The Good, the Bad, and the Ugly of the Board of Game's Wildlife Regulation Changes

The Board of Game meetings for Interior and Western Alaska were held earlier this year, with the Western Arctic meeting held in January in Kotzebue and the Interior meeting held in March in Fairbanks.

AWA was present at the meetings to serve as a voice for Alaska’s wildlife, opposing 55 proposals at the Interior Board of Game meeting. The Board of Game voted with AWA on those oppositions or Took No Action on 23 of the 55 proposals (40% success rate). AWA supported one proposal in the Interior, to stop wolf trapping on the border of Denali National Park, which the Board opposed.

At the Western Arctic Board of Game meeting, AWA opposed 9 proposals and the Board voted to carry all of them, most notably extending seasons for wolf trapping (0% success rate). However, AWA supported 7 proposals in the Arctic, of which the Board also supported 6 (86% success rate). Most of the proposals we supported in the Arctic were reductions in the allowable hunting of the Western Arctic Caribou herd, which has been in decline for years. Through this advocacy, we successfully lowered the limit for non-Alaska residents (out-of-state hunters) from 4 caribou per person per year to 1 per person per year. 

Read on for a full summary of the good, the bad, and the ugly of this year’s wildlife regulation changes.


The Good

Marten continue to get a spring break: Proposals 50 and 124 sought to lengthen the marten trapping season in Units 12, 19, 20, 21, 24, and 25 by two weeks. Thankfully, the Board opposed these proposals due to concerns about trapping marten into the breeding season.

Predator Control for Dall sheep? Thankfully, not this cycle.  The Board failed to adopt proposal 116, which sought to implement a non-intensive management predator control plan within the Tok Management Area (TMA) to “benefit Dall sheep”. Dall sheep are not listed as an Intensive Management (IM) species; only moose, caribou, and deer qualify. Therefore, the proposer sought to circumvent the IM requirements on predator control by creating a non-IM wolf control program. The legality of the Board being authorized to make such a decision was suspect; there is no precedent for non-IM wolf or coyote control and no precedent for IM coyote control in the State of Alaska. 

The TMA was designed to provide for trophy sheep hunting opportunities. Between regulatory years (RY) 19 and 23 the sheep population in the TMA decreased by 73%, with a corresponding 75% reduction in legal rams. In response to the decline, the allowable harvest was reduced for the RY21 season onward. Also, the hunt structure was altered from two hunt periods to a single period from RY22 onward; the number of offered permits dropped from 100 in RY20 to 60 in RY21 and to 10 in RY22-RY23. In short, sheep are not doing well.

In their comments about proposal 116, ADFG writes, “If adopted, coyotes and wolves would be allowed to be removed using aerial methods under the conditions of a permit authorized by ADF&G. Effects on the increased survival of Dall sheep population are unknown. The portion of coyote and wolf populations to be removed to improve sheep survival sufficiently for population growth is also unknown.

Ultimately, the Board opposed the program’s creation because sheep are not listed as an IM species and the legal ground for creating a non-IM predator control program was shaky. However, AWA is concerned that the Board will consider a statewide proposal to add sheep to the IM statue in 2025. In both public and agency comments, many expressed interest in trying to open a predator control program on Golden eagles, but if that didn’t work the agency would target wolves.

Wolves won’t be trapped into the summer…at least not in Units 12 and 20E. The Board opposed a proposal to lengthen the wolf hunting season in Units 12 and 20E by approximately six weeks, which would increase the trapping season to end on June 15. Thankfully, the Board failed this proposal. It should be noted that earlier this year in Kotzebue, the Board extended the wolf trapping season by one month in Unit 18, to end on April 30th.

No Intensive Management or Predator Control in the Arctic National Wildlife Refuge. The Board voted down proposals 146-148, which sought to adopt an Intensive Management Program and implement wolf control on all state lands in Units 24A and 25A. Most of 24A and 25A fall within the Arctic National Wildlife Refuge. The Board and the Department opposed these proposals because the State does not own enough land to “reduce the predators by 60-80%”, which the Department defined as the metric for such a program being “successful”. While the Commissioner of ADFG, Doug Vincent-Lang, lamented on record that the Wildlife Refuge will not implement predator control, AWA and our allies applaud the Fish and Wildlife Service for upholding their mandates by not permitting predator control on Refuge lands.

