The Board of Game Proposals for the Statewide Meeting have been released and AWA is carefully combing through them so that we can best represent the needs of Alaska’s wildlife at the Statewide Board of Game meeting in Anchorage in March. The written public comment period is open until March 7, 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 wildlife 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, BOG accepted and deliberated on proposals for the Central and Southwest Region in January, and will be deliberating on Statewide proposals in March. The next cycle for Statewide proposals is 2027/2028.
There are 26 game management units across Alaska, with several subunits.
This winter, the Statewide proposal book was released online.
In March of this year, different departments, including ADFG, Alaska Wildlife Troopers, and the Department of Law, will publish 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 March 7, 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 March 21 and 28, 2025, the Statewide BOG Meeting will be held in Anchorage at the Anchorage Egan Civic & Convention Center. 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@akwildlife.org for support and questions.
For more information on the Board of Game process, check out our informational video!
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 March 7 deadline.
If you are interested in testifying at the March Statewide Board of Game meeting, please contact nicole@akwildlife.org for support and questions.
If you missed our Wildlife Wednesday on the Statewide BOG proposals, you can watch the recording below.
Overview of the statewide proposals
Eighty-six proposals were submitted for the Statewide meeting; a third of the proposals deal with Dall sheep management, and many others concern moose and anterless moose hunts. Below, we have a breakdown of the most notable proposals by species, including sheep, migratory birds, bison, moose, musk ox, goats, bears, and furbearers.
While AWA is keeping their eyes on numerous proposals, there are several in particular that we are concerned with, including a proposal on Dall sheep, several proposals on night vision and thermal optics use, and a proposal on management of Alaska’s clean list.
The Proposals AWA Is Watching
Proposal 101: Add Dall sheep as a prey species under the Intensive Management statute: OPPOSE
This would include Dall sheep to the list of prey species on the Intensive Management statute, which already includes caribou, moose, and deer. This wouldn’t guarantee that sheep would be intensively managed, but recent BOG meetings and working groups record Department interest in enacting predator control on wolves and Golden eagles.
If Proposal 101 passes, the next steps would be for BOG to evaluate sheep populations to determine if there is a positive IM finding for a given population. If there is a positive IM finding, BOG would establish population and harvest objectives. Many of these objectives are best guesses about population “norms” and are often regarded as somewhat arbitrary.
Why we oppose:
We don’t think sheep qualify as a species that provides “high levels of human consumptive use”, and should not be in the same category as moose, deer, and caribou.
On average, hunters take 25,000 caribou, 10,000 deer, and 7,000 moose per year. Division of Subsistence surveys of harvest records show that the total sheep harvest, across 36 communities, is 266 per year. While sheep are important to some communities, the meat sheep hunting provides pales in comparison to the species originally identified in the statue: moose, deer, and caribou.
While Dall sheep produce great meat, they’re small and are often in areas that are difficult to get to. As ADFG notes: “these factors have limited sheep hunting to a relatively few, hardy individuals whose interest is more in the challenge and satisfaction of mountain hunting and the alpine experience than in getting food.”
Intensive Management has recently become synonymous with Predator Control, but predators aren’t the cause of sheep decline.
In management reports, the most frequent cause of sheep population decline is a loss of winter habitat and climate change, and weather. No research has indicated that Alaska’s sheep are declining because of predation.
This proposal would set a dangerous precedent if any hunted big game species can be characterized as providing “high levels of human consumptive use”. Mountain goats, musk ox, and bison could also be added, and the scope of IM was kept narrow on purpos
If BOG adopts this proposal, population objectives must be realistic for current and future conditions. The State and BOG have to recognize that sheep habitat is changing with the climate, and past objectives may not be attainable. BOG must wrestle with the costs to Alaskans and the State of enacting IM in areas where non-resident hunters account for a significant percentage of the sheep harvest. Is it ethical or sustainable management to enact IM so non-residents can have access to trophy sheep hunts?
A Full Overview of AWA’s Stance on Intensive Management and Predator Control
Proposals 126, 127, and 128: Night Vision and Thermal Optic Use - OPPOSE
Proposals 126, 127, and 128 would allow the use of electronically enhanced night vision and forward-looking infrared devices (FLIR) for taking furbearers statewide.
