Our Voice for Ecosystem-Based Management at Alaska’s Board of Game
We submitted comments on the 2020 Board of Game proposals, available for you here.
Proposal 46: Establish intensive management programs for bear across the Interior and Eastern Arctic Region
Alaska Wildlife Alliance Comment on Proposal 46
Alaska Wildlife Alliance opposes this proposal on the grounds that, at the very least, a feasibility assessment should be conducted to determine if predators are the true cause of ungulate declines. Further, an Intensive Management program should only be implemented with a statement of objectives and an outcome monitoring protocol to the degree prescribed by the ADF&G Intensive Management protocols.
In 2013, the Alaska Chapter of The Wildlife Society adopted their position statement on Intensive Management (IM). This multiagency group of wildlife professionals concluded that while the IM protocol is a positive advance in implementing IM, there are still several outstanding concerns including:
(1) the authority of Advisory Committees to revoke cow and calf moose hunts in their geographic areas (which can skew bull:cow ratios and/or give the appearance of reduced populations for harvest);
(2) the fact that achieving IM objectives may require removing more predators or more predator species than is possible in some programs, especially where predator reduction is primarily based on public participation;
(3) some ungulate population objectives may be unattainable due to habitat limitations or other environmental factors;
(4) the operational costs for IM are high, requiring as much as a third of the operations and salary budget of the Division of Wildlife Conservation in some regions;
(5) IM programs are not usually intended as research into predator-prey dynamics, which would require designed experiments with explicit controls; and
(6) the efficacy of IM programs are difficult to assess when they deviate from a structured decision framework in response to public demand for increased efficacy or participation.
None of these concerns are addressed in the proposal.
The Alaska Wildlife Alliance acknowledges that Intensive Management is a law that can be applied to temporarily increase the recreational harvest of moose, caribou and Sitka black-tailed deer on lands that the State of Alaska has authority over. We recognize that control of predators is a tool in wildlife management that in some circumstances may be appropriate to restore or prevent the extinction of rare, threatened and endangered species, small populations, and insular populations such as islands.
However,
We are concerned that IM population and harvest objectives have not been reassessed since their inception as recommended by the Alaska Chapter of The Wildlife Society;
We are concerned that ADF&G and BOG have not established a standard to determine if the “prey population is feasibly achievable utilizing recognized and prudent active management techniques” nor a process to disapprove IM action if it is likely to be “ineffective, based on scientific information”;
We are concerned that predator control is effectively the default mechanism that BOG uses to accomplish the IM law’s desired outcome of increasing recreational harvests of moose and caribou;
We are concerned that the BOG is disingenuously stepping around the rigorous and expensive demands of a scientifically-based IM program by promoting liberalized hunting and trapping regulations for carnivores outside designated Predator Control Areas;
We are concerned that big game management in Alaska has become a process whereby population objectives for wild ungulates are established based on public demand rather than on habitat capacity, promoting unsustainable management;
We are concerned that “sustained yield” as currently used is an artificial construct (a definition has not yet been codified) that does not appropriately consider large scale variation in ungulate populations that occur because of wildfire regimes and cyclic insect defoliation, as well as the cascading effects of a warming climate (in fact, the need to apply predator control is antithetical to scientifically-accepted definitions of sustained yield);
We are concerned that the economic costs of sustained predator control at landscape scales are generally so high that sustained yield becomes a euphemism for subsidized yield;
We are concerned that other human sources of ungulate mortality (e.g., moose-vehicle collisions, illegal and unreported harvest) are being ignored in the BOG’s interest in promoting predator control;
We are concerned that predator control undermines the ethos of humans learning to coexist with wildlife.
Proposal 55: Allow the use of dogs for hunting for lynx in Units 12 & 20
Alaska Wildlife Alliance Comment on Proposal 55
Alaska Wildlife Alliance opposes this proposal because the proposed hound hunting season overlaps with the trapping season and would likely lead to dogs being caught in traps.
