Dear Secretary Zinke:
We write to express grave concerns regarding the National Park Service's (NPS) proposed rule, published on May 22, 2018, titled Alaska; Hunting and Trapping in National Preserves (83 FR 23621). The proposed rule would roll back critical protections for America's beloved, rare and iconic native carnivores, including brown bears, black bears and wolves on the approximately 20 million acres of national preserves in Alaska--land that belongs to all Americans. The rule would effectively endorse the state of Alaska's efforts to use extreme practices to reduce bear and wolf populations in order to artificially inflate populations of prey species for sport hunting. Given these concerns, we urge you to withdraw the proposed rule.
The NPS proposed rule reverses a regulation that was promulgated in 2015 in response to two decades of escalating efforts by the state of Alaska to reduce native carnivore populations in an attempt[i] to meet the demand for caribou and moose by Alaskan and out-of-state hunters.[ii] That regulation prohibited certain extreme and historically-prohibited sport hunting practices such as brown bear baiting, the killing of black bear mothers and cubs in dens, and the killing of wolves during denning season, on the grounds that those methods were adopted to alter natural conditions and decrease native carnivore populations.
When NPS adopted its protective regulation in 2015, it did not do so lightly. From 2005-2015, under both the previous two Administrations, NPS made over 50 requests to the Alaska Board of Game to limit native carnivore-hunting efforts on national preserve lands. The state ignored every one of those requests. When NPS finally proposed its regulation in 2015, it provided a cumulative 120-day comment period and held 26 public meetings in affected communities in Alaska. The results revealed the overwhelming opposition to these fringe hunting practices--NPS received approximately 70,000 comments, almost all of which supported the effort to limit these extreme hunting methods on public lands.
DOI's proposal to reverse the 2015 rule wastes taxpayer money and agency resources and disregards the public interest resoundingly voiced in the 2015 rulemaking. We are concerned that the 60-day comment period, half of what was provided for the 2015 rule, and the fact that NPS has not yet announced any public meetings, diminishes the public's role in the management of federal lands. We request that the DOI hold public meetings to solicit feedback. Further, although the comment period on the rule has begun, the draft Environmental Assessment, a tool that could help the public consider the rule's impacts, has not yet been released.
The reversal of the 2015 regulation to protect NPS lands from extreme predator control methods ignores the purpose of national preserves in Alaska, as mandated by Congress. In the Alaska National Interest Lands Conservation Act (ANILCA) of 1980, Congress identified these federal lands to be managed as national preserves by NPS. They are subject to the benefits and limitations of the NPS Organic Act and must be managed to "conserve the scenery, natural and historic objects, and the wild life in the [NPS] System units and to provide for the enjoyment of the scenery, natural and historic objects, and wild life in such manner and by such means as will leave them unimpaired for the enjoyment of future generations."[iii]
We recognize there is an important difference between preserves and parks--hunting is to be allowed on preserves in recognition of Alaska's unique culture and landscape. The provision for hunting does not, however, obviate Congress' intent to protect the wildlife of the preserves, including native carnivores. ANILCA specifically instructs nine of the ten national preserves in Alaska to be managed to "protect habitat for, and populations of, fish and wildlife," including explicit reference to brown/grizzly bears, and also specifically calls for the protection of wolf populations on six of the ten preserves. Therefore, DOI's current course of action, to reverse the 2015 NPS regulation that protects wolf and bear populations from efforts to reduce these rare and iconic native carnivores and intentionally upend the natural balance on national preserve lands, directly contradicts Congress' mandate.
Congress has instructed DOI to manage national preserves "unimpaired for the enjoyment of future generations." The proposed rule does not meet the Department's statutory obligations and ignores the extensive process that clearly demonstrated overwhelming support for the 2015 regulation. Given its legal flaws and the inappropriate, extreme predator-control methods under consideration, we urge you to withdraw the proposed rule.