Federal Proposals to CLOSE Alaska's GMU 23 and 26A to caribou and moose hunters

[Larry Bartlett]

Bear Hunter, go back to page 1 of this thread for all the documents and transcripts.

The FSB did not include the "reason for request" on anything I've read, but the NWRAC meeting transcripts from 84-102 tell you how they drifted from a COVID closure to the two reasons I stated in my letter (above) and then added moose to the closure simply ala cart.

 

[DSC]

Happy to see this thread going. You've pretty much said it all, but I'll pass along the E-blast we just sent out to our members. Specifically so the contact information for you to voice your opinion stays fresh in the thread.

"In northern Alaska, a large portion of caribou and moose hunting is at risk for the 2021 season.

An Advisory Council is seeking to add new language to Federal regulations for caribou and moose in Alaska Units 23 and 26A. Nearly 80 percent of the 66.1 million acres that makes up Units 23 and 26A are federal lands. The proposed changes would prohibit the hunting of caribou and moose to all non-residents, and many Alaska residents, on all federal lands from August 1 through September 30, 2021. The Council’s request is not based on the scientific findings of Alaska Department of Fish and Game or any other official herd management group.

A telephonic public hearing is scheduled to receive public testimony on this temporary special action request. Additionally, the Federal Subsistence Board has opened a five-day public comment period (April 16-20). Submit a comment via email by clicking the button below.

Call in Information:
Friday, April 23, 2021
5:00 p.m. – 7:00 p.m. Alaska Time
(or until the end of public participation)
Phone: (877) 918-3011
Passcode: 8147177

• As a hunter, I know the necessity for wildlife to be sustainably managed by wildlife professionals.
• Decisions regarding wildlife management should always be science-based.
• The Western Arctic Herd that resides in the units is above management objective.
• I oppose the closing of Units 23 and 26A to those who aren't "federally qualified subsistence users""

Due to a "high level of public interest" a five-day public comment period has been authorized by the Federal Subsistence Board. You can send your comments, via email, to: [email protected].

 

[Catag94]

Happy to see this thread going. You've pretty much said it all, but I'll pass along the E-blast we just sent out to our members. Specifically so the contact information for you to voice your opinion stays fresh in the thread.

"In northern Alaska, a large portion of caribou and moose hunting is at risk for the 2021 season.

An Advisory Council is seeking to add new language to Federal regulations for caribou and moose in Alaska Units 23 and 26A. Nearly 80 percent of the 66.1 million acres that makes up Units 23 and 26A are federal lands. The proposed changes would prohibit the hunting of caribou and moose to all non-residents, and many Alaska residents, on all federal lands from August 1 through September 30, 2021. The Council’s request is not based on the scientific findings of Alaska Department of Fish and Game or any other official herd management group.

A telephonic public hearing is scheduled to receive public testimony on this temporary special action request. Additionally, the Federal Subsistence Board has opened a five-day public comment period (April 16-20). Submit a comment via email by clicking the button below.

Call in Information:
Friday, April 23, 2021
5:00 p.m. – 7:00 p.m. Alaska Time
(or until the end of public participation)
Phone: (877) 918-3011
Passcode: 8147177

• As a hunter, I know the necessity for wildlife to be sustainably managed by wildlife professionals.
• Decisions regarding wildlife management should always be science-based.
• The Western Arctic Herd that resides in the units is above management objective.
• I oppose the closing of Units 23 and 26A to those who aren't "federally qualified subsistence users""

Due to a "high level of public interest" a five-day public comment period has been authorized by the Federal Subsistence Board. You can send your comments, via email, to: [email protected].

Thank you. As supporting member of the DSC, and since this issue comes up regularly as a blatant attack on other American's rights, I urge you to engage our senators to hopefully put a stop to the repeated abusive use of ANILCA by these regional advisory councils. ANILCA, in and of itself is a valid and good act.

 

[Jackal7]

For what its worth, I submitted my emailed comment for next week's hearing. Here is the text of it:

Dear Madams/Sirs,



I write in regard to the proposal to close caribou hunting to non-subsistence hunters in Units 23 and 26A starting in 2021. I have a personal interest in opposing this measure as I have in the past hunted caribou in Unit 23 and hope to introduce my son and friends to this beautiful wilderness to enjoy unguided caribou hunting in the near future.



I am a United States citizen. I faithfully pay my federal taxes every year. I support the creation of wilderness areas and protection of federal lands and wildlife – for the enjoyment of all persons!



Federal lands should not be restricted for the use of a select few. Unless there is a compelling environmental or biological scientific basis for doing so. In this instance, no such compelling scientific rationales exist for the closure to non-subsistence hunters in Units 23 and 26. As a federal tax payer, I should enjoy equal access to such lands and their wildlife for hunting, as should every other person in the United States.



To pick and choose who gets to access and enjoy this resource in the manner currently proposed is an arbitrary and capricious decision-making process that effectively accepts my federal tax dollars yet excludes me from access to these hunting units.



I respectfully and strongly urge you not to implement this restrictive proposal. There are simply no scientific grounds to support the proposal. Thank you.

 

[brocksw]

Oppose Public Land Closure in Northwest Alaska

Backcountry Hunters & Anglers is the voice for our wild public lands, waters and wildlife.

www.backcountryhunters.org

 

[Skullwhite_designs]

Very well spoken Larry. Im sure I speak for most when I say I'm glad there are guys like you out there not only advocating for the wildlife but also for the hunters that seek it. I will be submitting my comment and attempting to call in on Friday. For anyone interested BHA has posted a quick link on their social media pages with a ready to submit email that you can edit to your own words as well. The squeaky wheel gets the oil!

 

[AKDoc]

Done and submitted this morning...what I sent is copied below as a support reference for others here:

I strongly oppose the Advisory Council's proposal to close Units 23 & 26A from 8/1 thru 9/30 to those who are not federally qualified subsistence hunters.

I am a thirty-five year Alaska resident whose children were raised on the meat of animals and fish that I have harvested each year. I have also volunteered for the ADFG, and I have always supported and protected the scientific management of our resources. The above referenced proposal has neither scientific nor field observational support...absolutely none. The Western Arctic Herd is above management objectives, and the taking of animals by nonlocal residents/nonresidents represents an extremely small fraction of the total harvest each year from those GMU's. Even the ADFG does not support this proposal.

80% of the 66.1 million acres that make-up Unit 23 and 26A are federal lands. This proposal is a selfish insult to those of us who value and protect our wildlife resources...and pay our federal taxes each and every year!

 

[Voyageur]

@AKDoc @Larry Bartlett and others....really appreciate you sharing your comments to be used as a template by others.
One question I have about the written comments is if we should provide our full name and address with our written comments? I know when commenting via email on Fish and Game issues in my home state we need to provide that info for the commission to consider our comments.
Thanks.

 

[Larry Bartlett]

yes definitely include your full name and home of record.

 

[mcseal2]

I will get my email sent this weekend as well. I hope to be able to participate in the call but if I can’t due to work I’ll have my email sent.

 

[AKBorn]

Sent my email in this morning, and hoping to get a couple of friends to do the same...

 

[bmrfish]

Oh man this makes me furious all over. We got hosed by the 2016 closure which led us to cancel a once in a lifetime trip for a couple older guys in our group. Wrote letters to all the board members, called into meetings, got news article publicity. The late cancellation also cost us thousands of dollars in lost deposits. I think we got one bs letter back and at least one of the board members didn’t even have the courtesy to open our letter - came back return to sender. Bleep the FSB


Sent from my iPhone using Tapatalk

 

[AK_Skeeter]

In 2019, the US Supreme Court ruled unanimously the National Park Service did not have right to control access to the State’s navigable waters within federal lands.

Therefore, this proposal is likely to increase conflicts between boat-based subsistence hunters
and non-subsistence hunters increased use of navigable waters thru federal lands.

Email by tomorrow your public comment input to: [email protected]

 

[Catag94]

Emailed my written comments on Friday. If given the opportunity, here are my public hearing comments:

I support ANILCA and believe it to be crucial for the protection of the subsistence and traditional use needs of the native people of Alaska. It created the law that empowers this board to take actions like this one. That law is carefully written and must be understood so, I would like to quote from the section pertaining to these types of actions if I may: “The Board may make such temporary changes ONLY after it determines that the proposed temporary change will not interfere with the conservation of healthy fish and wildlife populations, will not be detrimental to the long-term subsistence use of fish or wildlife resources, and is not an unnecessary restriction on non-subsistence users. (36 CFR 242.19 b1)​

The law also requires this board to consider TRADITIONAL USE PATTERNS when taking these actions. (36 CFR 242.18 a4)​

And, the law further gives this board authority to DENY such actions …”which the Board determines is not supported by substantial evidence…” (36 CFR 242.18 a4)​

​

​

WSA21-01​

Is an unnecessary restriction on non-subsistence users, ​

Is NOT supported by evidence, and​

Its approval could potentially be detrimental to long-term subsistence.​

The Law places the burden of proof on the FSB and the RAC.​

The NSRAC has provided you NO evidence that the subsistence of their region is threatened or that NFQU are effecting changes to it. In fact the minutes from their November 3rd, 2020 meeting record proof to the contrary meaning WSA21-01 is an unnecessary restriction.​

I assume this board, like I and other hunters, is familiar with the fact that prior to 1949, the caribou did not use the Buckland/Selwik flats area for wintering and that the Kobuk Valley people would go to the Upper Noatak to get caribou. This is exactly what has been happening recently including in 2020 and subsistence has been achieved. Board members Mr. Kramer and Mr. Shiedt said as much in their meeting in November.​

This is consistent with traditional use patterns for decades.​

The study published in 2017, conducted in a joint effort by the NPS and The Wilderness Society, found that sport hunting and the use of airplanes had no impact on the migration patterns of caribou.​

On multiple occasions, the RACs have been informed that this proposed closure will not have a biological effect on the subsistence harvest.​

And, the population data of the WACH as well as resent harvest estimates for subsistence do not support this action.​

