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Why CWD Striking Jackson Hole Elk Is A Big Deal

Is a Chronic Wasting Disease 'superspreader' event possible in the Greater Yellowstone Ecosystem? Experts say Wyoming, federal agencies have created conditions ripe for disaster

With the town of Jackson, Wyoming in the distance, visitors take a gander at elk, among several thousand wapiti that mass at the National Elk Refuge every winter. With the first case of Chronic Wasting Disease in a Jackson Hole elk confirmed in nearby Grand Teton National Park, wildlife officials worry about the deadly disease spreading to animals at the Elk Refuge. Photo courtesy US Fish and Wildlife Service
With the town of Jackson, Wyoming in the distance, visitors take a gander at elk, among several thousand wapiti that mass at the National Elk Refuge every winter. With the first case of Chronic Wasting Disease in a Jackson Hole elk confirmed in nearby Grand Teton National Park, wildlife officials worry about the deadly disease spreading to animals at the Elk Refuge. Photo courtesy US Fish and Wildlife Service

A Special Mountain Journal Report

By Todd Wilkinson

After years of continuous warnings from a chorus of wildlife disease experts, government whistleblowers and conservationists, the bad news no one wanted to receive has arrived: Chronic Wasting Disease has reached wild elk in the geographic heart of the Greater Yellowstone Ecosystem. Now, epidemiologists say, a high-profile unintended experiment in how a frightening disease spreads may be about to unfold.

Confirmation that a cow elk in Grand Teton National Park, killed by a big game hunter, has tested positive for the dreaded always fatal disease which strikes members of the deer family, was announced Friday, Dec. 18 by the Wyoming Game and Fish Department’s Wildlife Health Laboratory.

Scientists say that whether Jackson Hole CWD Elk Case No. 1 represents the start of a troubling new era for big game herds in America’s most iconic wildlife-rich region or possibly something much worse, the most stunning reality is that CWD is present among the most famous, migratory elk and deer herds on the continent. 

Although CWD’s arrival in Jackson Hole elk has long been anticipated, it is important to mention that solid evidence comes with no small amount of bitter irony. Early in the 20th century, Jackson Hole rose as a beacon in American wildlife conservation history when, in 1912, the National Elk Refuge was established as a rescue mission. Following winters when thousands of elk died from starvation owed to the fact they were unable to migrate out of Jackson Hole due to settlement blocking their traditional passageways, stranded wapiti on the flats stretching north of the town of Jackson were given supplemental rations of hay. As a result, it created an unnatural massing of elk in the high-elevation valley that previously did not exist prior to the arrival of white homesteaders.

Now, in more ecologically-enlightened times, this management practice is highly controversial. It is under withering scrutiny as disease experts say feeding, which puts elk at grave risk of catching CWD, could actually lead to the destruction of animals it was intended to save. But it is not merely a local concern.

Western Wyoming is home to the largest unnatural wildlife feedground complex in the world. Along with the Elk Refuge, there are another 22 elk feedgrounds operated by the state of Wyoming. In total, more than 20,000 elk will congregate in close quarters at those locations until spring, whereby they are highly likely to come in close contact with other CWD-infected wapiti or deer, experts say.

Most worrisome to infectious disease authorities is that Grand Teton Park, where Jackson Hole CWD Elk Case No. 1 was confirmed, is located immediately adjacent to the Elk Refuge where thousands of wild wapiti are again present. 

With an elk testing CWD-positive in the Jackson Elk Herd, and many of its animals wintering on the Elk Refuge, the Elk Refuge immediately started adhering to its “Disease Response Strategy” that is 19 pages long, Refuge Manager Frank Durbian told Mountain Journal. “I was not surprised [by confirmation of a CWD-positive elk]. I’ve studied the progression of CWD both within the state of Wyoming and across the country. It was not a matter of if CWD would get here but when. Unfortunately the when question just got answered.” Neither the Elk Refuge nor Wyoming Game and Fish have any plans to curtail feeding this winter—positions that have drawn sharp rebukes.

The Elk Refuge, in response to court action brought by the environmental law firm EarthJustice and conservation groups it represents, has been actively engaged in what it calls a “step-down” plan to wean elk off alfalfa pellets and hay over a course of years. But Dr. Tom Roffe, a veterinarian, research ecologist and former national chief of animal health for the Fish and Wildlife Service, penned a stinging critique of that plan. Worthy of note is that Roffe was lead author of a peer reviewed document published by the USGS put into wide circulation. It is titled Chronic Wasting Disease: Just the Facts.

The prime objective of the step-down plan, he notes, was “to mitigate the risk of catastrophic disease outbreaks by decreasing disease prevalence and transmission risks” but it “does not include a single disease prevalence- or transmission risk- criterion for assessing success.”

Moreover, Roffe noted that the step-down plan grew out of the 2007 Elk Refuge’s Bison and Elk Management Plan, which called for reducing elk numbers, to lower disease risk and prevent documented environmental harm to the refuge itself from elk overgrazing, has been a dismal failure. As Roffe notes, “that plan recognized that feeding wildlife (specifically elk) placed that resource at great risk of disease amplification and was antithesis to sound ecological management.”
Elk that survived decimation in the Greater Yellowstone Ecosystem at the turn of the 20th century have been used as feedstock to rebuild elk herds across the West. The Jackson Hole Herd is among several famous herds in the region numbering more than 11,000 strong. On any given winter, 80 percent of those wapiti get artificial nourishment at the National Elk Refuge. Photo courtesy US Fish and Wildlife Service
Elk that survived decimation in the Greater Yellowstone Ecosystem at the turn of the 20th century have been used as feedstock to rebuild elk herds across the West. The Jackson Hole Herd is among several famous herds in the region numbering more than 11,000 strong. On any given winter, 80 percent of those wapiti get artificial nourishment at the National Elk Refuge. Photo courtesy US Fish and Wildlife Service
A year after the Bison and Elk Management Plan was published, EarthJustice sued the Fish and Wildlife Service over alleged failures of the Elk Refuge to comply with a number of laws requiring it to make animal health a paramount priority.  Eventually, the case reached the DC Circuit Court of Appeals and jurists wrote in a scathing opinion, with the Fish and Wildlife Service promising to take step to reduce feeding and the size of the elk herd which is artificially large because it is fed.

