Battling Barbaric Practices At Kenai National Wildlife Refuge

Alaska's Kenai National Wildlife Refuge has weathered a lot of storms since it was created in 1941 as the Kenai National Moose Range. Its two million acres of forests and wetlands Anchorage is regularly wracked by cataclysms that dwarf lower 48 events. When the 2019 Swan Lake Fire burned 168,00 acres, an area larger than El Paso, it triggered muscle memories in firefighters who quelled the 200,000 acre Funny River Fire five years earlier. Wildfires threaten humans but their regenerative benefits for wildlife are indisputable. The same can't be said of political storms.

In the 1980s with James Watt as Secretary of the Interior, Kenai Refuge survived a hostile takeover by the Alaska Board of Game (BOG) which makes state hunting regulations and the Alaska Department of Fish & Game (ADFG) which implements them. Kenai Refuge's parent, the U.S. Fish & Wildlife Service (FWS) eventually ceded to demands and the Refuge adopted a State regulation that allowed hunters to shoot black bears over bait.  Thirty-five years later, Alaska Governor Mike Dunleavy is trying to leverage his relationship with the Trump administration and the outsized influence of Alaska's small congressional delegation for another hostile takeover.  Now ADFG wants to expand bear baiting to killing brown bears at smelly "bait stations" of old fruit, donuts, dog food, and garbage within Kenai Refuge. The State also wants the Refuge to remove conditions on trapping permits that made trapping compatible with Refuge purposes.

In the 1990s Kenai Peninsula brown bears were classified as a "population of special concern," a relatively small population geographically isolated on a virtual island and genetically distinct from mainland bears. From 1997 until 2012 hunting of Kenai brown bears was conservatively regulated with smaller harvests. But the State's philosophy changed dramatically and killing brown bears is now seen by BOG/ADFG as reducing moose predation and human conflicts while increasing hunting opportunity.

ADFG has long-coveted Kenai Refuge. Two-hours outside Anchorage, Kenai is Alaska's most popular Refuge.  Its hundreds of miles of hiking and canoe trails, campgrounds, and wilderness cabins complement a wildlife ensemble for a million visitors annually, including thousands of Alaskans. They fill their freezers with salmon in summer and moose in the fall. Hunting, fishing and trapping licensees are ADFG's constituency. Their misguided math says the fewer predators the happier their base. Yet a statewide poll in 2018 showed most Alaskans oppose killing female black bears and cubs in their dens, using bait stations to kill bears, and killing wolves, coyotes and pups in dens.  Some of these practices were once illegal in Alaska. But a 1994 Intensive Management Law directs BOG to identify moose and caribou populations to be managed for high human harvest and ADFG to develop regulations to maximize hunting opportunities. 

ADFG has always rejected the 1980 Alaska National Interest Lands Conservation Act (ANILCA), the legal backbone that supports Alaska's 16 national wildlife refuges purpose 'to conserve fish and wildlife populations and habitats in their natural diversity. . ." FWS has reiterated both the letter and spirit of ANILCA. In 1982 ADFG and FWS agreed to a Memorandum of Understanding (MOU) wherein ADFG recognized FWS' authority "to manage fish and resident wildlife populations in their natural species diversity on Service lands."  The 1997 Refuge System Improvement Act extended ANILCA's landscape conservation ethic to all units of the Refuge System mandating the "biological integrity, diversity and environmental health of the System." In 2006 FWS published its policy on Biological Integrity, Diversity and Environmental Health for the Refuge System that reaffirmed the priority of species diversity.