Proposal 56: Establish minimum distance requirements for trapping around dwellings in the Interior and Eastern Arctic Region
Alaska Wildlife Alliance Comment on Proposal 56
Alaska Wildlife Alliance supports this proposal. Establishing a one-mile buffer around dwellings does not pose a significant restriction on trappers, and protects the pets of local residents. This proposal is both ethical and reasonable. The Board of Game is tasked to manage for all Alaskans, including those who wish to have their pets and children roam free around their homes.
Proposal 57: Allow residents to take game from a boat under power in Unit 21
Alaska Wildlife Alliance Comment on Proposal 57
Alaska Wildlife Alliance opposes this proposal on the grounds that it violates tenants of ethical sport hunting and fair chase. Residents are already at an advantage in boats, and if taking caribou without power poses a significant safety risk or restriction, we recommend these hunters utilize alternative tactics.
The hunters in our membership agree that one of the most basic tenets of fair chase is determining if an animal has a reasonable opportunity to escape. If it does not, the sport hunt cannot be considered fair chase. That is because fair chase applies the hunter’s acquired knowledge of the animal against the animal’s own superior senses and evasive capability.
When the challenges of hunting are eliminated, we risk losing the special nature of the hunting experience itself. Most hunters agree that the uncertainty and the “no-guarantees” character of sport hunting is its most powerful attraction.
Recognizing that humans are the alpha predator and that there is a need to limit our hunting advantage over wildlife is key to using technology in an ethical manner. A fair chase sport hunter does not measure success by the sophistication of the technology they employ, but by the level of restraint they use.
Proposal 63: Repeal the Dalton Highway Corridor Management Area
Alaska Wildlife Alliance Comment on Proposal 63
Alaska Wildlife Alliance and its members oppose this proposal on the grounds that this would liberalize sport hunting in an area essential to the Central Arctic Caribou herd while their numbers continue to decline. Since it peaked in 2010 at 70,000 animals, the size of the Central Arctic herd has fallen 69 percent — to 50,000 in 2013 and 22,000 in 2016.This repeal would remove significant protections against sport hunting from the road in the corridor. These protections were put in place upon the approval of the highway to:
Protect the pipeline from bullet-fire;
Satisfy citizenry concerns that the road would open remote country to liberalized hunting practices.
Many of our members and Board have bow hunted in the area and request that the status quo be maintained to avoid further pressure on the Central Arctic caribou herd. We also note that this proposal does not address a subsistence issue, as subsistence use is recognized in the existing management plan.
Proposal 64: Clarify the legal use of highway vehicles, snow machines and off-road vehicles in the Dalton Highway Corridor Management Area for hunting and trapping.
Alaska Wildlife Alliance Comment on Proposal 64
Alaska Wildlife Alliance opposes this proposal on the grounds that what is set forth as a request for clarity would open the Dalton Highway Corridor to unsustainable sport hunting. When the Pipeline Authorization Act was considered, and then passed [1973], one prevailing argument against the pipeline was that the road and pipeline would open the central Brooks Range to roadside sport hunting. Sport hunting was thus prohibited within 5 miles of the road. That protection has been an Alaska statute, now codified as AS 19.59.
Members of our Board have hunted the Dalton several times with gun and bow. Recreational gun hunting needs to be greater than 5 miles away from road, both the protect the declining Central Arctic Caribou herd and shelter the pipeline from being damaged by bullet fire. The Central Arctic caribou herd has been in decline for the past 5 years and thus it would be a mistake to open the corridor to the possibility of roadside gun hunts at this time.
Proposal 75: Develop a feasibility assessment for intensive management of wolves and bears in Units 21D and 24
Alaska Wildlife Alliance Comment on Proposal 75
Alaska Wildlife Alliance opposes this proposal. We acknowledge that Intensive Management (IM) is a law that can be applied to temporarily increase the recreational harvest of moose, caribou and Sitka black-tailed deer on lands that the State of Alaska has authority over. We recognize that control of predators is a tool in wildlife management that in some circumstances may be appropriate to restore or prevent the extinction of rare, threatened and endangered species, small populations, and insular populations such as islands.
At present, this proposal does not satisfy the temporary or extreme circumstances listed above.
