This January, the Alaska Board of Game (BOG) will deliberate on nearly 200 proposals impacting wildlife, including Proposal 75, which was submitted by the Alaska Department of Fish and Game (ADFG). ADFG is requesting sweeping authority to aerially gun wolves and bears on the west side of Cook Inlet, between Denali National Park and Lake Clark National Park.
Proposal 75 would authorize ADFG staff to kill black bears, brown bears, and wolves with the use of aircraft, including helicopters, in all of Game Unit 16 to “achieve [predator] reduction goals”.
About Unit 16
Game Management Unit 16 is approximately 22,000 square miles, about the size of West Virginia. The area consists of the drainages into Cook Inlet between Redoubt Creek and the Susitna River, the drainages on the west side of the Susitna River (including the Susitna River) upstream to its junction with the Chulitna River, the drainages into the west side of the Chulitna River (including the Chulitna River) upstream to the Tokositna River (including the Tokositna River), and drainages into the south side of the Tokositna River upstream to the base of the Tokositna Glacier. It also includes all seaward waters and lands within three miles of these coastlines.
The area proposed for aerial gunning shares borders with Denali National Park, Denali National Preserve, Denali State Park, Lake Clark National Preserve, and Lake Clark National Park, which are all used by non-hunting recreationists and wildlife enthusiasts. The area also surrounds the communities of Tyonek, Skwetna, Petersville, Peters Creek, and Alexander, and neighbors well-traveled communities like Talkeetna, Willow, and Caswell.
While people enjoy the experience of watching bears feed on the sedge grasses, clams, and fish in the world-famous Chitina Bay, just 40 miles north other bears may be shot from helicopters in the Redoubt Creek drainage. While people flock to Denali National Park and Denali State Park in hopes of seeing wolves, packs just south of those boundaries may be decimated by the same predator control program. And when those of us living in Anchorage and the Kenai Peninsula look across the Cook Inlet, soon we could be viewing an active aerial gunning program on some of Alaska’s most cherished wildlife.
What’s more, there are already ongoing IM and predator control programs in Units 13 and 17, which flank Unit 16 to the east and west. With an active predator control program in Unit 16, this could mean over 600 miles of land stretching east to west across the state would be managed to reduce or remove predators.
History of Intensive Management in Unit 16
The State of Alaska has been implementing an Intensive Management program against predators in portions of Unit 16 for over twenty years to increase moose populations.
In 2003, the State began an Intensive Management (IM) program against wolves in 6,972 square miles of Unit 16. The program faced legal challenges, including those brought by Alaska Wildlife Alliance, and in 2006 the Board of Game held an emergency meeting to revise the Intensive Management plan to bring it into compliance with Alaska law by adding plan justifications, methods and means, predator and prey population objectives, and a time frame for updates and evaluations.
Later that year, after outlining the bare minimum in the plan to comply with the statute, the State increased the predator control area to 7,792 square miles and authorized public aerial shooting permits and public land-and-shoot permits.
In 2007, the Board added black bear removal to the plan and reauthorized the program for another 5 years, running from 2007 to 2012. Under the new black bear control provisions, the public could kill an unlimited number of black bears, cubs, and sows with cubs, and allowed fall black bear baiting. The goal was to reduce the black bear population by 60%.
In 2009, it got worse. The State authorized black bear snaring for the entire summer, allowed young hunters (10 to 15 years old) to kill bears, and allowed the use of helicopters to access black bear bait and foot-snaring camps.
In 2011, the Board reauthorized this plan for another 6 years, extending it to 2017 and adding brown bears. Under the expanded program, the public could kill brown bears over bait or with bucket snares
Example of a bucket snare. Bears reach in to retrieve the bait in the back of the bucket, which pulls on the trigger, and cinches the loop around the bear’s foot.
In the Spring of 2012, ADFG staff studied the moose calf mortality survey in the Tyonek study area. After all, the predator-killing program was designed to benefit moose. However, the study found that calf survival remained low despite IM efforts. A spatial analysis “showed no relationship between bear harvest locations and calf survival within the Tyonek study area”( Operational Plan for Unit 16 IM, page 5).
In 2013, the Board re-assessed the plan and suspended predator control activities.
The state restarts the im program in unit 16
After just two short years, in 2015 the State began its IM activities in Unit 16 again. The Board Authorized an Intensive Management plan with the following objectives:
Reduce wolves by 70 to 80%, resulting in a population of 35 to 55 wolves (.34 - .54 wolves/100 square miles) for Unit 16B. Unit 16B includes Denali and Lake Clark National Park and Preserve lands, but those federal lands are closed to aerial gunning.
