The Department of Livestock is not enforcing the required Designated Surveillance Area rules.

• The Department of Livestock’s “current compliance and oversight process does not directly monitor” and verify whether brucellosis testing is occurring for movements of livestock out of the Designated Surveillance Area. (18)
• Of 225 movements of livestock involving at least 10,000 head of livestock out of the Designated Surveillance Area, only 40 movements documented “health requirements” though this information does not disclose the required brucellosis test. (17)
• The Department of Livestock is not following up on rancher noncompliance for brucellosis testing and consistently enforcing its Designated Surveillance Area rules. (17)
• The Department of Livestock is “not documenting herd management risk assessments . . . including the basis for exceptions or variances to DSA brucellosis testing requirements.” (20)
• In 50 audited samples, “there were no documented risk assessments attached to or explained within the plans.” (20)
• The Department of Livestock is not annually reviewing the 160 herd management plans in place. (19, 20)
• The Department of Livestock is not documenting its basis for providing variances or exemptions for ranchers from brucellosis testing requirements. (21)
• “Allowing certain DSA livestock to not be subject to brucellosis testing requirements creates risks.” (21)

Cattle ranchers in the Designated Surveillance Area are not complying with the 5% brucellosis testing requirement.

• 107 cattle ranchers were noncompliant in 2015. (17)
• The Department of Livestock “could not demonstrate consistent enforcement actions” and did not conduct “consistent follow-up on cases of apparent noncompliance.” (17)

Montana is paying higher rates than Idaho and Wyoming to test for brucellosis and vaccinate cattle.

• Montana compensates ranchers $2 per head, in addition to covering veterinarian costs for vaccinating cattle. (22)

The Montana Department of Livestock is making reimbursements to ranchers without knowing the costs being reimbursed.

• Conclusion: “Audit work was not able to determine what direct costs the reimbursements to producers are intended to offset.” (22, 25)

The Montana Department of Livestock is making reimbursements for vaccinating cattle without proper documentation or the required approval for reimbursements over $5,000.

• Approximately $40,000 in payments were made to large cattle ranchers without the required sign-off of the administrator. (26)
  73% of adult vaccination payments “did not have full supporting documentation, such as an official record of all vaccinations being reimbursed.” (25)
• The Department of Livestock made $24,000 in payments for which it “did not request or maintain supporting documentation.” (26)

Montana Fish, Wildlife & Parks is targeting wild elk in brucellosis risk management actions.

• Since 2013, Montana Fish, Wildlife & Parks carried out 26 brucellosis risk management actions for elk. (34)
• 53% of elk in Paradise Valley have been exposed to brucellosis. (12)
• Between 3% and 53% of elk have been exposed to brucellosis in the hunting districts encompassed by the Designated Surveillance Area boundary. (33)
• The majority of the funding for Fish, Wildlife & Parks brucellosis management comes from federal revenue transferred from the Dept. of Livestock. Fish, Wildlife & Parks is also using general license and Pittman-Robertson funding. (35)
• Fish, Wildlife & Park’s assistance to landowners is provided without having defined eligibility criteria for landowners receiving such assistance. (35)
• “35 percent of the brucellosis response actions were carried out on land that either allowed no public hunting access or limited access to public hunters.” (36)
• “31 percent of the management actions lacked associated documentation of public hunting access status of the land the action was carried out on.” (36)

In lethally removing wild bison, the Montana Department of Livestock is not following adaptive management.

• “However, in 2015, DOL personnel conducted two lethal removals of bison. . . Though these bison were outside of the IBMP management zones, documentation of these incidents did not establish that the bison poses an imminent threat of coming into contact with livestock that necessitated lethal removal of the bison, nor were there initial attempts to haze the bison from the conflict area. The IBMP Adaptive Management Plan specifies that bison in conflict areas are initially to be hazed from the area. DOL lethally removed bison that may not have represented a brucellosis threat, and operational documentation did not provide a clear rationale as to why lethal removal was necessary in these cases.” (31)
• “Neither DOL management nor the associated documentation made it clear why the IBMP adaptive management guidelines were not followed in these particular cases.” (31)
• The legislative audit recommended the Department of Livestock follow the “Interagency Bison Management Plan adaptive management guidelines when lethally removing bison” and clearly document the need for lethal removals. (S-1, S-2)

Despite six incidences of brucellosis infection blamed on wild elk, the Designated Surveillance Area rule maintains Montana’s brucellosis Class Free status.

• “The regulations that comprise the DSA program impact approximately 78,500 head of livestock that graze or live within the DSA boundary on either a seasonal or a year-round basis, and this number represents approximately 5.2 percent of the livestock in the state as a whole, according to Department of Livestock records.” (7)
• Montana is maintaining its brucellosis Class Free status despite six incidents of brucellosis infections in livestock since 2010. (5, 9)