This is a sign-on letter in support of retaining the existing (2015) National Park Service (NPS) rule that limits hunting designed to reduce large carnivores in Alaskan National Preserves. If the new rule is adopted, it would effectively require the NPS in Alaska to adopt, in National Preserves, the State of Alaska’s hunting and trapping regulations that are designed to increase the abundance of ungulates (primarily moose and caribou) available for hunter harvests by reducing large carnivore abundance (grizzly bears, black bears, and wolves).  

If you are a biologist, please consider signing on to this letter. Thank you.

Re: Alaska: Hunting and Trapping in Alaskan National Preserves (36 CFR Part 13 RIN 1024-AE38); comments from scientists and natural resource management professionals and decision makers on the proposed rule change.

The undersigned urge the National Park Service (NPS) to retain the existing (2015) rule regarding hunting on Alaskan national preserves (80 FR No. 205, October 23, 2015, RIN 1024-AE21) and to reject the proposed replacement rule. The proposed rule would effectively require the NPS in Alaska to adopt the State of Alaska’s (SOA) hunting and trapping regulations in Alaskan national preserves. The SOA regulations of concern are designed to reduce the abundance of large carnivores (grizzly/brown bear, black bear, and wolves. These SOA regulations are intended to increase the numbers and hunter harvests of wild ungulates (primarily moose, and caribou). Such regulations are inappropriate for lands managed in the national interest by NPS. In this letter we also include a partial list of issues that must be addressed in the pending Environmental Assessment on the proposed rule.

Under the SOA’s “intensive management” (IM) law of 1994 (AS 16.05.255c) in cases where current abundance of ungulates is insufficient to meet hunter demand for wild game meat, IM must be undertaken in an effort to increase ungulate abundance and hunter harvests. This IM law establishes a demand-based harvest management priority for ungulates that is in effect throughout most of Alaska. The National Research Council made a series of recommendations regarding predator management in Alaska (NRC 1997) that have been ignored by the SOA in adopting these regulations (Miller et al. 2011, 2017).

Alaska is the largest area remaining in North American where large carnivore habitats remain both extensive and relatively unaffected by anthropogenic influences. Management practices for large carnivores adopted by the SOA, however, are a reversion to historical practices that treat large carnivores as lesser or undesirable species. Alaska is the best place remaining in the United States with the potential to maintain healthy and natural ecosystems with large and naturally-occurring abundances of predators and prey species. Accordingly, the NPS has a responsibility to manage these Alaskan lands in the national interest and not in narrow local interests of maximizing yields of game meat for local harvest.  

Manipulation of predator:prey ratios in efforts to increase hunter harvests of ungulates is inconsistent with the mandate of the NPS under its Organic Act and subsequent regulations: “…It is contrary to the National Park Service concept to manipulate habitat or populations to achieve maximum utilization of natural resources. Rather, the National Park System concept requires implementation of management policies which strive to maintain the natural abundance, behavior, diversity, and ecological integrity of native animals as part of their ecosystem” (US NPS 1981:30-31). Regardless, since 1990, federal authorities have adopted hunting regulations for national preserves in Alaska that largely mirror the regulations adopted by the Alaska Board of Game (BOG). There has been NPS pushback to these SOA regulations only in some cases mentioned in the 2015 rule including, for example, allowing baiting of both bear species in NPS-managed areas.

The 2015 rule correctly identified some SOA hunting regulations designed to reduce the abundance of large carnivores.  In contrast, the new proposed rule asserts only that the SOA “disputes” that their regulations are intended to function as ‘predator control’ programs.  The SOA’s ‘dispute’ is based on its very narrow definition of “predator control” that includes only specially designated “Predator Control Areas” (PCAs) where methods are allowed that have included state employees shooting bears from helicopters (both species), public snaring of both bear species, and public shooting of wolves using aircraft.

The most general form of predator reduction efforts that is widespread across Alaska, however, is liberalization of general hunting regulations for large carnivores.  This is identified as a preferred means for reducing predators in the SOA’s “Predator Management In Alaska” protocol which states that “take of predators by conventional hunting and trapping may be increased through liberalizations of seasons and bag limits to reduce the effects of predation on prey populations”(ADFG 2007:6). Hunting regulations for brown bears in Alaska have been greatly liberalized and include increasing areas allowing sales of brown bear hides and skulls, baiting of brown bears, and greatly expanded seasons and bag limits (Miller et al. 2017).

We are greatly concerned by the extremely low level of scientific evidence available to justify the liberalizations of hunting regulations for large carnivores that have occurred in Alaska (Miller et al. 2017). This lack of information applies to NPS-managed lands in Alaska including national preserves. NPS does not even have information on numbers of large carnivores harvested within any national preserve, national park, or national monument in Alaska.

