, grazing can only occur in an emergency situation. The FRMP will be created using the NEPA process. Text in the FSEIS concerning grazing in the WRFR has been revised to include the information that no permitted livestock use has occurred since its establishment in 2007 (page 119). The effects of any proposed livestock use will be disclosed in the FRMPAGE
48. Comment: 59 Hydro Resources Wetlands and Riparian Areas – This section indicates that the feedground area is impacted by cattle that are attracted to remnants of hay bales. It should be noted that cattle are trailed through the area and that the attraction is likely the riparian vegetation in addition to leftover hay. In addition, the Alkali area is in a location where cattle drift out of the allotment. Response: The specialist report has been amended, as has the FSEIS, to state that the feedground is in the Upper Gros Ventre cattle allotment and cattle are contributing cumulative impacts in the feedground and the analysis area to those impacts attributable to the elk feedground operations. Cattle attraction to the hay barn is noted due to the concentration of cow feces around the barn.
49. Comment: I think people should take a look up the Greys River and where the cattle and sheep graze all summer, more cows and sheep than grass, nothing left for the wildlife. Response: The Alkali Creek Feedground is located in the Gros Ventre drainage and would not affect cattle and sheep grazing along the Greys River. Fish 50. Comment: Fishery Resources Trout – the Snake River Cutthroat Trout is classified by the WGFD as a Species of Greatest Conservation Need (SGCN) with a Native Species Status (NSS) of 4 in the 2010 State Wildlife Action Plan (SWAP). At the time of the SWAP revision, the Abundance of the SRC was “common within a limited range.” The Population Status was stable and widely distributed throughout its historic range within the Snake River drainage of Wyoming. Response: Table 11 in Chapter 3 of the FSEIS discloses the Forest Service Sensitive and Management Indicator Species (MIS) status for Snake River cutthroat trout required by NEPA. The Wyoming Game and Fish Department classification status for cutthroat trout has been added to the text beginning on page 73 of the FSEIS. Alkali Creek Feedground is in a closed basin system. Runoff drains into the two wetland areas and is absorbed into the ground or evaporated. Forest Service resource specialists use their best judgment to estimate effects when empirical data are not available, such is the case concerning estimates of sediment delivery to waterways from game trails in the analysis area and corridor analysis area. Effects to vegetation resources and streambank and other browsing under Alternative 1 are described in Chapter 3 of the FSEIS.
51. Comment: Fishery Resources Environmental Consequences – The analyses should acknowledge that the Alkali feedground is in a closed basin system. Runoff from the feedground does not occur. Impacts
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Response to Comments from game trails and sediment delivery to waterways should be measured and confirmed before concluding that either alternative would cause it to be better or worse. Additionally, the No Action alternative should note that much of the corridor analysis area is within historic elk winter range, and streambank and other browsing would occur regardless of the feedground, though the distribution would be different and potentially more detrimental. Response: Table 11 in Chapter 3 of the FSEIS discloses the Forest Service Sensitive and Management Indicator Species (MIS) status for Snake River cutthroat trout required by NEPA. The Wyoming Game and Fish Department classification status for cutthroat trout has been added to the text beginning on page 73 of the FSEIS. Alkali Creek Feedground is in a closed basin system. Runoff drains into the two wetland areas and is absorbed into the ground or evaporated. Forest Service resource specialists use their best judgment to estimate effects when empirical data are not available, such is the case concerning estimates of sediment delivery to waterways from game trails in the analysis area and corridor analysis area. Effects to vegetation resources and streambank and other browsing under Alternative 1 are described in Chapter 3 of the FSEIS.
52. Comment: 69, 70 Fishery Resources Amphibians – the Boreal toad is classified by the WGFD as a SGCN, NSS 1. The Columbia spotted frog is an SGCN, NSS3. Response: The Wyoming Game and Fish Department classifications for boreal toad and Columbia spotted frog have been added to the text in the FSEIS beginning on page 75.
53. Comment: 14. Management Indicator Species Not issuing a permit to feed elk at Alkali Creek "would have a long term "beneficial impact" on Snake River cutthroat trout (Forest Service Sensitive Species and MIS) and rainbow trout (MIS). (DSEIS: 72 parentheses and emphasis in original) After removing the structures under Alternative 1, "there is the possibility of long term cumulative very minor positive effects (on amphibians) due to no possibility of disturbing hibernating amphibians in the feedground area." (Ibid, parenthesis added) "Alternative 1 would have a "beneficial impact" for boreal toads." (Ibid: 73, emphasis in original) "The effects of operating the Alkali Creek Feedground with its associated buildings combined with no winter activities including livestock grazing, vehicular use on roads, off road vehicle use, recreation trails, wildlife and livestock trailing, and dispersed camping have an adverse cumulative impact to amphibian habitat." (Ibid: 74) Both winter elk herbivory and summer cattle herbivory reduces aspen regeneration and removes vegetative cover which adversely affects spotted, boreal and chorus frogs, and boreal toads. (Ibid: 74-75 citing Patla 2001 and Barlet 2000 for boreal toad only). To best conserve amphibians and native cutthroat trout, the BTNF must phase out the Alkali Creek Feedground. Response: The purpose of a NEPA document is to analyze and disclose the effects of the proposed and no action alternatives. The text quoted is an example of such analysis and disclosure. The impacts to amphibians and fish are disclosed in Chapter 3 of the FSEIS. The Forest Service agrees with the commenter that not permitting continued use of Alkali Creek Feedground would improve habitat on NFS lands and the No Action Alternative is the environmentally preferred alternative (Draft ROD, page 9).
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Response to Comments
Soils 54. Comment: Soils Indicators – This section describes soil erosion as an indicator of soil quality in the analysis area, but under Active Erosion, does not indicate that erosion was actually measured on the feedground. Response: Measurement of active erosion is included in the soil disturbance protocol and is expressed as part of the percent of detrimental disturbance by alternative. The FSEIS states that no soil displacement was observed.
55. Comment: The feedground sits directly on a large active slide, as can be seen from the air photo (tried to include in text space for online form but didn't work - just look at Google Earth). This makes it susceptible to natural disruption due to the slide (and possible effects on its movement after the Red Rocks Fire), and any loss of vegetation and disturbance of the slide by reducing vegetative cover or cutting into it with roads (as is already occurring) could affect slide movement....“The feedground does not directly overlap habitats such as landslides or slumps” is not a correct statement. Response: Changes have been made in the Soils Specialist Report and the FSEIS to remove the text concerning landslides and slumps. Neither of the two alternatives is expected to affect the potential for landslides or slumps at Alkali Creek Feedground.
56. Comment: Soils-The last paragraph on Pg. 30 states “Soils at this feedground are affected by compaction from elk, horses, and cross country use of the hay wagon Page 31 states “The soil resources in the activity area are moderately compacted due to the current use as an elk feedground, plus cumulative effects from other uses such as cattle grazing.” Descriptions of causes of soil impacts should be consistent and include all relevant factors. Response: Changes have been made in the Soils Specialist Report and the FSEIS to include livestock grazing as a contributor to soils compaction at Alkali Creek Feedground. Errors 57. Comment: Veg Resources Environmental Consequences – The second paragraph states “WGFD has indicated that they would simply move the current feeding operation from Alkali Creek Feedground to land owned by the state of Wyoming at Patrol Cabin Feedground…” Again, Patrol Cabin is owned by the WGFC, not the State. Response: Text was revised in the FSEIS in various locations to correct the ownership of the land at Patrol Cabin Feedground.
58. Comment: 10 Table 1 Issue #13 – States “the state of Wyoming manages elk herd numbers.” Should be edited to read “the Wyoming Game and Fish Department manages elk herd numbers.” Response: This change was made in Table 1 of FSEIS.
59. Comment: Background Paragraph 2 states “Patrol Cabin is operated on state-owned lands.” Patrol Cabin is owned by the Wyoming Game and Fish Commission, not by the State. Response: The text has been corrected in the FSEIS to state that Patrol Cabin Feedground is located on land owned by the Wyoming Game and Fish Commission.
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Response to Comments
60. Comment: Public Involvement Paragraph 1 refers to Patrol Cabin as “state-managed lands.” Patrol Cabin is owned by the WGFC and is managed by the WGFD, not by the State. Response: The text has been corrected in the FSEIS to state that Patrol Cabin Feedground is located on land owned by the Wyoming Game and Fish Commission. Planning Process/Forest Plan 61. Comment: The effects on vegetation and on wildlife by maintaining elk feedgrounds - whether the wildlife are elk that are concentrated on or near feedgrounds or wildlife that are dependent on vegetation types that are heavily browsed or harmed by dense concentrations of elk are not in compliance with LRMP prescriptions for DFC 12. Response: The Management Emphasis in the Management Prescription for DFC 12 (page 242, Bridger-Teton Land and Resource Management Plan) is on “providing such important habitat for big-game as winter ranges, feedgrounds, calving areas, and security acres.” None of the Resource Prescriptions, Standards, and Guidelines provided in the description for DFC 12 (Plan, pages 243–246) explicitly or implicitly preclude the permitting by the Bridger-Teton National Forest of feedgrounds in DFC 12 areas. Moreover, the Fisheries and Wildlife Prescription identified for DFC 12 (page 243) states that habitat will be managed to help meet the game populations, harvest levels, success, and recreation-day objectives … identified by the Wyoming Game and Fish Department and agreed to by the Forest Service.” The Forest Service disagrees that elk feedgrounds are creating conditions that are not in compliance with prescriptions in DFC 12.
62. Comment: We request that our comments submitted earlier in collaboration with Greater Yellowstone Coalition, Wyoming Outdoor Council, and Jackson Hole Conservation Alliance be considered as well as the submission of comments during scoping for this proposal and those in this letter. While earlier comments took a broader perspective of the action under analysis, we have focused more on the wilderness concerns on the Draft Supplemental Environmental Impact Statement for Elk Feedgrounds (DSEIS). Response: The comments you submitted earlier will be considered in this decision process.
63. Comment: Additionally, approving this proposal would be contrary to Forest Service Policy. In the DEIS, the contrast between the effects of the No Action and the Proposed Action Alternatives is limited by the rationale that regardless of the decision on the proposal, the WGFC intends to continue to feed elk on private, state, or other federal lands. Due to the fact that, in so many instances in the DEIS, the effects of the two Alternatives are identical, the Forest Service has demonstrated that it believes that non-NFS alternatives available to the WGFC are basically equivalent to the Alkali Creek Feed Ground with regard to both effectiveness and impacts. Forest Service Policy, in Forest Service Manual (FSM) Title 2700 - Special Uses Management, directs authorized officers to: “deny proposals for uses of NFS lands which . . . can be reasonably accommodated on non-NFS lands”. This Policy also directs authorized officers not to . . . “authorize the use of NFS land just because it affords the applicant a lower cost and less restrictive location when compared with non-NFS land.”(FSM 2703.2) As demonstrated above, the WGFC believes that this use can be “reasonable accommodated” on other private, state of other federal land. The Forest Service shares this belief as evidenced by designing its analysis based on the premise
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Response to Comments that there will be no change in many of the impacts associated with supplemental elk feeding regardless of its decision relative to this proposal. Response: The current Forest Service Handbook (FSH) 2709.11, chapter 10, 11.2, dated 04/15/2011 indicates that initial and second-level screening applies to all proposals to use National Forest Service (NFS) lands except: c. Proposals involving existing rather than proposed uses (36 CFR 251.64). (1) Proposals to replace an authorization that has terminated because the term of the authorization has ended, and continued use does not involve new construction or expanded use or occupancy of National Forest System lands beyond what was previously authorized. In addition, proposals involving existing rather than proposed uses are to be accepted as applications which are not subject to initial and second-level screening. Following is additional handbook direction: 2. Proposals involving existing uses do not have to be submitted as proposals first and then accepted as applications. Rather, proposals involving existing uses are immediately accepted as applications upon submission. In reviewing an application involving an existing use, the authorized officer shall consider: a. Whether the proposed use would conform to the applicable Forest land and resource management plan; b. Whether the area requested is still being used for the purposes for which it is or was authorized; c. Whether the holder is in compliance with the terms and conditions of the authorization; and d. Whether the holder has the technical and financial capability to continue to undertake the use and to fully comply with the terms and conditions of the authorization. On 01/10/2011 the Forest Service Manual (FSM) 2700 zero code was reissued and 2703.2 “Denial of Use” was replaced by “Use of National Forest System lands.” It also removed obsolete criteria that were not consistent with 36 CFR 251.54. In the current Forest Service Manual, the requirements to authorize NFS lands only when the proposed use cannot reasonably be accommodated on non-NFS lands and to not authorize the use of NFS land solely because it affords the applicant a lower cost when compared with non-NFS lands must be considered only when applying the second-level screening criteria regarding public interest (FSM 2703.2). Therefore, since the use of Alkali Creek Feedground is an existing use, a proposal for continued use would automatically be accepted as an application and initial and second-level screening would not apply. Furthermore, direction at 36 CFR 251.64 states the following: (a) When a special use authorization provides for renewal, the authorized officer shall renew it where such renewal is authorized by law, if the project or facility is still being used for the purpose(s) previously authorized and is being operated and maintained in accordance with all the provisions of the authorization. In making such renewal, the authorized officer may modify the terms, conditions, and special stipulations to reflect any new requirements imposed by current Federal and State land use plans, laws, regulations or other management decisions. Special uses may be reauthorized upon expiration so long as such use remains consistent with the decision that approved the expiring special use or group of uses.
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Response to Comments
64. Comment: The BTNF should recognize and accept that previous submissions by GYC and our conservation partners regarding the 2008 DEIS for elk feedgrounds (both scoping comments and DEIS comments) and scoping comments for this DSEIS are part of the administrative record, along with letters and attachments to those submissions. Please also include as part of these comments and the administrative and official record, all the supporting documents and Exhibits accompanying the August 14, 2007 letter to the BTNF Supervisor from Earthjustice concerning scoping for temporary use authorizations analyzing four elk feedgrounds. Also include as part of these comments and the administrative and official record, scoping comments sent to the BTNF on September 17, 2007 for the consideration of issuing 20-year permits for the potential continuation of elk feedgrounds and related activities. Please also include in the administrative and official record any and all other additional comments, materials, references, and/or exhibits that we submit on this issue. We incorporate those comments here. Response: The analysis and the project record for the Alkali Creek Feedground decision includes all information that led to the 2008 Final Environmental Impact Statement (EIS) and Record of Decision (ROD) and this 2015 Final Supplemental EIS and Draft ROD. All comments, materials, references and/or exhibits that the commenters have provided are part of the project record. The majority of the comments submitted regarding previous decisions are specific to those decisions i.e. the Earth Justice comments are specific to a Categorical Exclusion level decision that had to do with temporary permitting of feeding and a test and slaughter facility, neither are part of the present decision to be made. Some of the general comments in the previous submissions are germane to the present decision. To address those, the previous submissions were reviewed and relevant topics addressed as they apply to the present decision. 1. Comments about chronic wasting disease are addressed in Johnson 2014 (CWD literature review technical report) which is Appendix 7 of the SFEIS. 2. Comments about brucellosis are addressed in the Wildlife section of the FSEIS and associated specialists reports (FSEIS, page 83 and pages 106-112 and 114-117). 3. Lungworm effects are covered in the FSEIS. 4. Impacts to vegetation are disclosed in the FSEIS and associated specialists reports. 65. Comment: Just as we did with the March 2008 DEIS for the Wyoming Game and Fish Commission’s Winter Elk Management Programs written by the BTNF, we find that this April 2013 DSEIS which focuses on the Alkali Creek elk feedground continues to be legally deficient, prepared without incorporating adequate information, and not in compliance with the National Environmental Policy Act (NEPA), and other laws and legal directives. It is apparent in reading this DEIS that few if any of the scientific materials and reports submitted by the conservation groups were considered by the BTNF, much less recognized for their value and applied. Yet at least 9 reports from the feedground proponent, the Wyoming Game and Fish Department and/or Commission are included in the DSEIS Reference Section (R-7, 8). While some of the reports from the Game and Fish do contain pertinent information, and we avail ourselves of some of their reports as well, the obvious bias of the BTNF to use the proponent’s
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Response to Comments information and not use relevant information that consists of valuable contemporary science and expert opinion suggested by the public interest groups speaks volumes about the bias and predetermination of the BTNF to favor permitting elk feedgrounds rather than transition to a healthy management paradigm without elk feedgrounds. It is readily apparent in many aspects of this DSEIS, just as in the 2008 DEIS for elk feedgrounds, that the BTNF dismisses or assigns far less importance to expert professional opinion and best available science that is contrary to the dogma of the Wyoming Game and Fish Department and Commission concerning wildlife disease and elk feedgrounds. Below we point out the apparent undue influence exerted by the WGFD by their disproportionate representation on the ID Team. The DSEIS is replete with examples where the BTNF uses rationale that parrots the opinion or policy of the WGFD rather than expressing the overwhelming preponderance of expert opinion and science that counsels discontinuation of winter elk feedgrounds. Virtual unanimity exists among North American wildlife professionals and scientists that winter feeding of big game should not occur, especially in or near areas of endemic transmissible diseases which is the case on and near the Bridger-Teton Forest. The BTNF is most definitely a high risk area for Chronic Wasting Disease to appear and conditions on elk feedgrounds would most likely amplify the prevalence of CWD in elk causing concomitant effects in other cervids throughout the extensive geographic range of the Jackson Elk Herd and beyond. We have provided strong evidence of these facts in our comments and references and it is most unfortunate that the BTNF has chosen to ignore the best available science and the best scientific opinion and continues to rationalize permitting elk feedgrounds in the Gros Ventre Valley and elsewhere. Certainly not the standard of "excellence" touted by their Vision Statement. Response: The Forest Service has the responsibility to solicit cooperation for other federal, tribal, state or local agencies with jurisdiction by law or special expertise on environmental issues that should be addressed in the environmental analysis (Forest Service Handbook (FSH) 1909.15 Section 11.31b). Invited agencies may cooperate in the analysis and may be included in the interdisciplinary team. (Ibid.) The Forest Service is required to reduce duplication of effort by cooperating with state and local agencies to the fullest extent possible when analyzing environmental effects of proposed projects (FSH 1909.15 Section 11.32). The Forest Service and WGFD relationship in this analysis is guided by a Cooperating Agreement and by the Project Initiation Letter that are filed in the project record. The Forest Service independently evaluated the information WGFD provided. The Forest Range Program Manager (Dave Cottle) and the Regional Range Ecologist (Dave Tart) reviewed the WGFD vegetation analysis and confirmed it met standards. The Project IDT Leader (Pam Bode) reviewed the WGFD CWD information and conferred with employees of USDA Animal and Plant Health Inspection Service (APHIS) concerning its accuracy. The APHIS employees provided additional CWD references. The Forest Service determined that the WGFD CWD information should be supplemented by the information provided by APHIS and the DSEIS commenters. A compendium of CWD information was prepared, was considered by the Forest Supervisor in the Draft Record of Decision (Draft ROD) and is included as Appendix 7 in the FSEIS. The 2008 FEIS and the 2012 DSEIS erred by listing up to five Wyoming Game and Fish Department employees as Interdisciplinary Team (IDT) Members. The FSEIS has been revised to correct the list of Interdisciplinary Team Members and add a list of preparers (FSEIS, Chapter 4). The IDT included one
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Response to Comments
WGFD biologist. That member was Scott Smith from the projects initiation to November 18, 2013. Scott Smith was replaced by Doug Brimeyer on November 18, 2013.
66. Comment: Having so many of the WGFD personnel on the ID Team amounts to undue influence from the proponent 40 C.F.R. § 1506.5 Agency responsibility. (a) Information. If an agency requires an applicant to submit environmental information for possible use by the agency in preparing an environmental impact statement, then the agency should assist the applicant by outlining the types of information required. The agency shall independently evaluate the information submitted and shall be responsible for its accuracy. On page 153 of the DSEIS it lists by name 17 members of the ID Team. We assume that “ID” means “Interdisciplinary Team”. It also lists the agency and title of each member of the ID Team. Twelve members are employed by the USFS, and there are five members employed by the proponent, the Wyoming Game and Fish Department (WGFD). (Earlier in the DSEIS the BTNF states that it is the Wyoming Game and Fish Commission (WGFC) that is the proponent, In this context it is apparent that the WGFD is aligned with and indeed does the work of the civilian governor-appointed WGFC.) Four of the five WGFD employees are elk feedground specialists: Feedground Supervisor, Brucellosis Feedground Habitat Biologists (2), and a Brucellosis-Feedground-Habitat Supervisor. Given that the entire 2008 DEIS and this 2013 DSEIS appear to strongly favor elk feedgrounds and consistently defer to the WGFD for information favoring elk feedgrounds, disregarding other available science and information offered by GYC and others (see below and elsewhere in these comments), the ID Team and the outcome of these EIS’s are obviously and unduly influenced by the WGFD. While we are familiar with the agreement between the USFS Rocky Mountain Region and Intermountain Region and the Wyoming Game and Fish Commission, 00-MU-11020000-052, such an MOU does not have the force of law and serves only as a guideline. We recognize the value of federal agencies consulting with state agencies, in this case the USFS with the WGFD. Yet the law cited above requires that the BTNF exercise its authority and conduct the analysis independently. It is worth noting that besides BTNF employees no representatives from any other entity such as non-governmental organizations, or academic institutions, sit on the ID Team, only five employees of the proponent, the WGFD. See below our comments regarding the absence of the USFS’ own sister agency, APHIS in this analysis. If the ID Team acts as the leaders in crafting this NEPA document which is supposed to comply with the National Environmental Policy Act, that Act requires that the decision not be a foregone conclusion and that there be a reasonable range of alternatives (see our comments below). It also requires that the Purpose and Need not be constrained so as to effectively eliminate any other outcome other than the one most desired by the proponent (see our comments below). The BTNF has violated NEPA by allowing the WGFD to exert undue influence on the process, content and outcome of this EIS. Response: The Forest Service has the responsibility to solicit cooperation for other federal, tribal, state or local agencies with jurisdiction by law or special expertise on environmental issues that should be addressed in the environmental analysis (Forest Service Handbook (FSH) 1909.15 Section 11.31b). Invited agencies may cooperate in the analysis and may be included in the interdisciplinary team. (Ibid.) The Forest Service is required to reduce duplication of effort by cooperating with state and local agencies to the fullest extent possible when analyzing environmental effects of proposed projects (FSH 1909.15 Section 11.32). The Forest Service and WGFD relationship in this analysis is guided by a Cooperating Agreement and by the Project Initiation Letter that are filed in the project record.
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Response to Comments
The Forest Service independently evaluated the information WGFD provided. The Forest Range Program Manager (Dave Cottle) and the Regional Range Ecologist (Dave Tart) reviewed the WGFD vegetation analysis and confirmed it met standards. The Project IDT Leader (Pam Bode) reviewed the WGFD CWD information and conferred with employees of USDA Animal and Plant Health Inspection Service (APHIS) concerning its accuracy. The APHIS employees provided additional CWD references. The Forest Service determined that the WGFD CWD information should be supplemented by the information provided by APHIS and the DSEIS commenters. A compendium of CWD information was prepared, was considered by the Forest Supervisor in the Draft Record of Decision (Draft ROD) and is included as Appendix 7 in the FSEIS. The 2008 FEIS and the 2012 DSEIS erred by listing up to five Wyoming Game and Fish Department employees as Interdisciplinary Team (IDT) Members. The FSEIS has been revised to correct the list of Interdisciplinary Team Members and add a list of preparers (FSEIS, Chapter 4). The IDT included one WGFD biologist. That member was Scott Smith from the projects initiation to November 18, 2013. Scott Smith was replaced by Doug Brimeyer on November 18, 2013.
67. Comment: The BTNF’s claims of not being able to affect management of elk on USFS land is false Time and again in this DSEIS the BTNF tries to escape their authority and responsibility to protect habitat on USFS lands by claiming that they do not have the ability to stop or affect winter feeding of elk in western Wyoming (DSEIS: iii, 8, 9, 10, 48, 96, 101, 149, 150 and elsewhere). For example, “(T)he Forest Service does not have the jurisdiction to stop elk feeding.” (Exec Summary iii) As in the 2008 DEIS, this oft repeated assertion by the BTNF indicates to the reader and the public that no other reasonable option exists for the BTNF than to permit elk feedgrounds. This is specious reasoning and unfortunately, using exactly this sort of rationalization, the BTNF re-permitted five elk feedgrounds for 20 years each in 2008. Given the history of the BTNF conducting legally deficient environmental analyses for elk feedgrounds on USFS lands and re-permitting them without adequate consideration of input from conservation groups and the public, it strongly indicates that this DSEIS is, again, considered little more than paperwork and the outcome is, as it was in 2008, predetermined. Additional indications that the outcome is predetermined were voiced on May 13, 2013 when NGO’s and the BTNF met in person, on video and on conference line to discuss this DSEIS. Two BTNF staff said “when” the feedground permit at Alkali Creek is issued it would only be for 15 years instead of 20. We were definitely not told “if” the permit is issued, but when. The BTNF does indeed have the authority and jurisdiction to affect the management of wildlife and habitat on USFS land and, even more specifically, it has the authority and jurisdiction to affect whether the WGFD feeds elk on USFS lands on the BTNF. The BTNF seems to tentatively and partially acknowledge as much when it states, “Forest Service regulations require authorization for use and occupancy of National Forest System lands.” (Exec Summary i) but then repeatedly rationalizes away their ability or more likely their will to implement such authority and jurisdiction by saying it makes no difference because the WGFD will feed somewhere anyway. The BTNF has exercised that authority and jurisdiction on USFS land, albeit in a small way, in the past (ca 2002) by preventing the WGFD from conducting its winter elk feeding operations on USFS lands adjacent to the Patrol Cabin elk feedground in the Gros Ventre Valley. The WGFD had repeatedly trespassed from State Land onto USFS land near Coalmine Draw in the Gros Ventre Valley while distributing hay from horse
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Response to Comments drawn sleighs to elk during winter feeding operations. The BTNF notified them that they were in trespass and were prevented from doing so in the future without proper authorization. The WGFD subsequently ceased unauthorized trespass. This example shows that the BTNF clearly has the authority to determine what wildlife management practices occur on USFS land within the B-T forest boundaries, has implemented such authority in the past and can do so in the future and, while not a requisite, even the WGFD understands this. And, perhaps most remarkable, the BTNF did not simply rationalize away any purpose for holding the WGFD accountable by saying the WGFD will feed anyway, so what’s the use? In that context, which is at issue here, the BTNF can, indeed, prevent feeding of elk on USFS lands. It is a false binary argument for the BTNF to lament that feeding will occur elsewhere and allegedly affect many of the forest values nonetheless if they do not permit winter elk feedgrounds where the WGFC requests. The issue is not what the WGFC wants or will do elsewhere, the main issue is how best to protect forest resources including wildlife and habitat. The most important issue(s) are not to be defined by the WGFD, but by the BTNF. As we commented on the 2008 DEIS, and applies here: “(W)hether or not the BTNF ever received a declaration from the WGFC that it intends to operate elk feedgrounds on other jurisdictions regardless of receiving SUPs from the USFS (the communication documentation was not revealed in the DEIS), it does not relieve the BTNF of its duties and responsibilities to manage the resources on USFS lands in a manner which protects the environment and mitigates impacts harmful to the environment. Whether healthy, harmful, or benign activities occur on adjacent, nearby, or distant lands does not diminish the responsibilities and duties held by the USFS through acts of Congress. Nor do such activities allow the USFS to deflect the responsibilities assigned to it by Congress onto other parties, such as the WGFC. If the mere existence of - or the threat of - harmful activities beyond USFS lands was justification or impetus for the USFS to permit such activities on USFS lands, it would open the door to any number of harmful activities occurring on USFS lands merely upon threat, coercion, implementation of such acts on other lands, or insinuation of intent to do so by any proponent. This would effectively remove the assurance to the American public that the USFS acts as stewards of these public lands. A duty clearly lacking fulfillment here.” (NGO’s 2008 comments: 8) “(T)he BTNF also has no reason to convince, enable, or solicit the WGFC to operate elk feedgrounds on USFS lands rather than on these other lands. By the BTNF’s own reasoning, not allowing these elk feedgrounds on USFS lands, “improves habitat . . .” on USFS lands, whereas allowing these elk feedgrounds and associated activities on USFS lands “maintains . .”, or , “increases [the] amount of degraded habitat . . .” on USFS lands (DEIS:23). It would best serve the American public and clearly better protect USFS resources for the BTNF to bow out of permitting WGFC elk feedgrounds completely. (Ibid: 9) While we are aware of the Memorandum of Understanding between the USFS and the WGFC, 00- MU-11020000-052, this MOU is a two-way pledge to collaborate on areas of mutual interest and is not enforceable as prevailing law. The BTNF should not refer to it repeatedly as if were prevailing law and closes the door on discussing, analyzing, or implementing options of resource management other than status quo. This MOU does not divest the BTNF of their legal directives, duties, authority and jurisdiction. As the MOU itself states in part, it merely recognizes “areas of cooperation and coordination.” The BTNF has, by permitting elk feedgrounds, turned a blind eye for decades to harmful actions on USFS land resulting from elk feedgrounds. If the BTNF were not to permit elk feedgrounds on USFS lands, it would position itself to better defend USFS resources against the effects of elk
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Response to Comments feedgrounds elsewhere. Just as if pollutants were being discharged onto USFS lands from a source nearby on another jurisdiction, the USFS would be expected to effectively protect the land it stewards in trust for the American people. Unfortunately, as a permitter of elk feedgrounds, the BTNF, the only forest in the Rocky Mountain area to permit this kind of wildlife program on this scale, has essentially become complicit in causing harm to soils, plant communities, and wildlife and has allowed for elevated risk to elk and other cervids from debilitating and deadly diseases for decades. This is not managing resources in the public trust for the public’s benefit, is not in compliance with law and cannot continue. Under the Multiple Use Sustained Yield Act (Public Law 86-517) “It is the policy of the Congress that the national forests are established and shall be administered for outdoor recreation, range, timber, watershed, and wildlife and fish purposes . . . . “and “The Secretary of Agriculture is authorized and directed to develop and administer the renewable surface resources of the national forests for multiple use and sustained yield of the several products and services obtained therefrom . . . .” The Act goes on to say that Multiple Use is defined in part as “the management of all the various renewable surface resources of the national forests so that they are utilized in the combination that will best meet the needs of the American people,” and Sustained Yield is defined in part as ‘in perpetuity” and “without impairment of the productivity of the land.” The US Forest Service achieved clarification of its powers and duties to protect habitat early on from the U.S. Supreme Court in 1928 in Hunt v. U.S. 278 US 96. After acting at odds with the State of Arizona by removing deer that were, by their excessive numbers promulgated by the state’s management of wildlife, injuring habitat and promoting starvation among their kind, the Supreme Court “summarily upheld the federal government’s power to govern its land.” (Freyfogle and Goble, Wildlife Law, 2009:2012) “The power of the United States to thus to protect its lands and property does not admit of doubt . . . . the game laws or any other statute of the state to the contrary notwithstanding. “ (Ibid) The BTNF should not repeatedly convey to the public in this DSEIS (DSEIS: iii, 8, 9, 10, 48, 96, 101, 149, 150 and elsewhere), as it did in the 2008 DEIS, that it does not have the ability to significantly influence the management of wildlife and habitat on USFS lands and to steer programs, such as the State of Wyoming’s “Winter Elk Management Activities” (aka, elk feedgrounds), away from inflicting harm and perpetuating unhealthy practices on USFS lands. “In 1976, in Kleppe v. New Mexico, . . . . The U.S. Supreme Court ruled that the federal government possessed almost unlimited sovereign power to manage the lands that it owned, in addition to its powers as landowner. If it wanted, the federal government could enact its own laws governing all aspects of hunting, fishing, and wildlife management, leaving no role for state laws or agents.” (Freyfogle and Goble, Wildlife Law, 2009:206) It is disingenuous of the BTNF in their EIS to indicate to the public that the BTNF is constrained to merely continue the status quo because of the preferences, policies or threats from the WGFC. They are not. The BTNF must manage the National Forest lands and natural resources for the benefit of the most people for the longest time. As the BTNF has found out from other comment opportunities, (as did the USFWS in their public comments received on the Bison and Elk Plan) far more citizens are in favor of phasing out elk feedgrounds than continuing them. “(F)eedgrounds like predator control policies, reflect a longstanding cultural and political bias- a bias that continues to trump science and defy common sense. “ (Donahue 2010:293) That bias and absence of common sense must be turned around by the BTNF. It’s high time to pay attention to the prevailing and overwhelming body of science and law, and inject common sense to find a much better way forward. According to their Vision
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Response to Comments
Statement, the BTNF is allegedly committed to “service, action and excellence”; transitioning away from the elk feedgrounds is an opportunity for them to display and implement these commendable traits. Response: While the Forest Service has the authority to decide whether or not to authorize the Wyoming Game and Fish Commission (WGFC) to use National Forest System (NFS) lands for the operation of feedgrounds, it is the WGFC, not the Forest Service, which decides whether or not there will be an elk feeding program in northwest Wyoming. The language in the FSEIS was included to explain that the Forest Service does not have the authority to stop WGFC from operating feedgrounds on state, Bureau of Land Management, private or other lands. Text in the FSEIS has been changed to clarify any misunderstanding in this regard. The Forest Service is required to consider the effects of the “no action” alternative, in this case if the Forest Service were to choose not to authorize the use of NFS land at Alkali Creek for operation of a feedground. For purposes of that effects analysis, it was our conclusion that elk feeding, and the effects of elk feeding, would likely continue at other feedgrounds on NFS lands and on land that is not administered by the Forest Service.
The decision as to whether or not to authorize continued use of NFS lands for the Alkali Creek Feedground will be made by the Forest Supervisor, based on the analysis prepared by agency staff. The criteria to be considered by the Forest Supervisor in making a decision is set forth in the Draft Record of Decision distributed with this FSEIS, which explains the rationale for the Forest Supervisor's proposed decision.
The Forest Service agrees with the commenter that not permitting continued use of the Alkali Creek Feedground would improve ecological conditions on NFS lands in the immediate vicinity of the feedground. The No Action Alternative is the environmentally preferred alternative due to the potential improvement of localized effects in the area of the feedground (FSEIS, page 49).
68. Comment: Purpose and Need at Purpose and Need for Action (SDEIS: 5) the BTNF defines the analysis from the narrow perspective of the project proponent, the Wyoming Game and Fish Commission (WGFC). As the conservation groups have repeatedly said, by framing this analysis and options only in the context of the desires of the WGFC the Forest Service forecloses on a reasonable range of diverse alternatives, some of which had repeatedly been suggested by conservation groups during scoping for the 2008 Winter Elk Management (aka, feedground) EIS and in the same groups’ comments on the 2008 DEIS and in May 2012 scoping for this SDEIS. While considering a SUP for a feedground, the BTNF could have done an environmental impact analysis titled “Healthy Elk Management in the Gros Ventre Valley”. Describing and giving careful consideration to other alternatives than feedgrounds would have enabled the forest to move toward healthier habitat: less soil compaction, no overbrowsed vegetation, no eroded streambanks, far less risk of buildup of infectious prions in the soil and water by large numbers of artificially concentrated elk and healthier wildlife, lower potential for disease transmission, more natural elk movements and foraging, elimination of heavy-handed management through vaccination and test-and- slaughter programs, and no adverse effects on Wilderness. As evidenced elsewhere on the BTNF and, indeed, on all other National Forests in the Rocky Mountains, feedgrounds are not necessary to manage elk. In fact, nearly all other elk herds in the Rockies are healthier and under less risk of catastrophic diseases compared to feedground elk. Courts’ interpretation of NEPA’s requirements are clear: “[A]n agency may not define the objectives of its action in terms so unreasonably narrow that only one alternative . . . would accomplish the goals of the agency's action…[as] the EIS would become a foreordained formality” Citizens Against Burlington, 938 F.2d at 196. The BTNF has shined the narrowest light possible when they defined the range of alternatives as “whether or not to authorize WGFC to use NFS lands at Alkali Creek Feedground for
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Response to Comments corrals, sheds, one hay stack-yard containing two hay sheds, a water facility and feeding grounds associated with their ongoing elk feeding and management programs." (BTNF 4-24-12 Scoping Notice) This definition of purpose is the narrowest imaginable and may suit the proponent (the WGFC), but does not comply with legal directives under which the USFS is required to operate; nor does it serve the public interest by putting forth a reasonable range of alternatives that may benefit the public through the analysis and eventual implementation of appropriate stewardship and protection of the largest amount of public lands, waters, and wildlife possible befitting the most people and natural resources for the longest amount of time. The obvious fact that the BTNF refers to this location as “NFS lands at Alkali Creek Feedground” plainly indicates the matter is, in the minds of the BTNF, a foregone conclusion (DSEIS:6). The BTNF apparently believes that this area of USFS lands is above all else an artificial feedground. Because the stated purpose and need for a federal action determines the range of alternatives, it is essential that the Forest Service clearly articulates the project’s purpose and need from the USFS’ perspective and not simply adopt the WGFC objectives for the project as its own. (40 C.F.R. § 1502.13). As courts have cautioned, “One obvious way for an agency to slip past the structures of NEPA is to contrive a purpose so slender as to define competing ‘reasonable alternatives’ out of consideration (and even out of existence.)” Davis v. Mineta, 302 F.3d 1104, 1119 (10th Cir. 2002) (quoting Simmons v. United States Army Corps of Eng’rs, 120 F.3d 664, 669 (7th Cir. 1997). As a defense of their inadequate range of alternatives and narrow Purpose and Need, the BTNF offers a history of elk management in western Wyoming: “Supplemental feeding of elk has been conducted in Wyoming since the early 1900’s.” (SDEIS: 2) It goes on to offer examples. This kind of rationale ignores the progress of science-based wildlife management in the more than 100 years since. Such rationale is also at odds with the part of the BTNF’s Mission Statement (which we will address below) at, “We aim to be progressive leaders in natural resource management.” The wildlife and habitat of the Gros Ventre Valley and, indeed, of the entire BTNF deserve and require a more enlightened perspective than harkening back to frontier era methods, as well intended as they may have been for the time. The duty of the BTNF is to enable healthy wildlife on healthy habitat, not to enable an artificial feedground regardless of the consequences. A better Purpose and Need could be: “To Ensure Healthy Wildlife and Habitat in the Gros Ventre Valley.” As we have explained above and in other submissions to the BTNF, the need for an elk feedground, per se, does not exist for the Forest Service. The Wyoming Game and Fish Commission, who may want an elk feedground, is not held to the same legal or ecological standards as the federal USFS. And the WGFC does not control the land where they are requesting the feedground, the USFS does. “The state of Wyoming has spent millions of dollars on supplemental feeding, which maintains artificially high populations of elk . . . . “ (Donahue 2010:289) A 2005 proposal from three NGO’s to phase out eight elk feedgrounds promised an annual savings of $352,000, and $3.52 million over ten years. (GYC, et al, 2005) Enabling free-ranging elk would be cheaper and less labor intensive and will serve the elk and other wildlife and natural resources far better than promulgating expensive and harmful feedground conditions. It will be healthier all around and meet the legal directives of the USFS for the BTNF to phase out elk feedgrounds on USFS land rather than continue to permit them. Response: As explained in the FSEIS (page 5), the Forest Service is not making a decision about whether or not there should be an elk feeding program in northwest Wyoming. As the agency with primary responsibility for management of elk populations, WGFC has determined that it is going to operate an elk feeding program on state, private, and BLM land. WGFC has also asked to continue to use National Forest System land for some of its
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Response to Comments feedgrounds, and the Forest Service is responding to this request in accordance with regulations at 36 CFR 251.54. The purpose and need was framed around this proposed federal action, and concerns whether to authorize WGFC to use National Forest System land for some if its feedgrounds and, if so, under what terms and conditions the use will be authorized.
