Category Archives: Bears

Take Action for Alaska’s Wildlife! Public Comment Period Extended until Nov. 5th

We vigorously opposed unethical hunting methods on Alaska’s National Preserves in 2015, and won. Now, under orders from the Trump administration, the National Park Service has proposed a rule to undo that success and remove certain wildlife protections for bears, wolves, coyotes, and caribou.   

Department of the Interior Secretary Ryan Zinke directed the review – and proposed reversal – of the National Park Service’s 2015 rule which we fought so hard to support. Based on input from more than two dozen public hearings and over 70,000 public comments, support for the ban was overwhelming. Now we need your support again to maintain that rule to protect wildlife on preserve lands.

What is the proposed rule change?

On October 23, 2015, the National Park Service (NPS) published a final rule (Final Rule) to amend its regulations for sport hunting and trapping in national preserves in Alaska (80 FR 64325). The Final Rule codified prohibitions on certain types of harvest practices that are otherwise permitted by the State of Alaska’s hunting regulations found at 5 AAC Part 85.

The 2015 Final Rule banned the following practices on National Preserves in Alaska:

  • Taking any black bear, including cubs and sows with cubs, with artificial light at den sites;
  • Harvesting brown bears over bait;
  • Taking wolves and coyotes (including pups) during the denning season (between May 1 and August 9);
  • Taking swimming caribou;
  • Taking caribou from motorboats under power;
  • Taking black bears over bait;
  • Using dogs to hunt black bears.

The 2015 Final Rule prohibited these hunting practices because the NPS found those practices:

(1) To have intent or potential to alter or manipulate natural predator-prey dynamics, and associated natural ecological processes for the purpose of increasing harvest of ungulates by man;
(2) to adversely impact public safety; or
(3) to be inconsistent with federal law authorizing sport hunting in national preserves in Alaska.

In addition, NPS has broad discretion in managing wildlife on national preserves under applicable laws, policies, and regulations.

On September 15, 2017, Secretary Zinke signed Secretarial Order 3356 to overturn the 2015 rule and permit the killing practices listed above. If the rule change is passed, Alaska’s wildlife will suffer. We need your help. 

What can you do? 

The Department of Interior has extended the public comment period until November 5th for both the proposed rule change and the environmental assessment regarding sport hunting and trapping on National Preserves in Alaska. You can submit the same comment through both portals, doubling your impact.

Comment on the proposed rule change now!

Comment on the Environmental Assessment now!

Please note: There is no direct email address to submit comments. Comments are accepted only via the above link, or by hand or mail addressed to:

National Park Service
240 West 5th Ave.
Anchorage, AK 99501

For the proposed rule change: ATTN: Regional Director, Alaska Regional Office, RIN 1024-AE38
For the Environmental Assessment: ATTN: Sport Hunting and Trapping in National Preserves EA- Alaska Regional Office, EPC

What are some examples of effective comments?

“I urge you not to adopt the proposed rule regarding recreational hunting on Alaskan federal preserves. The existing National Park Service rule considered strong public input opposing the extreme hunting practices at issue. The National Park Services process rightly concluded these hunting practices have adverse impacts on public safety, are inconsistent with federal law and potentially alter natural predator-prey dynamics for the purpose of increasing sport harvests.

The Department of Interiors new proposed rule to abandon these protections for Alaskan wildlife on Alaskan federal preserves would sacrifice the health of publicly owned lands and wildlife populations for the benefit of a small group of extreme sport hunters.

I urge the Department of Interior not to finalize the proposed rule revoking regulations on hunting practices in Alaskan federal preserves, and to instead retain existing rules properly considering the interest of all Americans. Thank you for considering my comments.”

**********

“As one of 1.3 million members and supporters of the National Parks Conservation Association, I strongly oppose the National Park Service’s attempt to roll back 2015 clarifications of existing park authority to protect bears and wolves on Alaska national preserves. Extreme sport hunting methods, like brown bear baiting and killing hibernating black bear mothers and cubs in dens, don’t belong on national preserves in Alaska.