Alaska can't override Kenai Refuge regulations so they're using the Federal rule-making process to make FWS echo State management on what is nominally a national wildlife refuge.  FWS' proposed regulations omit an environmental assessment of the impacts of eliminating trapping permit conditions including: 1) No orientation course for first-time trappers, 2) No trap-check requirements or other humane measures, 3) Elimination of no-trap safety zones within one mile of campgrounds, trailheads, roads, and visitor facilities, 4) Trapping will be allowed in the Refuge Headquarters/Visitor Center area, 5) Elimination of prohibition against site-bait (visible bait) which will threaten "non-target species" e.g. bald eagles and other raptors, magpies, moose, and dogs, 5) Elimination of trap/snare identification requirements so trappers will no longer be accountable for methods and locations, 6) Elimination of trapper harvest reports omits data on species diversity and health.

For decades, Kenai Refuge managers have walked a tightrope trying to fulfill ANILCA's vision for 21st century landscape conservation while Alaska's BOG/ADFG yearned for 19th century predator control to maximize harvest of moose and caribou. Abetted by the triple-threat of the Trump administration, a reactionary governor, and the outsized influence of Alaska's small congressional delegation, Kenai's FWS overseers are trying to repurpose the Refuge to model State priorities. Lip-synching ADFG, FWS' liberalized regulations would swell hunting and trapping as de facto predator control for bears and wolves, species expressly protected in Kenai's ANILCA purposes. FWS' new regulations would replace ANILCA's vision with the utilitarian trope that "good" species like moose and caribou are for food and trophies and "bad" wildlife, including "fur bearers," like wolves, coyotes, and bears are valuable only for their skins and removal as competitors to humans.

Hunting is part of the Refuge System's DNA and occurs on over half the 570 units. But only in the spirit of "fair chase," defined by the Boone and Crockett Club as "ethical, sportsmanlike, and lawful pursuit and taking of any free-ranging wild, native North American big game animal in a manner that does not give the hunter an improper advantage over such animals." The antithesis of "fair chase," bear baiting also threatens visitor safety on Kenai Refuge as the largest trophy bears are killed leaving others to roam with their newly-acquired taste for doughnuts and dog food. Bait hunting is highly effective and will have population consequences for brown bears on the Refuge. Promoting bear-baiting on Kenai Refuge shows the hypocrisy of ADFG whose media scolds "keeping bears away from human food is perhaps the most important thing we can do to prevent conflicts and confrontations between bears and people."  

The most important thing we can do is repudiate the U.S. Fish & Wildlife Service's proposed regulations on behalf of a small group of special-interest Alaskans and return management of Kenai National Wildlife Refuge to its rightful owners, the American people.

In the 1980s with James Watt as Secretary of the Interior, Kenai Refuge survived a hostile takeover by the Alaska Board of Game (BOG) which makes state hunting regulations and the Alaska Department of Fish & Game (ADFG) which implements them. Kenai Refuge's parent, the U.S. Fish & Wildlife Service (FWS) eventually ceded to demands and the Refuge adopted a State regulation that allowed hunters to shoot black bears over bait.  Thirty-five years later, Alaska Governor Mike Dunleavy is trying to leverage his relationship with the Trump administration and the outsized influence of Alaska's small congressional delegation for another hostile takeover.  Now ADFG wants to expand bear baiting to killing brown bears at smelly "bait stations" of old fruit, donuts, dog food, and garbage within Kenai Refuge. The State also wants the Refuge to remove conditions on trapping permits that made trapping compatible with Refuge purposes.

In the 1990s Kenai Peninsula brown bears were classified as a "population of special concern," a relatively small population geographically isolated on a virtual island and genetically distinct from mainland bears. From 1997 until 2012 hunting of Kenai brown bears was conservatively regulated with smaller harvests. But the State's philosophy changed dramatically and killing brown bears is now seen by BOG/ADFG as reducing moose predation and human conflicts while increasing hunting opportunity.

