Marcia Blaszak, Director Alaska Region, National Park Service 240 W. 5 th Avenue Anchorage, Alaska 99501 Sent as a PDF file via e-mail P.O. Box 64 Denali Park, Alaska 99755 August 16, 2006 Re: Subsistence hunting of wolves inside Denali National Park as of September 1 Dear Marcia: I am writing to renew my request for the National Park Service (NPS) to prohibit Kantishna subsistence permittees from killing wolves inside Denali National Park as of the beginning of the annual hunting season on September 1. One of about 15 groups of wolves in Denali Swift Northeast, aka, McKinley Slough uses the southern Kantishna Hills and is again raising at least three pups in that area of the park, less than a mile from where permittees are allowed to drive their pickups and camp (six miles off the park road, up a river trail). Swift Northeast has maintained a late winter size of 7-10 wolves since 2003. Unless NPS intervenes, Kantishna hunters will be allowed to shoot up to 10 wolves apiece, including pups. The situation is more problematic than last year when Swift Northeast denned in this area for the first time. Two of these wolves are radio-collared but this summer seem only loosely associated with the group. Without regular telemetry contact via these two wolves, it will be difficult to follow any moves from the natal den and thus to know how the risk of hunting impacts might change as the hunting season approaches. Swift Northeast was still using this den as of at least August 7. Last year, it used the den through early August and then moved to a rendezvous about a mile northeastward, still within the hunting area and less than a mile from the aforementioned hunter camp. Regardless of the specific homesite in use, Swift Northeast wolves travel throughout the hunting area and on the pickup trail during their frequent forays to provision the pups. They are especially vulnerable to being shot in the open terrain that predominates. The three pups that I have seen this summer are runts, which means they are more dependent than usual on the older wolves. I observed a similar situation two years ago when Swift Northeast successfully raised a runt pup through at least one year of age. There was extraordinary cooperation among the older wolves in attending to that pup, especially during the continuous travel of the fall and winter months. Allowing Kantishna permittees to shoot even one of the older wolves would likely complicate the job this year, with three runts.
2 It is just plain wrong to leave the Swift Northeast wolves open to this kind of risk, especially in a national park and with highly dependent pups. Swift Northeast is also important in the biological, multi-scale scheme of things at Denali. It is contributing valuable scientific insights on a wide front. It provides most if not all of the wolf-viewing opportunities for park visitors in the Wonder Lake-Kantishna area. Kantishna subsistence permittees are primarily after moose but are also allowed to kill wolves and bears. However, there is no significant wolfhunting tradition in the Kantishna area (per your letter of 9/9/05 and my reply of 9/10/05), so a wolf-hunting closure would not take anything significant from the permittees. As you will recall, I requested a closure from NPS last year. NPS insisted on viewing this as a Federal Subsistence Board (FSB) matter and advised me to raise the issue there. So I requested an emergency special-action closure from FSB via the U.S. Fish and Wildlife Service Office of Subsistence Management (USFWS). USFWS declined to convey my request to FSB (requests for FSB special actions can only be made through USFWS). This experience reiterated a couple of key points that I should not have forgotten: Several years ago I asked FSB directly, at a scheduled public meeting, for a wolfhunting closure in another area of Denali, to better protect the well-known Toklat (East Fork) group of wolves. Chairman Mitch Dementieff replied on the record that he was sympathetic but that FSB was under a Congressional mandate - through the Alaska National Interest Lands Conservation Act (ANILCA) to maximize subsistence opportunities. He stressed that FSB was not the appropriate venue to use in seeking this kind of protective action. In other words, the responsibility for managing Denali National Park and Preserve rests with NPS, not FSB, USFWS, or any other agency. And in managing Denali, NPS must adhere to various statutes, not just ANILCA. NPS retains considerable latitude and discretion in regulating subsistence activities, apart from ANILCA. ANILCA itself provides more latitude (and ambiguity) than NPS implies. For example, Section 1301 mandated a General Management Plan (GMP) to provide the primary guidelines for managing Denali. The GMP was developed through an extensive public process. It was signed by NPS and the Assistant Secretary of the Interior in 1986 and remains in effect. It emphasizes that wolves are of disproportionately high ecological value and vulnerability in Denali because of their relatively small numbers. One sentence alone gives you ample authority to attach a wolf-hunting prohibition to the Kantishna subsistence permits prior to September 1, without any FSB involvement:
3 Action will be taken to ensure that legal subsistence and sport harvests are consistent with the legislative objectives for wildlife protection in the [ANILCA additions] area, one of which is to maintain natural predator/prey relationships. (GMP, p. 56). Recall again your acknowledgement that there is no known significant wolf hunting history in this area, in the event that someone imagines wolf hunting to be integral to the area s natural predator-prey relationships. NPS assumes that killing wolves on September 1 constitutes a legal subsistence activity. Everything in the NPS (and USFWS) arguments is predicated on subsistence uses. However, subsistence hunters do not eat wolves, and September wolf pelts, especially from three-and-half-month-old runt pups, are not usable by reasonable standards, which is why trapping seasons do not normally begin until about two months later. Denali superintendent Paul Anderson and his staff subsistence specialist replied a year or two ago that somebody once told FSB he used a pelt from a wolf killed in September, from another area (not in Denali). This is where the discretion and judgment entrusted to you and Anderson should kick in: You are obligated to exercise this reasonably. It is not reasonable to allow such a feeble argument to prevail over the opposing ethical, biological, scientific, viewing, and other considerations of importance to far greater numbers of park users. By that standard you should never deny anything for which someone claims a subsistence use, however frivolous. It should also be remembered that many of the Kantishna permittees are likely to see wolves (and bears) as competitors for the moose they want. Some of the permittees are already well-known advocates of wolf control in general. This means there is an inherent likelihood that they will advocate for and avail themselves of opportunities to kill wolves in the Kantishna area apart from any direct subsistence intent. The last time I checked, predator control was not legal inside Denali. A recurring argument is that there is no need to prohibit wolf hunting in the Kantishna area because the historical record indicates so few have been shot there. As I ve explained in previous letters, the risk at hand is determined primarily by the whims of individual permittees, where the wolves are raising and hunting for their young, and related variables, not by the historical kill. The low historical kill does not change the fact that the Swift Northeast wolves are now using an area also preferred by permittees and that even a single permittee venturing to the area could easily do major damage to the group within minutes.