69. Comment: Failure to develop and consider a reasonable range of Alternatives violates NEPA This SDEIS suffers from many of the same violations of law as the 2008 EIS; this SDEIS did not analyze an adequate range of reasonable alternatives. “The purpose of an EIS is to apprise decision makers of the disruptive environmental effects that may flow from their decisions at a time when they ‘retain a maximum range of options’ to avoid environmental harms” (Connor v. Burford, 848 F.2d 1441, 1446 (9th Cir. 1988) quoting Sierra Club v. Peterson, 717 F.2d 1409, 1414 (D.C. Cir. 1983)). NEPA mandates that the Forest Service provide a detailed statement regarding the alternatives to a proposed action (42 U.S.C. § 4332(2)(C)(iii)). Its implementing regulations also require the Forest Service to “[r]igorously explore and objectively evaluate all reasonable alternatives” (40 C.F.R. § 1502.14). The agency must satisfy its “obligation to consider every significant aspect of the environmental impact of a proposed action” and “inform the public that it has indeed considered environmental concerns in its decisionmaking process” (Baltimore Gas and Elec. Co. v. Natural Resources Defense Council, 462, U.S. 87, 97 (1983)). In fact, a thorough and objective analysis of alternatives is so essential to reasoned and informed decision making that discussion of alternatives is considered the “heart of the environmental impact statement” 40 CFR at § 1502.14(a). NEPA requires agencies to “study, develop, and describe appropriate alternatives to recommended courses of action in any proposal that involves unresolved conflicts concerning alternative uses of available resources” 42 U.S.C. § 4332(E); 40 C.F.R. 1508.9(b). Moreover, the BTNF “shall” “to the fullest extent possible …use the NEPA process to identify and assess the reasonable alternatives to proposed actions that will avoid or minimize adverse effects of these actions upon the quality of the human environment.” 40 C.F.R. § 1500.2(e) (emphasis added). "Section 1502.14 of NEPA requires the EIS to examine all reasonable alternatives to the proposal. In determining the scope of alternatives to be considered, the emphasis is on what is "reasonable" rather than on whether the proponent or applicant likes or is itself capable of carrying out a particular alternative. Reasonable alternatives include those that are practical or feasible from the technical and economic standpoint and using common sense, rather than simply desirable from the standpoint of the applicant. . . . An alternative that is outside the legal jurisdiction of the lead agency must still be analyzed in the EIS if it is reasonable." (NEPA's 40 Most Asked Questions, at http://ceq.hss.doe.gov/nepa/regs/40/40p3.htm) The DSEIS considers only two alternatives: the “No Action and the Proposed Action.” (DSEIS:13) “Under the No Special Use Authorization Alternative, use of National Forest System lands for WGFC winter elk management activities would not be permitted at Alkali Creek Feedground.” (Ibid: 14) “The Agency’s Preferred Alternative under the Proposed Action alternative, a Special Use Authorization would be reissued for continuation of use of 91 acres of National Forest System lands for WGFC winter elk management activities at Alkali Creek Feedground.” (Ibid) By only including 2 alternatives despite repeated and clear recommendations from conservation groups to include other alternatives, the Forest Service failed to consider a reasonable range of alternatives violating the National Environmental Policy Act. In the September 17, 2007 scoping comments from Greater Yellowstone Coalition, Jackson Hole Conservation Alliance, and the Wyoming Outdoor Council several reasonable alternative components
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Response to Comments were suggested for inclusion by the BTNF for the 2008 DEIS concerning permits for multiple elk feedgrounds. GYC offered many of the same suggestions in our May 2012 scoping comments for this Alkali Creek SDEIS. We offer that 2007 section again here in our comments on the DSEIS to remind the BTNF what has been submitted in the past and what we deem is necessary now for the BTNF to comply with NEPA and offer a reasonable range of alternatives in any EIS dealing with elk feedgrounds: Some components needed in alternatives When analyzing a range of alternatives to elk feedlots, the BTNF must include analyses of elk transitioning to completely using natural forage on big game winter ranges to survive the winters. Maps of big game winter ranges designated by the USFS, NPS, FWS, BLM, and WGFD can be obtained from the WGFD; the winter ranges consist of many tens of thousands of acres and may spread across USFS, NPS, FWS, BLM, State and other lands. Winter ranges adjacent to current feedlot sites as well as winter ranges at reasonable distances from feedlot sites must be considered, as should the feasibility of the elk to access those ranges. The BTNF must assess the amount of forage on designated winter ranges left after the growing season that may be used by big game during winter. They must calculate the tonnage of forage using scientifically valid production plots, or use available information that may be applied to similar slopes, elevations, snow pack, and vegetation types as exist on the various winter ranges. Most importantly, the USFS should calculate the ability of that amount of forage to sustain the estimated number of elk using the range (i.e., carrying capacity). If any of those winter ranges are included in summer livestock grazing allotments, the BTNF must assess whether adjustments to livestock grazing management may allow for more forage left for wintering big game on the winter range portions of those allotments. For any unoccupied, vacant, or closed livestock allotments the BTNF must analyze how much of an increase of winter forage is available for wintering big game due to the absence of livestock use. The BTNF must include in its alternatives pragmatic step by step plans to end feeding of elk at all the feedlot sites and transition those elk to native range. Besides forage assessments and carrying capacity estimates, these plans must include, but not be limited to identification of and mitigation plans for preventing wintering livestock from commingling with elk, and preventing private property damage by elk to haystacks and livestock fences that exist on private lands. Mitigation plans must include elk-proof fencing to prevent commingling and damage to haystacks, and funding sources for such projects. Some of these fences may best be located on USFS or other public lands in order to expedite the mitigation against commingling. Even though these fences need to be elk-proof, they may be of a kind that is entirely or partially removable or otherwise adjusted during the summer months to allow passage of wildlife, livestock, and people. The elk fence near Soda Lake feedlot near Pinedale may offer some ideas, although there are many other types of fencing available. It is important when considering elk-proof fencing that consideration is given to not impeding trans-landscape movement of big game. Therefore, a minimum amount of fencing is desirable and fencing as close to the livestock feeding and haystack areas as possible to be effective would ameliorate this issue. The BTNF should also do a cost analysis for phasing out specific feedlots or several at a time if they are near one another, compared with the costs of maintaining the elk feedlots. Included in that cost analysis should be the elimination of vaccinating elk against brucellosis which would no longer be needed. It is a cost savings to phase out the feedlots, even considering initial costs such as fencing, rather than maintaining feeding and vaccinating at elk feedlots in the long term (see Brucellosis Solution 2005). The costs of maintaining brucellosis to various stakeholders such as livestock producers, the
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WGFD, and others should also be quantified as best as possible in order to truly realize the costs of elk feedlots, and the savings when feeding and vaccinating is phased out and brucellosis is no longer a problem for elk or livestock. This will greatly assist the BTNF in analyzing reasonable alternatives to artificially feeding elk at state operated feedlots. A wide range of alternatives is necessary in order for the public and decision makers to draw informed conclusions. Regarding elk-proof fencing alluded to above; the USFS has their own 1993 report from the Pacific Northwest Research Station describing techniques to construct elk-proof fences. (USDA-FS 1993, see citation in Reference section appended to these comments.) The BTNF could have developed and analyzed one or more reasonable and practical, and common sense, alternatives that carefully transition elk from artificial feeding to reliance on native range, while protecting hunting, outfitting, and ranching interests. Because the Forest Service failed to analyze a true range of alternatives, the record of decision risks becoming a foreordained formality and violates NEPA. Clear evidence of the inclination of the BTNF to approve a permit for the WGFD for an elk feedground without required consideration of a range of alternatives is the repeated assertion by the BTNF that if a feedground isn’t permitted by the BTNF on USFS land, “the WGFC would either continue to feed elk in the Gros Ventre only at Patrol Cabin and Fish Creek Feedgrounds or they would locate a new feedground on private or state land.” This assertion by the BTNF appears repeatedly throughout the DSEIS. But the BTNF doesn’t provide the document or method of communication of such assertion by the WGFC of the possibility of yet another site for a feedground despite requested to provide the documentation by GYC. In the DEIS and ROD in 2008 and again in the 2013 DSEIS the BTNF repeats this statement so many times there is no reason to believe that the BTNF seriously considered any other options or alternatives other than approving a Special Use Permit for feedgrounds for the WGFC. The BTNF appears to be taking the threat or assertion, if it exists, by the WGFC as effectively foreclosing on other options of managing elk and habitat in the BTNF. Despite denying it in their DEIS comment responses in 2008, the BTNF apparently sees no other options but continuing the status quo. As we wrote in our May 2012 scoping comments: “Whether healthy, harmful, or benign activities occur on adjacent, nearby, or distant lands does not diminish the responsibilities and duties held by the USFS through acts of Congress. Nor do such activities, like the State of Wyoming elk feedgrounds, allow the USFS to deflect the responsibilities assigned to it by Congress onto other parties, such as the WGFC. If the mere existence of - or the threat of - harmful activities off USFS lands was justification or impetus for the USFS to permit such activities on USFS lands, it would open the door to any number of harmful activities occurring on USFS lands merely upon threat, coercion, implementation of such acts on other lands, or insinuation of intent to do so by any proponent. This would effectively remove the assurance to the American public that the USFS acts as stewards of these public lands. Therefore the BTNF must not be swayed by the WGFD’s inclination and tradition of maintaining elk feedgrounds in western Wyoming. The BTNF has more important and binding directives to comply with.” If the BTNF did not approve a SUP for elk feedgrounds, they would be in a far better position to become an advocate for healthy habitat and healthy wildlife rather than a passive bystander. They could then far better defend against any adverse effects of elk feedgrounds, of which there are many, that may cross over from elk feedgrounds on state or private land onto USFS land. Currently, by permitting elk feedground SUP’s the BTNF enables possibly the worst wildlife management program to continue. Offering a permit to feed wildlife does not move towards a solution to the problems of disease and habitat degradation, it merely
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Response to Comments perpetuates the problems. The BTNF has, so far, ignored all the suggested solutions, such as phasing out feedgrounds, offered by the public interest groups. Response: The elk feeding program is conducted by the Wyoming Fish and Game Commission (WGFC) to accomplish its agency mission. It would be within WGFC's purview, not the Forest Service's, to consider transitioning elk to natural forage instead of feeding them in the winter. The Forest Service recognizes WGFC as the agency with the authority, jurisdiction, and responsibility to manage, control, and regulate fish and wildlife populations in NFS lands unless federal law specifically supersedes such authority (FS Agreement 00-MU-11020000-052). It is entirely within WGFC's jurisdiction to decide whether or not to feed elk in western Wyoming. The question for the Forest Service is whether or not to authorize WGFC to use National Forest System (NFS) lands near Alkali Creek for one of its feedgrounds. As discussed in the FSEIS, WGFC has indicated that the feeding program will continue, whether or not the Forest Service authorizes use of the site at Alkali Creek. The analysis and alternatives were developed to allow the Forest Supervisor to make a reasoned decision about whether or not to authorize the use of NFS land by WGFC for one feedground.
70. Comment: In regards to the Alkali Feedground Permit Renewal. I am irritated to think that the Forest Service has got to go through a comment period and had to do an analysis. In the first place, Kniffy Hamilton should have renewed the special use permit when it came up for renewal. But everyone is afraid of a lawsuit by the radical environmental community. Response: The decision concerning the Alkali Creek Feedground was not included in the 2008 Record of Decision because the 2008 EIS did not include the information Forest Supervisor Hamilton needed. She directed Jackson District Ranger Deiter to order a wilderness boundary survey and to cooperate with Wyoming Game and Fish Commission to perform a more detailed survey of vegetation effects inside the wilderness adjacent to the existing feedground. The 2015 FSEIS provides the information, in addition to other information about circumstances that have changed since 2008.
71. Comment: Just as we quoted the BTNF Vision Statement at the beginning of these comments, we approach the conclusion of our comments with the Mission Statement for the BTNF: "The employees of the Bridger-Teton National Forest are dedicated to sound natural resource management. We care for the land by improving and maintaining healthy Forests and rangelands, clean air and water, and diverse habitat for fish and wildlife populations. We serve the people by encouraging responsible use of the resources our Forest provides. We aim to be progressive leaders in natural resource management. We work effectively as a team, committed to timely completion of projects to meet resource and public needs. We value Extension] public comment [auto-markup end], we foster partnerships and we are active in our communities. Above all else, Bridger-Teton National Forest employees respect each other and the public we serve." While this is an excellent Mission Statement the Alkali Creek Feedground SDEIS does not exemplify the application of this Mission Statement, nor does any other elk feedground. As is shown by the science, law, and information we have continually submitted to the BTNF permitting or operating elk feedgrounds is not “sound natural resource management.” The BTNF continues to off load the responsibility of operating the feedgrounds onto the WGFD and defers to a 1990 Forest Plan that contains elk feedgrounds as a conditionally allowable special use. Despite the BTNF insinuating otherwise, elk feedgrounds are not a requirement on the BTNF or any USFS lands. Contemporary readily
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Response to Comments available science shows that this special use is archaic and not sound and does not comply with modern wildlife management standards. Continuing to permit and operate the feedgrounds does not improve or maintain “healthy Forests” but, in fact, undeniably continue what are known to be unhealthy practices. How else can any agency or persons reasonably interpret the reality of disease ridden elk confined en masse on small tracts of land, eating baled hay atop layers of feces built up over decades amidst overbrowsed, stunted and dead aspen? There is no other way to interpret elk feedgrounds, as virtually all other wildlife managers and scientists throughout North America acknowledge and, hence, counsel to abolish feeding of big game. We are hopeful that the BTNF does value Extension] public comment [auto-markup end] and, more importantly, applies the sound science and law included in our comments. Unfortunately the cryptic and dismissive responses in the BTNF’s Winter Elk Management Activities- Public Comments and Agency Response Revised as of 7-15-08 to our May 5, 2008 DEIS comments and the resulting ROD to re-permit 5 elk feedgrounds for another 20 years show that our comments and those of our members and supporters- and the contemporary science submitted in our comments- were not valued or heeded by the BTNF because the BTNF released a virtually identical DSEIS for Alkali Creek Feedground five years later. Also, during an in person, video and conference call meeting about this Alkali DSEIS held with some BTNF staff and staff from the Sierra Club, GYC, Wyoming Outdoor Council, Biodiversity Conservation Alliance and a board member of Wilderness Watch, on Monday May 13, 2013, the Deputy Forest Supervisor made statements that indicated that public comments are not valued by the BTNF. That contradicts what your Mission Statement says. A last point about the BTNF Mission Statement: It says quite plainly that BTNF staff “aim to be progressive leaders in natural resource management”. Not permitting elk feedgrounds and phasing out the BTNF’s involvement in an archaic unhealthy wildlife management paradigm, winter feeding of elk, would be progressive and would truly display leadership page 25. Recommendation it is the foremost duty of the Bridger-Teton National Forest managers to protect the resources of USFS lands, habitats, and the wildlife that depend on them. Permitting elk feedgrounds and thereby enabling the harmful impacts resulting from feedgrounds does not accomplish this. The BTNF is not required to permit elk feedgrounds or allow vaccinations of elk, and also has the authority to close the USFS land to vaccinations and other harmful practices. The BTNF must comply with NEPA, 42 U.S.C. sec 4321 et seq., the National Wilderness System Preservation Act 16 U.S.C. 1131, the National Forest Management Act, 16 U.S.C. 1604, the Administrative Procedures Act 5 USC 706, and the BTNF Forest Plan. We recommend that no permit for a feedground at Alkali Creek be issued beyond the winter of 2013-2014 and no Strain 19 vaccination for elk be allowed. We thank you for this opportunity to comment on this DSEIS, and we look forward to continuing the dialogue with the USFS on this and related issues. We commit ourselves to help all parties achieve a sustainable outcome and expeditiously phase out elk feedgrounds. We would be happy to help the BTNF acquire any of the cited and/or listed reference materials if they are unable to get them. Please notify us promptly of your actions on this and related issues. Response: The Forest Service has the authority to authorize or not authorize elk feedgrounds on NFS lands. The Bridger-Teton Forest Plan allows feedgrounds, but does not require them. The Forest Service is legally required to consider public comments in resource management decisions. The staff of the Bridger-Teton National Forest do value public comment and we regret the comments made in a meeting on 5/13/2013 that led you to a believe differently. This project is very contentious and it appears that it
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Response to Comments is not possible to find solution that the opposing sides can both support. The Forest Service and Wyoming Game and Fish Commission (WGFC) work together to manage elk populations and habitat on NFS lands. The Forest Service recognizes WGFC as the agency with authority, jurisdiction, and responsibility to manage, control, and regulate fish and wildlife populations on NFS lands unless federal law specifically supersedes such authority.
72. Comment: Other violations of NEPA the BTNF offers some sections of the National Environmental Policy Act as if the B-T intends to follow through on the intent of this key environmental policy act. “NEPA requires consideration of “the relationship between short-term uses of man’s environment and the maintenance and enhancement of long-term productivity” (40 CFR 150216). As declared by the Congress, this includes using all practicable means and measures, including financial and technical assistance, in a manner calculated to foster and promote the general welfare, to create and maintain conditions under which people and nature can exist in productive harmony, and fulfill the social, economic, and other requirements of present and future generations of Americans (NEPA Section 101).” DSEIS: 150, typo corrected in parenthesis) The BTNF continues, “Concentrating large numbers of elk on feedgrounds could affect the rate of spread of disease, such as chronic wasting disease, if it were to become established in the analysis area. The decision to be made by the Forest Service under either alternative would have no effect on whether or not chronic wasting disease arrives in the analysis area, or the potential rate of spread of the disease, since feeding would continue with or without the use of National Forest System land.” Despite listing a description of a requirement of NEPA, the DSEIS falls far short of complying with many sections of NEPA, some of which have been listed in our comments over the years including these comments. No one could interpret the operation of and effects from elk feedgrounds on USFS lands as contributing to “long-term productivity” of the land, or promoting the “general welfare” or “harmony” between people and nature. Disease ridden elk confined en masse on small tracts of land, eating baled hay atop layers of feces built up over decades amidst overbrowsed, stunted and dead aspen or willows is hardly the image described in NEPA and amounts to violations of law. Anyone who has ever witnessed and smelled the buildup of feces and filth of elk feedgrounds or the constant effort of the WGFD to herd elk with helicopters and snowmachines onto the feedgrounds and vaccinate them with a worthless vaccine biobullet would never in good faith use such NEPA terms as “productive harmony” to describe the reality. Response: When conducting an environmental impact analysis, the National Environmental Policy Act (NEPA) and 40 CFR 1501.16 requires federal agencies to disclose the relationship between local short-term uses of man's environment and the maintenance and enhancement of long-term productivity. NEPA and 40 CFR 1501.16 do not require agency decision-makers to choose the alternative that best maintains long-term productivity.
73. Comment: We are commenting on the proposal by the Bridger-Teton National Forest to grant 20-year special use permits to the Wyoming Game & Fish Department to operate elk feedlots on National Forest land. We incorporate by reference our previous input and comments to the main EIS as well as the other attachments provided with this letter. In addition, we incorporate by reference the comments and input provided by the Greater Yellowstone Coalition during the larger elk feedlot process as well as for this process. The issues we have raised have not changed significantly since the last elk
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Response to Comments feedlot NEPA process other than CWD has moved closer to the array of elk feedlots scattered across western Wyoming making the decision to continue the Alkali feedlot even more idiotic than it was 4 years ago when the Forest authorized 20 year SUP for the other feedlots on Forest Service lands. Response: The commenter's and Greater Yellowstone Coalition's previous scoping input, comments, and appeal concerning the 2008 DEIS, FEIS, and Record of Decision are part of the project record and will be considered during the decision-making process for the Alkali Creek Feedground decision. Responses to these previous submissions are filed in the project record. Climate Change 74. Comment: Climate Change We repeat here some of our May 2012 scoping comments about the need for the BTNF to consider Climate Change: Wyoming is experiencing significant climate change in the form of unusually warm years since 1978. “The frequent warm years coincide with a reduction in the frequency of extremely low (<-20 degrees C) January temperatures . . . “(Shuman 2011) It’s clear that climate change is affecting the natural ecosystems in Wyoming. It’s also clear that wildlife is affected by changes in climate. “The ecology of ungulates in the (Rocky Mountains and Upper Columbia Basin) is strongly influenced by climate.” (NPS 2010:48) “One of the key issues for ungulate management is wildlife disease, the spread and virulence of which is likely to be exacerbated by climate change (Harvell 2002).” (Ibid) It is known that elk feedgrounds exacerbate the incidence of diseases in elk. (Smith 2005, Peterson 2005) “Climate change will likely increase the range, frequency, severity, and impact of plant and wildlife disease (Harvell et al 2002).” (NPS 2010:17) “Plant communities and wildlife that are faced with multiple stressors are the least likely to resist the emergence of novel diseases.” (Ibid) Therefore the practical thing to relieve or mitigate a stressor on elk is to allow them to range free on native range, rather than be lured in and confined on unhealthy feedgrounds during winter. The BTNF should not make decisions that are in place for the next 20 years, like permitting elk feedgrounds, without considering climate change and implementing other less harmful alternatives. The best thing that the BTNF can do for elk and other wildlife in the face of climate change is to allow the wildlife access to needed habitats. “Species that are mobile, genetically diverse, show wide physiological tolerances, and have generalist diets will respond the most positively (to climate change).” (NPS 2010:50) The worst thing the BTNF can do is to confine elk on to unhealthy feedgrounds during winter. The best science available indicates that free-ranging wildlife will do best in the face of climate change. The BTNF admits that "winters will be shorter, spring will be wetter and summer and fall will be drier." And that the snowpack will "recede () earlier" in the springtime. (DSEIS: 148) Yet the BTNF appears to still accept that elk should be condemned to be baited and fed on elk feedgrounds even amidst the many thousands of acres of winter range producing millions of pounds of palatable forage in the Gros Ventre and in a milder climate that will make even more acres and more forage available to elk and other big game in the future. "The same amount of elk currently fed at three feedgrounds in the Gros Ventre would be fed at the two remaining feedgrounds, Patrol Cabin and Fish Creek." (Ibid) Since the BTNF manages the land at Fish Creek along the Gros Ventre River up valley from Alkali Creek, they can decline allowing elk to be fed anywhere on USFS land, especially during such comparatively milder climactic conditions and amidst bountiful winter ranges. (See our comments above on winter range.) Winters have gotten milder in this region and the BTNF, in passing, admits that "(s)ome changes are already apparent () (Karl, et al. 2009;
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Response to Comments
Harris et al 2006; Furniss et al 2010)". (Ibid) Why continue to feed? Additionally, the BTNF admits that "the predicted warmer weather with less snow and more spring rain would improve natural forage opportunities for elk . . . ". (Ibid: 149) But the BTNF continues to use the context of elk feedgrounds by saying such conditions would result only in "a reduced season for feeding at Alkali Creek" if they issue the permit to the WGFD. (Ibid, emphasis added) This is a mistaken context and only fits the preference of the proponent, the WGFC, which favors feeding of elk in western Wyoming above all other options. Yet, climatic conditions are already milder as the BTNF admits and the science shows. The climate will get even milder in the coming decades so, in the Gros Ventre Valley amidst vast winter ranges, wintering big game may have it even easier on native ranges. So it is obvious that feedgrounds do not need to be part of the equation for managing habitat and elk in this area. If the BTNF permits elk feedgrounds in the face of such information, such a decision would be arbitrary and capricious and a violation of agency discretion. Response: The Forest Service agrees with the commenter and the experts referenced by the commenter that the spread and impact of wildlife disease is likely to be exacerbated by the predicted changes in climate and that the predicted warmer weather with less snow and more spring rain would improve natural forage opportunities for elk. It is also very likely that, with decreased snow depth, elk herds would not remain on the feedgrounds, but rather disperse onto native winter range. Thus, it is possible that, in the future, many elk would choose to remain in the Gros Ventre drainage in the winter without supplemental feeding. The Forest Service does not agree that a decision to authorize WGFD to use NFS lands at Alkali Creek Feedground would be arbitrary, capricious, or a violation of agency discretion. Wildlife 75. Comment: If you want to do something productive, LEAVE WOLVES ALONE! You feed elk, make them slow and weak so hunters can easily pick them off, you increase their numbers unnaturally, and then kill predators for the whims of special interests! Response: Thank you for providing your views concerning the effects of Alkali Creek Feedground on wolves, other predators, the physical condition of individual elk, and elk populations. The continued operation of Alkali Creek Feedground would help provide a consistent and predictable source of winter food (elk) for predators, and further stabilize the spatial distribution of their primary prey. Wolves in Wyoming are currently federally protected under the 1973 Endangered Species Act as an experimental, non-essential species. Neither Wyoming Game and Fish Department nor U.S. Fish and Wildlife Service have ever initiated efforts to lethally remove or relocate wolves that consistently visit the feedgrounds in the Gros Ventre watershed and disrupt elk movement or elk use of supplemental feed. Thus, we believe that it is highly unlikely such measures would occur in the future, given the current status of the species as protected under the 1973 Endangered Species Act.
76. Comment: Sierra Club has supported the closing of feedgrounds in the past and finds it important in the future as concentrating elk promotes disease, domesticates wildlife to supplemental winter feeding, and provides a central location for predators to prey on elk. This then puts predators into a dangerous situation under the Wyoming Wolf Management Plan. Response: The effects of continuing to authorize the facilities at Alkali Creek for Wyoming Game and
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Response to Comments
Fish’s Winter Elk Management Program (Alternative 2) on elk and disease factors are discussed in the Final Supplemental Impact Statement (FSEIS) in Chapter 3 105-117). The relationships between feedground-supported elk and gray wolves are discussed on pages 128-132 in the FSEIS. Wolves are currently federally protected under the 1973 Endangered Species Act as an experimental, non-essential species. Neither Wyoming (under previous Wyoming wolf management) nor the U.S. Fish and Wildlife Service have ever initiated efforts to lethally remove or relocate wolves that consistently visited the feedgrounds in the Gros Ventre watershed and disrupted elk movements or use of supplemental feed. Thus, we believe that it is highly unlikely such measures would occur in the future, given the current status of the species as protected under the 1973 Endangered Species Act.
77. Comment: Artificially feeding wild herds only accommodates hunters. Natural predators are the correct answer to control disease and return balance to the land. Allow the introduction of wolves to these areas and stop over feeding grazing herds. Response: Thank you for providing your views concerning the relationship between winter elk feeding, wildlife disease, and the ecological role of gray wolves. Because wolves are well established in the project area, no re-introductions are necessary. Wolves serve an important role in culling diseased and otherwise vulnerable prey and help balance the numbers of ungulates with the available forage. The effects of continuing to authorize the feedground facilities at Alkali Creek on elk and disease factors are discussed in the FSEIS in Chapter 3, pages 106-116. The relationships between feedground-supported elk and gray wolves are discussed on pages 129-134.
78. Comment: Elk are not native to Jackson Hole. Abnormal numbers of elk are maintained by winter feeding, native range plants are not sustained because of this. The range plants are required for the survival of the native Big Horn Sheep. Elk feeding would have a very negative impact on indigenous sheep. Response: Elk are very likely native to Jackson Hole and the Yellowstone Region. Peek (2003; project record) states: “The misconception that wapiti [elk] were originally a “plains” animal, forced to the mountains by the onslaughts of advancing civilization, still prevails. However, wapiti were present in the Yellowstone region before significant intrusion by humans (Lovaas 1970, Boyce 1989)… Lewis and Clark took wapiti in 1805-1806 in the upper Missouri River, Columbia River, and Yellowstone River (Martin and Szuter 1999). The species was hunted to extirpation in much of its range east of the Rocky Mountains, but occurred in the mountains as well. It was extirpated from plains and deciduous forests, but is not a recent colonizer of mountainous and forested terrain. McCorquodale (1985) reported wapiti remains from 10 archaeological sites scatted across the Columbia Basin east of the Cascade Range, with dates ranging from 10,000 years ago to recent times.” The analysis of the effects of feedground elk on vegetation does not conclude that “abnormal” numbers of elk are maintained by feeding; only that elk are “supplemented” and “concentrated”. Regardless, elk are a management indicator species on the Bridger-Teton National Forest and the Forest Service works with the Wyoming Game and Fish Department to achieve agreed upon population objectives. Because no data on the condition of native winter range are available for the Gros Ventre watershed, it is speculative to conclude that plants on native range that support bighorn sheep (primarily the north side
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Response to Comments of the river and distant from the Alkali Creek Feedground) are currently “not sustained”, that is, not in good health due to herbivory of feedground elk. We acknowledge that native plants are required to sustain bighorn sheep under both Alternative 1 and 2, and that this species is indigenous. The effect of implementing Alternative 2 on big horn sheep is displayed in the FSEIS on page 143-144. Implementing Alternative 2 would carry benefits for bighorn sheep (increased grass and forb forage and a decrease in shrub cover and predation) in the immediate vicinity of the feedground. Concentrating elk at the feedground (Alternative 2) would also help reduce forage competition on native range (if it currently occurs) between elk and bighorn sheep that forage north of the Gros Ventre River.
79. Comment: Executive Summary Pronghorn Migration - Statements made about pronghorn needing to circumvent feedground structures during migration are inaccurate. Alkali hay sheds, corrals, and tack shed are located on a bench with mixed timber on two sides. It is unlikely pronghorn would move through this area and be obstructed by feedground structures. Response: To evaluate this comment, we reviewed location data provided by Nature Mapping Jackson Hole (unpublished data, project record), and the Wildlife Conservation Society (Beckman; project record). Among the data sets, use of the Alkali Creek Feedground and immediate vicinity is common during the migration. Thus, the data do support the text as written in the DSEIS. However, we stated in the FSEIS that most migratory movement in this portion of the watershed occurs on the north side of the Gros Ventre River, not the south side where Alkali Creek Feedground is located.
80. Comment: Pronghorn Migration Consistency of Alternative 2 for the Pronghorn Migration Corridor – In the third paragraph, statements made about pronghorn needing to circumvent feedground structures during migration are inaccurate. Alkali hay sheds, corrals, and tack shed are located on a bench with mixed timber on two sides. It is unlikely pronghorn would move through this area and be obstructed by feedground structures. Response: To evaluate this comment, we reviewed location data provided by Nature Mapping Jackson Hole (unpublished data, project record), and the Wildlife Conservation Society (Beckman; project record). Among the data sets, use of the Alkali Creek Feedground and immediate vicinity is common during the migration. Thus, the data do support the text as written in the DSEIS. However, we stated in the FSEIS that most migratory movement in this portion of the watershed occurs on the north side of the Gros Ventre River, not the south side where Alkali Creek Feedground is located.
81. Comment: Table E-1 Sage-grouse – Alternative 1 should disclose the impacts of additional elk on the NER, which overlaps sage-grouse core area. Response: In the analysis of the direct and indirect effects of Alternative 1 on elk, we disclosed that elk movements among the two remaining feedgrounds (Patrol Cabin and Fish Creek) and the National Elk Refuge (NER) are expected to increase. Likewise, the effects of elk herbivory on native range in the Gros Ventre River corridor are also expected to increase. We acknowledge that additional elk wintering on the NER would have herbivory effects on vegetation needed by sage grouse, but stated in the FSEIS that these effects would be minor and could not be quantified. Herbivory effects of newly added (Gros
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Response to Comments
Ventre) elk under Alternative 1 could not be measured and discerned from those of elk that currently use the NER. None-the-less, we added the following statement to the Wildlife section of the FSEIS (page 80): “Although additional elk wintering on NER in Alternative 1 would have herbivory effects that would affect other wildlife, these effects were considered but were not quantified because the effects of Gros Ventre elk could not be distinguished from elk that do not use Gros Ventre feedgrounds at all."
82. Comment: Table E-1 Bighorn sheep – Alternative 1 should disclose the impacts of displaced elk on bighorn sheep winter range. Specifically, no elk feeding at Alkali may contribute to competition for winter forage. Response: We added analysis to the FSEIS to disclose the impacts of displaced elk on bighorn sheep range under Alternative 1. Eliminating feedground operations at Alkali Creek would likely cause some feedground elk to be displaced to bighorn sheep winter range (versus displaced to other Gros Ventre feedgrounds) on the nearby Grey, Lavender, Red, and Russold Hills. Elk that elect to use crucial bighorn sheep winter range in preference to the feedgrounds would reduce forage available to bighorn sheep. An increase in elk numbers on native winter range would displace bighorn sheep from their usual winter haunts and slightly reduce population vital rates such as survival and fecundity. Although this effect may impact individual bighorn sheep, it is not likely to contribute to a trend toward federal listing or cause a loss of viability to the population or species.
83. Comment: Table E-1 Elk – Alternative 1 should disclose impacts to elk management. Specifically, no feeding at Alkali may contribute to the difficultly in managing toward herd objectives. More elk on the NER may lead to liberal hunting seasons and reduction of National Forest elk. Response: We added text in the FEIS to disclose that in the absence of feedground operations at Alkali Creek (Alternative 1), the difficulty of controlling elk movements within the watershed would increase and contribute to movements of Gros Ventre elk to the National Elk Refuge (NER). Winter elk management is expected to continue to occur at Patrol Cabin feedground on lands adjacent to National Forest System lands. Such management would help keep elk localized in the Gros Ventre watershed during the winter. However, some elk are expected to migrate to the National Elk Refuge (NER) in the absence of feedground operations at Alkali Creek, further adding to elk numbers at the NER and contributing to difficulties in managing toward objectives established for the Jackson elk herd. Alternative 1 would likely make it increasingly difficult for Wyoming Game and Fish Department to manage for their post-season objective of 11,000 elk and the goal of 5,000 wintering elk on the NER and 3,500 wintering elk in the Upper Gros Ventre. More elk on the NER could lead Wyoming Game and Fish Commission to initiate more liberal hunting seasons during the fall, resulting in a reduction of elk that use spring, summer, and fall ranges on NFS lands.
84. Comment: Wildlife Resources Elk cumulative effects – The analysis should be more explicit in acknowledging that no feeding at Alkali may contribute to a greater number of elk moving down drainage to the NER. The current objective on the NER is 5,000 elk. Alternative 1 would likely make it increasingly difficult to manage for post season objective of 11,000 elk and the goal of 5,000 on the NER and 3,500 in the Upper Gros Ventre.
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Response to Comments
Response: We added text in the FEIS to disclose that in the absence of feedground operations at Alkali Creek (Alternative 1), the difficulty of controlling elk movements within the watershed would increase and contribute to movements of Gros Ventre elk to the National Elk Refuge (NER). Winter elk management is expected to continue to occur at Patrol Cabin feedground on lands adjacent to National Forest System lands. Such management would help keep elk localized in the Gros Ventre watershed during the winter. However, some elk are expected to migrate to the National Elk Refuge (NER) in the absence of feedground operations at Alkali Creek, further adding to elk numbers at the NER and contributing to difficulties in managing toward objectives established for the Jackson elk herd. Alternative 1 would likely make it increasingly difficult for Wyoming Game and Fish Department to manage for their post-season objective of 11,000 elk and the goal of 5,000 wintering elk on the NER and 3,500 wintering elk in the Upper Gros Ventre. More elk on the NER could lead Wyoming Game and Fish Commission to initiate more liberal hunting seasons during the fall, resulting in a reduction of elk that use spring, summer, and fall ranges on NFS lands.
85. Comment: Table E-1 Mule deer, moose and pronghorn – Alternative 1 should disclose impacts of displaced elk on moose winter range in the corridor analysis area. Specifically, no elk feeding at Alkali may contribute to competition for winter forage. Alternative 2 states “For moose and mule deer, this alternative contributes negatively toward achieving the herd objectives…” The Department disagrees with this analysis as in this instance 91 acres is too small of an area to contribute negatively to a population. Similarly for pronghorn, in this instance 91 acres is too small of an area to contribute positively to a population. Response: Closing Alkali Creek Feedground (Alternative 1) would increase forage competition between elk and moose, as some elk that currently use Alkali Creek Feedground would likely elect to forage on native winter range. As discussed in the vegetation specialist report, elk mobility among the two remaining feedgrounds (Patrol Cabin and Fish Creek feedgrounds) and the National Elk Refuge is expected to increase, potentially increasing herbivory pressure in the river corridor and on native winter ranges used by moose. With regard to moose, mule deer, and pronghorn impacts described under Alternative 2, revised text in the FSEIS states that, while changes in vegetation species composition and abundance from feedground operations are negative for moose and deer and positive for pronghorn, they are insignificant at the herd unit scale because vegetation impacts at Alkali Creek Feedground cover a small (91 acres of concentrated impact) area. The revised text in the FSEIS further states that, because herbivory by elk at Alkali Creek Feedground is concentrated on and near the feedground, competition for forage between feedground elk and moose, mule deer, and pronghorn under Alternative 2 would be very minor.
86. Comment: The Alternative 2 analysis indicates that elk browsing creates unfavorable habitat conditions for other big game species and contributes negatively towards population objectives. The Department disagrees with this analysis as the acreage of Alkali (91 acres) is too small to have a population-level impact, in this instance. However, the analysis later states “…the effects of this alternative on achieving population objectives are insignificant.” These assessments seem contradictory. Alternative 2 allows the agency to minimize elk competition on winter ranges used by bighorns and moose. The Alternative 2 analysis indicates that elk browsing creates more favorable conditions for
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Response to Comments pronghorn and contributes positively towards populations objectives. Again, the Department disagrees with this assessment that Alkali will have population-level impacts for these species. However, the analysis later states “…the contribution of this alternative toward the population objective is insignificant.” These assessments seem contradictory. Response: Closing Alkali Creek Feedground (Alternative 1) would increase forage competition between elk and moose, as some elk that currently use Alkali Creek Feedground would likely elect to forage on native winter range. As discussed in the vegetation specialist report, elk mobility among the two remaining feedgrounds (Patrol Cabin and Fish Creek feedgrounds) and the National Elk Refuge is expected to increase, potentially increasing herbivory pressure in the river corridor and on native winter ranges used by moose. With regard to moose, mule deer, and pronghorn impacts described under Alternative 2, revised text in the FSEIS states that, while changes in vegetation species composition and abundance from feedground operations are negative for moose and deer and positive for pronghorn, they are insignificant at the herd unit scale because vegetation impacts at Alkali Creek Feedground cover a small (91 acres of concentrated impact) area. The revised text in the FSEIS further states that, because herbivory by elk at Alkali Creek Feedground is concentrated on and near the feedground, competition for forage between feedground elk and moose, mule deer, and pronghorn under Alternative 2 would be very minor.
87. Comment: Wildlife Resources Pronghorn – The analysis states, “Approximately 200 pronghorn spend the summer and fall months in the Gros Ventre drainage and in Grand Teton National Park….”. Approximately 400 pronghorn were classified by WGFD personnel in 2012 in Grand Teton National Park, the National Elk Refuge, and in the Gros Ventre. Response: We reviewed the final 2011 and draft 2012 pronghorn survey reports (project record) provided by Grand Teton National Park (GTNP). These reports summarized both GTNP and WGFD counts for the GTNP, the National Elk Refuge, and the Gros Ventre watershed. We changed the text in the FSEIS to provide an appropriate range (250-400) for pronghorn counts in late summer. Actual numbers were 241 in late summer, 2011 (WGFD) and 387 in late summer, 2012 (WGFD).
88. Comment: Table 3 Alternative 1: No Action should disclose the potential impacts associated with elk redistribution in analysis area. Response: We changed Table 3 in the FSEIS to include the following text concerning effects of Alternative 1 on wildlife: “Increases forage competition with bighorn sheep, moose, and elk that currently use native range.”
89. Comment: Wildlife Resources Harvest MIS – Elk – The third paragraph should be edited to state “The corridor analysis area supports 17,109 acres of crucial winter range…” Response: We changed the text in the FSEIS to identify elk crucial winter range rather than elk crucial range. We made similar changes for text concerning bighorn sheep, moose, and mule deer.
90. Comment: Wildlife Resources Gray Wolf – The first sentence should be edited as follows: “An important mortality factor for wolf packs is the hunting (mortality) quota set by the state of Wyoming Game and Fish Department, an action that contributes to the cumulative effects associated with the proposed action.”
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Response to Comments
Response: The gray wolf in Wyoming is currently federally protected under the 1973 Endangered Species Act as an experimental, non-essential species. The Wyoming Game and Fish Commission has suspended gray wolf hunting seasons and quotas.
91. Comment: Wildlife Resources Greater Sage-Grouse – This section should offer a discussion of the State of Wyoming Core Area Population strategy as embodied in Executive Order 2011-5. It should be noted that a portion of the NER overlaps the Jackson core area and the BTNF is part of an ongoing process to amend the Forest Plan to include additional protections for sage-grouse. Response: The Forest Service is proposing to amend the BTNF Forest Plan to add protection for greater sage-grouse habitat. We added that project to the list of actions considered in the cumulative effects analysis. We added the following text to the Affected Environment and Environmental Consequences chapter of the FSEIS (page 98). "The Bridger-Teton National Forest works with the Wyoming Game and Fish Department and county, state, and federal agencies to promote the conservation of greater sage-grouse. This effort includes active participation on the Upper Snake River Basin Sage Grouse Working Group. The Forest Service is part of an ongoing process to amend the Forest Plan to include additional protections for greater sage-grouse. In 2008, the Wyoming Game and Fish Department and other state agencies implemented a core area strategy (most recently Executive Order 2011-5) intended to protect suitable greater sage-grouse habitats, populations, and connectivity areas; and to create incentives for project proponents to locate activities in areas with unsuitable habitat. Portions of the Bridger Teton National Forest, the National Elk Refuge, Grand Teton National Park, and private and state land overlap the Jackson core area. The strategy focuses conservation efforts on greater sage-grouse leks and surrounding habitats (sagebrush and riparian communities) that are suitable for the species. The policy limits or prohibits surface disturbance, surface occupancy, and seasonal use (during sensitive periods such as breeding or nesting) in core areas. Activities in habitat not suited to sage grouse are allowed year-round, barring other federal or state permitting requirements. Existing activities are not be affected by the greater sage-grouse core area protection requirements. Other criteria affecting development within core areas include specific requirements for oil and gas activity and wind development, along with requirements for transportation activity, placement of overhead lines, noise, vegetation removal, sagebrush treatment, monitoring/adaptive response, and reclamation.
92. Comment: Wildlife Resources Great Gray Owl – The WGFD classifies this species as a Species of Greatest Conservation Need (SGCN) with a NSSU (unknown) status in the 2010 SWAPAGE. Response: We added text to the FSEIS (page 101) stating that the Wyoming Game and Fish Department classified Great Gray Owl as a Species of Greatest Conservation Need (status unknown) in the 2010 State Wildlife Action Plan.
93. Comment: Wildlife Resources Cumulative Effects – This analysis identifies the principle actions affecting elk in the corridor analysis area as feedground management at Patrol Cabin and Fish Creek, but fails to acknowledge that the corridor analysis area is influenced by elk distribution on native winter range. In other words, there are many factors that affect elk distribution in the corridor.
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Response to Comments
Response: With respect to the National Environmental Policy Act and its implementing regulations, cumulative effects are the impact on the environment which results from the incremental impact of the action, when added to the other past, present, and reasonably foreseeable future actions taken by federal and non-federal parties (40 CFR 1508.7). A brief definition of cumulative actions is found in the FSEIS in the paragraph preceding the one identified by the commenter. Natural factors such as the distribution of native winter range, wolf predation pressure or weather are not anthropogenic-based actions. We acknowledge that many such factors affect the distribution and behavior elk, but believe that identifying them as actions contributing to cumulative effects is not consistent with the definition. However, we added the following statement to the section of the FSEIS (page 82) describing the general population and habitat conditions for elk in the Gros Ventre watershed: “The distribution and quality of native winter range, and many other factors (e.g., weather, wolf predation pressure) influence the distribution of elk in the Gros Ventre watershed during the winter.”
94. Comment: Wildlife Resources Mule deer, moose, and pronghorn – direct and indirect effects – The analysis for Alternative 2 indicates that there would be an increase in human disturbance on these species, but fails to acknowledge that Alkali is used by the public as a trail head. Response: We added the following text to the FSEIS (117): “The feedground site also serves as a public trailhead for access to the Gros Ventre Wilderness, a use that also carries wildlife disturbance.”
95. Comment: Wildlife Resources Brewer’s Sparrow – direct, indirect, and cumulative effects – Statements indicating that the selection of Alternative 2 will have negative effects on sagebrush habitat in the corridor analysis area are likely inaccurate. Wintering and migrating elk may affect individual plants, but not likely to impact the quality of sagebrush habitat in the entire Gros Ventre corridor. Response: The text in the DSEIS that the commenter refers to indicates that the spatial extent of effects of herbivory and trailing by feedground elk is largely limited to individual sagebrush plants in the vicinity of the feedground area: "The proposed action would carry negative effects on the height and breadth of individual sagebrush plants and the coverage of sagebrush in the Analysis Area, with effects most visible near the feedground." and (a subsequent sentence) "Opposite of the No Action alternative, the Proposed Action would decrease the amount and quality of sagebrush habitat in the Analysis Area, particularly near the feedground." We modified the next sentence (FSEIS page 122) in response to this concern: "This negative effect would further contribute, although only slightly because of the limited spatial extent of herbivory by feedground elk, [new text addition] to the negative effect of the actions in Table 22."
96. Comment: Wildlife Resources Grizzly Bear – direct and indirect effects – The analysis indicates that Alternative 1 would eliminate the possibility that human food would be available to bears in the feedground area. Food storage rules as described on pg. 117 apply under Alternative 2 and so the impacts of human food absence vs. presence would essentially be the same. Response: We disagree that the potential effects of the two alternatives on food storage and bear mortality risks are the same. In Alternative 2, there is a risk that feedground personnel would accidently leave human food out that bears might find, an event common for forest visitors during the
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Response to Comments summer. This event under Alternative 1 would not occur because feedground personnel would not be visiting Alkali Creek Feedground. We indicate in this section of the FSEIS (page 133) that the risk of bears receiving human food rewards under Alternative 2 is low (as the commenter suggests): "... mortality risks for bears due to anthropogenic food would be low at the Alkali Creek Feedground because (1) the period of overlap between spring bear activity and feedground operations is short (four weeks maximum—mid March to mid-April) and food storage regulations would be in effect for the duration, (2) personnel would not use the feedground for over-night lodging (as at Finnegan Feedground), and (3) there is no history of grizzly bear visits or human-bear conflicts at Alkali Creek Feedground."
97. Comment: Wildlife Resources North American Wolverine – The cumulative effects and determination sections on this page are incorrectly titled as “North American Marten.” Response: The section title for North American Wolverine has been corrected.
98. Comment: Wildlife Resources Forest Service Region 4 Sensitive Species – effects common to both alternatives – The second sentence of this section presents examples of diseases including bovine tuberculosis, bovine paratuberculosis, and CWD. Two of these diseases haven’t been discussed thus far in the SEIS. It is our recommendation that reference to examples of “new disease” is stricken from the sentence. Alternative 1 - Bighorn sheep direct and indirect effects - The SEIS fails to disclose the effects of the alternative regarding elk movements down drainage and direct competition with bighorn sheep on sheep winter range. See our May 23, 2012 comments. Response: Tuberculosis and paratuberculosis have been removed from the FSEIS but CWD, a new disease to feedgrounds is discussed in the FSEIS (pages 5, 84-85). On page 137 of the FSEIS we discuss the potential under Alternative 1 for increased competition between ungulates foraging at the Grey, Lavender, Red, and Russold Hills winter ranges.
99. Comment: Wildlife Resources Gray Wolf – Determination – This section fails to acknowledge other factors, aside from management-related mortality, that impact wolf populations (e.g., reproduction). The statement “Thus, wolf numbers are not likely to soon increase within the cumulative effects analysis area” is a highly speculative statement and should be stricken. Response: Upon review and evaluation, we agreed, and removed the statement in question from the FSEIS.
