Mismanagement, Ineptitude, and Ignorance?

In Wyoming, Charges and Countercharges Fly Over Elk

By Todd Wilkinson, 5-24-06

Is the United States Fish and Wildlife Service "mismanaging" the internationally-famous wapiti herd that gathers every winter at the National Elk Refuge near Jackson, Wyo?

Did the federal government's supplemental feeding program at the refuge, which by concentrating animals has been blamed for producing a high percentage of brucellosis-infected elk, actually result in a higher death toll of elk calves in 2006?

Did refuge managers deliberately underfeed thousands of elk at the preserve in order to ensure that animals dispersed in search of natural forage?

Such are the charges being made by a controversial member of the Wyoming Game and Fish Commission named Clark Allan. By day, Mr. Allan serves as a deputy Teton County attorney.

During his free time, he has been a vocal member of the organization Sportsmen for Fish and Wildlife and has publicly stated his support for killing wolves and grizzly bears that venture beyond Yellowstone and Grand Teton national parks.

Allan's claims this week that National Elk Refuge managers are responsible for starving elk calves has caused an outcry now being heard throughout the Northern Rockies. Refuge manager Barry Reiswig dismissed Allan's allegations, published in the Jackson Hole News & Guide newspaper and cited in a 12-page letter to the Fish and Wildlife Service's regional office in Denver, as "ridiculous."

Allan says that as many as 25 percent of elk calves died at the Refuge this past winter compared to less than 1 percent mortality at state-run feed grounds. "Is it possible that some of the mismanagement on the refuge is intentional?" Allan wrote in an op-ed which appeared May 17, 2006 in the Jackson Hole News & Guide. He said the goal of refuge managers is to "maintain elk in a 'catatonic' state, or a state of semi-starvation where they lose considerable muscle mass but still survive until spring."

Defenders of refuge management and of Mr. Reiswig in particular, say that Allan is trying to create hysteria in order to serve his own antagonistic attitude toward the federal government and its successful restoration of both wolves and grizzlies in the greater Yellowstone ecosystem. Allan's critics dismiss his claim that as many as 25 percent of refuge elk calves died this winter as nothing more than uninformed "windshield biology

"These are wild animals and wild animals die," refuge manager Reiswig said. "There's no certainty we're going to carry every animal that winters—that's absurd."

Allan has also come under fire for writing his letter on official Wyoming Game and Fish Department letterhead.

For years, federal biologists and those working for the Wyoming Game and Fish Department have known that unnatural supplemental feeding of elk in winter has produced animals with a higher than average prevalence of brucellosis.

Montana Gov. Brian Schweitzer has been trying to broker a strategy for dealing with wandering Yellowstone bison known to be brucellosis carriers which are considered a threat to domestic livestock herds. But Schweitzer has also noted that in order to truly address the brucellosis issue, Wyoming needs to adopt strategies that reduce the incidence of disease in its large elk herds. In fact, elk have been incidentified as the likely source of transmission for brucellosis into Wyoming and Idaho cattle herds, which caused both states to lose their brucellosis-free status.

There is also concern that the Elk Refuge and state-sponsored feed grounds could become staging areas for possible outbreaks of bovine tuberculosis and chronic wasting disease.

While calls have been made to curtail artificial feeding, some sportsmen's groups have opposed the plan, saying that having fewer elk numbers would cause economic hardship for guides and outfitters in addition to resulting in fewer elk tags being issued to hunters.

In a rebuttal to Allan's claims, conservationist Robert Hoskins, a regular contributor to New West who lives in Crowheart, Wyo., has called upon Wyoming Governor Dave Freudenthal to remove Allan from the state game commission. Hoskins' letter to the governor is published below. Readers are invited to share their thoughts at the end of Mr. Hoskins' lengthy piece.

Dear Governor Freudenthal:

Recently, an individual whom you appointed to the Wyoming Game & Fish Commission, Clark Allan, a resident of Teton County, made a number of false and misleading allegations in a letter to the Fish and Wildlife Service regarding the management of the National Elk Refuge in Jackson Hole, Wyoming. These allegations reflect an unfortunate and unforgivable ignorance of elk ecology and best management principles for elk conservation specifically and wildlife conservation and management in general.

