The Chugach National Forest (CNF) "objections resolution meeting" took place during the afternoon of January 14, 2020 in Anchorage, Alaska. (See previous posts for background on CNF Llama Ban.) The purpose of the meeting was to discuss remedies regarding objections to restrictions on the use of llamas that are being imposed in the Chugach National Forest Land Management Plan (CNFLMP). Dave Schmid, Alaska Regional Forester (meeting facilitator) confirmed that this is our last opportunity to comment/object to the Chugach National Forest Land Management Plan which will be final in 2020. Meeting attendees representing the llama community in-state and out-of-state participated via teleconference and reiterated concerns to CNF staff that were previously expressed in their written objections which can be found here.
https://cara.ecosystem-management.org/Public/ReadingRoom?project=40816.
At issue is the restricted use of pack llamas in Chugach National Forest (the forest) based on a misperception that pack llamas pose a disease risk to wild sheep. This is an old and tiresome issue that has been debunked in the past but still continues to rear its ugly head. The "llama disease" issue was discussed at length and CNF staff were unable to provide credible scientific research (old or new) for their pack llama prohibition based on a camelid disease risk to wildlife. To the contrary, it was apparent that overwhelming evidence exists demonstrating pack llamas pose no more of a disease threat (probably less) to wildlife than horses due to their taxonomic separation. (Supporting documentation is available at www.packllamas.org*) However, CNF (and other federal agencies) place no restrictions on horses based on a hypothetical disease risk. Therefore, the onus is on CNF to provide scientific documentation/defense of their decision to prohibit llamas. Otherwise, in all fairness the prohibition must be rescinded, or extended to horses (and other domestic animals) that may come in contact with wildlife.
The lack of consistency between government agencies also came up during the discussion. Commenters pointed out that the State of Alaska, Department of Fish & Game (ADF&G) has studied the issue extensively and concluded that pack llamas are not a disease threat to wild sheep. ADF&G is the government agency best equipped with scientists and resources to examine the issue. Why would CNF decide to take this on without the scientific wherewithal when ADF&G has already done the science and does not view llamas as a disease threat? See ADF&G letter posted here:
https://www.packllamas.org/pdf/akban/alaska_department_fish_game_to_gala_06-11-18.pdf
Also at issue is that the Draft EIS did not specifically include restrictions on pack llamas. The llama prohibition was later added to the Final EIS after the public comment period. This is a significant (and perhaps fatal) procedural error on the part of CNF and it's unclear at this point how CNF will remedy this during the resolution process. Since CNF did not follow NEPA process, the logical (and legal) remedy is that pack llamas (and any restrictions) be removed from the final CNFLMP. The final forest plan should not go forward "as is" if llamas are included because llamas were not addressed in the Draft Chugach Land Management Plan and the public was not afforded the opportunity to comment (very disturbing.) In all fairness, CNF needs to remove llamas from the plan; otherwise they should scrap this LMP, start over and follow the NEPA process. Meeting attendees and objectors have repeatedly requested that CNF remove all references in the EIS, ROD and LMP that indicate llamas pose a" disease risk." This is the remedy, plain and simple.
*Supporting documentation that clearly demonstrates llamas pose no disease risk to wild sheep is posted on https://www.packllamas.org/. If you haven't checked-out this website, I encourage you to do so. It is the most complete repository for " research, scientific data, and information related to the scientifically unfounded proposals and current bans of pack llamas on our public lands."
https://cara.ecosystem-management.org/Public/ReadingRoom?project=40816.
At issue is the restricted use of pack llamas in Chugach National Forest (the forest) based on a misperception that pack llamas pose a disease risk to wild sheep. This is an old and tiresome issue that has been debunked in the past but still continues to rear its ugly head. The "llama disease" issue was discussed at length and CNF staff were unable to provide credible scientific research (old or new) for their pack llama prohibition based on a camelid disease risk to wildlife. To the contrary, it was apparent that overwhelming evidence exists demonstrating pack llamas pose no more of a disease threat (probably less) to wildlife than horses due to their taxonomic separation. (Supporting documentation is available at www.packllamas.org*) However, CNF (and other federal agencies) place no restrictions on horses based on a hypothetical disease risk. Therefore, the onus is on CNF to provide scientific documentation/defense of their decision to prohibit llamas. Otherwise, in all fairness the prohibition must be rescinded, or extended to horses (and other domestic animals) that may come in contact with wildlife.
The lack of consistency between government agencies also came up during the discussion. Commenters pointed out that the State of Alaska, Department of Fish & Game (ADF&G) has studied the issue extensively and concluded that pack llamas are not a disease threat to wild sheep. ADF&G is the government agency best equipped with scientists and resources to examine the issue. Why would CNF decide to take this on without the scientific wherewithal when ADF&G has already done the science and does not view llamas as a disease threat? See ADF&G letter posted here:
https://www.packllamas.org/pdf/akban/alaska_department_fish_game_to_gala_06-11-18.pdf
Also at issue is that the Draft EIS did not specifically include restrictions on pack llamas. The llama prohibition was later added to the Final EIS after the public comment period. This is a significant (and perhaps fatal) procedural error on the part of CNF and it's unclear at this point how CNF will remedy this during the resolution process. Since CNF did not follow NEPA process, the logical (and legal) remedy is that pack llamas (and any restrictions) be removed from the final CNFLMP. The final forest plan should not go forward "as is" if llamas are included because llamas were not addressed in the Draft Chugach Land Management Plan and the public was not afforded the opportunity to comment (very disturbing.) In all fairness, CNF needs to remove llamas from the plan; otherwise they should scrap this LMP, start over and follow the NEPA process. Meeting attendees and objectors have repeatedly requested that CNF remove all references in the EIS, ROD and LMP that indicate llamas pose a" disease risk." This is the remedy, plain and simple.
At this point, it is unclear how CNF will rectify this procedural error. Schmid did not offer anything definite on that. He indicated the next step would be for CNF staff to consider comments and respond (presumably in writing) to the llama community objections. He anticipated that the final ROD would be published by April or May 2020.
Thanks to all who participated in this meeting. And a special thanks to the Llama Association of North American (LANA) President, Dr. Michelle Kutzler, DVM who took time from her busy teaching schedule at Oregon State University to participate. Her input was invaluable.
*Supporting documentation that clearly demonstrates llamas pose no disease risk to wild sheep is posted on https://www.packllamas.org/. If you haven't checked-out this website, I encourage you to do so. It is the most complete repository for " research, scientific data, and information related to the scientifically unfounded proposals and current bans of pack llamas on our public lands."
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