We are concerned that ADF&G and BOG have not established a standard to determine if the “prey population is feasibly achievable utilizing recognized and prudent active management techniques” nor a process to disapprove IM action if it is likely to be “ineffective, based on scientific information”. Thus, such standards should be clarified before a feasibility study can be conducted responsibly.
We further request that the following concerns be addressed if such a feasibility assessment were conducted:
We are concerned that some methods (i.e., snaring of bears and wolves, “denning” of wolf pups) used in Predator Control Areas continue to be inhumane;
We are concerned that IM population and harvest objectives have not been reassessed since their inception;
We are concerned that predator control is effectively the default mechanism that BOG uses to accomplish the IM law’s desired outcome of increasing recreational harvests of moose and caribou;
We are concerned that the BOG is disingenuously stepping around the rigorous and expensive demands of a scientifically-based IM program by promoting liberalized hunting and trapping regulations for carnivores outside designated Predator Control Areas;
We are concerned that big game management in Alaska has become a process whereby population objectives for wild ungulates are established based on public demand rather than on habitat capacity, promoting unsustainable management;
We are concerned that “sustained yield” as currently used is an artificial construct (a definition has not yet been codified) that does not appropriately consider large scale variation in ungulate populations that occur because of wildfire regimes and cyclic insect defoliation, as well as the cascading effects of a warming climate (in fact, the need to apply predator control is antithetical to scientifically-accepted definitions of sustained yield);
We are concerned that the economic costs of sustained predator control at landscape scales are generally so high that sustained yield becomes a euphemism for subsidized yield;
We are concerned that the secondary ecological (e.g., loss of marine derived nutrients) and economic (e.g., loss of bear viewing) effects of predator control are not considered;
We are concerned that other human sources of ungulate mortality (e.g., moose-vehicle collisions, illegal and unreported harvest) are being ignored in the BOG’s interest in promoting predator control;
We are concerned that the BOG, at most, only represents the interests of ~25% of Alaskans who hunt but is promoting practices such as predator control and liberalized harvest that have outcomes that affect all Alaskans;
We are concerned that predator control undermines the ethos of humans learning to coexist with wildlife;
Lastly, we are concerned that predator control promotes a utilitarian view of wildlife as commodities rather than recognizing the intrinsic value of all wildlife (including large carnivores) and sustaining intact ecosystems.
Proposal 105: Authorize predator control for wolf and bear in Unit 19A
Alaska Wildlife Alliance Comment on Proposal 105
Alaska Wildlife Alliance opposes this proposal. Such a regulatory amendment should, at the very least, be subjected to feasibility assessments prior to determining if the area is truly deserving of Intensive Management (IM). Part of that assessment should include a statement of objectives and plans to monitor outcomes to the degree prescribed by the ADF&G IM protocols. We are also concerned that ADF&G and BOG have not established a standard to determine if the “prey population is feasibly achievable utilizing recognized and prudent active management techniques” nor a process to disapprove IM action if it is likely to be “ineffective, based on scientific information”. Such standards should be clarified before a feasibility assessment can be responsibly conducted.
We also request the following concerns be addressed before implementing an intensive management plan per this proposal:
We are concerned that predator control is effectively the default mechanism that BOG uses to accomplish the IM law’s desired outcome of increasing recreational harvests of moose and caribou;
We are concerned that the BOG is disingenuously stepping around the rigorous and expensive demands of a scientifically-based IM program by promoting liberalized hunting and trapping regulations for carnivores outside designated Predator Control Areas;
We are concerned that big game management in Alaska has become a process whereby population objectives for wild ungulates are established based on public demand rather than on habitat capacity, promoting unsustainable management;
We are concerned that “sustained yield” as currently used is an artificial construct (a definition has not yet been codified) that does not appropriately consider large scale variation in ungulate populations that occur because of wildfire regimes and cyclic insect defoliation, as well as the cascading effects of a warming climate (in fact, the need to apply predator control is antithetical to scientifically-accepted definitions of sustained yield);
We are concerned that the economic costs of sustained predator control at landscape scales are generally so high that sustained yield becomes a euphemism for subsidized yield;
We are concerned that the secondary ecological (e.g., loss of marine derived nutrients) and economic (e.g., loss of bear viewing) effects of predator control are not considered;
We are concerned that other human sources of ungulate mortality (e.g., moose-vehicle collisions, illegal and unreported harvest) are being ignored in the BOG’s interest in promoting predator control.
