The National Park Service (NPS) has a new rule out for public comment governing hunting on the 19 million acres of National Preserves in Alaska, including over eight million acres of designated Wilderness. This new rule would overturn a similar rule promulgated during the Trump administration, which Wilderness Watch and several allies have challenged in court. While the new rule is generally good, we believe it can be improved. Please speak up by March 27. The 1980 Alaska National Interest Lands Conservation Act (ANILCA) established the National Preserves in Alaska. These areas are administered by the NPS like the National Parks, except for allowing hunting and trapping. The NPS rightly banned controversial hunting practices on National Preserves in 2015, codifying into law its longstanding position that killing predators to increase prey populations violates its mandate to protect our National Preserves in all of their diversity. But, Trump’s Interior Department rolled back the NPS’s protective rule with its own rule in May 2020, which defers to state regulation that allows many egregious hunting practices: • Killing mother bears and cubs in their dens;
• Baiting brown and black bears with human food;
• Killing wolves and coyotes with pups during their denning season;
• Shooting caribou from boats or shore as they cross lakes or rivers;
• Expansive trapping practices; and
• Using dogs to hunt bears. The new proposed rule would overturn these cruel practices approved by the Trump administration as well as prohibit predator killing (“control” or “reduction”) aimed at increasing the number of prey species on the National Preserves. The proposed rule also limits trapping to only taking furbearers with a trap under a trapping license (as opposed to, for example, shooting furbearers), and prohibits trapping of any bear or ungulate species. The rule is good and deserves support, but needs to be fine-tuned and strengthened in the following ways: • The proposed rule exempts “subsistence uses by local rural residents....” Wilderness Watch appreciates and respects the rights of indigenous Alaskans to engage in traditional subsistence activities in National Preserves. However, Alaska is a large and varied landscape with a great diversity of indigenous cultures and practices. What was a traditional activity practiced by a Native community in one region was not necessarily a tradition in another. Thus, exceptions applied to subsistence uses should be tailored to each conservation unit or region, where such practices had traditionally and historically occurred by local rural Native hunters. • The NPS’s determination that hunting wolves and coyotes during the denning season, bear baiting, hunting bears with artificial lights at den sites, bear snaring, and using dogs to hunt big game are all inconsistent with its management policies and should be precluded for those hunting for sport purposes—regardless of whether the State achieves its goal of artificially depressing predator populations to increase prey populations. For example, the only purpose of killing wolves and coyotes during the denning season is to reduce predator populations. During this time, their pelts have little trophy, economic, or subsistence value. The NPS’s proposal to prohibit wolf and coyote killing from May 1 through August 9 should instead start well before denning season, and extend from early March through early August. The only justification for allowing wolf hunting during this period is population reduction, which is prohibited on National Preserves. • The determination for what qualifies as “subsistence uses” should use the federal definition found in ANILCA, not the more lax definition used by the State of Alaska. Please take action by March 27! | 
