International Fund for Animal Welfare
December 3, 2014
By Electronic Mail
Submitted via http://www.regulations.gov/#!submitComment;D=NPS2014-0004-0001
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United States
Dr. Bert Frost
Regional Director
National Park Service
Alaska Regional Office
240 West 5th Ave.
Anchorage, AK 99501
Re: Proposed Rule, Alaska; Hunting and Trapping in National
Preserves, RIN 1024–AE21
Dr. Frost:
On behalf of the International Fund for Animal Welfare (IFAW) and its
nearly two million supporters, I submit for your consideration the
following comments in support of the National Park Service’s (NPS)
proposed rule concerning hunting and trapping in national preserves in
Alaska (RIN 1024-AE21; Fed. Reg. Doc. No. 2014-20881).
The proposed rule would modify existing predator management practices
on NPS-managed lands in Alaska as follows:
(1) Ban—in accordance with NPS policies—taking wildlife, hunting
or trapping activities, or management actions involving predator
reduction efforts with the intent or potential to alter or
manipulate natural predator-prey dynamics and associated natural
ecological processes to increase harvest of ungulates by humans
on NPS-managed lands.
(2) Prohibit historically illegal practices for taking wildlife for sport
purposes, including the practices recently authorized by the state
for taking predators: (i) Taking black bear cubs and sows with
artificial light at den sites; (ii) taking brown bears over bait; and
(iii) taking wolves and coyotes during the denning season.
In addition to these proposals, the notice requests public comment on
whether NPS should prohibit the use of dogs for hunting black bears
(“hounding”) and the take of black bears over bait (“baiting”) on national
preserves.
1
www.ifaw.org
We support a ban on each of these inhumane, dangerous and unnecessary practices on NPSmanaged land, which accounts for over 20 million acres in Alaska. These changes are consistent with
sound science, important animal welfare considerations, and long-established fair chase principles.
They support the purpose of the national preserves and parks, and reflect vital ecosystem integrity
objectives. For these reasons, which are outlined in greater detail in the following comments, we
urge NPS to adopt and expeditiously implement the proposed rule, including a prohibition against
the use of dogs and bait to hunt black bears.
Killing predators to enhance populations of game species
Hunting and trapping native predators to enhance ungulate populations is ecologically unsound and
inconsistent with NPS’s mandate. NPS policy directs the Service to “maintain as parts of the natural
ecosystems of parks all plants and animals native to park ecosystems…by preserving and restoring
the natural abundances, diversities, dynamics, distributions, habitats, and behaviors of native plant
and animal populations and the communities and ecosystems in which they occur” and by
“minimizing human impacts on native plants, animals, populations, communities, and ecosystems,
and the processes that sustain them.”1
Creating or sustaining a predator-prey imbalance for purposes of promoting recreational hunting
contradicts these stated goals, and ignores the critical roles that predators play in ecosystem health
and function. When native predator populations are artificially depressed, the consequences are felt
throughout their range.2 Declining ecological health and stability resulting from predator control is
not an isolated risk; rather, the phenomenon has been observed around the world.3 The presence of
predators like wolves, bears and coyotes encourages ungulates to shift their grazing sites more
frequently than they otherwise would, reducing overgrazing and enabling riparian plants and other
native flora to recover.4 The restored plant cover provides far-reaching environmental services,
protecting water quality, preventing erosion and providing forage and habitat for diverse species.5
The presence of wild predators is also advantageous for scavenger species. In Yellowstone National
Park, for instance, twelve scavenger species make use of remains from wolf kills.6 In an era of rising
global temperatures, this is an increasingly important source of food for these animals.7 Shorter
winters and earlier thaws mean that fewer animals die from freezing conditions and limited food;
scavengers, in turn, have access to fewer carcasses.8 Predator kills provide some relief from this everintensifying resource constraint.
Prohibiting the manipulation of predator populations for the sake of enhancing hunting
opportunities is an important step in fulfilling NPS’s mission in Alaska and will promote ecosystem
integrity on public lands in Alaska. We strongly support this scientifically and economically justified
proposal.
Taking brown bears and black bears over bait
Like killing predators to enhance populations of game species, bear baiting is accompanied by
serious adverse ecological impacts. The practice tends to artificially concentrate populations of bears
and non-target species, and contribute to the spread of wildlife disease—an issue to which the
environmental assessment9 gives little attention—as well as habitat degradation and density-related
disturbances in natural interactions.10 In bears, this enhanced population density can interfere with
reproductive success by reducing the animals’ home range size relative to natural conditions, which
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in turn leads to heavily skewed sex ratios.11 It also strains natural resources in areas surrounding bait
stations, such as tree stands and other important ecosystem features.12 As NPS has acknowledged,
“baiting may alter the natural behavior of bears by conditioning them to human foods; this
conditioning is inconsistent with NPS policy.”13
Bear baiting also greatly enhances the risks associated with human-bear conflict, as bears become
habituated to artificial food sources and visit human-populated areas more frequently. Once
conditioned to these food sources and to human presence, they generally do not abandon these
behaviors in favor of their natural habits; accordingly, conflicts with humans and other nuisance
challenges are often closely associated with baiting practices.14 As one 2013 analysis of bear baiting
in Alaska concluded, “food conditioning of bears should be avoided to benefit the survival of
individual bears and to increase public safety.”15
In addition to prohibiting the baiting of brown bears on national preserves, we urge NPS to extend
the proposed ban to black bears. The species’ respective habitats overlap and the animals are
characterized by similar habituation and behavioral disruption risks.16 Although existing state
regulations establish small buffer zones between bait stations and populated areas—one mile for
homes and campgrounds, and one-quarter mile for roadways and trails17—they fail to adequately
address the concerns described above. Nor can this problem be addressed through other changes, as
the practice is inherently flawed for the reasons already stated. Accordingly, it is critical that NPS
ban the practice of bear baiting—already prohibited by the majority of states that have bear hunts—
on preserves in Alaska.
