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Pack Llamas Under Siege on Alaska's Public Lands (Updated)




Lost Lake Trail (Chugach National Forest) and Resurrection Bay 

Pack llamas have historically played an important role on our public lands. They are used both recreationally and commercially as sure-footed pack animals. They are also used by public agencies for trail and park maintenance as they do in Rocky Mountain National Park.  However, there have been proposals by some government agencies to ban llamas from our public lands based on a perceived "disease threat" to wildlife that is not scientifically defensible.

Proposed Llama Bans in Alaska (Past and Present)
In 2012, the Alaska Board of Game (BOG) took action to ban domestic goats, sheep, and llamas for use in hunting wild goats and sheep. The Alaska Department of Fish and Game (ADF&G) reviewed the science behind the BOG action and recommended against inclusion of llamas. The BOG agreed with ADF&G and removed llamas from that regulation which remains in place to this day.

In January 2015 the National Park Service proposed a ban on domesticated sheep, goats, alpacas and llamas in all Alaska national park jurisdictions having wild sheep and/or goat populations. After a public comment period ended in February 2015, domesticated sheep and goats were banned, but the pack camelids (llamas and alpacas) were still allowed in Alaska’s national parks with written permission from Alaska’s park superintendents.  Pack Llamas Get OK After Proposed Ban in Alaska National Parks.

In 2015, the US Fish and Wildlife Service (USFWS) imposed a prohibition that included domestic sheep, goats, and llamas in the Arctic National Wildlife Refuge (ANWR). Up to that time pack llamas enjoyed historic pack animal status as do horses.  USFWS failed to notify the llama community of their proposal to prohibit pack llamas. This effectively eliminated any objections from the llama community during the public comment period associated with this proposed rulemaking and banned an historic user group.

In April 2020 the USFWS Arctic National Wildlife Refuge (ANWR) announced  "additions and revisions to station-specific regulations in order to expand hunting and sport fishing opportunities for the 2020-21 hunting and sport fishing season." (According to their website, "the USFWS operates hunting and sport fishing programs on refuges to implement the National Wildlife Refuge System Improvement Act of 1997 directives to facilitate compatible priority wildlife-dependent recreational opportunities.")

Due to this latest proposed USFWS rulemaking, there was an open public comment period for this regulation package which ended June 8, 2020. The ANWR pack llama prohibition appeared in the current ANWR Comprehensive Conservation Plan (CCP) which is the guidance document for the proposed regulations. (More details here - USFWS Attempting to Ban Pack Llamas in ANWRThe llama community participated in the public meeting and provided over 75 pages of substantive comments objecting to USFWS's pack llama prohibition based on an unsubstantiated "disease threat." Comment and public testimony clearly demonstrated the USFWS perceived camelid disease risk was not supported by science. Furthermore it was pointed out that USFWS violated the NEPA process. (More info on this under the Blog's Public Lands subtitle - https://www.alaskallamas.com/search/label/Public%20Lands%20%26%20Llamas)

In spite of the llama user group's gallant effort, USFWS recently came out with a final rule effective August 31, 2020 which prohibits/bans use of pack llamas (camelids) in Arctic National Wildlife Refuge (ANWR). The llama industry is currently examining options (including legal) to reverse this decision by the USFWS. Here's a link to the entire final rule on the Federal Register -https://www.federalregister.gov/documents/2020/08/31/2020-16003/2020-2021-station-specific-hunting-and-sport-fishing-regulations

In December 2016, the Bureau of Land Management (BLM) approved the Eastern Interior Resource Management Plan (EIRMP) which prohibits the pack llama (camelid) user group from accessing lands in or near Dall’s sheep habitat within the Eastern Interior Resource Management Area (RMA). Again, like the USFWS-ANWR rulemaking that preceded it, the llama community was unaware of any BLM proposed rulemaking concerning llamas so the rule became final without objection. Subunits within the Eastern Interior RMA include Forty-mile, Steese, Draanjik and White Mountains. For more information, read the article published in Alaska Outdoor Council (AOC) 2018 Spring Newsletter (Click on the link and go to page 6.) Pack Animals Denied on BLM Lands in the Eastern Interior RMP.