"The whole point of a National Elk Refuge is to provide a sanctuary in which populations of healthy, reproducing elk can be sustained. See 16 U.S.C. § 673a (creating a “refuge” for the elk).," justices with the DC Circuit wrote. "The Refuge can hardly provide such a sanctuary if, every winter, elk and bison are drawn by the siren song of human-provided food to what becomes, through the act of gathering, a miasmic zone of life-threatening diseases.”

Despite the Elk Refuge pledging that it would make good and end feeding, and then implementing the step-down plan,  Roffe notes the refuge went backwards. Today there are several thousand more elk than the population target of 5000 recommended in the plan and most wapiti bunch up on the refuge. But even having 5000 elk being fed is hugely problematic, Roffe told Mountain Journal in 2019. He said that if CWD is confirmed in elk in the Elk Refuge and state feedgrounds “all bets are off because we don’t know how a major disease event will unfold but considering the ripe conditions for CWD to spread, it won’t be good.” 

° ° ° °

Classified within a family of prion diseases closely related to Mad Cow, CWD was first identified in Colorado in 1967 and since has spread to deer, elk and moose in 26 states and appears to be on the verge of soon reaching a dozen states more. The federal USGS, the government’s top biological/geological research bureau, says CWD has also been identified in over 175 captive cervid (deer family) facilities, many of them “game farms” where domesticated wild deer and elk are available for hunts, meat or parts such as antlers.
 
Until only recently, public awareness about CWD has mostly been present  among the 11.6 million Americans, including members of indigenous nations, who hunt to put game meat in their freezers.  According to the USGS, surveys of deer hunters suggest nearly half would stop hunting if approximately 50 percent of wild deer became infected with CWD or if CWD was ever shown to cross the species barrier from game animals to people.

Prions are not organic organisms like viruses and bacteria. They cannot be destroyed simply by cooking meat at higher temperatures. They are instead strange contorted proteins that cause irreversible incurable disease in the brains and central nervous system of victims. At present there is no CWD vaccine and none expected for the foreseeable future. 

Apart from the devastating consequences for wildlife populations, again there are elevated concerns that CWD could infect people who consume tainted venison and/or come in contact with hardy prions which are treated as a biohazard. So far, no cases of animal-to-human transmission have been recorded but the Centers for Disease Control advises that people not eat meat from animals that test positive.

CWD is characterized as a disease that typically is slow to take hold in elk and deer but over time, as infection rates rise, it can lead to population-level declines. Prominent wildlife disease experts, former Elk Refuge senior managers and an environmental attorney who has brought a lawsuit to halt feeding say that CWD reaching the Elk Refuge is unprecedented and could, because of the conditions, result in a “superspreading event.” 

Prions can be exchanged between elk, deer and moose through direct nose to nose contact and saliva. The agents also are shed into the environmental via urine, feces, gut piles, and decomposition of body tissue when animals die.  Upwards of 50,000 elk are believed to primarily inhabit the Greater Yellowstone region with tens of thousands more at its periphery in Wyoming, Montana and Idaho.  

What makes Jackson Hole geo-biologically unique, Roffe says, is that never before has the debilitating plague reached such a large concentration of wintering wild elk (or any deer family species) which, come spring, will disperse across thousands of square miles throughout the three-state Greater Yellowstone region. 
What makes Jackson Hole geo-biologically unique is that never before has the debilitating plague reached such a large concentration of wintering wild elk (or any deer family species) which, come spring, will disperse across thousands of square miles throughout the three-state Greater Yellowstone region. 
One of the cardinal rules in prevention and containment of a contagious disease is taking aggressive measures to limit possibilities for exposure, including minimizing large gatherings of potential victims and carriers. For decades, both Roffe’s former employer, the US Fish and Wildlife Service, which manages the Elk Refuge, and the US Forest Service which permits Wyoming to operate feedgrounds on federal public lands under its jurisdiction, have faced professional and judicial excoriation for being less than vigilant in taking precautionary action. 

Despite being presented with compelling scientific evidence that feeding wildlife and clustering animals together is the worst-possible form of management when dealing with communicable diseases such as CWD and brucellosis, both federal agencies, under pressure from Wyoming, have refused to halt the widely-condemned nourishment program.  

Wyoming governors, political appointees on the Wyoming Game and Fish Commission and members of the state’s Congressional Delegation have stalled the discontinuation of feeding because it’s what hunting guides and outfitters, as well as ranchers, desire. 
Outfitters and guides in Wyoming vociferously claim that if artificial feeding is phased out in the western part of their state thousands of elk will starve to death. It's a contention roundly disputed by a large group of professional wildlife biologists. In Montana's Madison Valley, thousands of wild elk, equal to the number in the Jackson Herd, pour out of Yellowstone and the Gallatin Mountains in the fall and winter,, without supplemental feed handouts in the high elevation valley between the Madison and Gravelly mountains. Photo courtesy Dave Showalter. To see more of Showalter's collectible work, go to dave showalter.com
Outfitters and guides in Wyoming vociferously claim that if artificial feeding is phased out in the western part of their state thousands of elk will starve to death. It's a contention roundly disputed by a large group of professional wildlife biologists. In Montana's Madison Valley, thousands of wild elk, equal to the number in the Jackson Herd, pour out of Yellowstone and the Gallatin Mountains in the fall and winter,, without supplemental feed handouts in the high elevation valley between the Madison and Gravelly mountains. Photo courtesy Dave Showalter. To see more of Showalter's collectible work, go to dave showalter.com
Guides and outfitters support feeding because it directly benefits them financially. Keeping more elk alive provides more wapiti available for clients to hunt. Ranchers wanting feeding maintained because they say it helps prevent elk from coming on their property and eating hay put out in the winter for cattle or exposing their domestic cows to brucellosis carried by elk.