Bear hunting with dogs
Hounding of bears—whether brown or black—is inherently inhumane and inconsistent with
traditional “fair chase” principles. Hunting dogs are trained to pursue and harass bears until they
climb a tree or are cornered on the ground, exhausted. Even in the best of conditions, this is an
extraordinarily stressful method of capture. Bears that are shot after hunters catch up with their
hounds may be further harassed and harmed by the dogs upon reaching the ground, wounded but
not yet dead. For those who are spared for any reason, the chase and accompanying trauma may
nonetheless have lasting consequences. For instance, bears may overheat during the course of a
chase, harming both their short-term health and threatening their reproductive capacity. Intense
chases may also cost bears valuable energy reserves needed for hibernation and interfere with the
natural behaviors of not only the pursued bear, but also others in the area.
Hounding also threatens to leave cubs orphaned, even where the hunter wishes to avoid doing so. It
is difficult to identify the age and gender of a treed or cornered bear and, accordingly, to determine
whether the bear might have dependent cubs.18 In such circumstances, where a sow is killed, cubs
under a year of age are unlikely to survive without human intervention.
Bears are not the only victims of the chase in hound hunting. Dogs may pursue or disturb nontarget animals, and may themselves be severely injured or killed. Like the bears subject to chase,
dogs endure physiological stress and may be severely injured or killed upon confronting a treed or
cornered bear.19 Even after bears have been shot, they may attack and maul nearby dogs between the
time that they are shot and the time that they lose strength. Moreover, dogs used for bear hounding
are often treated as equipment, kept in inhumane conditions, subjected to cruel training methods,
and abandoned or killed when they are injured during the chase or fail to perform.20
3
Acknowledging the inhumane and irresponsible nature of bear hounding, 14 states have banned the
practice. We strongly encourage NPS to join the many and diverse opponents of hounding and ban
the use of dogs to hunt both brown and black bears on NPS lands in Alaska.
Taking black bear cubs and sows with artificial light at den sites
Killing bears at their den sites is unsporting, as it involves taking the animals—including young
cubs—in a particularly vulnerable state. Like hounding, spotlighting may leave cubs orphaned before
they are able to survive independently, as sows care for cubs at their dens with little separation into
the spring months. Even where a sow and her cubs are not targeted, disturbances near den sites
related to denning activities can disrupt the animals’ natural behaviors and jeopardize cub survival.21
NPS’s proposed rule would protect bears inhabiting national preserves from this inhumane and
unnecessary practice.
Taking wolves and coyotes during the denning season
The take of wolves and coyotes during the denning and pupping season, as the EA acknowledges, is
irresponsible both because the animals’ pelts—which must be salvaged pursuant to state
regulations22—and trophies are of little economic value at that time and because the practice has the
potential to substantially depress populations of these ecologically important carnivores.23
Wolves and coyotes generally breed only once per year, so killing them during this critical time—
when they are at their dens and particularly vulnerable—is highly disruptive to the species’
propagation. Taking a breeding adult reduces the breeding population and, in the case of pregnant
females, means eliminating an entire litter of pups and the pack’s sole reproductive opportunity for
that year. Taking adult wolves and coyotes shortly after pups are born is also a death sentence for
the young animals, which rely on adults to provide food and care in the early months of their lives,
and are unable to survive on their own.
Finally, hunting and related activities near dens can harm even those wolves and coyotes that are not
subject to intentional take; the animals may abandon den sites in response to human disturbance,
which can adversely affect the survival of young pups.24 By finalizing and implementing the
proposed rule, NPS will take a critical step toward protecting these defenseless animals, ensuring
healthy wolf and coyote populations, and maintaining the health of the ecosystems in which they
serve as keystone predators.
Conclusion
We applaud NPS’ proposal to—consistent with its mission and mandate—put a stop to egregious
hunting practices that have been permitted by the Alaska Board of Game (ABG) on national
preserves. ABG’s incorporation of predator control efforts into sport hunting rules is both an
overreach of authority and a threat to predator and other wildlife populations that are to be
sustained for the benefit of all Americans.
For the foregoing reasons, NPS should proceed with implementation of prohibitions against the
following practices on NPS-managed lands in Alaska: the capture and killing of predators to boost
populations of game species (ungulates); the take of brown and black bears over bait; the use of
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dogs to hunt black bears; the take of black bear cubs and sows with artificial light at den sites; and
the take of wolves and coyotes during the denning season.
