2-26-24
Written Comments Submitted to the Alaska Board of Game
I am a long term Alaskan who has worked in Denali National Park for the past 36 years; 33.5 as a Tundra Wilderness Tour (TWT) Guide and Transportation System driver.
Furthermore, from 1991 to 2009, I had worked on a part time professional basis as a nature photographer with representation by Alaska Stock Images who was later bought by Design Pics.
While the BOG may only concern itself with populations of animals, we in Denali never see entire populations of wildlife. What we see are the representatives of those populations: the individuals, family groups, small herds and flocks of wildlife that visitors from all over the world, (including Alaskans) visit Denali to see and enjoy.
Consequently, they have great value to the 600,000+ visitors to Denali each year.
As a TWT guide, I take up to 52 visitors (including Alaskans) into the park and give them a guided tour that includes wolves and other wildlife. Conservatively, I have taken over a 100,000 visitors into Denali during my career.
During this time, I can easily state that when visitors see and enjoy wolves, that the excitement level skyrockets. In fact, I have been told on many occasions prior to 2012 that wolves are what made a visitor’s trip to Alaska.
Quoting from an economic study on Denali’s wolves titled: Economic Values of Wolves in Denali National Park and Preserve (DNPP) - See: https://static1.squarespace.co...
“In 1997, non-resident visitors who came to Alaska primarily to view wildlife had average expenditures of $6,000 per trip.”
“From economic valuation questions found in Alaska wildlife viewing literature, it can be inferred that a non-resident visitor may have an additional value in the range of $200-$300 per wildlife viewing trip to Alaska if a wolf is seen on their trip.”
“Qualitative content analysis of structured interview material with these same surveyed visitors yields a primary theme of dissatisfaction of not seeing wolves.” End Quotes
Declines in Wolf Viewing
Prior to 1995, 2005, and 2012, Headquarters, East Fork and Grant Creek wolf family groups were especially notable. Headquarter’s territory included the first 14.5 miles of the park road which allowed visitors the opportunity to view them without taking any kind of a bus into the park.
The trapping caused deaths of breeding females in each of the above wolf family groups in the above years, disrupted travel, use of territory, hunting, rendezvous and den site locations within these family groups, or in Headquarters case, lead to their complete disintegration.
All previous wolf family groups (Savage River, Headquarters, Sanctuary, Mt. Margaret, Nenana River, Riley Creek and East Fork (Toklat) that have moved into the far eastern portion of the Denali have suffered trapping/hunting caused deaths. In most of these, hunting/trapping was either a contributory or primary cause of their disintegration.
In all of these cases (and more) not only have the wolves been negatively impacted but so too has visitor viewing.
From 2004 to 2012, Grant Creek denned west of the Toklat River, a quarter mile away from the park road with two off years. This provided visitors unparalleled opportunities to view wolves and their pups with high quality sightings being common. Wolf viewing would reach its peak in 2010, when 45% of visitors saw wolves, primarily due to Grant Creek.
In 2012, the breeding female of Grant Creek was baited and killed outside the park by a local trapper.
Within one year, this lead to a serious decline in Grant Creek from 15 wolves to 3. Additionally, it created massive behavioral disruptions to travel, territory, hunting, rendezvous and den site selection and caused visitor viewing to plummet to 4% from its high of 45% in 2010.
What this points out is that wolves are not expendable biological cogs that replicate the behaviors of previous wolf family groups. Each individual and family group is unique in its behaviors and whether they will be viewed by park visitors or not.
Over the past three seasons, I and my passengers had 0 sightings for 2021, 2 sightings for 2022 and 3 sightings for 2023.
This is not an isolated case of one Denali Tour Guide/Driver.
In 2019, I conducted mid-season and end of season sighting surveys of wolves among my fellow drivers and of the 68 Denali drivers who responded, there were only 27 sightings involving 32 wolves over the course of a 135 days (April 27 - September 8, 2019).
NPS would later establish that in 2019 and 2022, wolf viewing declined to its all time low of 1%. This is the reality of the state’s policy’s is that visitors and residents are being denied a truly rare and unique experience as not only wolves are being eliminated/disrupted but so to is wolf viewing in Denali National Park.