Night vision goggles and FLIR devices allow trappers to more easily ID and locate animals through barriers such as snow and darkness. FLIR in particular detects infrared radiation emitted from a heat source and creates a picture instead of amplifying visible light. FLIR devices make it possible to detect the heat of animals against cooler backgrounds and are available in handheld cameras and cameras that can be attached to a smartphone, goggles, and rifle scopes.
At the 2016 Statewide Meeting, BOG adopted a proposal submitted by the Alaska Wildlife Troopers that prohibited the use of forward-looking infrared devices (FLIRs) for taking wildlife. Prior to the board adopting the proposal, only night vision scopes were prohibited.
Then, at the 2024 Interior Meeting, BOG adopted a proposal to allow the use of electronically enhanced night vision devices (not just goggles) and forward-looking infrared devices (FLIR) for taking furbearers in the Interior.
Surprisingly, ADFG supports this proposal, even though they’re normally neutral on methods and means and have had previous concerns about increased harvest with these technologies.
Why we oppose:
BOG previously proposed to prohibit the use of night vision and FLIR devices because of concerns about increased harvest. So, what changed?
The Interior proposal for FLIR was only passed in 2024, so we don’t have one full season’s worth of data to understand the impacts before it is proposed Statewide
AWA supports fair chase hunting principles. These technologies are not commonly allowed in hunting states, and when they are they rarely apply to all furbearers. This would be a massive change for Alaska, and an unusual one for the United States on the whole.
Proposal 147: The Department of Fish and Game proposes to have the BOG delegate its authors to manage 5 AAC 92.029, commonly referred to as the clean list, to the Commissioner - OPPOSE
This proposal is the second attempt at Governor Dunleavy’s 2024 Executive Order 124. The Executive Order faced broad opposition and was opposed by the legislature.
This proposal would allow the Commissioner of ADFG to manage the “clean list”, which contains all the mammal, bird, and reptile species that have been specifically approved for entry or possession in Alaska.
Why we oppose: Our position echoes what we submitted in comments against the Executive Order. Proposal 147 would have a substantial effect on the public process, and not a positive one.
Currently, the Board of Game puts out a call for proposals, ADFG analyzes and gives recommendations, there are public comments, and then BOG deliberations with all 7 members. The Commissioner simply drafts regulations, posts them on a system with an automated notice sent out to a list of recipients, and allows 30 days for public comment on the proposed regulations.
We understand the desire to streamline permitting for more responsive action on requests to import exotic species as potential food sources, particularly in remote communities, however:
Importing species not listed on the clean list carries an unknown but potentially substantial risk of disease or parasite transmission to native wildlife and domestic livestock
The risks are too important to bypass the more deliberative and open process of the BOG.
BOG may choose to delegate regulation of the live capture, possession, transport, or release of native or exotic game or their eggs to the commissioner to streamline individual permits (on a case-by-case basis) where disease risk and mitigation measures are clearly understood.
Other species (e.g., carnivores) should remain in the BOG process, particularly those posing a risk to public safety.
How to Submit a Comment
Public comments on the BOG proposals are open until March 7, 2025. 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 Other Proposals?
AWA is currently combing through the proposals and determining our positions on them. Below is a list of the ones that are currently on our radar, grouped by species. For the full list of proposals, head to the BOG website for the proposal book.
Furbearer Proposals
The Statewide furbearer proposals also fall under two broad categories, plus the night vision and thermal optics proposal. AWA supports the three proposals listed below, as they increase transparency and fair chase.
Trap ID - SUPPORT
Proposal 131: A person may not set a trap or snare unless there is attached to the trap or snare an identification tag. Identification tags must provide either the person's name, or a personal identification number (PIN) registered with the Alaska Department of Fish and Game
Snowmachine Use Restrictions - SUPPORT
Proposal 132: Prohibit nonresidents from using snowmachines to approach and pursue the take of wolves and wolverines.
Proposal 133: Prohibit trappers from using snowmachines to approach and pursue the take of wolverines.
