On Thursday, November 21,2013, the Interagency Bison Management Plan (IBMP) met at Chico Hot Springs for their final meeting of the year. On the Agenda was a Brucellosis Seroprevalence Timeline Discussion with 7 discussion goals: to begin clarifying future IBMP directions with respect to seroprevalence for Partners and Public. During this discussion, not only did Dol's Dr. Marty Zaluski and Christian MacKay state that they were going to begin bison capture, test and slaughter, vaccination program in late Feb. to March, but that they had statutory rights to do this, regardless of any objections or concerns that other IBMP partners presented. Dr. Marty Zaluski repeatedly stated what their rights were as the authorization for their plans. potential new mandate for brucellosis control in wildlife (APHIS) potential MDOL ramp up on bison vaccination (MDOL) status of bison remote vaccination (MDOL) potential for setting objectives for a boundary vaccination program and determining feasibility of achieving those objectives (all) status of Tom Hobbs predictive seroprevalence model publication and availability (NPS) brucellosis suppression as an IBMP goal (all) discussion of overall value of seroprevalence as a tool for achieving twin IBMP goals (all) Seroprevalence Timeline Discussion audio file MP3 1hour 3 minutes ( a number of the speakers are the supporting staff to the voting partners, who sit behind the partners, not having a mic. I had to manually raise the volume for these speakers to be able to hear them, hence the noise distortion. Keith Lawrence, the quietest of them all is still hard to hear.) Below are key points of discussion transcribed to give you an idea of the discussion. Suffice to say that I think every agency there besides APHIS was upset and voicing their concerns in opposition to this DoL bison vaccination program - vaccination that involves the test and slaughter of our wild bison and treating them like livestock with the tagging. I would first like to share two important science facts concerning bison and brucellosis that help to set the stage for the following information. "Median total risk to cattle from elk and bison was 3.6 cattle-exposure event-days (95% P.I. 0.1 - 36.6). The estimated percentage of cattle exposure risk from the Yellowstone bison herd was small (0.0 - 0.3% of total risk) compared with elk which contributed 99.7 - 100% of the total risk" - A Risk Analysis of Brucella abortus Transmission Among Bison, Elk, and Cattle in the Northern Greater Yellowstone Area (2010), which DoL's Dr. Marty Zaluski was one of 7 authors on. - page 41. "Montana's DSA includes 282 operations with 73,200 cattle and domestic bison. This fiscal year, 42,025 of the 73,200 animals have been tested to achieve a 99% confidence that the disease (if it exists) is present at a rate of less that 0.008%. The chance that any one Montana animal is brucellosis positive is 0.00024%." Dr. Marty Zaluski also stated, "So really the DSA in the state of Montana is in southwest Montana. And it is designed to identify the cattle at risk from brucellosis positive elk. So we know that brucellosis positive elk are in southwest Montana, they can potentially expose cattle and so the key to identifying the cattle at risk is to identify where the brucellosis positive elk are." Testimony and documentation submitted to the TAHC, Sept. 10, 2013. Bison were not mentioned by Zaluski. So if bison pose 0.0 - 0.3% risk of brucellosis transmission to cattle and of the 99.7 - 100% risk from elk to cattle - that being 0.00024%, we are really looking at a very rare risk of brucellosis transmission to cattle, one certainly not ethically, socially and economically justified by the draconian test and slaughter measures by the DoL and APHIS.

