Part 2 of Kofa Letter

Other Parks, Government Agencies, And Scientists
Have Categorically rejected The Dabney Decision

The view expressed by the CSU veterinarians in their May 1995 letter is echoed by Oregon State University Veterinarian Dr. Stanley Snyder.

As a reason for keeping llamas out of areas of our national forests, etc., the threat of llamas disseminating Johne's disease to wild ruminants is quite remote. In Oregon, where Johne's disease in cattle, sheep and goats is quite common and where llama raising is extremely popular, we have not had even a single confirmed case of Johne's disease in llamas....

It is my opinion that reintroduction of wolves into the American West represents a threat to wild ruminants of many orders of magnitude greater than the remote possibility of spreading Johne's disease from llamas.

Ex. 9.

Since the prohibition on llama use was instituted in Canyonlands, other federal government officials have considered prohibiting llama access to public lands. To date, the Associations are unaware of any other prohibitions, with the exception of the prohibition proposed in the instant Draft Plan.

In April 1995, the National Park Service determined not to ban llamas in Glacier National Park. In an April 24, 1995 letter, Chief Park Ranger Stephen J. Frye explained that the available scientific evidence would not support such a ban.

After several months of information gathering, consultation and evaluation, Park officials have decided not to prohibit the use of llamas as pack animals in the park's backcountry. This measure was being considered due to the possibility that llamas could transmit Johne's Disease (a paratuberculosis) to native mountain goats and bighorn sheep.

Initial concern was raised by a Colorado State University veterinary pathologist at the 1994 Desert Bighorn Council Meeting. The occurrence of Johne's disease in a herd of bighorn sheep on Mt. Evans in Colorado resulted in some mortality and prevented that herd from being used as transplantation stock for other areas. The disease was also found in a domestic llama breeding operation in Colorado.

The spread of disease from domestic animals to native wildlife populations is a serious concern for park officials. The Superintendent of Arches and Canyonlands National Parks decided to ban llamas last summer to protect their bighorn populations, some of which are used for transplantation stock and others which are struggling due to various other diseases.

The overwhelming response to inquiries by Glacier National Park officials was that the actual threat posed to indigenous species by llamas was not significant. Johne's disease is very rare in llamas and the risk of transmission is considered minimal.

Ex. 10 (emphasis added).

In response to a June 27, 1995 memorandum from the Director of the National Applied Resource Sciences Center recommending a ban on the use of llamas on public lands based, at least in significant part, on information received from Mr. Dabney and officials at the National Park Service's Southeastern Utah Group, John Fend, the Area Manager of the Cascade Resource Area in Idaho, wrote a February 2, 1996 letter to the Director of the National Applied Resource Sciences Center. Mr. Fend's letter explained in great detail the genesis and spread of misinformation regarding the alleged paratuberculosis transmission by llamas. Mr. Fend urged that the BLM issue a policy statement that "the BLM does NOT intend to ban llamas from public lands based on disease conflicts or risks." Ex. 12. In his letter, Mr. Fend, who has spent the first 15 years of his career as a Range Conservationist, stated:

I must take professional exception to the recommendations to the Director on this subject. I strongly believe the National Park Service, and now the Applied Sciences Center, has misrepresented the extent of the threat/risk of Johne's disease associated with llamas being spread to wild ungulates. Further, I believe this document should have had internal peer review, as it certainly has national implications.

While the National Park Service may have legitimate reasons for restricting the use of non-native species within its boundaries to preserve the integrity of its contained ecosystems, the Park Service should not be using Johne's disease as the vector for it ban ... it's just not scientifically sound land management (see attached letters from the Colorado State University Veterinary Teaching Hospital and Oregon State University College of Veterinary Medicine.) Similar statements/positions have been offered by the Wyoming State Veterinarian, Dr. Beth Williams, the Idaho Fish and Game State Veterinarian, Dr. Dave Hunter, and Dr. LaRue Johnson of Colorado State University who is the leading Veterinary researcher on llamas in North America.

Your memo to the Director found its way into the hands of the Wildlife Management Institute, and an article was released in their Outdoor New Bulletin (10/27/95), indicating the BLM and BLM biologists have proposed a Public Lands ban on llamas because the llamas are carriers of Johne's disease. Since release of the Wildlife Management Institute's Outdoor Bulletin, a newspaper article appeared in the Salt Lake Tribune (1/24/95). Other papers have subsequently carried the story citing the Bulletin as the source.

These stories have lead to the rampant spread of misleading information which can have devastating economic effects on the llama industry. The Bureau must not be the source of such information, yet it appears it is.

Ex. 12 at 1-2 (emphasis added).

On February 2, 1996, Regional Forester Dale N. Bosworth issued a letter, after conferring with the Manti-LaSal National Forest, which has administrative responsibility for United States Forest Service ("USFS") lands in southeastern Utah. Mr. Bosworth reported that the USFS:

currently (has] no plans to restrict llama use on the Forest or to take permit action on outfitters and guides who provide llama services. They are aware of the concerns expressed by the NPS with disease transmission, but feel that there currently is not sufficient scientific information to warrant such a restriction on National Forest System lands in southeast Utah.

Ex. 13 (emphasis added).

Further, on February 7, 1996, Utah State Veterinarian Michael R. Marshal responded to an inquiry regarding the prohibition of llama use in the Utah national parks (presumably Canyonlands), memorializing his belief that the Canyonlands decision was not based on credible science.

....I have been told the reason [the National Park Service is] prohibiting llamas from the national parks is because of a perceived disease threat from Johne's disease to the animals in the park. If I understand the current research material correctly, there is a grand total of four llamas in the United States which have been shown to have Johne's disease. Likewise to the best of my knowledge, there is no research that shows this disease transmissible to big horn sheep or elk from llamas.

Speaking in terms of risk assessment and epidemiology, I believe the ban of llamas from national parks is a poor decision on behalf of the National Park Service. It is my impression that the National Park Service prefers to have llamas banned from the park for other reasons, and is using this medical statement about Johne's disease as an excuse to do so. It is difficult for me to understand why such medical decisions are reached for the state of Utah, without the input from Utah veterinary medical regulatory officials.

In summary, I do not believe that medical science support the ban of llamas in national parks.

Ex. 14 (emphasis added).

Finally, the Associations have recently learned that the Superintendent of the Glen Canyon National Recreation Area, which is adjacent to the Canyonlands National Park, will shortly issue a public reversal of the pack llama access ban that Glen Canyon instituted simultaneously with Mr. Dabney in September 1994 and based on information supplied by Mr. Dabney. The Glen Canyon Superintendent has indicated that he will state, as the basis for his reversal, that there is no credible scientific basis for his previously taken action. Promptly upon receipt, the Associations will submit to the Agencies a copy of the Glen Canyon reversal.

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