Mission Statement:

February 13-14, 2004

To: The Alaska Board of Game

Re: Proposal Booklet

On behalf of the Board and members of Denali Citizens Council, thank you for the opportunity to provide comments on the Proposals to be considered at your meeting in Fairbanks February 26 - March 10, 2004. We appreciate the amount of work it took to get this information out to the public and would like to thank your staff, especially Don Young, area Biologist, and Justin Crawford, Middle Nenana River Advisory Committee Coordinator, for their help. We are hopeful that budget constraints will not damage the Advisory Committee infrastructure. Advisory Committees create an important dialogue between the public and the Department.

We will comment mostly on Proposals dealing with the Game Management Units of interest to the Denali Citizens Council. We are a grassroots group of local and regional citizens. Our membership of over 240 includes 163 Alaskans. Many of our “outside” members have lived and worked in Alaska. Our specific area of concern includes GMUs 13, 20A, 20B and 20C.

When you consider any proposals for managing wildlife, please keep in mind the following:

Intensive management for maximum sustained yield should not replace or dominate management for long term health and diversity on an ecosystem level. Long term ecosystem health will involve natural swings in the availability of some species for harvest.
The Board of Game cannot do its job effectively without strong scientific inquiry and adequate data gathering to make informed decisions on the appropriate number of game species throughout their ranges. Anecdotal observations are important, but must be backed up with more rigorous data gathering. We hope that financial constraints will not cut into this aspect of your work.
The Board of Game should avoid taking a general stance of approval toward predator control, especially because predator control involves the use of techniques not favored by a majority of Alaskans.
Motorized access to hunting areas is not a constitutional access right, it’s a privilege, and the growing use of all forms of motorized access to hunting requires your very careful consideration.

Our comments are listed below, by proposal:

Proposals 55 and 56 – Oppose – These proposals are for methods (baiting or same day airborne) of attracting or taking bears that are not sportsmanlike. In view of the fact that a statewide initiative opposing the baiting of bears has gathered momentum and will likely appear on the ballot next fall, these proposals are especially questionable.

Proposal 67 – Oppose - Unnecessary and potentially harmful to effective bear management

Although the proposal is quick to deny use of same day airborne or airborne hunting in any bear predator control program, what would prevent private hunters from taking bears in this manner, if they were part of a state mandated program? This could happen if Senator Seekins’ legislation (SB 297) is passed.

Proposal 118 - Approve - The Yanert Valley is known to have experienced a drop in the game populations as well as increased pressure by hunting outfitters. This proposal expresses the need to regulate the number of outfitters in a given area.

Proposal 124 – Guardedly approve- Biologist Young gave a good defense of this plan at the Middle Nenana AC meeting. Although we have not seen the final proposal, we support the general proposition that bull-cow ratios are too low and that there may be too many animals in the 20A herd, as evidenced by habitat stress and poor calf twinning. This area is one of intensive management and therefore maximum harvest numbers are encouraged. Short of taking a second look at the whole principle of intensive management for this area, the only way to avoid adverse impacts on the herd is to take some antlerless moose.

Proposal 145 – Guardedly oppose -Liberalize coyote season. Is there biological data to support this? Anecdotal observations of coyotes near human habitation are not science. To avoid habituation, people bear the responsibility of taking measures to avoid attracting animals, such as controlling garbage and keeping dogs inside or under control.

Proposal 150 – Oppose – Lengthening hunting season under the stipulation of “taking your child on a hunt” is too likely to have enforcement problems.

Proposals 156-159 – Oppose – These proposals remove hunting and trapping buffers established by the Department of Fish and Game in the Stampede area north of Denali National Park and in the Mt. Margaret area east of Denali Park. Denali Citizens Council did a survey of its members in 2002 then in 2003 and both times the great majority of respondents favored retaining these buffers as established (some even advocated enlarging them). The 2003 Survey results were submitted to the Middle Nenana River AC this January. There are few full time residents next to Denali Park and our membership is small, so the surveys had a small sample size. However, many of the respondents actually live in areas adjacent to the park and make their living in the area. Although some say that these buffers are not biologically justified, they do provide a hunting-free zone for wolves who naturally center their activities in Denali Park, but range beyond the park. Protection of these ranges in order to perpetuate viewing opportunities for Park visitors contributes to the local economy without significant harm to trappers or local folks.

Proposals 164, 165 – Oppose – Although access by airboats is justified by some as a low impact alternative to other forms of motorized access, the data are not unequivocal on this method of access. Airboats are loud and are widely unpopular. No form of motorized access is an inalienable right, but instead a privilege. Fish and Game takes on the additional responsibility of monitoring and enforcing rules on motorized activities when it permits them.

Proposals 167– Oppose – This proposal considers the impacts of larger ORVs, above 1500 lbs gross weight, on this area, and limits the size of vehicles that will be allowed in. However, will Fish and Game be able to enforce this restriction? See also our general comments on motorized access.

Proposal 168– Oppose – Motorized users state that ORVs provide a more democratic form of access for Alaskans who cannot afford air access, and also improve access for older and less able individuals. Motorized access also purports to give local hunters a better chance against outside, guided hunters who mainly use air access to the hunting grounds. This proposal suggests that it is the outside trophy hunters who are negatively influencing the bull:cow ratio. However, whether the use of motorized access for resident hunters is the only way to fix the bull:cow ratio is questionable at best. The costs of purchasing and operating an ORV in the backcountry are arguably greater than specific aircraft passage for a hunt.

In reality, adoption of this proposal will increase physical impact of ORVs on the area and will add to Fish and Game’s monitoring and enforcement burden.

Proposal 171 – Oppose See arguments above.

Proposal 172 - This Proposal arose from a discussion by the Middle Nenana Fish and Game Advisory Committee regarding the growth in numbers of people in the McKinley Village area and their potential conflicts with trappers. The majority of our members in that area have desired to keep the wolf hunting and trapping buffer there, but we have not polled them on their attitude toward other types of trapping in general. A local trapper who would be affected by Proposal 172 presented local signatures supporting him at the most recent meeting of the Middle Nenana Fish and Game Advisory Committee. There are no other trappers in the proposed closure area at this time. DCC does not have a formal opinion on this proposal, but we urge Fish and Game to consider the undeniable impacts of trapping within communities and to address this problem with regulations if it is the consensus of the community to do so.

Again, thank you for the opportunity to provide comment.

Sincerely,

Nancy Bale, President DCC