Wolverines also get a spring break, except for those in 20C. The Board failed proposals 153 and 170, which sought to lengthen the wolverine hunting and trapping seasons in Unit 21 and 25A by one month, which means the trapped season would end on April 30. We appreciate the Board opposing those proposals in the interest of conserving wolverines during the breeding season. However, the Board then surprisingly passed proposal 188, which lengthened the wolverine trapping season in Unit 20C, establishing the wolverine trapping season as November 1 – March 31. 

Barely avoided bear snaring. After much discussion and a few amendments, we were relieved that the Board failed proposal 166, which sought to establish trapping seasons for black and brown/grizzly bears and allow black and brown/grizzly bears to be taken by bucket snares in Unit 25D. It is important to note that 65% of the land in Unit 25D is federal public lands (USFWS) and current federal regulations prohibit the use of snares to take bears. It is also important to note that snares are nondiscriminatory in that they may catch bears of either species, sex, or of any age. Snaring cubs or sows with cubs would be, according to ADFG, “inevitable”.  While many Board members voiced support for bear snaring as a method they seek to permit, members who opposed the proposal cited concerns about incidental catch. The Board did reflect interest in adding brown bears to the classification of “furbearers”, which would permit them to be taken with traps and not considered incidental take. While this proposal ultimately failed, AWA is very concerned that bear snaring and/or brown bears as furbearers may be proposed at the upcoming 2025 statewide meeting.

Beavers won’t be trapped in downtown Fairbanks. The Board joined many members of the public and the Alaska Trappers Association in opposing proposal 188 which sought to open beaver trapping along the portion of the Chena River that flows through downtown Fairbanks, Fort Wainwright, and other urban areas near Fairbanks. That portion of the Chena River downstream of its confluence with the Little Chena River has been closed to beaver trapping for over 25 years. That portion of the river flows through neighborhoods and highly populated areas near Badger Road, Fort Wainwright, and downtown Fairbanks and is completely within the Fairbanks non-subsistence area. The population of beavers is as healthy as it is within this area and in the remainder of the Chena River because it is excellent beaver habitat. Although the trapping season has been closed in the proposed area for years, the department issues up to a dozen or more nuisance beaver permits annually under the authority of 5 AAC 92.041. Although ADFG was officially neutral on this proposal, staff noted that the current system “has worked well because it allows the department to target specific beaver colonies for harvest and avoid trapping in highly utilized recreational areas or private land. It also allows the department to mitigate issues between trappers and those that do not want the beavers harvested.”


The Bad

Night vision and thermal scopes authorized in an area larger than the size of Montana. To our surprise and disappointment, the Board approved proposal 52 to allow the use of night vision goggles and forward-looking infrared devices for taking furbearers with a trapping license in Units 12, 19, 20, 21, 24, 25, 26B, and 26C.  The Board amended the proposal to change night vision goggles to “electronic enhanced night vision devices”.  

At the 2016 Statewide Board of Game meeting, the board adopted a proposal submitted by the Alaska Wildlife Troopers that prohibited the use of forward-looking infrared devices (FLIRs) for taking game. Prior to the board adopting the proposal in 2016, only night vision scopes were prohibited. The difference between electronically enhanced night vision and FLIR technology is that FLIR detects infrared radiation emitted from a heat source by using thermal or infrared technology to create a picture instead of amplifying visible light. FLIR devices make it possible to detect the heat of animals against cooler backgrounds and use advanced image correction technology. The FLIR technology is available in handheld cameras and cameras that can be attached to a smartphone, goggles, and rifle scopes. Night vision goggles and FLIR devices provide a greater aid to trappers allowing identification of and locating animals from far away through barriers such as snow and darkness.

In their comments about this proposal, ADFG writes, “The board adopted previous proposals to prohibit the use of night vision and FLIR devices because of concerns with increased harvest. The department cannot say what impacts this proposal will have if adopted. However, the department has some concern that harvest may increase and encourages the board to proceed cautiously should the board wish to adopt this proposal.” 

 The Board did not proceed cautiously, and authorized this technology across 7 game units, encompassing an area larger than the state of Montana ( over 158,000 square miles).