Second, I would also like to preface the Seroprevalence Timeline Discussion with some additional groundwork of the situation. The DoL holds two voting seats on the IBMP. One is Christian MacKay, Executive Officer, and Dr. Marty Zaluski as DoL's state veterinarian. No other agency has two voting members represented. As partners on the IBMP, Dr. Marty Zaluski has made a lethal decision concerning the test and slaughter bison vaccination plan, without involving the other IBMP partners. This shows a complete disrespect and disregard for the IBMP process, the other Montana State and Federal agencies, as well as the Tribal Nations who have been partnered in this process. At which point, as a Montanan I have to ask, if Dr. Zaluski has such disregard for other representatives of Montana's public, how would the ag/livestock industry feel if they and their concerns were being likewise summarily dismissed? Furthermore, the Dol is a Montana state agency, a public agency, tasked with the general supervision over and, so far as possible, protect the livestock interests of the state from theft and disease and recommend legislation that in the judgment of the department fosters the livestock industry. Dr. Marty Zaluski is a science trained veterinarian, utilizing that science to carry out the Montana directives of protecting the livestock interests of the state from theft and disease. Dr. Zaluski utilized the current science on brucellosis to advocate for Montana's livestock at the Texas Animal Health Commission (mentioned and linked above). Yet, he has hypocritically denied that same science in Montana, giving Montana a black eye that we dont manage based on responsible science, but rather prejudice and politics - losing credibility. He has ignored not only peer science, but ignored science of which he has been a contributor to in making this bison slaughter/vaccination determination. By doing so, he has deceived the very livestock constituency that he is a servant of, as to the real (low) threat of brucellosis from wildlife to livestock and the real efficacy of a vaccination program. This causes the cattle ranchers to have false expectations that wildlife brucellosis eradication is obtainable and economical - a silver bullet. Therefore they are abandoning realistic efforts to protect their industry and Montana's Brucellosis Class Free Status. Per the science of which he has been a part of, this is an internal theft to the Department of Livestock, the State of Montana and her taxpayers, as well as the federal taxpayers whose monies fund this deception of brucellosis eradication/vaccination in wildlife (Brucellosis Eradication Economics - including the state legislators sponsoring of earmarks and appropriations that are for brucellosis eradication in wildlife, funneled through a defunct organization to the GYA states Depts. of Livestock), to the detriment of the cattle industry who would have benefited far more from a more effective cattle vaccine (cattle genome and Brucella abortus genome have both been completely mapped - all the tools necessary in creating a more efficient cattle vaccine) as well as real solutions in adaptive management to protect the livestock from the 0.0-0.3% chance of any brucellosis tranmission from bison (if it can occur in the wild) and the 0.00024% chance that any Montana cattle will become brucellosis positive from elk. Discussion Dr. Marty Zaluski (Department of Livestock) stated they were going to be vaccinating bison on the west side, utilizing a mobile trap setup. When asked what this was going to look like he responds, "The traditional way that we vaccinate the bison is we take the positives, we vaccinate the negatives and we take the positives to slaughter." When asked about the numbers he replies, "The goal will be to have as big of an impact as possible on seroprevalence." Concerning marking the vaccinated bison Zaluski states, "At a minimum we would put a steel tag on these animals so we would have a reference should those animals be captured again. And then I would expect some kind of temporary visual marker." Pat Flowers (FWP Region 3 Supervisor) asked when was the last time DoL vaccinated? Someone to the side stated 2005. Flowers asks, "So what has changed from '05 to 2014, that now it's become a priority?" ( EMWH Note : In the winter of 2005-2006 it was registered as a mild winter with a population of about 5000 bison. "Since 2000, about 3,200 bison have been removed from the Yellowstone herd with over 1000 animals, or 20% of the total population culled during the winter of 2005-2006. These actions have been controversial with animal advocay groups." - A Risk Analysis of Brucella abortus Transmission Among Bison, Elk and Cattle in the Greater Yellowstone Area, 2010 - pgs. 99,100. This 20% reduction of the herd not only affects the population numbers, but herd dynamics and genetics of an already small population. The horrible publicity this event received carried into the next few years, with additional slaughterings causing the herd to be reduced by 1/3. Groups decry Yellowstone bison slaughter. The outcry from the 2005-2006 slaughter reached such levels that an Oversight Hearing On Yellowstone National Park Bison was set within the House (Federal) in the 110th Congress, March 20th, 2007. Raul M. Grijalva (Chairman of the Subcommittee) stated, "Any legitimate threat of disease must be managed effectively but of equal importance - the slaughter of bison needs to stop... Effective disease control and free-roaming bison are not mutually exclusive. Given the enormous scientific and financial

