In recent weeks, a wide array of key entities, including the state and national sportsmen’s community and members of Alaska’s Congressional Delegation, have highlighted concerns with proposed rules from the U.S. Fish and Wildlife Service (FWS) that would severely restrict the Alaska Department of Fish and Game’s (ADFG) ability to carry out traditional, effective wildlife management techniques on National Wildlife Refuge (NWR) lands in Alaska. The FWS rule docket, titled “Non-Subsistence Take of Wildlife, and Public Participation and Closure Procedures, on National Wildlife Refuges in Alaska (proposed rule),” would severely inhibit ADFG’s ability to engage in predator management practices that have historically been used to sustain populations of key big game species critical to subsistence users in Alaska.
Among the chief concerns expressed by the aforementioned parties are that the proposed FWS rules:
- Run counter to Congressional direction on fish and wildlife management authority given to FWS in both the Alaska National Interest Lands Conservation Act (ANILCA) and the National Wildlife Refuge System Improvement Act of 1997 (NWRSIA);
- Abridge wildlife management primacy given to the state of Alaska in both the Alaska Constitution and the federal Alaska Statehood Act;
- Constitute an arbitrary assertion that managing for “natural” diversity takes precedence over all other management considerations, despite the fact that no scientific justification for the rules was ever provided or demonstrated by FWS, and that humans are considered by ANILCA to be a natural part of the environment;
- Did not take into any real consideration feedback and concerns expressed by ADFG on the negative consequences that the proposed rules would have for scientific fish and wildlife management efforts in the state;
- Would almost certainly have a negative impact on populations of key big game species in Alaska, which constitute a critical component of the diet of the many subsistence-based users that reside in the state;
- If passed, would represent a dangerous precedent for federal overreach into the fish and wildlife management duties that have traditionally been carried out by state fish and wildlife agencies, the primary managers of fish and wildlife resources in the United States; and
- Run directly counter to the North American Model of Wildlife Conservation, the unique and hugely successful ethic that has guided fish and wildlife management in the United States for over a century by relying on science-based management efforts carried out by trained professionals.
“If adopted, these rules would constitute one of the most egregious examples of federal overreach into state management authority in recent memory. While the proposed rule targets Alaska specifically, there would be nothing stopping similar attempts to subvert scientifically-based fish and wildlife management efforts carried out by the respective fish and wildlife management agency for any other state in the U.S. CSF strongly urges FWS to heed the concerns raised by sportsmen’s groups, the Alaska Congressional Delegation and others to rescind or revise the proposed rules and engage in a truly collaborative process that involves real input from all stakeholders,” noted CSF President Jeff Crane.
The deadline for comments on the proposed rules was Thursday, April 7, after which time the FWS will review all submitted comments and determine whether they will alter the proposed rules. A hard date has not yet been established for when FWS may publish the revised rules.
Click here for a letter from the American Wildlife Conservation Partners (AWCP) on the proposed rules.
Click here to view CSF's letter responding to the FWS's proposed rules.
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