Another Busy Week for Comments

SCI’s Legal Advocacy team submitted five public comments this week – three to the Alaska Board of Game, one to the U.S. Forest Service, and one to the Bureau of Land Management.  Later this month, the Board of Game will discuss three proposals related to the Western Arctic Caribou Herd (“WACH”): two of the proposals would eliminate nonresident hunting across all or part of the WACH’s range (Proposals 3 and 38) and the third would reduce the resident bag limit for caribou from the WACH (Proposal 2). SCI supports science-based management of wildlife and acknowledges that Alaska Department of Fish and Game data indicate a significant decline in the WACH population. If the WACH can no longer support regulated harvest, then SCI does not oppose a reduction or closure of hunting opportunities. However, with consultation from our Alaska chapters, our comments request that the Board of Game look to the science and the benefits of hunting when making these decisions. SCI especially urged the Board of Game to include in their discussions the important contributions of nonresident hunting to wildlife management in Alaska. 

In the fourth letter submitted this week, SCI joined a comment with our partner, the Wyoming Outfitters and Guides Association (“WYOGA”), in support of the Forest Service’s environmental review for continued supplemental winter feeding of elk on two feedgrounds in Wyoming. Together, SCI and WYOGA have litigated this issue, and the Forest Service’s environmental review follows up on the results of that litigation. The Forest Service’s proposed alternative would keep open the feedgrounds. SCI and WYOGA’s comment highlight the necessity of the action to reduce elk impacts on private land and to avoid mass starvation of elk that have been fed on these grounds for decades. Continuing the use of the Dell Creek and Forest Park feedgrounds prevents negative outcomes and supports the proliferation of Wyoming’s elk population. 

The final letter submitted by SCI’s Legal Advocacy team comments on the Rock Springs Field Office Draft Resource Management Plan and associated Draft Environmental Impact Statement. SCI’s letter requests that the Bureau of Land Management reconsider the selection of Alternative B as the Preferred Alternative in the draft plan. Instead, SCI’s letter encourages the Bureau to adopt Alternative D, the “moderate approach,” as the Preferred Alternative. Alternative D would advance conservation purposes while implementing a number of actions identified and requested by public comments and cooperating agency input. It would also utilize fewer special area designations and prescriptive actions than the current preferred alternative. SCI requests that the Bureau consider selecting Alternative D because it is more balanced and flexible, and protects public access for recreational purposes, including regulated hunting. 

SCI will continue to advocate for science-based management in Alaska and Wyoming.