NPS plans to provide an Environmental Assessment (EA) on the new proposed rule with a very short 30-day comment period. This short period precludes detailed comments on the EA here. Instead, we provide a partial list of items that the EA must address:

1. The role of large carnivores (apex predators) in ecosystem function based on a review of the literature in Alaska and elsewhere;

2. The proposed rule states that SOA “asserts” that their regulations are not “predator control” but the 2015 NPS rule clearly recognizes that predator reduction to increase ungulates is their intent. The EA must clearly recognize that this distinction is based on the SOA’s narrow definition of “predator control” and justify how predator reduction regulations are consistent with NPS policies and guidelines.

3. The scientific (non-anecdotal) bases used to inform and justify the hunting and trapping regulations already adopted or proposed for NPS lands in Alaska;

4. The process NPS will use to document changes in harvest numbers of the large carnivore species within the borders of the NPS units where the hunting regulations apply;

5. The NPS objectives for large carnivore abundance in NPS units and the basis by which NPS will determine if and when these objectives are (or are not) achieved;

6. A comparison of information available on mortalities of large carnivore species in NPS units in the lower 48 states with the information available in Alaska and how the disparity in information available is justifiable.

Thank you for your consideration of these comments.

Literature cited:

Alaska Department of Fish and Game. 2007. Predator management in Alaska. Division of Wildlife Conservation, Juneau, AK. 30 pp. Available at: http://www.adfg.alaska.gov/static/research/programs/intensivemanagement/pdfs/predator_management.pdf

Miller, S.D. , J.W. Schoen, J. Faro, and D.R. Klein. 2011. Trends in intensive management of large carnivores in Alaska, 1980-2010. J. Wildlife Management 75:1243-1252.

Miller, S.D., J.W. Schoen, and C.C. Schwartz. 2017. Trends in brown bear reduction efforts in Alaska, 1980-2017. Ursus 28:135-149.  

National Park Service. 1981. Rules and Regulations, National Park System Units in Alaska, Final rule. 36 CFR Part 13, U.S. Department of Interior, Washington DC. June 17, 1981. 77pp.

National Research Council. 1997. Wolves, bears, and their prey in Alaska: Biological and Social challenges in wildlife management. National Academy Press, Washington DC. 207pp.

Signed by:  

Steven C. Amstrup, Ph.D.

Chief Scientist, Polar Bears International

USGS Project leader (formerly) for Polar Bear Studies in Alaska (1980-2010)

Member (1980-present) and former Chair of IUCN Polar Bear Specialist Group

Kettle Falls, Washington, USA

Larry Aumiller, Ph.D. (honorary from Univ. Alaska Fairbanks)

Alaska Dept. Fish and Game manager of the McNeil River State Game Sanctuary (ret.)

Missoula, MT

James Burchfield, PhD

Dean (retired), W.A. Franke College of Forestry and Conservation, University of Montana

Missoula, MT USA

Len Broberg, Ph.D

Professor, Environmental Studies

University of Montana

Missoula, MT USA

R. Terry Bowyer, Ph.D.

Professor Emeritus, Institute of Arctic Biology

University of Alaska Fairbanks

Fairbanks, Alaska

L.N. “Lu” Carbyn, Ph.D.

Adjunct Prof. Univ. Alberta

Emeritus Research Scientist Canadian Wildlife Service

Canadian Rep. IUCN Wolf Specialist Group and Canid Group

Edmonton, Alberta, Canada

Joseph A. Cook, Ph. D.

Professor of Biology, University of New Mexico

Albuquerque, NM

Jeff Fair, M.S.

Fairwinds Wildlife Services and author of The Great American Bear and In Wild Trust

Palmer, Alaska

Kerry R. Foresman, Ph.D.

Emeritus Professor of Biology and Wildlife Biology

University of Montana

Missoula, Montana

David Garshelis, Ph.D.

Co-chair IUCN Bear Specialist Group

Bear Research Scientist, Minnesota Department of Natural Resources

Grand Rapids, MN 55744 USA

Barrie Gilbert, Ph.D.

Conservation Biologist & author of report on moving Brooks Camp in Katmai NP, Alaska.

Wolfe Island, Ontario, Canada

William H. Greer, MS

President, Montana Wildlife Federation

(former) Director, Utah Div. Wildlife Resources (ret.)

Lolo, MT, USA

Malorri Hughes, MS

Department of Biology, Portland State University (Ph.D. student)

Portland, Oregon, USA

Paul R. Krausman, Ph.D.

Professor Emeritus, University of Arizona

(former) President, The Wildlife Society

Editor, Journal Wildlife Management

Clinton, WA, USA

Djuro Huber, Ph.D.

