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

fatbacks

WKR
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Aug 26, 2017
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Interior AK
I will be calling in next Friday but for those of us who have hunts booked this Fall, what is the probability this gets passed and implemented in 2021? Does it really move that fast? What a blow to transporters and guides for those areas if this gets thru. Get on the phone next Friday!!!
I would hunt it anyway. Even if this passes, I would conjecture that there is about zero chance of enforcement.

I am not all over the forums, but I think the similar closure in unit 13 had little to no enforcement.

Actually I would like someone to get ticketed for this and then have it taken up in court. Might be the only way to stop this bullsh!t from popping up every other year
 

Catag94

Lil-Rokslider
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Mar 29, 2021
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One has to love government. They always want written comment. Until they don’t. See reply below:

Thank you for reaching out with your concerns regarding the special action request (WSP21-01) proposing a closure in Units 23 and 26A to the harvest of caribou and moose by non-Federally qualified users from August 1 through September 30, 2021.

You may be aware that we are holding a public hearing (teleconference) to gather comments on this proposed special action. For special actions, the Board only accepts comments at public hearings. We encourage you to participate in this hearing by calling the telephone number below and when prompted, enter the passcode. The comments you share during this public hearing will be forwarded to the Board for consideration.

Public Hearing Information:
Friday, April 23, 2021 from 5:00 p.m. – 7:00 p.m. (or until the end of public participation)
Teleconference: Toll Free: (877) 918-3011
Passcode: 8147177


For special actions, the Board does not accept written comments or comments submitted by email, fax, social media, or phone messages. Any comments submitted outside of the public hearings on this special action request will not be considered by the Board.

After the public hearing, OSM staff will compile all public comments and present them to the Board. In addition, an analysis, which includes biological and anthropological data, will be presented to the Board. All of this data will be used by the Board to make their decision on this issue.

Again, thank you for your interest in the Federal Subsistence Management Program and we look forward to your participation at the public hearing.

Theo Matuskowitz
Supervisory Regulations Specialist
US Fish and Wildlife Service
Office of Subsistence Management
1011 East Tudor Road, MS 121
Anchorage, AK 99503-6199
Office: (907) 786-3867
Telework: (907) 357-3095
FAX (907) 786-3898
[email protected]


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This is very interesting given that in the minutes from the meeting in April of 2016 for WSA16-01, the OSM had a representative (Zach Stevenson) the who specifically shared written comments they had received prior to that meeting (potentially after the public hearing). The public hearing in the case of WSA16-01 had been held in February of that year.
Nonetheless, Mr. Stevenson shared written comments from three individuals/organizations. All the were in favor of WSA16-01. The last of those three was from a Mr. Gordon Brower. I suspect he is related to Mr. Charles Brower - current public member-Barrow (voting Member) of the FSB.

If you care to read these minutes - https://www.doi.gov/sites/doi.gov/files/uploads/fsb_mtg_13_apr_16.pdf
this can be seen on page numbers 174-175.
 

Catag94

Lil-Rokslider
Joined
Mar 29, 2021
Messages
199
I would hunt it anyway. Even if this passes, I would conjecture that there is about zero chance of enforcement.

I am not all over the forums, but I think the similar closure in unit 13 had little to no enforcement.

Actually I would like someone to get ticketed for this and then have it taken up in court. Might be the only way to stop this bullsh!t from popping up every other year
I doubt you'd get a local transporter to take you.
 

207-12A

Lil-Rokslider
Joined
Nov 12, 2017
Messages
216
If you’re an Alaska resident, CALL your state Senator and state representative, neither of mine’s offices had even heard about this issue, but both were very receptive to my argument against the DOI’s proposal. Pick up the phone and start dialing.
 
OP
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Larry Bartlett

WKR
Rokslide Sponsor
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Agreed. I'm hunting anyway and recommending all groups who have planned their hunt not to sway. Your transporters will take you. Remember, I defied the WSA16-01 and 17-03/04 back 4 years ago and harvested successfully.

If you quit your plans out of fear, they win you lose.

The state troopers and federal LEO pilots are ill-equipped with man power to enforce this closure, even if it was legitimate. The state opposes this proposal and the Hunting Regulations have allocated a harvest limit and open hunting season for residents and non-residents.

That's the only real take-away from this post. Our 1st defense is next friday and then again with a predictable "WSA 24-01"
 

Catag94

Lil-Rokslider
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Catag94. Great citing. I'll research that one some more too. Thank you
Larry,
The more I read and research, the more it seems this FSB is allowed to enact these WSAs ripping rights from people with little to no accountability. At some point, the Secretary of the Department of the Interior should be responsible for these actions. Here is a citing from ANILCA section 805
"(c) The Secretary, in performing his monitoring responsibility pursuant to section 806 and in the exercise of his closure and other administrative authority over the public lands, shall consider the report and recommendations of the regional advisory councils concerning the taking of fish and wildlife on the public lands within their respective regions for subsistence uses. The Secretary may choose not to follow any recommendation which he determines is not supported by substantial evidence, violates recognized principles of fish and wildlife conservation, or would be detrimental to the satisfaction of subsistence needs. If a recommendation is not adopted by the Secretary, he shall set forth the factual basis and the reasons for his decision."