By making these indisputably misleading and false allegations, Mr. Allan has demonstrated a clear lack of knowledge and fitness for service as a Wyoming G&F Commissioner.

Additionally, although he claimed in the letter that he was writing as a private individual, he used the Wyoming Game and Fish Department letterhead, thereby giving the impression that he was officially speaking for the Commission/Department. Attempting to present his false allegations under color of Commission authority is highly improper.

Therefore, I recommend that you remove him from the Commission under the provision of Wyoming Statute 9-1-202(a).

Here's why Mr. Allan is wrong. His primary claim is that is that elk calves suffered 17 per cent mortality on the Refuge as a consequence of Refuge mismanagement. This claim demonstrates a profound ignorance of elk biology and ecology. It is well known to wildlife ecologists that a free-ranging, unfed elk population requires approximately only 30-35 per cent calf survival (more precisely stated as 30-35 calves per 100 cows) to maintain a herd.

Another way to look at this is that calf crops can suffer up to 70 per cent mortality over a period of years without affecting the size of a population. This means that calf mortality on the Refuge during the last winter, 17 per cent (or alternately, 83 per cent calf survival), is three times less than what is considered normal and natural by wildlife ecologists for a free-ranging, unfed elk herd. Furthermore, overall mortality for the Jackson Elk Herd last winter was three per cent, which is about average for fed elk but is profoundly abnormal for free-ranging elk.

The extremely low mortality of calf and adult elk on the Refuge is one reason why the Jackson Elk Herd is chronically 2,000 animals over its formal target or objective--an objective formally set by the Wyoming G&F Commission on which Mr. Allan unfortunately sits.

This chronic, decades-long overpopulation of elk in the Jackson Elk Herd is a consequence of artificial feeding; it fosters the transmission of disease and destruction of habitat. No one, not even the politically-motivated G&F Department, can reasonably deny this. Aside from manifesting unnatural levels of disease, the Jackson Elk Herd has severely damaged riparian areas and riparian vegetation in Jackson Hole and around the three State feedgrounds in the Gros Ventre River Valley. One reason moose are in trouble in Jackson Hole and the Gros Ventre is that too many elk have overbrowsed the moose's primary food source--willows. (The G&F claim that wolves are responsible for Jackson Hole's moose conundra is simply false).

Unfortunately, the Wyoming Game & Fish Department has had little success in bringing the Jackson Elk Herd down to objective, something that Refuge personnel have worried about since the 1940s (see Olaus Murie, "Our Big Game in Winter," Transactions of the Ninth North American Wildlife Conference, 1944, pps. 173-176). As Theodore Roosevelt noted in 1912 in commenting on the creation of the National Elk Refuge, if you don't kill enough elk in a herd by hunting, excess elk will die from something else (President's Commission on the Conservation of Jackson Hole Elk, 1927, pps. 9-10). Nothing has changed since 1912.

Mr. Allan's other major false claim is that Refuge mismanagement (failure to adequately feed elk) caused elk to starve to death or die of necrotic stomatitis, a common bacterial infection. This claim demonstrates a profound ignorance of the history of elk management on the Refuge and the important role of mortality in maintaining a healthy elk herd.

Even though the mortality of the Jackson Elk Herd is abnormally low from year to year because it is a fed herd, averaging around 3-5 per cent a year, all mortality cannot--and should not--be prevented, as Mr. Allan asserts. Elk are not livestock, even if Mr. Allan and others demand that they be managed as livestock.

When a wild herd exceeds the carrying capacity of its range, as the Jackson Elk Herd clearly does and has for decades, there will always be marginal, unhealthy, unfit animals that will succumb to disease, predation, or starvation. This is entirely natural; the death of marginal animals is essential to the health of any elk herd, not to mention the continued evolution of elk. Mr. Allan appears to be ignorant of this fact, but it was certainly clear to Theodore Roosevelt in 1912 and has been clear to wildlife scientists since then.

