Call to action in opposition to the USFWS Unimak Island predator control
Draft Environmental Assessment.   This proposed action to allow Alaska
Fish&Game to kill wolves from helicopters or fixed-wing aircraft in a
Congressionally-designatged wilderness area in the Maritime Refuge NWR
would be a major breach of the Wilderness Act and USFWS guidelines for
predator control.  If it is not prevented, it will cause great harm and
establish unacceptable precedents for predator control, wilderness, and
the entire National Wildlife Refuge System.   This EA from USFWS is
probably the worst piece of work  ever to justify an unacceptable action.
 The link to the FWS Environmental assessment. 
http://alaska.fws.gov/nwr/planning/nepa/pdf/izembek_ea.pdf  Email
comments to 
[log in to unmask]   Deadline is January 31. 
 Legal Concerns
1.      The EA fails to analyze a full range of reasonable alternative
actions as required by the National Environmental Policy Act.
2.      The proposed actions and population goals far exceed what is
necessary to meet the purpose of the EA or the purposes of the refuge
under ANILCA.
3.      The proposed actions violate the Wilderness Act because the
actions are not the minimum requirement necessary for managing
Wilderness.
1.      The EA fails to evaluate how the action will affect subsistence
use as required by ANILCA.
2.      The EA may violate the Refuge Improvement Act.



Biological/Scientific Concerns
1.      The EA fails to demonstrate that predation is the primary cause
for the recent decline in the caribou population.
2.      Bear predation is dismissed as a potential factor, even though a
high density of bears exists on the island.
3.      The EA fails to provide evidence that the long-term persistence
of caribou herd is threatened by current conditions.
4.      The caribou herd is not genetically isolated from other herds;
temporary loss of this herd has occurred in the past.
5.      Wolf surveys have not been conducted on the island; the EA fails
to explain how ADF&G (the responsible agency) will insure viable wolf
populations will remain.
6.      The EA fails to evaluate carrying capacity or provide information
on what the optimal size of the herd should be in order to provide
subsistence use and insure caribou viability.
Policy Implications
1.      Action on this EA would represent the first time state-sponsored
wolf control was allowed on FWS lands and could result in increased
proposals for wolf control on other federal lands.
2.      Action on this EA for the purpose of providing subsistence
hunting opportunity will set precedent under the Alaska National Interest
Lands Conservation Act (ANILCA) for all federal lands where hunting is
allowed, including FWS and National Park Service units.
3.      Action on this EA will set a precedent for the types of activity
and manipulation allowed in Wilderness.
Recommendations
1.      We recommend FWS take No Action on this EA as it is insufficient
from a biological, technical and policy standpoint.
2.      As required under the Wilderness Act and ANILCA the No Action
alternative must be amended to reflect that naturally occurring caribou
and wolf populations are desired, rather than ADF&G’s current goals of
1,000 caribou and 8-15 wolves.
3.      Unless the FWS chooses the No Action alternative – with the
amendments described above – the FWS should proceed with a full
Environmental Impact Statement (EIS).

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