100. Comment: Wildlife Resources Greater Sage-Grouse – these sections should acknowledge the State of Wyoming Greater Sage-Grouse Core Population Area strategy as it relates geographically to the analysis area. The majority of the Gros Ventre drainage is in non-core area where impacts to sagebrush habitat are not as highly scrutinized as in core areas. Further, big game management (aside from habitat treatments) is not guided by Executive Order 2011-5. For Alternative 1, it should be noted that the NER overlaps the Jackson core area. The analysis should evaluate the potential impacts of the No Action alternative on elk distribution on the NER and that portion of sage-grouse core area. Response: The Forest Service document Interim Conservation Recommendations for Greater Sage-Grouse and Greater Sage-Grouse Habitat currently provides the management direction for sage
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Response to Comments grouse in the applicable Forest Service Regions, including the Bridger-Teton National Forest. The relevant sections of these documents are reviewed in Chapter 3 of the FSEIS. Because we believe our current analysis meets this document’s management guidance and analysis requirements, there is no need to insert a detailed discussion of Wyoming’s core area policy. However, the Wyoming policy is briefly addressed in Chapter 3 as well. With respect to impacts of Gros Ventre feedground elk on the National Elk Refuge (NER) in Alternative 1 and the core sage grouse habitat it supports, this area is outside the cumulative effects (Corridor Analysis) area. We did not include the NER in our cumulative effects area because the effects of Alkali Creek Feedground elk that might move down river to the NER in Alternative 1 would be too difficult to distinguish from those of wintering elk that are not from Gros Ventre feedgrounds. Also, expanding the cumulative effects analysis area to include a broader area would expand the number and spatial extent of the cumulative actions, and dilute the significance of the direct and indirect effects of feedground elk on vegetation and terrain in the Gros Ventre watershed. Thus, the potential effects of Gros Ventre elk on core habitat in the NER were not evaluated. There is essentially no core habitat in the Gros Ventre watershed. We added statements to the background information provided in Chapter 3 in the FSEIS (page 99) to reflect this.
101. Comment: Wildlife Resources Alternative 2 – Bighorn sheep – direct and indirect effects – Again, the DEIS fails to disclose the effects of holding elk on the feedground and off of bighorn sheep range. Elk displaced off of Alkali would impact sheep on the Grey, Lavender, Red and Russold Hills. See our May 23, 2012 comments. Response: We agree with the commenter. We added text concerning bighorn sheep effects in Alternative 2 in the FSEIS (pages 146-147) stating that continuing feedground operations at Alkali Creek might also help localize feedground elk that otherwise might compete with bighorn sheep on native winter range (at a larger spatial scale than Alkali Creek Feedground) or displace bighorn sheep to marginal range.
102. Comment: Wildlife Resources Gray Wolf – determination – Strike the word “significant” in the first sentence. It is an unnecessary modifier. Response: We agree, and removed the word "significant" from the discussion of wolves in the FSEIS.
103. Comment: However, at this point in time, the biggest problem we have in elk utilizing the forage is the wolves. Early in the fall/winter when the elk first come into their traditional winter range they are well dispersed. Once the wolves appear in numbers the elk are pushed to the valley floor and become one big herd. Without daily supplemental feeding and with the pressure from the wolves, they soon eat what natural feed there is in the area. The elk have shown they will migrate down the river disrupting other wintering wildlife and their winter ranges and eventually end up on the National Elk Refuge. Once they do this it is going to be very difficult to ever keep them in the Gros Ventre drainage again. Under the present system wolves drive the elk off the upper feed grounds into the narrows at the Alkali feed ground where they are fed. If that feed ground is not there, there is no doubt in my mind that the elk on the Gros Ventre feed grounds would become elk on the National Refuge Elk Feed Grounds. This has already taken place on the Buffalo and Spread Creek winter ranges. The increasing GTNP and suburban
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Response to Comments elk herds have already filled the Elk Refuge to near capacity. The Buffalo Valley and Spread Creek wintering elk have started coming south to the refuge, and if the Gros Ventre herd all of sudden shows up on the Refuge, we are definitely looking at a lawsuit, or the killing off a lot of elk or both. The easiest elk to kill are the already diminished forest herds. Response: The Forest Service agrees with the commenter that, without the Alkali Creek Feedground, it is likely that some Gros Ventre elk would migrate to winter on the National Elk Refuge. The interactions between elk distribution, Gros Ventre feedgrounds, use of the National Elk Refuge by Gros Ventre elk, and wolf predation are discussed in general in the FSEIS on page 92 and for the two alternatives on pages 129-130 and pages 134-135.
104. Comment: Gray Wolf - The DSEIS concludes that it will be beneficial to gray wolves to permit the Alkali Creek Feedground. (DSEIS: Exec Summary vii; 129 and elsewhere). We disagree. The BTNF actually tries to make the case that "stabilizing prey" and keeping elk from "traveling to the National Elk Refuge" is somehow beneficial to wolves (Ibid). Shockingly, the BTNF asserts that concentrating elk onto feedgrounds and amplifying diseases such as CWD could be beneficial to wolves in the short term: "To the extent that it contributes to the establishment and continuance of new mortality agents such as chronic wasting disease, winter management at Alkali Creek would likely carry short-term benefits to wolves by increasing prey vulnerability." It's astonishing that the BTNF could put such a management scheme in positive terms, to knowingly and purposefully increase the prevalence of a deadly disease in a prey species could be considered good for the predator. (Ibid: 130) Elsewhere in our comments we question the BTNF's assertion that elk will abandon the Gros Ventre Valley in part or en masse and go to the Elk Refuge. In addition, our May 18, 2012 scoping comments pointed out that elk feedgrounds have been and may be in the future localized areas where people consistently kill wolves: The BTNF has a duty to manage conditions on the Forest to conserve and allow wolves to naturally disperse on the landscape. The Federal Land Policy and Management Act of 1976 declares that the policy of the United States is that (USFS) lands be managed in a manner that will protect the quality of scientific, scenic, historical, ecological, environmental, air and atmospheric, water resource, and archaeological values. Where appropriate these (USFS) lands will be preserved and protected in their natural condition. (43 U.S.C. 1701 emphasis added). There is nothing natural about elk feedgrounds and the BTNF permitting of elk feedgrounds creates long-term risk of catastrophic disease harming the primary prey source of this keystone species. Wolves play an important role in elk ecology as well as a natural buffer to disease, crowding, over-browsing, and other negative impacts of elk feedgrounds. By reducing prey numbers, dispersing these animals on the landscape, and removing sick animals, wolves may reduce the transmission and prevalence of wildlife diseases such as chronic wasting disease and brucellosis (Smith 2005,) Recent research has modeled how the presence of wolves may be considered an effective measure for controlling CWD. The authors of a recent paper published in Journal of Wildlife Diseases concluded that wolf predation may be a useful tool for management of CWD and that the absence of large predators presents an amplification risk factor for establishment of CWD. (Wild et al 2011) Even more concerning is that the BTNF would consider permitting elk feedgrounds and their associated management activities carte blanche. The Wyoming Game and Fish Department has direction per their Final Gray Wolf Management Plan (http://wgfd.wyo.gov/web2011/Departments/Wildlife/pdfs/WOLF_MANAGEMENT_PLAN_FINAL0000
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348.pdf Page(s): 32-39) and Wyoming State Statutes to lethally control wolves for the interactions that occur at winter elk feedgrounds. Wyoming’s Chapter 11 regulations state: (c) Gray wolves may be lethally removed when the Department determines that gray wolf predation is causing having an unacceptable impact on a wild ungulate population or herd or when gray wolf-wild ungulate conflict has occurred is occurring at any State operated elk feedground. (i) A gray wolf-wild ungulate conflict has occurred at a state operated elk feedground when a gray wolf or wolves displace elk from a feedground and it results in one of the following conflicts: (A) Damage to private stored crops by displaced elk; or, (B) Elk co-mingling with domestic livestock; or, (C) Displacement of elk from a feedground onto a highway right of way causing human safety concerns. Further WGFD specifically cites Alkali feedground as a location that there will be anticipated conflicts with wolves causing elk damage to stored hay or cattle feedlines and brucellosis transmission to livestock, as well as elk crowding, brucellosis, (and) hay supply issues (WGFD 2011, page 37). These conflicts would allow the WGFD, per their management plan, to lethally remove wolves through agency control efforts which may be precipitated through contract with Wildlife Services, involving helicopter gunning or other means. A consequence of elk feeding is the indirect actions that will result in the lethal removal of a keystone species. Further these activities will impair wilderness character, Forest Plan standards, and Wild and Scenic values of forest lands as described elsewhere in these comments. The BTNF must disclose and analyze what permitted actions associated with elk feedgrounds would be allowed and fully analyze the impacts of wolf control actions on elk feedgrounds and surrounding winter range closures. (GYC 2012 Scoping comments: 16-18) The BTNF actually admits that "Wolves would continue to be attracted to the concentration of elk at the feedgrounds." (Ibid: 122) Per the reasons given above, permitting the elk feedground at Alkali Creek cannot reasonably be interpreted as being beneficial to wolves. Response: We made several changes (detailed below) to clarify our analysis and more clearly articulate the relationship between wolves, elk, wildlife disease, and feedgrounds in response to this and other comments concerning the direct and indirect effects of the two alternatives on gray wolves. We also changed our determination from “Beneficial Impact” (as a Sensitive Species in Alternative 2) to "Will have little or no effect on the population in Northern Rocky Mountains, in Wyoming, and the Bridger-Teton National Forest; and will not trend the species away from future delisting under the Endangered Species Act" (for a species with federal protection). Any factor, feedgrounds or otherwise, that increases the spatial and numerical stability of an abundant ungulate prey (such as Gros Ventre elk) within a wolf pack’s territory is likely to be beneficial to the pack. Ungulates such as elk are a major and critical source of food in the Yellowstone Ecosystem. Any significant loss of this important prey within a pack’s territory (e.g., Lower Gros Ventre pack) would likely be detrimental, particularly in the absence of a large prey alternative. As indicated in our analysis, the absence of the Alkali Creek Feedground could increase elk movements to the National Elk Refuge, reducing prey available to Gros Ventre wolf packs, clearly to their detriment because the pack has limited opportunity to shift their activity into another pack’s territory. Any mortality or health factor that increases the vulnerability of an individual prey to its predator is, at least in the short term, beneficial to the predator. Indeed, for wolves, "vulnerability is everything" (Rolf Peterson, wolf expert and Doug Smith mentor). As pointed out by the commenter “By reducing prey numbers, dispersing these animals on the landscape, and removing sick animals, wolves may reduce the
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Response to Comments transmission and prevalence of wildlife diseases such as chronic wasting disease and brucellosis (Smith 2005,).” It is the prey’s vulnerability that predisposes it to selective removal by wolves and provides for ecological benefits to the natural system. Thus, we continue to assert our conclusion that wolves will benefit in the short term from increases in elk vulnerability. Of course, wolves would be negatively affected in the long term if a new mortality factor such as chronic wasting disease led to a strong and sustained reduction in numbers of their principal ungulate prey. We initially pointed this out on page 120 in the DSEIS, indicating that although wolves and bald eagles could benefit in the short term (vulnerable prey and increase in carrion), they might be negatively affected by a long term decrease in elk. We also identify the possibility of an irretrievable commitment of predator and scavenger resources to occur under Alternative 2 (page 169, FSEIS) if chronic wasting or other wildlife disease become establish and substantially reduce the elk population. The potential interactions between wolves, a new disease such as chronic wasting, and elk numbers is also considered on pages 131-132 of the FSEIS (direct and indirect effects of Alternative 2): “…However, the effect of chronic wasting disease on population dynamics of elk is unknown (Williams et al. 2002). Models developed for mule deer that did not include predation effects suggest a decrease in this prey's density and population stability following the introduction of chronic wasting disease (Gross and Miller 2001). Elk populations modeled by Hobbs (2006) did not decline over the long-term in either the presence or absence of selective predation by wolves. Selective predation by wolves potentially has a strong effect and interaction with the prevalence and persistence of chronic wasting disease (Hobbs 2006; Wild et al. 2001). “ As suggested from this brief summary of the literature, the long-term effect of chronic wasting on elk numbers is uncertain because the data and model results are currently equivocal. Thus, it was not appropriate in our analysis to conclude that a new disease would necessarily cause a reduction in elk numbers to the long-term detriment of wolves. However, it is clear that wolf predation has the potential to interact with disease factors and might work in concert with disease factors in a way that limits elk numbers. If elk were reduced by this mechanism, a sustained loss of elk would clearly carry a negative long-term effect on wolves. In the FSEIS (pages 92 and 129-130), we further clarify the potential for contrasting effects of the alternatives on wolves. The commenter incorrectly states that, under Alternative 1, the Forest Service asserts that elk will leave the refuge “en masse and go to the elk refuge”. Rather, we state that: Pp 128 FSEIS in Alternative 1, “closure of the Alkali Creek Feedground would eliminate this concentration of elk during winter, but likely trigger increased elk use of Patrol Cabin Feedground and Fish Creek Feedground. Elk would also make some round trips to the National Elk Refuge. Elk readily shift among the three feedgrounds in the Gros Ventre watershed due to predation pressure by wolves (Jimenez 2003).”; and Pp 131 FSEIS In Alternative 2, “The additional concentration of elk at a third [Alkali Creek] feedground (in addition to the Patrol Cabin and Fish Creek feedgrounds) in the Gros Ventre watershed would provide wolves a third predictable location to find prey, and would assist WGFD’s efforts in keeping elk from moving to the National Elk Refuge in response to wolf predation, and
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“The presence of the Alkali Creek Feedground would further stabilize the distribution of their prey, and keep elk from traveling to the National Elk Refuge where they would be less available to wolf packs in the middle and upper Gros Ventre watershed” (page 134, FSEIS). We conclude that some down-valley movement by elk from the Gros Ventre watershed to the Elk Refuge is likely under Alternative 1 and that feedground operations at Alkali under Alternative 2 would better help retain wintering elk in the Gros Ventre watershed. We believe this contrast between the two alternatives is reasonable, factual, and informative for the reader and the decision maker. Radio telemetry data obtained from Gros Ventre elk by the Wyoming Game and Fish Department, Jackson, from 2011 to present indicate down-valley drift by elk during the winter may occur from the collective feedgrounds in the upper Gros Ventre watershed to the lower portion of the analysis area and the National Elk Refuge. Although there is a natural migration from the upper watershed to Jackson Hole and the Refuge, such movements are apparently promoted by both late initiation and early cessation of feeding at Alkali Creek Feedground. Feeding at Alkali Creek may short-stop elk that might otherwise migrate to Jackson Hole proper (pers. comm., D. Brimeyer, Wyoming Game and Fish Department, July 30, 2013). For example, up to 700 elk were observed by Wyoming Game and Fish personnel moving down valley toward the National Elk Refuge during March 2012 and December 2012. Such movements may be related to wolf predation pressure on or near the feedground (pers. comm., D. Brimeyer, Wyoming Game and Fish Department, July 30, 2013). The commenter points out that because feedgrounds concentrate elk that themselves attract wolves, feedgrounds could indirectly contribute to legal (and illegal) wolf mortality caused by hunters. Because the gray wolf in Wyoming is currently protected as an experimental, non-essential species under the Endangered Species Act, legal losses through hunting do not occur. US Fish and Wildlife Service concurrence is required for any other lethal removal actions.
105. Comment: At Summary of Alternative Elements: No Action Alternative 1, DSEIS: 18, the BTNF states that not permitting the feedground will result in "More elk would likely congregate on the National Elk Refuge Feedground, increasing potential for disease transmission." How many more elk? 25? 150? If it is significant numbers of elk that the BTNF thinks would leave the Gros Ventre, why does the BTNF believe elk would leave the Gros Ventre Valley en masse and congregate on the National Elk Refuge? Since the Gros Ventre is excellent winter range- much better than the Elk Refuge- it contains everything elk need. While some wild elk normally and naturally drift from one winter range complex to another in response to a variety of natural influences, that is a natural function of wild elk in an ecosystem and to be encouraged and protected by the BTNF, not prevented. The DSEIS alludes to a "more mobile elk herd" in the absence of a permit to feed at Alkali Creek (DSEIS: 49). Ecologists promote the benefits of a "mobile elk herd" and we certainly support that. The BTNF should support this important component of a functioning ecosystem. Response: The Forest Service did not estimate the number of elk that might go to the National Elk Refuge (NER) in the winter and did not estimate how long elk might visit NER and then return to the Gros Ventre watershed. Such estimates would be speculative. However, up to 700 elk were observed by Wyoming Game and Fish personnel moving down valley toward the NER during March 2012 and
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December 2012. We do not know if these elk actually reached the Refuge. Because Gros Ventre elk number about 2,800 in the winter, 700 is none-the-less a large fraction (25%) of this herd. A further factor complicating the prediction of elk numbers and movement patterns in Alternative 1 is the potential for WGFC to continue feeding elk near Alkali Creek Feedground on private lands. In the description of Alternative 1 effects in the FSEIS, we did not predict that elk would move en masse to the NER. However, we agree that elk naturally move between winter range areas, including among and between native ranges and feedgrounds, and that interchange between winter foraging areas is natural among elk and ecologically desirable. In this case however, the movement of elk increases the likelihood that disease transmission among elk is likely to increase, as is disease transmission between elk and cattle. Thus, the increased potential for disease transmission is an undesirable aspect of Alternative 1, one that we disclosed. Moreover, although the Forest Service promotes and encourages natural processes such as inter-range movements of wildlife (e.g., through fence removal), processes that influence elk movements and migrations, such as supplemental feeding are permitted in the Bridger-Teton Land and Resource Management Plan. Indeed, the management emphasis for areas included in Desired Future Condition #12, including the Alkali Creek Feedground, is “… on providing such important habitat for big-game as winter ranges, feedgrounds, calving areas, and security areas” (BTNF Forest Plan, page 242).
106. Comment: Canada lynx Canada lynx are listed as Threatened and protected under the Endangered Species Act. (DSEIS: 81) "The Alkali Creek Feedground occurs in the 62,534 acre Upper Gros Ventre North LAU (Lynx Analysis Unit). Mapped lynx habitat in this LAU totals 54,274 acres . . . ." (Ibid, parenthesis added) Some, 27%, of the lynx habitat is unsuitable condition due to the Red Rocks and Grey Hills fires in 2011. (Ibid) The DSEIS errs on page 81 when it states "the Gros Ventre watershed provides little habitat" for Canada lynx. "Conifer and aspen stands south (upslope) of the feedground, including the analysis area, provide habitat for lynx." (Ibid: 82, parenthesis in original) Furthermore, "counts of snowshoe hare fecal pellets on one square mile plots east of the Alkali Creek Feedground (Upper Gros Ventre Slide and vicinity) during 2009 were moderate to high . . . " (Ibid). The BTNF may not permit activities that harm Canada lynx or their habitats. Response: We acknowledge (and indicate in the FSEIS, pages 91) that the south side of the Gros Ventre watershed provides some high quality lynx habitat based on horizontal cover and counts of snowshoe hare (fecal) pellets. To clarify for the reader, we modified the key sentence that the commenter identified as "in error". The sentence in text in the FSEIS (page 132) now reads: “The feedground site itself and the corridor analysis area provide little high quality habitat for Canada lynx." This statement is supported by the following data and observations in the same section: "Although some locations of Colorado lynx occurred in the Gros Ventre watershed, the sporadic locations suggested that no lynx used the area as residents." (page 90, FSEIS). “There currently are no records of lynx, including natal dens, at or near the Alkali Creek Feedground…” (page 90, FSEIS);
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Alkali Creek Feedground and its immediate vicinity (< 200 meters) to the east, west, and north provide little foraging and natal denning habitat for lynx due to sparse conifer forest and open understory conditions. “However, pellet count data collected from 2009 to 2013 on the north side of the Gros Ventre River 4 miles from the feedground suggested consistently low numbers of snowshoe hares.” (page 91, FSEIS); “Predominated by grassland, sagebrush, and rocky terrain, the Analysis Area (Gros Ventre River corridor) provides few of the primary elements of lynx habitat, namely foraging and denning habitat, and deep snow conditions. Dense, well-structured conifer stands are only extensive to the south of the feedground. “The Analysis Area readily provides ample matrix habitat for lynx travel, and contains no large anthropogenic barriers (e.g., roads or housing developments) to travel.” (page 91, FSEIS). In the effects analysis for Alternative 1, we also said “However, due the natural absence of dense coniferous forest cover and deep snow favored by lynx and their principal winter prey, the snowshoe hare, the Alkali Creek Feedground and its immediate vicinity does not naturally provide most of the primary consistent elements of lynx critical habitat (see habitat components in Existing Conditions section above). Vegetation cover at the feedground and vicinity includes mostly grasslands, sagebrush steppe, wet meadows, and scattered stands of aspen and conifers. An increase in the height and distribution of trees and shrubs would likely occur in the absence of feedground activity at feedground itself, and extending to 750 m from the feedground perimeter (Wyoming Game and Fish Department 2011). Removal of elk would not dramatically improve habitat conditions for lynx foraging and denning, and for snowshoe hares—analogous sites at in the same elevation and aspect adjacent to the feedground do not provide such prime habitat conditions for lynx.” (page 123, FSEIS); “The feedground site itself was also not mapped as lynx habitat under guidelines of the Lynx Conservation and Assessment Strategy (Ruediger et al. 2000).” (page 123, FSEIS). The above statements and information support our (now modified) conclusion (page 89-91) that the Alkali feedground and vicinity provide limited high quality foraging habitat for Canada lynx. With regard to the commenter’s statement that the Forest Service has a responsibility to “not permit activities that harm Canada lynx or their habitats”, the Bridger-Teton National Forest indeed has a goal (page 117, Land and Resource Management Plan) to achieve recovery of Endangered species and to prevent sensitive species from becoming federally listed as Threatened in Wyoming (page 123). The principal guidance documents that promote the recovery of Threatened lynx include the Forest Plan amendment for lynx (Northern Rockies Lynx Management Direction Summary) and the Lynx Conservation and Assessment Strategy. The proposed action is consistent with these document’s standards and guidelines. In keeping with the 1973 Endangered Species Act and its implementing regulations, we also consulted with the U.S. Fish and Wildlife Service and received concurrence on our conclusion that the proposed action will not carry adverse effects on lynx or Designated Revised Critical Lynx Habitat. Thus, although some minor negative effects on lynx and lynx critical habitat were identified in the effects analysis for Alternative 2, the proposed action is consistent with relevant law, regulation, and policy.
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107. Comment: Especially with the wolf numbers that have to be met to appease the U.S. Fish and Wildlife Service. The Gros Ventre is a wolf magnet and that herd has suffered severely with cow/calf ratios dipping to record low numbers. Elk displacement has become the norm and without the Alkali Feedground it will dramatically escalate to way worse problems with all elk issues. Response: Feeding elk does increase winter survival rates (FSEIS, page 106), however elk population numbers are not expected to be affected by closure of Alkali Creek Feedground in Alternative 1 because elk are expected to use other feedgrounds up or down-valley. In the Wildlife and Vegetation sections (Chapter 3) of the FSEIS, we compared the effects of the two alternatives on wolves (pages 129-130, 134-135), elk (pages 108-111 and 114-116), and vegetation (beginning on page 36). We did not compare the alternatives with respect to their effects on elk population dynamics because this analysis would be speculative. We considered the likely difference in elk movements and migrations under the two alternatives, and pointed out that under Alternative 2, Gros Ventre elk would be expected to increase their use of the National Elk Refuge, making it more difficult to attain the objectives of the Bison-Elk Management Plan for the National Elk Refuge and Grand Teton National Park.
108. Comment: Feedgrounds are not necessary to manage elk as we have written in previous comments to the BTNF about elk feedgrounds, the BTNF should take advantage of beneficial “natural capital” and ecological and geographical circumstances and manage for healthy habitat and healthy free-ranging wildlife rather than give 20-year permits for elk feedgrounds. The obvious truth is that the Gros Ventre Valley, where Alkali Creek exists, is surrounded by a contiguous expanse of federal public land including portions of the Shoshone Forest, the Bridger- Teton Forest, Grand Teton National Park, the National Elk Refuge and Yellowstone Park to the north. These hundreds of thousands of acres are in the heart of the Greater Yellowstone Ecosystem that totals some 20 million contiguous acres, the largest intact temperate ecosystem on the North American continent. The Bridger-Teton Forest, the Shoshone Forest, Grand Teton Park and the National Elk Refuge are inside the boundaries of the least populated state in our nation, Wyoming. Wyoming is about the same size as Colorado, but Colorado contains 9 times larger human population as Wyoming. Colorado also has nearly 3 times the amount of elk as Wyoming. Despite the large human population, three times the number of elk, and twice as many cattle in Colorado as Wyoming, Colorado doesn’t find it necessary to feed any of their 280,000 elk during winter. Nor does Montana or most any other jurisdiction in the Rocky Mountains. Rocky Mountain elk do not need artificial feed to thrive in Rocky Mountain winters, free-ranging elk can coexist in areas with livestock, feedgrounds are actually very harmful to elk and to habitat, and the BTNF should not permit elk feedgrounds. Better solutions to conflicts and better management methods for elk clearly exist. To continue the status quo on USFS lands is arbitrary and an abuse of agency discretion. As we explained in our 2008 DEIS comments and our May 2012 DSEIS scoping comments, “The BTNF is well aware that feedgrounds are not the only means of managing big game and big game habitat. Even within its own jurisdiction in Wyoming, on the BTNF itself, there are big game herds, including elk herds, which are not managed using winter feedlots, test and slaughter facilities, or bales of hay. The elk herds in the southern reaches of the Wyoming Range, the southern reaches of the Salt River Range, Commissary Ridge, and the Tunp Range, all within the BTNF, do not require feedgrounds. Nor do other big game species such as moose, bighorn sheep, mule deer, pronghorn antelope, mountain goats, or white-tailed deer throughout the BTNF. There are other methods of managing habitat and wildlife on and near the
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BTNF, and analysis of such methods under this EIS is reasonable, as well as legally mandated.” In this DSEIS, Table 1 List of Other Issues, page 10, there is a critical error put forth as fact: “Much of the native winter range for elk is not located on the National Forest, and is not available due to development and agriculture . . . . There are ongoing efforts to improve habitat on the National Forest, particularly winter range, but these efforts cannot compensate for the loss of native winter range in the short term.” The BTNF knows full well that virtually ALL of the native winter range in the Gros Ventre Valley where Alkali Creek Feedground is located is on USFS land and that there is approximately 100,000-acres of it. We submitted the references for this in our May 2012 SDEIS scoping comments 2. Anderson, Chester. 1958. The Elk of Jackson Hole: A Review of Jackson Hole Elk Studies. Wyoming Game and Fish Commission. Cheyenne, WY. ; and, 34. Wyoming Game and Fish Department. 2006). Evaluation of a Proposal from the Wyoming Outdoor Council, Greater Yellowstone Coalition and Jackson Hole Conservation Alliance for a Phase Out of Elk Feeding in the Gros Ventre. Cheyenne, WY.) Indeed, in the BTNF’s own Winter Travel Map 12/1 – 4/30, Revised/reprint 1993, the BTNF portrays purple polygons on the map where winter travel is restricted because of “Protection of wildlife on crucial big game winter ranges.” How can the BTNF continue to deny that there is plenty of winter range for thousands of free-ranging elk, particularly in the Gros Ventre Valley where Alkali Creek is? This denial is continued throughout the SDEIS and comes to light again and again when the BTNF defers to the policy of the Game and Fish to feed elk implying that there is no other alternative. There is a readily available and healthy- and free- alternative and that is to allow elk to use their ancestral winter ranges which, in the case of the Gros Ventre Valley, literally surround the areas- are within the view of the elk- where elk are artificially clustered together during winter by putting out hay. As Chester Anderson, 1958, and others have documented, thousands of elk wintered quite well in the Gros Ventre Valley in the early 1900’s (and probably for centuries prior) without elk feedgrounds. Those same winter ranges exist, are protected by the USFS, and can provide for thousands of elk as both GYC and the WGFD agree. Below is an excerpt from our May 2012 scoping comments: In 2005 the Greater Yellowstone Coalition calculated how many elk could winter in the Gros Ventre Valley: “Using some conservative assumptions such as dry-year production values, and estimating forage production, consumption by elk, and availability of forage during winter, it appears that between 4,419 – 6,628 elk can winter naturally on 33% - 50% of winter range while consuming only 60% - 64% of the palatable and accessible forage without supplemental feeding.” (GYC 2005) In 2006 the Wyoming Game and Fish Department responded to this proposal: “(B)ased on the three carrying capacity estimates calculated in this assessment for mean and above average precipitation years, to some degree historic accounts of elk numbers and starvation events, and the need to prevent added competition for forage with bighorn sheep and moose wintering in the Gros Ventre valley, it appears there may be adequate forage available most winters for an elk herd closer to 3,000 than the current 4,000-4,500.” (WGFD 2006:25) The number of elk counted in the Gros Ventre Valley during February 2012 by the WGFD is approximately 3,300. (Doug Brimeyer, personal communication and handout March 2012) Elk numbered approximately 4,000 – 4,500 around the time of the WGFD response to the NGO’s proposal to phase out winter feeding. (WGFD 2006, Figure 1) So, elk numbers have decreased by around 1,000, which achieves one of WGFD’s qualifiers to attempt phasing out winter feeding. 3,300 is also well below the carrying capacity determined by the NGO’s. We have submitted information in our previous comments about the very few (only 2 or 3) livestock and haystack
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Response to Comments fencing opportunities in the Gros Ventre that would prevent commingling of elk and livestock. There are only around 80 mother cows and approximately 150 or so horses that could easily be held behind elk-proof fences. Despite feedgrounds operating each winter, conflicts with elk continue to occur at these ranches year after year. So, without fences and with feedgrounds it’s a failed policy all around; elk keep getting into livestock and feedlines and elk keep getting sick on feedgrounds. Better solutions, such as elk-proof fencing at the private property boundaries of those few ranches in the Gros Ventre Valley, need to be assessed in an EIS and implemented. The Gros Ventre Valley within the Bridger-Teton National Forest is situated in between the CWD endemic area west of Thermopolis, Wyoming, and Grand Teton National Park and the Elk Refuge. (GYC 2009 CWD map, revised May 2013) Deer and elk are known to travel back and forth among these areas. (Smith 2005, WGFD 2009) The worst thing that the BTNF can do for the wildlife of Grand Teton National Park and the National Elk Refuge is to permit and maintain elk feedgrounds that would, according to experts, amplify the prevalence of deadly CWD and potentially cause a catastrophic outbreak among the elk and other cervids of Grand Teton National Park and the Elk Refuge (Smith 2005, Peterson 2005). Conversely, one of the best things the BTNF can do is not permit elk feedgrounds and allow big game to traverse those same landscapes in accordance with their natural behaviors. The responsibility is on the shoulders of the BTNF and the best way forward is clear: determine where the most effective locations are for elk-proof fences, and do not permit feedgrounds. 109. Response: We concur with the commenter’s assertion that the Gros Ventre Watershed, including the National Forest System lands located there, provides ample winter range for wintering elk and other wild ungulates. Accordingly, all language was removed in Table 1 (List of Other Issues) that indicates to the contrary. However, during severe winters forage may be limited and movements of animals out of the drainage are likely to be more common. Elk numbers observed in 2014 and 2014 in the upper Gros Ventre were below Wyoming Game and Fish Commission objective levels. Additional text was added to the Wildlife Specialist Report and the FSEIS that reviews winter range carrying capacity estimates made by Dorsey (2005) and Wyoming Game and Fish Department (2006). Wyoming Game and Fish Commission has set an objective of 3,500 elk wintering in the upper Gros Ventre. Adequate amount of winter range appears to be available for the 3,000 elk that currently use the Gros Ventre Valley, especially in mild or average winters. However, elk have moved down drainage to private lands and the National Elk Refuge in recent years. The acreage of winter range available to the Jackson elk herd overall is a limiting factor, at least in the context of the 11,000-elk objective set by the Wyoming Game and Fish Commission (WGFC). This is because winter range in Jackson Hole proper and Buffalo Valley that also supports the Jackson herd is inadequate (USFWS 1999b, cited in U.S. Fish and Wildlife Service and National Park Service 2007, project record). WGFD's primary use of the Alkali Creek Feedground is to prevent movement of elk from the upper Gros Ventre Valley to private lands down valley and to the National Elk Refuge (NER), not to increase elk numbers. Regardless of what alternative is selected, movement of Gros Ventre elk on to private lands in the Gros Ventre watershed and to the NER is undesirable. The amount of native range available to elk does not affect this movement--other feedgrounds in the Gros Ventre would remain operational and concentrate elk, and the Gros Ventre elk herd is likely to remain the same size (and at or below carrying capacity) under both alternatives. The use of private lands increases the probability of brucellosis
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Response to Comments transmission from infected elk to domestic livestock such as cattle, increases damage to private property such as fences, and reduces stockpiles of forage available to cattle (haystacks). Movement of elk to the NER exacerbates U.S. Fish and Wildlife Service and National Park Service (NPS) efforts to achieve objectives identified in their elk and bison management plan, that is, to limit numbers of elk wintering on the NER to 5,000, to reduce reliance on supplemental feeding, and to subsequently maintain desired habitat and population conditions in a way that elk rely predominantly on native habitat and cultivated (NER) forage. If large numbers of Gros Ventre elk were to migrate to the NER because of closure of the Alkali Creek Feedground, and additional removal of elk by hunting was necessary to meet the NER/NPS Plan objectives, then maintaining elk at the 11,000 (WGFC) objectives would be more difficult than at present. In sum, simultaneously attaining both the NER/NPS and the WGFC objectives would be more difficult if large numbers of Gros Ventre elk were to migrate to, and use the NER feed lines during the winter. Direction to support the WGFC objectives for the Jackson elk herd is provided in the Bridger-Teton Land and Resource Management Plan (page 114): “Provide suitable and adequate habitat to support the game and fish populations established by the Wyoming Game and Fish Department, as agreed to by the Forest Service.” The Forest Service considers and agrees to the Game and Fish Commission objectives directly and indirectly in annual coordination meetings (including USFS-WGFD meetings to provide input on hunting seasons and meetings of the Jackson Interagency Elk Working Group), by participating on the committee to develop an adaptive management plan for elk on the National Elk Refuge, and by contributing funding for telemetry-based elk monitoring.
110. Comment: An obvious problem with the BTNF relying so heavily on the Wyoming Game and Fish Department (see our comments on the ID Team) is that the WGFD rationalizes away the science and the recommendations from renowned experts by claiming there’s no other way than winter feedgrounds to manage elk in western Wyoming for a variety of alleged ecological and political reasons that don’t really to any third party perspective - stand up to scrutiny. For example, as we pointed out above, despite claims that sufficient winter range isn’t available to elk in western Wyoming (“Much of the native winter range for elk is not located on the National Forest, and is not available due to development and agriculture.” SDEIS:10) the BTNF should know well that there is plenty of winter range on USFS in the Gros Ventre Valley to winter thousands of big game animals because the WGFD Jackson Elk Herd Unit (E-102) Brucellosis Management Action Plan Updated April 2011 displays a map of the winter range on page 3 at Figure 2. Currently delineated seasonal elk range sand feedgrounds within the JEH. The BTNF knows that the expansive polygons on the map titled “Crucial Winter” and “Winter” are virtually entirely on USFS land. The BTNF only has to peruse other GIS maps of winter range and notice how much exist on USFS or BLM lands to realize the WGFD’s lament about a dearth of winter range is false. The designated winter range in the Gros Ventre Valley, to continue the one example, is approximately 100,000-acres. See the photo below of a sign on the BTNF in the Gros Ventre Valley announcing big game winter range. Critical Wildlife Winter Range sign in the Gros Ventre Valley. L. Dorsey Another canard expressed in the DSEIS is that “Habitat improvement projects cannot compensate for the loss of native winter range in the short-term and would not affect the current needs for supplemental feeding.” (DSEIS: 9) Since whether to issue a feedground permit at Alkali Creek is at issue in this DSEIS, the Gros Ventre Valley is again an appropriate context in which to consider whether habitat improvement is
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Response to Comments effective at improving and maintaining elk winter range and whether there is enough forage for elk and other big game. The BTNF knows well that it has led the effort to manage wildfire for resource benefits when possible for decades in the Gros Ventre Valley, and it implements Jackson Interagency Habitat Initiative (JIHI) prescribed fires on large areas in the Gros Ventre Valley on and adjacent to elk winter range. These actions improve the forage quality on winter range. The BTNF has also implemented travel management for summer, fall and winter/spring motorized and non-motorized human travel on winter ranges in the Gros Ventre, with most of the expansive designated winter range closed to all human entry during the winter months, and summer/fall motorized travel managed so as to minimize erosion, disruption to wildlife and other harm to habitat. The BTNF participates in weed control on Gros Ventre Valley elk winter ranges. The BTNF manages cattle grazing on USFS winter ranges and, in fact, in 2007 received a permit waived back to the B-T from the permittee on the Fish Creek/Bacon Creek Allotment which vacated 178,000-acres of USFS from cattle. 59,000 acres of that very area is designated by the BTNF as a “Big Game Winter Forage Allotment”. All these management actions (fire, travel management, grazing, and weeds) affect the quality and quantity of winter range available to big game. The BTNF should know that there is plenty of winter range in the Gros Ventre Valley to roam and feed upon by thousands of elk and other big game. They err- indeed they mislead the public- in the DSEIS when they indicate on page 9 that there is still the “need () for supplemental feeding”. There is not. Rather than mistakenly deferring to another agency, the BTNF can certainly conduct its own carrying capacity analysis for available public lands winter ranges near or reachable by wintering elk. Despite offloading the responsibility for using or creating appropriate science far too often by referring to the Memorandum of Understanding with the WGFC, 00-MU-11020000-052, in the DSEIS, the BTNF obviously has the professional expertise among existing staff if the listing of the ID Team on page 153 is any indication. Listed are no less than 2 wildlife biologists employed the USFS, plus a Soils Scientist, a Hydrologist, a Botanist, a Natural Resource Manager-Recreation/Wilderness staffer and others with the expertise, one would assume, needed to assess the big game carrying capacity of habitat. If those personnel are not sufficient the BTNF may be able to consult with other independent or agency personnel to assist. Fortunately, the BTNF does not have to abide by the WGFD’s rationale to maintain elk feedgrounds because the BTNF retains authority over USFS land and must manage according to law and science. The obvious exclusion by the BTNF of recognized disease experts and the astonishing de facto reliance on whatever the WGFD says, reports or wants is arbitrary on the part of the BTNF. A decision to issue to the WGFD long term permits to operate the elk feedgrounds would be “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law” (5 USC 706(2)(A)). Response: We concur with the commenter’s assertion that the Gros Ventre Watershed, including the National Forest System lands located there, provides ample winter range for wintering elk and other wild ungulates. Accordingly, all language was removed in Table 1 (List of Other Issues) that indicates to the contrary. However, during severe winters forage may be limited and movements of animals out of the drainage are likely to be more common. Elk numbers observed in 2014 and 2014 in the upper Gros Ventre were below Wyoming Game and Fish Commission objective levels. Additional text was added to the Wildlife Specialist Report and the FSEIS that reviews winter range carrying capacity estimates made by Dorsey (2005) and Wyoming Game and Fish Department (2006). Wyoming Game and Fish Commission has set an objective of 3,500 elk wintering in the upper
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Gros Ventre. Adequate amount of winter range appears to be available for the 3,000 elk that currently use the Gros Ventre Valley, especially in mild or average winters. However, elk have moved down drainage to private lands and the National Elk Refuge in recent years. The acreage of winter range available to the Jackson elk herd overall is a limiting factor, at least in the context of the 11,000-elk objective set by the Wyoming Game and Fish Commission (WGFC). This is because winter range in Jackson Hole proper and Buffalo Valley that also supports the Jackson herd is inadequate (USFWS 1999b, cited in U.S. Fish and Wildlife Service and National Park Service 2007, project record). WGFD's primary use of the Alkali Creek Feedground is to prevent movement of elk from the upper Gros Ventre Valley to private lands down valley and to the National Elk Refuge (NER), not to increase elk numbers. Regardless of what alternative is selected, movement of Gros Ventre elk on to private lands in the Gros Ventre watershed and to the NER is undesirable. The amount of native range available to elk does not affect this movement--other feedgrounds in the Gros Ventre would remain operational and concentrate elk, and the Gros Ventre elk herd is likely to remain the same size (and at or below carrying capacity) under both alternatives. The use of private lands increases the probability of brucellosis transmission from infected elk to domestic livestock such as cattle, increases damage to private property such as fences, and reduces stockpiles of forage available to cattle (haystacks). Movement of elk to the NER exacerbates U.S. Fish and Wildlife Service and National Park Service (NPS) efforts to achieve objectives identified in their elk and bison management plan, that is, to limit numbers of elk wintering on the NER to 5,000, to reduce reliance on supplemental feeding, and to subsequently maintain desired habitat and population conditions in a way that elk rely predominantly on native habitat and cultivated (NER) forage. If large numbers of Gros Ventre elk were to migrate to the NER because of closure of the Alkali Creek Feedground, and additional removal of elk by hunting was necessary to meet the NER/NPS Plan objectives, then maintaining elk at the 11,000 (WGFC) objective would be more difficult than at present. In sum, simultaneously attaining both the NER/NPS and the WGFC objectives would be more difficult if large numbers of Gros Ventre elk were to migrate to, and use the NER feed lines during the winter. Direction to support the WGFC objectives for the Jackson elk herd is provided in the Bridger-Teton Land and Resource Management Plan (page 114): “Provide suitable and adequate habitat to support the game and fish populations established by the Wyoming Game and Fish Department, as agreed to by the Forest Service.” The Forest Service considers and agrees to the Game and Fish Commission objectives directly and indirectly in annual coordination meetings (including USFS-WGFD meetings to provide input on hunting seasons and meetings of the Jackson Interagency Elk Working Group), by participating on the committee to develop an adaptive management plan for elk on the National Elk Refuge, and by contributing funding for telemetry-based elk monitoring.
111. Comment: The North Jackson Elk Herd, including those that winter in the Gros Ventre River drainage at the Alkali Creek Feedground, share summer and winter range areas with other herd segments in Grand Teton (GTNP) and Yellowstone National Parks and the USFWS’ National Elk Refuge (NER). Past work has made it clear that management of elk in one portion of the herd can also affect other segments. Thus, the National Park Service and NER have a strong vested interest in adopting coordinated and consistent management strategies for this herd. The GTNP and NER, in cooperation with the Wyoming Game and Fish Department (WGFD), completed a Bison and Elk Management Plan (BEMP) in 2007. The BEMP acknowledged that brucellosis transmission among elk is generally thought
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Response to Comments to be largely influenced by high concentrations of elk associated with winter feeding programs. Similarly, elk concentrated on feedgrounds is likely to facilitate the spread of chronic wasting disease (CWD) when it reaches this area. As such, an overarching strategy to achieve the goals of the BEMP is to reduce reliance on winter supplemental feeding of bison and elk, and to transition to complete reliance on natural standing forage at an undetermined time in the future. Reduced reliance on supplemental feeding is to be achieved by increasing natural standing forage on the GTNP and the NER, reducing the bison herd to 500 animals, and reducing the number of elk receiving supplemental feed on the NER to 5,000. We recommend the USFS, in conjunction with WGFD, consider some of these same goals for the Alkali Creek Feedground permit. For example, working with WGFD, the BEMP adopted a strategy to phase in a transition to reliance on native forage by installing new irrigation systems to improve forage production on the NER, and the NPS initiated habitat restoration to improve native plant communities that support elk and bison on transitional ranges. The BEMP also outlined a range of goals that are being implemented to address disease concerns, including, but not limited to, reducing elk and bison numbers and wintering densities, changing feeding sites daily, separating elk and bison, and feeding along meandering lines. The BEMP called for identifying criteria, in collaboration with WGFD, that would determine factors such as feeding initiation date, season length, daily ration, and winter conditions under which feeding would be necessary. We recommend the USFS adopt a similar approach for the Alkali Creek Feedground. Response: The Forest Service agrees that down-valley migrations of elk in the Gros Ventre watershed to the National Elk Refuge (NER) hamper the ability of the involved state and federal agencies to meet objectives of the Bison and Elk Management Plan. The WGFD employs a management strategy to prevent this movement, aimed not only at preventing excessive elk numbers on the NER but also preventing mingling between elk and livestock, and elk damage to stored hay crops on private property in both the Gros Ventre watershed and in Jackson Hole. The WGFD coordinates closely with USFWS Staff regarding the onset of feeding on the NER. However, a structured framework between the WGFD and USFS is not necessary, as the USFS is not actively involved in day-to-day elk feeding operations. The WGFD does maintain communication with the USFS regarding operations of the Gros Ventre feedgrounds in order to meet the terms and conditions of the feedground special use permit. The Forest Service has implemented actions in the past decades that have improved big game winter range in the Gros Ventre watershed. These actions include management of wildfire and prescribed fire for resource benefit, travel management for summer, fall and winter/spring motorized and non-motorized travel, weed control, and reductions in livestock grazing.