In 2019, Chugach National Forest (CNF) attempted to ban pack llamas for commercial use based on a perceived "disease threat" to wild sheep and goats. CNF "short circuited" the NEPA process by providing no public notice to eliminate commercial use of pack llamas when their Draft Chugach National Forest Land Management Plan was open for public comment in 2018. The verbiage to ban llamas was added into the Final Chugach National Forest Land Management Plan (CNFLMP) after the public comment period was closed which effectively eliminated comment by the pack llama user group. The pack llama user group was faced with protesting the final CNF decision – a much more onerous task.

Also at issue was CNF's ban on commercial use of pack llamas based on the misperception that they pose a disease threat. This opens the door to eliminate them for all uses (including recreational) in the future. This is an old and tiresome argument that has been debunked in the past but still continues to rear its ugly head from time to time. The "llama disease" misperception was discussed at length during a public meeting held in January 14, 2020. 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. However, CNF (and other federal agencies) place no restrictions on horses based on a hypothetical disease risk. (Supporting documentation at https://www.packllamas.org/)

The lack of consistency between government agencies was also noted. Meeting participants pointed out that the State of Alaska, Department of Fish & Game (ADF&G) has studied the issue extensively and is not limiting the use of pack llamas in sheep and goat habitat. ADF&G is the government agency best equipped with qualified staff 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?

On January 28, 2020 Chugach National Forest (CNF) announced their decision to rescind the llama ban in Chugach National Forest. The "Reviewing Officer's Response to Eligible Objections" to the Chugach National Forest Land Management Plan (CNFLMP) was attached to an email sent to objectors. David Schmid (CNF Regional Forester) stated in this email: "I am also instructing Forest Supervisor Schramm to remove references to llamas (or lamas) as potential vectors for the transfer of pathogens to Dall sheep or mountain goats from the FEIS. This may be completed in an errata to the FEIS." Verbiage related to llamas will be removed as objectors requested in the final Record of Decision.

The Record of Decision was signed in April 2020. As stated in an email communication dated 4/17/20 from Jeff Schramm, Forest Supervisor: "After 30 days, the Plan will be implemented and will guide all management decisions and activities on the Forest." The 2020 Land Management Plan and associated documents can be found on the Forest website at: https://www.fs.usda.gov/detail/chugach/landmanagement/planning/?cid=stelprdb5408185.

Pack Llamas on Alaska's Public Land
In 2012, the Alaska Department of Fish and Game (ADF&G) looked at the same Canadian studies (upon which BLM, CNF, USFWS and NPS based their decisions) and came to a completely different conclusion. This ADF&G position (llamas are OK in wild sheep and goat habitat) was reaffirmed again in 2018. As stated in the June 11, 2018 ADF&G Letter - "at this time we have no intention to promote or support limiting the use of South American camelids on public land in the State of Alaska”.

This decision was made by ADF&G despite the fact that they helped finance a subsequent camelid disease report (CCH-17) authored by the Canadian Centre for Coastal Health (CCH) and completed in 2017. The ADF&G letter states “there is no significant information in the RA.  After discussing the document internally and with other biologists from several jurisdictions (including the Western Association of Fish and Wildlife Agency Wild Sheep Work Group - WSWG), we will continue to focus and enhance our evaluation of disease risk from species other than llamas or related camelids. There is not enough information presented in this report or other current publications to warrant spending additional resources on this issue.” Furthermore, the ADF&G letter states “we understand that the WSWG pulled the RA report from their website partially due to some concerns about the report itself.” It's also worth noting that CCH-17 has not undergone a formal peer review or been published in a scientific journal.  A copy of the ADF&G letter is posted at this link:  https://www.packllamas.org/pdf/akban/alaska_department_fish_game_to_gala_06-11-18.pdf

Historical Use of Pack Llamas on Public Lands
Rocky Mountain National Park
In contrast, pack llamas have a long history in national parks such as Yellowstone and Rocky Mountain which have sensitive wild sheep and/or goat habitat. Park personnel in Rocky Mountain National Park have been using llamas for packing and trail maintenance for over 30 years. (Photo - RMNP)

For more on this go to these articles - CleaningToilets Amid 'God's Splendor' (Star Tribune) and Just a Beautiful Day, Gone to Waste (Denver Post).

