The Montana Archaeological Society responds to Fish, Wildlife and Parks suggestion to change management of the Madison Buffalo Jump State Park to the Department of Natural Resources and Conservation. Such a move will limit the educational interpretation of the site as well as potentially harm the significant material remains due to the leasing of grazing rights on the site.

1. MONTANA ARCHAEOLOGICAL
P.O. Box 2123 • Billings, MT 59103-2123 SOCIETY
Madison Buffalo Jump Comments
c/o Montana State Parks
PO Box 200701
Helena, MT 59620-0701
January 28, 2013
To the Fish, Wildlife, and Parks Commission:
Recent developments regarding the Madison Buffalo Jump site have led to a conversation
about changing the management from Fish, Wildlife and Parks to the Department of Natural
Resources and Conservation. The Montana Archaeological Society is concerned about this
change which would limit educational interpretation of the site as well as open the site to
potential destruction by leasing the grazing rights. Such a move would threaten the very spirit of
the 1965 act which established this important site as a state park in the first place.
The Madison Buffalo Jump State Park was established as such by Senate Bill 22, enacted in
1965 which authorized acquiring the land to be “preserved for the benefit of the people” and
established systems “as may be necessary to the proper care and management of the object to
be protected and preserved for posterity”. This law, approved February 26, 1965, clearly
expresses that this significant archaeological and historical resource was acquired to a) benefit
the people of the state of Montana and b) to protect and preserve it as a valuable archaeological
and historic place for posterity. The site was also federally recognized on the National Register
of Historic Places in 1970, further emphasizing its historic significance.
Limiting or removing educational interpretation and materials from the site could adversely
impact important educational programs around the state which make use of the Madison Buffalo
Jump for such purposes. The Indian Education for All program and Project Archaeology are two
state-wide programs which make use of the site to educate both students and teachers in this
important history.
Beyond the education issue, however, is the potential threat to the material remains at the site
which leasing the grazing rights could bring. The Montana Archaeological Society is concerned
that these materials and their contexts would be greatly damaged if grazing were to happen on
the site which has yet to be thoroughly evaluated and documented. Until a comprehensive
archaeological survey and evaluation are conducted of the Madison Buffalo Jump site, we
cannot evaluate its contemporary Native culture, tourism, and economic value, nor can we
evaluate the impact that a transfer of ownership will have on the property. Also, as such a
management change could have an adverse impact to the site which is protected under the
National Register of Historic places, there should be a review of the property using the National
Historic Preservation Act Section 106 as a guide before a management decision can be made.

2. Such a review should involve a field re-examination of the site and its contents, conducted in
consultation with Native people from the Shoshone, Bannock, Crow, and Apachean-speaking
tribes in addition to Salishan and Algonkian-speaking people, and a review of the original
ownership transfer documents.
Furthermore, the Montana Archaeological Society would like to remind the commissioners that
under the Montana Antiquities Act, state agencies are required to adopt/have rules to avoid
state actions that substantially alter heritage properties on state lands (MCA 22-3-424(1)); the
preservation review board is to act in an advisory capacity to state agencies (MCA 22-3-422(5)),
and heritage properties on state lands are to be given appropriate consideration in state agency
decision-making (MCA 22-3-424(2). Furthermore, the Montana Environmental Policy Act
declares that it is policy (MAC 75-1-103) of the
“state of Montana, in cooperation with the federal government, local governments,
and other concerned public and private organizations, to use all practicable means
and measures, including financial and technical assistance, in a manner calculated
to foster and promote the general welfare, to create and maintain conditions under
which humans and nature can coexist in productive harmony, and to fulfill the
social, economic, and other requirements of present and future generations of
Montanans .
(b) ensure for all Montanans safe, healthful, productive, and aesthetically and
culturally pleasing surroundings;
(e) preserve important historic, cultural, and natural aspects of our unique heritage
and maintain, wherever possible, an environment that supports diversity and variety
of individual choice.”
The Montana Archaeological Society encourages Fish, Wildlife and Parks to withhold any
decisions about the property until such research and evaluation is conducted at the Madison
Buffalo Jump. As SB 22 was enacted in order to preserve this site for posterity, every possible
action must be taken to ensure its protection and education as a significant archaeological and
historical resource.
On behalf of the Board of the Montana Archaeological Society,
Tim Urbaniak
President