112. Comment: As in the BEMP, we also recommend the USFS work with WGFD to develop a structured framework to coordinate feeding efforts with other feedgrounds in the area. Without such actions, elk management on the Alkali Creek Feedground may negatively impact the management of elk on the NER and Yellowstone and Grand Teton National Parks. For example, GPS elk tracking data have demonstrated an exchange of elk between the Alkali Creek Feedground and the NER during winter months. In addition, experience has shown that if supplemental feeding is not synchronized between these two sites, elk can drift down valley from Alkali Creek to the NER. This can substantially increase the number of elk on the NER and could prevent population objectives outlined in the BEMP from being
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Response to Comments achieved. Response: The Forest Service agrees that down-valley migrations of elk in the Gros Ventre watershed to the National Elk Refuge (NER) hamper the ability of the involved state and federal agencies to meet objectives of the Bison and Elk Management Plan. The WGFD employs a management strategy to prevent this movement, aimed not only at preventing excessive elk numbers on the NER but also preventing mingling between elk and livestock, and elk damage to stored hay crops on private property in both the Gros Ventre watershed and in Jackson Hole. The WGFD coordinates closely with USFWS Staff regarding the onset of feeding on the NER. However, a structured framework between the WGFD and USFS is not necessary, as the USFS is not actively involved in day-to-day elk feeding operations. The WGFD does maintain communication with the USFS regarding operations of the Gros Ventre feedgrounds in order to meet the terms and conditions of the feedground special use permit. The Forest Service has implemented actions in the past decades that have improved big game winter range in the Gros Ventre watershed. These actions include management of wildfire and prescribed fire for resource benefit, travel management for summer, fall and winter/spring motorized and non-motorized travel, weed control, and reductions in livestock grazing.
113. Comment: Wildlife Resources Mule deer, moose, and pronghorn – Direct and indirect effects – the analysis states that Alternative 1 would reduce human activity at the feedground, particularly in the winter and summer. It should be noted that this area serves as a public trail head, and reduction in summer human activity is not likely. The last sentence of the last paragraph on page 101 states that few moose use the willow communities between Alkali and Fish Creek. On page 102 the analysis concludes that Alternative 1 would bring positive local effects on moose due to elk herbivory relief. These seem like contradictory statements. Response: With regard to the reduction of human activity at the feedground, we added a statement in the FSEIS on page 112 to indicate that the Alkali Creek Feedground is located next to a public trailhead, so a strong reduction in human activity is unlikely. With regard to the contradiction regarding the effects of Alternative 1 on moose, we removed the discussion that states that few moose use the willow communities between Alkali and Fish Creeks. This change eliminates the contradiction.
114. Comment: Please do not feed them unhealthy food. Follow the feeding procedures of ELK as done in Elk Grove Village Illinois. Response: Feedgrounds on National Forest System (NFS) lands are operated by Wyoming Fish and Game Commission, not the Forest Service. In this project, it is within WGFC's jurisdiction to decide whether or not to feed elk in western Wyoming and it is within the Forest Service’s jurisdiction to decide whether or not to authorize the use of NFS lands for feedground purposes. Elk Grove Village, Illinois supports approximately 20 elk in a fenced urban forest preserve. The Jackson Elk herd numbers over 11,000 animals and inhabits hundreds of square miles. There are significant differences in managing these two elk herds. Please see Appendix 2 for specific information regarding supplemental feeding of elk in western Wyoming.
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115. Comment: Grizzly Bear "Although grizzly bears have widely varied diets, in Yellowstone they feed heavily on four key foods: whitebark pine, Yellowstone cutthroat trout, Army cutworm moths, and ungulates." (Craighead, et al. 2005:8) "Elk that die on the feedground serve as attractants that potentially lead bears into conflict with feedground personnel." (DSEIS: 117). "Should they become established, pathogens such as chronic wasting disease could affect numbers of elk, an important food source for grizzly bears (Mattson et al. 1991) in the Gros Ventre watershed in both short-term (less than 10 years) and long-term." (Ibid) "By concentrating animals, winter elk management at feedgrounds in the Gros Ventre watershed would contribute to new diseases such as chronic wasting disease becoming established and sustained in the Gros Ventre watershed and the region overall with the caveat that other feedgrounds would contribute to disease prevalence as well, regardless of management in the Gros Ventre watershed." (Ibid: 114) We certainly agree with most of the preceding statement that feedgrounds contribute to diseases and sustaining them, but the BTNF errs when it states that such will happen "regardless" of feedgrounds being in the Gros Ventre watershed. If the BTNF helps phase out feedgrounds, or even one feedground, in the Gros Ventre Valley that could be an important step in decreasing the elevated risk of wildlife diseases occurring and being amplified by feedgrounds in the region. The BTNF appears to dismiss the practicality, even the undeniable reality, of progressing towards a goal step by step and progressively managing for healthy natural resources. This is an arbitrary position adopted by the BTNF and does not offer the public any possible means to change or improve any management paradigm. How else do things improve other than in a step by step manner? Ending the elk feedground at Alkali Creek would have positive effects which could lead to more positive actions and effects. Continuing to operate elk feedgrounds that increase the risk of harmful diseases among elk will result in adverse impacts to "an important food source for grizzly bears". (Ibid: 117) The BTNF can implement a far better management paradigm for predators and prey alike by not permitting a feedground at Alkali Creek. Response: The Forest Service project biologist determined that the proposed action may affect grizzly bears but would not likely adversely affect them and would not impede the recovery of the grizzly bear population on the Bridger-Teton National Forest or in the Yellowstone ecosystem (FSEIS, page 133).
116. Comment: Impacts to Mule deer, Moose The DSEIS indicates that if the BTNF permits the feedground at Alkali Creek there will be adverse impacts to mule deer and moose because permitting the elk feedground at Alkali Creek, "contributes negatively toward achieving the herd objectives because it creates less favorable habitat conditions (less woody browse) for the two species near the feedground." (DSEIS: Exec Summary vii) The BTNF should acknowledge that additional impacts of elk feedgrounds to mule deer and moose, both cervids, would also be the eventual amplification of CWD should the elk be concentrated on feedgrounds during winter, acquire the deadly CWD in greater prevalence than in wild free-ranging elk, and then spread the disease throughout the landscape in greater prevalence than by herds not concentrated for several months on winter feedgrounds. Response: The Forest Service agrees with the commenter that an additional negative impact of the feedgrounds to mule deer and moose would be the eventual amplification of CWD should the elk concentrated on feedgrounds contract the disease. The FSEIS displays this additional effect on pages 83-84 and 106-107, 109, and 115.
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117. Comment: If the feedground at Alkali Creek were removed, elk would not concentrate in that area and would instead move over a greater area within the Gros Ventre drainage. Within the Environmental Consequences (SEIS: 96) there is repeated emphasis on constraining elk movement by maintaining this feedground thus preventing impacts within a potentially larger geographic area. This fails to address the greater, more detrimental, impacts that occur if elk are concentrated in a smaller area for a prolonged time over many years. Response: The Forest Service agrees with the commenter that the concentration of elk at Alkali Creek Feedground in the winter creates detrimental impacts on both elk and the environment near the feedground. If the feedground at Alkali Creek were to be removed, elk would end up overwintering on adjoining private agricultural lands (where elk would likely damage haystack yards and winter pastures) or on the National Elk Refuge (NER). The 2007 Bison and Elk Management Plan sets an objective for having no more than 5,000 elk on feed on the NER, which cannot be met if substantial numbers of elk leave the Gros Ventre drainage. These effects are displayed throughout the environmental consequences section of the FSEIS.
118. Comment: The map, Existing Feedground Locations in the Vicinity of Alkali Creek, Figure 3, DSEIS: 13, shows the Gros Ventre Valley, but does not indicate a very important feature: big game winter ranges. Neither does the map, Corridor Analysis Area Boundary, DESIS: 26. Since the best alternative to elk feedgrounds is winter range (see our comments above) the BTNF curiously omits this feature on these maps. The BTNF claims there is no winter range available to elk in this area, but as our comments prove, there is ample winter range to sustain thousands of free-range elk. Response: We agree that a map of crucial winter range for the relevant wildlife ungulates is pertinent to this analysis and have added it to the FSEIS as Figure 14 on page 85. There are 17,109 acres of crucial winter range available to elk in the project analysis area in the Gros Ventre watershed (FSEIS, page 82).
119. Comment: The forest should not permit the Wyoming Game & Fish Commission to operate an elk feedground at Alkali Creek beyond the winter of 2013-14. If it is permitted then there should be the reintroduction of wolves, mountain lions and other predators to eliminate the diseased elk. Response: Wolves, mountain lions, and grizzly bears already exist in the Gros Ventre drainage and are expected to prey upon diseased elk and other elk that are vulnerable. Disease 120. Comment: As I understand it, members of the U.S. Forest Service are trained professionals, who have majored in either Botany or Zoology, perhaps even veterinary sciences and have a clear understanding of the ecosystems where they work. If this is indeed so, why would there even be a question of undertaking ANY action -- such as winter feeding -- which would promote certain diseases among the wildlife under their charge?? Perhaps one of the major factors could be the fact that your ungulates aren't culled sufficiently by their natural predators, who are too severely culled themselves, under pressure from the ranchers & sheep men surrounding our parks and who are too often "feeding at the public trough" by pasturing their cattle on federal lands!! Their cattle & sheep are the "invading species" -- not the local wildlife, whom your agency is supposed to be protecting. Get Your Priorities Straight: Our precious wildlife -- not herds of cattle & sheep nor the occasional hunter, who wants to
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Response to Comments take home a trophy to hang over his fireplace!! Response: Thank you for providing your views concerning the relationship between winter elk feeding and wildlife disease; wolves and elk as their prey; livestock grazing on Forest Service lands; and big game hunters. The effects of continuing to authorize the facilities at Alkali Creek for Wyoming Game and Fish’s Winter Elk Management Program on elk and disease are discussed in the Final Supplemental Environmental Impact Statement (FSEIS) in Chapter 3 (page 84-85, 106-107, 109, and 115). The artificial concentration of elk during late winter and early spring is known to perpetuate brucellosis. Conversely, feedgrounds serve to aid in the separation of elk from cattle and thereby limit the potential of the disease transmission form elk to cattle. Brucellosis infections in cattle can impact Wyoming's brucellosis free status, resulting in increased testing requirements and potential trade sanctions on Wyoming’s cattle producers. Thus, elk feedgrounds maintain the disease in elk while limiting elk-to-cattle transmissions at the same time. Chronic wasting disease is well-established in Wyoming and Colorado, having existed there for at least three decades. In these states, as well as in Wisconsin and Saskatchewan, all management strategies to stop the spread of CWD have failed (page 83-84, FSEIS). Therefore, it is probable that CWD will be found in elk in northwestern Wyoming at some point in time and there appears little that wildlife management agencies can do to prevent this, including not conducting winter elk feeding operations at Alkali Creek. Although we do not have a side-to-side comparison to the feedgrounds and any other herds in the state, the Laramie Peak elk herd in southeast Wyoming remains a very productive herd in spite of living within the CWD endemic area for at least 30 years. This herd can approach similar densities as feedground herds in the winter, but CWD prevalence remains less than 10%, while overlapping deer herds exceed 40% (J. Binfet - Wyoming Game and Fish Department Biological Coordinator, Casper Region, personal communication). The relationship between feedground-supported elk and gray wolves, and the effect of wolf control actions in response to wolf depredations on livestock are discussed on page 92 and pages 129-130 in the FSEIS. Wolves are currently federally protected under the 1973 Endangered Species Act as an experimental, non-essential species. Neither Wyoming (under previous Wyoming wolf management) nor the U.S. Fish and Wildlife Service have ever initiated efforts to lethally remove or relocate wolves that consistently visited the feedgrounds in the Gros Ventre watershed and disrupted elk movements or use of supplemental feed. Thus, we believe that it is highly unlikely such measures would occur in the future, given the current status of the species as protected under the 1973 Endangered Species Act.
121. Comment: Some say the wasting disease is caused by feeding the elk or that if they weren’t fed there they wouldn’t have so many coming in contact with diseased elk...I would like to know if there is a vaccine or antibiotic that could be put into the food to cure the disease. I don’t want them to disappear or all starve to death...We have wasted so much of their habitat...we need to find a solution without abandoning them. Response: Research is currently being conducted on Chronic Wasting Disease (CWD) vaccines; however no effective vaccine has been identified to date. There is no known cure for CWD. Please see the Environmental Consequences section pages 106-117 and Appendix 7, for a review of CWD.
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122. Comment: Bison are being hazed and shot because of Brucellosis that they don't even carry. It is the cattle as you well know. Response: Based on testing by the Wyoming Game and Fish Department (WGFD) over the past several decades, wild bison in the Jackson area have a 61% sero-prevalence rate for brucellosis. In the Jackson area, bison are only hazed when damaging private property or posing a threat to human safety.
123. Comment: The BTNF ignores CWD experts and expert reports as we explained above and will detail further here, in the DSEIS and previously in the 2008 DEIS and ROD, the BTNF ignored prevailing contemporary science about the relationship between feeding and concentrating cervids and Chronic Wasting Disease and other infectious diseases. The BTNF made a decision in 2008 to re-permit elk feedgrounds that was arbitrarily in opposition to the counsel of disease experts, a violation of agency discretion. Examples follow of some expert reviews and recommendations that the BTNF continues to ignore. In the November 2002 “Review of Chronic Wasting Disease Management Policies and Programs in Colorado” report by “an external review panel”, page 11: Implemented or proposed management strategies include: -regulations to prevent feeding and baiting of cervids: This is a reasonable approach for reducing contact among potentially infected and susceptible animals and the potential for environmental contamination and should be enforced. Feeding also might artificially increase population density. The Colorado Division of Wildlife or private parties should not use feeding as a management strategy in severe winters. In the February 2003 “Chronic Wasting Disease and the Science in support of the Ban on Baiting and Feeding Deer” by Timothy R. Van Deelen, PhD, of the Wisconsin Department of Natural Resources Research it notes: In a review of the technical literature on CWD by the top CWD specialists in the world . . . “Concentrating deer and elk in captivity or by artificial feed probably increase the likelihood of direct and indirect transmission between individuals. . . . . (Williams et al. 2002, page 557) Several other experts who point out the higher risks of CWD in concentrated cervids are quoted by Dr. Van Deelen in his report. In the July 2004 “Chronic Wasting Disease in Canadian Wildlife: An Expert Opinion on the Epidemiology and Risks to Wild Deer Prepared by: Expert Scientific Panel on Chronic Wasting Disease”, the experts recommend on page 21 at B: Management of free-living cervids 1. Develop and implement policies to minimize artificial aggregations of free-living cervids to reduce transmission of CWD. Actions should include: ??Prevent access to hay stacks, salt blocks, and artificial water sources by wildlife in high risk areas. ??Ban baiting or artificial feeding for cervids in high risk areas. In the 2010 Boston College Environmental Affairs Law Review article, “Trampling the Public Trust” by Debra L. Donahue, she notes, “Experts agree that CWD cannot be eradicated, yet it may be possible to slow and perhaps interrupt its spread. “Thus the emphasis should be placed on preventing (CWD) from becoming established in naïve cervid populations.” Reducing animal density by banning supplemental feeding is among the experts’ top recommendations.” (Donahue, 2010, page 285, citing Sigurdson 2008, Peterson [in quotes], 2003, Williams, et al, 2002, and Smith 2001.) The BTNF should also know that at the section on Resources: CWD Experts on the CWD website http://www.cwd-info.org/index.php/fuseaction/resources.experts (last viewed 5-18-13) out of one dozen experts listed, no employee of the Wyoming Game and Fish Department or Commission is on the list. Among the biggest errors and assumptions made by the BTNF in this DSEIS is to state, "(P)reliminary evidence in captive elk suggests that elk can maintain very high prevalence of CWD without a concomitant population decline if allowed to reproduce. (Kreeger, unpubl. data.)" (DSEIS: 97)
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This one alleged study, conducted in the WGFD's own facility, and which is unpublished by a now retired Wyoming Game and Fish Department employee is used by the BTNF to counter all the expert reports concerning actual and anticipated effects of CWD on cervids available by reputable scientists some of which reports have been supplied to the BTNF or referenced in comments submitted by the Greater Yellowstone Coalition. How is the public to access such a remarkable finding of the WGFD if it is "unpublished"? Furthermore, how is such an alleged finding applicable to wild elk? As Bruce Smith, PhD, says in his book, Where Elk Roam, "animals debilitated by CWD would quickly be culled by large carnivores- an elegant natural check on the spread of disease. . . . packs of gray wolves chase and single out disadvantaged prey, what David Mech and other wolf biologists called the "sanitation effect" of predation." (Smith, 2012: 113) However, Smith offers a sobering assessment of outcomes when elk are concentrated on feedgrounds: "For the overstuffed numbers of elk on feedgrounds, however, there may be too few wolves to keep pace with disease epizootics." (Ibid) Rather than allow the WGFD to select the science and the reports to only suit their narrow purpose, in this case to perpetuate elk feedgrounds, the BTNF must incorporate the best available science in this analysis. This EIS fails on these accounts. In the closing remarks at the 2009 International Chronic Wasting Disease Symposium in Park City, Utah, Bryan Richards of the USGS characterized Wyoming's approach to CWD as the worst case scenario. "CWD affected wild animals have holes in their brains- how good can they take care of themselves and their offspring?" (L. Dorsey, 2009, personal notes from the Symposium) The BTNF errs when it states, "model predictions of CWD leading to declining abundance, or even local extinction have not occurred anywhere in free-ranging cervid populations (Peterson 2005)." This information is now known not to be true. "In 2010, 48 percent of the hunter-harvested mule deer in this (Converse County) herd tested positive for CWD. While the herd has decreased by more than 50 percent over the past 10 years, CWD prevalence has continued to increase each year." (Glenrock Independent, 3-31-11, parenthesis added) See also the graph and chart below from the 2011 WGFD Casper Region Mule Deer Job Completion Report, page 180. Smith also describes a "twenty-year population decline of deer" in a mule deer herd near Boulder, Colorado affected by CWD. (Smith, 2012: 113) Despite the BTNF's assertion otherwise, herds of cervids have declined with high prevalence of CWD. The BTNF concludes their discussion of CWD with, "there appears to be little that wildlife management agencies can do to prevent this." (DSEIS: 97) They further err on an order of the highest magnitude imaginable when the BTNF concludes, "There are currently no empirical data to support the contention that CWD in elk utilizing winter feedgrounds will result in catastrophic, even observable, population declines." (DSEIS: 98) The BTNF errs because they ignore virtually all CWD expert reports, they ignore game farm examples, and they ignore expert opinion. All expert reports recommend to all wildlife management agencies that feeding and baiting not occur. Some of the expert panels recommend allowing predators to range where vulnerable prey range in order to keep numbers of vulnerable cervids at a healthy level and to remove compromised individuals. Should the BTNF decide to permit any elk feedground(s) as a result of this EIS which uses the inaccurate interpretations and inappropriate reports, i.e., bad science, such an action is arbitrary and capricious. Such an action would also be mismanagement of the public's resources and a betrayal of the public's trust to manage wildlife, habitat and Forest Service lands using the best information available. Response: The Forest Service agrees with the commenter and with the experts cited by the commenter
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Response to Comments that concentrating elk by feeding them increases contact between infected animals and susceptible animals and increases potential for environmental contamination (FSEIS, page 114 and Appendix 7). The unpublished Wyoming Game and Fish Department study mentioned by the commenter has recently been published. The results of this recently published study indicate a population decline is expected until a genetic shift occurs that allows the population to rebound. The WGFD model on captive elk does not directly correlate to the Alkali Creek Feedground situation where wild elk infected with CWD would be vulnerable to predation by wolves. The Forest Service agrees with the commenter and the CWD experts cited by the commenter that elk population declines are likely when there is high prevalence of CWD in a herd. The Forest Service reviewed the references provided by the reader and have incorporated them and others (including the recently published WGFD study) into a compendium of information concerning CWD. Wyoming Game and Fish Department has informed us that, although they are not listed as a CWD expert on the website identified by the commenter, they routinely communicate and collaborate with most of the experts listed there. The FSEIS has been revised to remove the statement that the potential effects of this project are predictable with no scientific uncertainties or risks (FSEIS, page 28). This compendium of CWD information is part of the project record and was considered by the Forest Supervisor in the Draft Record of Decision (ROD) distributed with this FSEIS. Please see the "Reasons for My Decision" section of the draft ROD.
124. Comment: The BTNF claims incorrectly, "The conclusions (in this DSEIS) are based on the scientific analysis that shows a thorough review of relevant scientific information." (DSEIS: 27, parentheses added) As we have shown repeatedly in these comments and others we have submitted to the BTNF, the BTNF has consistently ignored relevant science. See our comments above and throughout. The DSEIS also claims, "Resource specialists determined that the potential effects of this project are predictable and well documented with no significant scientific uncertainties or risks associated with this proposal." (Ibid) We have gone to great lengths to submit information that counters this assertion by the BTNF. See our comments above and elsewhere. Response: The Forest Service agrees with the commenter and with the experts cited by the commenter that concentrating elk by feeding them increases contact between infected animals and susceptible animals and increases potential for environmental contamination (FSEIS, page115 and Appendix 7). The unpublished Wyoming Game and Fish Department study mentioned by the commenter has recently been published. The results of this recently published study indicate a population decline is expected until a genetic shift occurs that allows the population to rebound. The WGFD model on captive elk does not directly correlate to the Alkali Creek Feedground situation where wild elk infected with CWD would be vulnerable to predation by wolves. The Forest Service agrees with the commenter and the CWD experts cited by the commenter that elk population declines are likely when there is high prevalence of CWD in a herd. The Forest Service reviewed the references provided by the reader and have incorporated them and others (including the recently published WGFD study) into a compendium of information concerning CWD. Wyoming Game and Fish Department has informed us that, although they are not listed as a CWD expert on the website identified by the commenter, they routinely communicate and collaborate with most of the experts listed there. The FSEIS has been revised to remove the statement that the potential effects of this project are predictable with no scientific uncertainties or risks (FSEIS, page 28). This compendium of CWD information is part of the project record and was
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Response to Comments considered by the Forest Supervisor in the Draft Record of Decision (ROD) distributed with this FSEIS. Please see the "Reasons for My Decision" section of the draft ROD.
125. Comment: The USDA-USFS must reconcile differences with the USDA-APHIS At page 153 of the DSEIS, it lists Federal, State, and Local Agencies that the USFS consulted with in preparing the DSEIS. Under Federal agencies it lists the Forest Service, the USDOI-Grand Teton Park, the U.S. Environmental Protection Agency, the U.S. Fish and Wildlife Service and, oddly, the Environmental Protection Agency. It appears to list the EPA twice. Nevertheless, the list omits, and it appears the USFS did not consult with its own sister agency in the USDA, the Animal and Plant Health Inspection Service (APHIS). This agency has disease expertise and it is arbitrary for the USDA Forest Service not to consult with its sister agency. Unlike the WGFD, the APHIS is not a proponent of elk feedgrounds. As we wrote in our May 18, 2012 scoping comments, “The federal USDA-APHIS (Animal and Plant Health Inspection Service), which is in the same department of the federal government, the US Department of Agriculture, as the Forest Service, considers CWD a serious disease and allocates significant financial and educational resources in order to control it. Since 2002-03, APHIS has helped fund the surveillance of 70,000 – 100,000 wild cervids each year in the U.S. (USDA 2012) Yet, by permitting elk feedgrounds, the BTNF promotes conditions that would exacerbate the effects of CWD when it occurs on or near elk feedgrounds.” (GYC 2012 comments, page 12) Additionally, in the latest Review of Wyoming’s Brucellosis Management Plan by APHIS (Dates of Review: September 10 & 11, 2012) under Recommendations at page 17, APHIS counsels to “Continue research and specific herd management actions that could lead to the eventual discontinuation of elk feed grounds and elimination of brucellosis from elk.” This omission by the BTNF in the DSEIS of a sister agency’s input and/or consultation- particularly an agency that counsels to move to end elk feedgrounds- emphasizes the overly narrow information stream allowed by the BTNF when they had nearly 30% of the ID Team dominated by the feedground proponent, the WGFD, and did not have on the ID Team nor consult with agencies or non-governmental organizations or academic personnel who advocate phasing out elk feedgrounds. This is arbitrary, capricious, and an abuse of discretion by the BTNF. Response: APHIS has discontinued funding CWD surveillance in free-ranging wildlife and directs its CWD management efforts towards the captive cervid population. However, APHIS is certainly an agency with considerable expertise in wildlife disease and has assisted us in our analysis of this project. After receiving this and other comments, we met with two wildlife disease researchers from APHIS in Fort Collins, CO on November 22, 2013. We acknowledged the assistance of Dr. Jack Rhyan (brucellosis researcher) and Dr. Tom Gidlewski (CWD researcher) in a letter to APHIS on December 18, 2013. Fairly extensive consultation with Dr. Gidlewski occurred from November 2013 until October 2014 regarding CWD and its potential interaction with feedgrounds. One result of this was the CWD Literature Review Technical Report which is Appendix 7 in the FSEIS. Dr. Gidlewski reviewed and determined that this document represented the use of best available science with regard to the state of knowledge for the interaction of CWD and feedgrounds. The letter to APHIS is part of the project record as is email correspondence with Dr. Gidlewski.
126. Comment: Wildlife Resources Environmental Consequences – Elk – With regard to CWD, the second paragraph states that “Management strategies to prevent its spread are limited or
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Response to Comments non-existent.” Then states “The WGFC has adopted a plan for management of CWD, which is attached in Appendix 3.” These statements are seemingly contradictory. Response: The Wyoming Game and Fish Department Chronic Wasting Disease Management Plan notes on pages 2-6 that the prevailing opinion of professionals experienced with CWD epidemiology is that the spread of CWD can be slowed but not prevented. Therefore, the WGFD CWD Plan presented strategies concerning disease management, including intervention, surveillance, and selective removal of elk showing clinical signs of CWD at feedgrounds but does not present strategies concerning disease prevention.
127. Comment: Feeding wild elk results in over population which can lead to diseases that spread to healthy herds. I understand that hunting is big business in Wyoming but unnaturally keeping elk alive is not good for them. If anything I would recommend moving wolves into the area to thin the herds of elk, however, with Wyoming's terrible laws for killing wolves this recommendation could never be successful. Response: The Jackson elk herd is within 5 % of the Wyoming Game and Fish Commission (WGFC) population objective of 11,000 elk and therefore is not considered overpopulated by the state of Wyoming. The segment of this population of elk that occupies winter range in the Gros Ventre segment of this herd is below the WGFC objective of 3,500 elk. The Forest Service agrees that feeding elk increases the prevalence of disease. Wolves do occupy the Gros Ventre drainage and prey upon feedground elk and at present, wolves are protected by the 1973 Endangered Species Act.
128. Comment: Table 1 Issue #2 – Should identify that feedgrounds were established to keep elk from private lands, which decreases the risk of brucellosis spread to domestic stock. Response: The FSEIS acknowledges that while cattle originally gave brucellosis to the elk and feedgrounds increase the prevalence of this disease among elk, feedgrounds now are used to decrease the commingling of cattle and elk and the transmission of the disease back to cattle (page 83).
129. Comment: Additional concerns The BTNF is evidently still relying on old information when it shows no more contemporary information on the known occurrence of Chronic Wasting Disease than is represented by the map contained in the 2004 Elk Feedgrounds in Wyoming by the WGFD, on page 10, Figure 2, Deer Hunt Areas with CWD. CWD has been tracked farther west towards the elk feedgrounds and exists in many more hunt areas than is represented by this map. We will insert in these comments a newer map, below, crafted by GYC with information up through 2012. The BTNF must use the best available information and science in order to take the hard look required by NEPA. It fails to do so concerning Chronic Wasting Disease. Response: The FSEIS has updated the CWD information and map in Appendix 7.
130. Comment: It is incorrect at DSEIS, page 5, that CWD exists in only 8 states and one Canadian province. It exists in up to 22 states and two Canadian provinces. (http://www.nwhc.usgs.gov/disease_information/chronic_wasting_disease/) There is more current information on CWD in cervids in Wyoming than is indicated by the information on page 5 of this DSEIS. As we indicated above, as of late 2012 it is known that endemic CWD deer hunt areas are within 45 miles of elk feedgrounds in the Pavillion, Wyoming and Owl Creek Mountain areas of Wyoming.
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(http://gf.state.wy.us/web2011/wildlife-1000284.aspx viewed in May 2013; and GYC CWD map, revised May 2013) This disease now exists in areas where elk from feedground herds and deer from the endemic areas mix at various times of the year in the same areas. The BTNF used old no longer accurate information in this DSEIS and needs to update the information about CWD to comply with their legal directives. Response: Updates to the status of chronic wasting disease can be found in the FSEIS on pages 83-84, 106-117, and Appendix 7.
131. Comment: If the BTNF believes there is an alleged "potential for disease transmission" if some elk move to or towards the Elk Refuge, increase compared to what? Fewer elk? That's not a risk assessment. It's not always necessarily numbers of elk that is the important variable in calculating risk from transmissible diseases; it can also be density of infected and vulnerable animals, rates of contact, length of contact and so forth. For most of these variables the feedgrounds in the Gros Ventre, including at Alkali Creek, maintain densities of elk that are at the extreme of any known in North America for elk. Given the numbers of elk congregating on a feedground in the Gros Ventre of less than 100 acres, there are many hundreds- possibly thousands- of elk standing, feeding, and loafing per square mile or square kilometer for weeks at a time, and longer. The Elk Refuge is 24,700-acres. Alkali Creek Feedground is 91 acres. The density on the Elk Refuge may- or may not be- less elk per square mile than on a state operated feedground. The BTNF should offer the public an analysis based on quantifiable facts and current conditions, and anticipated future conditions, to assess any alleged risk attributed to elk moving around the Gros Ventre, to and from Jackson Hole, to and from the Upper Green and the Upper Wind River basins, to give an accurate assessment of effects of not permitting a feedground at Alkali Creek. In addition, any elk moving to or spending a portion of a winter on the National Elk Refuge will, according to the USFWS testimony in court, soon not find hay or alfalfa pellets. "(T)he agencies are committed to ending feeding" at the Elk Refuge. (Defenders of Wildlife, et al, v. Salazar, Decision 10-5144, decided August 3, 2011 at page 11) The Elk Refuge should be managed as part of an interconnected complex of winter ranges in and around Jackson Hole if they end feeding as they told the Appeals Court Judges they will. Elk may move from the Elk Refuge to the Gros Ventre, and indeed have in past years. The BTNF must factor the promised paradigm change on the Elk Refuge into their cumulative effects analysis as it is a connected federal action affecting elk in the very same Jackson Elk Herd as the Gros Ventre elk. Response: The Forest Service agrees with the commenter that the potential for CWD transmission appears to be related to 1) the density of infected and vulnerable animals and 2) rates and length of contact. The Forest Service also agrees that elk density at Alkali Creek Feedground may be higher than elk density at the National Elk Refuge and that the potential rate and length of contact between infected and uninfected elk may also be higher at Alkali Creek Feedground. The risk analysis requested by the commenter would be speculative due to the lack of definitive scientific information about CWD transmission. However, the information referenced in this comment has been modified in the FSEIS on pages 109 and 116 to present the opposing position that the risk of CWD transmission in Alternative 1 could be less than Alternative 2. The Forest Service also agrees with the commenter that the US Fish and Wildlife Service and National Park Service Bison and Elk Management Plan (BEMP) for the National Elk Refuge and Grand Teton
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National Park should be added to the list of actions considered in the Cumulative Effects Analysis. The BEMP presents management intended to adaptively manage habitat and populations over 15 years to decrease the need for supplemental food on the NER. Part of this strategy intends to support the Jackson elk herd objective of 11,000 by supporting 5,000 elk on NER in the winter. Although the Jackson elk herd population is estimated to be just above the population objective (approximately 11,600 animals in 2013), an average of 7,035 elk have wintered at NER since 2008, and the trend is stable rather than decreasing (Personal Conversation, Eric Cole). If NER succeeds in reducing the number of elk fed on the Refuge in the winter by 2,000 elk, while WGFD maintains the Jackson elk herd at 11,000, it is likely that the number of elk fed at Alkali Creek and other feedgrounds in the Gros Ventre would increase to some degree. NER pledged in the Record of Decision to develop a structured framework, in collaboration with WGFD, of adaptive management triggers for progressively transitioning from intensive supplemental winter feeding to greater reliance on free-standing forage, including complete transition to free-standing forage if and when several established criteria are met, including support from the Wyoming Game and Fish Department and the public.
132. Comment: The BTNF defers to the WGFD Chronic Wasting Disease Management Plan, which violates NEPA and the Administrative Procedures Act Unfortunately, as in the 2008 DEIS, the BTNF in this DSEIS, page 9 at 3, again defers to the WGFD CWD Management Plan to avoid having to adequately address and mitigate the effects of this deadly disease on elk herds and the environment. The BTNF also defers to the USFWS treatment of CWD in the 2007 Bison and Elk Plan (DSEIS: 9 at 3). This deferral has no substance and violates the “hard look” requirement of NEPA. “The “hard look” required by NEPA is not satisfied when the agency relies “on incorrect assumptions or data in an EIS.” Native Ecosystems Council v. U.S. Forest Service, 418 F.3d953, 964 (9th Cir. 2005)” (in GYC, et al, v. Supervisors of the CTNF and BTNF, Nov 21, 2006, Honorable Judge B. Lynn Winmill. PAGE 16) In reality, despite a commitment in the Bison and Elk Plan to do so, the USFWS has never described their own CWD plan, themselves deferring (despite their commitment in 2007 to make it a priority to craft their own) to the State’s CWD Plan until they do so. (See 2007 BEMP: 13-14.) However, according to our discussions with USFWS Region 6 Director Noreen Walsh and her staff, as of May 9, 2013 no “step-down plan” has yet been crafted by the USFWS “to address chronic wasting disease management on the National Elk Refuge.” Therefore the BTNF in this DSEIS is deferring to analysis and action that falls very short of meeting the commitments of the agencies and falls short of complying with the best available science and scientific opinion recommending best management practices (e.g., don’t feed, bait or unnaturally concentrate cervids). See our comments below about expert recommendations for dealing with CWD among wild cervids. Wyoming’s CWD Action Plan, quoted below, does nothing to avoid amplification of the disease if or when it is found on or adjacent to elk feedgrounds. C. Feedground Management If CWD is detected in elk inhabiting state feedgrounds, WGFD personnel will monitor the population intensively and remove any elk showing clinical signs of CWD. The WGFD will attempt to: 1) maximize the area of feeding to decrease animal-to-animal contact; 2) decrease days of feeding to disperse the elk; 3) take any other actions to decrease elk concentration provided such actions are consistent with other necessary wildlife management and feedground practices. Large scale culling of elk is not anticipated. (emphasis added)
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(WGFD 2007:6) The Action Plan, in fact, declares that only such actions will be considered that “are consistent with other necessary wildlife management and feedground practices.” (WGFD 2007:6) Its plan to “maximize the area of feeding” and “decrease days of feeding” have been in place for many years as an alleged prophylaxis (or preventive medicine) against brucellosis, to no avail whatsoever. Despite admitting that deer, elk and moose “may be more at risk due to winter concentrations of elk on feedgrounds,” (Ibid:5) the WGFD evidently cannot see past their compulsion to operate elk winter feedgrounds even in the face of a deadly disease moving towards the feedground locations. The BTNF cannot fall to such dysfunctional and circular reasoning when managing the “world class” resources its Vision Statement touts. To defer to the WGFD CWD Action Plan and the WGFD assessment of CWD, and to the USFWS treatment of CWD, which are one and the same, and ignore the entire body of real expert reports is arbitrary, capricious, and an abuse of discretion by the BTNF of the highest order. (5 USC Sec 706(2) (2000) As we commented in 2008 on the Feedground DEIS, we repeat here for the Alkali DSEIS: “(R)ather than appropriately analyzing the issue of CWD moving into any of the elk herds or onto the USFS lands at or near the elk feedgrounds at issue here and posing a risk to other cervid species, the BTNF refers to the WGFD 2006 Chronic Wasting Disease Management Plan on the WGFD website as providing, “supplemental information concerning the prevalence, risks and consequences” of CWD (DEIS:12). The BTNF appears to deflect its duties under NEPA onto the WGFD; but the WGFD is not bound by the requirements of NEPA nor does the WGFD need to meet any standard of analysis or accuracy in its reports. The WGFD CWD Plan makes clear that the WGFD intends to continue with winter elk feedgrounds even if CWD is discovered thereon. The WGFD is not bound by any regulations to maintain the health of federal lands other than to follow the conditions of permits issued by the USFS, and has stated clearly in its CWD Plan that even if CWD-infected elk are discovered on feedgrounds, it will continue to operate feedgrounds on those very USFS lands that may be contaminated with CWD prions. The duty to protect those USFS lands, however, lies with the USFS. The USFS may not allow reckless use of its lands such that contaminants are likely to affect the health of the habitat and wildlife. Whether or not the WGFD intends to conduct elk feedgrounds on other jurisdictions if the USFS denies it permits, such possibilities cannot relieve the USFS of its duties to protect the lands under its stewardship, nor can such possibilities serve as excuses for the USFS to knowingly allow a continued high risk of habitat contamination on USFS jurisdiction. To continue to permit feedgrounds and maintain such a risk when alternatives are available is negligent.” (from NGO’s DEIS comments, page 17) The BTNF consistently tries to defer to treatments of disease threats and management by other agencies. What they’re deferring to does not exist. The USFWS has adopted the WGFD CWD plan which essentially does nothing different on elk feedgrounds than has been done for decades: Baiting elk onto small plots of land and holding them there for months by distributing hay bales. In the case of the Elk Refuge it is alfalfa pellets and irrigated green plots. No problem is solved and no progress is made to protect the “world class wildlife” populations referred to in the BTNF Vision Statement. Deferring to ineffective and CWD plans absent the best science is certainly not being the “progressive leaders in natural resource management” touted in the BTNF Mission Statement which we will list at the end of these comments. It is also arbitrary and capricious and violates agency discretion. Response: Management of chronic wasting disease in wildlife is within the purview of Wyoming Game and Fish Department (WGFD). It is appropriate for the Forest Service to defer to the WGFD CWD
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Management Plan. If the Forest Service determines that WGFD's response to CWD at Alkali Creek Feedground is not adequate, the special use authorization may be revoked or suspended in whole or in part (Clause VII, Special Use Permit, Alkali Creek Feedground).
133. Comment: How many states have $465,000., and can quarantine and purchase there from, each CWD said infected farm, but how many states can afford this for all the CWD infected cervid game ranch type farms ??? ? Game farms in a state X $465,000., do all these game farms have insurance to pay for this risk of infected wild cervid herds, in each state??? How many game farms, are too many game farms? When you have states handing out shooting pen permits like candy on Halloween, just to advance their coffers, then other states wanting to do the same thing, with most all of them ignoring the science on shooting pens and CWD, what do you expect is going to happen. When is enough, enough? Response: The information provided in this comment appears unrelated to Alkali Creek Feedground. The Forest Service would not sell the land occupied by the feedground if it becomes contaminated with CWD.
134. Comment: Monday, March 18, 2013 Proceedings One Hundred And Fifteenth Annual Meeting Of The United States Animal Health Association September 29 – October 5, 2011 see updated 2012 Resolutions http://chronic-wasting-disease.blogspot.com/2013/03/proceedings-one-hundred-and-fifteenth.html please see what the U.K. DEFRA recently said ; Friday, December 14, 2012 DEFRA U.K. What is the risk of Chronic Wasting Disease CWD being introduced into Great Britain? A Qualitative Risk Assessment October 2012…In the USA, under the Food and Drug Administration’s BSE Feed Regulation (21 CFR 589.2000) most material (exceptions include milk, tallow, and gelatin) from deer and elk is prohibited for use in feed for ruminant animals. With regards to feed for non-ruminant animals, under FDA law, CWD positive deer may not be used for any animal feed or feed ingredients. For elk and deer considered at high risk for CWD, the FDA recommends that these animals do not enter the animal feed system. However, this recommendation is guidance and not a requirement by law. Animals considered at high risk for CWD include: 1) animals from areas declared to be endemic for CWD and/or to be CWD eradication zones and 2) deer and elk that at some time during the 60-month period prior to slaughter were in a captive herd that contained a CWD-positive animal. Therefore, in the USA, materials from cervids other than CWD positive animals may be used in animal feed and feed ingredients for non-ruminants. The amount of animal PAP that is of deer and/or elk origin imported from the USA to GB cannot be determined, however, as it is not specified in TRACES. It may constitute a small percentage of the 8412 kilos of non-fish origin processed animal proteins that were imported from US into GB in 2011. Overall, therefore, it is considered there is a __greater than negligible risk___ that (non-ruminant) animal feed and pet food containing deer and/or elk protein is imported into GB. There is uncertainty associated with this estimate given the lack of data on the amount of deer and/or elk protein possibly being imported in these products. 36% in 2007 (Almberg et al., 2011). In such areas, population declines of deer of up to 30 to 50% have been observed (Almberg et al., 2011). In areas of Colorado, the prevalence can be as high as 30% (EFSA, 2011). The clinical signs of CWD in affected adults are weight loss and behavioral changes that can span weeks or months (Williams, 2005). In addition, signs might include excessive salivation, behavioral alterations including a fixed stare and changes in interaction
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Response to Comments with other animals in the herd, and an altered stance (Williams, 2005). These signs are indistinguishable from cervids experimentally infected with bovine spongiform encephalopathy (BSE). Given this, if CWD was to be introduced into countries with BSE such as GB, for example, infected deer populations would need to be tested to differentiate if they were infected with CWD or BSE to minimize the risk of BSE entering the human food-chain via affected venison. The rate of transmission of CWD has been reported to be as high as 30% and can approach 100% among captive animals in endemic areas (Safar et al., 2008). In summary, in endemic areas, there is a medium probability that the soil and surrounding environment is contaminated with CWD prions and in a bioavailable form. In rural areas where CWD has not been reported and deer are present, there is a greater than negligible risk the soil is contaminated with CWD prion. In summary, given the volume of tourists, hunters and servicemen moving between GB and North America, the probability of at least one person travelling to/from a CWD affected area and, in doing so, contaminating their clothing, footwear and/or equipment prior to arriving in GB is greater than negligible. For deer hunters, specifically, the risk is likely to be greater given the increased contact with deer and their environment. However, there is significant uncertainty associated with these estimates. Therefore, it is considered that farmed and park deer may have a higher probability of exposure to CWD transferred to the environment than wild deer given the restricted habitat range and higher frequency of contact with tourists and returning GB residents... see full text report here ; Friday, December 14, 2012 DEFRA U.K. What is the risk of Chronic Wasting Disease CWD being introduced into Great Britain? A Qualitative Risk Assessment October 2012 http://chronic-wasting-disease.blogspot.com/2012/12/defra-uk-what-is-risk-of-chronic.html. Response: If Alkali Creek Feedground becomes contaminated with CWD, it is likely that soil could be transported to other locations by humans or animals as described in this literature citing. Wyoming Game and Fish Department would manage the harvest, use, and transport of animal carcasses infected with CWD.
