Our public comments on 2019 Southcentral BOG Proposals

The Alaska Wildlife Alliance believes it’s important for our organization and members to take part in the wildlife management decisions in the state. The 2019 Board of Game meeting for Southcentral Alaska was held from March 14th-19th, and the Alaska Wildlife Alliance submitted public comments on four proposals.

To see all the proposals, click here.

To read all the submitted public comments, click here.

Proposal 75, proposed by the Homer Fish and Game Advisory Committee

Background: Hunting seasons and bag limits for moose. Open an archery and muzzleloader permit hunt for moose Unit 15C as follows: One moose by permit only. The harvest of cows with calves is prohibited. Up to 50 archery permits and up to 50 muzzleloader permits may be issued. No more than 10% the permits may be allocated to nonresident hunters. All applicants must hold a hunter education certification, bow hunter applicants must hold a bow hunter certification and muzzle loader applicants must hold a muzzle loader certification.

moose alaska wildlife alliance board of game

What is the issue this proposal will address and why?
To provide additional opportunity to harvest moose in Unit 15C using archery and muzzle loaders. There is currently a harvestable surplus of moose in Unit 15C that is being underutilized. Unit 15C is an intensive management area and the current intensive management harvest objectives are not being met. If nothing is done, we will continue to miss out on the opportunity to harvest moose and intensive management objectives will continue to go unmet. In addition, if the population continues to grow, we run the risk of over-browsing our habitat, which would lead to a population decline and reduced hunter opportunity in this unit.

The Alaska Wildlife Association supports proposal 75.

We are in favor of carefully controlled, soundly managed draw hunts that would increase hunting opportunity and address the problem of the overpopulation of moose in area 15 C. This proposal would provide local hunters with a quality hunt that meets management objectives.

Proposal 92, proposed by Kenai/Soldotna Fish and Game Advisory Committee

Background: Open a hunting season for tundra swan in Units 7 and 15 as follows: Allowing a harvest of tundra swans within conservation guidelines may be warranted. Maybe a season from October 1 – December 16. Some opportunity should be allowed if no conservation concerns exist. We look forward to a new hunting opportunity on the Kenai Peninsula. While not our preferred option, a registration permit would be an option.

What is the issue the proposal will address and why?

There seems to be an abundance of tundra swans in Alaska. There are open seasons for tundra swans in Alaska and other states. If there is not a conservation concern, we would like to see some harvest opportunities.

Photo by Janet Pierce

Photo by Janet Pierce

Alaska Wildlife Alliance is opposed to proposal 92.

 There is certainly not an overabundance of Tundra Swans in the Kenai Peninsula. In fact, it would be very rare to see one at all. Their migratory patterns take them much more Inland than their Coastal relatives, the Trumpeter Swans.

Tundra and Trumpeter Swan Ranges:
Red is breeding range
Gray is migration route
Blue is wintering range
Source: Audubon Field Guide


Trumpeter Swan Range

Trumpeter Swan Range

Tundra Swan Range

Tundra Swan Range

It is very difficult to tell the difference between a Trumpeter Swan and a Tundra Swan with a casual observation. In fact, many birders express difficulty telling the two species apart.

 It makes no sense to open a season on a species of bird that is rarely on the Kenai Peninsula. it would be even worse to open a season that would almost guarantee that the wrong species of swans were taken by people hunting. The most likely result of this proposal being passed would be that an inordinate number of protected Trumpeter Swans would be taken.

Proposal 89, proposed by Jim Van Oss

Background: Furbearer trapping. Close the trapping season for beaver in an area of Units 7 and 15C as follows: 5 AAC 84.270(1) Beaver, Units 7 and 15. Beaver trapping in the headwaters of the south fork of the Anchor River starting at the fork in T4S R12W section 19. No open season.

