Category Archives: Federal Law

DRAFT AWA comment letter to NPS supporting proposed changes to sport hunting regulations

October 30, 2014

Joel Hard, Deputy Director
National Park Service, Alaska Region
240 W 5th Ave., Suite 236
Anchorage, AK 99501

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

Dear Deputy Director Hard,

The Alaska Wildlife Alliance Mission Statement

The Alaska Wildlife Alliance is a non-profit organization committed to the conservation and protection of Alaska’s wildlife.  We promote the integrity, beauty, and stability of Alaska’s ecosystems, support true subsistence hunting, and recognize the intrinsic value of wildlife.  The AWA works to achieve and maintain balanced ecosystems in Alaska managed with the use of sound science to preserve wildlife for present and future generations.

The Alaska Wildlife Alliance fully supports your proposals to ban spotlighting and killing of bears in dens, killing wolves and bears with dependent young, and baiting and killing brown bears on preserve lands in Alaska managed by the National Park Service.

We feel that the state of Alaska’s misguided “intensive management” policies have gone way too far promoting the brutal, wanton killing of wolves, and brown and black bears on both state and federal lands.  We thank you for your proposals to end these practices on some federally managed lands.

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

The simplistic management equation “fewer predators equal more moose and caribou for hunters” also conveniently ignores other important factors. Ongoing increases in harvest limits, increased access to remote areas, and habitat reduction, among other factors, can easily lead to overharvest by the most efficient hunters: humans.

In addition, “spotlighting” to kill bears in their dens, or using human-food bait to lure the bruins to snare sets or a camouflaged shooter should not be called “sport” hunting” at all. It is just killing. The same is true of shooting wolves with dependent pups and bear sows with dependent cubs. This is not “sporthunting,” it is killing for the sake of killing.

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.”

Only about 14 percent – a tiny minority – of Alaskans hold hunting licenses. Meanwhile, hundreds of thousands of visitors, spending millions of dollars, come to Alaska each year with the hope of seeing a wild wolf or bear. Everyone – Alaskans and visitors alike – should have an opportunity to enjoy the magnificent wildlife that inhabits Alaska’s preserves, not just a few hunters looking for a quick and easy target.

Thank you for proposing these common sense conservation policies.  We urge the NPS to adopt these proposed regulations.

Thank you for considering our comments.

Edward A Schmitt
Co-Director, Alaska Wildlife Alliance

Federal vs State of AK approach to ethics: Battle of the op-eds

On September 9th, 2014,  Joel Hard, Deputy Regional Director for the National Park Service, Alaska, published an editorial in Alaska Dispatch News ( formerly Anchorage Daily News):

Alaska predator control methods conflict with national preserve values

“Shooting wolves and coyotes when they are at the den with young pups. Using artificial light to take black bears and their cubs in dens. Using food like stale bread and bacon grease to attract grizzly bears and then shoot them…

These are not the Alaska hunting practices I learned growing up in Southeast Alaska, and they weren’t the sport-hunting practices that Congress anticipated some 35 years ago as it debated the Alaska National Interest Lands Conservation Act. Today, those practices are legal in much of Alaska. The state and its Board of Game use these and other means to reduce the numbers of bears, wolves and coyotes to boost the populations of moose and caribou. In doing so, they are following the laws passed by the Alaska Legislature…

….This week, the National Park Service proposed federal regulations that include a prohibition of the three hunting practices noted above in Alaska’s 10 national preserves. This action came after several years of discussion with the Alaska Department of Fish and Game and other state officials. It came after repeated requests to the Board of Game to exempt national preserves from liberalized predator hunting efforts. And it follows multiple years of implementing temporary federal restrictions on these practices. “

Read the full editorial at ADN…

Next up, on September 20th, was Doug Vincent-Lang, director of the Alaska Department of Fish and Game’s Division of Wildlife Conservation:

Vincent-Lang: Pre-empted Alaska hunting regulations are not ‘predator control’

“In his Sept. 10  commentary,  Joel Hard of the National Park Service wrote that certain Alaska hunting practices were not those he learned growing up in Southeast Alaska. While I appreciate Mr. Hard’s personal hunting ethics, I do not believe the National Park Service should insert such opinions and beliefs into federal regulations…

…The regulations being preempted by the Park Service were adopted by the Alaska Board of Game in response to local (mostly subsistence) hunters’ requests to allow their traditional practices to occur. The professionals at the Alaska Department of Fish and Game did not feel it was our role to judge the ethics of these practices. While individual biologists within the department may not have personally agreed with the proposals, leadership did not feel it was our mandate to insert personal hunting ethics into the wildlife management or regulatory process….”

Read the full editorial at ADN…

Vic Van Ballenberghe, a moose and wolf biologist who was appointed to the Alaska Board of Game three times by two governors, responded to Vincent-Lange on September 22nd:

Alaska law does not justify game regulators abandoning decades-old, ethics-based statutes 

“…Vincent-Lang repeatedly states that Hard and other NPS employees used their own ethical judgments when crafting federal regulations challenging the state’s approach. But Hard’s statement that he did not grow up where shooting wolves at dens, using lights to take bears at dens, and grizzly bear baiting were legal was not a reflection of his own ethics but rather an accurate observation that these practices were long illegal under state regulations until they were recently employed to reduce predator populations…

When I served on the board at various times between 1985 and 2002, Fish and Game and the board were very much concerned with ethical standards, and previous boards since statehood clearly were too. That is why shooting wolves from airplanes by private pilots, same-day airborne shooting of all big game species, herding of animals with motor vehicles, the use of poison, transporting hunters with helicopters, trapping bears, gassing wolf pups at dens and a host of other practices were made illegal prior to 2002. But since 2002, in its zeal to accomplish intensive management, the board decided to abandon long-held ethical standards and adopt extreme methods to reduce bears and wolves. And Fish and Game stood idly by, claiming as Vincent-Lang does, that the only standard is one of maintaining sustained yield…”

Read the full editorial at ADN…


Former governor Tony Knowles on Alaska’s predator policies – High Country News

Krista Langlois High Country NewsSep 11, 2014

High Country News How has Alaska’s approach to wildlife management changed in the 12 years since you left office? 