135. Comment: Conversion of human PrPC by cervid PrPSc Keywords: Prion / transmissible spongiform encephalopathy / infectivity / misfolded prion protein / prion strains. Response: This research examined the possibility that CWD could be mutated into a form available to humans. This is not relevant to the decision to be made for Alkali Creek Feedground.
136. Comment: After a natural route of exposure, 100% of white-tailed deer were susceptible to scrapie. http://www.usaha.org/Portals/6/Reports/2011/report-cwal-2011.pdf. Response: The fact that deer are susceptible to scrapie is not pertinent to the decision being made for Alkali Creek Feedground. Transmission of prion disease is discussed in a CWD literature technical report (Johnson, 2014, Appendix 7 of the FSEIS), which can be found in the project record.
137. Comment: Intranasal Inoculation of White-Tailed Deer (Odocoileus virginianus) with Lyophilized Chronic Wasting Disease Prion Particulate Complexed to Montmorillonite Clay Tracy A. Nichols mail, Terry R. Spraker, Tara D. Rigg, Crystal Meyerett-Reid, Clare Hoover, Brady Michel, Jifeng Bian, Edward Hoover, Thomas Gidlewski, Aru Balachandran, Katherine O'Rourke, Glenn C. Telling, Richard Bowen, [ ... ], Kurt C. VerCauteren equal contributor Abstract Chronic wasting disease (CWD), the only known prion disease endemic in wildlife, is a persistent problem in both wild and captive North American cervid populations. This disease continues to spread and cases are found in new areas each year. Indirect
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Response to Comments transmission can occur via the environment and is thought to occur by the oral and/or intranasal route. Oral transmission has been experimentally demonstrated and although intranasal transmission has been postulated, it has not been tested in a natural host until recently. Prions have been shown to adsorb strongly to clay particles and upon oral inoculation the prion/clay combination exhibits increased infectivity in rodent models. Deer and elk undoubtedly and chronically inhale dust particles routinely while living in the landscape while foraging and rutting. We therefore hypothesized that dust represents a viable vehicle for intranasal CWD prion exposure. To test this hypothesis, CWD-positive brain homogenate was mixed with montmorillonite clay (Mte), lyophilized, pulverized and inoculated intranasally into white-tailed deer once a week for 6 weeks. Deer were euthanized at 95, 105, 120 and 175 days post final inoculation and tissues examined for CWD-associated prion proteins by immunohistochemistry. Our results demonstrate that CWD can be efficiently transmitted utilizing Mte particles as a prion carrier and intranasal exposure. The results of this study confirm that CWD can be successfully transmitted IN as a lyophilized prion particulate adsorbed to Mte and that genotype at codon 96 affects the lymphoid distribution of CWD within the body. Additionally, two novel intranasal tracking methods were employed that provided insight into CWD translocation within the nasal cavity. The data collected in this study may also shed light on why there is a higher prevalence of CWD in males, as males participate in more behaviors that generate dust. We propose chronic, long-term exposure to CWD prions adsorbed to dust particles to be a natural CWD infection route in addition to chronic oral and nasal contact exposure. Citation: Nichols TA, Spraker TR, Rigg TD, Meyerett-Reid C, Hoover C, et al. (2013) Intranasal Inoculation of White-Tailed Deer (Odocoileus virginianus) with Lyophilized Chronic Wasting Disease Prion Particulate Complexed to Montmorillonite Clay. PLoS ONE 8(5): e62455. doi:10.1371/journal.pone.0062455 Editor: Anthony E. Kincaid, Creighton University, United States of America Received: November 30, 2012; Accepted: March 21, 2013; Published: May 9, 2013 This is an open-access article, free of all copyright, and may be freely reproduced, distributed, transmitted, modified, built upon, or otherwise used by anyone for any lawful purpose. The work is made available under the Creative Commons CC0 public domain dedication. Funding: Funding was provided by U.S. Department of Agriculture, Animal and Plant Health Inspection Service, Veterinary Services (VS). The funders had no role in study design, data collection and analysis, decision to publish, or preparation of the manuscript. Competing interests: The authors have declared that no competing interests exist. See full text; http://www.plosone.org/article/info%3Adoi%2F10.1371%2Fjournal.pone.0062455 Thanks again to PLOS et al for full text access to this scientific research on the CWD TSE prion disease... Response: The transmission of CWD is discussed in a CWD literature technical report (Johnson, 2014), Appendix 7 of the FSEIS...
138. Comment: April/May/June 2012; © 2012 Landes Bioscience PO-033: Replication efficiency of soil-bound prions varies with soil type Shannon Bartelt-Hunt, 1 Samuel Saunders, 1 Ronald Shikiya, 2 Katie Langenfeld, 2 Jason Bartz2 1University of Nebraska-Lincoln; Omaha, NE USA; 2Creighton University; Omaha, NE USA Prion sorption to soil is thought to play an important role in the transmission of scrapie and chronic wasting disease (CWD) via the environment. Sorption of PrP to soil and soil minerals is influenced by the strain and species of PrPSc and by soil characteristics. However, the ability of soil-bound prions to convert PrPc to PrPSc under these wide-ranging conditions remains poorly understood. We developed a semiquantitative protein misfolding cyclic amplification (PMCA) protocol
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Response to Comments to evaluate replication efficiency of soil-bound prions. Binding of the hyper (HY) strain of transmissible mink encephalopathy (TME) (hamster) prions to a silty clay loam soil yielded a greater-than-1-log decrease in PMCA replication efficiency with a corresponding 1.3-log reduction in titer. The increased binding of PrPSc to soil over time corresponded with a decrease in PMCA replication efficiency. The PMCA efficiency of bound prions varied with soil type, where prions bound to clay and organic surfaces exhibited significantly lower replication efficiencies while prions bound to sand exhibited no apparent difference in replication efficiency compared to unbound controls. PMCA results from hamster and CWD agent-infected elk prions yielded similar findings. Given that PrPSc adsorption affinity varies with soil type, the overall balance between prion adsorption affinity and replication efficiency for the dominant soil types of an area may be a significant determinant in the environmental transmission of prion diseases. PO-248: TSE infectivity survives burial for five years with little reduction in titer Allister Smith, Robert Somerville, Karen Fernie The Roslin Institute and R(D)SVS; University of Edinburgh; Edinburgh, UK BSE infected animals, BSE-contaminated materials and other sources of TSE (prion) infection, such as carcasses from scrapie infected sheep, CWD infected deer and cadavers of individuals infected with CJD may all end up in the environment through burial or other methods of disposal. They may continue to act as a reservoir of TSE infectivity if cattle or other susceptible animals were to be exposed to these sources in the future. In order to address these concerns, we performed two large scale demonstration experiments under field conditions which were designed to mimic some of the ways by which TSE infected materials may have been disposed of. The project examined the fate of TSE infectivity over a period of five years in two scenarios; when the infectivity was contained within bovine heads and when the infectivity was buried without any containment. Two soil types were compared: a sandy loam and a clay loam. We used the 301V TSE strain which was derived by serial passage of BSE in VM mice. TSE infectivity was recovered from all the heads exhumed annually for five years from both types of soil, with little reduction in the amount of infectivity throughout the period of the experiment. Small amounts of infectivity were found in the soil immediately surrounding the heads, but not in samples remote from them. Similarly there was no evidence of significant lateral movement of infectivity from the buried bolus. However large amounts of TSE infectivity were recovered at the site of burial of both boluses. There was limited vertical upward movement of infectivity from the bolus buried in clay soil and downward movement from the bolus buried in sandy soil. Now that these experiments are completed we conclude that TSE infectivity is likely to survive burial for long periods of time with minimal loss of infectivity and restricted movement from the site of burial. These experiments emphasize that the environment is a viable reservoir for retaining large quantities of TSE infectivity, and reinforce the importance of risk assessment when disposing of this type of infectious material. http://www.landesbioscience.com/journals/prion/11-Prion6-2-PrP-blood-safety-decontimination.pdf PRION 2011 Envt.16: Soil Properties as a Factor in CWD Spread in Western Canada Alsu Kuznetsova,† Tariq Siddique and Judd Aiken University of Alberta; Edmonton, AB Canada†Presenting author; Email: [email protected] Soil can serve as a stable reservoir for infectious prion proteins (PrPSc). Soils are diverse and complex, varying in clay, silt, sand and organic components. We have shown that PrPSc binds clay minerals avidly, an interaction that considerably enhances prion infectivity. Conversely quartz sand bound PrPSc less avidly. These studies would suggest that soils with lower clay and higher sand content bind prions less avidly and do not enhance infectivity to the same level as clay-rich soils. We
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Response to Comments hypothesize that clay content of a soil plays an integral role in the spread of CWD. In this study, we present the soil properties in the western Canada. Soils of the CWD-region generally are similar in texture, clay mineralogy and soil organic matter content. In total these soils can be characterized as clay loamy, montmorillonite (smectite) with 6–10 % organic carbon. The major soils in the CWD-region are Chernozems, present in 60% of total area. These soils have a humic horizon in which organic matter has accumulated (1–17% organic C). Solonetzic soils are also common to Alberta and Saskatchewan. We suggest that the greatest risk of CWD spread in western Canada is restricted to clay loamy, montmorillonite soils with humus horizon. Such soils are predominant in the southern region of Alberta, Saskatchewan and Manitoba, but are less common in northern regions of the provinces. Envt.28: High Survival Rates of TSE Infectivity Buried in Two Soil Types Allister J. Smith The Roslin Insitute; Roslin, UK Email: [email protected] Two field experiments nearing completion are investigating the migration and/or persistence of TSE infectivity in the soil environment, either buried within bovine heads or buried without containment. In the first experiment five pairs of bovine heads, spiked with mouse-passaged BSE (301V) macerate, were buried within lysimeters containing either clay or sandy soil. A pair of unspiked bovine heads was also buried to act as controls. Pairs of heads have been exhumed annually during which a corer is used to take soil samples above, surrounding and below the head. Any brain material within the head is recovered during dissection. The soil samples have undergone protein extraction, and the extracts along with the brain material have been assayed for infectivity by bioassay in VM mice. Bioassay results from the first experiment show that for all four years most of the intracranial brain samples have been positive for TSE infectivity in both the clay and sandy soil. There is little change in the survival curves between years 1 and 4 indicating little reduction in the amounts of infectivity over time. There has been very limited infectivity found in samples surrounding the heads buried in the sandy soil, but infectivity has been found in the soil samples surrounding the clay heads and the levels increase slightly from years one to four, presumably as the heads have decomposed. In a parallel experiment a bolus of infectivity (301V) was placed in the center of two large lysimeters, containing either clay or sandy soil. Over the course of four years, core samples have been taken at eight time points, on the vertical and at 3 distances from the center. These samples have been assayed for infectivity and to date only one sample from the sandy soil has produced pathological evidence of TSE disease in one mouse. In order to ascertain whether any of the bolus remained at the end of the experiment, we collected a much larger central core (d = 16 cm) and extracted samples for bioassay, concentrating on the core portions that correlated to the original bolus location. The samples from these core portions caused disease in a high proportion of mice (bioassay still in progress), with apparently higher infectivity levels in the clay soil, so far. This result indicates that there has been very little migration of TSE infectivity without containment in either clay or sandy soil and that there has been little reduction in titre with time. Envt.29: Time-Dependent Decline in PrPTSE Desorption from Soil Particles Christen B. Smith,1,† Clarissa J. Booth,2 Kartik Kumar2 and Joel A. Pedersen1–3 1Environmental Chemistry and Technology Program; 2Molecular and Environmental Toxicology Center; 3Department of Soil Science, University of Wisconsin; Madison, WI USA †Presenting author, Email: [email protected] Environmental routes of transmission are implicated in epizootics of sheep scrapie and chronic wasting disease in deer, elk, and moose. Strong evidence suggests that soil may serve as an environmental reservoir of prions, which can persist in the environment for years. The
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Response to Comments disease-associated form of the prion protein (PrPTSE) readily attaches to soil particle surfaces. Prior studies reported reduced PrPTSE recovery from experimentally spiked soils after longer contact times, which in some cases have been interpreted as degradation of PrPTSE. Here, we investigate PrPTSE desorption from sterilized and untreated soil particles as a function of protein-soil contact time. Soil particles were sterilized by autoclaving or g-irradiation. Desorption of PrPTSE from whole soils, montmorillonite clay, and quartz sand was analyzed by immunoblotting following 1-, 7-, and 14-day contact times. We found that PrPTSE recovery from both sterile and untreated soil samples declined significantly with contact time suggesting the strengthening of protein-particle interactions over time. Recovery of PrPTSE from whole soils declined to a larger extent than did that from montmorillonite and quartz sand possibly reflecting the contribution of particle-associated natural organic matter to the mechanisms of PrPTSE attachment. The influence of PrPTSE-soil particle attachment on oral disease transmission warrants investigation. PRION http://www.landesbioscience.com http://www.prion2011.ca/files/PRION_2011_-_Posters_(May_5-11).pdf Soil clay content underlies prion infection odds W. David Walter 1 , * , Daniel PAGE Walsh 2 , * , Matthew L. Farnsworth 3 , Dana L. Winkelman 1 & Michael W. Miller 2 1 United States Department of the Interior, United States Geological Survey, Colorado Cooperative Fish and Wildlife Research Unit , Fort Collins , Colorado 80523-1484, USA. 2 Colorado Division of Wildlife, Wildlife Research Center, Fort Collins, Colorado 80526-2097, USA. 3 United States Department of Agriculture, Animal and Plant Health Inspection Services, Veterinary Services, Centers for Epidemiology and Animal Health , Fort Collins , Colorado 80526-8117 , USA . * These authors contributed equally to this work. Correspondence and requests for materials should be addressed to M.W.M. (email: [email protected] ) . Received 6 Sep 2010 | Accepted 19 Jan 2011 | Published 15 Feb 2011 DOI: 10.1038/ncomms1203 Environmental factors — especially soil properties — have been suggested as potentially important in the transmission of infectious prion diseases. Because binding to montmorillonite (an aluminosilicate clay mineral) or clay-enriched soils had been shown to enhance experimental prion transmissibility, we hypothesized that prion transmission among mule deer might also be enhanced in ranges with relatively high soil clay content. In this study, we report apparent influences of soil clay content on the odds of prion infection in free-ranging deer. Analysis of data from prion-infected deer herds in northern Colorado, USA, revealed that a 1 % increase in the clay-sized particle content in soils within the approximate home range of an individual deer increased its odds of infection by up to 8.9 % . Our findings suggest that soil clay content and related environmental properties deserve greater attention in assessing risks of prion disease outbreaks and prospects for their control in both natural and production settings. ... The capacity of clay minerals and clay-laden soils to capture and enhance infectivity of shed or deposited prions 19,20,25 – 27 and the common tendency of ruminants to ingest soil both deliberately and incidentally in the course of foraging and grooming 12,44,45 provide an elegantly simple hypothetical mechanism for indirect prion transmission, as follows: infected individuals propagate infectious prions in mucosa-associated lymphoid tissues and shed prions into ingesta and saliva; ingested and environmental soil microparticles with a high phyllosilicate (especially smectite) content bind to, sequester and enhance infectivity of prions both before and after leaving the host; microparticle-bound prions are incorporated into surface soil; susceptible individuals consume contaminated soil and some become infected. (Also see Supplementary Figure S1 .) This mechanism may underlie the apparent
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Response to Comments importance of indirect transmission in explaining observed patterns of prion infection among captive mule deer 10,11 , and perhaps among sheep 3,4,6,7 . In light of these and others ’ findings, soil clay content and related environmental properties deserve greater attention in assessing local and regional risks of prion disease outbreaks and prospects for their control in natural and production settings. http://www.nature.com/ncomms/journal/v2/n2/pdf/ncomms1203.pdf Friday, February 25, 2011 Soil clay content underlies prion infection odds http://chronic-wasting-disease.blogspot.com/2011/02/soil-clay-content-underlies-prion.html Thursday, February 17, 2011 Environmental Sources of Scrapie Prions http://scrapie-usa.blogspot.com/2011/02/environmental-sources-of-scrapie-prions.html PRION 2010 International Prion Congress: From agent to disease September 8–11, 2010 Salzburg, Austria .. PPo4-4: Survival and Limited Spread of TSE Infectivity after Burial Karen Fernie, Allister Smith and Robert A. Somerville The Roslin Institute and R(D)SVS; University of Edinburgh; Roslin, Scotland UK Scrapie and chronic wasting disease probably spread via environmental routes, and there are also concerns about BSE infection remaining in the environment after carcass burial or waste 3disposal. In two demonstration experiments we are determining survival and migration of TSE infectivity when buried for up to five years, as an uncontained point source or within bovine heads. Firstly boluses of TSE infected mouse brain were buried in lysimeters containing either sandy or clay soil. Migration from the boluses is being assessed from soil cores taken over time. With the exception of a very small amount of infectivity found 25 cm from the bolus in sandy soil after 12 months, no other infectivity has been detected up to three years. Secondly, ten bovine heads were spiked with TSE infected mouse brain and buried in the two soil types. Pairs of heads have been exhumed annually and assessed for infectivity within and around them. After one year and after two years, infectivity was detected in most intracranial samples and in some of the soil samples taken from immediately surrounding the heads. The infectivity assays for the samples in and around the heads exhumed at years three and four are underway. These data show that TSE infectivity can survive burial for long periods but migrates slowly. Risk assessments should take into account the likely long survival rate when infected material has been buried. The authors gratefully acknowledge funding from DEFRA. http://www.prion2010.org/bilder/prion_2010_program_latest_w_posters_4_.pdf?139&PHPSESSID=a30 a38202cfec579000b77af81be3099 Wednesday, September 08, 2010 CWD PRION CONGRESS SEPTEMBER 8-11 2010 http://chronic-wasting-disease.blogspot.com/2010/09/cwd-prion-2010.html ALSO, NOTE MINERAL LICKS A POSSIBLE SOURCE AND TRANSMISSION MODE FOR CWD http://chronic-wasting-disease.blogspot.com/2009/08/third-international-cwd-symposium-july.html 2009 CWD SYMPOSIUM UTAH http://www.cwd-info.org/pdf/3rd_CWD_Symposium_utah.pdf Detection of Protease-Resistant Prion Protein in Water from a CWD-Endemic Area 65 Detection of Protease-Resistant Prion Protein in Water from a CWD-Endemic Area Tracy A. Nichols*1,2, Bruce Pulford1, Christy Wyckoff1,2, Crystal Meyerett1, Brady Michel1, Kevin Gertig3, Jean E. Jewell4, Glenn C. Telling5 and M.D. Zabel1 1Department of Microbiology, Immunology and Pathology, College of Veterinary Medicine and Biomedical Sciences, Colorado State University, Fort Collins, CO 80523, USA 2National Wildlife Research Center, Wildlife Services, United States Department of Agriculture, Fort Collins, Colorado, 80521, USA 3Fort Collins Water and Treatment Operations, Fort Collins, Colorado, 80521, USA 4 Department of Veterinary Sciences, Wyoming State Veterinary Laboratory, University of
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Wyoming, Laramie, Wyoming, 82070, USA 5Department of Microbiology, Immunology, Molecular Genetics and Neurology, Sanders Brown Center on Aging, University of Kentucky, Lexington, Kentucky, 40536, USA * Corresponding author- [email protected] Chronic wasting disease (CWD) is the only known transmissible spongiform encephalopathy affecting free-ranging wildlife. Experimental and epidemiological data indicate that CWD can be transmitted horizontally and via blood and saliva, although the exact mode of natural transmission remains unknown. Substantial evidence suggests that prions can persist in the environment, implicating it as a potential prion reservoir and transmission vehicle. CWD- positive animals can contribute to environmental prion load via biological materials including saliva, blood, urine and feces, shedding several times their body weight in possibly infectious excreta in their lifetime, as well as through decomposing carcasses. Sensitivity limitations of conventional assays hamper evaluation of environmental prion loads in water. Here we show the ability of serial protein misfolding cyclic amplification (sPMCA) to amplify minute amounts of CWD prions in spiked water samples at a 1:1 x106 , and protease-resistant prions in environmental and municipal-processing water samples from a CWD endemic area. Detection of CWD prions correlated with increased total organic carbon in water runoff from melting winter snowpack. These data suggest prolonged persistence and accumulation of prions in the environment that may promote CWD transmission. The data presented here demonstrate that sPMCA can detect low levels of PrPCWD in the environment, corroborate previous biological and experimental data suggesting long term persistence of prions in the environment2,3 and imply that PrPCWD accumulation over time may contribute to transmission of CWD in areas where it has been endemic for decades. This work demonstrates the utility of sPMCA to evaluate other environmental water sources for PrPCWD, including smaller bodies of water such as vernal pools and wallows, where large numbers of cervids congregate and into which prions from infected animals may be shed and concentrated to infectious levels...end...full text at ; http://www.landesbioscience.com/ http://www.cwd-info.org/pdf/3rd_CWD_Symposium_utah.pdf http://chronic-wasting-disease.blogspot.com/2009/08/third-international-cwd-symposium-july.html http://chronic-wasting-disease.blogspot.com/2009/10/detection-of-protease-resistant-cervid.html PO-248: TSE infectivity survives burial for five years with little reduction in titer Allister Smith, Robert Somerville, Karen Fernie The Roslin Institute and R(D)SVS; University of Edinburgh; Edinburgh, UK BSE infected animals, BSE-contaminated materials and other sources of TSE (prion) infection, such as carcasses from scrapie infected sheep, CWD infected deer and cadavers of individuals infected with CJD may all end up in the environment through burial or other methods of disposal. They may continue to act as a reservoir of TSE infectivity if cattle or other susceptible animals were to be exposed to these sources in the future. In order to address these concerns, we performed two large scale demonstration experiments under field conditions which were designed to mimic some of the ways by which TSE infected materials may have been disposed of. The project examined the fate of TSE infectivity over a period of five years in two scenarios; when the infectivity was contained within bovine heads and when the infectivity was buried without any containment. Two soil types were compared: a sandy loam and a clay loam. We used the 301V TSE strain which was derived by serial passage of BSE in VM mice. TSE infectivity was recovered from all the heads exhumed annually for five years from both types of soil, with little reduction in the amount of infectivity throughout the period of the experiment. Small amounts of infectivity were found in the soil immediately surrounding the heads, but not in samples
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Response to Comments remote from them. Similarly there was no evidence of significant lateral movement of infectivity from the buried bolus. However large amounts of TSE infectivity were recovered at the site of burial of both boluses. There was limited vertical upward movement of infectivity from the bolus buried in clay soil and downward movement from the bolus buried in sandy soil. Now that these experiments are completed we conclude that TSE infectivity is likely to survive burial for long periods of time with minimal loss of infectivity and restricted movement from the site of burial. These experiments emphasize that the environment is a viable reservoir for retaining large quantities of TSE infectivity, and reinforce the importance of risk assessment when disposing of this type of infectious material. http://www.landesbioscience.com/journals/prion/11-Prion6-2-PrP-blood-safety-decontamination.pdf . Response: This literature discusses the interaction of CWD and soil ecology, whereby CWD can exist in and on soil particles, thus providing for an environmental transmission possibility to ungulates. The transmission of CWD from animal to environment and back to animal is discussed in a CWD literature technical report (Johnson, 2014, Appendix 7 of the FSEIS).
139. Comment: Aiken, Judd. 2011. Chronic Wasting Disease Strains. In Management of CWD in Canada: Past Practices, Current Conditions, Current Science, Future Risks and Options. Workshop Summary. Edmonton, Alberta, Canada. Response: The biological background of CWD is described in the FSEIS (pages 83-84) and the ecological background is provided in a CWD literature technical report (Johnson, 2014, Appendix 7 of the FSEIS).
140. Comment: Wyoming Game and Fish Commission Alkali Creek Feedground #39126 Singeltary comment submission http://chronic-wasting-disease.blogspot.com/2013/05/wyoming-game-and-fish-commission-alkali.html. Response: This blog-post is a copy/paste of his submission of this letter. This entire collection of comments is from the author's blog at chronic-wasting-disease.blogspot.com. The comments submitted are a copy-paste of the blog on May 25, 2013. It was sometimes very difficult to follow exactly what was being submitted as a comment. For instance the commenter included in his letter here some posts from his blog that refer back to themselves and are included in their entirety, so the same post from the blog is included two or three times in the same 'comment'. To ensure that all posts included in this letter are addressed, a 'comment' was created for a thread of posts that pertained to the same subject (i.e. potential transmission of CWD to humans). Because of this it is possible that the comment coding has broken some of the threads in the posts that were sent in the comment letter. For instance some of the comments submitted were letters to other government agencies which included a copy/paste from the blog, as a result of the comment coding some of the posts from that copy/paste are in different "comments" than the rest of the letter.
141. Comment: 2012 PO-039: A comparison of scrapie and chronic wasting disease in white-tailed deer Justin Greenlee, Jodi Smith, Eric Nicholson US Dept. Agriculture; Agricultural Research Service, National Animal Disease Center; Ames, IA USA Interspecies transmission studies afford the opportunity to better understand the potential host range and origins of prion diseases. The purpose of these experiments was to determine susceptibility of white-tailed deer (WTD) to scrapie and to compare the resultant
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Response to Comments clinical signs, lesions, and molecular profiles of PrPSc to those of chronic wasting disease (CWD). We inoculated WTD intracranially (IC; n = 5) and by a natural route of exposure (concurrent oral and intranasal (IN); n = 5) with a US scrapie isolate. All deer were inoculated with a 10% (wt/vol) brain homogenate from sheep with scrapie (1ml IC, 1 ml IN, 30 ml oral). All deer inoculated by the intracranial route had evidence of PrPSc accumulation. PrPSc was detected in lymphoid tissues as early as 7 months-post-inoculation (PI) and a single deer that was necropsied at 15.6 months had widespread distribution of PrPSc highlighting that PrPSc is widely distributed in the CNS and lymphoid tissues prior to the onset of clinical signs. IC inoculated deer necropsied after 20 months PI (3/5) had clinical signs, spongiform encephalopathy, and widespread distribution of PrPSc in neural and lymphoid tissues. The results of this study suggest that there are many similarities in the manifestation of CWD and scrapie in WTD after IC inoculation including early and widespread presence of PrPSc in lymphoid tissues, clinical signs of depression and weight loss progressing to wasting, and an incubation time of 21-23 months. Moreover, western blots (WB) done on brain material from the obex region have a molecular profile similar to CWD and distinct from tissues of the cerebrum or the scrapie inoculum. However, results of microscopic and IHC examination indicate that there are differences between the lesions expected in CWD and those that occur in deer with scrapie: amyloid plaques were not noted in any sections of brain examined from these deer and the pattern of immunoreactivity by IHC was diffuse rather than plaque-like. After a natural route of exposure, 100% of WTD were susceptible to scrapie. Deer developed clinical signs of wasting and mental depression and were necropsied from 28 to 33 months PI. Tissues from these deer were positive for PrPSc by IHC and WB. Similar to IC inoculated deer, samples from these deer exhibited two different molecular profiles: samples from obex resembled CWD whereas those from cerebrum were similar to the original scrapie inoculum. On further examination by WB using a panel of antibodies, the tissues from deer with scrapie exhibit properties differing from tissues either from sheep with scrapie or WTD with CWD. Samples from WTD with CWD or sheep with scrapie are strongly immunoreactive when probed with mAb P4, however, samples from WTD with scrapie are only weakly immunoreactive. In contrast, when probed with mAb’s 6H4 or SAF 84, samples from sheep with scrapie and WTD with CWD are weakly immunoreactive and samples from WTD with scrapie are strongly positive. This work demonstrates that WTD are highly susceptible to sheep scrapie, but on first passage, scrapie in WTD is differentiable from CWD. http://www.landesbioscience.com/journals/prion/03-Prion6-2-Transmission-and-strains.pdf 2011 . Response: The behavior of scrapie and CWD are discussed where relevant in the CWD literature technical report (Johnson, 2014), Appendix 7 of the FSEIS.
142. Comment: Friday, February 25, 2011 Soil clay content underlies prion infection odds http://chronic-wasting-disease.blogspot.com/2011/02/soil-clay-content-underlies-prion.html Monday, January 17, 2011 Aerosols Transmit Prions to Immunocompetent and Immunodeficient Mice http://transmissiblespongiformencephalopathy.blogspot.com/2011/01/aerosols-transmit-prions-to.htm l Wednesday, January 07, 2009 CWD to tighten taxidermy rules Hunters need to understand regulations http://chronic-wasting-disease.blogspot.com/2009/01/cwd-to-tighten-taxidermy-rules-hunters.html Friday, February 08, 2013 *** Behavior of Prions in the Environment: Implications for Prion Biology http://chronic-wasting-disease.blogspot.com/2013/02/behavior-of-prions-in-environment.html pens,
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Response to Comments pens, PENS ??? *** Spraker suggested an interesting explanation for the occurrence of CWD. The deer pens at the Foot Hills Campus were built some 30-40 years ago by a Dr. Bob Davis. At or about that time, allegedly, some scrapie work was conducted at this site. When deer were introduced to the pens they occupied ground that had previously been occupied by sheep http://collections.europarchive.org/tna/20080102193705/http://www.bseinquiry.gov.uk/files/mb/m11 b/tab01.pdf. Response: This comment refers to aerosol transmission of CWD, soil binding of CWD and the environmental transmission of CWD. All these issues are addressed in the CWD literature technical report (Johnson, 2014), Appendix 7 of the FSEIS. This document particularly discusses environmental transmission of CWD from cervids to the environment and back to cervids.
143. Comment: Committee Business: The Committee discussed and approved three resolutions regarding CWD. They can be found in the report of the Resolutions Committee. Essentially the resolutions urged USDA-APHIS-VS to: Continue to provide funding for CWD testing of captive cervids Finalize and publish the national CWD rule for Herd Certification and Interstate Movement Evaluate live animal test, including rectal mucosal biopsy, for CWD in cervids http://www.usaha.org/Portals/6/Reports/2011/report-cwal-2011.pdf . Response: The Bridger-Teton National Forest has coordinated their efforts with APHIS. This coordination is documented in the project record.
144. Comment: 2011 Annual Report Research Project: Transmission, Differentiation, And Pathobiology of Transmissible Spongiform Encephalopathies Location: Virus and Prion Research Unit 2011 Annual Report In Objective 1, Assess cross-species transmissibility of transmissible spongiform encephalopathies (TSEs) in livestock and wildlife, numerous experiments assessing the susceptibility of various TSEs in different host species were conducted. Most notable is deer inoculated with scrapie, which exhibits similarities to chronic wasting disease (CWD) in deer suggestive of sheep scrapie as an origin of CWD. 4. Accomplishments 1. Deer inoculated with domestic isolates of sheep scrapie. Scrapie-affected deer exhibit 2 different patterns of disease associated prion protein. In some regions of the brain the pattern is much like that observed for scrapie, while in others it is more like chronic wasting disease (CWD), the transmissible spongiform encephalopathy typically associated with deer. This work conducted by ARS scientists at the National Animal Disease Center, Ames, IA suggests that an interspecies transmission of sheep scrapie to deer may have been the origin of CWD. This is important for husbandry practices with captive deer, elk and sheep for farmers and ranchers attempting to keep their herds and flocks free of CWD and scrapie. http://ars.usda.gov/research/projects/projects.htm?ACCN_NO=411467&showpars=true&fy=2011 White-tailed Deer are Susceptible to Scrapie by Natural Route of Infection Jodi D. Smith, Justin J. Greenlee, and Robert A. Kunkle; Virus and Prion Research Unit, National Animal Disease Center, USDA-ARS Interspecies transmission studies afford the opportunity to better understand the potential host range and origins of prion diseases. Previous experiments demonstrated that white-tailed deer are susceptible to sheep-derived scrapie by intracranial inoculation. The purpose of this study was to determine susceptibility of white-tailed deer to scrapie after a natural route of exposure. Deer (n=5) were inoculated by concurrent oral (30 ml) and intranasal (1 ml) instillation of a 10% (wt/vol) brain
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Response to Comments homogenate derived from a sheep clinically affected with scrapie. Non-inoculated deer were maintained as negative controls. All deer were observed daily for clinical signs. Deer were euthanized and necropsied when neurologic disease was evident, and tissues were examined for abnormal prion protein (PrPSc) by immunohistochemistry (IHC) and western blot (WB). One animal was euthanized 15 months post-inoculation (MPI) due to an injury. At that time, examination of obex and lymphoid tissues by IHC was positive, but WB of obex and colliculus were negative. Remaining deer developed clinical signs of wasting and mental depression and were necropsied from 28 to 33 MPI. Tissues from these deer were positive for scrapie by IHC and WB. Tissues with PrPSc immunoreactivity included brain, tonsil, retropharyngeal and mesenteric lymph nodes, hemal node, Peyer’s patches, and spleen. This work demonstrates for the first time that white-tailed deer are susceptible to sheep scrapie by potential natural routes of inoculation. In-depth analysis of tissues will be done to determine similarities between scrapie in deer after intracranial and oral/intranasal inoculation and chronic wasting disease resulting from similar routes of inoculation. see full text ; http://www.usaha.org/Portals/6/Reports/2010/report-cwal-2010.pdf . Response: This is a summary of research regarding cross-species transmission of scrapie, a prion disease that is similar to CWD. It is known that CWD can be transmitted both within and among cervid species. The dynamics of CWD transmission are discussed in the CWD literature technical report (Johnson, 2014), Appendix 7 of the FSEIS.
145. Comment: Tuesday, December 20, 2011 Chronic Wasting Disease CWD WISCONSIN Almond Deer (Buckhorn Flats) Farm Update DECEMBER 2011 The CWD infection rate was nearly 80%, the highest ever in a North American captive herd. RECOMMENDATION: That the Board approves the purchase of 80 acres of land for $465,000 for the Statewide Wildlife Habitat Program in Portage County and approve the restrictions on public use of the site. Form 1100-001 (R 2/11) NATURAL RESOURCES BOARD AGENDA ITEM SUBJECT: Information Item: Almond Deer Farm Update FOR: DECEMBER 2011 BOARD MEETING TUESDAY TO BE PRESENTED BY TITLE: Tami Ryan, Wildlife Health Section Chief SUMMARY: http://dnr.wi.gov/about/nrb/2011/december/12-11-2b2.pdf http://chronic-wasting-disease.blogspot.com/2011/12/chronic-wasting-disease-cwd-wisconsin.html SEE MORE USAHA REPORTS HERE, 2012 NOT PUBLISHED YET...TSS http://www.usaha.org/Portals/6/Proceedings/USAHAProceedings-2010-114th.pdf http://www.usaha.org/Portals/6/Proceedings/2009_USAHA_Proceedings.pdf http://portals5.gomembers.com/portals/6/proceedings/2008_usaha_proceedings.pdf Wednesday, November 14, 2012 PENNSYLVANIA 2012 THE GREAT ESCAPE OF CWD INVESTIGATION MOVES INTO LOUISIANA and INDIANA http://chronic-wasting-disease.blogspot.com/2012/11/pennsylvania-2012-great-escape-of-cwd_14.html Pennsylvania CWD number of deer exposed and farms there from much greater than first thought Published: Wednesday, October 17, 2012, 10:44 PM Updated: Wednesday, October 17, 2012, 11:33 PM http://chronic-wasting-disease.blogspot.com/2012/10/pennsylvania-cwd-number-of-deer-exposed.html Tuesday, October 23, 2012 PA Captive deer from CWD-positive farm roaming free http://chronic-wasting-disease.blogspot.com/2012/10/pa-captive-deer-from-cwd-positive-farm.html HERE, we see why these shooting pen owners some much like the USDA oversight of these game farms ; USDA TO PGC ONCE CAPTIVES ESCAPE "it‘s no longer its business.” problem solved $$...TSS Sunday,
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January 06, 2013 USDA TO PGC ONCE CAPTIVES ESCAPE "it‘s no longer its business.” http://chronic-wasting-disease.blogspot.com/2013/01/usda-to-pgc-once-captives-escape-its-no.html what happened to the PA deer from the CWD index heard that went to Louisiana ??? Monday, April 15, 2013 Deer farmers in the state of Louisiana are under a quarantine due to Chronic Wasting Disease CWD http://chronic-wasting-disease.blogspot.com/2013/04/deer-farmers-in-state-of-louisiana-are.html Friday, September 28, 2012 Stray elk renews concerns about deer farm security Minnesota http://chronic-wasting-disease.blogspot.com/2012/09/stray-elk-renews-concerns-about-deer.html Monday, June 11, 2012 OHIO Captive deer escapees and non-reporting http://chronic-wasting-disease.blogspot.com/2012/06/ohio-captive-deer-escapees-and-non.html Friday, October 12, 2012 Texas Animal Health Commission (TAHC) is Now Accepting Comments on Rule Proposals for “Chronic Wasting Disease (CWD)” TO: [email protected]; Texas Animal Health Commission (TAHC) http://chronic-wasting-disease.blogspot.com/2012/10/texas-animal-health-commission-tahc-is.html please note, I do not know how much of this 125 TONS of banned mad cow protein was part of the ; e) "Big Jim's" BBB Deer Ration, Big Buck Blend, Recall # V-104-6; but, this was about 10 years post mad cow feed ban from 1997. 10 years later, and still feeding banned mad cow protein to cervids??? considering that .005 gram is lethal to several bovines, and we know that the oral consumption of CWD tainted products is very efficient mode of transmission of CWD. Subject: MAD COW FEED RECALL AL AND FL VOLUME OF PRODUCT IN COMMERCE 125 TONS Products manufactured from 02/01/2005 until 06/06/2006 Date: August 6, 2006 at 6:16 pm PST PRODUCT a) CO-OP 32% Sinking Catfish, Recall # V-100-6; b) Performance Sheep Pell W/Decox/A/N, medicated, net wt. 50 lbs, Recall # V-101-6; c) Pro 40% Swine Conc Meal -- 50 lb, Recall # V-102-6; d) CO-OP 32% Sinking Catfish Food Medicated, Recall # V-103-6; ***e) "Big Jim's" BBB Deer Ration, Big Buck Blend, Recall # V-104-6; f) CO-OP 40% Hog Supplement Medicated Pelleted, Tylosin 100 grams/ton, 50 lb. bag, Recall # V-105-6; g) Pig Starter Pell II, 18% W/MCDX Medicated 282020, Carbadox -- 0.0055%, Recall # V-106-6; h) CO-OP STARTER-GROWER CRUMBLES, Complete Feed for Chickens from Hatch to 20 Weeks, Medicated, Bacitracin Methylene Disalicylate, 25 and 50 Lbs, Recall # V-107-6; i) CO-OP LAYING PELLETS, Complete Feed for Laying Chickens, Recall # 108-6; j) CO-OP LAYING CRUMBLES, Recall # V-109-6; k) CO-OP QUAIL FLIGHT CONDITIONER MEDICATED, net wt 50 Lbs, Recall # V-110-6; l) CO-OP QUAIL STARTER MEDICATED, Net Wt. 50 Lbs, Recall # V-111-6; m) CO-OP QUAIL GROWER MEDICATED, 50 Lbs, Recall # V-112-6 CODE Product manufactured from 02/01/2005 until 06/06/2006 RECALLING FIRM/MANUFACTURER Alabama Farmers Cooperative, Inc., Decatur, AL, by telephone, fax, email and visit on June 9, 2006. FDA initiated recall is complete. REASON Animal and fish feeds which were possibly contaminated with ruminant based protein not labeled as "Do not feed to ruminants". VOLUME OF PRODUCT IN COMMERCE 125 tons DISTRIBUTION AL and FL END OF ENFORCEMENT REPORT FOR AUGUST 2, 2006 ### http://www.fda.gov/Safety/Recalls/EnforcementReports/2006/ucm120413.htm 10,000,000 lbs banned blood laced meat and bone meal mbm 2007 http://www.fda.gov/Safety/Recalls/EnforcementReports/2007/ucm120446.htm [388-19] Response: The Forest Service reviewed the references provided. The infection level of CWD in captive animals in the eastern U.S. is not germane to the decision to be made for Alkali Creek Feedground.
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146. Comment: Friday, October 12, 2012 Texas Animal Health Commission (TAHC) is Now Accepting Comments on Rule Proposals for “Chronic Wasting Disease (CWD)” TO: [email protected]; Texas Animal Health Commission (TAHC) http://chronic-wasting-disease.blogspot.com/2012/10/texas-animal-health-commission-tahc-is.html please note, I do not know how much of this 125 TONS of banned mad cow protein was part of the ; e) "Big Jim's" BBB Deer Ration, Big Buck Blend, Recall # V-104-6; but, this was about 10 years post mad cow feed ban from 1997. 10 years later, and still feeding banned mad cow protein to cervids??? considering that .005 gram is lethal to several bovines, and we know that the oral consumption of CWD tainted products is very efficient mode of transmission of CWD. Subject: MAD COW FEED RECALL AL AND FL VOLUME OF PRODUCT IN COMMERCE 125 TONS Products manufactured from 02/01/2005 until 06/06/2006 Date: August 6, 2006 at 6:16 pm PST PRODUCT a) CO-OP 32% Sinking Catfish, Recall # V-100-6; b) Performance Sheep Pell W/Decox/A/N, medicated, net wt. 50 lbs, Recall # V-101-6; c) Pro 40% Swine Conc Meal -- 50 lb, Recall # V-102-6; d) CO-OP 32% Sinking Catfish Food Medicated, Recall # V-103-6; ***e) "Big Jim's" BBB Deer Ration, Big Buck Blend, Recall # V-104-6; f) CO-OP 40% Hog Supplement Medicated Pelleted, Tylosin 100 grams/ton, 50 lb. bag, Recall # V-105-6; g) Pig Starter Pell II, 18% W/MCDX Medicated 282020, Carbadox -- 0.0055%, Recall # V-106-6; h) CO-OP STARTER-GROWER CRUMBLES, Complete Feed for Chickens from Hatch to 20 Weeks, Medicated, Bacitracin Methylene Disalicylate, 25 and 50 Lbs, Recall # V-107-6; i) CO-OP LAYING PELLETS, Complete Feed for Laying Chickens, Recall # 108-6; j) CO-OP LAYING CRUMBLES, Recall # V-109-6; k) CO-OP QUAIL FLIGHT CONDITIONER MEDICATED, net wt 50 Lbs, Recall # V-110-6; l) CO-OP QUAIL STARTER MEDICATED, Net Wt. 50 Lbs, Recall # V-111-6; m) CO-OP QUAIL GROWER MEDICATED, 50 Lbs, Recall # V-112-6 CODE Product manufactured from 02/01/2005 until 06/06/2006 RECALLING FIRM/MANUFACTURER Alabama Farmers Cooperative, Inc., Decatur, AL, by telephone, fax, email and visit on June 9, 2006. FDA initiated recall is complete. REASON Animal and fish feeds which were possibly contaminated with ruminant based protein not labeled as "Do not feed to ruminants". VOLUME OF PRODUCT IN COMMERCE 125 tons DISTRIBUTION AL and FL END OF ENFORCEMENT REPORT FOR AUGUST 2, 2006 ### http://www.fda.gov/Safety/Recalls/EnforcementReports/2006/ucm120413.htm 10,000,000 lbs banned blood laced meat and bone meal mbm 2007 http://www.fda.gov/Safety/Recalls/EnforcementReports/2007/ucm120446.htm.
Response: This is an emailed comment regarding what appears to be a case of beef recalled due to the feeding of animal protein to cattle. This is not relevant to the Alkali Creek Feedground FSEIS because the elk are fed hay that does not contain animal by-products.