resources of the Departments of Interior and Agriculture, along with the resources and expertise of Montana, Wyoming and Idaho, I am confident that bison and cattle can be managed in a way that is not a death sentence for either species." The GAO Report (full 52 pg. pdf), "GAO is recommending that Agriculture and Interior—with the Montana state agencies—improve their accountability, transparency, and management of Yellowstone bison by developing measurable objectives and reporting yearly on progress, among other actions.") Are we looking at a repeat of the horrific 2005-2006 slaughterings and the detrimental ramifications that resulted for Montana on the world stage, as well as the bison? Zaluski replies that seroprevalence has always been important. Flowers asks, "So have you projected how many animals you'd have to vaccinate over time to have any meaningful impact on seroprevalence? What's the endgame?" Zaluski, "The endgame would be to improve the herd, immunity of the herd." Flowers,"Have you projected or in any way modeled what that's going to look like over time and so you can describe, because there's, I mean there's some trade offs to doing this in terms of hunting opportunities and that sort of thing and it would be helpful for this group to know what those trade offs are, in order to evaluate that. I think it would be helpful if you could tell us what projected outcome you expect over time, in terms of seroprevalence." Zaluski gives no projection or modeling. He states that what has been done is insignificant. Flowers, "So you said what we've done so far is insignificant. What number would be significant? That's what I'm trying to get at. What I'm concerned about is that we're throwing darts at a dart board without knowing where the target is and it comes at expense and it comes at some trade off with hunting opportunity and such. I think we need to identify what the target is or at least project what we think the target is over time. How many bison we would have to vaccinate to get there. I'm just, in some ways very similar to what we are doing in terms of a harvest plan. We have goals of how many we are going to harvest every year in order to bring it back to target population levels. It seems like we would want to do the same with seroprevalence, with vaccination, in order to achieve reduced seroprevalence." Zaluski wants vaccination to be partnered on the northside as well. Christian MacKay (DoL) said they would kick this off late February - early March (time of mid-gestation which causes more abortions). Dave Hallac (Yellowstone National Park), "A perfect example is the science we have right now shows that vaccinating animals in that time you plan to do it is the worst possible time." Hallac brings up the Science Panel and their recommendations (which Zaluski has disparaged). Brucellosis Science Review Workshop Panelists Report 2013. Pg. 6, vaccination - Cost ineffective tool. Hallac brought up many points about the controversy concerning bison vaccine effectiveness. See - Bison Vaccination Science, compiled by Kathryn QannaYahu, not supplied by the NPS or Dave Hallac. Don Herriott (USDA APHIS), " To address the issue of the elk, we've had conversations recently where we want to attempt to broaden the conversation, which is not part of the IBMP, to include elk, in our 3 states partners too, evaluate, come up with a plan of what we can do to decrease the risk, decrease the prevalence of these species in wildlife, both elk and bison. So theres ? that we would like to do, that we are prevented from doing, but I think we need to do those things. " See the APHIS Brucellosis Eradication in Wildlife Agenda Jim Stone (I think) (Inter Tribal Buffalo Council) expressed concern about the "partnership", that DoL was laying down a course of action prior to input from the partners; felt that this discussion should be the priority. He asked where the science was, had read the report that said there was almost no positive result from the vaccination program at this time. "From our perspective, in a partnership, I don't know how many resources one agency should throw at the politics." He said, "that a public agency, such as DoL, program should have been vetted through a couple different forums." Majel Russel (ITBC attorney), "ITBC has a larger goal of protecting the bison in their habitat and trying to prevent unnecessary interference to these animals in that habitat, and I think that it's difficult for us to be a partner and have a partnership here, at this table and then sort of be surprised about an action that you're going to take without them."