All Alaskans and visitors should have a realistic opportunity to experience Denali’s Big Five (moose, caribou, Dall Sheep, grizzly bears and wolves). Targeting and killing Denali’s wolves in The Wolf Townships significantly impacts wolf viewing in the park. It further degrades and cheapens the experience for Alaska visitors/residents and denies them that rare experience.
Wolf viewing isn’t based on the numbers of wolves, but on the behaviors that individual wolves and family groups adopt such as: travel and hunting near or on the park road. Far more rare, is the establishment of rendezvous sites and the ultra rare den site near the park road; with den sites being the ultimate gold standard for viewing.
The targeting, trapping and killing of Denali’s wolves within The Wolf Townships has repeatedly disrupted wolf family group dynamics impacting not only the wolves themselves but the viewing of wolves for up to 600,000+ visitors per year.
The above demonstrates the fragility of wolf family structure and the behaviors that allow for visitor viewing. These examples and more point out that one knowledgable trapper can destructively impact the social structure of Denali wolf family groups and visitor viewing of wolves…….for years.
NPS Study
In January of 2023, NPS released a study on the impacts of human caused mortality to wolf family groups titled: Human-caused mortality triggers pack instability in gray wolves -
See: https://esajournals.onlinelibr...;
This study included: Denali, Yellowstone, Grand Teton, Voyageurs National Parks and Yukon Charley Rivers National Preserve.
The conclusions of this study support my testimony. Even the death of a single wolf (depending on which one) can have significant implications for wolf family structure, behaviors and/or whether they disintegrate as a family unit or not.
How the State Treats Wolves
The state typically treats wolves in its management as expendable, biological cogs while ignoring fundamental wolf family structure, behavior, and significant ecosystem and economic benefits. And in Denali’s case, the state further ignores the devastating impacts to visitor viewing.
No place in Alaska, is a family group of wolves granted full protection throughout their territory. Even in Denali’s 6.2 million acres, wolves are only protected in the 2 million acres of Denali’s original park; not the 4 million acres of Preserve and New Additions.
In these areas, bag limits for trapping is unlimited and hunting begins on either August 1st or 10th (depending on the Game Management Unit - GMU) when wolf pups are using rendezvous sites and are highly dependent on the adults.
According to the Alaska Conservation Alliance and Ecotrust, wolves are only protected in 2.4% of Alaska leaving 97.6% open to wolf killing. Where is the balance in this type of biased management?
The Wolf Townships have been recognized for decades as critical winter habitat for Denali’s caribou herd and wolves. Yet, while the caribou herd have enjoyed protection since 1972; the wolves have not. Why the double standard in wildlife management between these two species both of which spend most of their time within the park?
The Contempt by Extremist Trappers/Hunters for Visitors
The contempt by extremist trappers/hunters for Denali visitors, the tourism industry and all non consumptive users is best illustrated by quoting the trapper responsible for the death of Grant Creek’s breeding female in 2012.
Quoting from the National Geographic article: How Can Six Million Acres at Denali Still Not Be Enough?
“That was the third time I ruined millions of people’s Denali National Park viewing experience,” Wallace quips.
The cascading and rippling impacts of the killing of this breeding female destroyed the best wolf viewing in my 36 years in Denali. And furthermore, it denied in the words of the above trapper “millions of people’s” unique and unforgettable wolf viewing experience; which included pups.
How does the desires of the above trapper as well as a handful of others outweigh the desires of “in the words of the above trapper;” “millions of people’s” who wish to see wolves?
Wolves are the number 1 wildlife draw in Yellowstone and bring in $83 million dollars into the local economies. They further provide many direct and indirect jobs and are a significant economic benefit to Yellowstone’s tourism economy and consequently, to businesses and employees in Montana, Wyoming and Idaho.
A similar, positive economic effect on a lower scale could be achieved in Denali if and only if wolves are protected within The Wolf Townships. This would allow for wolf family group structure continuity (as best as possible) and help set the stage for realistic visitor viewing.
