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. h
ttp://alaska.fws.gov/nwr/planning/nepa/pdf/izembek_ea.pdf Email comments to

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).