Finally, please understand that if you approve WSA21-01 despite it being an UNNECESSARY restriction on non-subsistence users, and without the support of evidence, you will actually be in violation of the very law that grants you this authority. Such behavior will only encourage the members of the ten regional advisory councils to write more of these erroneous proposals.​

Perpetuating this abusive use of ANILCA and using it as a tool to improperly strip other Americans of their right to public resources invites challenge that could lead to permanent changes. This puts the Secretary of the DOI in a compromising position and it threatens the stability of ANILCA itself. Yes, this action could be very detrimental to the legitimate protection of subsistence long-term. This reminds me of the boy who cried wolf one too many times!​

So I urge you to DENY this wildlife special action, send a clear message to all of the RACs, and put an end to this abusive use of a noble Act.​

​

Thank you.​

 

[AK_Skeeter]

Emailed my written comments on Friday. If given the opportunity, here are my public hearing comments:

I support ANILCA and believe it to be crucial for the protection of the subsistence and traditional use needs of the native people of Alaska. It created the law that empowers this board to take actions like this one. That law is carefully written and must be understood so, I would like to quote from the section pertaining to these types of actions if I may: “The Board may make such temporary changes ONLY after it determines that the proposed temporary change will not interfere with the conservation of healthy fish and wildlife populations, will not be detrimental to the long-term subsistence use of fish or wildlife resources, and is not an unnecessary restriction on non-subsistence users. (36 CFR 242.19 b1)​

The law also requires this board to consider TRADITIONAL USE PATTERNS when taking these actions. (36 CFR 242.18 a4)​

And, the law further gives this board authority to DENY such actions …”which the Board determines is not supported by substantial evidence…” (36 CFR 242.18 a4)​

​

​

WSA21-01​

Is an unnecessary restriction on non-subsistence users, ​

Is NOT supported by evidence, and​

Its approval could potentially be detrimental to long-term subsistence.​

The Law places the burden of proof on the FSB and the RAC.​

The NSRAC has provided you NO evidence that the subsistence of their region is threatened or that NFQU are effecting changes to it. In fact the minutes from their November 3rd, 2020 meeting record proof to the contrary meaning WSA21-01 is an unnecessary restriction.​

I assume this board, like I and other hunters, is familiar with the fact that prior to 1949, the caribou did not use the Buckland/Selwik flats area for wintering and that the Kobuk Valley people would go to the Upper Noatak to get caribou. This is exactly what has been happening recently including in 2020 and subsistence has been achieved. Board members Mr. Kramer and Mr. Shiedt said as much in their meeting in November.​

This is consistent with traditional use patterns for decades.​

The study published in 2017, conducted in a joint effort by the NPS and The Wilderness Society, found that sport hunting and the use of airplanes had no impact on the migration patterns of caribou.​

On multiple occasions, the RACs have been informed that this proposed closure will not have a biological effect on the subsistence harvest.​

And, the population data of the WACH as well as resent harvest estimates for subsistence do not support this action.​

Finally, please understand that if you approve WSA21-01 despite it being an UNNECESSARY restriction on non-subsistence users, and without the support of evidence, you will actually be in violation of the very law that grants you this authority. Such behavior will only encourage the members of the ten regional advisory councils to write more of these erroneous proposals.​

Perpetuating this abusive use of ANILCA and using it as a tool to improperly strip other Americans of their right to public resources invites challenge that could lead to permanent changes. This puts the Secretary of the DOI in a compromising position and it threatens the stability of ANILCA itself. Yes, this action could be very detrimental to the legitimate protection of subsistence long-term. This reminds me of the boy who cried wolf one too many times!​

So I urge you to DENY this wildlife special action, send a clear message to all of the RACs, and put an end to this abusive use of a noble Act.​

​

Thank you.​

You need to include your name and physical address in order for public input to be accepted by the Department of Interior

 

[Catag94]

You need to include your name and physical address in order for public input to be accepted by the Department of Interior

My written comments are different and do included those details. These are my public forum notes and I will state my name etc. But, your point is a good one.

 

[Slugz]

https://www.adfg.alaska.gov/static/home/library/pdfs/wildlife/caribou_trails/caribou_trails_2020.pdf

I didn't find this anywhere on the thread but I feel good info to build awareness and name recognition. Link above

 

[DSC]

Friendly reminder that today is the deadline for written comments. You can submit comments, via email, to [email protected]. Additionally, the telephonic public hearing has been extended by two hours. New time is now from 3p-7p AK time.

Public Hearing Information:

Friday, April 23, 2021 from 3:00 p.m. – 7:00 p.m. (or until the end of public participation)
Teleconference: Toll Free: (877) 918-3011
Passcode: 8147177

*edited to include email address

 

[Larry Bartlett]

You guys rock! I'm impressed and thankful for everyone's acknowledgement and contributions of time and effort to stick this proposal up the arse of the FSB.

lb

 

[AK_Skeeter]

I assume after the Sturgeon vs Frost Supreme Court ruling, planes could drop hunters off on navigable waters and the feds do not have control of these waters?

If the proposal was implemented, would this likely increase conflict between boat-based subsistence hunters and non-subsistence hunters on navigable waterways within federal lands?