Both groups claim that stopping or drawing down feeding would result in a massive die-off of elk—an assertion that has never been tested nor is there compelling research to suggest it’s true.  In a number of mountain valleys in Greater Yellowstone and throughout the Rockies, herds of wild elk are at or above population objectives without getting food rations from humans. 

Disease experts say, ironically, that feedgrounds bolster brucellosis infection rates in elk that disperse more widely around the ecosystem yet of graver concern is that feedgrounds will exacerbate the spread of CWD.

Wyoming Game and Fish spokesman Mark Gocke said confirmation of the CWD-positive elk in Jackson Hole brings the level of concern to a whole new level and noted, just as Game and Fish Director Brian Nesvik did months ago, that the state does not have plans to make any major immediate adjustments to operating feedgrounds.

“We continue to be concerned about the steady progression of CWD westward across Wyoming and of course this CWD-positive elk in close proximity to elk feedgrounds is of particular concern,” he said.  “It really underscores the importance of the public collaborative process we recently initiated, along with our partnering federal agencies, on state-managed elk feedgrounds in Wyoming. By engaging the public and going through this planning process we expect to get the best ideas on the table for managing CWD and elk in western Wyoming.”
Contract workers with the Wyoming Game and Fish Department distribute rations of hay to elk at the state-run Patrol Cabin feed ground in the Gros Ventre River drainage north of Jackson, Wyoming and east of the National Elk Refuge and Grand Teton National Park. Photo courtesy Mark Gocke/Wyoming Game and Fish
Contract workers with the Wyoming Game and Fish Department distribute rations of hay to elk at the state-run Patrol Cabin feed ground in the Gros Ventre River drainage north of Jackson, Wyoming and east of the National Elk Refuge and Grand Teton National Park. Photo courtesy Mark Gocke/Wyoming Game and Fish
Former Elk Refuge senior biologist Bruce Smith says the sincerity of that sentiment must be called into question. “The best ideas for managing CWD and elk in western Wyoming” have actually been known and touted for a quarter century—and that’s phasing out feeding, he said. Smith asserts that it’s the very same special interests that have refused to heed scientific warnings—and to whom the state now is giving deference to—who are using the guise of “public collaboration processes” as a stalling tactic to deny what it knows to be true.” 

Three years ago, the Elk Refuge convened a large group of scientific experts who warned about potentially dire consequences.  At that meeting, Rocky Mountain National Park was cited as a reference point. There, CWD infection rates in elk have in some years reached 13 percent and resulted in a dramatically declining herd. CWD is the leading cause of death there in elk.

Researchers have said that elk density in the park is one reason for facilitating faster spread of CWD in Rocky Mountain. What’s noteworthy is this: At the National Elk Refuge there are ten times more elk than at Rocky Mountain Park, they are clustered together in much smaller areas than at Rocky Mountain and they are on feedlots which is not the case at Rocky Mountain. 

On January 20, 2017, only weeks after the CWD forum was held in Jackson Hole, Eric Cole, a longtime Elk Refuge senior biologist, delivered a corroborating shot across the bow. Cole circulated information via email to wildlife colleagues and interested citizens that left many shocked. His informal report stated that CWD “infection in the Jackson elk herd is inevitable and possible at any time.”

Verbatim, his written assessment: “Population modeling predicts a wide range of CWD prevalence and effects on Jackson elk herd population growth rates in the short term (within 5 years) following introduction of the disease, but in the long term the effects of CWD on the health of the Jackson elk herd and recreational opportunities dependent on the Jackson elk herd will likely be significant and negative. For example at any level of CWD prevalence, current levels of cow elk harvest [e.g. hunting] could not be sustained.  The current supplemental feeding regime will exacerbate the effects of CWD on the Jackson Elk Herd because elk density at NER far exceeds elk density reported at Rocky Mountain National Park, which was the source of the annual infection rate used in the model.” 
Researchers have said that elk density in Rocky Mountain National Park in Colorado  is one reason for facilitating faster spread of CWD. What’s noteworthy is this: At the National Elk Refuge there are ten times more elk than at Rocky Mountain, they are clustered together in much smaller areas than at Rocky Mountain and they are on feedlots which is not the case at Rocky Mountain. 
Elk are fed on the same 5,000 acres of [the National Elk Refuge] each year, and “given the persistence of CWD prions in the environment, these areas will likely become heavily contaminated with the CWD prion over time if status quo management continues. 60-80 % of the Jackson elk herd use NER feedgrounds each winter, which will regularly expose these elk to CWD prions at these sites. Various elk migration studies and research on another disease prevalent on [the National Elk Refuge], (brucellosis), suggest that the current feeding regime and its associated high concentrations of elk could be a source of CWD infection for cervids throughout the Greater Yellowstone Ecosystem.”

Cole’s blunt acknowledgment, contradicting Wyoming’s sanguine stance, repeated warnings made by a number of his predecessors who spent careers in Fish and Wildlife Service uniforms and who were kindly advised it was better if they kept quiet. Reiswig, Smith, and other Elk Refuge managers refused to be muzzled.

Just months after the CWD forum and Cole’s warning, Wyoming State Wildlife Veterinarian Dr. Mary Wood stood before the Wyoming Game and Fish Commission and said, “If we want to really look at proactive management, the single most proactive thing we can do for feedgrounds in the face of CWD is to find ways to reduce reliance on feed before CWD ever hits.” She then noted, “We know that will occur. I would be doing my profession and the oath that I took as a vet a disservice if I didn’t say artificially concentrating animals over a feed source will facilitate disease transmission.”