Proposal 150: Establish an intensive management plan for wolves and bear in the Minto Flats Management Area in Unit 20B
Alaska Wildlife Alliance Comment on Proposal 150
Alaska Wildlife Alliance opposes this proposal and requests that the following concerns be considered if such a feasibility assessment were conducted:
We are concerned that some methods (i.e., snaring of bears and wolves, “denning” of wolf pups) used in Predator Control Areas continue to be inhumane;
We are concerned that IM population and harvest objectives have not been reassessed since their inception;
We are concerned that ADF&G and BOG have not established a standard to determine if the “prey population is feasibly achievable utilizing recognized and prudent active management techniques” nor a process to disapprove IM action if it is likely to be “ineffective, based on scientific information”;
We are concerned that predator control is effectively the default mechanism that BOG uses to accomplish the IM law’s desired outcome of increasing recreational harvests of moose and caribou;
We are concerned that the BOG is disingenuously stepping around the rigorous and expensive demands of a scientifically-based IM program by promoting liberalized hunting and trapping regulations for carnivores outside designated Predator Control Areas;
We are concerned that big game management in Alaska has become a process whereby population objectives for wild ungulates are established based on public demand rather than on habitat capacity, promoting unsustainable management;
We are concerned that “sustained yield” as currently used is an artificial construct (a definition has not yet been codified) that does not appropriately consider large scale variation in ungulate populations that occur because of wildfire regimes and cyclic insect defoliation, as well as the cascading effects of a warming climate (in fact, the need to apply predator control is antithetical to scientifically-accepted definitions of sustained yield);
We are concerned that the economic costs of sustained predator control at landscape scales are generally so high that sustained yield becomes a euphemism for subsidized yield;
We are concerned that the secondary ecological (e.g., loss of marine derived nutrients) and economic (e.g., loss of bear viewing) effects of predator control are not considered;
We are concerned that other human sources of ungulate mortality (e.g., moose-vehicle collisions, illegal and unreported harvest) are being ignored in the BOG’s interest in promoting predator control;
We are concerned that the BOG, at most, only represents the interests of ~25% of Alaskans who hunt but is promoting practices such as predator control and liberalized harvest that have outcomes that affect all Alaskans;
We are concerned that predator control undermines the ethos of humans learning to coexist with wildlife;
Lastly, we are concerned that predator control promotes a utilitarian view of wildlife as commodities rather than recognizing the intrinsic value of all wildlife (including large carnivores) and sustaining intact ecosystems.
Proposal 151: Change the season dates for hunting wolves in a portion of Unit 20C
Alaska Wildlife Alliance Comment on Proposal 151
Alaska Wildlife Alliance opposes this proposal because the conditions that gave rise to the shortened season in 2016, per 2016 Proposal 141, have not been resolved— realigning the two seasons would simply repeat the history that led to an emergency closure in May 2015.
In 2016, Denali National Park put forward Proposal 141. The proposal argued that the changes in hunting regulations that allowed for the taking of brown bears at bait stations along with the lengthening of the wolf hunting season to May 31 had exposed wolves that are attracted to bait stations to increased and unforeseen harvest pressure in the Stampede Corridor within Unit 20C. The proposal was supported by the Middle Nenana AC and the BOG.
In early May 2015, Denali National Park and Preserve staff learned that a collared male wolf from the East Fork pack (1507GM) and an un-collared and reportedly pregnant female wolf were shot by a hunter at an illegally kept bear baiting station outside of the park near the Stampede Trail. GPS data provided by 1507GM's collar indicated that he had spent most of the prior week at a location within a mile of the location where he was shot. Upon investigation, park staff learned that there was a bear baiting station within a quarter of a mile from where the two wolves were shot and the bait station was the same location where GPS data indicated the collared wolf had been the prior week.
