Comment from Yaak Valley Forest Council

Submitted electronically June 1, 2023 to: https://www.regulations.gov/commenton/FWS-R6-ES-2022-0028-0001 Re: Protecting the American bison under the Endangered Species Act I am writing on behalf of the Yaak Valley Forest Council to give formal comment on the Proposed Upper Thompson Connectivity Project Conservation Easement. The Yaak Valley Forest Council, created in 1997, is a Montana based 501(c)3 nonprofit whose mission includes the conservation and restoration of critical wildlife habitat for the sensitive, threatened, and endangered species inhabiting the wild Yaak Valley, as well as protection of the last roadless areas in the Yaak Valley and the Kootenai National Forest. We strongly advocate for the listing of bison as an endangered species under the federal Endangered Species Act. Threats to the American bison that warrant endangered species protection: •The State of Montana’s cattle industry’s unreasonable intolerance for native wild buffalo. •The Interagency Bison Management Plan, a joint state/tribal/federal plan that facilitates the destruction of wild, migratory buffalo through capture-for-slaughter and -quarantine (domestication), excessive hunting, hazing, and unnecessary and harmful scientific experimentation, all to benefit Montana’s livestock industry. •Excessive hunting along Yellowstone’s North and West boundaries that blocks migration to available habitat, prevents restoration, and results in numerous pregnant females being killed. •The presence of invasive cattle along with accompanying fencing that takes away critical habitat. •Threats of diseases from invasive cattle. •Human developments such as agricultural lands, sub-divisions, roads, etc., that have all but destroyed ancient migration corridors and habitat connectivity. •Government-created “drop dead zones” and “intolerance zones” that prevent wild, migratory bison from accessing public and private lands. •The lack of safe passage infrastructure along dangerous highways, specifically U.S. Hwy. 191, which cut through a critical migration corridor in Montana’s Hebgen Basin. •The poor decision by the USNF Gallatin National Forest which denied wild, migratory buffalo Species of Conservation Concern status. •The draconian law, MCA 81-2-120, that gives authority over wild, migratory bison to the Montana Department of Livestock. •Climate changes resulting in accelerated rises in temperature and less precipitation that impairs these Ice Age mammals’ evolutionary potential, by threatening their ability to adapt to increased and prolonged heat. •Climate changes alters the composition of grasses and sedges rendering them less nutritious. •The failure of of state, tribal, and federal managers to consider the perspective of the buffalo in management decisions. •The refusal of the State of Montana to allow buffalo to migrate onto buffalo-friendly private lands. •The massive fence and cattle guard at Yankee Jim Canyon, north of the Gardiner Basin, that aims to prevent wild, migratory buffalo from accessing ancestral home ranges. •Wild, migratory bison exist on less than 1% of their historic ancestral home ranges. •The bison ranching industry which has reduced bison to livestock and has given the false impression that bison have been “recovered” throughout their native range. Thank you for the opportunity to comment and protect these wonderful animals.