Dr. Wood has since left Wyoming and today has the same job in Colorado. Following her departure, Wyoming in July 2020 released an updated CWD Management Plan and offered this assessment of the toll CWD is likely to take. “Initial modeling efforts predicted CWD would drive affected cervid populations to extinction. More recent projections suggest CWD may have significant population-level impacts in Rocky Mountain National Park elk, Wyoming white-tailed deer, and Wyoming mule deer. Other research suggests certain populations may be able to survive, bolstered by genetic selection and some level of hunting season restrictions,” Wyoming’s CWD Plan states. “Regardless, endemic CWD will likely depress some cervid populations at an unknown but potentially significant level. As such, management efforts designed to reduce the spread and prevalence of CWD are warranted.”

When asked directly if Game and Fish has any plans now to alter feeding at the state-run facilities, Gocke says the agency “will more intensively monitor feedgrounds and surrounding areas for any elk appearing ill or exhibiting clinical signs of CWD and those animals will be lethally removed, sampled, tested and properly disposed of in a timely manner. As far as any adjustments to feeding, we will continue to start feeding as late as possible and end feeding as soon as possible to shorten the feeding season or not feed at all where possible. And when we do feed elk, we will practice low-density feeding to the extent possible, to spread animals out and reduce the risk of disease transmission.”

Gocke put a positive spin on how Wyoming is dealing with CWD. “As far as what happens next, we are really encouraged by the early participation and feedback we've gotten so far in the feedgrounds public collaborative process. Of course, it's just getting started, but we are really optimistic that we will come away with a solid, publicly-supported long-term management plan with some innovative ideas for moving forward.”
Not a pretty sight: Photos of elk and deer afflicted with CWD, which is always fatal.
Not a pretty sight: Photos of elk and deer afflicted with CWD, which is always fatal.
Retired wildlife biologist Smith, who wrote a critically-acclaimed book about elk feeding and the menace of CWD, Where Elk Roam: Conservation and Biopolitics of Our National Elk Herd was not impressed with Gocke’s response nor with Wyoming’s CWD Management Plan. He said the state continues to dodge addressing the crux of the biggest wildlife disease threat facing Greater Yellowstone in modern times.

In its CWD plan, Wyoming Game and Fish recommends consideration of CWD suppression strategies utilizing an adaptive management framework developed by the Western Association of Fish and Wildlife Agencies (WAFWA) comprised of state and federal wildlife agencies. Notably, the WAFWA’s national governing body, the Association of Fish and Wildlife Agencies, recently issued a technical report identifying the best management practices for confronting CWD.

"To reduce the risk of CWD transmission and establishment of CWD through unnatural concentrations of cervids, states and provinces should eliminate the baiting and feeding of all wild cervids using regulatory mechanisms such as jurisdictional bans," the contributors and reviewers of the AFWA report, which includes Wyoming’s senior wildlife health official Hank Edwards, write. 

They go on: "From the perspective of control and management of infectious diseases, anything that aggregates animals will, in most circumstances, also increase the opportunity for disease transmission. While natural aggregations of animals exist due to a variety of behavioral, seasonal, and resource factors, human-associated aggregations related to baiting and feeding can greatly increase the risk of disease transmission due to increased animal numbers and concentrations over extended time periods. This can lead to exposure to larger doses of infectious agents, multiple exposures, or exposures sustained over prolonged periods of time all resulting in greater probability of infection."

Also in its CWD Management Plan, Wyoming defends continued operation of the feedgrounds. “Supplemental feeding of elk during winter was initiated to mitigate for the loss of winter range, reduce human/elk conflict, and increase elk overwinter survival. While elk feedgrounds continue to address those issues, they now also facilitate spatial and temporal separation of elk and cattle to reduce the spread of brucellosis.” 

Smith says the argument Wyoming uses is absurd. The state says feedgrounds are necessary to allegedly reduce the spread of brucellosis when, in fact, it is feedgrounds that are known reservoirs for brucellosis and are certain to be accelerants for CWD.  

Authors of the AFWA also refute Wyoming’s argument. "There is currently no evidence that baiting and feeding of free-ranging cervids can be conducted to mitigate increases in the opportunity for disease transmission. There is also no evidence the practice is likely to increase harvest sufficiently to overcome the negative effects of those increases by disease transmission” if and when animal mortality outpaces reproduction in a population.

Still another contradiction is that Wyoming’s CWD Management Plan has a literature citation at the end, listing numerous studies on disease management, CWD and epidemiology. Not one of the peer-review studies or articles suggests that concentrating large numbers of elk together with CWD in their midst is sound stewardship. Many indicate exactly the opposite. But it isn’t the first time that Wyoming wildlife officials have implied that when it comes to CWD and elk, the laws of disease transmission recognized by professionals in other states do not apply to Wyoming. 

“This [CWD-positive elk] isn’t likely to change anything for the state of Wyoming. Yes, they’ve been carrying out a public process, a series of events called ‘listening sessions’  but they began them by saying they had no intension of closing feedgrounds any time soon,” Smith says. “My view is Wyoming seems determined to not fix the barn door until all the horses are out.”

