Cover Image - for illustration purposes only - Male grizzly bear looking straight into the camera at McNeil River/Southwest Alaska/Alaska Peninsula/Summer 2002 

April 1, 2025

On Saturday March 22nd, I gave testimony before the Alaska Board of Game (BOG) regarding an emergency petition from Alaska Fish & Game (ADF&G). This emergency petition was to continue killing grizzly (brown) bears via helicopter in the Mulchatna area. ADF&G has been killing grizzlies in this area for the past two years in an attempt to artificially boost the Mulchatna caribou herd. 

Recently, ADF&G lost a lawsuit where it was found that this type of predator control without proper public input and notification was unconstitutional.

ADF&G's emergency petition is an effort in my opinion to circumvent the court's ruling.

More information can be found here: Justice for Mulchatna Bears

I did record my testimony and uploaded it to Soundcloud here: 3-22-25 Alaska Board of Game Testimony

For those who would prefer to read the text to my comments it is as follows: 

March 22, 2025 

BOG Testimony Regarding Alaska Department of Fish & Game (ADF&G) Petition for Emergency Regulations to Kill Grizzly (Brown) Bears to Artificially Inflate the Mulchatna Caribou Herd

I would like to comment on ADF&G’s petition for emergency regulations for the killing of grizzly (brown) bears to artificially increase the Mulchatna caribou herd. 

First off, ADF&G announced on Friday 3-21-25 this emergency petition. This gives the public very little time to review the science (or lack thereof) or facts of predator control. 

Within ADF&G’s petition and I quote: 

The previously adopted IM program for the MCH was vacated by the Alaska Superior Court in March 2025 in part due to lack of evidence that the board had taken a hard look at the sustainability of the brown bear population due to bear removal.  

The court also found the Alaska Wildlife Alliance had standing to bring the lawsuit against the department and the board; and that the public was not afforded adequate opportunity to review and comment on the planned operations. 

I don’t feel one day’s notice is an adequate opportunity for the public to review and comment on this issue or any other, whether through written or verbal testimony. This is especially the case when many within the public are unfamiliar with grizzlies (brown bears) having the lowest birth rate of any North American mammal. 

Due to this low reproductive rate, grizzly populations are fragile and are susceptible to human caused population declines, especially when females are killed. Females are the foundation of any grizzly bear population. 

As of this time, ADF&G has not conducted any population studies or knows the population dynamics (ratio of males, females, subadults and cubs), natural mortality or whether the population is increasing, decreasing or stable. 

Furthermore, ADF&G has claimed that there is a “high” bear population within this area due to anecdotal opinions from hunters. Yet, they do not specify by numbers what a high population is for this area. 

Naturally occurring bear populations vary dependent on food availability, types of food, calorie content, habitats and ecosystems and onset of winter weather. 

In general, bears south of the Alaska Range who have access to salmon and other rich food sources will be able to support more bears. Bears north of Alaska Range who do not have access to these rich food sources will be fewer in number. 

Comparing the bears in Denali (north of the Alaska Range) versus the bears at Katmai (south of the Alaska Range) illustrate this difference perfectly. 

Katmai supports more bears, they are larger, yet this larger population reflects what the habitat/ecosystem can support. 

More bears in a naturally regulating ecosystem does’t suggest a “high” bear population; it is a natural reflection of the habitat that can support that population. 

ADF&G uses the term “high” in a pejorative manner, yet they do not define it nor do they have any current population studies to support it. 

Additionally, the only way one could have a “high” bear population is if it was artificially created by humans whether directly or indirectly through garbage, improper food storage, bait sites, or through intentional feeding. 

I have not read anywhere where ADF&G makes this claim. Consequently, there is no “high” bear population. 

Due to the lack of ADF&G’s bear population studies, they have yet to determine what a sustainable grizzly bear population is within this area. This is why knowing the population dynamics and natural mortality rates in this area is so important. 

Furthermore, ADF&G fails to consider other forms of the Mulchatna caribou herd decline that makes predator control irrelevant. 

Habitat/ecosystem/vegetation change is occurring throughout Alaska and is leading to declines in both caribou and Dall Sheep. Both caribou and Dall Sheep must have the types of vegetation that can support their populations. 

If there isn’t enough of the critical vegetation types, then the populations decline. Caribou are dependent on lichens and mosses which are being crowded out by willows, dwarf birch and alder. 

While the expansion of specific willow types will benefit moose, they are of no benefit to caribou during the winter months. 

Additionally, with Alaska having more heavy snowfall/icy type winters, this blocks caribou and especially Dall Sheep from reaching their food sources. 

