Bison Coalition Petitions Department of Interior to Fulfill Public-trust Responsibilities for Preserving Wild Plains Bison

 

In an April 14 letter to Interior Secretary Deb Haaland, the Montana Wild Bison Restoration Coalition responded to Department of Interior Order 3410, the Bison Conservation Initiative of 2023. The letter noted perceived deficiencies in the Initiative and suggested a path forward that would “clearly recognize and commit to dealing with the most serious bison conservation issue south of Canada; and commit to providing equal and legally mandated access to wild public-trust bison on federal lands.”

The Coalition noted that gradual but persistent domestication is “the most serious threat to plains bison in the USA”; but is essentially neglected in Order 3410. Without defining “wild bison”, 3410 asserts there are 15,000 “wild” bison in the country, misleading the American public. The genetics of most of these 15,000 bison in “conservation herds” are being domesticated with small herds and artificial management in less-than-wild environments.

Order 3410 briefly mentions a need for consistency with unnamed federal laws. The Coalition asserts: “The people deserve a more complete review” of the legal mandates within the Park Service Organic Act and the Refuge System Improvement Act.

The overwhelming focus and stated priority of Order 3410 is to develop Tribal co-stewardship of bison on federal lands. There is no discussion of how this priority will complicate Refuge management, affect public access to bison, determine management goals and practices, or possibly conflict with existing laws that emphasize biotic diversity and integrity (wildness).

South of Canada, Tribes have well over 20,000 bison in about 65 herds on reservations. Tribes have received thousands of excess federal bison since at least the 1960s, and this process will continue.

 In Contrast, the Department of Interior has about 15,000 bison in only 10 herds managed without existing co-management with a state or The Nature Conservancy. These are the only herds with clear, reliable, legal mandates to restore and maintain wildness of plains bison. Only 2 of these herds have at least 1,000 bison, the minimum number for avoiding serious genetic drift. Four herds are less than 100 bison. Additional large herds are critically needed.

 As a path forward, the Coalition petitions the Department of Interior to:

1. Recognize the threat of domestication to conservation of wild plains bison.

2. Commit the 10 above public-trust bison herds under complete Department control, as a separate genetic metapopulation with priorities for restoring wildness of bison, benefiting all Americans.

3. Restore a large public-trust wild bison herd on the Charles M. Russell National Wildlife Refuge, the largest federal refuge within the historic range of plains bison; and commit this herd into the above metapopulation.

On CMR Bison, Legislature Misinterprets Laws, Reality, and Montana Values

 

With Senate Joint Resolution 14, the Montana legislature lobbies the United States Congress and 3 federal agencies to prevent restoring public-trust, wild bison on the Charles M. Russell National Wildlife Refuge (CMR). SJ 14 passed both houses with party-line votes. It claims the State of Montana opposes any restoration of bison on the CMR. In contrast, 3 random polls have shown that about 70% of Montana voters support returning bison to the CMR.

The CMR is the largest federal refuge within the historic range of plains bison.

The legislature claims that the state has supreme jurisdiction over wildlife on federal lands and that unilateral restoration of bison would violate the U. S. Constitution. This legal mythology was extensively reviewed and denied in the Journal Environmental Law (2017) by a University of Montana law team. The Refuge System Improvement Act (1997) directs the Refuge to collaborate with the state “for timely and effective [resource] management to the extent practicable”. Getting bison on the CMR, proposed in 1937, has not been timely or effective, and given anti-bison laws from the 2021 legislature, waiting longer for state collaboration is clearly not practicable.

The legislature warns of disease transmission from bison to private livestock, whereas this has not been a problem with several herds of private bison already surrounding the CMR – a condition that is common throughout the country.

The legislature exaggerates the amount of state land within the CMR; but correctly notes that achieving state goals for these parcels is difficult, as they are isolated within the Refuge. Clearly, it would benefit the state, occasional private users of these lands, and the Refuge, if state lands within the CMR were traded for isolated federal lands outside the CMR.

A Reliable Future for Public, Wild Bison Depends on Only 10 Herds

 

 Recent NEWS items presented two different numbers for plains bison herds with reliable mandates to restore and maintain wild, public bison. March 13 NEWS referred to 13 herds; upon further study, March 27 NEWS referred to only 10 herds. Here we clarify this change.

To qualify, a herd must be managed as public-trust bison, with primary management to develop and maintain natural selection that is preponderant over artificial selection and genetic drift. Only Department of Interior herds, under the Park Service or under Fish & Wildlife Service Refuges qualify under relatively dependable legal mandates for wildness enacted by Congress.

Previous news releases from the Department of Interior claimed as many as 19 federal bison herds with 11,000 bison are managed for biotic diversity and biotic integrity – the equivalent of “wildness”. Subsequent news releases by this and other organizations have reduced this number to 16, 13, and now 10. Nine of the alleged 19 public, wild herds are:

2 herds in Alaska -- Not on native plains bison range.