It would be one thing if all of this involved a population of white-tailed deer in the Upper Midwest, but Wyoming’s “obstinance,” he says, is putting the ecological integrity of the globally-renowned Greater Yellowstone Ecosystem at risk. Healthy ungulate herds are the basis for the tradition and economy of hunting. They are synonymous with Yellowstone and Grand Teton national parks, and they are the foundation for supporting robust predator and prey populations that tourists come from around the world to see.
What if there were fewer elk and they weren't fed? A view of the National Elk Refuge looking northwest toward the Tetons. Photo courtesy Ann Hough/ US Fish and Wildlife Service
What if there were fewer elk and they weren't fed? A view of the National Elk Refuge looking northwest toward the Tetons. Photo courtesy Ann Hough/ US Fish and Wildlife Service
Just as Wyoming politicians have been in lockstep with the coal industry in denying that carbon emissions from the burning of that fossil fuel is a major contributor to climate change, so too are its top elected officials and political appointees in expected alliance with outfitters, guides and ranchers in claiming CWD fears are overblown. The years have shown, critics say, that nearly all of Wyoming’s predictions about CWD—that it would spread slower than it has, that it wouldn’t severely impact deer, that there would be a vaccine, and that CWD might not reach elk on the feedgrounds—have been wrong.

A group called Concerned Citizens for the Elk has even taken out full-page ads in the Jackson Hole News & Guide claiming scientists are wrong and outfitters and guides have boisterously shouted down conservationists at public meetings. In filmmaker Danny Schmidt’s documentary, Feeding the Problem which aired on PBS, outfitter Harold Turner, concessionaire of the Triangle X Dude Ranch, has said it is better to wait for CWD to arrive and then take action rather than practice prevention.

On camera, legendary Jackson Hole outfitter Glenn Taylor seemed to represent the mindset of many when he said, “I’ve been asked about Chronic Wasting Disease before and I don’t think it’s as serious as they try to make you think,” he told filmmaker Schmidt. “Maybe today there’s too much scientific demand [reliance on science and the opinion of scientists). Maybe we need to ‘manage from the seat of our pants’ is a good term, I think. Let the animals kind of do their thing. We may be better off than trying to initiate or use too much science to manage maybe what science shouldn’t be doing that.”

Apparently lost on Taylor was that letting animals kind of do their thing would mean not feeding elk. You can view Feeding the Problem just by clicking here.

Barry Reiswig, former chief Elk Refuge manager now retired, says the moment is rapidly approaching when Wyoming’s willingness to deal with the feedgrounds in a rational, science-based way becomes too little, too late.  

“When should the state and federal agencies take preventative aggressive action? When did they know what was coming? Try two decades ago,” he said. “We’ve got a real mess now. This is potential Armageddon and a lot of people just don’t realize it. Some say we’ll come up with a vaccine, which we don’t have. Or that we’ll shoot the herd down until the disease is gone, which is nonsense. When you are concentrating that many animals and those few acres over time you are sowing the seeds of destruction.”

Bruce Smith, who had Reiswig as his boss, asserts that Wyoming has been able to have veto power over any action the Elk Refuge takes on feeding. Reiswig agrees, saying he experienced it firsthand. Back in the late 1990s, the Clinton Administration was poised to support the gradual phase out of feeding.

A proposal to make it happen was backed by Interior Secretary Bruce Babbitt and his assistant secretary Don Barry but when the George W. Bush Administration arrived in 2001, it was nixed by Paul Hoffman, who had the same post as Barry during the Bush Administration. Prior to his political appointment, Hoffman was director of the Cody Chamber of Commerce. “Mr. Hoffman knew what we were proposing to do and when we were together he said, ‘Not going to happen.’”

Reiswig says he and his superiors in the Fish and Wildlife Service were subjected to top-down political pressure exerted by Wyoming’s Congressional Delegation and the office of Vice President and former Wyoming Congressman Dick Cheney.

Another irony, he notes, is that Montana and Wyoming forbid individual citizens from feeding wildlife because of disease concerns and most states where CWD infection rates are rising have also banned the practice. Some states also have adopted a strategy of severely knocking down deer numbers or depopulating entire small local herds to prevent spread as well as banning the transportation of deer carcasses out of areas.  

Following an outbreak of CWD in white-tailed deer in southwest Montana along the lower Ruby River, the Montana Fish and Wildlife Commission has enlisted hunters to aggressively reduce the number of deer. In Wisconsin, millions of dollars have been spent on trying to severely depress white-tail deer numbers to lower the spread and incidence of CWD but those efforts have failed.

Research has demonstrated in both Wyoming and Colorado that animals can catch CWD merely by coming in contact with prion-contaminated soils. “CWD generally moves relatively slowly through wildlife compared to say, something like hoof and mouth and other diseases that are quick spreading,” Reiswig said. “My understanding is there’s no place in Wyoming that’s been shown to have the disease and then have it disappear from the area. The kind of crowding we see at the feedgrounds are perfect environments for CWD to really spread. Under natural conditions, it takes time, but when you have 5000 animals nose to nose and it gets into the soil with new animals coming in every year, who knows what will happen. We really are in uncharted territory. The whole country will be watching.”

Tim Preso, senior attorney for the environmental law firm EarthJustice, which is representing several conservation organizations in again suing the Fish and Wildlife Service to phase out feeding at the Elk Refuge, responded with incredulity and condemnation. “It is long past time to recognize that it is completely irresponsible wildlife management to continue crowding elk together on feedgrounds with chronic wasting disease on the refuge doorstep.  If the experience of coronavirus has taught us anything, it is that crowding spreads disease,” Preso told Mountain Journal.

“Unfortunately the U.S. Fish and Wildlife Service is now running an annual superspreader event for elk in the form of the winter feeding program. This program threatens to infect large numbers of elk, contaminate the refuge environment with infectious material, and spread chronic wasting disease throughout the Greater Yellowstone Ecosystem.  The Service needs to take immediate steps to begin weaning elk from artificial feed while we still have a chance to avoid the worst impacts of CWD.”
“Unfortunately the U.S. Fish and Wildlife Service is now running an annual superspreader event for elk in the form of the winter feeding program. This program threatens to infect large numbers of elk, contaminate the refuge environment with infectious material, and spread chronic wasting disease throughout the Greater Yellowstone Ecosystem."  —Tim Preso, senior attorney with EarthJustice
The Elk Refuge’s Durbian is in a tough position, observers say. The Elk Refuge’s own disease response strategy very clearly prescribes what managers ought to do to prevent disease from arriving and spreading. “One basic epidemiological principle serves as the foundation for a response to CWD at the National Elk Refuge: Limit transmission of prions to susceptible animals and limit contamination of new geographic areas to the greatest extent possible,” the document reads. “These actions are taken in an effort to minimize the population impacts of CWD on wildlife utilizing the refuge.”