National parks and preserves in Alaska were set aside by Congress as special places where bears, wolves and other wildlife roam as part of a natural ecosystem. This is why I oppose the National Park Service’s proposal to allow extreme hunting practices.

I urge you to protect our last, best chance to make sure our children inherit a world with wild spaces and wildlife. Thank you.”

What makes a good comment?

When commenting on proposed Federal rulemaking actions, there are misconceptions that reduce the effectiveness of one’s submission.  To try and help you have the most effective impact when voicing your perspectives to a Federal agency during a public comment period, below we have provided some helpful tips and links.

It is not a popularity contest.

  • A form letter signed by thousands of people is often only considered as one comment. Consider submitting comments in your own words instead of, or addition to, signing form letters.
  • It doesn’t really matter how many people said they support or don’t support the proposed action, what matters is the extent of the substantive comments received during the public comment period.

Submit “substantive” comments.

  • According to the 2015 National Park Service’s NEPA Handbook, “substantive” comments:
    • question, with reasonable basis, the accuracy of the information in the document;
    • question, with reasonable basis, the adequacy of the environmental analysis;
    • present reasonable alternatives other than those presented in the document; or
    • cause changes or revisions in the proposal.
  • Any comments deemed “non-substantive” are in danger of not being included in any additional analyses, and thus will not influence a decision. They essentially may be dismissed.

Help them help you.

  • When crafting your comments, be respectful and try recognize the constraints of the agency’s authority and provide the tools and information necessary to for them to fight for your perspective.
  • When trying to influence the Federal rulemaking process, facts and data are your friend. Any evidence you can provide to support your statements are helpful.
  • When preparing your written comments, make sure your main points are easy to find and stand out, otherwise they may be missed if the reviewer only has time for a quick scan.

There are numerous resources available to help you understand the Federal rulemaking process and how to write more effective public comments.  Here are a couple we think are useful.

Bear Cub Killers in Alaska Have an Ally in Donald Trump – Mother Jones article

Bear Cub Killers in Alaska Have an Ally in Donald Trump

The brutal scene unfolded in 30-second snapshots, captured in discrete moments by a motion-activated camera. Two hunters skied toward a den on Esther Island in southern Alaska and found a sow and its two newborn bear cubs. After killing all three with rifles, the hunters packaged meat from the mother in game bags, leaving the dead cubs in the snow. Two days later, they returned to retrieve the shells from their weapons and hide the cubs’ bodies.

The April 14 slaying, detailed in police reports and the Anchorage Daily Newsoutraged activists and environmental groups who have long protested the state-sanctioned killing of bears and wolves through extreme means. The two hunters in Esther Island were charged with breaking anti-poaching laws and hiding evidence, but Alaskan hunters have long resorted to shooting these animals from helicopters and butchering them in dens without legal consequence. Not even research subjects for government studies are spared from the dramatic rise in predator killings. The three bears on Esther Island were part of a US Forest Service study, and the sow wore a collar identifying it as a research subject. Between 2005 and 2015, hunters killed 90 wolves wearing similar collars… read the full article at Mother Jones

Citizens letter to Governor Walker on predator control

The following letter has been submitted to Governor Walker on August 15th, 2016.

The letter has 150 signatories (from 28 Alaska communities), including several former Alaska Board of Game members, a former ADFG commissioner, a former gubernatorial Chief of Staff, scientists, writers, photographers, doctors, lawyers, artists, musicians, teachers, hunters business owners, and so forth — all Alaskans, all with equal constitutional say re: Alaska wildlife.

