Board of Game Passes Consecutive Trophy Brown Bear Season on Alaska Peninsula

On June 3rd the Alaska Board of Game authorized an unprecedented consecutive Spring trophy hunt on Alaska Peninsula brown bears, despite public concern for impacts on the bear population.

Though closed to oral testimony, 31 people submitted written comments in opposition to the proposal, and 32 wrote in support. Thank you to all our members and supporters who spoke up for Alaska Peninsula bears and commented before June 3rd!

Trophy brown bear hunting on the Alaska Peninsula (Game Unit 9/GMU 9) occurs for both Alaska residents and nonresidents in the spring and fall, but in alternating years (spring season in even years; fall season in odd years). This alternating cycle of hunting seasons has been in effect regionally since 1976 after managers found that two hunting seasons per year wasn’t sustainable for the bear population. For over 45 years, the bear population has not been robust enough to handle consecutive trophy seasons.

Alaska Peninsula Bear Hunting trip priced at $29,500 | Worldwide Trophy Adventures

Alaska Peninsula Bear Hunting trip priced at $29,500 | Worldwide Trophy Adventures

At the Alaska State Board of Game (Board) meeting on June 3rd, the Board considered their own proposal to open an additional spring 2021 bear hunt on the Alaska Peninsula. In the recorded meeting summary, Board of Game members said that proposals discussed at the meeting “explore[d] ways to recoup hunter opportunity lost due to the restrictions and closures imposed to protect public health and safety during the worldwide Covid-19 pandemic.” The Board also passed a proposal to roll over hunts into future years.

“The registration and drawing permits that could not be used in spring 2020 represent some of the most highly coveted bear hunts in the state, and many hunters try for years to obtain those permits and participate in those hunts. By developing alternative solutions to allow them another chance to fulfill their hunting plans and dreams, there will also be the ancillary benefit of providing economic opportunity for guide/outfitters, transporters, air-taxis, and many other small businesses that support hunters and who were also adversely impacted by Covid-19 response actions. By doing that equitably and without adversely impacting the wildlife populations, we will be fulfilling our Constitutional mandate of conservation, utilization, and development of game resources “for the maximum benefit of the people.”

Alaska Board of Game members | Alaska Dept. of Fish and Game

Alaska Board of Game members | Alaska Dept. of Fish and Game

The proposal adds a resident spring 2021 Spring hunt with the same season dates as spring 2020 hunts. Hunters who participated in Spring 2020 hunt are not eligible for a permit in spring 2021. For nonresidents, the proposal adds a spring 2021 hunt with the same season dates as spring 2020 hunts.  This proposal does not change the annual resident hunt near villages and subsistence registration hunt.

Alaska Wildlife Alliance has serious concerns about this additional Spring 2021 season, which legalizes unprecedented consecutive trophy brown bears seasons (Spring 2021, Fall 2021, Spring 2020) on the Alaska Peninsula. Contrary to the Board statement that this proposal manages wildlife for the “maximum benefit of the people”, we believe this proposal manages for the maximum benefit of trophy hunters and guides, and puts the Alaska Peninsula brown bear population at unnecessary risk.

Unintended consequences

The State’s Big Game Commercial Services Board (BGCSB) commented in concern of the proposal’s unintended consequences. “While it is clearly the intent of the proposals to allow in 2021 for lost opportunity in the 2020 season,” wrote the Chairman of the GBCSB, “…some within the guiding industry could view this as a unique and “extra” opportunity to guide / operate in GMU 9 in the Spring of 2021 when they had not previously, in the Spring of 2020, intended to do so; there could be a “bear rush” (akin to a land grab) and influx of guides trying to operate in GMU 9 in the spring of 2021.”

The BGCSB also vocalized concerns about potential for guides that had planned to operate in GMU 9 in the Spring of 2020 to potentially “double dip” and contract more hunters in 2021 than they would have in 2020.

From these concerns, the Big Game Commercial Services Board passed their own proposal to reduce guide participation in any season the Board of Game allows in 2021. This proposal would “probably be expedited” to be in effect next year (Van Daele, 50:25).