Durbian this week said the Refuge still plans to feed elk if heavy snows arrive preventing elk from having access to adequate natural forage. Wyoming and the Elk Refuge, in their own CWD plans, puts a lot of stock in surveillance both through testing but also visual observation. “If CWD is detected in elk inhabiting feedgrounds, [Game and Fish] Department personnel will monitor the feedground and surrounding area intensively. Any elk exhibiting clinical signs of CWD shall be lethally removed, sampled, tested, and properly disposed of in a timely manner. Large- scale culling of elk on a feedground and on native winter range is not an anticipated action to address CWD.”

Roffe scoffs at this, noting that there probably won’t be any overt clinical signs of CWD in many affected animals and that by the time an animal looks sick, transmission of prion contagions to other animals has already happened. 

The first hint that an elk case might be imminent in Jackson Hole came in November 2018 when an asymptomatic mule deer buck tested positive for CWD in Grand Teton Park. Up to that point, a state wildlife biologist had claimed erroneously  that there appeared to be something in the environment preventing CWD from crossing the east side of the Continental Divide to the west and reaching wildlife in Jackson Hole. At the time the Elk Refuge CWD response strategy was crafted, the closest CWD detection in elk was 140 miles to the east in the Bighorn Basin. 
An outbreak of CWD that begins in Jackson Hole is not going to stay confined to Jackson Hole, epidemiologists say. Indeed, as illustrated in this map from the Wyoming Migration Initiative, elk from Jackson Hole stream into Yellowstone during summer where they come in contact with other herds that disperse widely across the three-state region.  Infected elk, whether asymptomatic with CWD or not, will live for a few years after they contract the disease and shed prions through their saliva, feces, urine as they migrate.
An outbreak of CWD that begins in Jackson Hole is not going to stay confined to Jackson Hole, epidemiologists say. Indeed, as illustrated in this map from the Wyoming Migration Initiative, elk from Jackson Hole stream into Yellowstone during summer where they come in contact with other herds that disperse widely across the three-state region. Infected elk, whether asymptomatic with CWD or not, will live for a few years after they contract the disease and shed prions through their saliva, feces, urine as they migrate.
Elk and deer range widely and this points to another concern. On Dec. 21, 2020, Wyoming Game and Fish circulated another press release noting that another elk tested positive for CWD in Elk Hunt Area 67 north of Dubois, Wyoming in the southern Absaroka Mountains. It caught the attention of Lloyd Dorsey who for years had led the Sierra Club’s analysis of CWD issues in Wyoming but who has since retired. Dorsey also hunts deer and elk to put game meat in the freezer.

He pointed to a map provided by Game and Fish that showed where the CWD elk north of Dubois was killed. “In my opinion the location map also helps bring into focus the discovery of the CWD-positive elk in Grand Teton Park earlier this month,” he said. “It indicates that the disease is likely in elk that range from the Bighorn Basin through the Absaroka Mountains, into the Jackson Hole area. Additionally, the studies of collared elk by the partners of the Wyoming Migration Initiative and Montana’s wildlife managers, in their excellent maps of elk movements throughout the Greater Yellowstone Ecosystem, show that all Greater Yellowstone elk herds mingle over time.”

Coupled with the specter of environmental contamination occurring at the Elk Refuge and Wyoming’s 22 feedgrounds,  there are  indeed concerns about how elk leaving those sites then, in spring, fan out toward summer habitat. Yellowstone Park, for example, is a place where several different elk herds converge from different directions, including wapiti from Jackson Hole, and then intermix. 

It is not inconceivable that an elk that becomes infected with CWD at the Elk Refuge might come in contact with elk from eastern Idaho or the Madison Valley of Montana, possibly with members of the Northern Yellowstone Herd that spend winters in Paradise Valley or with elk that head east to the Bighorn Basin. And, of course, CWD infected animals would be shedding prions along the way.  Hence, that’s what scientists mean by potential superspreading. 

What happens  if and when elk and deer in Yellowstone contract CWD and drop dead from disease. As best officials know, CWD isn’t in Yellowstone yet but there’s no reason it isn’t there either.  “If epidemics lead to widespread population reductions in Yellowstone, CWD could indirectly alter the structure and function of this ecosystem during future decades; adversely affect species of predators and scavengers; and have serious economic effects on the recreation-based economies of the area,” authors of Yellowstone’s CWD Surveillance Plan write. 

“No strategy has been effective at eradicating CWD from areas where the disease is present," the document further states. "Thus, our disease management objectives will focus on early detection and monitoring. CWD management is a long-term commitment of personnel and funding because reducing transmission risk factors and prevalence by any conceivable approach will take many decades. Implementation of this plan could be expensive and exceed the park’s current financial capability with regards to wildlife disease management.”
“If epidemics lead to widespread population reductions in Yellowstone, CWD could indirectly alter the structure and function of this ecosystem during future decades; adversely affect species of predators and scavengers; and have serious economic effects on the recreation-based economies of the area."  —A passage from Yellowstone's CWD Surveillance Plan
Yellowstone provides summer range for more than 10,000 deer and elk from multiple herds. “Surveillance for the majority of these populations is difficult because they are widely distributed in high mountain habitats during summer and winter at lower elevations outside the park,” authors of Yellowstone CWD Surveillance Strategy add. "Also, deer and elk from different populations intermix during summer, making it impossible to differentiate animals from different target populations and difficult to define sampling units.” 

