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