1 herd on the Bison Range in Montana -- Recently ceded to the Kootenai/Salish Tribes.

2 herds in Utah -- Book Cliffs and Henry Mountains herds: spend some or much time on federal lands; but are managed and limited as state game animals and (Book Cliffs) by the northern Ute Tribe.

1 herd in Wyoming -- Jackson Hole herd: co-managed as state game; recently reduced from 1000 to 500.

1 herd in Arizona -- Has habitat in Grand Canyon National Park: co-managed as state game to limit numbers and consequent damage to Park’s prehistoric relics.

2 herds in Colorado and Kansas -- co-managed with The Nature Conservancy; have some federal habitat, but most habitat is TNC.

Likely, Department of Interior has collaborative agreements to exchange animals between these 9 herds and Interior herds to limit loss of alleles to genetic drift. However, excluding 2 herds in Alaska, the management priorities for these herds include production as game or for sale, limiting competition with private livestock, or other priorities that detract from managing for wildness.

Thus, the future of wild plains bison genomes, south of Canada, depends upon the remaining 10 herds, with approximate herd sizes totaling 7,880 bison and only 2 herds with at least 1000 bison to forestall weakening of natural selection by genetic drift. These herds are:

Yellowstone National Park: 4800 bison, not welcome in surrounding states.

Badlands NP: 1000 bison (new management plan coming).

Wichita Mountains National Wildlife Refuge: 650 bison.

Theodore Roosevelt NP: 525 bison (south herd: 350; north herd: 175).

Wind Cave NP: 400 bison.

Fort Niobrara NWR: 350 bison (includes separate “Sully” herd of 60).

Neal Smith NWR: 70 bison.

Rocky Mountain Arsenal NWR: 55 bison.

Whitehorse Hill Nat. Game Preserve: 20 bison.

Chickasaw Nat. Recreation Area: 10 bison.

These 10 herds are critical to preserving examples of genetically wild bison within the public trust. In the long run, they will be inadequate. Herds less than 100 must be enlarged. Additional large herds on large, diverse landscapes are needed.

Three large or growing private herds¹ may contribute some to saving “wild” alleles; but their management today includes some artificial selection, and limited natural selection, and they are not public-trust herds. There is no evidence that any Tribal herds have management priorities to retain wildness of bison. One impressive Tribal attempt was abandoned in 2004².

¹TNC Tallgrass Preserve in OK; TNC Medano Ranch in CO; American Prairie in MT.

²Braun, F. F. 2008. Buffalo, Inc. University of Oklahoma Press, Norman, OK. p. 235.

Wildlife Management Institute Lauds Interior Bison Initiative: Disregards Domestication Threat

 

 A recent news release from the Wildlife Management Institute describes Interior Secretary Haaland’s Order 3410, “Restoring American Bison and the Prairie Grasslands”. (See release on WMI website: wildlifemanagement.institute.) WMI was careful to avoid any limitations or important uncertainties in the Order, or the associated Interior news release. WMI reiterates wordings provided by Interior, with little comment. Important information, buried in an appendix to 3410, was neglected.

Unfortunately, avoiding the uncomfortable issues in public discourse has facilitated persisting domestication of public-trust wild bison for decades.

This is the third Interior Bison Initiative since 2008. It is described as “establishing” a Bison Conservation Working Group; whereas a Working Group has also existed for 14 years. On balance, previous Initiatives and Work Groups have been able to make little on-the-ground progress in restoring wild, public bison on large landscapes. It is easy to be skeptical about another initiative. But hope remains.

WMI mentions Interior’s goals of “wild and healthy” bison, and a “viable” bison species; but does not define these terms. (We define “wild” as a herd influenced by a preponderance of natural selection – equal to Interior’s mandates for biotic diversity and integrity. “Healthy” has different meanings for individuals vs. for herds. With thousands of extant bison, the species is already “viable”.) The word “domestication” is not used, even though the foremost threat to a future with wild plains bison in the USA is domestication of the species.

Success of the Initiative is described as “depending upon” collaboration with states and Tribes. If this is 100% true, Interior is signaling retreat from its obligations to unilaterally manage National Park and Refuge resources, if collaborators supporting federal mandates for wildness are unavailable. History may be repeated.

WMI does not mention the overriding emphasis in 3410, upon Tribal needs and plans for Tribal co-management of public bison on public lands. A significant place for public-trust, wild bison in the Initiative is not assured.

WMI notes that Interior manages or co-manages 16 plains bison herds south of Canada. Only 10 of the 16 are under exclusive management of Interior in Parks and Refuges. In the other 6 herds, efforts to restore wildness according to federal mandates, can be much diluted by existing co-management. And only 2 of the 10 exclusively Interior herds are large enough to forestall random genetics that will weaken natural selection for wildness.

For public-trust, wild bison, the success of the Interior Bison Initiative will depend upon greater public understanding of the domestication vs. wildness issue and public support to fulfill the wildness mandates of federal Parks and Refuges. WMI can help to address this critical problem that has plagued restoration of wild bison for decades.

In that regard, we applaud WMI’s mention of a potential restoration of wild bison on the Charles M. Russell National Wildlife Refuge. It is the largest federal refuge within the historic range of plains bison. Significant restoration of public, wild bison likely cannot be achieved in the USA without a large herd on the CMR Refuge. We urge WMI to join us in aggressively promoting restoration of bison, under the 1997 Wildlife Refuge Act, on the CMR Refuge.

Interior has allocated $25 million to support the Bison Initiative. A two-track program, for Tribal and public bison, will be needed to use the funding fairly. The Biden administration has little time left. Any delay will jeopardize the program.

Interior Department Prioritizes Tribal Bison: Commitment to Maintain Wild Bison Uncertain

Coalition Promotes Two Equal Tracks for Interior Department Bison 

A March 4 Department of Interior News Release, based on Secretary Haaland’s Order 3410, describes a new federal commitment to restore “wild and healthy” populations of bison on American grasslands. It states that Native American led opportunities to establish new large herds owned or managed by Tribes will be centrally prioritized. A “shared stewardship plan” is described in 3410. As presented, shared stewardship implies co-management and some degree of co-control of public bison with Tribes. Unfortunately, “wild and healthy” are not defined, and neither the news release nor 3410 recognize laws mandating Interior to restore truly wild public-trust bison in National Parks and Refuges, and these documents do not acknowledge almost certain conflicts between these obligations and Tribal goals.

As background, a misrepresentation of 19^th century bison history occurs in the news release and in 3410. The complicated eradication and near extinction of bison is presented emphasizing a “U. S. policy” intended to “harm and control” Tribes that depended upon bison. This oversimplification of history is common in today’s media. In reality, bison were near-eradicated for several reasons including commercial harvests as well as to “control” Tribes. Both Euro-Americans and Native Americans participated, though not always equally or for the same purposes. A selective, biased presentation of 19^th century history should not be used to justify exceptional access to public bison for Tribes today. A more complete and authentic history would recognize our common humanity and be less divisive in today’s world. We cannot heal what we do not reveal.

Today, plains bison exist in private commercial herds, in Tribal herds, and in “conservations herds” owned by government agencies, The Nature Conservancy or by American Prairie. Only 13 herds are fully controlled by the Department of Interior. For plains bison in the USA, the most important conservation issue is the long-practiced and continuing domestication of bison with loss of wild genetics. Restoration and maintenance of wildness in bison requires a large herd to forestall effects of genetic drift, minimizing artificial selection practices, and maximizing natural selective forces, to the extent practicable. (See elsewhere on this website under the toolbar “Why Wildness”.) Most bison herds are small and subject to some, usually a lot of, artificial selection. Domestication is most pronounced in commercial herds containing the vast majority of plains bison. For bison in the USA, only 13 federal herds within National Parks and Wildlife Refuges have a reliable mandate, in the law, to restore and maintain wildness. These herds are critical to the future wildness of our plains bison.

The Department of Interior has dual obligations for bison management – centered in its Bureau of Indian Affairs, the National Park Service and the Fish & Wildlife Service. Tribal goals vary among tribes and have varied with time, as indicated by the limited but consistent information available for current Tribally-owned herds. Tribal goals appropriately emphasize Tribal nutrition and economic development, with management for abundant production. This emphasizes artificial selection that is not compatible with National Park and Federal Refuge mandates for wildness.

Today, 63 Tribes own over 20,000 bison (Intertribal Buffalo Council website). Almost all these herds are small such that genetic drift augments preponderant artificial selection. This compares to only 13 federal herds with about 10,000 bison. Only 2 of these federal herds have at least 1000 bison, possibly sufficient to forestall effects of genetic drift in weakening natural selection.

Despite the above disparity and the overwhelming threat of domestication to plains bison, Haaland’s news release and 3410 emphasize support for more Tribal bison, including “shared stewardship” and “prioritizing Tribal led opportunities” to enhance bison on federal lands. Mandates of the Department of Interior emphasizing natural selection that is not compatible with major Tribal goals requiring artificial management are relegated largely to an appendix of 3410. The stark inadequacy of Interior’s few, mostly small, bison herds to avoid further domestication is not mentioned.

The Charles M. Russell National Wildlife Refuge lies in the center of this disparity. It is the largest federal refuge within the historic range of plains bison. It has no bison, despite decades of efforts to promote restoration. It is the most obvious federal opportunity to establish a “large, wide-ranging bison herd subject to the forces of natural selection, where their role as ecosystem engineers shapes healthy and diverse ecological communities (Section 3,f; appendix to 4310). The Refuge Improvement Act (1997) provides a clear mandate for this important goal. Tribal co-management may be illegal and would threaten the necessity to minimize artificial management for bison production on the CMR.