Yellowstone officials say they will readily remove and test animals that appear sick or those struck and killed by vehicles, though they acknowledge it can be difficult telling the difference between an animal left lean and haggard by winter only to die in spring and an animal in the early stages of CWD. The plan also calls for, when possible, collecting tissue samples from wolf-killed elk, deer and moose and testing soils in areas where larger numbers of those animals gather.

Moreover, the Elk Refuge CWD response strategy alludes to how insidious CWD can be. Once an elk, deer or moose is infected, it can take around 16 months for the animal to appear ill, though it is still shedding prions and potentially getting shot and eaten by hunters if they don’t have it tested for disease. The elk shot by a hunter during Grand Teton’s annual “elk reduction program” had already been butchered before word reached the hunter about disease confirmation.
How will CWD impact wildlife in Yellowstone? Part of the park's CWD surveillance plan is identifying animals that appear ill or in physical distress. These bull elk are not sick with CWD but left haggard and fragile by a long hard winter.  Knowing whether an animal has CWD or is just weakened by the elements could prove difficult. Photo courtesy Diane Renkin/NPS
How will CWD impact wildlife in Yellowstone? Part of the park's CWD surveillance plan is identifying animals that appear ill or in physical distress. These bull elk are not sick with CWD but left haggard and fragile by a long hard winter. Knowing whether an animal has CWD or is just weakened by the elements could prove difficult. Photo courtesy Diane Renkin/NPS
The Elk Refuge has a monitoring program that requires hunters of harvested elk to provide heads for testing. In 2020, 312 tissue samples were submitted to a lab, pertaining to 272 hunter-killed elk, road killed wapiti or other causes of death. Every one has come back negative.  “Our sampling here is robust,” Durbian said. "We are sampling at a high level and can detect a prevalence rate of less than one percent.”

At present, only dead animals can be tested for CWD. Occasionally live animals are killed to be tested. However, it is possible that one or several CWD-infected elk or deer could wander around live and remain undetected for a couple of years.

Although the times before symptoms appear can vary, death often occurs within two years after infection, meaning an elk could get infected on a Wyoming feedground and make two full trips back and forth between winter and summer ranges, coming in contact with other wapiti and dropping infectious prions into the soil. 

Key to slowing the proliferation of any disease is some semblance of contact tracing, so that epidemiologists can get a handle on the source of hot spots and whether different strains are emerging. Still looming is the question of potential CWD transmissibility from infected elk, deer or moose to humans via game meet consumptions. To date, that hasn’t happened. Should it ever occur, the Elk Refuge action plan calls for an incident command to be established. 

° ° ° °

Wyoming makes several assertions in its 2020 CWD Plan that wildlife disease experts characterize as dubious, such as claiming the results of CWD reaching feedgrounds cannot be predicted. “Potential impacts from CWD on feedground elk populations are largely unknown, although it is possible that CWD prevalence within feedground elk may exceed that of unfed elk,” authors of Wyoming’s plan write.  

However, the document also acknowledges what is widely accepted in every other state dealing with CWD: “In general, disease transmission can be correlated to the density of animals in a given area, as well as the frequency of contact between animals. It is assumed that if the disease becomes established, artificially concentrating elk on feedgrounds may result in more rapid spread of CWD and contribute to increased persistence of prions in the soil and uptake by vegetation.”

The report also contains recommendations that epidemiologists say makes no sense. “Where possible, elk feeders [will] work to expand their feeding areas in order to feed on clean snow and new areas to increase the opportunity for elk to feed on areas with less biological contamination each day. This helps reduce the effects of environmental contamination of the feeding area,” the Wyoming CWD plan states.

Not only does spreading out feeding, when it involves large numbers of elk year after year, actually lead to more contaminated areas, Roffe says, but it discounts the fact that if infected animals are urinating, defecating, spewing saliva and dying, invisible prions will persist beneath clean or sullied snow. 

Prion uptake in plants is being studied at the USGS National Wildlife Health Center. Photo courtesy USGS/Christina Carlson
Prion uptake in plants is being studied at the USGS National Wildlife Health Center. Photo courtesy USGS/Christina Carlson
Another part of the plan references an issue that could radically expand concern about CWD to farmers, ranchers and consumers concerned about the food they buy at the grocery store. Laboratory experiments conducted in Texas and at the National Wildlife Health Center in Madison, Wisconsin, have shown that prions infecting soils can be taken up in the roots and tissues of plants such as alfalfa, corn, tomatoes and wheat grass. Could prion presence in those monoculture crops increase the possible risk of CWD crossing the species barrier to livestock and people. No one knows for sure but  CWD experts say the more that prions are moved around, the more they mutate and different CWD strains emerge, the more that they are consumed or absorbed through contact, the better the chances of CWD crossing a species barrier from cervids to other mammals, including humans, wildlife and livestock. 

“Prions are primarily retained in surface soils and the close contact of ruminant animals with soils renders soil-bound prions a likely source for prion disease transmission through ingestion or inhalation,” authors of a study published in Plos Pathogens wrote. “Therefore, prions binding to soil may increase the bioavailability of prions for transmission. Inactivation of soil-bound prions will be required to control and prevent the spread of prion diseases in the environment.”

This, then, raises a question: how could thousands of acres encompassing feedgrounds and the Elk Refuge be decontaminated in a way that renders prions inactive and unlikely to infect elk and deer year after year? 

In places like the lower Ruby River corridor in southwest Montana where the infection of rate of white-tailed deer tested in a hunting unit exceeded 40 percent, how are those deer not shedding prions into the environment in a way that won’t result in chronic infection of deer and potentially grasses there?

Wyoming’s CWD Plan goes so far as to acknowledge that hay from CWD endemic areas—therefore potentially contaminated with prions— should not be fed to elk at the Elk Refuge and feedgrounds.