Professor Emeritus, Faculty of Veterinary Medicine University of Zagreb, Croatia

(former) Vice-president for Eurasia of the International Association for Bear Research and Management

David R. Klein, Ph.D.

Professor Emeritus, Inst. Arctic Biology, Univ. of Alaska Fairbanks

Member, National Resource Council 1997 Study on “Wolves, Bear, and their Prey in Alaska”.

Recipient, The wildlife Society’s Aldo Leopold Award

Fairbanks, Alaska, USA

Tony Knowles

Governor of Alaska 1994-2002

Originator of the National Research Council study leading to the 1997 report "Wolves, Bear, and their Prey in Alaska"

Chair of the National Park System Advisory Board 2010 – 2017

Anchorage, AK

Katherine C. Kendall, M.S.

Research Biologist, U.S. Geological Survey (ret.)

Principal Investigator, Greater Glacier N.P. and Northern Continental Divide Grizzly Bear Projects (ret.)

(former) Vice President, International Association for Bear Research and Management

Columbia Falls, Montana

Kyran Kunkel, Ph.D.

Julie Lurman Joly, J.D., M.E.S.

(former) Asst. Prof. of Natural Resources Law and Policy, Univ. Alaska Fairbanks &

Co-author of “Preemption of State Wildlife Law in Alaska: Where, When, and Why”.  Lurman and Rabinowitch (2007)

Fairbanks, AK

Colleen Matt

Alaska Dept. Fish and Game, Region II Lands and Public Information Coordinator (ret.)

Missoula, MT

Sterling D. Miller, Ph.D.

Alaska Dept. Fish and Game, carnivore research biologist (ret.)

(former) President, International Association for Bear Research and Management

Lolo, MT

Michael R. Pelton, Ph.D.

Professor Emeritus, Wildlife Science

(former) President, International Association for Bear Research and Management

University of Tennessee

Middlebrook, Virginia

Rolf Peterson, Ph.D.

Prof. School of Forest Resources and Environmental Science

Michigan Tech University

Houghton, Michigan

Kurtis Jai-Chyi Pei, Ph.D.

Prof. Institute of Wildlife Conservation, National Pingtung University of Science and Technology, Pingtung, Taiwan

Prof Department of Natural Resources and Environmental Studies and Dean College of Environmental Studies, National Dong Hwa University, Hualien, Taiwan

Vincenzo Penteriani, Ph.D.

Spanish Council of Scientific Research (CSIC), Pyrenean Institute of Ecology

Cantabrian Brown Bear Research Group, Spain

Sanford P. Rabinowitch, M.L.A.

National Park Service, Subsistence Manager, AK Regional Office (ret.) &

Co-author of “Preemption of State Wildlife Law in Alaska: Where, When, and Why”.  Lurman and Rabinowitch (2007)

Anchorage, AK

Harry Reynolds MS

Alaska Dept. Fish and Game bear research and management biologist (ret.)

(former) President, International Association Bear Research and Management

Fairbanks, Alaska

William J. Ripple, Ph.D.

Distinguished Professor of Ecology, Oregon State University

Corvallis, Oregon

Jeanne M. Schaaf, Ph.D.

Cultural Resource Manager Lake Clark and Katmai National Parks and Preserves, Aniakchak National Monument and Preserve, Alagnak Wild River (1996-2014 ret)

Anchorage, Alaska

Christopher Servheen Ph.D.

U.S. Fish and Wildlife Service (retired)

Grizzly Bear Recovery Coordinator for 35 years

Missoula, Montana

Rick Sinnott M.S.

Anchorage Area Biologist, Alaska Department of Fish and Game (retired)

Chugiak, Alaska

John W. Schoen, Ph.D

Alaska Department of Fish and Game Research Coordinator and Research biologist (ret.)

Audubon Alaska, Sr. Scientist (ret.)

Anchorage, Alaska

Charles C. Schwartz, Ph.D.

Alaska Department of Fish and Game Research Coordinator and researcher (ret.)

Team Leader, Grizzly Bear Study Team, USGS, Yellowstone Ecosystem (ret.)

Bozeman, Montana

Winston P. Smith, Ph.D.

Principal Research Scientist, Institute of Arctic Biology, University of Alaska - Fairbanks

Fairbanks, AK

Jim Stratton

(former) Director Alaska State Parks

Anchorage, AK

Richard P. Thiel, B.S., CWB

WI Dept. Natural Resources, Wildlife Educator (ret.)

Tomah, WI

Donald M. Waller, Ph.D.

John T. Curtis Professor of Botany & Environmental Studies

Chair, Conservation Biology major

Science Advisory Board, Environmental Law & Policy Center

Madison, WI                                            

Adrian Wydeven, MS & CWB

WI Dept. Natural Resources, Large Carnivore Specialist (ret.)

Cable, WI