Sheep Proposals
In total, there are 29 Sheep Proposals, the majority of which (Proposals 102-118, 190, and 192) pertain to Unit 19C, between Denali National Park and Lake Clark National Park. One of the main organizations involved with sheep proposals is the 19C Dall Sheep Working Group.
What is the 19C Dall Sheep Working Group?
The 19C Dall Sheep Working Group was established by ADFG to discuss the management of Dall sheep in Unit 19C, between Denali and Lake Clark. The group is tasked with determining long-term sustainability in Unit 19C for Dall sheep. In October 2024, they submitted a letter to the BOG. In the letter they state that they want:
ADFG to continue to learn about sheep populations, specifically adding radio collars to better understand mortality issues.
Clear, measurable biological objectives for predator control, as well as humane control methods, efforts to gain public support, and research and science to back predator control
“At this time, the sheep working group wishes to see [...] research documenting mortality prior to any predator control for sheep.”
A guide concessionaire program that will control commercial efforts and harvest of Dall sheep.
The Working Group submitted Proposal 109, which would close Unit 19C in 2025 to all general season hunts except the RS380 subsistence hunt. They propose a temporary draw hunt in 2026/2027. They also request that Unit 19C be used as a pilot program for the guide concession program, implemented by 2028.
The Working Group also supports Proposal 92, recommending hunter education. The Working Group takes no action on Proposal 101, which would add Dall sheep to the list of prey species on the Intensive Management statute.
What is AWA’s Position on 19C Sheep?
We generally support working groups and appreciate ADFG’s support of the working group model. Like the 19C Working Group, AWA is concerned about the declining sheep population and would like to see more research, including collars. We also support the higher percentage of resident allocation over non-resident allocation (while understanding that allocation to both is important).
If you are concerned about sheep management in Alaska, we urge you to look at the full rundown of sheep proposals in the proposal book.
Migratory Bird Hunting Proposals
The migratory bird hunting proposals primarily cover species such as divers (Barrows golden eye, common golden eye, greater scaup, bufflehead), sea ducks (harlequin, surf scoter, black scoter, white wing scoter, common merganser, red-breasted merganser), and puddle ducks (mallards, pintail, widgeon, green wing teal, gadwalls).
Proposal 86: Require mandatory harvest reporting of sea ducks
A mandatory harvest reporting of sea ducks would allow ADFG to monitor changes in sea duck harvest. Alaska’s current migratory bird harvest reporting system (HIP) uses randomized voluntary reporting, which doesn’t provide much information. To the proposal author’s knowledge, ADFG has never adjusted bag limits on the basis of HIP reporting.
Alaska does not currently require sea duck harvest reporting, since sea ducks are classified as small game. However, sea ducks are special and their populations do not recover quickly. According to the Sea Duck Joint Venture, populations are slow to recover for the following reasons:
Sea ducks are known to have a remarkable degree of site fidelity–(~5 miles) which means that if an area’s population is depressed, birds from other areas will not boost recovery.
In general, sea ducks do not breed until they are 2 or 3 or so years old, which is late in comparison darling ducks.
They lay only one clutch of eggs per year, in contrast with the 2 or 3 for many dabbling ducks.
They have significantly lower chick survival rates than other ducks.
Sea duck populations across the United States have fallen 30% since 1970, and they remain in decline, according to the U.S. Committee of the North American Bird Conservation Initiative’s “2022 State of Birds Report”. Kachemak Bay Community Science Sea Duck Surveys have noted that:
“[Kachemak Bay] Populations have not bounced back after a significant harvest. Fish and Game has historically monitored sea duck populations in Kachemak Bay, but they have not surveyed in Kachemak Bay since several years before community science surveys began, so our data is the only record of this trend.”
AWA supports the intent of the proposal but is seeking more guidance on the solution. At a time when federal capacity may be limiting and guided sea duck hunting is expanding, we encourage the State to advise on ways to have more accurate sea duck monitoring/reporting, including partnerships with Tribes and non-profits to support surveys
Proposal 87: Restrict the use of boats for hunting waterfowl.
While the use of a moving vessel is legal for retrieval of dead or crippled waterfowl is legal, this is sometimes used to justify the continual movement of affiliated vessels during a hunt, resulting in illegal driving, herding, or chasing migratory birds into single or multiple hunter parties on shore, or on other boats.