Perhaps if this passes, with no evidence or science, in fact in spite of real evidence and science, the next step is to take this to Deb Haaland.
 

Fatcamp

WKR
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May 31, 2017
Messages
5,673
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Sodak
I understand the effects of sport hunting on Caribou migration patterns has been studied multiple times. one of these studies is can be read her:
and here is an excerpt from the conclusions.

"Our analysis of caribou movement in Noatak National Preserve shows that caribou respond to environmental features such as terrain ruggedness and land cover type, but not to sport hunting activity at the scale considered. The negative effect of terrain ruggedness on caribou movement aligns with patterns seen for the WACH at the scale of the full autumn migratory path (Fullman et al., in revision), though in winter, when they are non-migratory, caribou may select for more rugged terrain [27, 70]. Similarly, our finding that caribou avoid migratory pathways with greater river area aligns with caribou crossing more frequently in narrow portions of rivers in Canada [76] and with increased landscape resistance to autumn migratory movement from major rivers for the WACH (Fullman et al., in revision). Patterns of vegetation influence on step selection also coincide with other reports of avoidance of dense vegetation by caribou ([70, 97], Fullman et al., in revision). Avoidance of dense vegetation may be to facilitate travel and/or to reduce predation risk.

We did not detect an effect of sport hunting activity on caribou resource selection, supporting our null hypothesis. This indicates that sport hunting does not inhibit the ability of caribou to migrate through Noatak. Local hunters have harvested caribou at key river crossing locations for 10,000 years in northwest Alaska [98]. That these locations continue to be used by caribou and local hunters to this day [24] may support our findings. Further, studies elsewhere have also found environmental factors have a greater impact on animal space use than hunting (e.g., [61, 62]). Our finding of a lack of effect of sport hunting activity on the likelihood of caribou migrating through Noatak does stand in apparent contrast to concerns voiced by local hunters regarding the negative effects of sport hunters and commercial air transporters (e.g., [39, 42, 43]). "


My transporter for this fall has encouraged us to join the teleconference and get as many others to join as possible. It is his opinion, and the most natural one to draw from reading all the meeting minutes of the NWARAC meetings) that their motivation is strictly based on discrimination and racism, and that there is no scientific or biological reasoning to support their position. Certainly Larry and others on this site, more knowledgeable and experienced in this repetitive matter, have voiced similar findings.

I read the minutes of the April 2016 meeting in which the FSB approved WAS16-01. I find the following statements by the then chairman in his response to the representative from the National Park Service to be utterly disgusting. Its amazing how the facts and scientific data meant nothing to this person. The RAC had no real data to support their WSA then. This chairman supported whatever they (RAC) request. I also find the fact the the USDS representative also voted for WSA19-01 to also be disturbing since non of the other Federal representatives did.

Her are the comments to which I referred:

[I]"CHAIRMAN TOWARAK: That is completely contrary to what the Regional Councils are saying though. And I personally am not going to vote against the Regional Council."[/I]

So in other words - Facts don't matter, what does its what the RAC says despite any real proof or data to their claims??? Unbelievable power to control so much! But, that man is no longer on the board.
I will join the call and do my part.
Science only counts when it aligns with the desired results.
 

Catag94

Lil-Rokslider
Joined
Mar 29, 2021
Messages
199
I will be calling in next Friday but for those of us who have hunts booked this Fall, what is the probability this gets passed and implemented in 2021? Does it really move that fast? What a blow to transporters and guides for those areas if this gets thru. Get on the phone next Friday!!!
See this notice:

https://www.doi.gov/sites/doi.gov/files/nr-public-hearing-wsa-21-01.pdf

It will take affect this season if it passes. Can't speak to the odds, but base on previous WSAs, they may be good despite actual justification or lack thereof.
 
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Larry Bartlett

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If passed, it would likely be announced in May/june. I have heard they will be announcing a second teleconference for this special action request, likely a week or two after the first one (next friday), then decided within 30-days from the last "public testimony."
 
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Larry Bartlett

WKR
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I have never tipped my hand on public testimony prior to the event, but in this case it could help some of you who have never testified in a public meeting. The following testimony is to oppose WSA21-01. The word count is 580 and spoken aloud in 4 min 10 seconds. The common allocated timeframe for these public testimonies is 3-5 minutes, but I would keep it clear and simple closure to 3 min or <450 words.


I’m Larry Bartlett, a 26-year resident of Alaska and 25-year harvester of WA Caribou. I’m also a 12-year Army Veteran, Disabled Veteran and father of two future hunters who rely on this state resource for non-local subsistence.