The Bison Coalition has supported a two-track approach to achieving the goals of Haaland’s bison initiative. (See NEWS, August 11 and 21, 2021, this website.) We should support Tribal bison for Tribal needs on Tribal lands; but the critical status of federal bison, with but 2 large herds to save wild bison genomes, and Congressional mandates for the Park Service and for Federal Refuges, dictate a separate management track focused on bison wildness.

(Possible introduction of wild bison on BLM or Forest Service lands, likely under state management, is not addressed here. It will be politically difficult; but could occur based on Tribal political support. The subject of Tribal co-management of such bison on federal multiple-use lands is beyond the scope of these comments. Any devil would be in the details to be negotiated.)

Montana Senate Opposes Bison for the CMRussell Refuge

 

 By a vote of 34-16, the Montana Senate has passed Joint Resolution 14, opposing bison introduction at the Charles M. Russell National Wildlife Refuge. The resolution has been transmitted to the House of Representatives. (see more at leg.mt.gov)

The Resolution notes that the Federal Fish & Wildlife Service has identified the CMR Refuge as a potential location to restore public trust bison. (FWS has contacted potential stakeholders re this possibility. However, this Resolution was written before Department of Interior Secretary Haaland released Order 3410 with general details of a new DOI Initiative for bison restoration. Order 3410 does not mention any Refuge by name.)

The Resolution states that Montana has supremacy for wildlife management, even on federal lands including Refuges; and suggests that unilateral bison introduction by FWS would violate the U. S. Constitution. However, a review of this issue (Nie et al. 2017) debunks this states-rights position.

The Resolution asserts that bison restoration on the Refuge would jeopardize critical grazing land. There is very little, and infrequent livestock grazing on the Refuge. Very much of the surrounding grazing land is federal, Bureau of Land Management land, leased for a pittance. Studies have shown that bison grazing can enhance native grasslands whereas livestock grazing tends to damage the soil and flora, especially in riparian areas.

Also claimed is that bison would increase disease transmission between livestock and wildlife. We note that private commercial bison herds are abundant, with only rare transmission of disease to livestock, and more transmission from livestock to several wildlife species.

The Resolution fears for livelihoods of ranch families who may have to bear costs of unspecified “damages” caused by bison. It also mentions a potential loss of state revenue from small parcels of state land within the Refuge. We believe these issues would be minimal and can be handled in a fair manner, once FWS would prepare an impact statement for bison restoration.

The Resolution fails to note that the 2021 Montana legislature has already made bison restoration by the state impossible. Thus, FWS must act on its own to fulfill its legal mandates dating back to the 1997 Refuge Improvement Act of the federal Congress.

Thus, the Resolution proclaims the state of Montana opposes introduction of any bison on the CMR Refuge. However, three Montana polls have shown about 70% approval of bison for the CMR. The Resolution recognizes the state has a vested interest in the economic health of agriculture through disease control and promoting the much subsidized industry. No comparable interest in Montana’s biodiversity or the biotic integrity of Montana’s ecosystems, nor any ethical obligation to support any national goals are recognized.

Approval of SJ 14 by the Montana House of Representatives is expected.

Nie et al. 2017. Fish and wildlife Management on federal lands: Debunking state supremacy. Environmental Law 47:797-932.  

Long-term Study: Bison Facilitate Persistent and Resilient Increases in Grassland Plant Diversity

 

A 29-year study of year-round bison grazing¹ has demonstrated the value of this keystone species in restoring vegetative diversity in a Kansas Flint Hills tallgrass prairie. The study was conducted on the Konza Prairie Biological Station, administered by Kansas State University. Year-round bison grazing was compared to no grazing and to the common practice of seasonal cattle grazing.

Ungrazed plots were dominated by a few grass species, with minimal diversity of other species. Plant species diversity increased with both grazing treatments, especially for forbs (non-grass species). However, with bison grazing, the steady 29-year increase in native plant species was about twice that observed with cattle grazing. Many of the increasing species have been relatively rare and targeted for conservation in Kansas. Nonnative plant species remained uncommon. Bison-grazed communities now include a set of plant species that are nearly absent in the ungrazed and cattle-grazed treatments. Moreover, year-round bison grazing promoted plant communities that were resilient to a 2-year extreme drought.

In this study, the bison pasture was 3.8 square miles, where about 275 bison had free range. The pasture grassland contained a dynamic mosaic of fire frequencies. Our Coalition recommends at least 1000 bison on 100 square miles for rewilding bison and their associated biotic community. Under our recommendation, we expect the response of a plant community to bison restoration will be at least as diverse as in the Kansas study.

This study demonstrates, uniquely with long-term data, a need to reestablish public, wild bison on the Charles M. Russell National Wildlife Refuge, as mandated by Congress, to restore the overall biological integrity of the Refuge.

¹Ratajczak, Z. et al. 2022. Reintroducing bison results in long-running and resilient increases in grassland diversity. Proceedings, National Academy of Sciences 119(36):1-7.

See also, Olson, W. and J. Janelle. 2022. The Ecological Buffalo: On the Trail of a Keystone Species – reviewed here in an earlier News item.