What is the issue the proposal will address and why?

otter alaska wildlife alliance board of game

Beaver are currently absent from the headwaters of the south fork of the Anchor River Drainage. Evidence of historic beaver activity is present in this area, including old dams and lodges. Trapping records indicate that beaver were present in this system as recently as 2006 and well established in the late 1990s. The loss of beaver from this area has decreased the overall wildlife habitat quality and has reduced trapping opportunity due to lack of animals. Beaver are a keystone species that alter their environment, providing habitat for other species such as moose, songbirds, waterfowl, and salmon rearing. Beavers increase water table levels and nutrient deposition that increases forage values. This area is void of potential for human wildlife conflicts due to beaver activity as no roads, agriculture or other man-made activities exist in the proposed area. I propose that the headwaters of the south fork of the Anchor River Drainage be closed to beaver trapping to allow the reestablishment of beaver to this area. If this area is not closed to trapping, the area will remain void of beaver and habitat benefits will be lost. Alternatively, I have requested that the Department of Fish and Game relocate beavers to this watershed, but this is unlikely to be successful without a trapping closure, as any animals that are relocated have a high probability of being trapped before becoming established.

The Alaska Wildlife Alliance supports proposal number 89.

The Homer advisory commission has stated that there appears to be almost complete extirpation of beavers in the upper anchor River drainage.It would make sense therefore to limit further trapping of these animals until their population can rebound. Robbing an ecosystem of its natural diversity is almost universally detrimental to all species in the ecosystem. Beavers play an important role in the health and vitality of the Upper Anchor River ecosystem.

 Beaver dams and the associated ponds can provide nurseries for salmon and trout.  An early indication of this was seen following the 1818 agreement between the British government of Canada and the government of America allowing Americans access to the Columbia watershed. The Hudson's Bay Company, in a fit of pique, instructed its trappers to extirpate the fur-bearing animals in the area. The beaver was the first to be made locally extinct. Salmon runs fell precipitously in the following years, even though none of the factors associated with the decline of salmon runs were extant at that time.

There are several reasons why beaver dams increase salmon runs. They produce ponds that are deep enough for juvenile salmon to hide from predatory wading birds. They trap nutrients in their ecology and notably the huge nutrient pulse represented by the migration of the adult salmon upstream. These nutrients help feed the juveniles after the yolk sac has been digested. The dams provide calm water which means that the young salmon can use energy for growth rather than for fighting currents; larger smolts with a food reserve have a better rate of survival when they reach the sea. Finally, beaver dams keep the water clear which favors all salmonoids.

We also note that beavers occur in the lower anchor river system and on many of the other small rivers on the Kenai Peninsula that have sustainable salmon runs.

We believe that good scientific management of Wildlife consists of restricting or ending a season when numbers of that wild life become too low. this seems to be the case in the upper anchor River beavers.

Proposal 74, proposed by the Homer Fish and Game Advisory Committee (EG-F18-044)

Background: Hunting seasons and bag limits for moose. Open a resident drawing hunt for moose in Unit 15C as follows: Unit 15C, Resident Hunters: 1 antlered bull, by drawing permit only; up to 200 permits may be issued. This number was arrived at by adding the 142 moose current harvest average plus 160 (200 draw permits at a conservatively high success rate of 80%) equals 302 moose, squarely within the harvest objective of 200–350. This hypothetical calculation includes the entire harvest structure.

What is the issue the proposal will address and why?
Provide additional harvest opportunity due to high moose population in Unit 15C. Currently, Unit 15C is above the intensive management (IM) population objective, far below IM harvest objective, and the bull:cow ratio is very high; substantial opportunity is thus being underutilized. There is adequate room to add 200 “any antlered bull” draw permits, and these would work well alongside current selective harvest strategy (SHS) regulations to balance the herd and provide prime opportunity in a high use area.

  • The latest point estimate as of this writing for moose in Unit 15C shows a population of 3,529; above the IM objective of 2500–3500.

  • Last five years harvest average is 142 moose; well below harvest objective for Unit 15C of 200–350 moose. Of those 142, 27 were cows taken under DM549 and 118 were general season bulls. Hunters are excited about seeing many bulls but frustrated because most don’t meet the current requirement of spike, 50-inch, or four brow tines.