Quite simply the state’s policies have undermined and sabotaged wolf viewing in Denali to such a degree that the odds of visitors seeing and experiencing wolves is “almost nonexistent”.
While wolf viewing cannot be guaranteed, the stage can be set for its realistic possibility if wolves are fully protected in their critical habitats that are adjacent to Denali National Park.
No Government Overreach for Proposal 186:
Whenever a proposal is made to actually protect wildlife, especially wolves and/or grizzlies, the howling, caterwauling and whining begins over government overreach.
Proposal 186 isn’t a case of Federal overreach on state lands; it is a proposal not a takeover. In past years, the Fairbanks North Star Borough (2016) as well as opinion polls by Remington Research Group in 2018, show overwhelming public support for the establishment of a protective buffer to protect the park’s wolves, grizzlies and wolverines.
It is the vocal minority of howling extremists in the hunting/trapping community that are opposed to such a proposal.
Alaska wildlife is supposed to be managed for all Alaskans; including non consumptive users who wish to view, photograph, video and enjoy living wildlife.
The only places in Alaska where wolves enjoy complete protection is the original National Parks of Denali and Glacier Bay and the original National Monument/Park of Katmai. This being the case, they are not protected throughout their entire territories.
Consequently, I am currently on my sixth trip to Yellowstone in 2 1/2 years specifically to look for, observe and photo/video wolves. And even though, this trip has not been successful to the extent that I would like, at least I have the opportunity to view wolves while here. The same cannot be said for Denali. A one to six percent viewing possibility of seeing wolves in Denali is not a realistic opportunity but a spin of the roulette wheel.
Protecting Denali’s wolves in The Wolf Townships will help set the stage for the visitor viewing of wolves for Alaskans and all visitors. It will further encourage these visitors to spend their hard earned cash in Healy and other Alaskan locations as opposed to Gardiner, Montana and locations in the Lower 48.
I urge you to support Proposal 186 in it’s entirety and on a year round basis.
Wolf Control Proposals for GMU 19c
Am Opposed to the following proposals: 60, 61, 62, 65,
Sheep Proposals for GMU 19c
Am Opposed to the following proposals: 76, 77, 78, 79, 80, 81, 82, 83, 84, 85, 86, 87, 89, 90, 91
Support Proposal 92
Grizzly Bear Proposals for GMU 19c, 19e, 19b, 19d, 21a, 21e
Am Opposed to the following proposals: 93, 94, 95, 96, 97, 98, 99, 100, 101, 102, 103, 104, 105, 106, 107
Tok Area Proposals for GMU 12, 20d, 20e, 24
Am Opposed to the following proposals: 108, 109, 120, 121, 122, 123, 136, 137, 138, 146,147,148, 149, 150, 151, 152, 153
Proposals for Units 20A, B, C, F, 25a 25c
Am Opposed to the following proposals: 166, 167, 168, 169, 170, 182, 183, 184, 185, 187
Notes on Opposing the Above Proposals
None of the Dall Sheep proposals mention human caused climate change impacts (heavy snowfall and/or icy winters) and their duration on sheep populations. It should be expected that as long as human beings continue to burn fossil fuels that climate change impacts will worsen for Dall Sheep and other species; including caribou.
Sheep populations are declining statewide, yet the following sheep proposals allow for expanded sheep hunting by resident and non resident hunters. This contradicts attempting to maintain and/or increase sheep populations and no amount of wolf control will alleviate the problem for sheep when it is a human caused, climate change issue. Consequently, Proposals 60, 61, 62 & 65 will only squander limited state resources.
Furthermore, no ADF&G studies of ungulate, sheep, wolf or grizzly/black bear populations are cited in any of these proposals. Nor, are any formal vegetation studies on lichen, mosses and willows mentioned to determine habitat condition.
It should be expected that as willows expand into areas of lichen and mosses that these important food sources for caribou will decline in time.
Habitat/vegetation quality is directly related to carrying capacity of the ecosystem for ungulates.
