Proposal 141 � Implementation of Black Bear Trapping Regulations and Seasons
Submitted by the Alaska Department of Fish & Game
Board of Game Meeting Region III March 2-11

Read the proposal in the proposal book at THIS LINK

Why we strongly OPPOSE proposal 141

(Note: the recent reclassification of black bears as also being furbearers in order to allow for the sale of black bear hides and parts (excluding galls) as a new incentive for hunters to harvest more bears in no way forces the board or otherwise puts the board under any obligation to authorize any bear trapping seasons anywhere in Alaska.)

This proposal and recommendations from the Alaska Department of Fish & Game to legalize �black bear� trapping seasons in some areas of interior Alaska by the public is fraught with inconsistencies, 180-degree position shifts, lack of sound wildlife management principles having to do with any real efficacy in any new bear trapping seasons leading to measurable increases in moose recruitment and densities, and offers no protections for the grizzly bears the proposal admits would also be caught in foot snares set for black bears.

It�s important to recognize that nowhere else in North America is it legal to trap/snare black bears under a general trapping season in areas where grizzly bears are also present. We believe there is a good and valid reason for that, having to do with conservation concerns for grizzly populations, the ecological and economic importance of grizzly bears, the ethical and safety concerns of trapping grizzly cubs and sows with cubs, and public perception and acceptance of trapping grizzly bears.

�Incidental� Catch of Grizzly Bears

The only real data we have so far in Alaska as to the overall percentage of grizzly bears that may be caught in bucket snares set for black bears in areas where both black and grizzly bears are present comes from the experimental snaring program in the Unit 16B bear control area, conducted under the supervision of a paid contractor and experienced volunteer trappers who underwent an ADFG orientation course and in-the-field training.

The snaring itself was conducted by these permittees out of bear snaring camps in mostly remote locations with ADFG personnel present to tranquilize and release any grizzly bears captured. Snares had to be checked a minimum of every 24 hours. The Department was supposed to pre-screen snaring sites in order to choose areas where grizzly bears were not as prevalent.

Prior to changes in the Unit 16B bear control plan that actually targeted grizzly bears in a portion of the unit, the average take of grizzly bears in sets specifically intended to catch black bears and minimize grizzly catches was 10%.

What the "experimental" black bear snaring program proved beyond a doubt was something that was already assumed, and that was discussed by the Board in 2009 deliberations � that it is impossible for even trained participants to just catch black bears and never catch a grizzly in areas where both species are present.

So here we have not just the potential, but a guarantee that if "black bear" trapping/snaring seasons are ever authorized in Alaska, some grizzly bears will also be caught by independent trappers. Legalizing black bear snaring in essence is also to legalize grizzly bear snaring, even if the state mandates forfeiture of any grizzlies killed at snaring sites, declaring the keeping of those animals to be technically �illegal.�

So if 5AAC 92.260 is to ever allow for the taking of �black bear� sows with cubs, and cubs, by any �black bear� trapper during an open trapping season, since grizzly bears are members of the same Ursidae family being specifically targeted and there is a 100% guarantee that some grizzly bears will also be caught, it would seem that the Board would also have to legalize the taking of grizzly bear cubs, or sows with cubs.

Or provide the same kind of protections to grizzly bears we initially did in the Unit 16B bear control area, by only allowing bear trapping to take place under the oversight and presence of trained professional biologists authorized and trained to tranquilize any captured grizzly bears.

Other Issues to Consider with this Proposal

There are several concerns we have in how this proposal is worded, just what it would allow for under the new statutory language, and the possible outcomes.

Aircraft use: We oppose the use of aircraft to establish and visit snaring sites unless the pilot/trappers remain at the site. The mandate to check sites every 24 hours, or even every 48 hours as the department is now proposing, is basically an ethics issue on how long we consider is ethical for a live bear to be caught in a foot snare. Given the real world reality of how fast Alaska flying conditions can change, if we allow aircraft to be used for bear snaring, it is a certainty that the minimum check time will at times not be met. And it could easily be a week at times before flying conditions improve enough to get back to check snares.

Same-day-airborne, spot from the air, land and shoot: Under a trapping license according to this proposal, in areas where trapping may be authorized, is an allowance for pilots to spot black bears from the air, that aren�t at snaring sites, and then land and shoot the same day. We oppose that provision and don�t think it should be a part of any bear trapping regulations.

Unlimited number of snare sets: The allowance for trappers to set an unlimited number of bucket snares in an open bear trapping area could lead to problems among some who decide to make a lot of sets in differing parts of a unit in meeting the minimum check time and in more incidental catches of grizzly bears. Even in Maine and Canada where black bear foot-snaring is allowed, there are strict limits on the number of sets a trapper can run.

Lack of sealing requirements in this proposal: A new program like this should have some means of strictly monitoring harvests even in areas where sealing of bears is not required.