We thank you for considering this important issue and urge you to adopt the proposed rule.
Sincerely,
Jeff Flocken
Regional Director, North America
International Fund for Animal Welfare
NATIONAL PARK SERVICE, MANAGEMENT POLICIES 2006 at 42.
See Robert L. Beschta & William J. Ripple, Large Predators and Trophic Cascades in Terrestrial Ecosystems of the Western United
States, 142 BIOLOGICAL CONSERVATION 2401 (2009); Joel Berger, Peter B. Stacey, Lori Bellis & Matthew P. Johnson, A
Mammalian Predator-Prey Imbalance: Grizzly Bears and Wolf Extinction Affect Avian Neotropical Migrants, 11 ECOLOGICAL
APPLICATIONS 947 (2001).
3 William J. Ripple & Robert L. Beschta, Large predators limit herbivore densities in northern forest ecosystems, 58 EUR. J.
WILDLIFE RES. 733 (2012).
4 See, e.g., William J. Ripple & Robert L. Beschta, Wolf Reintroduction, Predation Risk, and Cottonwood Recovery in Yellowstone
National Park, 184 FOREST ECOLOGY & MGMT. 299 (2003); William J. Ripple & Eric J. Larsen, Historic Aspen Recruitment,
Elk, and Wolves in Northern Yellowstone National Park, USA, 95 BIOLOGICAL CONSERVATION 361 (2000).
5 See Beschta & Ripple, supra note 2.
6 Christopher C. Wilmers, Daniel R. Stahler, Robert L. Crabtree, Douglas W. Smith & Wayne M. Getz, Resource Dispersion
and Consumer Dominance: Scavenging at Wolf- and Hunter-Killed Carcasses in Greater Yellowstone, USA, 6 ECOLOGY LETTERS 996
(2003).
7 Christopher C. Wilmers & Wayne M. Getz, Gray Wolves as Climate Change Buffers in Yellowstone, 3 PLOS BIOLOGY 571
(2005).
8 Id.
9 NATIONAL PARK SERVICE, ENVIRONMENTAL ASSESSMENT: WILDLIFE HARVEST ON NATIONAL PARK SYSTEM
PRESERVES IN ALASKA (2014).
10 See Rachel M. Gray, Michael R. Vaughan & Steve L. McMullin, Feeding wild American black bears in Virginia: a survey of
Virginia bear hunters, 1998-99, 15 URSUS 188 (2004).
11 See Jon P. Beckmann & Joel Berger, Rapid ecological and behavior changes in carnivores: the responses of black bears (Ursus
americanus) to altered food, 261 J. ZOOLOGY 207 (2003).
12 Grant V. Hilderbrand, Sanford P. Rabinowitch & Dave Mills, Black bear baiting in Alaska and in Alaska’s National Park
Service lands, 1992–2010, 24 URSUS 91 (2013); Juliet L. Manning, Jennifer L. Baltzer, Impacts of American black bear baiting on
Acadian forest dynamics, 262 FOREST ECOLOGY & MGMT. 838 (2011).
13 Hilderbrand et al., supra note 12, at 95.
14 See Hank Hristienko & John E. McDonald Jr., A perspective on trends and controversies in the management of the American black
bear, 18 URSUS 72 (2007).
15 See Hilderbrand et al., supra note 12, at 95 (citing Stephen Herrero, BEAR ATTACKS: THEIR CAUSES AND AVOIDANCE
(2002)).
16 Michael E. Jacoby, Grant V. Hilderbrand, Christopher Servheen, Charles C. Schwartz, Stephen M. Arthur, Thomas A.
Hanley, Charles T. Robbins & Robert Michener, Trophic Relations of Brown and Black Bears in Several Western North American
Ecosystems, 63 J. WILDLIFE MGMT. 921 (1999).
17 See 79 Fed. Reg. 52595, 52597 (Sept. 4, 2014).
18 See Michael R. Vaughan & Kristine L. Higgins Inman, Hunter Effort and Success Rates of Hunting Bears with Hounds in
Virginia, 13 URSUS 223 (2002).
19 See, e.g., Bill Lueders, Is state too open to hunting with dogs?, WISCONSINWATCH, Oct. 14, 2013,
http://wisconsinwatch.org/2013/10/is-state-too-open-to-hunting-with-dogs/.
1
2
5
Id.
John D. C. Linnell, Jon E. Swenson, Reidar Andersen & Brian Barnes, How Vulnerable Are Denning Bears to Disturbance?,
28 Wildlife Soc’y Bull. 400 (2000).
22 Alaska Department of Fish and Game, 2014-2015 ALASKA TRAPPING REGULATIONS 14, available at
http://www.adfg.alaska.gov/static/regulations/wildliferegulations/pdfs/trapping.pdf.
23 EA, supra note 9, at 15.
24 L. DAVID MECH & LUIGI BOITANI, WOLVES: BEHAVIOR, ECOLOGY AND CONSERVATION 302 (University of Chicago
Press 2010).
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