Action Alert: Submit Your Comments on Central and Southwest Board of Game Proposals

The Board of Game Proposals for the Central and Southwest Region have been released and AWA is carefully combing through them so that we can best represent the needs of Alaska’s wildlife at the Wasilla Board of Game meeting in January. The public comment period is open until December 27, and we could use your voice to help safeguard Alaskan wildlife. 

What is the Board of Game?

The Board of Game (BOG) consists of seven members, each serving three years. There are no term limits. Members are appointed by the Governor and confirmed by the legislature. 

The BOG makes decisions regarding game management in Alaska, including population and harvest objections and hunting regulations. These decisions include when to open and close seasons, areas for hunting and trapping, bag limits, methods and means, setting “policy and direction” for state wildlife management, allocative decisions, and deciding population objectives across the state.  

The Alaska Department of Fish and Game (ADFG) is then responsible for enacting management based on those decisions.

The Proposal Process

Any Alaska resident can submit proposals to the Board of Game. Proposals are submitted and deliberated upon by region on a rotating basis, with a three-year cycle. For the 2024–2025 cycle, the BOG is accepting proposals for the Central and Southwest Region, which include the areas around Glennallen, Palmer, King Salmon, and Dillingham. Proposals for Southeast and Southcentral are next up, in the 2025–2026 cycle. 

In the spring, the BOG requested proposals, which had to be submitted by May 1 for the Central and Southwest Region. This is also when the BOG member confirmations are taken up by the legislature. 

In the fall, the proposal book is released online. Advisory Committees (ACs), local groups that function as mini BOGs, review and vote on the proposals. Their votes are sent to the BOG and can have an impact on the Board’s decisions. 

In December of this year, different departments, including ADFG, Alaska Wildlife Troopers, and the Department of Law, published most, if not all, of their comments on the proposals. These comments give valuable biological information and can provide a sense of what the departments feel about the proposals. 

On December 27, public written comments are due on proposals. This is where you come in! Public comments can sway the BOG’s decisions on what proposals to approve or deny. 

Between January 10 and 17, 2025, the Central and Southwest BOG Meeting will be held in Wasilla at the Best Western on Lake Lucille. There is a public comment period in the first few days, where written testimony may be given. Public comments are then closed and the BOG deliberates on all proposals. If you are interested in testifying, please contact nicole@awildlife.org for support and questions.

How to Get Involved

There are several ways to get involved in the BOG proposal process. You can submit your own proposals, get involved with your local AC, or engage with the BOG nomination and confirmation process. 

One of the easiest ways to get involved is to review proposals and submit written or oral testimony. Below, we’ll break down the proposals that AWA is concerned, and give you resources to submit your public comment by the December 27 deadline.

If you are interested in testifying and the January Board of Game meeting, please contact nicole@awildlife.org for support and questions.

If you missed our Wildlife Wednesday on the BOG proposals, you can watch the recording below.

Four 2024 Proposals AWA is Watching

Eighty-four proposals were submitted for the Central and Southwest Region; 8.3 percent of the proposals affect coyotes and wolves, while 27.4 percent affect bears. There are four proposals in particular that AWA is watching closely:

Proposal 75 - Aerial Gunning Outside of Denali: OPPOSE

Proposal 75 has the potential to become another Mulchatna Predator Control Program, which has so far killed over 200 brown bears in southwest Alaska. The proposal would add department removal of wolves, brown bears, and black bears to Unit 16’s Intensive Management Plan. Unit 16 lies between Denali National Park and Preserve and Lake Clark National Park and Preserve.

ADFG would be authorized to kill wolves, brown bears, and black bears with the use of aircraft, including helicopters, to achieve reduction goals. The reduction goals, according to Unit 16’s Intensive Management Plan are: 

  • Wolves: remove 73–80% of wolves in the area (population of 35- 55 wolves)

  • Brown bears: remove 60% of brown bears in the area (minimum population of 375)

  • Black bears: remove 60–80% of black bears in the area (minimum population of 700)

Why we oppose:

  • Studies have shown that Alaska’s predator control programs — aimed at boosting moose, caribou, and deer populations for hunters — do not increase human moose harvest.

  • Large carnivore management in Alaska is a reversion to outdated management concepts and occurs without effective monitoring programs designed to scientifically evaluate impacts on predator populations or identify causal relationships between predator control and pre-population dynamics.

  • If approved, this proposal would give ADFG full reign to implement an aerial gunning plan in Unit 16. Once a proposal like this is approved, ADFG has the authority to develop an Operational Plan for aerial gunning that is not open to public comment. 