Recognizing the Threat of Bison Domestication: 75 Years Ago

 

Elsewhere, we have noted historic recommendations to restore public, wild bison in Montana – from Hornaday in 1910 and Murie in 1937. To these, we add a 75-year old recommendation using the ominous “D” word!

In 1947, Victor Cahalane published “Mammals of North America” (Macmillan Co., NY), with general descriptions of 94 “species”. He devoted 11 pages to American buffalo. On page 74 we find:

“A big national monument should be established in the Great Plains area where a moderate sized herd could live under primitive conditions, together with other plains species. This would ensure the perpetuation of the animals as a wild species, free from the danger of domestication.”

Our cause is far from novel. It has persisted, but not yet prevailed. The Charles M. Russell National Wildlife Refuge is, by far, today’s best location to fulfill Cahalane’s recommendation.

Please see a new website article on the diversity of bison management practices that weaken natural selection and hasten domestication. Click on the “Why Wildness” toolbar.  

“Eco-cultural Restoration” of Bison: A Euphemism Disguising Incompatible Goals

 

 

“Eco-cultural restoration” has been suggested for returning plains bison to the Charles M. Russell National Wildlife Refuge in Montana. The term can be a slogan for proposed co-management of a Refuge bison herd by an Intertribal Council with the U.S. Fish & Wildlife Service. Such attractive slogans can develop public support without revealing conflicts inherent in the proposal.

We interpret ecological restoration of bison as fulfilling the mandates of the Refuge Improvement Act (1997) to restore biodiversity and biological integrity of the Refuge’s biotic community. More, we consider this mandate to be a restoration of “wildness”. Wildness is the opposite, in a continuum, from domestication. Here, wildness includes bison and their genome, and their relationships with their surrounding biota.

Cultural restoration refers to bison management focused on needs and goals of Tribal nations. Tribes would influence to what extent such needs and goals would be emphasized in co-management on the Refuge. However, recent history indicates that nutrition and economic benefits are overriding needs of the Tribes. A current publication (Shamon et al. 2022) concurs and suggests that management practices for wildness and for Tribal needs are not mutually exclusive and can be merged on federal lands.

However, restoring and maintaining wildness of a bison herd requires maximizing natural selection (to the extent practicable, a standard in the Refuge Improvement Act). This requires minimizing genetic drift and artificial selection that weaken and replace natural selection. Minimizing genetic drift requires a large herd. Minimizing artificial selection requires foregoing most management activities that increase annual production of animals. (Only human harvest of bison facilitates both production and natural selection. Human predation has been a major selective force in the evolution of the modern bison species, as discussed elsewhere on this website.)

Across existing Tribal bison herds, numerous management interventions constitute artificial selection. These are: much constrained bison mobility on monotonous ranges; pasture rotations; frequent capture and handling; selective culling; a skewed herd sex/age structure; forced weaning, frequent or emergency feeding; vaccinations and other disease management; lack or control of predators; and maintaining a stable herd at only a moderate ecological density. These diminish restoration and maintenance of wildness, for both the bison genome and its associated biota.

Co-management of federal bison is a false panacea. Efforts to enhance overriding Tribal goals will diminish achievement of “ecological” goals, as interpreted here. Efforts to achieve ecological goals will diminish attainment of important Tribal goals.

In contrast, Tribal goals for bison should be maximized on numerous Tribal lands; whereas biological diversity and integrity – wildness – is reliably mandated only on National Parks and Federal Refuges. Currently, there are only 13 such federal bison herds, and only 2 of these have at least 1000 animals to effectively limit genetic drift. The few opportunities to achieve these mandates on federal lands should not be compromised.

Shamon et al. The potential of bison restoration as an ecological approach to future Tribal food sovereignty on the northern Great Plains. Frontiers in Ecology & Evolution. 28 January 2022. 

 

 

Interior Department’s Bison Conservation Initiative May Accept Defeat Redefining “Wildness”

 This decade of the 2020’s, with a focus on endangered species, has brought what environmentalists describe as a “war on wildlife”. Centered in this war are two Department of Interior agencies, the Park Service and the Fish & Wildlife Service. The battles are politically difficult. Rather than lamenting defeat, and informing Americans of our continuing demise, the Department of Interior may simply redefine “victory”.

The Park Service is mandated to save ecosystems and species “unimpaired”. The federal Refuge System is mandated to preserve biodiversity and biological integrity on refuge lands. These mandates were generated by an American interest and passion for “wildness”.

But as our human population grows, requiring occupation and conversion of ever-more landscape, many components of the natural world either disappear or adapt to and become dependent upon domesticated environments. Wilderness and wildlife are disappearing. In public dialogue, failing to reveal and emphasize this trend fosters public indifference, allowing an ever-faster demise of natural resources.