ADFG has long-coveted Kenai Refuge. Two-hours outside Anchorage, Kenai is Alaska's most popular Refuge.  Its hundreds of miles of hiking and canoe trails, campgrounds, and wilderness cabins complement a wildlife ensemble for a million visitors annually, including thousands of Alaskans. They fill their freezers with salmon in summer and moose in the fall. Hunting, fishing and trapping licensees are ADFG's constituency. Their misguided math says the fewer predators the happier their base. Yet a statewide poll in 2018 showed most Alaskans oppose killing female black bears and cubs in their dens, using bait stations to kill bears, and killing wolves, coyotes and pups in dens.  Some of these practices were once illegal in Alaska. But a 1994 Intensive Management Law directs BOG to identify moose and caribou populations to be managed for high human harvest and ADFG to develop regulations to maximize hunting opportunities.

ADFG has always rejected the 1980 Alaska National Interest Lands Conservation Act (ANILCA), the legal backbone that supports Alaska's 16 national wildlife refuges purpose 'to conserve fish and wildlife populations and habitats in their natural diversity. . ." FWS has reiterated both the letter and spirit of ANILCA. In 1982 ADFG and FWS agreed to a Memorandum of Understanding (MOU) wherein ADFG recognized FWS' authority "to manage fish and resident wildlife populations in their natural species diversity on Service lands."  The 1997 Refuge System Improvement Act extended ANILCA's landscape conservation ethic to all units of the Refuge System mandating the "biological integrity, diversity and environmental health of the System." In 2006 FWS published its policy on Biological Integrity, Diversity and Environmental Health for the Refuge System that reaffirmed the priority of species diversity.

Alaska can't override Kenai Refuge regulations so they're using the Federal rule-making process to make FWS echo State management on what is nominally a national wildlife refuge.  FWS' proposed regulations omit an environmental assessment of the impacts of eliminating trapping permit conditions including: 1) No orientation course for first-time trappers, 2) No trap-check requirements or other humane measures, 3) Elimination of no-trap safety zones within one mile of campgrounds, trailheads, roads, and visitor facilities, 4) Trapping will be allowed in the Refuge Headquarters/Visitor Center area, 5) Elimination of prohibition against site-bait (visible bait) which will threaten "non-target species" e.g. bald eagles and other raptors, magpies, moose, and dogs, 5) Elimination of trap/snare identification requirements so trappers will no longer be accountable for methods and locations, 6) Elimination of trapper harvest reports omits data on species diversity and health. 

For decades, Kenai Refuge managers have walked a tightrope trying to fulfill ANILCA's vision for 21st century landscape conservation while Alaska's BOG/ADFG yearned for 19th century predator control to maximize harvest of moose and caribou. Abetted by the triple-threat of the Trump administration, a reactionary governor, and the outsized influence of Alaska's small congressional delegation, Kenai's FWS overseers are trying to repurpose the Refuge to model State priorities. Lip-synching ADFG, FWS' liberalized regulations would swell hunting and trapping as de facto predator control for bears and wolves, species expressly protected in Kenai's ANILCA purposes. FWS' new regulations would replace ANILCA's vision with the utilitarian trope that "good" species like moose and caribou are for food and trophies and "bad" wildlife, including "fur bearers," like wolves, coyotes, and bears are valuable only for their skins and removal as competitors to humans. 

Hunting is part of the Refuge System's DNA and occurs on over half the 570 units. But only in the spirit of "fair chase," defined by the Boone and Crockett Club as "ethical, sportsmanlike, and lawful pursuit and taking of any free-ranging wild, native North American big game animal in a manner that does not give the hunter an improper advantage over such animals." The antithesis of "fair chase," bear baiting also threatens visitor safety on Kenai Refuge as the largest trophy bears are killed leaving others to roam with their newly-acquired taste for doughnuts and dog food. Bait hunting is highly effective and will have population consequences for brown bears on the Refuge. Promoting bear-baiting on Kenai Refuge shows the hypocrisy of ADFG whose media scolds "keeping bears away from human food is perhaps the most important thing we can do to prevent conflicts and confrontations between bears and people."  

The most important thing we can do is repudiate the U.S. Fish & Wildlife Service's proposed regulations on behalf of a small group of special-interest Alaskans and return management of Kenai National Wildlife Refuge to its rightful owners, the American people.