Proposal 82 - Palmer Trapping Setbacks: SUPPORT

Proposal 82 is a special one for us, as it was originally submitted by AWA in 2022. We are calling for trapping setbacks in Palmer, Game Management Unit 14. Our proposal asks the BOG to establish a 50-yard trapping setback along specific trails in the area, particularly ones that are heavily used for recreational purposes. These trapping setbacks would help keep dogs and people safe from incidental trapping. 

Why we support:

  • This was a negotiated outcome. Originally submitted in 2022, the BOG deferred the proposal until a stakeholder meeting between trappers and nontrappers could be held to discuss the setback proposal. The meeting adjourned with consensus on the setback locations and conditions listed in the proposal.

  • Trapping setbacks are popular, easy to put in place, and seem to work; they have been successful in Unit 1C in Juneau and in the Anchorage municipality.

  • The setback distance is small enough to not significantly reduce the BOG’s ability to manage wildlife.

  • Trapping setbacks on these popular trails would help reduce incidental trap encounters with recreationists and their dogs. 


Proposal 11 - Shortened Brown Bear Seasons Near Katmai: SUPPORT

Proposal 11 is for Unit 9C, located around Katmai National Park in the King Salmon region. The proposal is to shorten the spring and fall brown bear seasons by one week, back to their previous length. This would re-establish the season as October 7–21 and May 10–25. The hunting season had been previously lengthened in 2022.

The author of the proposal notes that the area is home to the Moraine, Funnel, and Kulik Rivers, which are well-known by photographers, film crews, and wildlife viewing guides. With the current, longer season, sport fishermen and wildlife viewers on the rivers are being dropped off in the same places as hunters. Shortening the brown bear season would prevent further user conflicts and increase public safety. 

Why we support:

  • With the early season hunt, operators were still dropping off sport fishermen and wildlife viewers on rivers where bear hunting was taking place. Hunting camps and hunters were occupying critical habitats where bears were fishing, forcing other users to avoid these areas. 

  • Bears were shot right at the outlet of the Kulik River. The Kulik Lodge had employees breaking down camp, there were several groups of sport fishermen on the river as well as wildlife viewers. A bear had cached a hunter-shot carcass right at the outlet of the Kulik River where aircraft picked up sport fishermen and other visitors.

  • This proposal would restore the hunting season to the pre-2022 length and would reduce human-wildlife conflicts.


Proposal 29 - Mulchatna Caribou Herd Population Review: SUPPORT

Proposal 29 concerns the Mulchatna Caribou Herd (MCH) in Unit 17. The MCH has been on a sharp decline since the late 1900s, plummeting from 200,000 animals to an estimated 30,000 in 2019. In 2020, State biologists determined that the main reasons for the decline were disease and a lack of food, as a result of climate change. To save the Mulchatna herd, the State enacted the Mulchatna Predator Control Program, which targets bears and wolves, despite no evidence that predator control programs work or that predation was a main cause of mortality among the MCH. 

Proposal 29 calls for a review of the population and harvest objectives for the MCH. Minimum numbers are not being met, and the herd has declined far below lower population objectives. This review could help abate the State’s attempts to increase the caribou herd through predator control, which, in the two years that it has run, has killed over 200 bears in the area. 

Why we support:

  • The Mulchatna caribou herd has changed continuously from the time monitoring began. The current population objective (30,000-80,000) was established in 2008 at which point the population was estimated to be 30,000. This objective has been achieved only once since then.

  • Habitat quality has likely changed since the last population objective was established, and a new review should take this into consideration as it has almost certainly reduced population potential. 

  • A review of the population and harvest objective for the MCH would provide valuable data to inform game management and the Mulchatna Predator Control Program.

How to Submit a Comment

Public comments on the BOG proposals are open until December 27, 2024. The BOG has an online form where you can submit your comments.

For your comment, include the proposal number and clearly state whether you support or oppose the proposal.  You’ll also need to include your reasoning; feel free to use the information above, particularly the key points, and include any personal or anecdotal information you have to support your position. 

For more information on the individual proposals, reference the BOG proposal book.

Interested in the Other Proposals? 

AWA is currently combing through the proposals and determining our positions on them. Below is an inexhaustive list of the ones that are currently on our radar, grouped by region. For the full list of proposals, head to the BOG website for the proposal book. And, if you missed our Wildlife Wednesday on the BOG Proposals, check out the recording below.