There was no evidence that the East Fork pack denned in 2015. The loss of the pregnant female thus may have represented a loss of the reproductive potential for this pack and potentially represents the first time that the East Fork pack has not produced pups in over 28 years of continuous monitoring of this pack.
Although it was known that the open season for bear baiting in the Stampede area (April 15-June 30) would overlap the hunting season for wolves, this was the first time that there was evidence that a bear baiting station attracted wolves and increased their vulnerability to hunting. Park staff shared the information gathered from their investigation with the Alaska Department of Fish and Game. Soon after, the Commissioner issued an emergency order closing the wolf hunting season in the area two weeks early, stating that:
"The department has received new information that has led to the decision to close wolf hunting in the area of Game Management Unit 20C along the Stampede Trail near Denali National Park. Trapping seasons are already closed for this regulatory year. The normal hunting season for wolves ends on May 31 in this area. There are no conservation concerns for wolves in Game Management Unit 20C, which includes a large portion of the park. However, changes in bear hunting regulations have increased the chances of wolves that primarily inhabit the park being taken as they venture on to adjacent lands. On average, this general area has a harvest of about four wolves per year and, prior to this year, little of that harvest had occurred in May. The controversy regarding the so-coiled "wolf buffer" is centered around the allocation of wolves between harvest through trapping and hunting and wildlife viewing opportunities for Park visitors. Allocation issues are the purview of the Board of Game. This temporary closure will allow the board to revisit the issue in light of the new information without additional take of wolves this May adding to the controversy.”
Although wolf populations may be able to compensate for losses from low levels of harvest through increases in reproduction or immigration or reductions in emigration, at low densities, the ability for the wolf population to compensate through movement in or out of the population is limited by fewer wolves available. The unforeseen effect of additional harvest, particularly during the season when females are pregnant, can remove the reproductive capacity of for entire packs. Thus, the timing of this unforeseen additional harvest (which overlaps with the whelping and nursing period) combined with the current population status indicate the potential for population level impacts and present a legitimate conservation concern.
This proposal requests a concurrent change to the wolf hunting season to extend wolf hunting through the end of May. Wolves are known to be attracted to bear baiting stations (Bump et al 2013) but the effect of these bear hunting regulations on wolf take (legal until May 3 I under existing regulations) was unforeseen when the bear hunting regulations were adopted in 2012. However, as evidenced by the 2015 emergency closure and 2016 proposal, they have now been tested and found unacceptable.
For all the reasons listed above, and with the support of the Middle Nenana Advisory Committee in 2016, the season was shortened. To open the season again so that it overlaps with the brown bear baiting season would simply be history repeating itself:
There are no additional wildlife troopers to ensure that bear baiting stations are legally kept;
Wolves will still be attracted to the bait stations;
Wolf movement is largely the same in this area;
The hunter who took these wolves under illegal circumstances is still permitted to bait in this area, despite the outcry from local trappers that they not be permitted to operate in the area because of their behavior in 2015.
Finally, the shortened season (again, with the support of the local AC in 2016) does not burden hunter opportunity, as only two trappers (on average) utilize the area and the closure is at a time when pelts are of less quality.
Proposal 152: Establish closed areas for the taking of wolves near Denali National Park in Unit 20C
Alaska Wildlife Alliance supports this proposal, Closure Option 1 for the following reasons:
Proposal 152 is NOT an attempt to expand the park. It is an attempt to reduce the risk on wolves that venture onto state lands, during those weeks and months from February until summer, when research (Borg et.al 2016) finds they are consolidating their family groups, mating, and establishing territories, and when the death of a breeding wolf is most damaging to the integrity of the pack.