147. Comment: USDA TO PGC ONCE CAPTIVES ESCAPE "it‘s no longer its business.” problem solved $$...TSS Sunday, January 06, 2013 USDA TO PGC ONCE CAPTIVES ESCAPE "it‘s no longer its business.” http://chronic-wasting-disease.blogspot.com/2013/01/usda-to-pgc-once-captives-escape-its-no.html what happened to the PA deer from the CWD index heard that went to Louisiana ??? Monday, April 15, 2013 Deer farmers in the state of Louisiana are under a quarantine due to Chronic Wasting Disease CWD http://chronic-wasting-disease.blogspot.com/2013/04/deer-farmers-in-state-of-louisiana-are.html Friday, September 28, 2012 Stray elk renews concerns about deer farm security Minnesota http://chronic-wasting-disease.blogspot.com/2012/09/stray-elk-renews-concerns-about-deer.html
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Monday, June 11, 2012 OHIO Captive deer escapees and non-reporting http://chronic-wasting-disease.blogspot.com/2012/06/ohio-captive-deer-escapees-and-non.html Friday, October 12, 2012 Texas Animal Health Commission (TAHC) is Now Accepting Comments on Rule Proposals for “Chronic Wasting Disease (CWD)” TO: [email protected]; Texas Animal Health Commission (TAHC) http://chronic-wasting-disease.blogspot.com/2012/10/texas-animal-health-commission-tahc-is.html please note, I do not know how much of this 125 TONS of banned mad cow protein was part of the ; e) "Big Jim's" BBB Deer Ration, Big Buck Blend, Recall # V-104-6; bbbut, this was about 10 years post mad cow feed ban from 1997. 10 years later, and still feeding banned mad cow protein to cervids??? considering that .005 gram is lethal to several bovines, and we know that the oral consumption of CWD tainted products is very efficient mode of transmission of CWD. Subject: MAD COW FEED RECALL AL AND FL VOLUME OF PRODUCT IN COMMERCE 125 TONS Products manufactured from 02/01/2005 until 06/06/2006 Date: August 6, 2006 at 6:16 pm PST PRODUCT a) CO-OP 32% Sinking Catfish, Recall # V-100-6; b) Performance Sheep Pell W/Decox/A/N, medicated, net wt. 50 lbs, Recall # V-101-6; c) Pro 40% Swine Conc Meal -- 50 lb, Recall # V-102-6; d) CO-OP 32% Sinking Catfish Food Medicated, Recall # V-103-6; ***e) "Big Jim's" BBB Deer Ration, Big Buck Blend, Recall # V-104-6; f) CO-OP 40% Hog Supplement Medicated Pelleted, Tylosin 100 grams/ton, 50 lb. bag, Recall # V-105-6; g) Pig Starter Pell II, 18% W/MCDX Medicated 282020, Carbadox -- 0.0055%, Recall # V-106-6; h) CO-OP STARTER-GROWER CRUMBLES, Complete Feed for Chickens from Hatch to 20 Weeks, Medicated, Bacitracin Methylene Disalicylate, 25 and 50 Lbs, Recall # V-107-6; i) CO-OP LAYING PELLETS, Complete Feed for Laying Chickens, Recall # 108-6; j) CO-OP LAYING CRUMBLES, Recall # V-109-6; k) CO-OP QUAIL FLIGHT CONDITIONER MEDICATED, net wt 50 Lbs, Recall # V-110-6; l) CO-OP QUAIL STARTER MEDICATED, Net Wt. 50 Lbs, Recall # V-111-6; m) CO-OP QUAIL GROWER MEDICATED, 50 Lbs, Recall # V-112-6 CODE Product manufactured from 02/01/2005 until 06/06/2006 RECALLING FIRM/MANUFACTURER Alabama Farmers Cooperative, Inc., Decatur, AL, by telephone, fax, email and visit on June 9, 2006. FDA initiated recall is complete. REASON Animal and fish feeds which were possibly contaminated with ruminant based protein not labeled as "Do not feed to ruminants". VOLUME OF PRODUCT IN COMMERCE 125 tons DISTRIBUTION AL and FL END OF ENFORCEMENT REPORT FOR AUGUST 2, 2006 ### http://www.fda.gov/Safety/Recalls/EnforcementReports/2006/ucm120413.htm 10,000,000 lbs banned blood laced meat and bone meal mbm 2007 http://www.fda.gov/Safety/Recalls/EnforcementReports/2007/ucm120446.htm ------Original Message ------Subject: DOCKET-- 03D-0186 -- FDA Issues Draft Guidance on Use of Material From Deer and Elk in Animal Feed; Availability Date: Fri, 16 May 2003 11:47:37 –0500 From: "Terry S. Singeltary Sr."
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Response to Comments draining the alimentary tract within a few weeks after oral exposure to infectious prions and may reflect the initial pathway of CWD infection in deer. The rapid infection of deer fawns following exposure by the most plausible natural route is consistent with the efficient horizontal transmission of CWD in nature and enables accelerated studies of transmission and pathogenesis in the native species. http://vir.sgmjournals.org/cgi/content/full/80/10/2757 now, just what is in that deer feed? _ANIMAL PROTEIN_ Subject: MAD DEER/ELK DISEASE AND POTENTIAL SOURCES Date: Sat, 25 May 2002 18:41:46 -0700 From: "Terry S. Singeltary Sr." Reply-To: BSE-LTo: BSE-L 8420-20.5% Antler Developer For Deer and Game in the wild Guaranteed Analysis Ingredients / Products Feeding Directions .. _animal protein_ http://www.surefed.com/deer.htm .. DEPARTMENT OF HEALTH & HUMAN SERVICESPUBLIC HEALTH SERVICEFOOD AND DRUG ADMINISTRATION April 9, 2001 WARNING LETTER 01-PHI-12 CERTIFIED MAIL RETURN RECEIPT REQUESTED Brian J. Raymond, Owner Sandy Lake Mills 26 Mill Street PAGE O. Box 117 Sandy Lake, PA 16145 PHILADELPHIA DISTRICT Tel: 215-597-4390 Dear Mr. Raymond:Food and Drug Administration Investigator Gregory E. Beichner conducted an inspection of your animal feed manufacturing operation, located in Sandy Lake, Pennsylvania, on March 23,2001, and determined that your firm manufactures animal feeds including feeds containing prohibited materials. The inspection found significant deviations from the requirements set forth in Title 21, code of Federal Regulations, part 589.2000 - Animal Proteins Prohibited in Ruminant Feed. The regulation is intended to prevent the establishment and amplification of Bovine Spongiform Encephalopathy (BSE) . Such deviations cause products being manufactured at this facility to be misbranded within the meaning of Section 403(f), of the Federal Food, Drug, and Cosmetic Act (the Act).Our investigation found failure to label your swine feed with the required cautionary statement "Do Not Feed to cattle or other Ruminants" The FDA suggests that the statement be distinguished by different type-size or color or other means of highlighting the statement so that it is easily noticed by a purchaser. In addition, we note that you are using approximately 140 pounds of cracked corn to flush your mixer used in the manufacture of animal feeds containing prohibited material. This flushed material is fed to wild game including deer, a ruminant animal. Feed material which may potentially contain prohibited material should not be fed to ruminant animals which may become part of the food chain. The above is not intended to be an all-inclusive list of deviations from the regulations. As a manufacturer of materials intended for animal feed use, you are responsible for assuring that your overall operation and the products you manufacture and distribute are in compliance with the law. We have enclosed a copy of FDA's Small Entity Compliance Guide to assist you with complying with the regulation... blah, blah, blah... http://www.fda.gov/foi/warning_letters/g1115d.pdf end...full text ; 2003D-0186 Guidance for Industry: Use of Material From Deer and Elk In Animal Feed EMC 1 Terry S. Singeltary Sr. Vol #: 1 http://www.fda.gov/ohrms/dockets/dailys/03/Jun03/060903/060903.htm http://www.fda.gov/ohrms/dockets/dailys/01/Oct01/101501/101501.htm see my full text submission here ; http://madcowfeed.blogspot.com/2008/07/docket-03d-0186-fda-issues-draft.html. Response: These comments refer to farmed cervids that have escaped from captivity. The elk that visit Alkali Creek Feedground in the winter are free-roaming animals. The impacts of congregating elk in the winter are disclosed throughout the FSEIS.
148. Comment: Subject: DOCKET-- 03D-0186 -- FDA Issues Draft Guidance on Use of Material From Deer and Elk in Animal Feed; Availability Date: Fri, 16 May 2003 11:47:37 –0500 From: "Terry S. Singeltary Sr."
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Response to Comments
149. Comment: Subject: MAD DEER/ELK DISEASE AND POTENTIAL SOURCES Date: Sat, 25 May 2002 18:41:46 -0700 From: "Terry S. Singeltary Sr." Reply-To: BSE-LTo: BSE-L 8420-20.5% Antler Developer For Deer and Game in the wild Guaranteed Analysis Ingredients / Products Feeding Directions_animal protein_ http://www.surefed.com/deer.htm. DEPARTMENT OF HEALTH & HUMAN SERVICESPUBLIC HEALTH SERVICEFOOD AND DRUG ADMINISTRATION April 9, 2001 WARNING LETTER01-PHI-12CERTIFIED MAILRETURN RECEIPT REQUESTED Brian J. Raymond, Owner Sandy Lake Mills 26 Mill Street PAGE O. Box 117 Sandy Lake, PA 16145 PHILADELPHIA DISTRICT Tel: 215-597-4390 Dear Mr. Raymond: Food and Drug Administration Investigator Gregory E. Beichner conducted an inspection of your animal feed manufacturing operation, located in Sandy Lake, Pennsylvania, on March 23,2001, and determined that your firm manufactures animal feeds including feeds containing prohibited materials. The inspection found significant deviations from the requirements set forth in Title 21, code of Federal Regulations, part 589.2000 - Animal Proteins Prohibited in Ruminant Feed. The regulation is intended to prevent the establishment and amplification of Bovine Spongiform Encephalopathy (BSE) . Such deviations cause products being manufactured at this facility to be misbranded within the meaning of Section 403(f), of the Federal Food, Drug, and Cosmetic Act (the Act).Our investigation found failure to label your swine feed with the required cautionary statement "Do Not Feed to cattle or other Ruminants" The FDA suggests that the statement be distinguished by different type-size or color or other means of highlighting the statement so that it is easily noticed by a purchaser. In addition, we note that you are using approximately 140 pounds of cracked corn to flush your mixer used in the manufacture of animal feeds containing prohibited material. This flushed material is fed to wild game including deer, a ruminant animal. Feed material which may potentially contain prohibited material should not be fed to ruminant animals which may become part of the food chain. The above is not intended to be an all-inclusive list of deviations from the regulations. As a manufacturer of materials intended for animal feed use, you are responsible for assuring that your overall operation and the products you manufacture
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Response to Comments and distribute are in compliance with the law. We have enclosed a copy of FDA's Small Entity Compliance Guide to assist you with complying with the regulation... blah, blah, blah... http://www.fda.gov/foi/warning_letters/g1115d.pdf ..end...full text ; 2003D-0186 Guidance for Industry: Use of Material From Deer and Elk In Animal Feed EMC 1 Terry S. Singeltary Sr. Vol #: 1 http://www.fda.gov/ohrms/dockets/dailys/03/Jun03/060903/060903.htm http://www.fda.gov/ohrms/dockets/dailys/01/Oct01/101501/101501.htm see my full text submission here ; http://madcowfeed.blogspot.com/2008/07/docket-03d-0186-fda-issues-draft.html. Response: This comment concerns letters to the Department of Health and Human Services and other agencies regarding animal protein in feed. This issue is not relevant to the Alkali Creek Feedground decision, as there are no animal by-products in the hay distributed on the feedgrounds.
150. Comment: Sunday, April 21, 2013 Politicians ignore alarming CWD spike in Wyoming valley Wisconsin http://chronic-wasting-disease.blogspot.com/2013/04/politicians-ignore-alarming-cwd-spike.html Tuesday, April 16, 2013 Cervid Industry Unites To Set Direction for CWD Reform and seem to ignore their ignorance and denial in their role in spreading Chronic Wasting Disease http://chronic-wasting-disease.blogspot.com/2013/04/cervid-industry-unites-to-set-direction.html Thursday, May 02, 2013 Chronic Wasting Disease (CWD) Texas Important Update on OBEX ONLY TEXTING http://chronic-wasting-disease.blogspot.com/2013/05/chronic-wasting-disease-cwd-texas.html what about human exposure to CWD and friendly fire (iatrogenic) pass it forward mode of transmission i.e. 2nd hand exposure via surgical, medical, blood, tissue, dental, to humans ??? Response: These comments refer to concerns regarding transmission of CWD to humans. Transmission of CWD to humans or to mice expressing human genetics has never been documented.
151. Comment: Monday, May 23, 2011 CDC Assesses Potential Human Exposure to Prion Diseases Travel Warning Public release date: 23-May-2011 Contact: Francesca Costanzo [email protected]
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Response to Comments diseases are a group of rare brain diseases that affect humans and animals. When a person gets a prion disease, brain function is impaired. This causes memory and personality changes, dementia, and problems with movement. All of these worsen over time. These diseases are invariably fatal. Since these diseases may take years to manifest, knowing the extent of human exposure to possible prion diseases could become important in the event of an outbreak. CDC investigators evaluated the results of the 2006-2007 population survey conducted by the Foodborne Diseases Active Surveillance Network (FoodNet). This survey collects information on food consumption practices, health outcomes, and demographic characteristics of residents of the participating Emerging Infections Program sites. The survey was conducted in Connecticut, Georgia, Maryland, Minnesota, New Mexico, Oregon, and Tennessee, as well as five counties in the San Francisco Bay area, seven counties in the Greater Denver area, and 34 counties in western and northeastern New York. Survey participants were asked about behaviors that could be associated with exposure to the agents causing BSE and CWD, including travel to the nine countries considered to be BSE-endemic (United Kingdom, Republic of Ireland, France, Portugal, Switzerland, Italy, the Netherlands, Germany, Spain) and the cumulative length of stay in each of those countries. Respondents were asked if they ever had hunted for deer or elk, and if that hunting had taken place in areas considered to be CWD-endemic (northeastern Colorado, southeastern Wyoming or southwestern Nebraska). They were also asked if they had ever consumed venison, the frequency of consumption, and whether the meat came from the wild. The proportion of survey respondents who reported travel to at least one of the nine BSE endemic countries since 1980 was 29.5%. Travel to the United Kingdom was reported by 19.4% of respondents, higher than to any other BSE-endemic country. Among those who traveled, the median duration of travel to the United Kingdom (14 days) was longer than that of any other BSE-endemic country. Travelers to the UK were more likely to have spent at least 30 days in the country (24.9%) compared to travelers to any other BSE endemic country. The prevalence and extent of travel to the UK indicate that health concerns in the UK may also become issues for US residents. The proportion of survey respondents reporting having hunted for deer or elk was 18.5% and 1.2% reported having hunted for deer or elk in CWD-endemic areas. Venison consumption was reported by 67.4% of FoodNet respondents, and 88.6% of those reporting venison consumption had obtained all of their meat from the wild. These findings reinforce the importance of CWD surveillance and control programs for wild deer and elk to reduce human exposure to the CWD agent. Hunters in CWD-endemic areas are advised to take simple precautions such as: avoiding consuming meat from sickly deer or elk, avoiding consuming brain or spinal cord tissues, minimizing the handling of brain and spinal cord tissues, and wearing gloves when field-dressing carcasses. According to Abrams, "The 2006-2007 FoodNet population survey provides useful information should foodborne prion infection become an increasing public health concern in the future. The data presented describe the prevalence of important behaviors and their associations with demographic characteristics. Surveillance of BSE, CWD, and human prion diseases are critical aspects of addressing the burden of these diseases in animal populations and how that may relate to human health." ### The article is "Travel history, hunting, and venison consumption related to prion disease exposure, 2006-2007 FoodNet population survey" by Joseph Y. Abrams, MPH; Ryan A. Maddox, MPH; Alexis R Harvey, MPH; Lawrence B. Schonberger, MD; and Ermias D. Belay, MD. It appears in the Journal of the American Dietetic Association, Volume 111, Issue 6 (June 2011) published by Elsevier. In an accompanying podcast
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CDC's Joseph Y. Abrams discusses travel, hunting, and eating venison in relation to prion diseases. It is available at http://adajournal.org/content/podcast. http://www.eurekalert.org/pub_releases/2011-05/ehs-cap051811.php Thursday, May 26, 2011 Travel History, Hunting, and Venison Consumption Related to Prion Disease Exposure, 2006-2007 FoodNet Population Survey Journal of the American Dietetic Association Volume 111, Issue 6 , Pages 858-863, June 2011. Travel History, Hunting, and Venison Consumption Related to Prion Disease Exposure, 2006-2007 FoodNet Population Survey Joseph Y. Abrams, MPH, Ryan A. Maddox, MPH , Alexis R. Harvey, MPH , Lawrence B. Schonberger, MD , Ermias D. Belay, MD Accepted 15 November 2010. Abstract Full Text PDF References . Abstract The transmission of bovine spongiform encephalopathy (BSE) to human beings and the spread of chronic wasting disease (CWD) among cervids have prompted concerns about zoonotic transmission of prion diseases. Travel to the United Kingdom and other European countries, hunting for deer or elk, and venison consumption could result in the exposure of US residents to the agents that cause BSE and CWD. The Foodborne Diseases Active Surveillance Network 2006-2007 population survey was used to assess the prevalence of these behaviors among residents of 10 catchment areas across the United States. Of 17,372 survey respondents, 19.4% reported travel to the United Kingdom since 1980, and 29.5% reported travel to any of the nine European countries considered to be BSE-endemic since 1980. The proportion of respondents who had ever hunted deer or elk was 18.5%, and 1.2% had hunted deer or elk in a CWD–endemic area. More than two thirds (67.4%) reported having ever eaten deer or elk meat. Respondents who traveled spent more time in the United Kingdom (median 14 days) than in any other BSE-endemic country. Of the 11,635 respondents who had consumed venison, 59.8% ate venison at most one to two times during their year of highest consumption, and 88.6% had obtained all of their meat from the wild. The survey results were useful in determining the prevalence and frequency of behaviors that could be important factors for foodborne prion transmission. http://www.adajournal.org/article/S0002-8223(11)00278-1/abstract CDC Saturday, February 18, 2012 Occurrence, Transmission, and Zoonotic Potential of Chronic Wasting Disease CDC Volume 18, Number 3—March 2012 SNIPAGE .. Interspecies transmission of CWD to noncervids has not been observed under natural conditions. CWD infection of carcass scavengers such as raccoons, opossums, and coyotes was not observed in a recent study in Wisconsin (22). In addition, natural transmission of CWD to cattle has not been observed in experimentally controlled natural exposure studies or targeted surveillance (2). However, CWD has been experimentally transmitted to cattle, sheep, goats, mink, ferrets, voles, and mice by intracerebral inoculation (2,29,33). CWD is likely transmitted among mule, white-tailed deer, and elk without a major species barrier (1), and other members of the cervid family, including reindeer, caribou, and other species of deer worldwide, may be vulnerable to CWD infection. Black-tailed deer (a subspecies of mule deer) and European red deer (Cervus elaphus) are susceptible to CWD by natural routes of infection (1,34). Fallow deer (Dama dama) are susceptible to CWD by intracerebral inoculation (35). Continued study of CWD susceptibility in other cervids is of considerable interest. Reasons for Caution There are several reasons for caution with respect to zoonotic and interspecies CWD transmission. First, there is strong evidence that distinct CWD strains exist (36). Prion strains are distinguished by varied incubation periods, clinical symptoms, PrPSc conformations, and CNS PrPSc depositions (3,32). Strains have been identified in other natural prion diseases, including scrapie, BSE, and CJD (3). Intraspecies and interspecies transmission of prions from
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CWD-positive deer and elk isolates resulted in identification of >2 strains of CWD in rodent models (36), indicating that CWD strains likely exist in cervids. However, nothing is currently known about natural distribution and prevalence of CWD strains. Currently, host range and pathogenicity vary with prion strain (28,37). Therefore, zoonotic potential of CWD may also vary with CWD strain. In addition, diversity in host (cervid) and target (e.g., human) genotypes further complicates definitive findings of zoonotic and interspecies transmission potentials of CWD. Intraspecies and interspecies passage of the CWD agent may also increase the risk for zoonotic CWD transmission. The CWD prion agent is undergoing serial passage naturally as the disease continues to emerge. In vitro and in vivo intraspecies transmission of the CWD agent yields PrPSc with an increased capacity to convert human PrPc to PrPSc (30). Interspecies prion transmission can alter CWD host range (38) and yield multiple novel prion strains (3,28). The potential for interspecies CWD transmission (by cohabitating mammals) will only increase as the disease spreads and CWD prions continue to be shed into the environment. This environmental passage itself may alter CWD prions or exert selective pressures on CWD strain mixtures by interactions with soil, which are known to vary with prion strain (25), or exposure to environmental or gut degradation. Given that prion disease in humans can be difficult to diagnose and the asymptomatic incubation period can last decades, continued research, epidemiologic surveillance, and caution in handling risky material remain prudent as CWD continues to spread and the opportunity for interspecies transmission increases. Otherwise, similar to what occurred in the United Kingdom after detection of variant CJD and its subsequent link to BSE, years of prevention could be lost if zoonotic transmission of CWD is subsequently identified, CWD will likely continue to emerge in North America. ... SNIPAGE .. http://wwwnc.cdc.gov/eid/article/18/3/11-0685_article.htm http://wwwnc.cdc.gov/eid/article/18/3/11-0685_article.htm Response: The FSEIS and the CWD literature technical report (Johnson, 2014, Appendix 7) in the project record, describe the potential effects of the proposed action on the arrival and spread of CWD.
152. Comment: Generation of a new form of human PrPSc in vitro by inter-species transmission from cervids prions. Our results have far-reaching implications for human health, since they indicate that cervid PrPSc can trigger the conversion of human PrPC into PrPSc, suggesting that CWD might be infectious to humans. Interestingly our findings suggest that unstable strains from CWD affected animals might not be a problem for humans, but upon strain stabilization by successive passages in the wild, this disease might become progressively more transmissible to man. http://www.jbc.org/content/early/2011/01/04/jbc.M110.198465.full.pdf Our results also have profound implications for understanding the mechanisms of the prion species barrier and indicate that the transmission barrier is a dynamic process that depends on the strain and moreover the degree of adaptation of the strain. If our findings are corroborated by infectivity assays, they will imply that CWD prions have the potential to infect humans and that this ability progressively increases with CWD spreading. http://www.jbc.org/content/286/9/7490 http://www.jbc.org/content/286/9/7490.full.pdf+html P35 ADAPTATION OF CHRONIC WASTING DISEASE (CWD) INTO HAMSTERS, EVIDENCE OF A WISCONSIN STRAIN OF CWD Chad Johnson1, Judd Aiken2,3,4 and Debbie McKenzie4,5 1 Department of Comparative Biosciences, University of Wisconsin, Madison WI, USA 53706 2 Department of Agriculture, Food and Nutritional Sciences, 3 Alberta Veterinary Research Institute, 4.Center for Prions and Protein Folding Diseases, 5 Department of
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Biological Sciences, University of Alberta, Edmonton AB, Canada T6G 2P5 The identification and characterization of prion strains is increasingly important for the diagnosis and biological definition of these infectious pathogens. Although well-established in scrapie and, more recently, in BSE, comparatively little is known about the possibility of prion strains in chronic wasting disease (CWD), a disease affecting free ranging and captive cervids, primarily in North America. We have identified prion protein variants in the white-tailed deer population and demonstrated that Prnp genotype affects the susceptibility/disease progression of white-tailed deer to CWD agent. The existence of cervid prion protein variants raises the likelihood of distinct CWD strains. Small rodent models are a useful means of identifying prion strains. We intracerebrally inoculated hamsters with brain homogenates and phosphotungstate concentrated preparations from CWD positive hunter-harvested (Wisconsin CWD endemic area) and experimentally infected deer of known Prnp genotypes. These transmission studies resulted in clinical presentation in primary passage of concentrated CWD prions. Subclinical infection was established with the other primary passages based on the detection of PrPCWD in the brains of hamsters and the successful disease transmission upon second passage. Second and third passage data, when compared to transmission studies using different CWD inocula (Raymond et al., 2007) indicate that the CWD agent present in the Wisconsin white-tailed deer population is different than the strain(s) present in elk, mule-deer and white-tailed deer from the western United States endemic region. http://www.istitutoveneto.it/prion_09/Abstracts_09.pdf PPo3-7: Prion Transmission from Cervids to Humans is Strain-dependent Qingzhong Kong, Shenghai Huang,*Fusong Chen, Michael Payne, Pierluigi Gambetti and Liuting Qing Department of Pathology; Case western Reserve University; Cleveland, OH USA *Current address: Nursing Informatics; Memorial Sloan-Kettering Cancer Center; New York, NY USA Key words: CWD, strain, human transmission Chronic wasting disease (CWD) is a widespread prion disease in cervids (deer and elk) in North America where significant human exposure to CWD is likely and zoonotic transmission of CWD is a concern. Current evidence indicates a strong barrier for transmission of the classical CWD strain to humans with the PrP-129MM genotype. A few recent reports suggest the presence of two or more CWD strains. What remain unknown is whether individuals with the PrP-129VV/MV genotypes are also resistant to the classical CWD strain and whether humans are resistant to all natural or adapted cervid prion strains. Here we report that a human prion strain that had adopted the cervid prion protein (PrP) sequence through passage in cervidized transgenic mice efficiently infected transgenic mice expressing human PrP, indicating that the species barrier from cervid to humans is prion strain-dependent and humans can be vulnerable to novel cervid prion strains. Preliminary results on CWD transmission in transgenic mice expressing human PrP-129V will also be discussed. Acknowledgement Supported by NINDS NS052319 and NIA AG14359. PPo2-27: Generation of a Novel form of Human PrPSc by Inter-species Transmission of Cervid Prions Marcelo A. Barria,1 Glenn C. Telling,2 Pierluigi Gambetti,3 James A. Mastrianni4 and Claudio Soto1 1Mitchell Center for Alzheimer's disease and related Brain disorders; Dept of Neurology; University of Texas Houston Medical School; Houston, TX USA; 2Dept of Microbiology, Immunology & Molecular Genetics and Neurology; Sanders Brown Center on Aging; University of Kentucky Medical Center; Lexington, KY USA; 3Institute of Pathology; Case western Reserve University; Cleveland, OH USA; 4Dept of Neurology; University of Chicago; Chicago, IL USA Prion diseases are infectious neurodegenerative disorders affecting humans and animals that result from the conversion of normal prion protein (PrPC) into the misfolded and
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Response to Comments infectious prion (PrPSc). Chronic wasting disease (CWD) of cervids is a prion disorder of increasing prevalence within the United States that affects a large population of wild and captive deer and elk. CWD is highly contagious and its origin, mechanism of transmission and exact prevalence are currently unclear. The risk of transmission of CWD to humans is unknown. Defining that risk is of utmost importance, considering that people have been infected by animal prions, resulting in new fatal diseases. To study the possibility that human PrPC can be converted into the infectious form by CWD PrPSc we performed experiments using the Protein Misfolding Cyclic Amplification (PMCA) technique, which mimic in vitro the process of prion replication. Our results show that cervid PrPSc can induce the pathological conversion of human PrPC, but only after the CWD prion strain has been stabilized by successive passages in vitro or in vivo. Interestingly, this newly generated human PrPSc exhibits a distinct biochemical pattern that differs from any of the currently known forms of human PrPSc, indicating that it corresponds to a novel human prion strain. Our findings suggest that CWD prions have the capability to infect humans, and that this ability depends on CWD strain adaptation, implying that the risk for human health progressively increases with the spread of CWD among cervids. PPo2-7: Biochemical and Biophysical Characterization of Different CWD Isolates Martin L. Daus and Michael Beekes Robert Koch Institute; Berlin, Germany Key words: CWD, strains, FT-IR, AFM Chronic wasting disease (CWD) is one of three naturally occurring forms of prion disease. The other two are Creutzfeldt-Jakob disease in humans and scrapie in sheep. CWD is contagious and affects captive as well as free ranging cervids. As long as there is no definite answer of whether CWD can breach the species barrier to humans precautionary measures especially for the protection of consumers need to be considered. In principle, different strains of CWD may be associated with different risks of transmission to humans. Sophisticated strain differentiation as accomplished for other prion diseases has not yet been established for CWD. However, several different findings indicate that there exists more than one strain of CWD agent in cervids. We have analyzed a set of CWD isolates from white-tailed deer and could detect at least two biochemically different forms of disease-associated prion protein PrPTSE. Limited proteolysis with different concentrations of proteinase K and/or after exposure of PrPTSE to different pH-values or concentrations of Guanidinium hydrochloride resulted in distinct isolate-specific digestion patterns. Our CWD isolates were also examined in protein misfolding cyclic amplification studies. This showed different conversion activities for those isolates that had displayed significantly different sensitivities to limited proteolysis by PK in the biochemical experiments described above. We further applied Fourier transform infrared spectroscopy in combination with atomic force microscopy. This confirmed structural differences in the PrPTSE of at least two distinct CWD isolates. The data presented here substantiate and expand previous reports on the existence of different CWD strains. http://www.prion2010.org/bilder/prion_2010_program_latest_w_posters_4_.pdf?139&PHPSESSID=a30 a38202cfec579000b77af81be3099 2012 Envt.06: Zoonotic Potential of CWD: Experimental Transmissions to Non-Human Primates Emmanuel Comoy,1,† Valérie Durand,1 Evelyne Correia,1 Aru Balachandran,2 Jürgen Richt,3 Vincent Beringue,4 Juan-Maria Torres,5 Paul Brown,1 Bob Hills6 and Jean-Philippe Deslys1 1Atomic Energy Commission; Fontenay-aux-Roses, France; 2Canadian Food Inspection Agency; Ottawa, ON Canada; 3Kansas State University; Manhattan, KS USA; 4INRA; Jouy-en-Josas, France; 5INIA; Madrid, Spain; 6Health Canada; Ottawa, ON Canada †Presenting author; Email: [email protected]
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Response to Comments wasting disease (CWD) incidence in North America raises a question about their zoonotic potential. A recent publication showed their transmissibility to new-world monkeys, but no transmission to old-world monkeys, which are phylogenetically closer to humans, has so far been reported. Moreover, several studies have failed to transmit CWD to transgenic mice overexpressing human PrPAGE Bovine spongiform encephalopathy (BSE) is the only animal prion disease for which a zoonotic potential has been proven. We described the transmission of the atypical BSE-L strain of BSE to cynomolgus monkeys, suggesting a weak cattle-to-primate species barrier. We observed the same phenomenon with a cattle adapted strain of TME (Transmissible Mink Encephalopathy). Since cattle experimentally exposed to CWD strains have also developed spongiform encephalopathies, we inoculated brain tissue from CWD-infected cattle to three cynomolgus macaques as well as to transgenic mice overexpressing bovine or human PrPAGE Since CWD prion strains are highly lymphotropic, suggesting an adaptation of these agents after peripheral exposure, a parallel set of four monkeys was inoculated with CWD-infected cervid brains using the oral route. Nearly four years post-exposure, monkeys exposed to CWD-related prion strains remain asymptomatic. In contrast, bovinized and humanized transgenic mice showed signs of infection, suggesting that CWD-related prion strains may be capable of crossing the cattle-to-primate species barrier. Comparisons with transmission results and incubation periods obtained after exposure to other cattle prion strains (c-BSE, BSE-L, BSE-H and cattle-adapted TME) will also be presented, in order to evaluate the respective risks of each strain. Envt.07: Pathological Prion Protein (PrPTSE) in Skeletal Muscles of Farmed and Free Ranging White-Tailed Deer Infected with Chronic Wasting Disease Martin L. Daus,1,† Johanna Breyer,2 Katjs Wagenfuehr,1 Wiebke Wemheuer,2 Achim Thomzig,1 Walter Schulz-Schaeffer2 and Michael Beekes1 1Robert Koch Institut; P24 TSE; Berlin, Germany; 2Department of Neuropathology, Prion and Dementia Research Unit, University Medical Center Göttingen; Göttingen, Germany †Presenting author; Email: [email protected]
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Response to Comments literature technical report (Johnson, 2014, Appendix 7) or the FSEIS. The fact that CWD can be transmitted between and among cervid species is described in Johnson, 2014. The possible transmission of CWD to other species has not been scientifically documented.
153. Comment: CJD9/10022 October 1994 Mr R.N. Elmhirst Chairman British Deer Farmers Association Holly Lodge Spencers Lane BerksWell Coventry CV7 7BZ Dear Mr Elmhirst, CREUTZFELDT-JAKOB DISEASE (CJD) SURVEILLANCE UNIT REPORT Thank you for your recent letter concerning the publication of the third annual report from the CJD Surveillance Unit. I am sorry that you are dissatisfied with the way in which this report was published. The Surveillance Unit is a completely independent outside body and the Department of Health is committed to publishing their reports as soon as they become available. In the circumstances it is not the practice to circulate the report for comment since the findings of the report would not be amended. In future we can ensure that the British Deer Farmers Association receives a copy of the report in advance of publication. The Chief Medical Officer has undertaken to keep the public fully informed of the results of any research in respect of CJD. This report was entirely the work of the unit and was produced completely independently of the Department. The statistical results regarding the consumption of venison was put into perspective in the body of the report and was not mentioned at all in the press release. Media attention regarding this report was low key but gave a realistic presentation of the statistical findings of the Unit. This approach to publication was successful in that consumption of venison was highlighted only once by the media ie. in the News at one television proqram. I believe that a further statement about the report, or indeed statistical links between CJD and consumption of venison, would increase, and quite possibly give damaging credence, to the whole issue. From the low key media reports of which I am aware it seems unlikely that venison consumption will suffer adversely, if at all. http://web.archive.org/web/20030511010117/http://www.bseinquiry.gov.uk/files/yb/1994/10/000030 01.pdf now, let’s see what the authors said about this casual link, personal communications years ago. see where it is stated NO STRONG evidence. so, does this mean there IS casual evidence ???? “Our conclusion stating that we found no strong evidence of CWD transmission to humans” From: TSS (216-119-163-189.ipset45.wt.net
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Response to Comments disease of cervids: Chronic wasting disease Sigurdson CJ... *** twenty-seven CJD patients who regularly consumed venison were reported to the Surveillance Center***,.. full text ; http://chronic-wasting-disease.blogspot.com/2008/04/prion-disease-of-cervids-chronic.html http://chronic-wasting-disease.blogspot.com/2006_12_01_archive.html Sunday, January 22, 2012 Chronic Wasting Disease CWD cervids interspecies transmission http://chronic-wasting-disease.blogspot.com/2012/01/chronic-wasting-disease-cwd-cervids.html. Response: These are references to letters to various other government agencies regarding CWD infection in humans. The fact that CWD can be transmitted between and among cervid species is described in the CWD literature technical report (Johnson, 2014, Appendix 7 in the FSEIS). The possible transmission of CWD to other species including humans has not been scientifically documented.
154. Comment: Friday, November 09, 2012 *** Chronic Wasting Disease CWD in cervidae and transmission to other species http://chronic-wasting-disease.blogspot.com/2012/11/chronic-wasting-disease-cwd-in-cervidae.html Friday, November 09, 2012 *** Chronic Wasting Disease CWD in cervidae and transmission to other species http://chronic-wasting-disease.blogspot.com/2012/11/chronic-wasting-disease-cwd-in-cervidae.html Sunday, November 11, 2012 *** Susceptibilities of Nonhuman Primates to Chronic Wasting Disease November 2012 http://chronic-wasting-disease.blogspot.com/2012/11/susceptibilities-of-nonhuman-primates.html Friday, December 14, 2012 Susceptibility Chronic Wasting Disease (CWD) in wild cervids to Humans 2005 - December 14, 2012 http://chronic-wasting-disease.blogspot.com/2012/12/susceptibility-chronic-wasting-disease.html Saturday, March 09, 2013 Chronic Wasting Disease in Bank Voles: Characterization of the Shortest Incubation Time Model for Prion Diseases http://chronic-wasting-disease.blogspot.com/2013/03/chronic-wasting-disease-in-bank-voles.html. Response: The fact that CWD can be transmitted between and among cervid species is described in the CWD literature technical report (Johnson, 2014, Appendix 7 of the FSEIS). The possible transmission of CWD to other species has not been scientifically documented.
155. Comment: *** NOR IS THE FDA recalling this CWD positive elk meat for the well-being of the dead elk; Wednesday, March 18, 2009 Noah’s Ark Holding, LLC, Dawson, MN RECALL Elk products contain meat derived from an elk confirmed to have CWD NV, CA, TX, CO, NY, UT, FL, OK RECALLS AND FIELD CORRECTIONS: FOODS CLASS II ______PRODUCT a) Elk Meat, Elk Tenderloin, Frozen in plastic vacuum packaging. Each package is approximately 2 lbs., and each case is approximately 16 lbs.; Item number 755125, Recall # F-129-9; b) Elk Meat, Elk Trim, Frozen; Item number 755155, Recall # F-130-9; c) Elk Meat, French Rack, Chilled. Item number 755132, Recall # F-131-9; d) Elk Meat, Nude Denver Leg. Item number 755122, Recall # F-132-9; e) Elk Meat, New York Strip Steak, Chilled. Item number 755128, Recall # F-133-9; f) Elk Meat, Flank Steak Frozen. Item number 755131, Recall # F-134-9; CODE Elk Meats with production dates of December 29, 30, and 31 RECALLING FIRM/MANUFACTURER Recalling Firm: Sierra Meats, Reno, NV, by telephone on January 29, 2009 and press release on February 9, 2009. Manufacturer: Noah’s Ark Holding, LLC, Dawson, MN. Firm initiated
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Response to Comments recall is ongoing. REASON Elk products contain meat derived from an elk confirmed to have Chronic Wasting Disease (CWD). VOLUME OF PRODUCT IN COMMERCE Unknown DISTRIBUTION NV, CA, TX, CO, NY, UT, FL, OK. http://www.fda.gov/bbs/topics/ENFORCE/2009/ENF01099.html Monday, February 09, 2009 Exotic Meats USA Announces Urgent Statewide Recall of Elk Tenderloin Because It May Contain Meat Derived From An Elk Confirmed To Have CWD... Cross-sequence transmission of sporadic Creutzfeldt-Jakob disease creates a new prion strain Date: August 25, 2007 at 12:42 pm PST our results raise the possibility that CJD cases classified as VV1 may include cases caused by iatrogenic transmission of sCJD-MM1 prions or food-borne infection by type 1 prions from animals, e.g., chronic wasting disease prions in cervid. In fact, two CJD-VV1 patients who hunted deer or consumed venison have been reported (40, 41). The results of the present study emphasize the need for trace back studies and careful re-examination of the biochemical properties of sCJD-VV1 prions. http://www.jbc.org/ Wednesday, March 18, 2009 Noah's Ark Holding, LLC, Dawson, MN RECALL Elk products contain meat derived from an elk confirmed to have CWD NV, CA, TX, CO, NY, UT, FL, OK RECALLS AND FIELD CORRECTIONS: FOODS CLASS II http://chronic-wasting-disease.blogspot.com/2009/03/noahs-ark-holding-llc-dawson-mn-recall.html. Response: The recall of potentially CWD-infected elk meat is not proposed in this project.
156. Comment: Tuesday, March 05, 2013 Chronic Wasting Disease Management Plan/Environmental Impact Statement, Shenandoah National Park Virginia http://chronic-wasting-disease.blogspot.com/2013/03/chronic-wasting-disease-management.html [388-46] Response: This blog post is a copy of the letter sent to Shenandoah National Park (SNP) regarding their CWD Management Plan. That letter was a copy/paste of the blog and expressed concerns specifically about CWD and related diseases being transmitted to humans. The majority of the posts within that letter that could be considered comments for this project have been addressed in the present comment and response effort. All others are either specific to the SNP decision or have to do with human diseases. The fact that CWD can be transmitted between and among cervid species is described in the CWD literature technical report (Johnson, 2014, Appendix 7 in the FSEIS). The possible transmission of CWD to other species, including humans has not been scientifically documented.
157. Comment: Monday, April 15, 2013 Dr. Stephen B. Thacker Director Centers for Disease Control and Prevention's Office of Science, Epidemiology and Laboratory Services (OSELS) dies from Creutzfeldt Jakob Disease CJD http://creutzfeldt-jakob-disease.blogspot.com/2013/04/dr-stephen-b-thacker-director-centers.html http://creutzfeldt-jakob-disease.blogspot.com/ http://chronic-wasting-disease.blogspot.com/ http://transmissiblespongiformencephalopathy.blogspot.com/ Thursday, May 02, 2013 Chronic Wasting Disease (CWD) Texas Important Update on OBEX ONLY TEXTING http://chronic-wasting-disease.blogspot.com/2013/05/chronic-wasting-disease-cwd-texas.html Wednesday, May 15, 2013 Intranasal Inoculation of White-Tailed Deer (Odocoileus virginianus) with Lyophilized Chronic Wasting Disease Prion Particulate Complexed to Montmorillonite Clay Research Article http://chronic-wasting-disease.blogspot.com/2013/05/intranasal-inoculation-of-white-tailed.html
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Response: The potential transmission of CWD to humans and the method used for testing are not relevant to the decision to be made for Alkali Creek Feedground. The fact that soil can play a role in CWD transmission between and among cervids is disclosed in the CWD literature technical report (Johnson, 2014, Appendix 7 of the FSEIS).
158. Comment: Friday, November 16, 2012 Yellowstone elk herds feeding grounds, or future killing grounds from CWD http://chronic-wasting-disease.blogspot.com/2012/11/yellowstone-elk-herds-feeding-grounds.html. Response: This blog post includes a rather lengthy series of clips from other blogs, websites, newspaper articles, and research articles about CWD in the Greater Yellowstone Area. Some of these clips are direct quotes from other commenters (Greater Yellowstone Coalition and Earth Justice) or from other federal or state agencies. The issues raised in these 'sub-comments' have been discussed and disclosed in the CWD literature technical report (Johnson, 2014, Appendix 7 of the FSEIS).
159. Comment: Animal and Plant Health Inspection Service, USDA. 2012. See www.aphis.usda.gov/animal_health/animal_diseases/csd/wild-cwd Viewed May 4, 2012. Response: The Bridger-Teton has worked extensively with Dr. Tom Gidlewski of APHIS in Fort Collins, CO from November 2013 to August 2014 with regard to the generation of the CWD literature technical report and other facets of the present analysis. This collaboration was aimed at ensuring that the CWD literature technical report (also referred to as Johnson, 2014, Appendix 7 of the FSEIS) has been approved by Dr. Gidlewski as a current, relevant, accurate and impartial disclosure of the state of the literature with regard to CWD and elk (email dated 7/11/2014).
160. Comment: Billings gazette. 2011. Wyoming Game and Fish Tests For Chronic Wasting Disease. Feb 25, 2011. Available at http://billingsgazette.com/news/state-and-regional/wyoming/wyoming-gameand- fish-tests-for-chronic-wasting-disease/article_8609ca5d-0450-5b5e-b8b6- 4907ea837cde.html viewed 5-27-13. Response: This newspaper article is about testing for CWD; the testing for CWD is not part of the proposed action.
161. Comment: Chronic Wasting Disease Alliance. 2012. www.cwd-info.org/ Sections “Baiting and Feeding” and “Meetings and Symposia”. Viewed 5-15-12. Response: The three articles listed at this website (http://www.cwd-info.org/index.php/fuseaction/resources.baiting) pertain to CWD and artificial congregation of susceptible cervids. The CWD literature technical report (Johnson, 2014, Appendix 7 of the FSEIS), which can be found in the project record, discusses the consequences of artificial congregation of cervids and the potential introduction and spread of CWD.
162. Comment: Donohue, Debra L. 2010. Trampling The Public Trust, section III Elk Feedgrounds and Wildlife Disease. University of Wyoming College of Law. Laramie, WY. Response: The effects of congregating elk are disclosed in both the CWD literature technical report (Johnson, 2014, Appendix 7 of the FSEIS) for CWD and in the FSEIS for other diseases.