Multiple and Regional Areas

  • Proposal 2: OPPOSE: This would open two bear baiting seasons in Units 9, 11, 13, 14B, 14C, 16, and 17, broadly expanding bear baiting. The ADFG is already killing bears under IM in Units 17, 18, and 19. There is also potential for user conflicts and more human and bear interaction in Units 13 and 14.

  • Proposal 3: OPPOSE: This would allow the use of cellular cameras for taking bears over bait in Units 9, 11, 13, 14B, 16, and 17. Bear baiters would be allowed to use game cameras that communicate wirelessly to locate, identify, and monitor activity at bait stations. If adopted, it would likely pursued statewide.


King Salmon - Units 9 and 10 

There were numerous proposals regarding bears for this region. Unit 9 in particular is complicated, as it contains areas around Katmai as well as more remote areas, and it is difficult to obtain bear population and density estimates. There are several proposals to both shorten and lengthen bear seasons in the area. Proposal 9, and 12 through 17 ask to lengthen the season, while Proposals 11 and 18 call for a shortened season.

In general, we support proposals that reduce conflict and promote conservation.


Dillingham - Unit 17

Many of the proposals for Unit 17 concern the Mulchatna caribou herd (MCH). Proposals to close hunting caribou align with regulations across the MCH’s range, including a four-year moratorium on neighboring Unit 18 that was put in place at the Arctic and Western Region BOG meeting in Kotzebue. AWA opposes proposals that increase the killing of predators in the area, as there is already a Mulchatna Predator Control Program approved through 2028.

  • Proposal 30: SUPPORT: This calls for a three-year moratorium on caribou hunting in Units 9b, 17, 19A, and 19B, which is within the Mulchatna caribou herd’s range.

  • Proposal 31: SUPPORT: This would close the caribou season in 9B, 17, 19A, and 19B until the Mulchatna herd population numbers have reached or exceeded the 30,000 animal threshold for harvest. 

  • Proposal 32: OPPOSE: This would allow the year-round killing of bears in Unit 17, with two bears per year. We believe that every species needs a resting period. ADFG also states that hunting should be avoided while a predator control program is in place, which it is. 

  • Proposal 33 and 34: OPPOSE: This would allow same-day airborne killing of brown bears (33) and wolves (34) in Unit 17. Same-day airborne take of wolves in 17 is prohibited by statute unless under a permit issued by an IM program. 

Other proposals include: 

  • Proposal 28: SUPPORT: This proposal would reduce population and harvest objectives for moose in 17B. Minimums have only been met a few times in the last 40 years, so this would make the estimates more realistic. Reasonable population numbers might also encourage ADFG to not implement Intensive Management. 

  • Proposal 35 and 36: SUPPORT: This would shorten the wolverine trapping season in Units 9 and 17 to the first day of February (35), and shorten hunting in Unit 17 to September 1-February 29 (36). The extended season allows the killing of female wolverines during denning. 


Glennallen - Units 11 and 13

There are several proposals to change the population and harvest objectives for moose in Unit 13, which extends from Denali State Park to the border of Wrangell-St. Elias. AWA is supporting Proposal 39 and Proposal , which reduce population and harvest objectives to more reasonable numbers. 

Proposals 43 through 47 all suggest changes to moose hunting regulations.

Proposals 48 and 49 deal with the Nelchina caribou herd. Proposal 48 modifies the IM plan for Unit 13 to include Nelchina caribou (the current program is for moose). Proposal 49 would close caribou hunting for six years, or until the herd reaches the management objective of 37,500. 

Proposals 50 through 56 concern sheep and goats. 

Proposals 57 through 60 concern bears and wolves in Units 11 and 13. We are opposing all of them. 

  • Proposal 57: OPPOSE: This would increase the bag limits for brown bears in Unit 13 from one to two. 

  • Proposal 58: OPPOSE: This would reduce the minimum wolf population in Unit 13’s Intensive Management plan to 100. The current spring population is around 300. This would significantly lower the population from historical numbers. 

  • Proposal 59 and 60: OPPOSE: This would lengthen wolf (59) and/or coyote (60) trapping season, and would interrupt breeding season. Spring furs are also lower quality. 

Proposals 61 and 63 deal with ptarmigan hunting, both changing the season dates and requiring registration permits. AWA supports both proposals. 


Palmer - Units 14A, 14B, and 16

AWA is primarily concerned with the proposals dealing with bears for this region. We oppose Proposals 70, 71, 72, 76, and 77

Proposals 79 through 82 deal with trapping regulations in the area. AWA opposes Proposal 79, and supports Proposals 80.

There are numerous proposals for changes in moose hunting regulations