If you wish to weigh in further in support of this ask, we would encourage you to email Governor Walker directly at:

governor@alaska.gov

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IM2014

Click to enlarge

August 15, 2016
Honorable Bill Walker, Governor
State of Alaska
Office of the Governor
P.O. Box 110001
Juneau, AK 99811-0001
RE: Requested adjustments to State of Alaska predator control/Intensive
Management program
Dear Governor Walker,

Over the past 13 years, lethal predator control/Intensive Management (IM) in
Alaska has expanded dramatically. A graphic display of the increase in predator
control areas in Alaska from 2001 – 2014 can be found here:
http://unbearableterms.tumblr.com/post/72770119451/predator-controlareas#.V5U5kTV5-8A

The Alaska Department of Fish & Game (ADFG) reports that each year, Alaska
predator control programs directly kill approximately 200 wolves, 150 black bears,
and 10 brown bears. However, this total does not include the number of pups and
cubs that die after being orphaned by the program, nor does this total reflect the
increased predator harvest that has resulted from the liberalization of predator take
regulations, including liberalization/elimination of bag limits, significant extensions
of hunting/trapping seasons for predators, elimination of brown bear tag
requirements, baiting/snaring of bears, permitting the take of sows with cubs,
permitting use of helicopters to run IM trap lines and bear snare sets, and so on.
Clearly, the actual kill in Alaska’s predator control/IM program is significantly larger
than the total reported.

Alaska’s lethal predator control/IM program, as currently practiced, is unscientific,
unnecessary, ineffective, costly, unethical, inhumane, and controversial.

Accordingly, we the undersigned Alaska citizens, respectfully request that you make
three important and reasonable adjustments to Alaska’s predator control/IM
program, as currently conducted by ADFG:

1. Replace lethal predator control methods with non-lethal methods;
2. Terminate the “collaring for later control,” or “Judas wolf” program;
3. Prohibit all IM within 5 miles of federal conservation units.

As discussed below, you have the authority, indeed the responsibility, to order such
adjustments in this state program.

I. Replace lethal predator control methods with non-lethal methods.

We recognize that state statute provides authority for IM programs, but statute and regulation do not prescribe what techniques must be used for such.

State law and regulation (5 AAC 92.110 and 115) provide the following IM authority to the ADFG commissioner:

The commissioner or the commissioner’s designee, including contracted agents
of other governmental agencies, may reduce [wolf and bear] populations in an
efficient manner, by any means, but as safely and humanely as practical,
including the use of a helicopter.

While the state explicitly prohibits use of certain methods in its lethal predator
control program (e.g., machine guns, bombs, explosives, pits, fire, smoke, electronic
night vision scopes, expanding gas arrows, etc.); and generally authorizes use of all
other methods (lethal and non-lethal); it does not affirmatively require use of any
specific method. Notably, nowhere does statute or regulation require the use of
lethal vs. non-lethal methods for predator control/IM.

For instance, while 5 AAC 92.110 authorizes the department to lethally gas wolf
pups in dens using carbon monoxide, and to otherwise kill pups in dens (“denning”)
in predator control areas (with the approval of the commissioner), it does not
require such. And while poison is authorized to kill predatory animals
(AS.16.35.200), written permission is required from the Board of Game.
Similarly, while statute and regulation authorize the use of state employees,
helicopters, and other equipment in IM, AS 16.05.783 (e) prohibits such without
direct approval of the commissioner:

The use of state employees or state owned or chartered equipment, including
helicopters, in a predator control program is prohibited without the approval
of the commissioner.

We further note in 5 AAC 92.110 (control of predation by wolves) and 5 AAC 92.115
(control of predation by bears) the following:

After the board has adopted a predation control implementation plan, the
commissioner may, at any time during the period for which the plan is in
effect, determine whether to implement the plan and may, by regulation,
amend the plan to apply additional restrictions in light of circumstances
existing at the time of implementation.

Clearly, implementation and/or amendment of IM plans, including methods to be
used, remains within the discretionary authority of your administration.

On this point, we note that during the administration of former Governor Tony
Knowles, IM was successfully implemented using exclusively non-lethal methods
(e.g., translocation, sterilization, diversionary feeding, habitat enhancement through
wildfire policies, etc.). These non-lethal methods represent effective alternatives to
the lethal control methods.
There are numerous problems with Alaska’s current lethal predator control/IM
programs, including that they:
• Are based on poor science and inadequate predator/prey population
surveys;
• Are not scientifically peer reviewed;
• Do not recognize or protect natural variability of dynamic ecosystems;
• Do not account for the growing ecological impacts of climate change;
• Are designed for mostly urban, not rural subsistence, hunters;
• Are not supported by many Alaska citizens;
• Can result in prey populations exceeding habitat carrying capacity, thus
degrading habitat;
• Can lead to unintended consequences, including increasing predation due to
immigration of predators into control areas;
• Prioritize consumptive use of wildlife over non-consumptive use, contrary to
the Alaska constitution; and
• Produce little scientific evidence that the programs are effective.

It is time for reputable, professional wildlife scientists in ADFG to admit such, and
provide scientific leadership on this issue to the Board of Game and commissioner.
Further, it is clear that the state’s lethal predator control program is currently
financially supported in large part through the federal Pittman-Robertson “Federal
Aid in Wildlife Restoration” program. This federal program contributes the single
largest component of the annual budget of the ADFG Division of Wildlife
Conservation. Although the state maintains that its federal aid accounts do not
reflect direct support to actual IM operations, it is apparent that lethal control is
indeed being supported, inappropriately, with these federal funds (e.g. collaring for
later control, as discussed below). In addition, most of the state’s funding for survey
and inventory monitoring, and assessment of impacts of the lethal predator control
program, derives directly from these federal wildlife restoration funds.

As you know, the U.S. Fish & Wildlife Service is now drafting a new proposed rule to
clarify whether such uses by states are permissible, and the U.S. Department of
Interior Inspector General is preparing to conduct an audit of the past use of these
federal funds by the State of Alaska, paying specific attention to this issue of funds
used for lethal predator control. The continuation of the lethal predator control
program, with support by these federal wildlife restoration funds, jeopardizes the
continuation of this substantial funding source to state wildlife management.

Finally, as aerial lethal control involves chasing and often wounding wolves and
bears from aircraft, this can cause significant suffering of animals. As such, this
practice violates the state legal requirement to conduct predator control “as
humanely as practical.” While “humane” is not defined in statute, it is generally
taken to require compassion, kindness, and sympathy for animals; and to require
that actions cause the least possible harm, pain, and suffering. The practice of
chasing, shooting and wounding wolves and bears from aircraft does not meet this
legal requirement of humane treatment.
In addition, bear baiting/snaring conducted in GMU 16 is exceptionally cruel and
inhumane, as snared bears can struggle and suffer painfully for days before
succumbing or being killed.
Governor, you and your ADFG commissioner clearly have the authority to substitute
exclusively non-lethal IM methods for the lethal methods now in use. The IM
surcharge you approved this year can be used to support the non-lethal IM effort.
Non-lethal IM will effectively sustain ungulate populations for human harvest, will
comply with statute, and will increase public acceptance of state wildlife
management.
For the above reasons, we request that you order the substitution of humane, nonlethal
predator control options for all lethal control options now in use.

II. Terminate the “collaring for later control,” or “Judas wolf,” program.
Secondly, we ask that you terminate the practice of “Judas wolf” collaring/killing.
As you know, this program places tracking collars on wolves, and then state gunners
track the collared wolves back to their family group/den, where as many as possible
are then killed by state biologists. The “Judas” animals are often spared in order to
lead state gunners to other wolves for elimination.
We note the following in July 7, 2016 correspondence from Bruce Dale, Director of
the ADFG Division of Wildlife Conservation:

A total of 28 wolves were fitted with radio collars since 2005 in the Upper
Yukon–Tanana wolf control area. This is the only area where radio-collared
wolves have been used to locate wolves during a wolf control program. These
wolves were all radio-collared between fall 2011 and spring 2016
(Regulatory years 2011 through 2015; RY11–RY15). A total of 179 wolves
were killed by ADF&G during RY11–RY15 in this wolf control program.
We estimate that approximately 30% of wolves killed by ADF&G in the Upper
Yukon–Tanana wolf control area in the last 5 years were associated with
collared wolves.

Wolves serve a critical role in terrestrial ecosystem stability, and are intelligent,
social animals, with strong family bonds. We find it reprehensible that this very
sociality and family bond is being lethally exploited in state predator control efforts.
This program adds another layer of concern regarding the inhumane killing of
wildlife from helicopters. The program also raises legal questions regarding
compliance with FCC licensing of airwaves used for tracking, as well as NEPA
compliance.
The “Judas wolf” collaring/killing program is unethical, inhumane, an
embarrassment to Alaska, and should be ended immediately.

III. Prohibit all IM within 5 miles of federal conservation units.

Finally, we ask that you prohibit all state predator control/IM programs (lethal or
non-lethal) within 5-miles of any federal conservation unit – National Parks,
National Preserves, National Wildlife Refuges – to minimize impact on wolves and
bears from these conservation units and the consequent erosion of ecological
integrity of these national interest lands.
On this point, we note that over the past decade, state IM programs have targeted
and eliminated most wolf family groups (packs) from Yukon-Charley Rivers
National Preserve, including most of those collared for federal research programs.
As a result, the Park Service now concludes that the Preserve is “no longer in a
natural state,” and there are not enough survivors in the Preserve to maintain a
“self-sustaining population.” In a 5-year period, state IM efforts have killed 90
Preserve wolves from nine packs, and terminated the 20-year federal wildlife
research program.

As example in 2013, all 24 members of Yukon Charley’s Seventymile Pack, including
two with radio collars, were shot by ADFG-authorized private airplane gunners,
eliminating the pack altogether. In 2012 and 2014, ADFG helicopter gunners shot
all 19 members of the Lost Creek Pack, including two collared animals, eliminating
that pack as well. And in March 2016, state helicopter gunners shot and wounded a
female Yukon Charley wolf along the boundary of the Preserve, and then pursued
the wounded animal into the Preserve, where they illegally killed her. Of the 18
other wolves killed by state predator control in this area this spring, half were
young of the year.
Yet despite the state IM program, calf survival in the Forty Mile Caribou herd has not
increased in the past 5 years.
State predator control on the boundaries of federal conservation units is causing
significant harm to the ecological integrity of these federal lands, it isn’t achieving
the stated goal, and it further erodes the state-federal relationship. This practice
needs to end.

In conclusion, the manner in which we conduct our activities, including how we
manage and treat our wildlife, is an important reflection of who we are as a society.
Throughout the Murkowski, Palin, and Parnell administrations, Alaska’s predator
control programs have grown more aggressive, inhumane, costly, unscientific,
ineffective, and unacceptable to most Alaskans. These lethal predator control
programs seriously tarnish the image and reputation of Alaska, which in turn poses
risk to our sustainable tourism industry.
As you are aware, the National Park Service and U.S. Fish & Wildlife Service have
recently published rules restricting lethal predator control on these federal
conservation units in Alaska. This welcome federal action reflects a growing
national sentiment that such lethal IM programs are inappropriate, and should be
ended.
Unfortunately, your administration has, so far, continued aggressive, lethal predator
control/IM on other lands in Alaska.
Governor, we are better than this. We need new “rules of engagement” in Alaska’s
predator control program.
The reasonable adjustments we request here present an opportunity for you to
restore responsible wildlife management in Alaska, sustain ungulate populations for
human consumption, and honor your commitment to represent the interests of all
Alaskans.

As a way forward, we encourage you to convene an independent, science-based
Intensive Management Working Group to examine these, and other such proposals.
We look forward to your positive response.
Very Respectfully,

[150 signatories (from 28 Alaska communities), including several former Alaska Board of Game members, a former ADFG commissioner, a former gubernatorial Chief of Staff, scientists, writers, photographers, doctors, lawyers, artists, musicians, teachers, hunters business owners, and so forth — all Alaskans, all with equal constitutional say re: Alaska wildlife.]

Alert: The National Park Service needs your comment to protect Alaska’s wolves and bears!

Please help us stand with the feds to limit the state’s egregious predator control!

