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Hunters Action Alert
November 17, 2021

Caribou & Moose hunts may be closed despite no shortage

Wednesday, 17th, 2021, from 4 to 6 pm Alaska Time Zone, or until comments are finished (7 to 9 pm CST).

Call: 888-942-9690  Passcode: 6071806

The Regional Advisory Council (RAC) requested the Federal Subsistence Board (FSB) close approximately 43 million acres of federal lands to non-local hunters for caribou and moose in GMUs 23 and 26A.  There is no shortage of moose or caribou.  The RAC asserts:

“The Council is particularly concerned about the effect transporters and non-local hunters are having on the migration of the Western Arctic Caribou Herd, and believe that transporter activity in Units 23 and 26A may be delaying caribou migration. The Council hopes this request would reduce aircraft traffic, creating an easier path for migrating caribou.”

Closing state-regulated hunting of healthy wildlife populations will unnecessarily deprive non-local hunters, both Native and nonnative, of subsistence and nonsubsistence use.  Scientific study determined the level of activity is not delaying caribou migrations.

Action needed:

  1. You can submit written comments or testify at a public hearing on November 17, 2021.  Your time to comment at the public hearing will be limited, usually to 2 minutes.  Written public comments for the FSB consideration of this “special action” request may be sent, via email to:  subsistence@fws.gov.
  1.  To listen or participate in the public hearing:

When:  Wednesday, 17th, 2021, from 4 to 6 pm Alaska Time Zone, or until comments are finished (7 to 9 pm CST).

Call: 888-942-9690  Passcode:  6071806

  1. You can also join over 4,5000 hunters, by signing the petition at: Defend Your Access to Public Lands! Sign The Petition!

Your  hunting area may be next!!  The FSB has increasingly closed other areas without a factual basis, so the hunting community must voice its objections to stop this closure. 

Points to consider:

The herd is healthy and sustainable at current harvest levels:

  • ADF&G says there is no biological concern with caribou in these units at this time to warrant a closure on federal lands–or any lands.
  • The Western Arctic Caribou Herd is healthy with a population estimate of 244,000.  This is above ADF&G’s population objective of 200,000.
  • The Teshekpuk Herd is healthy with a population estimate of 56,000, above the objective of 15-28,000.
  • The Western Arctic Caribou Herd Working Group voted December 2020 to maintain the status quo on the management of the herd.
  • Local harvest is currently estimated at 12,000 caribou, which is the upper end of the amount needed for subsistence for both herds.  
  • The total estimated harvest by non-locals is 300-350 caribou, of which non-federally qualified Alaska residents harvest on average 212 caribou (roughly 1.7% of the total)

Closing federal land will increase conflicts on non-federal land, impact traditional and cultural family hunting, and will not reduce ongoing aircraft traffic unrelated to hunting

  • The proposed closure would concentrate hunters on state and private lands, which tend to be closer to communities, thereby increasing perceived and real conflicts.
  • This closure impacts the ability of rural residents to hunt with family members that moved to urban areas for school or employment, thus impeding transmission of cultural values and traditions.
  • Actions taken over 30 years by the State and Federal agencies reduced use of aircraft for hunting in this area, e.g., the Noatak Controlled Use Area, Anaktuvuk Pass Controlled Use Area, and a prohibition within part of Noatak Preserve all directly restrict use of aircraft while hunting.
  • The proposal would only restrict use of aircraft by hunters but would not limit other aircraft use for travel and access in these federal lands or nonfederal inholdings or adjacent lands.

Closing federal land will not improve caribou numbers, affect migration, or provide additional subsistence hunting opportunity

  • A scientific study found no basis for the RAC’s assertion that aircraft transport of non-local hunters change caribou migration (see Attachment 1) and concluded:

We found that caribou avoided rugged terrain and areas with more river, forest, and tall shrubs while selecting for areas dominated by tussock tundra and dwarf shrubs. Migration of caribou through Noatak does not appear to be inhibited by sport hunting activity, though this does not preclude the possibility of temporary effects altering availability of caribou for individual hunters. Caribou exhibited exploratory movement, following predictions of a random walk model. This behavior may facilitate the location of remaining patches of high-quality forage prior to the onset of winter, especially during mild autumns.

The closure unnecessarily interferes with the State’s Constitutional mandate to manage fish and wildlife for the greatest benefit of all residents on a sustained yield basis and unnecessarily impacts nonsubsistence use, contrary to ANILCA Sections 815 and 1314.

  • The proposal would close 43 million acres to harvest of caribou and moose under State regulations without being necessary for “the conservation” of the population or to “provide a priority subsistence opportunity” by rural residents, as required by ANILCA.
  • The federal and state seasons are very liberal and the populations are healthy.  The rural families would be deprived of sharing traditions with nonlocal family members unless they concentrate on the Native corporation lands in these Units.  (7 million acres in these Units are privately owned and already limit access by non-shareholders.)
  • This proposed closure is similar to others increasingly adopted by the FSB around the State not based on a need for conservation (which determination should be deferred to the State managers) or to provide a priority opportunity for subsistence (instead basing closures on perceived social conflicts), thereby increasingly concentrating non-local hunters into ever shrinking areas and resulting in more conflicts in other areas.

To read an interesting article on this proposed closure go to:                                                             www.outdoorlife.com/hunting/alaska-caribou-hunt-closures-not-about-herd-numbers