Reactivate wolf control in units 12, 20D, and 20E. The board adopted wolf (6,600 square miles) and brown bear (2,700 square miles) control in a portion of southern Unit 20E in Spring 2004, and control permits were issued beginning in the regulatory year 2004. In 2006, the wolf control portion of the program was expanded to 18,750 square miles to “benefit the Fortymile Caribou Herd”. The brown bear control portion was expanded to 4,050 square miles. 

The bear control portion of the program was removed in 2009 because “the bear removal objectives were not being met”. Moose were removed from the program in 2014 because no focused wolf control specifically intended to benefit moose had been conducted nor was any planned at that time. However, wolf control to “benefit the Fortymile Caribou Herd” continued through 2017, and it was assumed that moose within the active wolf control portions of the Upper Yukon–Tanana Predator Control Program would continue to benefit to some degree. Public aerial wolf control permits were issued annually between 2004- 2017, and department wolf control using helicopters was conducted in 2008, 2009, and between 2011-2017. The department wolf control was concentrated within the Fortymile Caribou Herd calving and postcalving range during 2011–2017. 

In their comments, ADFG wrote, “Because only 15% of the proposed area is within northwestern Units 12 and eastern 20D, the remainder of this analysis will focus on Unit 20E.” Basically, the wolf control on the caribou calving grounds wasn’t broad enough to include possible benefits for moose. 

The passage of this proposal reauthorized predator control in the tried-and-failed predator control area of 2004-2009 and added wolf control in units 12 and 20D.

Increased pressure on bears outside Arctic National Wildlife Refuge. The Board approved proposals 168 and 169, which lengthen the brown bear hunting seasons within the Dalton Highway Corridor Management Area for residents and nonresidents, and remove the resident registration permits RB988 and RB989 for brown bear in Unit 26B. This makes the brown bear hunting season longer and reduces Department supervision of the hunt by eliminating the registration hunts (that require hunters to apply for a permit). The Board also passed proposal 182, which lengthened the brown/grizzly bear season in Units 20A, 20B, and 25C for residents and nonresidents by two weeks to close on June 15.  Mating season occurs from mid-May to mid-July and thus an extended season further disrupts this important period.

Wolf control reauthorized along the eastern border of the Yukon Delta National Wildlife Refuge. The Board passed proposal 58, establishing a wolf control program in 19A. This was passed despite ADFG’s feasibility Assessment noting that this area had an active wolf control program for wolves from 2004-2008, however, it was “determined to be ineffective and was discontinued”. What’s more? The Board passed this predator control program without any information on the number of predators. This chart from the agency’s feasibility assessment says it all.

In addition, the assessment indicates that the ADFG does not know the effect of predation by individual predator species known for the ungulate species of interest in the proposed area as there have been no mortality studies conducted in this area.  Furthermore, the assessment states that the upper end of the current IM population objective in Unit 19A is 5,300 moose. The current population in Unit 19A is 5,500 moose. Thus the population is currently above the upper end of the IM population objective. 


The Ugly

Open Season on bears. It was a bad meeting for bears across the Interior, but particularly along the west/northwest borders of Denali National Park and Lake Clark National Preserve. Multiple proposals sought to lengthen seasons, increase bag limits, and liberalize bear-killing methods and means. Throughout our comments and advocacy, we encouraged the Board to deeply consider the lack of biological data on bears in the region, and if they did liberalize bear seasons, to do so incrementally. 

Instead, the Board went all in. 

Why were these changes so sweeping? Mostly for “regulatory simplicity”. Let’s look at a few examples.

Three proposals sought to liberalize bear hunting in 19C:

  • Proposal 95: Lengthen the brown/grizzly bear hunting season in Unit 19C by 52 days to open August 10 and close June 30. 

  • Proposal 97: Increase the bag limit from 1 bear to 2 bears per year in 19C.

  • Proposal 101: Allow brown/grizzly bears to be taken over bait in Unit 19C, and to be taken at a bait site the same day a hunter has flown. 

In their comments, ADF&G confirmed that there has never been a bear survey in any of Unit 19, but "based on the extrapolation of bear densities in similar habitats, the brown bear population in Unit 19C is estimated at 260 bears." The bear population of 19B is also unknown and was not estimated in ADF&G comments. 