Forfeiture of grizzly bears killed at snaring sites: We know that some grizzly bears will be caught in snares set for black bears. At times this could include a number of grizzly bears should a cub be captured and then the mother and any other cub need to be dispatched. Given the time it takes to properly skin a grizzly bear and remove the skull for sealing/forfeiture, and the likely distances involved to pack/haul the hide(s) and skull(s) out, and in some areas the lack of any ADFG personnel or office to turn these parts over to the state, and the fact that after a predetermined number of grizzlies are caught in a unit the trapping program would be shut down, we believe there is the real potential for some to simply not report grizzly captures/kills at snaring sites.

Nonresident participation: AK BHA strongly opposes any nonresident participation in any bear trapping seasons. And interestingly, the department in 2009 strongly opposed nonresident participation in any aspect of the black bear control program in Unit 16B: "The department is opposed to the participation of nonresidents in any control program because of the similarity in costs associated with sport hunting and control activities (i.e., non-resident license and tag fees, transportation costs, etc.). Also, the perception that hunting by non-residents is the same as non-resident control activities would blur the distinction between the two activities thereby jeopardizing the current public support for sport hunting and control programs."

Permitting Requirements, Costs, and Oversight: Participation in the black bear foot-snaring efforts in the Unit 16B bear control area requires an ADFG orientation course and in-the-field training, and participants must be experienced trappers. There is also department and paid contractor oversight of those snaring efforts and the ability for department personnel to release any captured grizzly bears.

This proposal leaves the decision on any permitting requirements for a general bear trapping season to the board�s discretion. And there is no oversight whatsoever required out in the field. Does the department have the funding to conduct the same kind of orientation courses and in the field training for permittees should this proposal pass? Would applicants undergo the same level of scrutiny?

The department stated that this proposal is in part to �experiment with bear trapping techniques as a management tool.� Which is what the department also stated the Unit16B bear snaring control efforts were in part about. Why then should this brand new allowance for the public to trap bears have any less scrutiny, permitting requirements, and oversight than the 16B snaring program? Or no means to release captured grizzly bears?

Public Perception of Bear Trapping in Alaska

Few would deny that the notion to allow the trapping of black and grizzly bears, including sows with cubs, and cubs, in parts of Alaska under a general trapping season is highly �controversial.�

The fact that such a recommendation comes from our own Alaska Division of Wildlife Conservation and thus has the ostensible backing of numerous professional biologists and managers makes it even more so.

Black bear foot-snaring is legal in Maine and a few Canadian provinces where grizzly bears aren�t present. The snares must be checked a minimum of every 24 hours, as this is considered the �ethical� standard time period that a live bear can be caught in a snare. (The department recommends doubling that to a two-day minimum check time in this proposal.)

The claim can be made that in Maine and the few Canadian provinces where it is legal to foot-snare black bears that there is little controversy over those regulations. Whether that is true or not has absolutely no bearing on how controversial it would be in Alaska where grizzly bears are also present and would be caught.

We are certainly not alluding that the Board should base decisions solely on whether or not they may be controversial. However, it is our strong belief that the majority of hunters and trappers in Alaska do not support bear trapping seasons or the snaring of any bears outside any formal bear control implementation plans.

And we have fears we think are entirely valid that opening up bear trapping to the general public by independent trappers, that includes the allowance for trappers to kill any captured grizzly bears and other family members that may be present at a snare site � even if those bears must be forfeited to the state � has the real potential should pictures and stories make their way to the internet and media, to cause a backlash to the hunting and trapping community, to the reputation of the department and the board and in how the rest of the country views Alaska and our system of wildlife management.

Other Solutions to Increase Bear Harvests

The board has tried to provide an incentive for hunters to harvest more black bears by reclassifying them as furbearers so as to allow the sale of hides and claws and skulls.

We think the board should slow down on approving more extreme solutions like bear trapping seasons before we�ve even given this new incentive time to show results, and recommend that the Board also discuss and consider other possible solutions to try to get hunters to harvest more black and grizzly bears in areas where moose densities are below objectives and bear predation is a primary factor.

We have heard a number of different ideas on how to increase incentive and harvest of bears under more traditional hunting methods and means, some of which the board has already authorized in some areas, such as SDA for hunters who want to fly (fixed wing) to a bait station and be able to take a bear the same day they land, longer black bear baiting seasons, and the allowance for more bait stations.

Other newer ideas range across the spectrum, from preference points of some kind for hunters who take a predator from a certain unit, to less restrictive ways to try to hunt bears over gutpiles or carcasses in the fall, to possible bear �derbys�. And the board is continually voting on various proposals over the last several years that ask for grizzly bear baiting in certain units.

Part of the education efforts we�d like to see is for the board and the department and groups to reinforce that black bears (and grizzlies) in the interior especially are good healthy sources of game meat all summer long. And certainly black bears throughout the state are a great source of game meat in the spring.

Final Thoughts on ADFG Proposal 141

What was bear �control� yesterday simply cannot be relabeled as a new management tool today, whereby the process and requirements and monitoring and oversight by which we have in the past conducted any bear control programs is suddenly waived.