These factors are attributed to global climate change, yet I have yet to hear ADF&G discourage oil development or the burning of fossil fuels to maintain both caribou and Dall Sheep habitat. 

Combine the above with a highly contagious disease such as brucellosis and it should be expected that the Mulchatna caribou herd would decline. 

Both wolves and to a much lesser degree grizzlies, can limit the expansion of contagious diseases such as brucellosis. Predator control encourages the expansion of such diseases as the removal of predators encourages more intense spread of disease outbreaks.  

In the Lower 48, Montana, Idaho and Wyoming refuse to acknowledge this fact through their anti-predator policies and consequently, chronic wasting disease is spreading throughout these states and the west. 

Also, I am not aware of ADF&G conducting vegetation studies to determine current quality of caribou habitat within the Mulchatna area nor of the rate of plant succession. 

This is critical in determining the rate of decline of the habitat to determine what caribou numbers the habitat will support.   

Quite simply, ADF&G hasn’t done any comprehensive studies to justify this emergency petition and I urge you to reject it. 

Followup BOG Meeting on Wednesday March 26th

On Wednesday March 26th, I returned to the Egan Center to listen to the final BOG deliberations. Initially, they deliberated over what constituted an emergency and whether they needed to hold another public hearing whether in person or by Zoom. 

They came to the decision that the Mulchatna situation did equate to an emergency situation that justified the killing of bears and that they did not need to hold a separate public hearing and listen to further public input. 

We took a break at that point but the writing was on the wall that they would authorize ADF&G in their later session to once again kill grizzlies and black bears from helicopters beginning from mid-May to early June of this year. 

I left at that point and didn't hear ADF&G’s presentation to the BOG, which by the way, there would be no later opportunity to rebut. 

Impressions

My impressions are that the same issues that lead to the court ruling against the State of Alaska still exists. One day’s notice through an Alaska Wildlife Alliance Alert (which I received) does not constitute proper notice to the public. Nor, does it allow the public to review and adequately comment on the emergency petition. 

Furthermore, the State must treat bears in a sustainable fashion, yet they have conducted no studies to determine what is sustainable and what is not. 

It was this lack of proper notice, public involvement and lack of sustainability that lead the court to find against the State of Alaska. Will there be further court action? 

I don’t know but I certainly hope so. 

Grizzlies, Wolves & Our National Parks & Public Lands

Grizzlies, wolves and all wildlife need the active support of the public. Additionally, National Parks, Monuments, Refuges, Recreation Areas, National Forests, and BLM lands are all under threat from the Trump administration. 

All of the above are interconnected. 

If you enjoy wildlife viewing, photography, bird watching, camping, backpacking, hiking, canoeing, kayaking, mountain biking, mountain climbing, fishing, hunting, etc then please get involved in protecting your public lands and wildlife. 

If you don’t know where to start then I would suggest the  Alaska Wildlife Alliance (primary organization that is a voice for Alaska’s wildlife).

The Denali Citizens Council who covers issues that are primarily relevant to Denali National Park: The Denali Citizens Council

Defenders of Wildlife in Alaska: Alaska Defenders of Wildlife

Defenders of Wildlife primary website: Defenders of Wildlife

Trustees for Alaska (lawyers who protect Alaska and its wildlife): Trustees for Alaska

Other suggestions: 

Talk to friends and family about any issue that resonates with you. 

Think of your favorite National Park, Monument, etc and/or recreational activity and ask yourself what you can do to support and protect it? 

Join a protest in support of National Parks and your public lands. Be sure to take photos and video and upload them to social media to spread the word and to encourage others to protect our public lands and wildlife. 

Find an issue that you are passionate about and write a letter to the editor. 

Write an op-ed for your local newspaper or social media. 

Give $5-10 or more to an environmental organization that you agree with and support. 

Whatever you choose to do, do what you are comfortable with. 

Saving Our Public Lands & Wildlife

And finally, National Parks are known as America’s Best Idea. This idea incorporates the best qualities of America from compassion, empathy, understanding, tolerance, acceptance, education, generosity and…….democracy. 

These are not “woke” qualities but traditional American qualities that have been held in high esteem and that we have collectively, aspired to. 

Now is the time to passionately defend this idea and expand it to all public lands and wildlife. 

Because if we don’t act to save our public lands and wildlife, then these lands could become privatized, sanitized and finally………. cannibalized. 

This is the intention of those “black hearted and soulless" few who care nothing for  public lands, wildlife or America’s Best Idea. To them, profit and greed is all that matters regardless of the pain, suffering, waste and loss that it creates.   

Let’s insure that our public lands and wildlife will be available not only for us to enjoy in the future but also for future generations as well. 

All the best. 

Bill