We define “wild” as one extreme in a continuum from the other extreme of domestication. Wildness requires a preponderance of natural selection over the forces of artificial selection and genetic drift. As preponderance of natural selection declines, wildness is lost by degrees. “Wild” is a qualitative, not absolute, condition. The decline of wildness is a gradual, insidious process.

In its Bison Conservation Initiative, the Department of Interior commits to maintaining the wild character of bison, allowing forces of natural selection to operate – to the extent possible. But a recent Department release (Foundations for Recognizing Bison as Wildlife) emphasizes that “not all forces of natural selection” are necessary for bison wildness. It provides little discussion of how human-caused artificial selection and genetic drift diminish and replace natural selection, of the many management practices that comprise artificial selection, that loss of natural selection leads to domestication of the species, or that possibilities for natural selection are “impossible” only because of economic or political constraints. A commitment to maximizing biological wildness, to the extent practicable, is not emphasized. Gradual depletion of wildness is not recognized. The Foundations document allows federal bison managers to rationalize and accept artificially maintained bison as “wild”.

The Foundations document implies that what is politically possible in preserving wildness is “good enough”. We see too many non-government conservation organizations embracing this idea. The public, often unwittingly, gives government agencies mandates while also providing little decision-space for their fulfillment. The legacy of wildness to future generations is at stake.   

Article Recognizes Limitations of Tribal Herds for Rewilding Bison

 

 

A January article in Frontiers of Ecology and Evolution (cited below) reviews the potential of bison restoration for Tribal food sovereignty on the Northern Great Plains. Authored by Hila Shamon of the Smithsonian Conservation Biology Institute, the article has 30 co-authors representing numerous Native American Tribes and three major public conservation organizations (Defenders of Wildlife, Wildlife Conservation Society, World Wildlife Fund).

Diverse values of Tribal bison herds are emphasized: nutritional, economic/commercial, spiritual/cultural/educational values, and the ability of bison herds to ecologically restore native ecosystems on the Plains. These values are emphasized due to overriding and vital needs for nutritional and economic benefits to Tribal communities.

Authors barely, and indirectly, recognize the ongoing domestication and genetic deterioration of wild plains bison.

Moreover, the article injects a semantic complication into the social/political issue of bison domestication vs. recovery of wildness. We have always defined “rewilding” as a condition in which the genome-effects of natural selection are predominant over combined effects of human-caused artificial selection and genetic drift. This article defines this condition as “true restoration”. It defines “rewilding” as an imperfect version of true restoration: “the reorganization and redevelopment of the species and its ecosystem under new environmental conditions”. This justifies the continuing domestication of American plains bison, branding it with a misleading euphemism.

The article offers three Tribal herds in Montana and one in South Dakota as examples in which “overarching goals are to enhance the cultural, economic and ecological health of the Tribes and their lands”. Presented data on sizes of herds and “pastures”, and other management practices, demonstrate the contribution of these herds to plains bison domestication.

We do not criticize Tribal emphasis on nutritional, economic and cultural values in their bison management and agree these are overriding needs. They are exacerbated by limits of available Tribal lands, intermingling of non-Tribal lands within reservations, and by social aspects of competition from Tribal cattle operations on reservations.

Looking to the future, the article suggests allowing bison on large federal lands under Tribal/federal co-management. It is stated that rewilding and Tribal economic/nutritional/cultural benefits from bison “are not mutually exclusive”, implying that each can be produced to a satisfactory degree within one large herd. We disagree and have suggested that wildness, forestalling domestication of bison, will only be adequately maintained in a few large National Parks and Refuges suitable for large bison herds, according to the mandated missions of these agencies. The future of these bison and Tribal bison should proceed on different parallel tracks.

While the article describes Tribal efforts as “leading the way” in overall bison restoration, it clearly demonstrates that restoring wildness of bison and of their grassland ecosystem is not occurring in Tribal herds – and makes the contention that this wildness can be achieved with Tribal/government co-management on federal lands dubious.

Lasting political constraints, generated by the livestock industry and involving perceived states’ rights, prevent the wider USA population from counteracting domestication of plains bison and their habitats. The continued success of this political opposition to bison restoration on federal lands depends a great deal on the indifference of major non-government conservation organizations, including those co-authoring this article.

It is past time for major non-government conservation organizations to work both sides of the bison conservation fence!

Shamon, H. et al. 2022. The Potential of Bison Restoration as an Ecological Approach to Future Tribal Food Sovereignty on the Northern Great Plains. frontiersin.org/articles/10.3389/fevo.2022.826282/full

 

 

“The Ecological Buffalo”: To be Available in July!

 

 

 

We have been anticipating publication of “The Ecological Buffalo” by Wes Olson and Johane Janelle. The University of Regina Press has released a pre-publication announcement and sale, expecting shipment on July 9 (much delayed by COVID-caused shortages of paper and ink).

Wes Olson, now retired, has worked with and managed bison in Canada for 35 years. Johane Janelle provides stunning full-color photographs. UR Press describes the paperback book: “An expert on the buffalo tells the history of this keystone species through extensive research and beautiful photographs – a story that takes the reader on a journey to understand the myriad connections this keystone species has with the Great Plains.” The intricacy of relationships bison once had with thousands of species is the subject of this book.