“Based on research that grass plants can bind, retain, uptake, and transport prions, the potential prion transmission risk of contaminated hay harvested from the CWD endemic area being fed at state elk feedgrounds should be considered,” authors of Wyoming’s CWD plan note. “Prior to hay being purchased and transported to elk feedgrounds, the [Wyoming Game and Fish] Department will consider the spatial and temporal relationships between the location of potential source hay fields and the prevalence and distribution of CWD in cervids in these areas. Additionally, the Department will communicate with the appropriate land management agency(s) as it pertains to hay use and CWD at elk feedgrounds.”

The gist is this: Be it elk, mule deer or more prolific white-tailed deer moving across or wintering on private ag lands, should CWD become established in the hundreds of thousands of wapiti and deer,  will it result in prion hotspots?  The fact is that, as of now, nobody knows but the potential of it happening is a frightening proposition, says veterinarian Tom Roffe. He has said for years that the looming threat should cause the Fish and Wildlife Service, Forest Service and Game and Fish to be guided by the precautionary principle, which means agencies act now to prevent CWD from expanding and turning the entire Greater Yellowstone Ecosystem into a CWD endemic area.  

° ° ° °

In his critique of the Elk Refuge feeding step-down plan, Roffe expresses incredulity that a landscape-level infectious disease like CWD is not being met with a comprehensive strategy from federal and state agencies in the three-state Greater Yellowstone region. 

“Wildlife on National Wildlife Refuges and National Park lands in the US is a public trust managed for the benefit of all citizens, not just a few, and not just the state of Wyoming,” Roffe wrote. “Further, the federal agencies must manage in accordance with their enabling and governing legislation. The Fish and Wildlife Service has an obligation under the Bison Elk Management Plan and its Environmental Impact Statement, as well as the National Wildlife Refuge Improvement Act, to manage for healthy populations, ecological functioning and biological integrity on the National Elk Refuge and other lands under its jurisdiction to provide  THAT  specific value for the American public.”

With two parks, five different national forests, BLM lands and three national wildlife refuges in the region, the Greater Yellowstone Ecosystem is big. An entity called “The Yellowstone Coordinating Committee” is comprised of top federal agency managers and  has, for decades, touted itself as a leader in promoting problem-solving beyond and across jurisdictional boundaries. 

Yet bewildering to conservationists is that while some agencies have written general plans for responding to CWD, there is not yet a single uniform strategy for addressing CWD in a way that recognizes elk and deer moving in long distance migrations, across the lines of three different states, 20 different counties and a mosaic of federal, state and private land. Durbian noted, just as his predecessor Brian Glaspell did, that no coordinated plan exists, which disease experts say is exactly what’s required if there’s any hope of preventing multiple CWD flareups.

Three autumns ago, the Montana Fish and Wildlife Commission sent a letter to Wyoming requesting that feedgrounds move toward a phase-out of feedgrounds, noting that they represented high risk factors for disease spread into Montana. The overture was ignored. For one state to defy a neighbor’s desire to not want more cases of a contagious disease creeping across its border is problematic. 

“This wakeup call of having a CWD-positive elk in Jackson Hole isn’t likely to change anything for the state of Wyoming,” Smith says, noting that the state’s latest stalling tactic has been asking citizens what they want rather than heeding an overwhelming body of scientific evidence.”

Reiswig says that in the case of the Elk Refuge, the only way feeding will be stopped is if an edict comes down from the Fish and Wildlife Service Director in Washington DC, or arrives via a federal court order compelling the Elk Refuge to take action, or involves an act of Congress. He predicts Wyoming will fight those possibilities until it can no longer deny the facts.
“Heaven help us if a human ever catches a case of CWD or if the number of CWD cases explodes in Wyoming in our region. At that point, the response will be not asking what we should be doing, but who is going to take the blame?”  —Former Elk Refuge chief manager Barry Reiswig
“Heaven help us if a human ever catches a case of CWD or if the number of CWD cases explodes in Wyoming in our region,” he said.  “At that point, the response will be not asking what we should be doing, but who is going to take the blame?”

Perhaps the closest thing to a mea culpa for inaction coming from Wyoming is this passage in its CWD plan, which people like Roffe, Reiswig, Smith and others agree with.

“It is incumbent upon wildlife managers to explore ways to manage CWD prevalence and contribute to the broader understanding of effective CWD management. Since the initial discovery of CWD in 1985 in a free-ranging mule deer in Wyoming, the Department has not implemented any formal strategies to combat the spread or prevalence of this disease,” authors of the Wyoming plan write. “Unfortunately, CWD has since been documented throughout most of the state, with many mule deer and white-tailed deer herds now exhibiting CWD prevalence levels high enough to potentially impact population performance. The need to develop proven methods to manage CWD is now readily apparent, and doing nothing to combat this disease is no longer acceptable, a sentiment strongly echoed within hunter survey data.”

Connie Wilbert, state chapter director for the Sierra Club in Wyoming, one of the groups that sued to compel the Elk Refuge to halt feeding says, “There is no time to waste. We need to start phasing out elk feedlots now, before a chronic wasting disease epidemic decimates wildlife in northwestern Wyoming and the entire region.”


Todd Wilkinson
About Todd Wilkinson

Todd Wilkinson, founder of Mountain Journal,  is author of the  book Ripple Effects: How to Save Yellowstone and American's Most Iconic Wildlife Ecosystem.  Wilkinson has been writing about Greater Yellowstone for 35 years and is a correspondent to publications ranging from National Geographic to The Guardian. He is author of several books on topics as diverse as scientific whistleblowers and Ted Turner, and a book about the harrowing story of Jackson Hole grizzly mother 399, the most famous bear in the world which features photographs by Thomas Mangelsen. For more information on Wilkinson, click here. (Photo by David J Swift).
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