  • Bull:cow ratios have increased steadily from 19 to 55 bulls per 100 cows in the last five years, with total moose remaining roughly constant or increasing. An adequate and sustainable ratio is normally considered to range about 25–30 bulls per 100 cows; about half of Unit 15C’s current ratio of 55:100 cows. One bull can service dozens of cows.

  • Current regulatory hunt structure in Unit 15C consists of spike/50-inch or four brow tines for the general bull hunt, along with DM549 antlerless hunt (25–30 cows taken annually) and the targeted hunt (yet to be authorized) for highway corridor during heavy snow years. We appear to have a substantial number of additional bulls available for harvest. High bull:cow ratios can lead to stressed moose populations as more bulls than necessary for the herd’s productivity compete for browse and habitat with the future of the herd: the cows and calves. Nutritional stress, while truly a factor of population, may also be exemplified by percent calves (last five years high 20, currently 11) and lower twinning rate. Additionally, for the bulls, mating stress and less nutrition on a per-animal basis may produce less antler growth, which puts more mid-size “illegal class” bulls in the population, compounding the situation of too many bulls competing for browse and perhaps also exacerbating illegal take with its inherent enforcement, prosecution and regulation costs. Longer term nutritional stress may play out in genetics. The Unit 15C moose population is over objective yet the harvest is less than half of its objective. This prime freezer-filling opportunity should be utilized to provide maximum benefit to hunters.

    The proposers believe that the population will respond favorably, we will stay within harvest objectives, and hunters will be happy with a better chance at winter meat if we offer up to (at Department of Fish and Game (ADF&G) discretion) 200 “any antlered bull” permits by drawing in addition to the existing hunt structure. Other solutions were considered to add opportunity and bring down the bull to cow ratio: A registration “any bull” hunt would be more difficult for ADF&G to manage in-season and make Alaska Wildlife Trooper enforcement more complicated. It would surely necessitate small window “hunt periods;” these are undesirable due to traditional family camp activity and also to ethical moose harvesting weather, which is spotty at best in the warm maritime climate of Unit 15C. A return to more liberal selective harvest strategy (SHS) antler restrictions (add forked antler and reduce to 3 brow tines/50-inch) was rejected due to overly adequate bull:100 cow ratio (indeed, the SHS may be working TOO well). Removal of the existing cow hunt makes some mathematical sense with respect to sex ratio, but removed from consideration due to popularity, low harvest (25–30 cows/ year), and is only a very small portion of Unit 15C in suburban Homer. Changing the entire general harvest ticket hunt to allow “any antlered bull” would be too liberal, resulting in heavy localized overharvest even if the season is drastically shortened (undesirable again due to weather and loss of opportunity to hunt). Concerns of nonlocal competition in the draw (which is lawful) have merit, but we don’t think a big factor with other “any bull” hunt opportunities elsewhere around the road system offering enticement to traveling hunters. Additional prime moose harvest opportunity can be safely implemented in Unit 15C by adopting this proposal adding up to 200 “any antlered bull” draw permits to the existing harvest structure. This will bring the harvest up closer to objective, bring down the bull:cow ratio, help the overall health of the herd and put an additional hundred thousand pounds of meat in Alaskans’ freezers. Thank you for your thoughtful consideration of this proposal.

Alaska Wildlife Alliance supports proposal 74.

We feel that this proposal would add an outstanding hunting opportunity on the Kenai Peninsula for local hunters. Too often the hunting on the Kenai Peninsula is overcrowded and is statistically very unlikely to be successful. Therefore peninsula hunters frequently have to travel long distances, often at great expense and effort to find some place where they can get a quality hunting experience. Providing a draw season for local hunters would be of tremendous value to those who live on the Kenai Peninsula.

 We feel this is biologically sound in that the moose population is currently above the objectives yet the harvest numbers are below objectives. This would obviously solve both of those problems.

We are worried that if the moose population continues to exceed the carrying capacity, habitat damage could cause long-term detriment to the moose population. This very sound proposal for reducing the moose overpopulation and increasing harvest makes very good sense.

All comments submitted by Ed Schmitt, Board President, on behalf of the Alaska Wildlife Alliance.