The Shoshone National Forest Land Management Plan Revision FEIS Volume II states “Pack animals that do not pose disease transference issues including llamas, horses, donkeys, and assistance dogs are not restricted for use by elderly forest visitors.”  As originally proposed, the recent CNFLMP  would have been inconsistent with USDA Forest Service policy regarding the “pack llama disease issue” in other Forest Service jurisdictions. (However as noted above, llamas will not be included or banned in the amended CNFLMP.)

Taxonomic Separation and Disease Epidemiology of Llamas
Facts concerning taxonomic separation and disease epidemiology of llamas are being disregarded by those advocating llama bans. Llamas are from the family Camelidae while wild sheep, domestic sheep, and goats are from the family Bovidae. Their evolutionary pathways diverged beginning 40 million years ago. Consequently, strong species barriers (similar to horses) make llamas extremely unlikely to transmit disease as compared to goats and sheep.

Furthermore, science has shown that llamas are less likely to transmit disease to wildlife than other pack stock such as horses or mules. Ironically these are the very animals that are considered to be the preferred species by federal agencies. However, horses (equine species) are a greater disease risk than llamas as they have a number of endemic disease susceptibilities (equine influenza, equine encephalomyelitis, equine herpesvirus rhinopneumonitis-EHV, Potomac Horse Virus, vesicular stomatitis, strangles, etc.) and are overall less healthy than llamas.

On the other hand, llamas have no identified endemic diseases and are naturally healthy and disease free. Both llamas and horses have been pen-tested with wild sheep and shown to not carry nor transfer the pathogens that are lethal to wild sheep. However, horses are less healthy overall and can carry respiratory infections secondary to their primary endemic infections that could be transferrable to wild animal populations including wild sheep. Additionally, llamas have an exceptionally strong, broad spectrum immunologic system such that their serum is being considered in development of flu vaccines for humans that give a wider spectrum and more enduring protection. (See Antibody Derived From Llamas may Provide Cure for Human Diseases.) All current information and history indicate llamas present less disease threat to wild sheep than horses and humans that develop zoonotic infections (TB, MAP, and CE) which can be transmitted to wild sheep.

Commentary on the History of Perceived “Llama Disease” Threats
The North American llama community comprised of 3000+ llama owners and users represented by the Greater Appalachian Llama & Alpaca Association (GALA), the International Llama Registry (ILR), and the Rocky Mountain Llama Association (RMLA) formed a "watchdog" committee and website to serve as a repository of scientific information about pack llamas to clarify and resolve any misconceptions concerning perceived disease issues. A forty-one (41) page "commentary" on their website www.packllamas.org provides a detailed response to these scientifically unfounded proposals and documents the history of perceived "llama disease threats."

In conclusion, some government agencies are prohibiting pack llamas on Alaska's public lands due to a perceived "disease risk" which is not based on science. The danger is that these Alaskan government agencies may set a precedent that will ultimately be applied on public lands in the lower 48 states. Therefore it's imperative that pack llama owners and anyone who uses our public lands remain vigilant and make their voices heard through the public process. (**Updated 2/28/20)

Published in the Llama Association of North America Spring (LANA) Newsletter -
LANA Spring 2020 Newsletter

Chugach State Park, Alaska (Photo by Linda Nuechterlein)




Related reading at these links-
-Respiratory Pathogen "Movi" Documented in Additional Species in Alaska Is Also Implicated in Alaska Caribou Death - ADF&G Press Release 

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