Northern Center supports proposed US Fish & Wildlife Service wildlife regulations
The Northern Alaska Environmental Center (Northern Center) supports the proposed rule preempting state laws, regulations, and programs that have the intent or potential to alter or manipulate natural predator-prey dynamics and associated natural ecological processes to increase harvest of ungulates.
The Northern Alaska Environmental Center (Northern Center) supports the proposed rule preempting state laws, regulations, and programs protecting refuge wildlife on our National Wildlife Refuges that have the intent or potential to alter or manipulate natural predator-prey dynamics and associated natural ecological processes to increase harvest of ungulates.
For more than a decade, the State of Alaska has intensified its efforts to control predator populations for the purpose of increasing numbers of game animals for hunters. This now includes allowing the baiting of bears, hunting wolves and their pups during denning season, and increasing seasons and bag limits for predator species even within our National Wildlife Refuges. These inappropriate and unethical methods have no place anywhere, especially the Refuges. The U.S. Fish and Wildlife Service has initiated a regulatory process to preempt such State hunting rules that have the intent to manipulate predator populations to increase game for hunters. This marks a new precedent for protection of wildlife and the wild qualities on Alaska National Wildlife Refuges established for protection.
The USFWS is accepting public comments on these proposed regulations until March 7, 2016. A strong show of public support is necessary to assure that USFWS actually finalizes these rules. You can make comments and read the regulations online. When you are searching in the search box enter FWS-R7-NWRS-2014-0005
The Northern Center's specific comments are below and are being made public to help concerned citizens submit comments. We support the proposal's intention to maintain natural numbers, interactions, and ecological interactions of wildlife.
Wolf hunting seasons and bag limits:
We support the proposed prohibition of taking wolves during the denning season when they are especially vulnerable. State regulations that allow killing wolves when their pelts are of no value are obviously designed to increase the harvest of wolves with the intent to boost ungulate populations. This is exactly what the proposed regulations should address. We recommend that the Final Rule specifically preempt excessive bag limits for wolves and other predators by setting reasonable daily bag limits that will assure that natural diversity and abundance of predators and prey are maintained.
Prohibited methods for taking bears:
The Northern Center supports all the proposed prohibitions. We also recommend that the final rule include a prohibition on the use of bait for taking black bears in Refuges. Since black and brown bears often occur in the same areas, if black bear baiting is allowed to continue, it will result in also attracting and habituating brown bears as well. This will counter-act the goal intended by the prohibition of brown bear baiting. If it is unacceptable to bait brown bears, then the baiting of all species of bears in Refuges should be prohibited. We also support a prohibition on the use of dogs for the taking of black or brown bears.
Other harvest methods:
We support prohibition of the use of remote controlled aircraft (drones) and the use of cameras and other electronic devices in the taking of wildlife. These disturbing instruments should be prohibited in Refuges under all circumstances. We also support the prohibition of methods such as use of poison, motorized equipment to take, drive or harass wildlife, explosives, night vision equipment, and artificial salt licks.
There is a growing body of peer-reviewed science that describes significant negative effects on the phenotype of a large diversity of species where human harvest is focused on the largest individuals. (See references provided below). Thus, long term effects of harvest strategies like trophy hunting may influence genetic diversity and ultimately population health. The Final Rule should indicate that the USFWS will conduct research in Refuge units having a significant amount of trophy hunting and propose further regulations based on scientific findings to protect genetic diversity, natural age and sex composition and healthy populations of wildlife.
Ethical Hunting Practices:
While the unmanipulated, wild condition of these areas is of primary concern, many of our members are hunters who consider the State of Alaska intensive management practices such as killing wolf pups in their dens, bear-baiting etc. to be unsportsmanlike, unethical, and degrading of the hunting tradition. We suggest adding a provision requiring that hunting on Refuges must follow the highest ethical and fair-chase standards.