So, under the abnormal, high-density, game farm conditions that exist on the feedgrounds, there will always be a higher number of unhealthy, unfit animals in the herd that, were they not fed, would and should succumb. Mortality functions to maintain populations within the carrying capacity of their ranges and to ensure the health of animals that do survive. Artificial feeding distorts this important ecological function and is the primary contributor to an unhealthy, diseased Jackson Elk Herd.

Mr. Allan also refers in his letter to necropsies that G&F conducted this past February on 20 elk, which found both bacterial necroses and emaciation as the causes of death of these animals (additionally, one animal suffered from a broken femur, another from pasteurellosis, both natural hazards of elk).

Aside from the fact that 20 animals in a 13,000 plus elk herd do not a valid sample for statistical analysis make, it is also true that diseases, starvation, and injuries are natural in both free-ranging and fed herds, a fact well-established in the elk literature. These natural factors will, however, be more intense and devastating in a herd that chronically exceeds the carrying capacity of its range.

Regarding necrotitic stomatitis of the jaw or hooves, according to the great American biologist Olaus Murie, who studied the Jackson Elk Herd from 1927 until his death in 1964 and whose ecological expertise is unimpeachable, "There are ... two principle conditions that favor winter losses from necrotic stomatitis. One is overstocked range, where the animals are forced to eat too much coarse forage, thus causing injury ... and opening a channel for infection. The other is artificial feeding" (The Elk of North America, 1951, p.185). Artificial feeding is the reason that the ranges of elk in western Wyoming are overstocked.

I would note that even the G&F necropsy report, which Mr. Allan attached to his letter as "proof" of his allegations, acknowledges that the bacterium that causes necrotic stomatitis "is a normal inhabitant of the gastrointestinal tract and is therefore excreted in [elk] feces. The bacterium is not a pathogen of healthy animals." The bacterium is, understandably, widespread in the soil of elk ranges. As noted by Murie, the bacterium becomes toxic to elk when it enters the body through cuts or abrasions.

In any case, necrotic stomatitis on the Refuge and the 22 State elk feedgrounds goes back decades. On elk feedgrounds--the ground caked with the feces of elk at unnaturally high densities--Murie noted (above) that losses from necrotic stomatitis increase with the number of elk fed. For example, when over 10,000 elk were fed on the Refuge in 1942-43, 1,175 elk died of the disease. However, a decade earlier, when no elk were fed because snow cover was light and elk were able to spread out on natural forage, "the loss was negligible." In other words, the lower the densities of elk--the more widely distributed they are across the landscape--the more healthy they will be and the fewer that will succumb to the disease.

Perhaps G&F could inform the public how many elk die each year of necrotic stomatitis on the 22 State feedgrounds. A brief review of the annual G&F herd unit reports provides that information. I could work that information out from the herd unit reports myself but I would prefer that G&F do some proper, honest work for once.

One reason that the Refuge switched to alfalfa pellets in 1970 for feeding elk and abandoned the practice of feeding baled hay to elk is that necrotic stomatitis, most often brought on by cuts or abrasions to the gums of elk by coarse hay, was considered excessive. Switching to pellets has significantly reduced the number of elk deaths on the Refuge from necrotic stomatitis over the last thirty six years.

The other, more important reason that the Refuge switched to pellets is that elk consume the pellets more quickly and thus spend less time on the feedlines to spread out to spend more on the available range away from the feedlines, thus lowering their densities. This is the main reason that brucellosis seroprevalence in elk is approximately ten per cent less on the Refuge than the average seroprevalence on the 22 State feedgrounds.

The Refuge has proven that spreading elk out, not vaccinating them against brucellosis or conducting elk test & slaughter, is the key to reducing brucellosis seroprevalence in the elk of western Wyoming.

In short, the "findings" of the G&F necropsy report on these 20 elk from the National Elk Refuge reveal nothing remarkable, other than an extremely low incidence of natural factors of mortality as a consequence of feeding excess, unfit elk that would otherwise die.

