Katmai Guided Hunting Concession
The National Parks Conservation Association (NPCA) has a long history of taking action to protect the brown bears of Katmai National Park & Preserve. Katmai National Park & Preserve was established in the Alaska National Interest Lands Conservation Act (ANILCA) of 1980 to, among other purposes, perpetuate “high concentrations of brown/grizzly bears.”
Most of NPCA’s actions to support maintaining high concentrations of brown bears have focused on the Alaska Board of Game, which has primary responsibility for managing sport hunting in Alaska, including federal lands such as Katmai National Preserve. Federal regulations in 36 CFR 13.40(d) state: “Hunting and trapping are allowed in national preserves in accordance with applicable Federal or non-conflicting state law and regulations.” Those state laws and regulations that conflict with federal management policy have been our focus with the Alaska Board of Game and the focus of the National Park Service (NPS), which historically has shared many of our management concerns.
Primary among those concerns is the perpetuation of the Congressional mandate in Katmai’s enabling legislation for “high concentrations of brown/grizzly bears”[1] and the directive for "conservation of healthy populations…of fish and wildlife.”[2] This is a unique mandate among Alaska’s national parks. Congress did not direct any other parks to protect “high concentrations” of brown bears and, as such, no other parks in Alaska have the same high responsibility to protect their bears.
In 2005, 2007 and 2009, both NPCA and the National Park Service advocated that the Alaska Board of Game adopt varying measures to reduce the number of brown bears harvested, out of concern that the Board’s actions may be causing NPS to violate the high concentration standard. Beginning in 2003, Katmai saw an almost 250% increase in the number of bears harvested.
According to the data we have collected from the Department of Fish & Game, from 1985 to 2002, the harvest level for each regulatory year[3] averaged 13.5 bears. From 2003 through 2008, that number increased to 33 bears harvested in a regulatory year. This drastic increase coincided with a notable decrease by some professional bear viewing guides in the number of bears observed in the Funnel/Moraine Creek region of Katmai National Preserve, especially large males. This reduction in observable bears, at the same time the harvest level significantly increased, caused us to dig deeply into this issue. The issue also concerned the NPS, as exemplified in their comment letters to the Board of Game seeking changes to hunting regulations over this same time period.
While recognizing that the Alaska Board of Game sets the bag limits and season length and that the Board of Game virtually ignored requests from NPS and others, including NPCA, to reduce the brown bear harvest levels, there was the recognition that NPS could influence the brown bear harvest levels through its standards and stipulations on two guided hunting concession contracts issued for Katmai National Preserve. These two Guided Hunting Concessions are the Park Service and the public’s only other venue and opportunity to address harvest level concerns while discussing how best to perpetuate “high concentrations of brown/grizzly bears” in Katmai.
A newsletter published in May 2011 was the first time that NPS provided the public with the opportunity to comment on the concession contracts prior to the release of its contract prospectus. Furthermore, within that newsletter, NPS proposed to limit the number of brown bear hunts to 13 for the fall hunt and 8 for the spring hunt, or 21 in a regulatory year[4]. While appreciative that NPS had set limits, we had questions and concerns about how the Park Service developed the number of bears that may be hunted.
NPCA commented on that concern and requested that NPS provide the public an opportunity to significantly engage in fully understanding the purpose and need for two Katmai Guided Hunting Concession Contracts, and the data used, assumptions made and the analysis performed by NPS in setting the contract’s proposed terms and conditions, including the proposed number of bears that could be hunted. The Park Service responded to our concerns by writing a Draft Environmental Assessment (EA) for Guided Sport Hunting Concessions in Katmai National Preserve, which was released in June 2012.
To be clear, NPCA's concerns should not be construed as anti-hunting, nor should they be interpreted as anti-guide. On the contrary, Congress is clear that hunting is to be permitted in national preserves “under applicable State and Federal law and regulation.”[5] And the applicable state law is that out-of-state brown bear hunters must be guided. We understand and accept these legal realities. Rather, our concern is one of government accountability as the Park Service should use this concession contract opportunity to influence the amount of bears allowed to be hunted and adopt other stipulations we feel are necessary to perpetuate high concentrations of brown bears.
Unfortunately, the EA did not meet our expectations. As we requested, the EA did disclose the data the National Park Service used to determine the bear harvest levels it suggested in May 2011, but those suggestions were now dismissed as “eliminated from detailed study” and not considered. Instead, NPS stated that there are plenty of bears to sustain a “moderate harvest level” of up to 28 bears a year. This misses the point on several accounts:
- NPCA has never disputed that there are plenty of bears in/around Katmai. The conflict has always been a localized one in the Preserve, and more specifically around Funnel and Moraine creeks, where most of the bear viewing and much of the bear hunting takes place. This is, first and foremost, a user conflict between bear hunters and bear viewers. Bear hunters want to kill large male brown bears – they are considered a trophy. Those are the very same bears that many bear viewers seek as well. So while the overall bear population is not threatened by hunting, the ability to view a large male brown bear is impacted by hunting in the preserve and that point was completely missed by the National Park Service. The EA inadequately analyzes this user conflict.
- Congress called for high concentrations of brown bears, which to us is something different than the population levels of bears in all other parks. Yet the National Park Service did nothing to quantify or define what they meant by high concentrations and they didn’t delineate how it is different from bear populations in other parks. Furthermore, it didn’t discuss how a moderate harvest level could impact high concentrations. This should have been a major topic of discussion and evaluation in this EA.
- In addition, any meaningful range of alternatives is missing. The status quo is 28 guided hunts per year, with the ability for each hunter to kill a bear. The EA proposes no change. A year ago, NPS proposed limiting the harvest to 13 bears in the fall hunt and 8 bears in the spring hunt. Now they are proposing 28 bears could be killed in the fall and other 28 in the spring. That’s a total increase of 21 potentially harvested bears over the fall/spring hunt (the hunt is set by the state as an every-other year fall/spring hunt) to now a potential of 56 bears harvested.
A prudent range of alternatives would have explored either fewer hunters or a limit on the number of bears harvested, as NPS suggested a year ago. Yet the status quo on the number of hunters remained the same, with the only thing differentiating the status quo proposal and the National Park Service preferred alternative is the redrawn boundary lines between the two existing concession areas, to make them about equal in size. The public was essentially provided no reasonable range of alternatives from which to choose.
Footnotes
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A regulatory year is July 1 to June 30 and includes both a fall and spring bear hunt. The hunt in Katmai occurs every other regulatory year. For example fall 2009/spring 2010 and not another hunt until fall of 2011.
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A regulatory year is July 1 to June 30 and includes both a fall and spring bear hunt. The hunt in Katmai occurs every other regulatory year. For example fall 2009/spring 2010 and not another hunt until fall of 2011.
