These comments were submitted by Bob Lindstrom, Bear Creek Council member and Yellowstone National Park employee.

To learn more about the issue, go to the NPS Website.

Bob’s Letter:

January 23, 2007

Michael D. Soukup, Ph. D.
NPS Associate Director, Natural Resources, Stewardship & Science
1849 C. Street NW
Washington DC 20240

NPS Employee comments on Benefits Sharing Draft EIS

Dear Dr. Soukup:

The Taq-PCR patent is the perfect model of how to do things right. The NPS is to be commended for preserving biodiversity and making it available for the advance of science. But let us quit while we are ahead, taking credit for doing what we know best and not continue to be bogged down in litigation that can be a bottomless pit.

Concerning the Benefits-Sharing (BS) DEIS, I am disappointed by the length of time it has taken, and the lack of scientific justification for this paradigm shift in NPS policy.

1. JUSTIFICATION: Like the goose that laid the proverbial golden egg, the advance of science has been thwarted during the past 7 years by the red tape we are generating concerning research permitting in Yellowstone and access to the American Type Culture Collection (ATCC) Yellowstone Collection. The free market, and the free flow of scientific information are the qualities that make America great. I fear that the Benefits-Sharing (BS) proposal is antithesis to this.

The DEIS justifies it’s existence claiming that the NPS received nothing from the Taq-PCR patent. To the contrary, the lack of NPS involvement in the Taq-PCR patent resulted in a multi-billion dollar revenue stream of great benefit to society and a tidy remuneration to the US Treasury, the source of all NPS base funding. According to Dr. Mark Young, of Montana State University, over 1 Billion dollars per year in commerce is being generated by PCR and when we siphon off the normal IRS percentage the total approximates the entire $65 million Yellowstone NP (YNP) operating budget each year, even now that the patent has expired, revenue from Thermus aquaticus DNA polymerase continues supporting YNP via the US Treasury.

2. HUMAN VECTORED CONTAMINATION: As a microbiologist, I am not so concerned with what people are taking out of the hot springs as I am with what they are putting into them. As with the other aquatic and terrestrial ecosystems in Yellowstone, exotic species have been introduced by well meaning NPS staff with disastrous results. For example, the Lake Trout problem probably results from our “aquarium program” from years past. Xenic weed species and mud snails all were introduced by people into Yellowstone. I was hoping to see a scientific survey on the question of exotic species in hot springs. But instead, the BS DEIS deliberately excluded one of the only such studies on hot spring contamination, a publication resulting from a presentation at the 5th Biennial Science Conference on Xenic Species in Yellowstone. This publication, along with all the other peer-reviewed exotic species publications, was published in the Western North American Naturalist magazine in January 2002. No mention of this paper appears in the DEIS which signals to me that this issue is being swept under the carpet, covered-up in the characteristic BS DEIS black-box style confusing this issue and avoiding the hard questions introduced at the conference.

For this reason, the lack of assurance that the geothermal ecosystem is safe from contamination by human activities, the preservation & protection question of hot springs biodiversity remains unanswered. The paper which presented a 25 year long inventory of a few acid hot springs did indicate that a new species, possibly a “weed species” Acidianus brierleyi is now present where none existed prior to human influence. Using this as a model, shouldn’t we be asking these questions? Until we can be sure sampling is safe, we should not encourage yet more cross-contamination of the ecosystem. Having personally accompanied researchers to these sites in the past, I know they leave no micro-habitat untouched when searching for unique thermostable enzymes. According to one of our leading microbial ecologists, Dr. Richard Castenholz, “…exotic species tend to establish only in disturbed habitats…”

Furthermore, no microbiologists or microbial ecologists were involved with the production of the DEIS. This is disconcerting to me since many of the potential discoveries involve prokaryotic life. It seems that once again, a lot of good government resources of time and money have been wasted. This DEIS is a Pandora’s Box, and I hope we do not compound it into a solicitors office calamity as well. Let us stick to the basics in running our Parks, and not venture into the “away game” with marketing our genetic resources.

My opinion is Alternative A, just leave well enough alone. Perhaps unhindered by the NPS the next super-enzyme will materialize and give us some nanotechnology breakthrough or a cancer cure, but keep the door open for the advance of science in national parks, for we safeguard the “Crown Jewels” of Earth’s biological diversity!

Sincerely,

Bob Lindstrom
Finance Technician

Cc: Benefits sharing DEIS Team