4 Last September, these wolves lucked-out due to bad weather. Rain kept most hunters from driving their pickups into the area, due to high water at the river crossings. A couple years earlier, just before the wolves began denning in this area, the weather was excellent and I saw at least a half dozen pickups parked at the campsite near the den. Another recurring argument is that Swift Northeast and other groups of wolves do not matter much from a biological standpoint - that there is no need to worry about anything except the wolf population. To the contrary, based on extensive peer-reviewed, published research (e.g., Haber 1977, 1996, 1999; Walters et al 1981), groups are the primary wolf functional units in Denali and elsewhere from behavioral, predation, and system standpoints. While there are naturally short-lived groups in certain areas of Denali, in other areas the groups are quite persistent (e.g., Toklat/East Fork), for prey-related reasons. Both are important in the multi-scale way that systems work. The true (biological) population to which Denali wolves belong extends far beyond the park s boundaries, probably to the Arctic Ocean. Hunters could kill every wolf in Denali without endangering that population there is no threshold below which NPS could declare endangerment with a scientific rationale. A population standard is meaningless for Denali wolves. Sincerely, Gordon C. Haber, Ph.D. References cited Haber, G.C. 1977. Socio-ecological dynamics of wolves and prey in a subarctic ecosystem. Ph.D. dissertation, University of British Columbia, Vancouver. 817 pp. Haber, G.C. 1996. Biological, conservation, and ethical implications of exploiting and controlling wolves. Conservation Biology 10: 1068-1081. Haber, G.C. 1999. A selective view of wolf ecology. Conservation Biology 13: 460-461. Walters, C.J., M. Stocker, and G.C. Haber. 1981. Simulation and optimization models for a wolfungulate system. Chapter 16 in, C.W. Fowler and T.D. Smith (eds.), Dynamics of large mammal populations. Wiley, New York. 477 pp. Republished 2004, Blackburn Press, Caldwell, New Jersey.
Marcia Blaszak, Director Alaska Region, National Park Service 240 W. 5 th Avenue Anchorage, Alaska 99501 Sent as a PDF file via e-mail Re: Subsistence hunting of wolves inside Denali National Park: Followup Dear Marcia: P.O. Box 64 Denali Park, Alaska 99755 August 25, 2006 A point in my August 16 letter warrants emphasis. Several times in the last couple of years I have heard it suggested that reducing the current limit of 10 wolves per Kantishna permittee - perhaps to one - might provide a solution. To the contrary, anything short of a complete prohibition would likely compound the problem. A reduction in the limit would prompt some of the Kantishna permittees to try to kill a wolf each year simply to establish a tradition of wolf-hunting in Kantishna; they would view this as a way to prevent a complete prohibition at some future point. You have to know these folks personally to fully appreciate that they would do this not with any subsistence intent but out of paranoia about the feds taking away another God-given right. It should also be remembered that the group in question, Swift Northeast, is small enough and currently has such dependent (runt) pups that it wouldn t take more than one or a few hunters shooting one wolf apiece to do major damage. As I indicated, there is extensive peer-reviewed, published research from Denali emphasizing the functional importance of groups from behavior, predation, and system standpoints. Wolves differ markedly from moose, caribou, and many other species in this regard. Shooting just one key wolf in a group such as Swift Northeast (which itself is one of only about 15 groups of wolves in Denali) stands to have disproportionately much greater biological consequences, at multiple scales. For example, a trapper killed the primary breeding female of the Toklat/East Fork family group in 2005. Her close mate, the alpha male, returned repeatedly to the trapping area obviously distressed and trying to find her, then finally abandoned the established territory on his own and was shot shortly thereafter. Absent the experienced adults, the six surviving Toklat one- and two-year-olds reproduced but have since used only a small, probably unsustainable, portion of the established territory, and a neighboring group is expanding into the rest. None of this can be considered natural or acceptable, especially in a world-class national park and international biosphere reserve and for the frivolous uses being claimed. Sincerely, Gordon C. Haber, Ph.D.