Alaska; Hunting and Trapping in National Preserves

Dear Director Creachbaum, The National Park Service is required to manage wildlife in Alaska's National Preserves to maintain natural abundance and behaviors. The proposed regulation would result in managing Preserves like game farms, prioritizing boosting game species by targeting predators. It is inconsistent with the agency's mission and mandate and should be withdrawn. The proposed regulation would defer to the Alaska Department of Fish and Game's (ADFG) hunting regulations in Alaska's National Preserves. But under state law, ADFG is required to manage wildlife for maximum human consumption of ungulates like moose, caribou and deer. In many areas, ADFG manages predators to scarcity in order to maximize these "big game prey" populations for human consumption. That management goal, and the predator reduction methods that it produces, are inconsistent with the Park Service's management responsibilities and goals in Preserves, as the agency has said itself: "It is contrary to the National Park Service concept to manipulate habitat or populations to achieve maximum utilization of natural resources. Rather, the National Park System concept requires implementation of management policies which strive to maintain the natural abundance, behavior, diversity, and ecological integrity of native animals as part of their ecosystem." Alaska holds the largest, most intact population of brown bears in the world outside Russia. It is also the only place where brown bears are deliberately managed for population reduction over wide areas by encouraging high human harvest. Baiting bears also creates increased potential for human-bear conflict as human foods are brought into their natural ecosystems, encouraging bears to seek human foods. Alaska's National Preserves remain one of the last great strongholds of our natural heritage, sustaining robust populations of iconic apex predators. The Park Service must do its job and continue to manage all wildlife – predators and prey alike – for natural abundance and behaviors in our beloved preserves. Don't sell out our National Preserves!