We vigorously opposed unethical hunting methods on Alaska’s National Preserves in 2015, and won. Now, under orders from the Trump administration, the National Park Service has proposed a rule to undo that success and remove certain wildlife protections for bears, wolves, coyotes, and caribou.
Department of the Interior Secretary Ryan Zinke directed the review – and proposed reversal – of the National Park Service’s 2015 rule which we fought so hard to support. Based on input from more than two dozen public hearings and over 70,000 public comments, support for the ban was overwhelming. Now we need your support again to maintain that rule to protect wildlife on preserve lands.
What is the proposed rule change?
On October 23, 2015, the National Park Service (NPS) published a final rule (Final Rule) to amend its regulations for sport hunting and trapping in national preserves in Alaska (80 FR 64325). The Final Rule codified prohibitions on certain types of harvest practices that are otherwise permitted by the State of Alaska’s hunting regulations found at 5 AAC Part 85.
The 2015 Final Rule banned the following practices on National Preserves in Alaska:
Taking any black bear, including cubs and sows with cubs, with artificial light at den sites;
Harvesting brown bears over bait;
Taking wolves and coyotes (including pups) during the denning season (between May 1 and August 9);
Taking swimming caribou;
Taking caribou from motorboats under power;
Taking black bears over bait;
Using dogs to hunt black bears.
The 2015 Final Rule prohibited these hunting practices because the NPS found those practices:
(1) To have intent or potential to alter or manipulate natural predator-prey dynamics, and associated natural ecological processes for the purpose of increasing harvest of ungulates by man;
(2) to adversely impact public safety; or
(3) to be inconsistent with federal law authorizing sport hunting in national preserves in Alaska.
In addition, NPS has broad discretion in managing wildlife on national preserves under applicable laws, policies, and regulations.
On September 15, 2017, Secretary Zinke signed Secretarial Order 3356 to overturn the 2015 rule and permit the killing practices listed above. If the rule change is passed, Alaska’s wildlife will suffer. We need your help.
What can you do?
The Department of Interior has extended the public comment period until November 5th for both the proposed rule change and the environmental assessment regarding sport hunting and trapping on National Preserves in Alaska. You can submit the same comment through both portals, doubling your impact.
Please note: There is no direct email address to submit comments. Comments are accepted only via the above link, or by hand or mail addressed to:
National Park Service
240 West 5th Ave.
Anchorage, AK 99501
For the proposed rule change: ATTN: Regional Director, Alaska Regional Office, RIN 1024-AE38
For the Environmental Assessment: ATTN: Sport Hunting and Trapping in National Preserves EA- Alaska Regional Office, EPC
What are some examples of effective comments?
“I urge you not to adopt the proposed rule regarding recreational hunting on Alaskan federal preserves. The existing National Park Service rule considered strong public input opposing the extreme hunting practices at issue. The National Park Services process rightly concluded these hunting practices have adverse impacts on public safety, are inconsistent with federal law and potentially alter natural predator-prey dynamics for the purpose of increasing sport harvests.
The Department of Interiors new proposed rule to abandon these protections for Alaskan wildlife on Alaskan federal preserves would sacrifice the health of publicly owned lands and wildlife populations for the benefit of a small group of extreme sport hunters.
I urge the Department of Interior not to finalize the proposed rule revoking regulations on hunting practices in Alaskan federal preserves, and to instead retain existing rules properly considering the interest of all Americans. Thank you for considering my comments.”
“As one of 1.3 million members and supporters of the National Parks Conservation Association, I strongly oppose the National Park Service’s attempt to roll back 2015 clarifications of existing park authority to protect bears and wolves on Alaska national preserves. Extreme sport hunting methods, like brown bear baiting and killing hibernating black bear mothers and cubs in dens, don’t belong on national preserves in Alaska.
National parks and preserves in Alaska were set aside by Congress as special places where bears, wolves and other wildlife roam as part of a natural ecosystem. This is why I oppose the National Park Service’s proposal to allow extreme hunting practices.
I urge you to protect our last, best chance to make sure our children inherit a world with wild spaces and wildlife. Thank you.”
What makes a good comment?
When commenting on proposed Federal rulemaking actions, there are misconceptions that reduce the effectiveness of one’s submission. To try and help you have the most effective impact when voicing your perspectives to a Federal agency during a public comment period, below we have provided some helpful tips and links.
It is not a popularity contest.
A form letter signed by thousands of people is often only considered as one comment. Consider submitting comments in your own words instead of, or addition to, signing form letters.
It doesn’t really matter how many people said they support or don’t support the proposed action, what matters is the extent of the substantive comments received during the public comment period.
Submit “substantive” comments.
According to the 2015 National Park Service’s NEPA Handbook, “substantive” comments:
question, with reasonable basis, the accuracy of the information in the document;
question, with reasonable basis, the adequacy of the environmental analysis;
present reasonable alternatives other than those presented in the document; or
cause changes or revisions in the proposal.
Any comments deemed “non-substantive” are in danger of not being included in any additional analyses, and thus will not influence a decision. They essentially may be dismissed.
Help them help you.
When crafting your comments, be respectful and try recognize the constraints of the agency’s authority and provide the tools and information necessary to for them to fight for your perspective.
When trying to influence the Federal rulemaking process, facts and data are your friend. Any evidence you can provide to support your statements are helpful.
When preparing your written comments, make sure your main points are easy to find and stand out, otherwise they may be missed if the reviewer only has time for a quick scan.
There are numerous resources available to help you understand the Federal rulemaking process and how to write more effective public comments. Here are a couple we think are useful.
Gov – Frequently Asked Questions (about the rulemaking process and commenting via regulations.gov)
Public Participation in Environmental Decision-Making: Step-by-Step Tips for Writing Effective Public Comments (by the Environmental Law Institute)