For proposal 65, ADF&G fails to give any reason to continue Intensive Management, or it’s current state of effectiveness, or its current cost or future, expected costs.
Furthermore, no numbers of ungulates or predators are given or population goals to be reached.
Quite simply, no justifications based on rigorous scientific study is given for any of these proposals. The above proposals for intensive management and wolf control if approved, would continue to pour limited state resources into the “Black Hole” of wasteful spending.
Opposing all Expanded Grizzly Bear Hunting/Baiting Proposals
Grizzlies have the lowest reproductive rate of any North American mammal, consequently, their management must be scientifically based with comprehensive studies conducted beforehand.
No scientific justification for these proposals is given to justify expanding hunting seasons. No studies on the grizzly bear population is given, no population dynamics (ratios of males, females, subadults & cubs) is given, no natural mortality is established for cubs in GMU 19c (or other GMU’s), or whether the population is increasing, stable or decreasing.
Furthermore, this GMU is adjacent to the southwest corner of Denali National Park/Preserve, meaning National Park/Preserve bears could be targeted and killed which is unacceptable.
Bear baiting is one of the most unethical practices to hunt grizzly or black bears. In addition to its unethical nature, it also carries with it the strong possibility of creating human food habituated bears.
Food habituation by grizzly bears has been well documented going all the way back at least to the 1967 bear attacks on two different women in two different areas of Glacier National Park, Montana by two different grizzly “dump” bears.
Grizzlies have the capability of creating indirect food association (no people present) through the presence of human scent on human food items or garbage. This has lead to human injuries and in rare cases, predatory behavior by grizzlies that has resulted in the deaths of people.
Bear bait stations are miniature dumps created by hunters. Since not every bear is killed at these bait stations, the possibility of hunters creating problem bears for others is a very real possibility.
Additionally, female bears with cubs who visit bait stations teach their cubs this association.
Lastly, it makes absolutely no sense to encourage the public to keep a clean camp, to never feed bears, to not put bird seed out in spring, summer and fall, to put trash cans out for pickup on the day of pickup, to clean fish by streams, to use bear proof food containers, food lockers, garbage cans for campers, backpackers, etc and then have hunters put out human food, grease and/or dog food in creating these bait stations.
Quite simply, bear baiting should be banned in Alaska; not expanded.
Sincerely,
Bill Watkins
References:
Economic Values of Wolves in Denali National Park and Preserve (DNPP)
https://static1.squarespace.co...
Human-caused mortality triggers pack instability in gray wolves
The Wolf Connection Podcast with Kira Cassidy on NPS Study: Human-caused mortality triggers pack instability in gray wolves
https://thewolfconnection.buzz...
Trapper lures wolves from Denali, kills 2; pack’s future in doubt
https://www.latimes.com/nation/la-xpm-2012-may-21-la-na-nn-denali-wolf-20120521-story.html
Battle over wolf hunting on Denali boundary continues
Looking to see a wolf at Denali? A grassroots bus-driver survey puts the odds at ‘not-quite nonexistent’
https://www.adn.com/alaska-new...
New Denali wolf study omits the full story
https://www.adn.com/commentary...
How Can Six Million Acres at Denali Still not be Enough?
https://www.nationalgeographic.com/magazine/article/denali-national-park-alaska
NPS Wolf Sighting Index
https://www.nps.gov/dena/learn/nature/wolf-sighting-index.htm
NPS - 2022 Annual Wolf Report
https://irma.nps.gov/DataStore/DownloadFile/689410 -
Quoting from Under Summary - Page 7 - A index of wolf viewing for the eastern portion of the road (to East Fork) was 0.01 in 2022.; only one data collection trip out of 91 observed a wolf in 2022.
No wolf sighting data is available for 2020 & 2021 due to Covid
Denali Wolves on FB - Educational/Advocacy Group
https://www.facebook.com/groups/denaliwolves
Denali Wolves & The Wolf Townships - Explanatory Video
Denali Wolf Time Capsule Photos - Prior to 2009
https://billwatkins.photography/portfolio/denali-wolves
More film images prior to 2009, will be scanned and added at a later date.