Reduce brown bear populations in 16B by 60%, and 80% for black bears, resulting in an estimated abundance of 375 brown bears and 700 black bears. There is no reliable information on black bear population status or trends in this area. Despite this, the Department made a “removal” goal of 60-80%.
Because it was deemed “ineffective”, in 2017 the bear control was suspended. We anticipate that, with Proposal 75, ADFG will seek re-authorization of bear control at the Board of Game meeting in January.
How are moose, wolf, and bear populations measured for unit 16?
Moose: The IM objectives for moose in Unit 16 are a population size of 6,500 to 7,500 and a harvest between 310 and 600. In 2019, population estimates indicated that the moose population was well above the midpoint population objective, and harvest was also well within objectives and approaching the midpoint. Therefore, the IM objectives for moose population had been met.
Wolves: The most recent fall abundance estimate for Unit 16 was conducted over twenty years ago in 2003, based on a wolf study conducted in the winter of 1999. A minimum number of wolves was established in 1999 based on the number of wolves caught during the study. The estimate was “refined” in 2014.
Black bears: The last fall abundance assessment was conducted in 2007 using a line-transect sampling method. Density estimates were measured at 187 bears/1,000 km and were extrapolated to all of 16B. The spring abundance was estimated as being between 300 to 3,500 black bears. However, as ADFG writes in their Black Bear Management Report and Plan, Game Management Unit 16, “simple, repeatable, and accurate surveys have not been developed to assess the Unit 16 black bear population density.”
Brown bears: Similar to black bears, portions of 16B were sampled in 2007. Those data were integrated with a density continuum from Units 9 and 13 to determine a brown bear density of 40 bears/1,000km. The spring abundance for Unit 16 was estimated as being between 313 to 937 brown bears.
What does this mean for 2024 and proposal 75?
The State has set a goal of 35 to 55 wolves, meaning the State’s goal is to kill “at least 113 wolves” (Department comments on Prop 75, page 224). The proposal does not expressly outline a reduction goal for bears, but in the existing predator control plans for Unit 16, the goal is to reduce black bears by 60 to 80% and brown bears by 60%.
In their proposal, ADFG states that “the department has no plans to activate bear control at this time”, yet the State has a track record of authorizing bear control programs without a proposal, and of authorizing bear control in this game unit. The Department would not ask for the authority to aerially gun both wolves and bears unless they had the private inclination to add bear control within the next three years.
Key Points:
AWA OPPOSES Proposal 75 for the following reasons:
Alaska’s predator control programs — aimed at boosting moose, caribou, and deer populations for hunters — do not work to increase human moose harvest. A 2022 article by ADFG and University of Alaska Fairbanks biologists published in the scientific journal Diversity, found no increase in moose harvests in the years following nearly 40 years of predator control in Southcentral Alaska. Listen to an interview with the author here.
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 prey population dynamics. Large carnivore management in Alaska should be based on rigorous science including the status and trends of carnivore populations - this program does not meet those standards. Read more in the 2019 article, Large carnivores under assault in Alaska, which was authored by three Alaska state and federal wildlife biologists.
The proposed aerial gunning program borders some of the most iconic wildlife viewing areas in the world. Predator control is not popular with the general public. The State’s reputation as a responsible wildlife manager is rightfully beginning to sour after aerially gunning down nearly 200 bears in southwestern Alaska. Authorizing this program on such loose and un-studied biological grounds bruises Alaska’s image and erodes public faith in the Board of Game to make sustainable decisions.
By ADFG’s own admission: “Adoption of this proposal would result in significant costs to the department if department staff conduct control activities” (ADFG comments on Prop 75, Page 224). The Intensive Management program against bears and wolves a few hundred miles west cost $231,000 in 2022 and $612,000 in 2023 (page 14, 2024 annual report to Board of Game) Predator control as a whole has accounted for ~$2.5 million in lost federal funding, as Pitman Roberts funds cannot be used for Intensive management. At a time when ADFG has almost no funding for non-game programs and the State is struggling for cash, it is unwise to dedicate another quarter million dollars each year to predator control programs that have yet to be deemed effective.
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. This is the time to weigh in.
AWA’s Position Paper on Predator Control and Intensive Management clearly lays out our position on these programs, as well as our recommendations.
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 (Proposal 75) 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.