This is well within the interests and mandates of the Board of Game:
Statewide policy recognizes both consumptive and non-consumptive management options. “…ADF&G will manage wolf populations to provide for human uses and to ensure that wolves remain an integral part of Interior Alaska's ecosystems. Compatible human uses include hunting and trapping (both for personal use and commercial sale of furs), photography, viewing, listening, and scientific and educational purposes (ADF&G 2002). The aesthetic value of being aware of or observing wolves in their natural environment is also recognized as an important human use of wolves. We also recognize that integral to wolf management is the premise that wolf populations are renewable resources that can be harvested and manipulated to enhance human uses of other resources. Management may include both the manipulation of wolf population size and total protection of wolves from human influence…”- Species Management Report and Plan ADFG/DWC/SMR&P – 2018-30
The Denali region, and specifically the Stampede townships, are by history, science and public opinion the ideal state lands on which to practice non-consumptive use of wolves. Furthermore, there is nothing in the Board of Game policies that prevents managing at a sub-population level.
This is not a subsistence issue. Wolf hunting and trapping in the area identified for closure in Stampede lands does not satisfy the eight criteria for Customary and Traditional Use (5 AAC 99.010).
This proposal does not assert a biological emergency or population-level crisis. It is meant to prevent disruption of wolf packs during late winter and spring, making it more likely that their denning activities inside the National Park are completed successfully.
Wildlife viewing also brings an important socio-economic benefit to the state of Alaska, with wildlife viewing activities in Alaska supporting over $2.7 billion dollars in economic activity in 2011. Forty percent of visitors to Alaska reported hoping to view wild wolves during their visit. (ECONorthwest 2012). This proposal provides wildlife viewers an increased opportunity to see wolves, just as the Board of Game provides increased opportunity for hunters to utilize wildlife through consumption with annual proposals.
The average number of people hunting and trapping wolves in the proposed closure is less than two people per year over the last 20 years. Those average two individuals would only lose 29% of their access to wolf hunting and 50% of their access to wolf trapping (in days) in this area. It is important to note that wolf hunting and trapping opportunities are still available in surrounding game units— this would not preclude people from trapping anywhere else outside this small area during the breeding season. The impact on trappers presents less than a 50% compromise. Meanwhile, over 400,000 people visit DNPP and, like the hunters who have opportunity to consume these wolves, have a right for the opportunity to view wolves.
As Alaskans, we ask that the Board of Game recognize non-consumptive interests as legitimate user group that deserves consideration, particularly when hunter interests are also considered and protected in the proposal. If this proposal passes, the Board of Game can take credit for supporting compromise in an area known for controversy since the 1990s. This is a compromise between hunting opportunity and wildlife viewing in its most studied and reasonable form.
A lack of compromise has led many Alaskan wildlife viewers and advocates to pursue protections outside the authority of the Board of Game, and if continually sidelined from management discussions, those efforts will likely continue. In 2017, the Alaska House approved HB 105 to create a 530 square mile buffer in this area, there is currently a petition with over 371,000 signatures requesting a full buffer, and in 2019 an Alaska-based petition requested an emergency closure. A compromise, as outlined in this proposal, may satisfy the viewability concerns by making denning inside the Park more successful. The Board has a responsibility to manage State lands for all Alaskans, and this proposal provides the opportunity for scientists to see if a wolf buffer is necessary for meeting the needs of viewability advocates, thus resolving the issue through the Board of Game as intended.
Protections in this area have historically been win-win. The presence of the buffer did not decrease the average annual number of wolves hunted or trapped in UCUs overlapping the Stampede Corridor (UCUs 502, 605, 607), in fact wolf take was higher during the years the buffer was in place (Alaska Department of Fish & Game 2013). During the presence of the buffer zone, hunting and trapping of wolves adjacent to DNPP was on average greater than during the period without the presence of the buffer zone. Simultaneously, the buffer was associated with substantially increased wolf sightings (Borg et al 2016).
We recognize that this proposal does not remove all risks to wolves. However, given the almost unlimited take authorized under current Fish and Game hunting/trapping regulations, those local wolves that are most viewed and studied remain vulnerable to disruption and possible complete loss of the pack.
As an organization, we appreciate the contributions hunters have made to Alaska's economy and conservation efforts. We also advocate for our non-consumptive members who utilize wildlife through tourism revenue, photography, or personal wildlife viewing. Those Alaskans, equal under the State Constitution, must also be considered. This proposal, unique to the past proposals in the long history surrounding this issue, addresses both user group interests in an effort at compromise.
Thank you for your consideration.