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163. Comment: Dunkley, L. M.R.L. Cattet. 2003. A Comprehensive Review of the Ecological and Social Effects of Artificial Feeding and Baiting of Wildlife. Canadian Cooperative Wildlife Health Centre. University of Saskatchewan. Saskatoon, Saskatchewan, Canada. Response: The effects of congregating elk are disclosed in the CWD literature technical report (Johnson, 2014, Appendix 7) for CWD and in the FSEIS for other diseases.
164. Comment: 12. Greater Yellowstone Coalition. 2012. Materials (including CWD map, expert reports, forage reports, etc.) on website at Elk Feedgrounds. At www.greateryellowstone.org/issues/wildlife. Response: The information on this website is contained and addressed in various comments from the GYC letter (CARA letter 450); a map from CWD-info.org is included in the CWD literature technical report (Johnson, 2014, Appendix 7 of the FSEIS).
165. Comment: 20. Smith, Bruce L. 2005. Disease and Winter Feeding of Elk and Bison: A Review and Recommendations Pertinent to the Jackson Bison and Elk Management Plan and Environmental Impact Statement. Response: The potential role of feedgrounds in disease arrival and spread is disclosed in the CWD literature technical report (Johnson, 2014, Appendix 7 in the FSEIS). This document discusses what is known about the role that mammalian and avian scavengers and predators may play in the disease dynamics of CWD.
166. Comment: 21. Smith, Bruce L. 2012 Where Elk Roam: Conservation and Biopolitics of Our National Elk Herd. Response: Both the roles of prevalence and predators are addressed in associated parts of the FSEIS and in the CWD literature technical report (Johnson, 2014, Appendix 7 of the FSEIS).
167. Comment: Discuss the density of elk and the feedgrounds and its relationship to the spread of CWD. Response: The CWD literature technical report (Johnson, 2014, Appendix 7 of the FSEIS) calculates, discloses, and discusses the density of elk at feedgrounds. See Table 1 of that document.
168. Comment: USDA-Animal and Plant Health Inspection Service (APHIS). 2012. Review of Wyoming Brucellosis Management Plan. Gary Brickler, Team Leader. Cheyenne, WY. Response: The CWD literature review technical report (Johnson 2014, Appendix 7 of the FSEIS) has been reviewed and approved by Dr. Tom Gidlewski of APHIS as an up-to-date and accurate description of the interaction of CWD and elk feedgrounds.
169. Comment: Van Deelen, T. R. 2003. Chronic Wasting disease and the Science in support of the Ban on Baiting and Feeding Deer. Wisconsin DNR Research. Madison, WI. Response: The fact that most literature agrees that artificially concentrating animals increases the chances of disease transmission is discussed extensively in the CWD literature technical report (Johnson, 2014, Appendix 7 of the FSEIS).
170. Comment: Wild Margaret A., Hobbs, T., Graham, M., Miller, M. (2011) The role of predation in disease control: A comparison of selective and nonselective removal on prion disease dynamics in deer.
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Response: This journal article is used and cited in the CWD literature technical report (Johnson, 2014, Appendix 7 in the FSEIS).
171. Comment: Williamson, Scott J. Unk year. Feeding Wildlife . . . Just Say No! Wildlife Management Institute. Response: These concepts are reviewed and discussed in the CWD literature technical report (Johnson, 2014, Appendix 7 in the FSEIS).
172. Comment: Bruce L. Smith, in his 2012 book, Where Elk Roam, warns us of the danger of concentrating elk on feed grounds, because of two serious diseases: brucellosis and chronic wasting disease (CWD). Noting that Wisconsin has spent $27 million depopulating its whitetail deer to curb CWD (and no CWD has been detected where wolves live), he traces the inexorable march of CWD across Wyoming. “Recent modeling suggests wolf predation may suppress CWD emergence in deer.” Wolves and other large carnivores are essential to the health of the ecosystems on which our game animals and we depend. Wolves have been shown to be capable of reducing or eliminating the spread of brucellosis and chronic wasting disease (Hobbs 2006, Wild et al 2011), in part by reducing density and group sizes of elk and deer. Wild et al concluded, “We suggest that as CWD distribution and wolf range overlap in the future, wolf predation may suppress disease emergence or limit prevalence.” Cross et al (2010) wrote, “(T)he data suggest that enhanced elk-to-elk transmission in free-ranging populations may be occurring due to larger winter elk aggregations. Elk populations inside and outside of the GYE that traditionally did not maintain brucellosis may now be at risk due to recent population increases.” Response: The Forest Service reviewed the references you provided and agree that the research is applicable to this project. Please see page 92, 108-111, 114-116, 129-130 and 134 in FSEIS for the discussion of the effects of feedgrounds on wolves and the effects of wolves on elk disease.
173. Comment: Prohibit S-19 vaccinations of elk Our May 2012 scoping comments apply here as well. Strain 19 vaccinations of elk against brucellosis are not effective. The WGFD has suspected this since brucellosis seroprevalence in elk on the Greys River feedground increased around the year 2000 despite their having vaccinated elk there since 1985. The data is now conclusive. "Brucellosis seroprevalence data from Dell Creek and Grey's River feedground elk indicate no significant difference, no downward trend . . ." (WGFD 2011) The WGFD has never vaccinated elk at Dell Creek, they've vaccinated at Grey's River since 1985, and data shows no statistically significant difference in seroprevalence between the two after 27 years. “(F)eedgrounds provide the only opportunity to effectively vaccinate elk . . . “ (DEIS 2008: Appended: Elk Feedgrounds in Wyoming [WGFD 2004] page 10). Obviously the WGFD uses the excuse- and the BTNF has allowed them to do so- that it’s easier to vaccinate elk as one of the reasons to have feedgrounds. The elk are clustered together and easy to shoot with a biobullet. Yet, now, the WGFD admits that the Stain 19 vaccine isn’t effective. Therefore, the BTNF should not enable a harmful practice on USFS land, densely concentrated elk feedgrounds, to take place since the reasons for feedgrounds, including keeping elk away from livestock and vaccinating elk against brucellosis are no longer purposeful. The livestock in the Gros Ventre Valley can do just fine on private lands behind elk-proof fences and the vaccination program isn’t effective. Indeed the elk contract and maintain brucellosis by being densely concentrated and have lower seroprevalence in western Wyoming when allowed to free range. Therefore feedgrounds are clearly not needed. The BTNF must consider this
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Response to Comments information in new SEIS and make a reasonable decision based on the best available science. (GYC Scoping comments May 2012: 22-23) The appended 2004 WGFD Elk Feedgrounds in Wyoming claims, "The strain 19 vaccine is designed to prevent abortion, but not infection by field strain Brucella. . . . . Even though the strain 19 vaccine is not 100% effective, vaccinating all the calves over several years develops a "herd immunity", which is effectively higher than a single year's 30% efficacy." (page 16) The WGFD is being less than forthcoming about the intended goal of their strain 19 vaccination program because the only field indicator that infectious abortions are actually reduced in feedground elk as a result of their vaccination program is to do serology on successive generations of elk over the years to see if a lowering of seroprevalence has indeed occurred and if it may be attributable to their decades-long vaccination program. As is very explicitly indicated in their own 2011 assessment of their own program above, there is no lowering of the seroprevalence for exposure to brucellosis in feedground elk vaccinated with strain 19 and therefore infectious abortions must not have been reduced. Therefore, after 27 years, the program is ineffective. Given that the S-19 Vaccination program necessitates clustering elk together for weeks, at least, during winter and shooting them with a biobullet with live infectious bacteria inside, the BTNF must not allow this program to occur on USFS land. Response: The Forest Service recognizes the Wyoming Game and Fish Commission (WGFC) as the agency with the authority, jurisdiction, and responsibility to manage, control, and regulate fish and wildlife populations on NFS lands unless federal law specifically supersedes such authority. WGFC's decision to test the efficacy of Strain 19 vaccinations on NFS lands is within their jurisdiction.
174. Comment: Yet another error in the last paragraph quoted from page 150 in the DSEIS, is that the BTNF appears to confuse the “spread” of a disease with a critical element when discussing diseases, the level of infection within a given populations, or “prevalence”, of the disease. While the discovery of a single new infected individual in a geography not previously known for any infection can amount to a spreading of the disease in a geographic context and may occur in a timeframe affected by many geophysical, anthropogenic and ecological variables, the number of infected individuals at a given time within the population is of the utmost concern among scientists and wildlife professionals (with the possible exception of the WGFD or the USFWS at the Elk Refuge). Which is why, as we note in these comments when we refer to CWD experts, virtually every expert and expert panel in North America recommends not to densely concentrate cervids. Most experts recognize that the geographic spread of CWD in the Colorado and Wyoming areas may be inevitable, but all experts counsel to mitigate the transmissibility and rate of the infection using the best known method available: don’t feed or bait in order to allow cervids to disperse in natural densities rather than higher artificial densities. The BTNF repeats this mistake many times in this DSEIS. Their assertion that their actions- no matter what decision they make have no effect on the “rate of spread of disease” is less than forthcoming to the public. The Alkali Creek area is closer to Jackson Hole and the Elk Refuge than the other two elk feedgrounds in the Gros Ventre Valley, and is some four miles or more distant from the next elk feedground to the east. If elk are not densely concentrated at Alkali Creek, and the elk are allowed to spread out naturally, it may allow more elk to free-range in natural densities and act to suppress the prevalence of the disease in elk and other cervids in that area compared to what could happen if densely crowded feeding was maintained at Alkali Creek. Again, the DSEIS misleadingly says, “feeding would continue” but there is no evidence of the WGFD planning to operate an elk feedground anywhere else in the Alkali Creek area.
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Therefore not permitting a feedground at Alkali Creek may be beneficial. Response: The Forest Service agrees with the commenter that the dense concentration of elk at feedgrounds would increase the prevalence, transmissibility, and rate of infection of CWD. The Forest Service does not agree with the commenter's assertion that elk would spread out naturally if they were not fed at Alkali Creek Feedground. The Forest Service predicts that, in the event of the closure of Alkali Creek Feedground, elk that have been conditioned to spend the winter at feedgrounds would choose to congregate at other nearby feedgrounds (Patrol Cabin, Fish Creek, or the National Elk Refuge) instead of dispersing and wintering on natural forage. With the presence of wolves in the area, it is likely that densities of elk would remain high as elk move through the drainage to other feedgrounds.
175. Comment: Diagnostic accuracy of rectal mucosa biopsy testing for chronic wasting disease within white-tailed deer (Odocoileus virginianus) herds in North America...The overall diagnostic specificity was 99.8%. Selective use of antemortem rectal biopsy sample testing would provide valuable information during disease investigations of CWD-suspect deer herds. http://chronic-wasting-disease.blogspot.com/2012/08/diagnostic-accuracy-of-rectal-mucosa.html Tuesday, April 09, 2013 EFFICACY OF ANTEMORTEM RECTAL BIOPSIES TO DIAGNOSE AND ESTIMATE PREVALENCE OF CHRONIC WASTING DISEASE IN FREE-RANGING COW ELK (CERVUS ELAPHUS NELSONI) http://chronic-wasting-disease.blogspot.com/2013/04/efficacy-of-antemortem-rectal-biopsies.html. Response: As requested, we generated a Literature Review Technical Report (hereafter Johnson, 2014) in order to use and disclose relevant research regarding CWD and elk for the present analysis. Johnson (2014) is included in the FSEIS as Appendix 7. This report reviewed all literature that was relevant to CWD and supplemental elk feeding in western Wyoming and elk in the West in general. The review and synthesis of this literature was conducted by Tyler D. Johnson of the Bridger-Teton National Forest and was reviewed and determined to be current, relevant, accurate, and impartial by CWD expert Dr. Tom Gidlewski of the USDA Animal Plant Health Inspection Service in Fort Collins, CO. The correspondence regarding communication between the Forest Service and Dr. Gidlewski is a part of the project record. With regard to the density of elk, the commenter is correct that the densities of elk in the study group are similar to those that use Alkali Creek Feedground. Table 1 in Johnson (2014) shows the herd densities associated with various studies of free-ranging and artificially congregated elk that exist in the literature, including the herd mentioned in this comment. The exact journal article mentioned in this comment was not included in Johnson (2014), there were far more germane and recent journal articles by the same author (Monello, 2014) that discuss the exact herd in this comment. Including the specific paper mentioned in this comment would have added nothing to the review. The relevant journal articles are included in Johnson (2014). Johnson (2014) discusses the interaction of herd densities, artificial congregation, and CWD transmission at length and discusses population level impacts that may result from CWD arrival and spread at the Wyoming feedgrounds. Below is the abstract from Johnson (2014). Chronic wasting disease is an invariably fatal prion disease of cervids. There has been a recent increase in studies regarding the transmission and impacts of CWD in free-ranging and artificially contained elk and deer. Research indicates that CWD is easily transmitted between and among cervid species, can contaminate the environment and subsequently infect new individuals, and can impact cervid
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Response to Comments populations. Population level impacts have been noted in free-ranging elk and deer after a time lag. Such population level impacts arise from alterations in reproduction rates, increases in individual mortality from CWD, and increased susceptibility to other agents of mortality. CWD is lethal across all age groups. Management options for controlling CWD arrival and spread are very limited, and a review of relevant literature indicates that congregating elk at very high densities at feedgrounds is likely to increase the spread of the disease because of an increased number and rate of potentially infectious contacts with infected individuals and an infected environment.
176. Comment: The accompanying paper is Efficacy of Antemortem Rectal Biopsies to Diagnose and Estimate Prevalence of Chronic Wasting Disease in Free-Ranging Cow Elk (Cervus elaphus nelson), published in the Journal of Wildlife Diseases, 49(2), 2013, page 270-278. Authors are: Ryan J. Monello (National Park Service, Biological Resource Management Division), JG Powers (NPS), NT Hobbs (Colorado State University, Natural Resource Ecology Laboratory and Graduate Degree Program in Ecology), TR Spraker (Colorado State University, Diagnostic Laboratory, College of Veterinary Medicine), KI O'Rourke (USDA, Ag Research Service, Animal Disease Research Unit, Washington State University currently at: Department of Veterinary Microbiology and Pathology, School of Veterinary Medicine, Washington State University), and MA Wild (NPS, biological Resource Management Division). This paper, published in April 2013, is important to accept and include as addenda because the BTNF errs in the DSEIS when it dismisses actual or predicted declines in free-ranging herds of cervids from CWD (DSEIS: 97 and elsewhere). We offered comments about this significant deficiency in the DSEIS in our June 3, 2013, comments at page 16-19 and elsewhere. This paper by Monello, et al, about free-ranging elk in Rocky Mountain National Park (RMNP), states in part: "(T)he prevalence of CWD in our study population is disconcerting because more than a quarter of the adult female elk sampled were infected with PrPcwd over 3 year and elk dynamics are particularly sensitive to changes in female survival (Nelson and Peek, 1982; Raithel et al., 2007; Sargeant et al., 2011)." (page 276) The authors also state, "Finally, our results demonstrate that high-density elk populations (10-100 elk/km2) can support relatively high rates of CWD (>10% prevalence) that may substantially affect the dynamics of such populations." (page 277) In the DSEIS the BTNF maintains that "Since 1998, wolf activity has influenced elk distribution in the Gros Ventre, resulting in elk aggregating into one large group of up to 3,221 animals." (DSEIS: 4) This aggregation is on an elk feedground. The authors of the RMNP study determined that "high---density" elk populations are those ranging from 10---100 elk per square kilometer. The authors of the RMNP study expressed their concern that endemic CWD In such densities of elk (10---100 Elk per square kilometer) could result in impacts to elk populations. If The Alkali Creek Feedground is 91 acres, and as many as 3,221 Elk attend that acreage to use hay distributed daily during the winter by the WGFD, That density of elk would equate to 35 Elk per acre. Since there are 247.11 Acres in a square kilometer, such numbers could equate to an elk density of 8,648 Elk per square kilometer. Even If only 900 Elk attend the 91---acre Alkali Creek Feedground during winter, the density per acre would be slightly less than 10 Elk per acre if they were equally distributed throughout. Again, In comparison to the RMNP Determination of "high---density" Elk herds being 10 --- 100 Elk per square kilometer, at 10 Elk per acre and 247 Acres per square kilometer, that would equate to a density of 2,470 Elk per square kilometer if 900 Elk attended Alkali Creek. Obviously The densities on Wyoming's Elk feedgrounds, including those elk feedgrounds on USFS land, are far greater by several orders of magnitude for all the months the elk
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Response to Comments are fed than those densities that caused concern for the researchers in RMNPAGE In This DSEIS The BTNF Must consider all relevant research including the latest research published in April 2013. Please Let us know of any questions you have regarding this addendum to our June 3, 2013 comments. [467-1] Response [Seq#208]: As requested, we generated a Literature Review Technical Report (hereafter Johnson 2014) in order to use and disclose relevant research regarding CWD and elk for the present analysis. Johnson (2014) is included in the FSEIS as Appendix 7. This report reviewed all literature that was relevant to CWD and supplemental elk feeding in western Wyoming and elk in the West in general. The review and synthesis of this literature was conducted by Tyler D. Johnson of the Bridger-Teton National Forest and was reviewed and determined to be current, relevant, accurate, and impartial by CWD expert Dr. Tom Gidlewski of the USDA Animal Plant Health Inspection Service in Fort Collins, CO. The correspondence regarding communication between the Forest Service and Dr. Gidlewski is a part of the project record. With regard to the density of elk, the commenter is correct that the densities of elk in the study group are similar to those that use Alkali Creek Feedground. Table 1 in Johnson (2014) shows the herd densities associated with various studies of free-ranging and artificially congregated elk that exist in the literature, including the herd mentioned in this comment. The exact journal article mentioned in this comment was not included in Johnson (2014), there were far more germane and recent journal articles by the same author (Monello, 2014) that discuss the exact herd in this comment. Including the specific paper mentioned in this comment would have added nothing to the review. The relevant journal articles are included in Johnson (2014). Johnson (2014) discusses the interaction of herd densities, artificial congregation, and CWD transmission at length and discusses population level impacts that may result from CWD arrival and spread at the Wyoming feedgrounds. Below is the abstract from Johnson (2014). Abstract: Chronic wasting disease is an invariably fatal prion disease of cervids. There has been a recent increase in studies regarding the transmission and impacts of CWD in free-ranging and artificially contained elk and deer. Research indicates that CWD is easily transmitted between and among cervid species, can contaminate the environment and subsequently infect new individuals, and can impact cervid populations. Population level impacts have been noted in free-ranging elk and deer after a time lag. Such population level impacts arise from alterations in reproduction rates, increases in individual mortality from CWD, and increased susceptibility to other agents of mortality. CWD is lethal across all age groups. Management options for controlling CWD arrival and spread are very limited, and a review of relevant literature indicates that congregating elk at very high densities at feedgrounds is likely to increase the spread of the disease because of an increased number and rate of potentially infectious contacts with infected individuals and an infected environment.
177. Comment: I am concerned that feeding the wild elk so close to Yellowstone may make the herds at Yellowstone sick with Chronic Wasting Disease (CWD) please try to avoid any cross contamination by maybe feeding the elk somewhere else not so close to Yellowstone? I would hate for you to stop feeding the wild elk just maybe feed them elsewhere. Response: Feedgrounds on National Forest System (NFS) lands are operated by Wyoming Fish and Game Commission, not the Forest Service. In this project, it is within WGFC's jurisdiction to decide whether or
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Response to Comments not to feed elk in western Wyoming and it is within the Forest Service's jurisdiction to decide whether or not to authorize the use of NFS lands for feedground purposes. The Jackson elk herd's entire range is within the Yellowstone Ecosystem and some of these elk spend their summers in Yellowstone National Park. Therefore, anywhere that they could be fed within their range would be "close to Yellowstone". Support for Alternative 1 – No Action 178. Comment: Alternative 1 is preferred in that it promotes a healthy ecosystem for the Gros Ventre drainage and the Gros Ventre Wilderness. It also would provide an opportunity to see if after one hundred plus years of artificial feeding that elk could winter successfully in the Gros Ventre drainage by natural methods. Under your own analysis, general vegetation will improve under Alternative 1. “Ground cover would increase, vegetation diversity and shrub density would increase, and there would be fewer introductions of noxious weeds and invasive plants in the project area.” Under your own analysis, wetlands and riparian areas condition will improve with improvement in water quality. With less concentration of elk, stream channel conditions and elevated sediment levels will improve over time. From what your analysis shows is that habitat quality will improve and provide a natural setting for elk and other species. By not concentrating elk onto an artificial feedground, the chance of disease transmission will be less a problem and hopefully will improve the health of the elk herd. The Gros Ventre drainage is prime winter range. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
179. Comment: The elk need to find their food naturally. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
180. Comment: Continuing to feed elk in an unnatural way can easily lead to the spread of disease. Please do not approve permit to allow this practice. people should see Elk in their natural state and this feeding creates an unnatural situation. These animals are wild and need to remain wild for their health and survival. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
181. Comment: I understand that the feeding of elk may contribute to the spread of chronic wasting disease because of the animals' close proximity to each other at the feeding grounds. I urge that this practice be discontinued immediately! Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest
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Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
182. Comment: It is time to finally draw a line in the sagebrush and say no to the unnatural feeding of elk in western Wyoming, starting at a place called Alkali Creek. The unnaturally dense concentrations of elk at such feedgrounds have resulted in diseased animals, ravaged habitat and the prospect of a CWD disaster moving inexorably closer to the famed herds in Yellowstone National Park and Jackson Hole. As America's Voice for a Greater Yellowstone, we can restore and preserve healthy herds by phasing out these feedgrounds and allowing elk to roam free. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
183. Comment: Please do not order a new 20 year permit for feeding elk at Alkali Creek. Allow the elk to roam free. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
184. Comment: Wyoming Game and Fish is an organization run by people who have no clue as to what balance should be in an ecosystem. They pander to special interests to the detriment of ALL Wyoming wildlife! There is always the question why the most unqualified people are put into these critical positions and here it is again! It would be different if there was a reliance on science, but, there is none of that. Just knee jerking for hunters and ranchers. This is shameful, dangerous and just plain stupid! Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
185. Comment: Please do not approve the new permit for the feeding of elk at Alkali Creek. The re-permitting of this obsolete elk feed ground in the Gros Ventre will allow for the spread of CWD, which must be stopped before it reaches Yellowstone National Park. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
186. Comment: It’s time to end feedgrounds on U.S. Forest Service land — starting at Alkali Creek. Chronic Wasting Disease is only 35 miles to the east of the Gros Ventre watershed. Allow elk to roam on
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Response to Comments expansive natural winter ranges in the Gros Ventre Valley. Bridger-Teton National Forest should not permit the Wyoming Game & Fish Commission to operate an elk feedground at Alkali Creek beyond the winter of 2013-14. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
187. Comment: Do not feed wild elk. This causes more problems than it solves. Allow nature to take its course and allow numbers to fall so that the herds are more sustainable with their environment. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
188. Comment: People shouldn't feed elks. They are already taken care of by people whose job this is. Feeding elks can have a negative impact on them. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
189. Comment: Don't make elk a semi-domesticated animal. Extend their range and the range of their natural predators to keep the herds healthy. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
190. Comment: Help keep Elk herds healthier by denying the unnatural feeding practice at Alkali Creek. Overpopulation of any species should always be prevented and respecting their natural inclinations is always a wiser choice to keep the balance on the environment. Stopping these feedings will help prevent the transmission of Chronic Waste Disease creating a better outcome. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
191. Comment: Wild animals need to find their own food. It's safer for them. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
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192. Comment: As we strive to enrich our environment, it is important to restore the natural environment and natural habitats in which our wildlife can thrive. We seem to have restored a balance in the grizzly bear population by forcing them to find their own food. The same needs to be done for the elk in the Greater Yellowstone and Bridger Teton areas. It is time to phase out the feeding of wild elk and the place to begin is at Alkali Creek. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
193. Comment: Feeding grounds for wild Elk only create problems such as too many Elk converging on too small of areas, spread of chronic wasting disease and other illnesses, and damage to the local eco system. Healthy Elk herds need to graze and migrate through multiple feeding grounds, not congregate and become dependent on feed provided by people. It is past time to stop the feeding schemes at Alkali and others in and around Bridger- Teton, and Yellowstone. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
194. Comment: Feeding elk makes them gather unnaturally closely, facilitating disease transmission. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
195. Comment: The elk in Yellowstone are healthy, and those in Montana should not be encouraged to be near them. Montana should be allowing their elk to be wild, and provide ample habitat so they will be wild and healthy. They are not domestic cattle.
Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
196. Comment: Protect the wild elk and moose that still live in the wild. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
197. Comment: Please stop taking chances with wild elk. Stop the unnatural feeding that causes them to congregate in unnatural densities of population near the feeding stations. This can lead to outbreaks of Chronic Wasting Disease which could wipe out the entire population of elk in these regions.
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Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
198. Comment: It is sad when animals die. However, the unnatural feeding of the elk isn't going to be saving them and instead will increase the likelihood of disease and a slow death due to overcrowding in the feeding areas. Also, if the weakest of the animals are artificially sustained through this feeding program, it weakens the whole herd. More environmentally sensitive actions must be taken into account. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
199. Comment: It is time to finally draw a line in the sagebrush and say no to the unnatural feeding of elk in western Wyoming, starting at a place called Alkali Creek. As you are considering a new 20-year permit for feeding elk at Alkali Creek, I wish to state my opposition to this idea! The unnaturally dense concentrations of elk at such feedgrounds have resulted in diseased animals, ravaged habitat and the prospect of a CWD disaster moving inexorably closer to the famed herds in Yellowstone National Park and Jackson Hole. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
200. Comment: Having read about the situation it seems prudent to enforce a ban on artificial feeding elk in order to save them. While it may have seemed fine to feed them it is not in their best interest and not in the interest of their environment either. Chronic wasting disease is a mere 35 miles away. Considering the location this should be an area where they are not made dependent of feedlots. The Bridger-Teton should act responsibly to prevent more wasting disease and work towards keeping the elk healthy by managing natural resources and allowing elk to roam freely and eat as elk do in the wild. Please do not let Wyoming Game and Fish to run the feedlot beyond the winter of 2013-2104. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
201. Comment: I strongly oppose the re-permitting of the obsolete feedgrounds in the Gros Ventre's Alkali Creek area . Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section
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Response to Comments on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
202. Comment: Stop what is not natural to earth! Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
203. Comment: After more than a half-century of artificial winter feeding of elk, it’s time to end feedgrounds on U.S. Forest Service land — starting at Alkali Creek. Habitat and wildlife have suffered from the practice of artificially concentrating and feeding elk. An endemic area of deadly Chronic Wasting Disease is only 35 miles to the east of the Gros Ventre watershed. Scientists agree that should CWD arrive on elk feedgrounds it could be a disaster for our elk herds. The Gros Ventre Valley is at the geographic center of the 20-million-acre Greater Yellowstone Ecosystem, where 80 percent of ownership is federal public lands, including national parks and forests. This should be an area where wildlife is not artificially lured to feedlots. The Bridger-Teton should exercise its responsibility to manage for healthy natural resources and allow elk to roam on expansive natural winter ranges in the Gros Ventre Valley. The forest should not permit the Wyoming Game & Fish Commission to operate an elk feedground at Alkali Creek beyond the winter of 2013-14.
Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
204. Comment: I'm concerned about feeding grounds at Alkali Creek, a US Forest Service area. Artificial feeding sounds humane, but habitat and wildlife have suffered from it. An area of Chronic Wasting Disease is only 35 miles to the east of the Gros Ventre watershed. If CWD arrives on elk feeding grounds, it could be a disaster for the herds. Gros Ventre Valley is at the center of the Greater Yellowstone Ecosystem, where 80 percent of the land is under federal ownership. Wildlife should not be lured to artificial feedlots in this area. I urge Bridger-Teton to manage for healthy natural resources and let elk roam on natural winter ranges in the Gros Ventre Valley. Please do not allow the Wyoming Game & Fish Commission to operate an elk feedground at Alkali Creek beyond the winter of 2013-14. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
205. Comment: The Bridger-Teton should exercise its responsibility to manage for healthy natural resources and allow elk to roam on expansive natural winter ranges in the Gros Ventre Valley. The forest should not permit the Wyoming Game & Fish Commission to operate an elk feedground at Alkali Creek
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Response to Comments beyond the winter of 2013-14. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
206. Comment: Please stop mass feeding of the elk in the Jackson Hole area. Chronic wasting disease and numerous other health issues are created in this artificial environment. Please revert back to natural feeding and behavior for this elk population. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
207. Comment: Please do not renew the permit to feed elk at Alkali Creek; it doesn't make sense to feed them since that can lead to diseased animals. It makes more sense to get rid of this feedground and allow the elk to roam free. Thank you for considering my comments. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
208. Comment: feeding the elk creates concentrations of animals and spread of disease as a consequence. Please let the elk find their own food and maintain their health. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
209. Comment: This "unnatural" feeding brings elk together in concentrations that would not normally be found without this artificial feeding. That can significantly increase the spread of disease. It is just like in National Parks where we are always told not to feed the animals as it is not healthy for them. Please do not continue the feeding at Alkali Creek. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
210. Comment: Please phase out feeding grounds and allow the elk to roam free. Response Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
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211. Comment: I do not think it makes a whole lot of sense to feed wild elk near a water way. Wild elk have grazing pastures across several states. They have foraged for food for generations. To feed these wild animals is to interrupt their feeding patterns and jeopardize their future ability to sustain themselves off the land in the wild. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
212. Comment: Please stop the unnatural feeding of elk in western Wyoming, starting at a place called Alkali Creek. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
213. Comment: It has been proven absolutely that people who live in or live close to green spaces are happier... After all is said and done all human beings are animals and need to interact with nature . Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
214. Comment: I was not aware of this problem. It is a must for this Alkali Feed Ground to be free of having these elk be fed. If they are breeding disease and such, it is sensible to allow these elk to roam free. It is unnatural to feed them and without these feed grounds, the herds will be healthier. Please be responsible and let these herds do what they are naturally supposed to do and not rely on being fed . Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
215. Comment: I am opposed to the re-permitting of the obsolete elk feedground in the Gros Ventre. Let them just feed naturally. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
216. Comment: You can stop the progression of Chronic Wasting Disease by suspending the concentrated feeding of elk. Chronic Wasting Disease is only 35 miles to the east of the Gros Ventre watershed. The Bridger-Teton should exercise its responsibility to manage for healthy natural resources and allow elk to roam on expansive natural winter ranges in the Gros Ventre Valley. The forest should
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Response to Comments not permit the Wyoming Game & Fish Commission to operate an elk feedground at Alkali Creek beyond the winter of 2013-14. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
217. Comment: I love elk, as does everyone. However, I think chronic wasting disease is real, and it is on the march westward. When it hits feed grounds (state and national) it will spread like wildfire, and of course there is no cure. I realize not feeding elk in winter will cause a decrease in the elk herd, but it is a price to be paid to avoid a catastrophic decline from disease. I know many elk will starve, a least initially until herd size drops. But it is the only way to disperse elk, and end feeding grounds. At least many predators and carrion eaters will benefit. I am sad for hunters, outfitters, wildlife viewers who oppose closing feed grounds; they too love huge herds, but it is time to end artificial feeding. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
218. Comment: Chronic wasting disease could decimate elk populations - stop feeding the elk at Alkali Creek. I have been on week-long backpacks in the Bridger-Teton NF several times and consider it one of my favorite wilderness areas. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
219. Comment: Thank you for taking my comments. Deadly disease could be prevented for elk, deer, and other wildlife by opposing repermitting feedground and allowing elk to roam free. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
220. Comment: Please, stop the unnatural feeding of elk! It is only hurting them, not helping them. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
221. Comment: Please stop treating the wild elk as if they were farmed livestock. Maybe feed lots would be more effective. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest
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Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
222. Comment: Please discontinue the practice of feeding elk. It increases the potential transmission of diseases such as CWD and TB. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
223. Comment: Feeding elk and killing wolves. How insane! Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
224. Comment: When there is an epidemic, people or animals should not collect in groups. This elk feeding is collecting a lot of elk together at Alkali Creek, and is helping to spread the epidemic. Please end this feeding program now, and let the elk spread out in a more natural way as they feed themselves. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
225. Comment: Please follow the recommendations not to feed the elk and let the disease die out before it causes further problems for the wildlife that we should try to preserve. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
226. Comment: I feel that artificial feeding of elk invites disease and discourages natural behavior. In the long run, this is not in the elk's best interest and threatens to spread disease to domestic animals. I would like to see this policy ended. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
227. Comment: Audubon is only the first wildlife organization alphabetically, that I belong to. As a retired national park ranger, I'm well aware of the political knot that keeps favoring wasting and other diseases. Still if enough of us keep the pressure on, eventually good things can happen, such as wolves. Please count this email in favor of suspending feed lot style "management."
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Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
228. Comment: Please help save the animals to propagate for future generations so that our grandchildren can actually see what elk look like instead of having to look at old books and old videos of extinct animals. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
229. Comment: The Bridger-Teton National Forest should not consider a new 20-year permit for feeding elk at Alkali Creek. The unnaturally dense concentrations of elk at such feedgrounds have resulted in diseased animals, ravaged habitat and the prospect of a CWD disaster moving inexorably closer to the famed herds in Yellowstone National Park and Jackson Hole. Please, stop feeding the elk at Alkali Creek! It's an unnecessary expense and makes the herd "unnatural". As America's Voice for a Greater Yellowstone, we can restore and preserve healthy herds by phasing out these feedgrounds and allowing elk to roam free. Let’s make Alkali Creek the first. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
230. Comment: Please work towards allowing Elk, deer, and other animals to roam more free and not have feeding grounds at all. Your part of game and fishing. Do you not converse with DNR's from Wisconsin, Illinois, Minnesota? Are you unaware of the horrible problems deer and turkey have had from common feeding grounds? We are not allowed to put food out for them even from our homes. I am really surprised and sad to see that this is even a question for debate. Please close feeding grounds and make our national parks work the way they should for animals to live like they are supposed to, and so we can observe and enjoy them in their natural habitat. Not grouped together trying to forage for food in a single area. Thanks. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
231. Comment: The ultimate betrayal...feed elk keeping herds high and then blasting them with gunfire come next fall. What a concept ...what a "sport". The feeding is artificial. These same mindsets want to slaughter wolves who would gladly keep down the elk numbers, removing the old or sick instead of the biggest antlered animals as is the case with human hunters. Just wondering what the reaction would be should animal defenders wish to feed wolves, bears and other animals who struggle to make it in
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Response to Comments nature? Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
232. Comment: Wyoming has proven to be such a poor steward of its natural wonder. Feeding wild Elk? Even I know that will play havoc with the habitat and the digestive systems of the animals. Can we have some professionalism on the part of your Game and Fish Commission Alkali Creek Feedground? [132-1] Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
233. Comment: Stop the unnatural feeding of wild elk. Mother Nature is really getting mad! Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
234. Comment: I would like to urge you to stop the feeding of wild elk. These animals should be left alone and wild. I thank you for your time and consideration. I am a MT resident on the border of Wyoming and frequently enter the WY area. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
235. Comment: Wyoming spends tax dollars feeding wild elk? Surely there is a better use for hard-earned dollars. Elk that congregate for 'the dole' are far more likely to contract 'wasting disease' than those animals closer to a natural selection process. Save the elk by saving money. It's that easy. Response [Seq#98]: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
236. Comment: Wild animals need to stay wild. Look at what happens after bears are fed unnaturally. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
237. Comment: Please to not allow feeding of wild elks and scrap the plan to do so. It will lead to chronic wasting disease and unnaturally high concentrations of the animals in one small area.
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Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
238. Comment: Stop feeding the elk that are infected and are carrying disease toward Yellowstone National Park. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
239. Comment: Please do the right thing to prevent the spread of Chronic Wasting Disease and cease feeding the animals in question. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
240. Comment: We need to protect all of our wild life mainly from us humans, so please we got to stop this feeding of wild elk. It will only endanger all the deer and elk and who knows what other wild animals. Please say no to the human feeding. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
241. Comment: Artificial feeding makes artificial animals that depend on an unnatural food source. I believe wildlife deserves better management, and elk should not be enticed into unhealthy concentrations. This concentration places the elk herd at high risk for disease. With chronic wasting disease getting closer to the Gros Ventre Valley, the Forest Service should reject the feedground concept and let elk disperse naturally. I can't imagine why any agency that manages wildlife would risk the loss of Wyoming elk to this deadly disease. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
242. Comment: Please phase out the elk winter feeding areas in the Gros Ventre area starting with the Alkali Creek feeding ground. Thanks for your support. I am a Greater Yellowstone Coalition member. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section
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Response to Comments on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
243. Comment: I live in Idaho and travel frequently to the Jackson Hole area as well as Star Valley, the Salt River Range, and the Wyoming Range mountains, for hiking. I am aware that the winter feeding of elk creates large congregations of the animals. This is spreading disease. Last year we even had the tragic killing of a grizzly in the National Park. It is time to stop this artificial feeding on U.S. Forest Service land — starting at Alkali Creek. There is great potential for Chronic Wasting Disease to spread to the Gros Ventre Valley. This could decimate the elk. Hunters certainly won't be happy about that. The USFS should allow elk to roam on expansive natural winter ranges in the Gros Ventre Valley. The forest should not permit the Wyoming Game & Fish Commission to operate an elk feedground at Alkali Creek beyond the winter of 2013-14. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
244. Comment: Please phase out feeding stations for elk. The unnatural concentrations lead to diseased herds.
Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
245. Comment: I oppose the re-permitting of this obsolete elk feedground in the Gros Ventre. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
246. Comment: We are killing bison/buffalo to keep elk for hunters and now to know you are trying to feed them for hunters too. HOW sick can this imbalance get before the balance of nature returns. Oh! And bring back the wolf to help too! OKAY! Back to ""sick"" elk and CWD (chronic wasting disease). As man has tried to balance their desires because of the 'hunt' they along with your/this agency - animals have suffered. END this long term trial of manipulation for the 'hunt' and return to a sane, really sane, policy for the preservation of all the species needed to balance their and our lives. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
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247. Comment: As a property owner in Island Park, Idaho, and visitor to Wyoming and Montana, I oppose Bridger-Teton National Forest renewing a new 20-year permit for feeding elk at Alkali Creek. It is an outdated practice and it is necessary to stop feeding wild elk in the Gros Ventre. The unnaturally dense concentrations of elk at such feedgrounds have resulted in diseased animals, ravaged habitat and the prospect of a Chronic Wasting Disease disaster moving closer to the famed herds in Yellowstone National Park and Jackson Hole. CWD also affects deer and other wildlife. It is an unnatural process and needs to be stopped. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
248. Comment: Ironically, the original intent of supplemental feeding may have been a bridge to increased numbers of elk in the northwest regions and national parks. However, with the dramatic increases of elk populations until the introduction of the northern gray wolf in 1995 and the continued regional herd numbers still exceeding objectives in almost all herd units, it should be clear that this artificial feeding and the continued presence of feedgrounds is no longer a necessity particularly in light of the fact that said feedgrounds concentrate animals in close proximity to each other. This crowding clearly fosters the transmission of a variety of diseases to include CWD and damages habitat that also adversely affects other wildlife. In this instance the permit to operate a feedground at Alkali Creek should not renewed for the 2013-2014 period. Thank you for your consideration of this comment. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
249. Comment: Please do not feed wild elk at Alkali Creek. Chronic wasting disease will spread from there. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
250. Comment: I am opposed to feeding projects that concentrate large numbers of wild elk and thus increase the risk of disease that can affect elk throughout Yellowstone. Response [Seq#98]: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
251. Comment: The Bridger-Teton should exercise its responsibility to manage for healthy natural resources and allow elk to roam on expansive natural winter ranges in the Gros Ventre Valley. The forest should not permit the Wyoming Game & Fish Commission to operate an elk feedground at Alkali Creek
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Response to Comments beyond the winter of 2013-14. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
252. Comment: Please stop feeding the elk herds and allow the balance of nature to predominate. This will result in healthier herds of elk. Stop killing the wolves and allow them to cull the herds of old, sick and deformed elk. You need to use scientific knowledge and common sense in Wyoming, instead of allowing these ecological issues to become far right-wing fodder. Do you see what climate change is doing? Yet, too many ignorant people with political agendas are running us into the ground. It is far past due to stop this kind of destructive and illogical behavior. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
253. Comment: Chronic Wasting Disease (CWD) -- a deadly disease for elk, deer, and other wildlife -- is marching toward Yellowstone, and we need your help to stop it. It is time to finally draw a line in the sagebrush and say no to the unnatural feeding of elk in western Wyoming, starting at a place called Alkali Creek. The Bridger-Teton National Forest will consider a new 20-year permit for feeding elk at Alkali Creek, and I must voice opposition to this idea! The unnaturally dense concentrations of elk at such feedgrounds have resulted in diseased animals, ravaged habitat and the prospect of a CWD disaster moving inexorably closer to the famed herds in Yellowstone National Park and Jackson Hole. Bridger-Teton National Forest- stop feeding wild elk at Alkali Creek! As America's Voice for a Greater Yellowstone, we can restore and preserve healthy herds by phasing out these feedgrounds and allowing elk to roam free. Let’s make Alkali Creek the first domino to fall! I oppose the re-permitting of this obsolete elk feedground in the Gros Ventre. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
254. Comment: I am writing to encourage you to end the feeding of elk on US Forest Service land. Concentrating the number of elk as is done when they are fed by humans in winter serves to expose large numbers of these magnificent animals to Chronic Wasting Disease. There is an endemic area of CWD just 35 miles away; scientists agree that if CWD should reach a concentrated group of animals it would be disastrous for elk in the Bridger-Teton Forest. The Bridger-Teton should exercise its responsibility to manage for healthy natural resources and allow elk to roam on expansive natural winter ranges in the Gros Ventre Valley. I urge that you not permit the Wyoming Game & Fish Commission to operate an elk feedground at Alkali Creek beyond the winter of 2013-14. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section
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Response to Comments on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
255. Comment: Please stop feeding the elk. Their population is dangerously inflated and disease is the inevitable result. Artificial feeding is keeping these elk unbalanced relative to the rest of the ecosystem. Thank you for your consideration. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
256. Comment: Sounds like you could use the assistance of some endangered species; the wolf, fully protected, fully respected, and fully capable of restoring the balance and health of your elk herd. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
257. Comment: Please do the right thing and restore and preserve healthy herds by phasing out feedgrounds and allowing elk to roam free. I oppose the re-permitting of this obsolete elk feedground in the Gros Ventre. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
258. Comment: Feeding sites are known to concentrate the elk and then diseases are easily spread. This is a very bad method. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
259. Comment: The unnaturally dense concentrations of elk at such feedgrounds have resulted in diseased animals, ravaged habitat and the prospect of a CWD disaster moving inexorably closer to the famed herds in Yellowstone National Park and Jackson Hole. Elk Feedgrounds Tell the Bridger-Teton National Forest to stop feeding wild elk at Alkali Creek! As America's Voice for a Greater Yellowstone, we can restore and preserve healthy herds by phasing out these feedgrounds and allowing elk to roam free. Let’s make Alkali Creek the first domino to fall! Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
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260. Comment: In my view, the Bridger-Teton should exercise its responsibility to manage for healthy natural resources and allow elk to roam on expansive natural winter ranges in the Gros Ventre Valley. After more than a half-century of artificial winter feeding of elk, it’s time to end feed grounds on U.S. Forest Service land. The unnaturally dense concentrations of elk at such feed grounds have resulted in diseased animals, ravaged habitat and the prospect of a Chronic Wasting Disease (CWD) disaster moving inexorably closer to the famed herds in Yellowstone National Park and Jackson Hole. The Forest Service should not permit the Wyoming Game & Fish Commission to operate an elk feed ground at Alkali Creek beyond the winter of 2013-14. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
261. Comment: Given the devastating impact of CWS on elk populations in Colorado every attempt should be made to avoid artificial concentrations of elk in Wyoming. It is simply a "no-brainer." It does not merit further discussion. Just stop it. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
262. Comment: It's long past time to do away with feeding wild animals of any kind over the winter months especially the vast elk herd that congregates just outside Jackson, Wyoming. It's unnatural and makes the animals prone to disease which is a well-known fact. Allow nature to takes its course, PLEASE, for the benefit of the elk and us! Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
263. Comment: Please protect our animals from unnatural diseases and deaths. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
264. Comment: Feeding wild life is not natural, especially if it is an area that is thriving. When disease takes over it will wipe out herds of elk, and when areas are so densely populated it depletes the food available for the herds. Do what is best for the elk and end the unnatural feeding. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
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265. Comment: Please begin to end elk feeding on U.S. Forest Service land — starting at Alkali Creek. Artificially concentrating and feeding elk isn't worth it considering CWD and various negative environmental repercussions. The Bridger-Teton should exercise its responsibility to manage for healthy natural resources and allow elk to roam on expansive natural winter ranges in the Gros Ventre Valley. Why hang on to this dinosaur, this completely old-school way of thinking about elk? The forest should not permit the Wyoming Game & Fish Commission to operate an elk feed lot at Alkali Creek beyond the winter of 2013-14. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
266. Comment: Please stop feeding the wild elk, I know it is a source of tourists for Jackson Hole, but it can cause the spread of disease. Jackson Hole is beautiful enough on its own hook for touristy, disease can cause lasting devastation to the herds and domestic cattle. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
267. Comment: Every sign on every national forest and park tells visitors to NOT feed the wildlife, yet Wyoming continually feeds elk. This is extremely deleterious because it unnaturally concentrates elk, greatly facilitating the spread of communicable diseases such as wasting disease. This practice needs to stop. It is not good for the elk and only serves to maintain an unnatural population size for hunters. Change your hunting permit system instead. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
268. Comment: The Elk feeding grounds in the Gros Ventre, did serve a purpose years ago, but times have changed. Wild and migrating elk, living adjacent to migrating herds in this area certainly causes health problems. We don't have CWD and we/hunters and residents certainly don't want to risk having it. Maybe a 1 year renewal or year by year until better alternatives can be found. The Bridger-Teton should exercise its responsibility to manage for healthy natural resources and allow elk to roam on expansive natural winter ranges in the Gros Ventre Valley. The forest should not permit the Wyoming Game & Fish Commission to operate an elk feedground at Alkali Creek beyond the winter of 2013-14. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
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269. Comment: Please stop feeding our wild Elk and other wildlife around the creek. We all must do something to stop the spread of disease. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
270. Comment: It is completely wrongheaded to be feeding elk in western Wyoming (starting at Alkali Creek) because the unnaturally dense concentrations of elk at such feeding grounds have resulted in diseased animals, ravaged habitat and the prospect of a CWD disaster moving inexorably closer to the herds in Yellowstone National Park and Jackson Hole. Such dense concentrations of elk also increase the possibility for the spread of Lyme disease in humans and should not be allowed to continue. Please reconsider this decision. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
271. Comment: We must do all we can to help save the critters that share the planet with us. Our careless and dangerous manufacturing and energy producing activities, as well as ignorance of how to properly offer assistance to wildlife are destroying the planet and the habitat for both animals and humans. We simply must take stock of the progressing climate change crisis as well as the depletion of our natural resources and stop this irrational and irresponsible mass production of newer, more "fashionable" forms of status and identity creating garments, automobiles, jewelry, houses, etc. We are destroying the Earth. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
272. Comment: Please stop feeding the wild elk the way you are doing it. The dense concentrations of animals promote the dangerous spread of Chronic Wasting Disease. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
273. Comment: You're creating a bad situation and the balance of Nature is being skewed again by human intervention. Leave the predators alone, allow the strongest to survive to ensure the survival of a strong elk population and stop bending over and kissing the arses of the ranchers and farmers who apparently slip enough money into the government hands to screw up everything up there. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section
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Response to Comments on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
274. Comment: I urge you to reconsider feeding elk on state feed grounds. There is adequate data that show that feed grounds lead to high concentrations of elk, which spread disease among themselves. Although feeding elk in the winter may seem like a sustainable action, it in fact is of detriment to our herds. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
275. Comment: While we applaud the efforts of Wyoming organizations to help elk and other wildlife out during brutal winters by operating and stocking feed lots, the time is right to bring nature back into balance and let natural order take its course. Artificially sustaining wildlife in a same place, same time, same feed inevitably leads to conditions that introduce diseases and promotes epidemic spread. Breaking bad habits should start now and, if situations occur, still leave room for occasional interventions under extreme conditions. Please stop the program before irreversible damage is done, if it hasn't been already. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
276. Comment: I am against any type of feeding of Elk by humans. Leave the elk alone to feed themselves. Your organization is promoting disease and dependence, an animal welfare state. Use the money to feed humans! Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
277. Comment: Please let these elk go back home. Maybe put some of the cattle grazing on BLM land there and feed them. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
278. Comment: Let nature take its course. Feeding the elk only prolongs the effects of this terrible disease. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section
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Response to Comments on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
279. Comment: Feeding elk is not only harmful to the elk themselves but also to the environment as a whole. Just look to the deer population in Wisconsin and the Midwest to see the devastation brought on by CWD. Let’s learn from other mistakes and allow nature to take care of its wildlife as it was created to do. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
280. Comment: Stop the unnatural feeding of any wild animals especially the elk at this juncture. We need to let our elk roam free and disease free. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