This important work will inform and help justify efforts to restore public, wild bison herds to the Great Plains, including on the Charles M. Russell National Wildlife Refuge. In the USA, the Wildlife Refuge Improvement Act directs the Fish & Wildlife Service to restore, to the extent practicable, the biological integrities of wildlife and their ecosystems on our federal refuges. However, “biological integrity” is a term easily passed over by all but the most informed readers. We believe Olson’s book will, with numerous examples, demonstrate that the biological integrity of ecosystems of the Russell Refuge cannot be restored without bison. With occasional wildfire, bison were once the most important “managers” of what is now the Russell Refuge, including its native plants and other wildlife.

The Ecological Buffalo is a must-have reference for individuals and organizations that promote restoration of truly wild bison as a keystone species in some historic plains bison habitats.

We’ve ordered our copy of The Ecological Buffalo. Cost, including shipping is $51 Canadian dollars. To see more, visit uofrpress.ca/Books/T/The-Ecological-Buffalo.

Fish & Wildlife Service Manual Requires Federal Restoration of Biological Diversity and Biological Integrity on Charles M. Russell Refuge

 

 

In previous Coalition News items, going back at least 9 months, we have noted that restoration of public-trust, wild bison on the Charles M. Russell National Wildlife Refuge has been mandated, supported and confirmed by Congress in the Wildlife Refuge Improvement Act (1997), by the Department of Interior’s 2008 Bison Conservation Initiative (recommitted in 2012), and by goals of the Refuge Conservation Plan (2012). Here, we add the Fish & Wildlife Service Manual (2008) as a source for these clear commitments.

The FWS Manual summarizes policy, and guides employees in the management of resources under Service supervision. Appropriate sections are based largely upon mandates of Congress in the Refuge Improvement Act. The Act mandates maintaining and restoring, where appropriate, the biological integrity and diversity of the federal Refuge System.

The Manual defines biological diversity as the variety of life and its processes, including genetic differences and the ecosystems in which they occur. It defines biological integrity as the composition, structure and functioning, at genetic, organism and community levels, comparable with historic conditions, including the natural biological processes that shape genomes, organisms and communities.

These mandates cannot be fulfilled on the CMR Refuge without restoring a large population of bison, as a keystone species managed for wildness and influencing habitats for other plants and animals over a large and diverse landscape. Despite persisting opposition to bison restoration in Montana, the Service has never claimed that such restoration is “not appropriate”.

The Manual states “biological diversity and integrity are critical components of wildlife conservation” and “We will restore lost or severely degraded elements of integrity and diversity at the refuge scale.” Despite these mandates and repeated commitments, the Service has been waiting many decades for the state of Montana to reintroduce public bison on the CMR Refuge.

That said, the Manual states that the Service will coordinate with the state wildlife agency in a timely and effective manner and will ensure that federal management plans are, to the extent practicable, consistent with state laws. Clearly, Refuge coordination with Montana on restoring bison to the CMR has not produced timely or effective results. Moreover, any such restoration of bison cannot be consistent with recent state laws and therefore could not be practicable.

It is time for the Fish & Wildlife Service to proceed, without Montana’s blessing, with restoration of bison on the CMR Refuge -- obeying Congressional mandates and fulfilling the Service’s stated commitments. No doubt, the current Montana administration would appeal to the courts. But past courts have established a federal prerogative over management of resources on designated federal lands (Nie et. al 1917), and the Refuge Improvement Act should supersede state laws.

For many years, federal natural resource agencies have ceded most of their management authority and obligations for wildlife population management on federal lands to the states, even to the extent of ignoring Congressional mandates. Restoring bison to the CMR Refuge is a clear and extreme case and deserves bold action that would result in a landmark court decision. The legal door to bison on the CMR is open; only a closed political door prevents federal action to fulfill federal mandates and, so far, empty written commitments of the Fish & Wildlife Service.

Nie, M., C. Barns, J. Haber, J. Joly, K. Pitt and S. Zellmer. 2017. Fish and wildlife management of federal lands: Debunking state supremacy. Environmental Law 47 (4): 1-126.

 

 

 

Alaskans: On Indigenous Beliefs and Wilderness – Focus on Common Elements, not Differences

 

Artwork by Linsday Carron

 

A recent article from the Rewilding Institute, authored by a former U. S. Fish & Wildlife Service biologist and two Native Alaskans, cautions us not to focus on differences between traditional Indigenous beliefs and the “modern” wilderness concept. Rather, with the huge environmental threats that we all face, we should recognize what they have in common.