Given the uncertainty of the Big Game Commercial Services Board proposal roll out, the Board of Game made an attempt to avoid hunter “double-dipping”. Member Hoffman proposed an amendment to exclude residents who traveled to the Alaska Peninsula to hunt in Spring 2021. The amendment passed, but ADF&G Commissioner Doug Vincent-Lang was clear that the department would not enforce the amendment on the ground.

“I want to make sure you guys understand we will not be investigating individual hunters as to whether or not they hunted [in Spring 2020], “ said Vincent-Lang, “…there won’t be any investigative assessment(Vincent-Lang, 1:08:12).

If the bear population is impacted, which is likely given the biological data, the impacts to other industries utilizing GMU 9 (e.g., bear viewers, sport fishing operations that sell bear viewing as part of the experience) would be immense. Not only are these other groups also suffering due to a drop in tourism this year, but could suffer dramatically in the future should the bear population decline. These bears are extremely famous, both in hunting and viewing arenas, and impacts to all wildlife users should be taken into consideration for this decision.

Bear 435, aka "Holly," before and after her prehibernation weigh-in. Holly went on to win the final round in Fat Bear Week 2019. Katmai National Park & Preserve.

Bear 435, aka "Holly," before and after her prehibernation weigh-in. Holly went on to win the final round in Fat Bear Week 2019. Katmai National Park & Preserve.

The number of Brown bears killed in the Spring 2020 hunt is more than ADF&G predicted

Before the meeting, ADF&G submitted agency comments on the proposal that predicted 15–20 bears would be trophy hunted in the Spring 2020 season.

 “Social factors will substantially reduce resident hunter participation in the spring 2020 season,” ADF&G stated. “Travel restrictions may still be in place for resident hunters, who are mandated to avoid travelling to remote communities.”

However, one week later at the Board of Game meeting, the ADF&G Unit 9 biologist reported that hunting efforts were double what was predicted. 38 bears have been killed so far this year, despite the spring ban on resident travel. That’s almost double the agency’s prediction, and a higher kill tally than the average spring resident hunt (~37 bears).  

ADF&G underestimated the number of trophy hunted bears on the Alaska Peninsula and continued to regard the Spring 2020 hunt as “a wash”, despite the fact that the resident season was above average.

ADF&G claimed there would be no biological concerns, despite lacking population survey data and population concerns in 2018

The agency reported that “this onetime additional spring harvest will have little effect, if any, on the Unit 9 bear population.” But just two years ago ADF&G testified that the bear population was not robust enough to handle the existing alternating seasons.

At the 2018 Board of Game meeting in Dillingham, ADF&G’s bear biologist for the region expressed concerns that the population of brown bears on the Alaska Peninsula had been declining since the 2000s. From 2013-2017, he received numerous reports from area scientists, long-term guides, and the public asking, in his words, “Where’s the bears?” When the Board considered adding consecutive resident-only hunts in 2018, Unit 9 biologist stated that agency could not support consecutive hunts, even if they were restricted to residents.

Sow with mixed-aged cubs rest at the mouth of the Brooks River | NPS/M. Fitz

Sow with mixed-aged cubs rest at the mouth of the Brooks River | NPS/M. Fitz

ADF&G biologists also testified that they believed an entire cohort (age class) of young bears was lost, likely due to a longer spring hunt in 2013, failed berry crops in 2013-15, and severe weather events in winter 2011/2012 and 2012/2013. This loss, according to the agency, was in addition to the long-term decline in bear numbers.  ADF&G was concerned that hunters are “mining out the last of the big adults”; “we’ve seen fewer large bears on the landscape,” testified the ADF&G Unit 9 biologist (Crowley, 8:58).

And yet, ADF&G’s comments on the new proposal made no mention of the cohort loss or population decline they testified on only two years ago.

The agency claimed that the age structure has returned to normal, based solely on fall 2019 hunt statistics for male skull size. One “normal” year for one sex does not equate to a balanced age structure across the population, especially when looking at decadal trends.

ADF&G’s comments on the proposal also only provided information about the spring season, but an accurate assessment of impacts of an additional hunt must look at the full picture. For example, in fall 2019, when the season was reduced to 2-weeks instead of the normal 3-weeks, a total of 192 bears were killed – 30 more bears than during the longer fall 2017 season; a 15% increase. This means that in the last year, hunting pressure on these bears already increased, even without an extra spring hunting season.

No one knows how many bears are on the Alaska Peninsula

Alaska Wildlife Alliance asked ADF&G about the annual rate of bear decline they referenced in 2018;  understanding population trends is imperative to making biologically-sound management decisions, and knowing this information in 10-year horizons is standard practice in wildlife management. We were shocked when on May 26, 2020 they responded:

Unknown. Bear populations fluctuate like other wildlife populations, but are difficult and very expensive to monitor like we do for ungulate populations.” 

alaska GMU 9

Surprisingly, ADF&G has not surveyed the population of brown bears in GMU 9 for 15-30+ years, depending upon subunit. We asked for agency reports on abundance and trends:

  • Unit 9A, last surveyed in 1991: 213 bears (Sellers and Miller, 1991)

  • Unit 9B is unknown. Only northern Unit 9B was surveyed in 1999–2000: 645 bears. (Becker, 1999-2000)

  • Unit 9C, including Katmai National Park and Preserve, last surveyed in 2004-2005: 1,951 bears (Becker, internal report)

  • Unit 9D, last surveyed in 2002: 1,683 bears (Becker and Crowley in prep)

This totals 7,751 bears. However, the most recent subunit survey was 15 years ago, and the only survey data for 9A and 9E is 29 years old.

ADF&G continues to claim there are “up to 8,000 bears” on the Alaska Peninsula based on extrapolations from data collected from prior to 1991 through 2005, despite some of their other reports suggesting the estimate is too high.  The agency also says they have no plans to conduct any abundance surveys in the foreseeable future.

So, how can ADF&G manage bear populations? Harvest data. Making management decisions on how many bears to kill based on how many bears were killed.

Board member Larry Van Daele in 2018 remarked that “harvest data is imperfect data,” which requires managers to rely heavily on what people tell them. But, in response to concerns about the reported cohort loss, Van Daele said, “if we are managing for big bears, we are seeing all the signs that we need to reduce harvest”… “Harvest is the only tool we have to manage this” (Van Daele, 7:40).

And yet, Board member Al Barrette echoed his fellow Board members in approving this hunt because there was, from their perspective, an “unused harvestable surplus” (Barrette, 2:27), despite having no population survey data, a lost cohort of young bears, and a full resident trophy season this spring.

Few remedies to ensure too many bears aren’t killed

At the June 3rd meeting, Board member Larry Van Daele asked ADF&G to “be on their toes” to track bear kills and consider emergency closures if killing exceeds 75% of the five-year average.

“We may get a greater cumulative harvest than we would if we had one season,” Van Daele said, before voting to approve the proposal. “If the Big Game Commercial Services Board does not pass this regulation and there is a guide rush, we need to have a fallback position conservation wise.” Van Daele, 2:23

But emergency closures are known to be ineffective in the region. Again at the 2018 Board of Game meeting, Unit 9 biologist said that closing hunts by emergency order is not feasible in the region because hunters spend a lot of money to get there, and once they’re there, the area is too vast to get the word out (Crowley, 8:32). In short, managers won’t have much time or resources to stop excessive bear kills once they’ve identified a biological concern.

Bear at Brooks Falls | Russ Taylor, National Park Service. 

Bear at Brooks Falls | Russ Taylor, National Park Service.

Alaska Wildlife Alliance is very concerned about the additional spring hunting season in 2021 for what appears to be solely for the purposes of providing benefits to a single user group. This change would result in 3 back-to-back hunts, which hasn’t occurred since the 1970s because multiple seasons per year result in known overharvest. This is a brown bear population with an outdated abundance estimate, that is experiencing a long-term decline — including an entire lost cohort— for which a disproportionately large number of adults are killed over the past decade.

Alaska Wildlife Alliance believes the Board of Game should not make regulatory decisions based upon economic benefits to one user group, but rather should make decisions on sound science and future sustainability of wildlife for all user groups and the bears themselves. We have submitted a Public Records Act request to ADF&G and the Board of Game to obtain records related to the origin of this proposal, and will investigate the extent to which biological concerns were considered within the agency and the Board of Game. Stay updated through our online newsletter, follow us on Facebook, or check our website for information.

If you work, live, or travel frequently to the Alaska Peninsula and notice a change in the bear population, immediately inform Alaska Department of Fish and Game at (907) 746-6300.

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