281. Comment: As we learn more we now know that to feed the elk is not helpful and is actually dangerous to this region.
Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
282. Comment: The Gros Ventre Valley is at the geographic center of the 20-million-acre Greater Yellowstone Ecosystem, where 80 percent of ownership is federal public lands, including national parks and forests. This should be an area where wildlife is not artificially lured to feedlots. The Bridger-Teton should exercise its responsibility to manage for healthy natural resources and allow elk to roam on expansive natural winter ranges in the Gros Ventre Valley. The forest should not permit the Wyoming Game & Fish Commission to operate an elk feedground at Alkali Creek beyond the winter of 2013-14. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
283. Comment: Please stop feeding the elk, you are changing the ecological system of both the area where the feeding occurs and the biological eco system of the elk themselves. It is time that common sense is used in dealing with nature and a time for stepping back and looking at past mistakes. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section
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Response to Comments on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
284. Comment: Feeding Elk in this way is not treating them like the wild animals they are. It is treating them like cattle which they were never supposed to be. Leave them alone and nature will take care of them. That is if they don't become so dependent on humans first, Nature provides. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
285. Comment: Please stop the use of feeding grounds. This is not a natural way for elk to feed. More importantly it could cause such destruction of elk herds. Please do not let them die from this terrible disease. They are awesome, majestic animals they do not deserve to die because of human error. I know you will do what is necessary to save their lives. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
286. Comment: As a concerned citizen, I participate in local and national issues and am especially concerned with human intrusion. This includes what superficially may appear as care, involvement, appreciation. But in reality amounts to great harm. Such is roads, bike paths or other intrusion into wilderness, diversion of natural water courses and touching or disturbing sea creatures in tidal pools. The feeding of animals, birds, reptiles and mammals may appear innocuous, but creates imbalance, dependency and weakening of herds/species. As stewards, caretakers, the best approach is to leave things alone unless there is evidence of prior tampering or impending decimation of what supports a healthy and balanced population. I urge greater thought on purpose and effect by the Alkali Feed ground with emphasis on "do no harm." Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
287. Comment: The feeding of elk is causing an unnatural concentration of animals that leads to easy transmission of disease. This practice should be stopped and allow the animals to feed naturally. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
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288. Comment: I live in Wisconsin in the area where Chronic Wasting Disease was first discovered in our state. Believe me, it is a tragic and divisive disease, creating suffering in the deer and bad feelings among communities and professionals alike. One thing we know, after more than 10 years fighting CWD...feeding of deer, or elk, hastens the spread of the disease by bringing animals together. My husband and I enjoy the Yellowstone and surrounding national forests, getting there as often as we can. This year, we'll be there in late July. For the sake of the animals and humans, I urge you to ban feeding to help stop the spread of this awful disease. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
289. Comment: Please protect these wild animals from the spread of a potential epidemic when they amass for feed. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
290. Comment: You Keep Fooling With Mother Nature And She Will Bite Back. We Have Already Seen How Messing With Mother Earth Can Affect Us. So Stop Before We Have No Resources Left Or Animals.
Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
291. Comment: Wildlife should not be fed artificially. This concentrates them making them more susceptible to disease and predation. In Montana we do not have CWD, thou in Wyoming it is widespread. Concentrating elk for winter feed is an obvious vector for transmitting this disease to Montana, as elk from both states could congregate together. Stop feeding and concentrating these wild elk, give them the opportunity to forage naturally on Park and Forest Service land, as well as access to private land where available. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
292. Comment: Wildlife feeding is not natural, and only endangers the animals and commits them to an unnatural life-style. Why would we ask the public to stop feeding wildlife and then continue to do so? Just doesn't make any sense. Let nature take care of nature. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section
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Response to Comments on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
293. Comment: Please, think about epidemiology, wildlife management, and other science based studies and STOP feeding the wild elk of Wyoming! Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
294. Comment: I am writing to urge you to not approve any plan to feed elk. The concentration of elk in a feeding area brings with it the danger of disease which can spread among wildlife, and it endangers the wildlife of Yellowstone Park. Elk are wild animals and should be left to find food on their own in the wild, as they have been doing for thousands of years. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
295. Comment: The Gallatin Wildlife Association (GWA) is a non-profit volunteer wildlife conservation organization representing hunters and anglers in Southwest Montana and elsewhere. Our mission is simply to protect habitat and conserve fish and wildlife. GWA supports sustainable management of fish and wildlife populations through fair chase public hunting and fishing opportunities that will ensure these traditions are passed on for future generations to enjoy. We remain extremely concerned about the effects of artificial feeding of elk, bison and other wildlife in Wyoming as we live and treasure the wildlife that depend on the interconnected ecosystem upon which we all enjoy and that we refer to as the Greater Yellowstone Area. Please phase out the feedgrounds, including the Alkali Creek Feedground #39126 and opt for programs that aim to protect and reconnect critical wildlife habitats. In Montana, we have the Habitat Montana program, which is funded with sportsmen's dollars to provide funding to protect and connect critical pieces of wildlife habitat. We oppose the use of national public lands for the artificial feeding and concentration of native wildlife that should be managed as free-ranging wildlife and we support the North American Model of Wildlife Management that promotes protection of habitat and the conservation of public fish and wildlife. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
296. Comment: Our family greatly enjoys visiting our national parks and forests to experience the few remaining natural areas in the United States. Signs throughout these areas, as well as our local forest preserves and parks, direct visitors not to feed wildlife because it disrupts the natural cycle. Our children are also taught this in school. This project violates this practice on a large scale which can lead to greater concentrations of weak animals and the spread of disease. Please discontinue the practice of feeding elk
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Response to Comments in this area and set an example to our youth by your actions. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
297. Comment: I am writing to ask you not to continue the artificial feeding of elk in the Bridger-Teton National Forest. This practice endangers the animals and makes them more susceptible to the spread of diseases, like chronic wasting disease. Please do not grant permission for this type of activity to continue. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
298. Comment: Please allow nature to take its proper course and eliminate this practice. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
299. Comment: I'm writing to indicate my opposition to the state's feeding of the elk herd. Of all the environmental issues that I have dealt with in recent years, this appears to be the most difficult to understand that there is any issue. Everything I have read has been of the same opinion – that is, that the health of the elk herd suffers and nature should take its course. Further is the concern of the spreading of disease among the herd. While the project is well-intentioned, I remain incredulous that in the name of good wildlife management, with all of scientific knowledge we have, that the feeding program continues. This is even more remarkable in light of the funding problems every government has in the country. This money could be well spent on a constructive wildlife management program instead of a destructive one. Please discontinue it. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
300. Comment: We have lived and recreated in Greater Yellowstone for over 30 years and believe the USFS, Bridger-Teton National Forest, should not re-permit WY Fish and Game to feed wild elk in the winter at Alkali Creek. The Gros Ventre Valley has abundant winter range for elk. They should not be concentrated where they can spread disease such as chronic wasting disease or brucellosis to other elk. There should be no feedlots on USFS lands. MT does not have elk feeding stations, and our elk do just fine. Historical precedent notwithstanding, times change. Science is not on the side of feeding wild native elk in winter. Our native wildlife should not be unnaturally fed to placate the livestock industry. If ranchers want to protect their hay, they can do so; the elk then would have no reason to come around.
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Response to Comments
Please get rid of all feedlots on USFS lands in WY. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
301. Comment: All indigenous people, animals, forests, waters are to roam and move FREE, as creation INTENDED. People are not wise enough to CONTROL any other being or habitat. STOP! We are guests here to pursue spiritual knowledge, not to take anything away from Mother Earth! Organic Vegan diet, clean and green lifestyle are ESSENTIAL to meet our purpose. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
302. Comment: Please reconsider the continuous feeding of the elk. As a student of Wildlife Natural Resources, I took part in research projects that included feeding programs of several wildlife species. I strenuously reject them as it tends to create dysfunctions in a range situation. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
303. Comment: We have a similar problem in Michigan caused by hunters baiting whitetail deer with bait piles. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
304. Comment: I urge you to stop feeding wild elk at Alkali Creek. That is a harmful unnatural practice that will encourage disease including chronic wasting disease. It is irresponsible for Bridger-Teton National Forest that you allow such harmful practices as wild elk feeding grounds in the Gros Ventre. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
305. Comment: Please stop feeding elk on USFS managed public lands and spreading disease that is then transferred to healthy elk in Montana, Idaho and Wyoming. Montana stopped feeding elk 50 years ago. The potential for chronic wasting disease to spread to more Wyoming elk herds as a result of concentrated feeding areas and then spread CWD to adjacent states would be devastating to the recreation industry and public. Even BLM doesn’t allow feeding of livestock on public lands it manages
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Response to Comments due to the environmental impacts of such an action. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
306. Comment: We need to pay more attention to the way we are actually harming this species! Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
307. Comment: I am extremely concerned that a project which sounds humane may have unintended consequences. Providing food to the elk at the Alkali Creek Feedground may actually cause damage by concentrating the elk in a small area, thus aiding the spread of disease. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
308. Comment: Please do not extend the program to feed elk at the Alkali Creek area. It makes no sense to increase the likelihood of wildlife in adjoining areas being infected with Chronic Wasting Disease. Control of disease is a primary factor in protecting the natural elements of the entire area, which is unique. Please carefully weigh this in your decision making concerning Alkali Creek. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
309. Comment: I have learned there is a question of continued wild elk feeding program. I have watched and enjoyed that practice for years. But I also grew up in a day where we tossed our left over picnic foods to the bears so they would walk up to the car and get their pictures taken in black and white. We learned as cute as that was, and as rewarding to the human tourist, it really endangered the bears in the long run. We as responsible persons of conservation must act just as responsibly for the elk populations. The large concentrations I have learned endanger the whole regional herd population because of disease or condition involving chronic wasting.. I strongly urge the cessation of the elk feeding practices. In the long run the population will achieve its own natural level of concentrations. The Bridger-Teton should exercise its responsibility to manage for healthy natural resources and allow elk to roam on expansive natural winter ranges in the Gros Ventre Valley. The forest should not permit the Wyoming Game & Fish Commission to operate an elk feedground at Alkali Creek beyond the winter of 2013-14. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section
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Response to Comments on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
310. Comment: WY G. & F. personnel: It has been shown, many times, that the adverse effects of large-scale feeding of large ruminants such as elk during the winter time greatly outweighs the possible advantage of preventing starvation of these animals. It is a waste of money. I would urge you to terminate feeding of our elk at the Alkali Creek Feedground during the winter. Spend the money on conservation of habitat; an action that will truly improve the health and well-being of the animals. Thanks. Del & Linda Coolidge; living with elk in Montana. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
311. Comment: It is a bad idea to feed the elk at the Alkali Creek. This practice has resulted in ravaged habitat and diseased animals. It does not make sense. Thank you for your attention to this matter. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
312. Comment: Chronic Wasting Disease CWD of cervids is spreading, and there seems no stopping it. It would seem prudent to use all your weapons and sources to stop this agent from spreading, and this includes the enhancement of CWD by the unnatural feeding of these cervids, thus causing the congregation of said cervids, thus causing the surrounding environment becoming exposed and loaded up with the CWD TSE prion. Once this is done, there is no going back. Once the soil content is so loaded with the CWD TSE prion, you risk exposing every animal and man that comes on that land. The land will then be rendered useless. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
313. Comment: Please stop feeding the elk. It disrupts the natural balance, and increases the incidence of Chronic Wasting Disease. It should end now. Thank you. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
314. Comment: Hello there, I've never seen an elk in the wild and living in the wild western end of the San Fernando Valley I'm not likely to do so. Then again, if the organized group feeding of these beautiful wild animals continues I'm not likely to see one if/when I come to Wyoming either! That'll be a fine
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Response to Comments thing: here I scrimp and save and pinch pennies to come East and see the locales made famous and desirable in all of the C.J. Box novels I've read and loved-all of them-and guess what? NO ELK! Because they've been wiped out due to pig-headed ignorance by well-intentioned/lazy bureaucrats. These I can see anytime just by driving over to city hall but elk??!! PLEASE give the elk a chance! Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
315. Comment: Where is the famed Elk Foundation in this battle? Of all organizations, it needs to recognize the folly of continuing the elk feeding stations. It is unnatural for elk to be grouped in such large numbers, and they are then much more susceptible to disease. Let nature cull the herds by allowing the elk to survive (or not) in the wilderness during the winter months. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
316. Comment: I will for the life of me, never understand why we do not do everything in our power to preserve our wildlife. PLease, please, let us stop the feeding of elk.
Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
317. Comment: Please consider discontinuing the practice of feeding elk at Alkali Creek. Elk are wild creatures so why are we feeding them like a domesticated animal? The whole population could end up being wiped out as the natural evolution stage is being removed by man. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
318. Comment: I wish you would please stop feeding the wild elk. I'm surprised this is allowed at all. It sets a very bad example for folks who then go home and feed wild animals in their neighborhoods. Unless wild animals are actually starving, endangered or otherwise compromised, feeding them does them no good at all and a good deal of harm. Please stop this program now. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
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319. Comment: This has just led to diseased animals, destroyed habitat, soon/preventable CWD disaster, unnatural predator/prey animal (unhealthy)populations, unbalanced ecosystems, waste of taxes. Predators (animal) are vital to ecosystem balance- thereby Our health. Do your job- Protect Our Public lands, waters, wildlife, health & future! You work for All citizens, not just (vast minority) hunters. Your attention to this most urgent matter would be much appreciated by all present & future generations of all species. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
320. Comment: The attempt to increase the density and gathering together large herds of elk by feeding is a perfect plan for spreading the chronic wasting disease in our elk populations. We have no known cure or preventative measure to avoid this at the present time other than maintaining reasonable distances between infected populations and uninfected populations. Let's stop activities that work to the opposite effect. If hunters want abundant elk for hunting, the last thing we need is to facilitate the spread of a fatal and incurable disease! Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons For My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
321. Comment: Do not use coyotes as bait in pens! Completely sick, cruel and inhumane. Wildlife should be respected, not tortured and killed! disgusting. Response: This comment has nothing to do with any actions that will be taken as a result of this project.
322. Comment: Dear Bridger-Teton National Forest: I strongly urge you to stop the practice of artificially feeding elk on U.S. Forest Service land, and to initiate this change at Alkali Creek. To continue doing so puts elk, a national resource, at great risk of contracting Chronic Wasting Disease (CWD) which is more likely due to the unnatural densities of elk that such feeding grounds foster. I have traveled and explored many areas of the Greater Yellowstone area and am extremely concerned about the wildlife management practices being used, elk feeding grounds prime among them. The science is clear - when CWD hits our national elk herds, it will be a conservation disaster. The solution is also clear and so I call on the Bridger-Teton National Forest to base decisions on science and to manage responsibly for healthy natural resources and allow elk to roam on natural winter ranges. The forest should not permit the Wyoming Game & Fish Commission to operate an elk feedground at Alkali Creek beyond the winter of 2013-14. Thank you. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
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323. Comment: I oppose the re-permitting of the elk feedground in the Gros Ventre in Western WY. This outdated practice perpetuates CWD and wreaks havoc on the environment and wildlife habitat. The close proximity to the Greater Yellowstone ecosystem endangers the Yellowstone NP and Jackson Hole elk herds to exposure to CWD. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
324. Comment: As a concerned citizen who has traveled extensively through the Greater Yellowstone Ecosystem, as well as throughout the lands to the south of it, I urge you to reconsider feeding elk at Alkali Creek. Unnaturally concentrating these animals, by feeding them at certain locations, is likely contributing to the rampant spread of Chronic Wasting Disease (CWD), as well as placing undue burden on the surrounding ecosystem. It would be a shame if human attempts to feed elk resulted in the spread of disease and malaise, ultimately resulting in the destruction of healthy elk herds farther north. Thank you considering my point of view. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
325. Comment: Phase out feeding elk. This is totally unnatural and may cause disease. Remember when we stopped feeding bears in YNP at garbage dumps years ago. The bears recovered, became healthier, and allowed people to see wildlife in their natural, healthy state. Let’s do this with elk, but phase it out. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
326. Comment: Please cease feeding wild elk at Alkali Creek Feed-ground. This practice is disruptive of natural processes and undermines the health of individuals and the herd. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
327. Comment: The science is very clear: feeding large numbers of elk in concentrated areas contributes to disease in the elk, specifically chronic wasting disease, and fosters the spread of brucellosis, which then becomes an issue to ranchers and bison advocates. The consequences of Wyoming's feeding program impacts us in Montana and all those who visit Yellowstone to see healthy, vibrant wildlife. Elk will be better off without this artificial feeding and so will all of the rest of our wonderful wildlife.
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Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
328. Comment: I oppose the re-permitting of this obsolete elk feedground in the Gros Ventre. The unnaturally dense concentrations of elk at such feedgrounds have resulted in diseased animals, ravaged habitat and the prospect of a CWD disaster moving inexorably closer to the famed herds in Yellowstone National Park and Jackson Hole. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
329. Comment: Feeding these elk year after year all winter with these close quarters is just asking for trouble, it’s a time bomb waiting to happen. It’s going to be hard because they've been doing this for years but it needs to be done.....for the strength of the herd. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
330. Comment: Leaving environments in their natural state helps the ecology of all species, flora and fauna. Remember killing the wolvers, allowed the elks to overpopulate, and the beavers died, because the elk ate the trees that the beavers needed for their dams. Here we go again. The wisest man in the world said doing the same thing over and expecting a different result is insanity! Please stop feeding the elk, if you want the ecology of Yellowstone to survive. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
331. Comment: I support long term authorization for Wyoming Game and Fish Commission to continue to use lands and facilities at the Alkali Creek Feedground to conduct their winter elk feeding and related management programs. This proposal would be for 20 years of continuous use. I understand that these areas would be used by the WGFC for corrals, sheds, one hay stack-yard containing two hay sheds, a water facility and feeding grounds associated with their ongoing winter elk management program. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
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332. Comment: Feeding elk is endangering the health of these populations. Please stop. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
333. Comment: It is time to phase out feeding elk and other species who show up for the feast at Alkali Creek. It is unnatural and promotes the animals to become dependent. Also disease spread is an issue that threatens to affect all the herds in the greater Yellowstone area. As a homeowner in Montana, I fear when the spread of disease affects herds in Yellowstone and beyond. "According to the court ruling, the refuge adopted a plan in 2007 that calls for decreasing reliance on intensive feeding over a 15-year period." (Billings Gazette, August 4, 2011) Feeding must begin to taper off so that when it is required to stop within 15 years from the 2007 ruling, the elk, bison, and other animals will be able to find winter grazing on their own. Installing a 5 million dollar irrigation system when the mandate was to stop feeding is outrageous and will not encourage elk and bison to find winter feeding areas on their own. You must stop this artificial feeding. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
334. Comment: Initially, I would like to state that concentrating elk at feed grounds on National Forest System (NFS) lands is not in the public interest since, as acknowledged by the DSEIS, this practice facilitates the transmission and increases the incidence of diseases such as brucellosis. Given the management problems associated with the prevalence of this disease in the elk and bison populations in the Yellowstone area, any activity that promotes its spread is clearly undesirable. I understand the history associated with the elk feed grounds but times and conditions have changed and demand a new approach to the problem. There is a wise saying that: “when you find yourself in a hole the first thing to do is stop digging”. With regard to elk feed grounds, now is the time to “stop digging”. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
335. Comment: While the WGFC’s commitment to continue feeding elk on other sites if the Alkali Creek Feed Ground is not approved may result in similar broad scale effects; this is clearly not the case for the site specific effects. The DEIS documents how the soil, vegetation, wildlife and Wilderness resources are being negatively impacted due to the concentration of large numbers of elk drawn to the site by supplemental feeding. As stated in the DEIS: “the primary consideration for the Forest Service are the potential effects to land under its administration and conflicts with public uses and other National Forest Programs”. The DEIS documents undesirable effects to the land and conflicts with public uses
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(specifically conflicts with Wilderness uses). By simply following Forest Service Directives, and denying the WGFC’s proposal to continue supplemental feeding, these site specific impacts will cease to occur and the Alkali Creek site can begin to heal and return to a natural condition. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
336. Comment: The BTNF should not approve the reauthorization of this feedground and should instead take this opportunity to improve habitat and wildlife conditions, not only within the Gros Ventre Wilderness, but within all of the Gros Ventre River drainage. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
337. Comment: We make note here of the excellent Vision Statement of the Bridger-Teton National Forest which is prominently displayed in the Supervisor's Office at 340 N. Cache in Jackson, Wyoming: “The Bridger-Teton National Forest is home to world-class headwaters, wildlife, wilderness and wildlands. Conserving these values, in concert with providing for sustainable uses, is our legacy. We are leaders committed to service, action and excellence.” We commend the leaders and staff of the BTNF for crafting such a mission statement years ago. It is unfortunate, however, that the “excellence” criteria of the Vision Statement is not well served by the Alkali Creek Feedground DSEIS as we will explain in these comments, and have also described at length in our May 2012 scoping comments and other comment opportunities regarding the 2008 elk feedground DEIS and ROD. The environmental analyses, decision to permit and the actual operation of elk feedgrounds on USFS lands are substandard treatments of habitat and wildlife which are done almost nowhere else in North America other than in western Wyoming, several on the BTNF. The BTNF is not living up to its Vision Statement by permitting elk feedgrounds which, by their influence on other habitats and wildlife populations, are harmful to a broad swath of the BTNF. Definitely not the treatment of “world-class wildlife” the public expects and deserves. We will also address the BTNF's Mission Statement in the context of our comments on the Alkali Creek Feedground DSEIS later in these comments. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
338. Comment: "Unavoidable" Adverse Effects The very sparse list of six sentences on page 150 of the DSEIS describes briefly that soils, water, wildlife and plants are harmed by the operation of elk feedgrounds. One issue briefly mentioned is especially important: "Feedgrounds increase the probability of disease and parasite transmission among elk, including brucellosis, chronic wasting disease and other diseases." (DSEIS:150) Despite this statement being accurate, the BTNF knew this in 2008 yet, ignoring their legal directives, they issued 20- year permits to operate five other feedgrounds on USFS land in July
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2008. Alkali Creek is an opportunity for the BTNF to consider the science and make a lawful decision not to permit an elk feedground that will harm wildlife and habitat. Any reader of this list on page 150 of the DSEIS of Adverse Effects to forest resources from elk feedgrounds cannot help but wonder why the BTNF has insisted over the years on approving actions that result in such harm. The public's interest will be better served and for much longer if this kind of harm to USFS land is not permitted by the BTNF. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
339. Comment: 9. Irreversible and Irretrievable Commitments of Resources This appears to be a section in the DSEIS where the BTNF actually describes some of the stark realities of the effects of elk feedgrounds: “Irretrievable commitments of resources are those that cannot be regained, such as the extinction of a species or the removal of mined ore. Irretrievable commitments are those that are lost for a period of time such as the temporary loss of timber productivity in forested areas that are kept clear for use as a power line right-of-way or road. “Irreversible losses could occur in willow habitat within and adjacent to feedgrounds due to loss of root stock as continued heavy browsing by elk in the winters prevents suppressed willow plants in wet meadow habitat from recovering to a healthy condition. Irretrievable losses of aspen habitat could occur due to heavy browsing. “The potential exists for irretrievable commitments of both elk and deer resources if chronic wasting disease (CWD) became established in western Wyoming and substantially reduces these populations. While the arrival of CWD is beyond the control of wildlife managers, the potential effect would be greater under any alternative where large numbers of animals are concentrated on feedgrounds. The loss would be irretrievable because in addition to always being fatal to infected animals, chronic wasting disease contaminates the environment for long periods of time.” Additionally, “The potential exists for irretrievable commitments of predator and scavenger resources to occur if CWD became established and substantially reduced the elk population. (U.S. Fish and Wildlife Service and National Park Service Bison and Elk Management Plan and Environmental Impact Statement (2007)).” (DSEIS:151) As we commented in 2008 about the above section in the DEIS, “The BTNF would do well to heed its own cautionary words.” Furthermore, if the BTNF actually intends to implement its Mission Statement it should not approve elk feedgrounds given the known harm, the risk, and the public’s expectation that the BTNF will act in the public’s best interests now and for the future. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
340. Comment: My comment concerns elk feeding near Jackson, WY. I spent 60 years in Wyo. I still spend time there and can almost see it from where I live. The elk feed project is good for the alfalfa growers, some of the guides, and the guys who have jobs feeding elk. For the natural balance, it's a disaster. The summer range has a carrying capacity which has been exceeded for over 100 years. Less so now that we have a few wolves to make the elk act like elk, but with Wyo's pathological hatred of
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Response to Comments anything that eats something somebody wants to kill, the wolves are again doomed. I'm fine with hunting as I define it. It ain't hunting to go out having fired 2 rounds through a fancy rifle with a scope and blow away an animal at 400 yards. Black powder? Sure. Bow? Sure. Iron sights? OK. The US military by 1890 had a training program for open sight shooting out to 1,000 yards. Fair chase is a good principle. Buying accuracy is not fair chase. It's hunting, not slaughtering. Which says nothing about the diseases that spread on the feed ground and get into other wild populations and domestic animals. Time to shut down the feeding. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision. Support for Alternative 2 – Proposed Action 341. Comment: Support of the renewal of the Forest Service permit to continue to allow feeding of the elk on the Alkali Feed Ground. The Alkali Creek Feed ground is one of the most crucial components in the management of the Jackson Hole elk herd. History has proven the importance and necessity for this feed ground to remain in the location it is currently as well as the importance to continue the feeding program. This feed ground is a stopping point to help keep these elk from dropping down into the National Elk Refuge as well as from intermingling with livestock on private land. There are many prominent housing areas that risk being affected if these elk begin to seek their winter feed on their landscaping, shrubs and foliage. Wildlife/ vehicular incidents may also rise significantly if these animals are left to cross heavily traveled highways and roads in search of alternative sources for feed. If feeding is discontinued on the Alkali feed ground it would cause a tremendous negative impact on an already declined moose and big horn sheep population as it will cause the elk and these other species to be in competition for browse forage. Pronghorn routinely and successfully encounter and bypass many anthropogenic features such as fences, highways and housing developments along the course of their long migration to and from the Pinedale area. The Alkali Creek feed ground and its facilities has minor to no impact on migratory pronghorn. Any pronghorn that encounter the said area would have no problem navigating their way through. Without feed grounds in the Gros Ventre drainage, congregating of elk on the National Elk Refuge and the surrounding area would increase significantly. Having multiple and strategically located feed grounds enables the Game and Fish to properly manage healthy elk herds enabling them to utilize native forage when available and minimizes the risk of the spread of disease. Due to large predator impact on the elk herds it has become less feasible for elk to winter out on native ranges when forage is available. Allowing the Wyoming Game and Fish to maintain a healthy number of elk in the Gros Ventre River drainage only enhances the preservation of the wilderness as well as the wild and scenic corridor. The absence of this native species would be a great disservice. Response: Thank you for providing your views concerning the benefits of continuing elk feeding operations at Alkali Creek. In the wildlife and vegetation sections (Chapter 3) of the FSEIS, we compare the effects of the two alternatives on wolves, elk and vegetation.
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342. Comment: The Wyoming Outfitters & Guides Association is writing in support of the renewal of the Forest Service permit to continue to allow feeding of the elk on the Alkali Feed Ground. The Alkali Creek Feed ground is one of the most crucial components in the management of the Jackson Hole elk herd. History has proven the importance and necessity for this feed ground to remain in the location it is currently as well as the importance to continue the feeding program. This feed ground is a stopping point to help keep these elk from dropping down into the National Elk Refuge as well as from intermingling with livestock on private land. There are many prominent housing areas that risk being affected if these elk begin to seek their winter feed on their landscaping, shrubs and foliage. Wildlife/ vehicular incidents may also rise significantly if these animals are left to cross heavily traveled highways and roads in search of alternative sources for feed. If feeding is discontinued on the Alkali feed ground it would cause a tremendous negative impact on an already declined moose and big horn sheep population as it will cause the elk and these other species to be in competition for browse forage. Pronghorn routinely and successfully encounter and bypass many anthropogenic features such as fences, highways and housing developments along the course of their long migration to and from the Pinedale area. The Alkali Creek feed ground and its facilities has minor to no impact on migratory pronghorn. Any pronghorn that encounter the said area would have no problem navigating their way through. Without feed grounds in the Gros Ventre drainage congregating of elk on the National Elk Refuge and the surrounding area would increase significantly. Having multiple and strategically located feed grounds enables the Game and Fish to properly manage healthy elk herds enabling them to utilize native forage when available and minimizes the risk of the spread of disease. Due to large predator impact on the elk herds it has become less feasible for elk to winter out on native ranges when forage is available. Allowing the Wyoming Game and Fish to maintain a healthy number of elk in the Gros Ventre River drainage only enhances the preservation of the wilderness as well as the wild and scenic corridor. The absence of this native species would be a great dis-service. We respectfully ask you to consider all the pertinent information and views brought forth. Response: Thank you for providing your views concerning the benefits of continuing elk feeding operations at Alkali Creek. In the wildlife and vegetation sections (Chapter 3) of the FSEIS, we compare the effects of the two alternatives on wolves, elk, and vegetation.
343. Comment: Full feeding of the elk in the winter is absolutely necessary for the health of the elk as well as the bighorn sheep, moose, and deer in the area, in addition to the health of the plant community and must be continued. Response: Indeed, closing Alkali Creek Feedground would increase forage competition between elk and moose, bighorn sheep, and mule deer on native range, as some elk that currently use Alkali Creek Feedground would elect to forage on native range. This statement was added to the FEIS on page 112. As discussed in the FSEIS for vegetation resources (beginning on page 34), elk mobility among the two remaining feedgrounds in this alternative and the National Elk Refuge in Jackson Hole is expected to increase, potentially increasing herbivory pressure in the river corridor and on native ranges used by other ungulates. However, because no prior quantitative data on the condition of the native winter range and throughout the river corridor were available for our analysis, it is speculative to conclude that feeding elk is essential to maintain the health of the big game species that use native winter range Gros
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Ventre. Similarly, the assumption of a negative effect on plant community health that might result from increased elk herbivory on native range under Alternative 1 is speculative. Health of moose and mule deer that winter in the corridor may (or may not) be currently adequate, and may remain so if Alternative 1 is implemented. Bighorn sheep may have recently declined (winter 2012) in the Gros Ventre watershed related to disease, and the herd may be nutritionally stressed. Thus, new foraging competition between elk and bighorn sheep under Alternative 1 could further reduce the health of bighorn sheep. The potential for forage competition between elk and bighorn sheep is discussed on page 112 of the FEIS.
344. Comment: We need to keep the feedground for many reasons! Here are a few. Elk are constantly being pressured by wolves and move them between the 3 feedgrounds. If alkali is not there it is the last chance to stop the elk that would be pushed down on to private lands and even on down onto the elk refuge and we know that Steve Kalin at the refuge does not want the Gros Ventre elk showing up there also. The historic use is important to keep the Gros Ventre elk in the Gros Ventre. The Wyoming Game and Fish have done a very good job being responsible for the care and well-being of our elk..!!!! Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
345. Comment: I believe we would be doing more harm to the elk if we quit the supplemental feed of the elk. There is way too much snow in most years for the elk to forage on their own. With the pressure from the wolves in winter and little forage the elk don't stand a chance. I vote keep the feed ground. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
346. Comment: We are opposed to the closing of the feedground. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
347. Comment: I wish to go on record as strongly opposed to the closure of the Alkali feedground! I have lived in the Gros Ventre area most of my life---75 years. I have observed many, many heavy winters and know if the feedground is closed many elk will starve to death! The fear of disease is greatly exaggerated---and probably will not happen. But, with the advent of a regular winter many elk will die of starvation if the feedground is closed. Please continue the feeding program. It has saved the lives of most of the elk population in existence today. I've seen the health of the elk improve greatly since the feeding programs were started. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section
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Response to Comments on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
348 Comment: I have been reading several of the comments on this site. Please note many of the opposing letters were written by the same person and submitted by people without much thought or information. Thanks for your time and effort to keep the feedground program working for the good of the elk in the Gros Ventre Valley. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
349. Comment: I’m writing to voice my concern in the reauthorization of the Alkali Feedground. I strongly urge you to renew the permit to continue the current use of this wildlife management area. This feedground is an essential part of the Wyoming Game & Fish Dept. winter management system, likely the most important feedground in the Gros Ventre. As private property owners in the Gros Ventre we support the Wyoming G&F and their efforts to maintain these wildlife management areas in the best interest of all wildlife, and to minimize damage to private property throughout the Gros Ventre drainage. The USFS is a key player in the management of our wildlife as well. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
350. Comment: As the closest neighbor to the Alkali feedgrounds I would strongly urge you to keep feeding the elk for the winter. We have already had to spend thousands of dollars to build a fence to keep the resident migrating elk herd out of our feed lot for our horses. The damage to private property and fence lines from the small amount that still migrate would be compounded by adding the main herd searching for food. I am sure there are countless studies by individuals claiming numbers, trends etc.. But for the layman who has to deal with the Elk on a daily basis I see the real everyday life and actual events that happen up here. So from my humble perspective it would benefit the resident herd to keep the feeding program as they have been accustomed to. Also from a local residents perspective dealing with property damage and daily elk on our feed lines it would compound our daily duties to an almost extreme level. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
351. Comment: I manage the Red Hills ranch up the Gros Ventre. We live here year round. We are located about 6 mile west of the alkali feed ground. We get to see all the elk that migrate up and down the Gros Ventre. They pass right by our ranch. We see hundreds of elk passing by or just grazing near our ranch we love it. We don't have any problems with the elk until winter. We raise registered paint
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Response to Comments and quarter horses on our ranch. We have our own stud and mares and we raise about 20 colts per year. We take great care in feeding our horses good quality hay to ensure quality colts every year. We have an average of 75 horses on the ranch at all times. We rely heavily on the fish and game for the management of the elk herd in the winter. In the winter we have huge herds of elk breaking right into our pastures and eating the hay that we feed. At certain times at the beginning of winter we have to chase the elk out of our ranch 2 to 3 times per day. If we fail to get the elk out they can quickly clean up all the hay we feed. It is also very damaging to our fences. The elk herds break down the fences constantly. Once the fish and game begin to feed the elk at the alkali feed ground it takes the pressure off of us. The elk that break into the ranch are much less and we are able to properly nourish our horses without the constant presence of elk in our pastures. We ask that you make it possible for the fish and game to continue feeding the elk at alkali feed ground. If you discontinue feeding at alkali it would make it impossible for us to get our horses fed. As the wolves chase the elk off the main cabin feed ground they usually run to the alkali feed ground. If you discontinue feeding at alkali the elk will go right to the red hills ranch. This is unacceptable for us and will not work. Please stand up for the property owners and for the elk herds. The elk need to be fed and we can’t feed them here at the ranch. Please stop letting the same groups tell you and I how to manage the wildlife and the forest. You are in charge, please make us proud. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
352. Comment: It is essential that the complete feed ground complex in the Gros Ventre Valley be kept intact as these three feed grounds are one of the important spokes in keeping a strong, healthy and diversified North Jackson Hole Elk Herd. There is ample natural habitat in the area to accommodate the herd objective UNDER OPTIMUM CONDITIONS. However, we seldom have these conditions and with the wolf numbers being what they are in the area, the elk will never be allowed to use what forage is available. All the acres and tons of forage that are calculated in the summer, even under the best conditions, are not available in the winter. Most of the feed on the east and north slopes, and in the gullies are covered with too much snow for the elk to use. It does them no good. Even on the south and west slopes, if we have an early snow and then warm/rainy weather, followed by a cold spell, things will freeze and the forage becomes inaccessible. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
353. Comment: Disease is a concern, with CWD being the big one. My feelings are that when CWD does hit this elk herd, the feed grounds are going to be an asset rather than a liability. On the feed grounds the feeders can change the feed lines each day and feeding on snow will protect the elk from Prions that are in the ground or on the snow from previous feedings. The elk on winter range are bunched because of the wolves. They are chased from one bare ridge to the next, and when looking for food they are back
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Response to Comments eating the soil, where these prions could have been collecting over a period of time. Because of the stress from the chasing and foraging, the elk wintering are probably not in as good of shape as the feed ground elk and may be more susceptible to disease. With each snow storm the elk get a prion free dinner table. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
354. Comment: I do not envy you in the decision that must be made, but am hoping you will reissue the permit for the Alkali Feed Ground. It is a very important cog in maintaining a viable herd in Jackson Hole. This elk herd is a historical icon of Jackson Hole and the State of Wyoming. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
355. Comment: Concerned Citizens for the Elk support Bridger-Teton National Forest’s renewal of the Wyoming Game & Fish Alkali Feedground Permit. This elk feedground is important for these reasons: 1. Prevents starvation 2. Protects Wyoming’s brucellosis-free cattle status 3. Prevents elk from moving downward, ending up on the National Elk Refuge 4. Prevents elk from competing for Big Horn Sheep habitat 5. Corresponds with existing feedground leases 6. Maintains economic support to Teton County and the State of Wyoming. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
356. Comment: I really strongly feel we should continue to feed the elk on the feedgrounds. Weather has been mild last couple of winters in some areas, but in bad winter conditions the elk would be wiped out. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
357. Comment: The Alkali Feedground is the most crucial feedground of all twenty plus feedgrounds operated by the WG&F Dept. If feeding stops on Alkali, there will be no way to hold elk from drifting to the N.E.R and complicating the NER elk management EIS plan. In order to hold elk in the Upper Gros Ventre the Game and Fish will have to start feeding way early at Patrol Cabin and Fish Creek. And as we all know, the longer elk are off feed it is more cost effective financially and ecologically. This feedground has been in place for several decades and the Game and Fish has managed it properly and it has been an asset to their program and the public.
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Response to Comments
Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
358. Comment: The bottom line is that the environmental community doesn't want any unnatural settings in the Yellowstone ecosystem. There biggest problem in there thinking is that they want all Federal lands to be managed like the Department of Interior. And they are constantly trying to change the policies of the Department of Agriculture. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
359. Comment: I hold four Forest Service S.U. Permits in the Gros Ventre and will be dramatically affected if Alkali is not renewed. I recommend that Alkali be reauthorized and lets all move forward with status quo and not risk devastating a major asset to the Jackson Hole Valley. Response: Thank you for expressing your opinion about this project. The Bridger-Teton Forest Supervisor reviewed and considered your comments. Please read the "Reasons for My Decision" section on pages 4-8 in the Draft Record of Decision distributed with the Final Supplemental Environmental Impact Statement to see the rationale for the proposed decision.
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