I served for 3 years as a member of the WA Caribou Herd Working Group starting in 2010 alongside the current chairman of the NWRAC. I left the group because of their misguided intentions to thwart non-local hunters and transporters.

In 2016 and 2017 I testified at public meetings against WSA 16-01 and 17-03/-04, during which seasons I also produced a 2.5-hour hunting documentary for community awareness, titled WSA 16-01: Hunt for Western Arctic Caribou. This film took place in the heart of GMU 23 and 26A from Kotzebue, where NWRAC members claim non-local hunting and transporter presence continue to negatively impact caribou migration and interrupt the continuation of subsistence use. The evidence within this film documented unbiased, factual field-based observations that contradicted all native hunches that formed the basis for closing federal lands under ANILCA Title 8.

In winter of 2017 a dozen copies of this film were provided to the NW RAC for review and a request to collaborate on ideas to reduce perceived user conflicts between local and non-local hunters. One hour after their meeting ended, I returned to their room and removed 12 copies of this project from the trash can by the door.

This is a valid reference because the same RAC members (1st and 2nd chairman) are perpetuating those same invalid claims with scintilla, not evidence.

WSA21-01 is an invalid proposal lacking the qualities of being factually sound and having substantial evidence-based support proving non-local hunters and transporter activity are threats to:
  • Continuation of subsistence use
  • Conservation of the caribou and moose population
If non-local hunters and transporters are responsible for those two concerns, then you must reference substantial evidence to support WSA21-01, but you must not pursue this special action request without it. Title 36 CFR 242.19 (b) 1 The proposed change is an unnecessary restriction on non-subsistence users because there is no data or evidence supporting this special action.

Furthermore, non-local hunters have planned and financed their 2021 hunt for WAH caribou and will be forced to pursue hunting below mean high water line on federal lands within GMU 23 and 26A but also on state land closest to huntable caribou. WSA21-01 will create unjustified displacement of hunting pressure on Teshekpuk Lake caribou within 26A. This non-migratory caribou population has one of the highest numbers of harvest of all herds (proportionate to its size) and a single community that relies heavily on harvest sustainability. Consideration of the plausible negative impact on Teshekpuk caribou and tangible user conflict that will be created by this proposal must be weighed against the disputable hunches of a few active RAC members in Kotzebue.

Lastly, WSA21-01 has no factual, scientific, biological or evidence-based grounds for closing federal public lands to hunting by non-locals. If this proposal passes, I will challenge the authority of the FSB and respectfully encourage federal LEOs to search for my camp in these closed areas. Until the state of Alaska wildlife management and the BOG agrees with imposing hunting restrictions on non-subsistence users, or until such time that the proponent presents sufficient evidence to support their distaste for non-local hunters, I will pursue my right to hunt in GMU 23 and 26 despite the OSM decision on this matter.

WSA21-01 is a commanding NO.
 

207-12A

Lil-Rokslider
Joined
Nov 12, 2017
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216
Larry,
Spot on with your above post. I think the key is to stay unemotional, and you really stick to your points in a coherent manner. The thing for me is that this closure isn’t supported by the science. The Alaska BOG and ADFG both do not support it, why should Federal interests override state management? Thats not the American model (migratory birds and ESA critters notwithstanding).
 

Clarktar

WKR
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AK
Some great guidance in this thread. Really appreciate the efforts from Rokslide members.

But, it's all for not if folks don't make it a priority to call in and be heard during the public comment period.

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Kansas

Public comment opportunity announced for Temporary Wildlife Special Action Request WSA21-01 (Units 23 and 26A caribou and moose)​

Due to a high level of public interest in a temporary special action request submitted to the Federal Subsistence Board, there will be an opportunity to submit written comments on this request during a five-day comment period (April 16-20, 2021), in addition to an already-scheduled public hearing.

 

Clarktar

WKR
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AK
Well, it's encouraging to see there is attention and that the subsistence board is paying attention (to some degree).

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Catag94

Lil-Rokslider
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Wow. I left a message for Theo today and never heard back. I guess this is a start.


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Sconnie77

FNG
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Sep 8, 2019
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They must be hearing us... here is another opportunity to tell them NO....https://www.doi.gov/subsistence/news/general/public-comment-opportunity-announced-temporary-wildlife-special-action
 

gbflyer

WKR
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Feb 20, 2017
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1,593
Thanks for the new link. I submitted comment also. Suggest keeping it very short and on point without delving off into the scientific weeds. You are addressing a board, not a body of professionals. They will not read it if it’s 3 pages long with big words.
 

Bear_Hunter

Lil-Rokslider
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Willow, AK
I'm sorry if I missed it, but is there a link somewhere to the proposal for WSA21-01 trying to justify this? I want to see their specific arguments so I can meticulously and thoroughly shred them to pieces with facts and logic in my comments.
 
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I'm in for a 2022 trip and emailed a link from the 13 closure. I'll type another email for this one over the weekend. I also plan to call in but I'll be on a trip with my dad next Friday and am not sure how much time/cell service I will have.
 
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