I would also like to comment on Mr. Allan's allegation on page 2 of his letter that "Department biologists ... indicate that the loss of elk calves from the 2005/2006 winter will have a severe impact on elk numbers in the Jackson Hole elk herd for several years to come. Furthermore (sic), it will result in significant loss of hunting opportunity for Wyoming sportsman." As a Wyoming sportsman and elk hunter, I find this claim scientifically absurd. I've already shown that calf and adult losses in the Jackson Elk Herd, rather than being excessive, are minimal, and have been so for decades as a consequence of artificial feeding. Furthermore, I fail to understand how a herd that is 2,000 animals over objective would in and of itself cause a loss of hunting opportunities.

The problems with hunting the Jackson Elk Herd have nothing to do with levels of mortality, an ecological and biological issue, but with the unusual management scheme in place for the Herd. The most serious restriction on hunting opportunities for the Jackson Elk Herd is the Congressional prohibition on hunting west of the Snake River in Grand Teton National Park. This is why of the four segments of the Herd, the Grand Teton segment is significantly underhunted while the other three segments are arguably overhunted. The other problem with hunting is the presence of a major U. S. highway that runs along the western boundary of the Refuge and through the center of Grand Teton National Park. Aside from the safety issues, the highway contributes to the problem that locals call "the Firing Line." The Firing Line problem concerns the unfortunate spectacle of slob hunters blasting away at elk in constricted areas near roads where all can see it. Jackson Hole residents and responsible hunters have long complained about the Firing Line spectacle. The Park, the Refuge, and the G&F Department have long struggled with solutions to the problem, not very successfully, because of the overarching need to reduce the Herd to ecologically sustainable levels. So public pressure over the Firing Line is another factor in reduced hunting opportunities.

The best solution to the lack of hunting opportunities in Jackson Hole would be to convince Congress to permit hunting in Grand Teton National Park west of the Snake River. However, I'm not going to hold my breath waiting for Congress to make what would be a very politically unpopular decision.

Finally, I would like to bring to your attention that feeding elk on the Refuge is not required by law, as Mr. Allan seems to believe. The law that established the Refuge (16 USC 673 and 673a) specifically states that the purpose of the Refuge is to serve as a "winter game (elk) reserve ... for the grazing of, and as a refuge for, American elk and other big game animals ...." (The latter provision, by the way, takes care of the claim that bison don't belong on the Refuge).

In other words, feeding is not required; the legal requirement is to provide winter range for grazing, not stockyards for feeding.

The Refuge's charter is to manage elk and the Refuge as naturally as possible. Feeding is unnatural and abnormal; feeding is nothing more than a politically expedient, extra-legal policy derived from the selfish demands of politically powerful special interests (e.g., the livestock and outfitting industries), not the biological needs of wildlife nor the requirements of law nor the public interest. As noted in the Wildlife Management Institute book Elk of North America: Ecology and Management (1982, p. 501), "Sociopolitical considerations rather than principles of balanced resource management dictate the need for this practice [of feeding]."

In summary, it is undisputed among wildlife ecologists that elk feedgrounds violate the principles of wildlife management and grossly distort elk ecology and overall biodiversity in the ecosystem.

The Refuge has taken positive steps over the years to reduce the potential for the transmission of disease in the Jackson Elk Herd by changing feeding practices and working to widely distribute elk on the Refuge and surrounding Forest land and make more efficient use of all forage. The Refuge has accomplished a lot with not much land to work with--not even 30,000 acres. As chronic wasting disease marches toward western Wyoming's elk feedgrounds, the Refuge is doing far more than the Wyoming G&F Department to reduce the impact of this deadly disease.

The Refuge deserves our applause and support for its wise and practical decisions, not false allegations from individuals like Clark Allan who don't know what they're talking about.

In closing, no competent and honest wildlife ecologist or wildlife manager would support Mr. Allan's claims. His claims have no credibility whatsoever. Further, he made these personal claims as the self-appointed representative of the Department on G&F letterhead without the authority of the Commission. Mr. Allan clearly demonstrates a lack of knowledge and judgment necessary to serve as a G&F Commissioner. I urge you to remove him from office and appoint someone from Teton County who understands the complexities and needs of wildlife management and further will represent the public trust and not special interests.

Sincerely,
Robert Hoskins, Private Citizen
Crowheart, Wyoming

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