Citing an interest in regulatory simplicity, the Board of Game amended proposals 95, 97, and 101 to include 19B, despite not being provided any bear data from 19B. 19C is 6,123 square miles. The proposal was amended to include 19B (6,828 square miles) without an analysis of the bear population in 19B. In total, these proposals increased the bear season by 52 days, doubled the bag limit, and permitted same-day airborne spring bait seasons for 12,951 square miles (just larger than the state of Maryland).  

The Board also took proposals from 19E and 21A and amended them to apply to all of Unit 19. 

Proposal 100 sought to lengthen the brown/grizzly bear season in Unit 19E to year-round (no closed season). In ADFG’s proposal presentation, they reported an estimate of just 50 brown bears in 19E.  In their written comments, ADFG writes, "[Brown bear] population surveys have not been conducted in Unit 19 and estimates of the bear population are based on extrapolated densities of similar habitats from other surveys. The brown bear population in Unit 19 is thereby estimated to be 900-1,250 brown bears."

With almost no brown bear population data, the Board of Game amended this proposal to apply to all of Unit 19, 21A, and 21E, and then passed it. 19E is 4,269 square miles. The board amended this proposal to apply to all of Unit 19, 21A, and 21E, increasing the affected area to approximately 47,400 square miles - that’s larger than the entire state of Pennsylvania.

Proposals 102 and 105 were much the same. The proposers sought to open a fall bear bait season in Unit 19E (Proposal 102) and 21A (Proposal 105). The Board first amended proposal 102 to apply to Units 19, 21A, and 21E, with season dates of 8/1 – 10/31, and to allow killing bears same day airborne over bait if within 300 feet of the plane. The proposal passed as amended. Again the proposals were originally drafted to open a fall bait season on ~4,200 square miles (19E) and ~6,600 square miles (21A), but were expanded without biological review to include over 47,000 square miles of the Interior.

An expansion of same-day airborne baiting, statewide. Prior to the meeting, it was legal to kill brown bears over bait the same day a hunter is airborne in Units 7, 11–13, 14A, 14B, 14C, the remainder of 15–16, 18, 19A, 19D, 19E, 20A, 20B, 20C, 20D north of the Tanana River, 20E, 20F, 21C, 21D, 23, 24C, 24D, 25C and 25D. 

By the end of the meeting, this method was expanded to include all of 19, 21A, 21E, all of 20D, 21B, and 24B. 

This was particularly disappointing in the context of Proposal 136, which succeeded in allowing brown bears to be killed over bait in Unit 20D south of the Tanana River. In the Department’s draft Brown Bear Management Report and Plan for 20D, ADFG wrote in the Conclusions and Management Recommendations section, “As of now, with the information available, the department is not comfortable with additional harvest pressure in Unit 20D. Total harvest and especially percent females in the harvest are at the maximum level within our harvest objectives that were developed based on DuBois 1995 estimate. It will likely be difficult to get a more detailed population estimate in the next few years because of the lack of a financially feasible technique being available. We remain committed to analyzing all available Unit 20D data that is available to the highest degree possible, including harvest data and collar tracking data regarding brown bears in this area. We also recommended a full population estimate of Unit 20D brown bears, especially Unit 20D south when funding and a technique becomes available to complete such an estimate. While the 5-year female harvest is averaging right at the recommended limit of 45%, and overall harvest is creeping up since the initiation of baiting in RY17 harvest trend data and anecdotal observations suggest the brown bear population is stable in Unit 20D. Therefore, no changes to the hunting season dates and bag limits are recommended at this time. With brown bear baiting only being authorized since RY17 very little harvest data is available at this time and the effects may not be fully noticed well into the next reporting period; therefore, harvest should be monitored closely during the next reporting period.”

However, when it came time to comment at the Board of Game, the Department flipped its position to support more brown bear baiting in 20D. In their comments, ADFG states “The department supports this proposal because the department recognizes the brown bear population can support an increase in harvest. However, the department does have a concern that harvest could exceed sustainable levels because southern Unit 20D is easily accessible due to an extensive trail and road network and there are a high number of black bear bait stations.”

Wolf control without a plan. Within the same morning, the Board made an Intensive Management finding for moose in 19, then created an IM plan in 19A, B, E, and then authorized wolf control along the western border of Denali National Park and Preserve (19C) under those brand new plans -  without a feasibility assessment. 


Read the summary of actions from the Interior Board of Game meeting here, as well as the meeting documents.

Read the summary of actions from the Arctic Board of Game meeting here, as well as the meeting documents.