The National Park Service (NPS) has taken a courageous stand against the Alaska Department of Fish & Game and the Alaska Board of Game for the protection of bears and wolves. The Park Service will undoubtedly face staunch opposition from the Board of Game and rabid criticism from many hunters for its proposal to ban the following egregious predator control (killing) methods:

* baited snare sites to attract grizzly bears,
* spotlighting (to locate and then kill) denned black bears,
* shooting wolf mothers with dependent pups, and
* shooting bear sows with dependent cubs

The Park Service has proposed banning these activities on the approximately 20 million acres of land designated as “national preserves” it manages in Alaska. The Alaska Board of Game’s longstanding insistence that predator control programs apply to lands managed by the feds is a threat to the Park Service’s ability to sustain natural and healthy wolf and bear populations.

The proposed regulations would apply in the following national preserves: Denali, Wrangell-St. Elias, Glacier Bay, Yukon-Charley Rivers, Gates of the Arctic, Noatak, Bering Land Bridge, Lake Clark, Katmai, Aniakchak, and the Alagnak Wild River. (Note: “preserves” are managed in the same manner as national parks, but by law are open to sport hunting. The proposed regulations would affect the 1.3 million acres of land designated as “preserve” within Denali National Park and Preserve’s 6 million total acres.)

Please take a moment to write to the NPS to express your strong support for its proposal to ban these barbaric predator control methods. The agency desperately needs broad public support for this action, which surely will draw unbelievable fire from the well-funded and politically influential hunting organizations both in Alaska and the Lower 48.

Please show your support for Alaska’s wildlife by sending comments via e-mail or snail mail. Comments will be accepted until Dec. 3, 2014.

Email:
http://www.regulations.gov/#!submitComment;D=NPS-2014-0004-0001
(You may wish to first write your comments, then paste them into the comment box provided on that page.)

Mail:
Joel Hard, Deputy Regional Manager
National Park Service
240 W 5th Ave.
Anchorage, AK 99501

Below is a sample letter. Please feel free to personalize the letter or write a comment in your own words – these can have a much greater impact than form comments. You may also use the draft of AWA’s comment letter,  and the NPS press release.

Please note: a Facebook chat on the proposal will be held later this month, and public hearings on the proposed ban will be held in locations across Alaska in October and November. We will be sending a list of these dates and times in a separate email Alert.

Thank you for supporting AWA and Alaska’s wildlife.

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Sample letter:

Joel Hard, Deputy Regional Manager
National Park Service

RE: Hunting and Trapping Regulations in Alaska National Preserves
RIN: 1024-AE21

Dear Mr. Hard;

Thank you for standing up to the Alaska Board of Game by proposing regulations to permanently prohibit snaring, brown bear baiting, use of artificial light to locate and then kill hibernating bears, taking wolves when they are with pups, and killing bear cubs and sows with cubs on our national preserve lands.

I strongly support your approval of these proposed regulations.

Such targeted killing of top predators ignores the resulting long-term and possibly irreversible negative impacts on entire ecosystems. No doubt these Intensive Management programs will eventually have a detrimental effect on the very species – primarily moose and caribou – which they seek to increase, solely for the benefit of hunters.

The NPS is directed by Congress to protect natural and healthy populations of wildlife. Manipulation of wildlife populations to benefit other species (such as those being hunted) is specifically prohibited in the NPS Management Policies, which states: “The Service does not engage in activities to reduce the numbers of native species for the purpose of increasing the numbers of harvested species (i.e., predator control), nor does the Service permit others to do so on lands managed by the National Park Service.”

I ask that you follow the above directive and implement the proposed ban on the state’s abhorrent and ill-conceived intensive management program on national preserve lands in Alaska.

Being able to see bears and wolves in Alaska’s national preserves is an experience that I want to ensure is safeguarded for my generation and those to come.

Again, I ask that you approve these proposed hunting regulations. Thank you for the opportunity to comment.
Sincerely,

[Your Name]
[Address]
[City, State ZIP]