Roger Kaye worked for the U. S. Fish & Wildlife Service in Alaska for 41 years, as Native liaison and wilderness coordinator. He notes that early Indigenous people had no concept of wilderness, but neither did EuroAmericans before they were exposed to environmental degradations that led to developing the wilderness ethic. He cites the notion that “Wilderness” implies such pristine conditions that it fails to recognize the presence of Indigenous peoples on the prehistoric landscape - as an unfortunate misunderstanding. The notion is currently common within major environmental organizations, often justifying their diminished emphasis on Wilderness, replaced by support for “working landscapes”.

Kaye cites the Wilderness Act: “a place where man is [currently] a visitor and does not remain”, a place that appears to have been affected primarily by the forces of nature. He states the idea of Wilderness was a reaction against environmental threats of the industrial age. “It was certainly not at variance with the Indigenous people or their sustainable lifeways.”

Polly Napiryuk Andrews is Cup’ik Eskimo, working for the SouthCentral Native Foundation. She says “Too often we focus” on differences between the traditional world view and the Wilderness concept, “whereas commonality is what’s important”. She finds Indigenous traditional ways of expressing the relationships upon which our mutual well-being depends are reflected in early justifications of the Wilderness Act, recognizing dependence and interdependence, indebtedness, and responsibility.

Bernadette Dimientieff is Gwitch’in Athabaskan, pursuing protection of the Arctic National Wildlife Refuge and environmental justice. Her people have a spiritual and cultural connection with caribou that need the Refuge as a birthing ground. She states, “More than any other land category or management system, Wilderness recognizes our way of relating to the land and the Earth. The Wilderness idea that humans are part of a larger ‘community of life’ has been known to my people for millennia. We can live as respectful, interdependent, and low-impact members of this Earth’s community of life.”

The message of these Alaskans, to focus on commonalities rather than differences, applies to our issue of restoring wild bison to the Charles M. Russell National Wildlife Refuge. Our view is that restored public-trust bison should be managed, to the extent practicable, to maintain the wild plains bison genome, the underlying basis for wildness – not domestication. Management would be based on concepts of modern evolutionary genetics. This goal is supported in law and policy of the Fish & Wildlife Service.

In contrast, some Montana Tribes, backed by the National Wildlife Federation, have proposed restoration with Tribal-trust bison and an uncertain management priority for retaining wildness vs. priorities for commercial and nutritional needs of Tribes.

The Indigenous spiritual/cultural view that humans are part of a larger community of life is consistent with modern ecological thought. The view that humans and other animals are “related”, as Plains Tribes considered bison to be “brothers”, is consistent with evolutionary genetics. These common, most basic principles, generating respect based on interdependence and interrelatedness, should lead all of us to support management of CMR bison that emphasizes accepting natural selection, including allowance for great bison mobility – which is the most basic evolved trait of plains bison. There is currently no greater opportunity for achieving this goal, for all the American people, than on the CMR Refuge. Rejecting divisiveness, we all can “let bison be bison”.

 

 

 

Interior and Agriculture Departments Will Fulfill Trust Responsibility to Indian Tribes in Managing Federal Lands and Waters

 

In November, Secretaries of the Departments of Agriculture and Interior released a joint order to ensure that management of resources, including National Forests, Parks and Wildlife Refuges, and Bureau of Land Management lands, protects treaty, religious, subsistence and cultural interests of Native American Tribes. The wide-ranging order mandates Tribal collaboration in management priorities and activities for millions of acres of land, waters and their resources, including wildlife.

The order mandates “collaboration in co-stewardship” of Federal lands and resources, including wildlife and wildlife habitat. Notably, “co-stewardship” is a nebulous term. However, the order recognizes that activities must be “consistent with applicable law”. Laws include Congressionally mandated mission statements for agencies and for individual federal land holdings. Proceeding with some caution, the White House has ordered a legal review of land, water and wildlife treaty responsibilities, and a guidance document on the co-use of indigenous traditional ecological knowledge with science. These are to be completed within one year.

These directives could shape any action on the Coalition’s goal to restore public-trust, wild bison on the Charles M. Russell National Wildlife Refuge (CMR), which is already in an uncertain legal-political quandary. Questions that must be addressed include:

Are states’ rights subservient to federal Tribal treaty obligations that are older than statehood? States claim primary authority to manage most of their wildlife, especially hunting, even on federal land. While federal agencies have superior rights on federal lands, the Fish & Wildlife Service (FWS) almost always yields to the state assertion. Might FWS use treaty obligations to justify restoring bison on the CMR and eventually to conduct federal hunting seasons, both without the state’s blessing?

What would co-stewardship of a CMR wild bison herd look like? How will Tribes be represented and how will the rest of the general American public be represented. What, if any, priorities will be given to Tribal proposals?

To what degree can Tribal aspirations for bison be fulfilled while prioritizing the general American public and maintaining the genetic and ecological integrities of wild bison, as required in applicable law?

To what degree, must treaty, religious, subsistence and cultural interests of Tribes be fulfilled by CMR bison? Are these interests more properly fulfilled on multiple-use lands than on Refuge lands congressionally dedicated for natural ecosystems and wildlife?