Proposal 87 seeks to add to the regulation that: “all boats shall remain stationary throughout the duration of the hunt, beached or anchored, within 100 yards of those discharging firearms to eliminate driving, herding, or chasing migratory birds into hunters on land, or on other boats.” The author’s intent is to help prevent the illegal driving, herding, or chasing of migratory birds
BISON PROPOSALS
Proposal 88: Add wood bison to the list of game species allowed to be taken for cultural purposes under a permit issued by the Department of Fish and Game.
The ADFG commissioner may issue a permit for the taking, and use within this state, of game for the teaching and preservation of historic or traditional Alaskan cultural practices, knowledge, and values. Proposal 88, written by the Minto-Nenana Fish and Game Advisory Committee and Tanana Chiefs Conference, requests that wood bison be added to the list of allowed species.
Proposal 122: Allow proxy hunting for plains bison statewide.
At the 2024 Interior and Eastern Arctic Region Board of Game meeting in Fairbanks, the BOG passed a proposal to allow plains bison to be proxy hunted in that region. To reduce regulatory complexity, ADFG has proposed to allow proxy hunting for plains bison statewide, including the Chitina herd in Unit 11 and the Copper River herd in Units 11 and 13D.
Moose Proposals
The Statewide moose proposals fall under three broad categories.
Education
Proposal 89: Require nonresident moose hunters to attend a hunter orientation course and be accompanied by a registered guide or resident family member within the second degree of kindred.
Methods
Proposal 129: Establish a minimum standard of centerfire rifle cartridges for taking big game. Legal rifle cartridges for big game must have a barrel bore of at least .25 inches and be chambered to fire a centerfire cartridge of not less than two inches overall length including the bullet which is designed to expand.
Proposal 130: Establish a minimum standard of centerfire rifle cartridges for taking moose. A minimum of .243 caliber rifle would be required to take moose.
Both of these proposals seek to minimize moose and big game suffering, allowing for a cleaner, quicker kill.
Antlerless Hunt:
Proposal 149: Add the Nushagak and Togiak ACs to the subunits having jurisdiction for anterless moose seasons.
Proposals 152-165: All of these proposals largely reauthorize anterless moose hunting in units across the state, and were submitted by ADFG.
All of the anterless moose proposals are likely to pass unless local ACs oppose them.
Goat Proposals
Proposals 90 and 91: Require all goat hunters to pass an online mountain goat quiz prior to hunting.
Requiring additional education could reduce the take of nannys, and help bolster the goat population and involved hunters in goat conservation.
Bear Proposals
Proposal 124 and 125: Define the term “permanent dwelling” and “developed recreational facility” for the purpose of bear baiting setbacks.
According to the the proposal authors, there have been several incidents of confusion and, in some cases, charges, due to there being no clear definition of what a permanent dwelling or developed recreational facility is.
AWA supports the premise that these definitions need clarification, and is waiting for input from Alaska Wildlife Troopers.
Proposal 150-151: These proposals would reauthorize resident brown bear tag exemption fees in various units.
Proposal 148: Impose certain conditions on the commissioner’s ability to implement an intensive management plan following its adoption by the Board of Game.
This would modify the process so that:
After BOG has adopted a predation control plan, the Commissioner may determine whether to implement the plan, but only
(i) if the Commissioner finds that the conditions specified in Part E of the statute apply at that time;
(ii) in the event the Commissioner determines to authorize the use of aircraft and/or the taking of wolves from aircraft the same day airborne, the Commissioner also finds that the conditions specified in Part A of the statute apply at that time.
Before the implementation, prior public notice of the commissioner’s determination and findings must be given, and the public given the opportunity to comment as provided in the Administrative Procedures Act.
AWA is still assessing this proposal, but we generally want more transparency and a deliberative process when enacting IM.
Musk Ox Proposals
Proposal 136: Limit bison and musk ox drawing permit hunts to once in a lifetime, and allow applicants to apply once per hunt.
Proposal 138: Remove the requirement for a locking tag in subsistence hunts for musk ox.
Thank you for your support of Alaska’s wildlife! Public comments are due by March 7.