Tony Knowles The most disappointing thing is that the balance of views on the Board of Game has just disappeared. I tried to work with a balanced board that reflected subsistence hunters, sport hunters, guides and conservationists, but now the Board is made up of people who want to make hunting ungulates the priority for wildlife management. There’s been a focused effort to dramatically reduce populations of wolves, coyotes and bears, and the methods and means they’ve used are both unscientific and unethical.

Read the full interview at High Country News…

Sweeping new rule for Alaska’s predator control – High Country News

Federal versus state wildlife politics get even hotter.

Krista Langlois, High Country News Sep 11, 2014 

When Jim Stratton, deputy vice president for the National Parks Conservation Association, heard last week that the National Park Service had announced a sweeping new rule banning the manipulation of predators and prey in Alaska’s national preserves, his reaction was — to put it mildly — unfettered joy. “This is totally exciting news,” he says. “I’ve only been working this for ten years. Game on.”

The reaction of the state Division of Wildlife Conservation? A little more tepid. Director Doug Vincent-Lang sees any attempt by the feds to usurp Alaska’s wildlife management authority as overreach, and this new rule — which maintains hunting rights on Alaska’s 22 million acres of national preserves but bans certain controversial practices — is overreach at its worst: “unfounded and unjust,” he told Alaska Dispatch News



Rare Alaskan Wolf Closer to Endangered Species Act Protection

From Center for Biological Diversity

For Immediate Release, March 28, 2014

Contacts: Larry Edwards, Greenpeace, (907) 747-7557
Rebecca Noblin, Center for Biological Diversity, (907) 274-1110

Alexander Archipelago Wolf Threatened by Logging in Tongass National Forest

ANCHORAGE, Alaska— The U.S. Fish and Wildlife Service announced today that Alaska’s Alexander Archipelago wolves may need protection under the Endangered Species Act because of unsustainable logging in the Tongass National Forest and elsewhere in southeast Alaska. The agency will now conduct an in-depth status review of this rare subspecies of gray wolf, which lives only in the region’s old-growth forests.

Today’s decision responds to a scientific petition filed in August 2011 by the Center for Biological Diversity and Greenpeace. Following the status review and a public comment period, the agency will decide whether or not to list the species as threatened or endangered.

“The Alexander Archipelago wolf, one of Alaska’s most fascinating species, needs the protection of the Endangered Species Act if it’s to have any chance at survival,” said Rebecca Noblin, Alaska director of the Center. “The Endangered Species Act is the strongest law in the world for protecting wildlife, and it can save these beautiful wolves from reckless logging and hunting.”

Alexander Archipelago wolves den in the root systems of very large trees and hunt mostly Sitka black-tailed deer, which are themselves dependent on high-quality, old forests, especially for winter survival. A long history of clearcut logging on the Tongass and private and state-owned lands has devastated much of the wolf’s habitat on the islands of southeast Alaska.

“This gray wolf subspecies exists only in southeast Alaska, and its principle population has declined sharply in the last few years,” said Larry Edwards, Greenpeace forest campaigner and long-time resident of the region. “Endangered Species Act protection is necessary to protect the wolves, not least because of the Forest Service’s own admission that its so-called transition out of old-growth logging in the Tongass will take decades. The negative impacts on these wolves are very long-term and have accumulated over the past 60 years of industrial logging.”

Logging on the Tongass brings new roads, making wolves vulnerable to hunting and trapping. As many as half the wolves killed on the Tongass are killed illegally, and hunting and trapping are occurring at unsustainable levels in many areas. Despite scientific evidence showing that Alexander Archipelago wolf populations will not survive in areas with high road density, the Forest Service continues to build new logging roads in the Tongass. Road density is particularly an urgent concern on heavily fragmented Prince of Wales Island and neighboring islands, home to an important population of the wolves.

In 2013 the Alaska Board of Game authorized killing 80 percent to 100 percent of the wolves in two areas of the Tongass because habitat loss has reduced deer numbers so that human hunters and wolves are competing for deer — putting yet more pressure on the wolf population.

The Fish and Wildlife Service considered listing the wolf under the Endangered Species Act in the mid-1990s but then chose not to do so, citing new protective standards set out in the Forest Service’s 1997 Tongass Forest Plan. Unfortunately, as outlined in the conservation groups’ 2011 petition, the Forest Service has not adequately implemented those standards.

Today’s U.S. Fish and Wildlife Service 90-day finding on the Alexander Archipelago wolf determined that protecting this wolf as threatened or endangered “may be warranted” under three of the five factors specified in the Endangered Species Act: (1) present or threatened destruction of habitat; (2) overutilization (e.g., from hunting and trapping); and (3) the inadequacy of existing regulatory mechanisms.

A recent declaration by Dr. David Person, the foremost Alexander Archipelago wolf researcher, concerning the wolf population on Prince of Wales Island is at: 

A recent declaration by Dr. David Person, the foremost Alexander Archipelago wolf researcher, concerning the wolf population on Prince of Wales Island is at: