Our petition to halt trapping of Alexander Archipelago Wolves

165 of 170 Alexander Archipelago wolves were trapped on Prince of Wales Island - state says there’s “no emergency”

Wolf tracks, photo courtesy of AWA Advisory Committee member Bob Armstrong

Wolf tracks, photo courtesy of AWA Advisory Committee member Bob Armstrong

Prince of Wales island is home to Alexander Archipelago wolves, a genetically distinct wolf in southeast Alaska. Numbers of these wolves had dropped to just 89 animals in 2014, and after involvement of multiple wildlife groups and agencies, including Alaska Wildlife Alliance, the population rebounded to 170 wolves in 2018.

In 2019, the Alaska Department of Fish and Game (ADF&G) requested that the Board of Game authorize a new system for managing these wolves. Originally, trappers would seal the wolf pelts on the island within 14 days, and when the number of trapped wolves reached an unsustainable level, the agency would issue an emergency closure on the season. Under a new plan approved by the Board of Game in 2019, Fish and Game shifted to manage for a target population of 150-200 wolves. Under this new scheme, the wolf populations dictate trapping seasons as follows:

  • Wolf population is 0-100 : the season is closed

  • Wolf population is 101-135 : up to a 6 week season

  • Wolf population is 136-180 : up to a two-month season

  • Wolf population is greater than 180 wolves : up to a four-month season

In fall 2019, the wolf population was estimated around 170 wolves on Prince of Wales island. The agency opened a 2 month trapping season with no limit on the number of trappers and no limit on the number of wolves each trapper could kill. The agency also dropped the 14 day sealing requirement, instead authorizing that trappers only had to seal wolves within 30 days of the season closing date. To avoid overharvest, the agency asked trappers to “moderate their effort”.  

In short, ADF&G’s stance was to allow trappers to self-regulate their trapping effort. The agency had no way of knowing how many wolves were killed until 30 days after the season closed.

The results of this new management plan were devastating.

In March, the Department of Wildlife Conservation released a report confirming that 165 wolves were killed in the two month open season. Again, the Department’s population estimate of wolves was 170 wolves on Prince of Wales island with a possible range 147-202 wolves. Under the most optimistic estimates, that would leave just 37 wolves surviving after the most recent population estimate (not factoring in natural mortalities).

In August 2020 , Alaska Wildlife Alliance and Joel Bennett, under representation of attorney Joseph Geldhof filed a petition to close wolf hunting and trapping in Prince of Wales island by emergency regulation.

Wolf captured on a trail camera, photo by ADF&G

Wolf captured on a trail camera, photo by ADF&G

Basis for the Request

In essence, this petition for closure of wolf trapping and hunting is made because the most recent biological data available indicates that the present wolf population estimate in Game Management Unit 2 will not sustain any additional harvest, according to the Wolf Harvest Management Strategy (RC 011), and the principles of sustained yield management.

On March 20, 2020, Alaska Department of Fish & Game reported 165 wolves were killed from both hunting and trapping over a two-month season in Game Management Unit 2.  This kill rate nearly exceeded the most recent department population estimate of 170 wolves (establishment of the population figure of 170 wolves  was set by the department to be within a range of 147-200 wolves), believed to be living in relevant unit.  In addition, an unknown number of additional wolves killed in this geographical unit are not reported and are therefore not included in wolf kill total. As a result, to avoid overharvest and significant damage to the population of wolves in Game Management Unit 2, no additional harvest of wolves should be permitted in this unit for the foreseeable future.

The wolf population in Game Management Unit 2 is obviously perilously low based on available data from the Alaska Department of Fish & Game.  Even if additional 2019 wolf population data becomes available, it will be dated, gathered as it was before the high harvest of Fall/Winter 2019-2020, a culling that is problematic.  It is inconceivable that review of the wolf population data from 2019 (surveyed prior to the 2019-2020 harvest season), would indicate a population in excess of approximately 400 wolves within Game Management Unit 2, the only conceivable wolf population justification for allowing the massive wolf kill rate that took place in the Fall/Winter of 2019-2020.  Accordingly, given the known exceedingly high harvest rate last hunting and trapping season and the apparent lack of any data gathered after the 2019-2020 wolf trapping and hunting season for Game Management Unit 2, there is no basis for continuing the unsustainable killing of wolves in Game Management Unit 2.

In January 2019, the Alaska Board of Game endorsed the Alaska Department of Fish & Game’s revised harvest management plan, essentially replacing a harvest quota system with a harvest based on a population objective.  This new wolf harvest management regime was based on population thresholds calculated to trigger changes in season length.[1]  Based on this management plan and the implicit population objectives embedded in the plan pertaining to the lowest acceptable population threshold for maintain a viable wolf population in Game Management Unit 2, a population of less than 100 wolves in the unit is insufficient to support an additional wolf harvest in the 2020-2021 trapping and hunting season.  Under the wolf management plan adopted by the Alaska Board of Game and binding on the Alaska Department of Fish & Game, no further wolf harvest in Game Management Unit 2 is possible for the foreseeable future.  As a consequence of the very high harvest rate of wolves in Game Management Unit 2 and given the obvious application of the criteria in the strategy in RC 011, an emergency closure of wolf hunting and trapping in the impacted unit must be adopted.

It should also be noted that before the high harvest  last season triggered this need for emergency action, the wolf population on Prince of Wales Island and the associated nearby islands in Game Management Unit 2 were already under considerable stress. The wolves in Game Management Unit 2 are an isolated population with little or no immigration and subject to large-scale habitat alteration through logging and associated road construction. Hunters and trappers seeking to harvest wolves in this unit have benefited from increased access by using the network of roads constructed for timber access as well as by boat along the shoreline.  Finally, insufficient genetic diversity through inbreeding is an additional concern with the extremely low wolf population in GMU 2.

This petition is being submitted because there is no Board of Game meeting scheduled before the 2020-21 wolf hunting and trapping season begins.  As a result, there is no obvious way to submit a proposal for a regulation change during the normal board process. Without an emergency closure, a Fall/Winter 2020-21 hunting and trapping season will commence well before the next scheduled Board of Game meeting which is scheduled to begin on January 21, 2021.

Unless the hunting and trapping season is closed for 2020-2021 for Game Management Unit 2, the wolf population in this unit which is already precipitously diminished and almost certainly significantly below the threshold levels mandated by the current management regime will be further reduced, placing the wolf population in Game Management Unit 2 in extreme danger, a course of action that deviates from constitutional mandates and inconsistent with sensible game management standards.

The State’s Reply

On September 8, Commissioner of Alaska Dept of Fish and Game Doug Vincent Lang issued a response stating, ”The purpose of this letter is to relay my decision that we cannot find an emergency at this time.”

The agency’s stance is to wait for the fall 2019 population data to be released, which will inform how many wolves were on the island before the season that took at least 165 wolves from the population.

Alaska Wildlife Alliance is continuing to seek relief for these wolves and track the population estimate reports. We will update members on the this issue as soon as the data are released.

How you can help

Email ADF&G Commissioner Doug Vincent-Lang at douglas.vincent-lang@alaska.gov to voice your concerns about Prince of Wales wolves and encourage the Department to close the upcoming season.


Thank you to the members who make this work possible. Help us secure protections for Alexander Archipelago wolves and other Alaskan species by becoming a member for as little as $35/year.