Endangered and Threatened Species: 90-Day Finding for Three Petitions to List the Yellowstone Bison

The commenter is submitting a peer-reviewed scientific article from the journal *Biological Conservation* regarding a meta-analysis of minimum viable population (MVP) sizes. The document provides research data and methodology on population viability but does not express a specific stance on the proposed action to list the Yellowstone Bison.

A group of researchers and conservationists submitted an academic paper titled "The Ecological Future of the North American Bison" to provide a long-term, large-scale vision for bison restoration. The document outlines the "Vermejo Statement," which emphasizes inclusive, ambitious, and ecologically significant goals for the species over the next century.

The Wildlife Law Program of Friends of Animals argues that the Yellowstone bison should be listed as threatened under the Endangered Species Act. They provide scientific evidence regarding the bison's genetic diversity, current threats from habitat destruction and overutilization, and the inadequacy of current management plans to ensure long-term viability.

The Buffalo Field Campaign is submitting extensive research, source materials, and comments in support of the U.S. Fish & Wildlife Service's 12-month status review regarding the Yellowstone bison. They are providing data and evidence to support the listing of the Yellowstone bison as an endangered species.

Conservation Congress supports the listing of the Yellowstone Plains bison as a Distinct Population Segment (DPS) under the Endangered Species Act. They argue that the bison meet all five listing factors due to habitat destruction by the livestock industry, overutilization through slaughter, and the inadequacy of current management practices.

The Council on Wildlife and Fish, Native Ecosystems Council, and Alliance for the Wild Rockies argue that Yellowstone bison face significant and overwhelming threats from habitat loss, illegal hunting, and the Interagency Bison Management Plan (IBMP). They strongly urge the U.S. Fish and Wildlife Service to use emergency listing provisions under the Endangered Species Act to protect the species from extinction and habitat degradation.

Roam Free Nation, a native-led advocacy group, argues that the Yellowstone bison herds warrant protection under the Endangered Species Act due to severe threats from the Interagency Bison Management Plan (IBMP), habitat loss, and hunting. They contend that current management is failing to conserve the wild, migratory population and that federal intervention is necessary to ensure their survival.

The Council on Wildlife and Fish, along with the Alliance for the Wild Rockies and the Native Ecosystems Council, argues that the Yellowstone bison are being subjected to excessive killing and habitat loss due to commercial interests and poor management. They support the ESA listing as a necessary measure to protect migratory routes, end illegal fencing and hazing, and preserve the cultural significance of the bison.

The Council on Wildlife and Fish, Native Ecosystems Council, and Alliance for the Wild Rockies are urging the U.S. Fish and Wildlife Service to use emergency listing provisions to protect Yellowstone bison. They argue that the bison face significant threats from the Interagency Bison Management Plan, unregulated hunting, and habitat degradation, and that current management practices are inadequate.

The commenter, representing Great Old Broads for Wilderness and the Gallatin Wildlife Association, supports the listing of the Yellowstone bison to protect them from extinction and habitat loss. They argue that the federal government must assert supremacy over state agencies to ensure bison conservation and criticize the current management practices of the State of Montana and the U.S. Forest Service.