Comments on plans to liberalize predator hunting in national preserves in Alaska must be made by November 5/NPS

Little more than a week remains to comment on an environmental assessment the National Park Service has written to ease back on protections for predators in national preserves in Alaska. The Park Service's latest position is a wholesale reversal from where it stood in 2015 when it pushed back against Alaska's requests to allow for the killing of more wolves and bears from national preserves and refused to back down.

The proposed regulations, which would align Alaska national preserves with state rules that were implemented to suppress carnivore numbers in order to increase game populations, were requested by the Trump administration. The practices, which the Park Service banned in 2015 and which are now set to be legalized, would allow:

* Taking any black bear, including cubs and sows with cubs, with artificial light at den sites

* Harvesting brown bears over bait

* Taking wolves and coyotes (including pups) during the denning season (between May 1 and August 9)

* Taking swimming caribou

* Taking caribou from motorboats under power

* Taking black bears over bait

* Using dogs to hunt black bears

In the decade leading up to the 2015 rule, the Park Service made more than 50 requests to the Alaska Board of Game to limit native carnivore-hunting efforts on national park lands, according to the National Parks Conservation Association. The vast majority of requests were ignored and resulted in adoption of the 2015 rule, the group said.

As they were going through the rulemaking process in 2015, NPS officials pointed out to the acting director of the Alaska Department of Fish and Game that, "the State does not believe there are any sustained yield concerns, and thus no basis for NPS actions. As has repeatedly been communicated in writing and verbally, the differing legal frameworks for the State of Alaska and the National Park Service compel each of our agencies to assess issues associated with wildlife management and the national park areas differently."

Nearly 60,000 comments were received during that rulemaking process. 

"Over 59,000 comments objected to recent state-sanctioned practices as being inconsistent with generally accepted hunting practices," the Park Service noted in analyzing those comments. "These commenters described these (state) activities as 'not sustainable,' 'cruel,' 'barbaric,' 'unsporting,' 'unethical,' 'inconsistent with fair chase,' and "danger[ ous] to humans and wildlife.' Additional comments were also received in support of the NPS position that intensive management of wildlife is not appropriate in NPS Preserves."

In comments submitted to the Park Service on the latest EA concerning the regulations, a retired NPS environmental protection specialist pointed time and again to a lack of scientific data to support many of the state's positions that increased hunting of predators won't lead to problems.

"... the EA again relies heavily on (Alaska Department of Fish and Game) conjecture that registered black bear bait stations have not resulted detectable problems related to bear baiting. Has this been studied? Does the State have research to prove this statement?" the letter asks. "Furthermore, we know wolves are also taken at bear bait stations. Sows with cubs are not taken at bear bait stations, so they get a free pass on human foods, and sows end up teaching their young to take human food when they find it. Sure, these animals are easy prey after they mature and don’t have cubs with them. But is this wise?"

The author also points to inconsistent reasoning in the EA.

"This section (3.2.2 Effects on Wildlife of Alternative 1) states, 'based on input from ADFG, population level effects on prey species are not expected.' If this is truly the case, then why approve egregious methods and seasons to harvest predators in national preserves?" they wrote. "The ADFG 'maintains' that increased hunting of predators, other than in areas near population centers with available access, would not result in reduced predator populations or increased prey populations. This may hold true for remote parts of national preserves, but road accessible preserves such as parts of Wrangell Saint-Elias could result in adverse impacts on predators and prey."

The letter also noted that the EA was silent on how a potential overharvest of predators could lead to "overgrazing of available browse for caribou and their ultimate need to move or not reproduce. The 2018 EA omits other references in this part of the EA regarding trophic cascades and the effects of adding or removing predators from ecosystems that were noted in the 2014 EA."

"Given that this EA and proposed new rule present a complete reversal of what the NPS presented to the public in 2014 and decided near the end of 2015 by the same regional director as now serving in Alaska, one cannot help but think this EA and proposed new rule are not really what the NPS prefers or the overwhelming public prefers," the writer summarized. "It was in 2015 when the Park Service adopted a rule that allowed it to reject extreme hunting regulations on national preserves, including extremely long seasons into periods when hides and meat of wolves and bears are of little value, excessively high bag limits, baiting of brown bears, and the commercial sale of brown bear hides and skulls."

Park Service law and regulations long have prohibited intensive management and “predator control” to manipulate predator:prey ratios on NPS-managed lands, whether national parks or national preserves.

In composing the EA now open for public comment, Park Service staff relied on the state of Alaska's position that increased hunting of the predators would not have an overall impact on their populations. 

Pete Christian, a public affairs spokesman for the Alaska regional office of the Park Service, said the 180-degree shift in the agency's position on predator control stemmed from the change in administrations.

“We have new leadership at the department level and the Department of Interior has taken a new direction. This is an interpretation of policy," he said Thursday. "They’re wanting to more closely align federal regulations with state regulations."

The move by the Trump administration and Interior Secretary Ryan Zinke to overturn the 2015 rule has been controversial. More than 100 scientists have written to oppose the move. 

The EA, which is open for public comment through November 5, acknowledges that the changes likely would reduce opportunities for wildlife viewing and degrade wilderness character in the preserves. The proposed amendments to the regulations would only apply to hunting on Alaska national preserves. National parks in Alaska would not be affected by the proposed changes.

While more than 180,000 comments, mostly negative, have been submitted on the proposed rule to change the hunting regulations, only 80 had been filed on the EA itself as of Thursday afternoon. The comments on the rule itself don't necessarily carry the sway of those made on the EA. Comments making sound arguments against the rule changes are best made on the EA's comment page.

Comments on the EA can be made at this site. You also can read the full EA on that site.