Justification memo

United States
Department of
Agriculture
Marketing and
Regulatory
Programs
Washington, DC
20250

TO:

Elyse Greenwald
Office of Management and Budget Desk Officer

THROUGH: Ruth Brown
Department Clearance Officer
Office of the Chief Information Officer
FROM:

Jennifer Lester Moffitt
Under Secretary
Marketing and Regulatory Programs

JENNIFER
MOFFITT

Kevin Shea
Administrator
Animal and Plant Health Inspection Service
Rosemary Sifford
Deputy Administrator
Veterinary Services

ROSEMARY
SIFFORD

Digitally signed by
JENNIFER MOFFITT
Date: 2022.03.27
17:45:40 -04'00'

ANTHONY
SHEA

Digitally signed by
ANTHONY SHEA
Date: 2022.03.16
10:52:44 -04'00'

Digitally signed by ROSEMARY
SIFFORD
Date: 2022.03.04 21:05:13 -05'00'

SUBJECT: Request for Emergency Approval of a New Information
Collection for Identifying Risk Factors of Mycoplasma bovis in American Bison
The Animal and Plant Health Inspection Service (APHIS) is submitting to the
Office of Management and Budget (OMB) an information collection request for
an emergency 6-month approval for a case control survey of Mycoplasma bovis
emergence in bison herds. Bison producers need this information immediately to
mitigate risk for this rapidly spreading pathogen. Mortality losses from this
pathogen are high and recurring, creating significant economic losses for
producers, cultural losses for Native American tribes, and threatening
conservation of the National Mammal. No effective treatments or vaccines
currently exist for this pathogen. Therefore, the best option APHIS and bison
producers have is to identify risk factors and develop mitigation strategies based
on these factors.
In December 2021, the USDA Office of Tribal Relations asked for a rapid
response from APHIS on behalf of Native American tribes to address these
multiple Mycoplasma bovis outbreaks. APHIS has identified collaborators and
resources needed for immediate data gathering in March and April 2022 to
identify risk factors and mitigate future outbreaks. APHIS will collect data via
telephone and email surveys. APHIS will solicit study participation from a list
of National Bison Association members and from affected producers who
consent to having their identifications turned over by diagnostic laboratories.
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APHIS’ main mission is the prevention, control, and eradication of animal
diseases to safeguard animal health. Disease detection and prevention is the most
effective method for maintaining a healthy animal population and for enhancing
the United States’ ability to compete globally in animal and animal product trade.
APHIS has determined that in this situation, traditional information collection and
rulemaking procedures could further cause public harm, is contrary to the public
interest, and that there is good cause under 5 U.S.C. 553.
USDA first recognized Mycoplasma bovis as an emerging pathogen in bison in
2013. Since that time, only a few premises have been affected until 2021. In 2021
there was a substantial increase in new affected premises and herds. These
affected herds are experiencing 10 to 50% herd loss in multiple age classes, with
reproductive aged cows suffering the most significant losses. Despite the unique
and significant burden of this pathogen in bison, little information exists on the
sources of infection to naïve herds. Once affected, bison producers report
significant recurrent losses in subsequent years. For instance, producers first
affected in 2013 continue to experience significant losses, particularly in 2021.
No diagnostic testing is currently able to identify animals infected but not
shedding the bacterium. This means that these animals can serve as a hidden
source of infection during subsequent years. Therefore, to limit additional herds
becoming infected in the 2022 season, is it critical for APHIS to develop
information on the potential sources of new infections in naïve herds.
To develop the prevention and control recommendations that bison producers
need, APHIS needs to identify differences in management practices,
environmental conditions, and herd-level factors between affected and unaffected
herds. This information is a critical component to protect the industry and tribal
and conservation herds. Bison serve as a growing economic industry, and a
critical food source, particularly for Native American tribes, where bison also
serve important cultural and spiritual roles. This native species is of unique
conservation importance on public and private lands alike and carries significant
and unique importance to the American public and wildlife enthusiasts.
Prevention and control measures are desperately needed to stem further economic
losses and threats to the conservation of this wildlife species that has already
experienced significant loss of genetic diversity when it was hunted to near
extinction.
Thank you for your time and consideration.

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