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USFWS Attempting to Ban Pack Llamas in ANWR

We need your help again. The U.S. Fish and Wildlife Service (USFWS) Arctic National Wildlife Refuge (ANWR) recently announced that it is proposing to eliminate the pack llama (camelid) user group as part of a proposed regulation package. This is yet another attempt (in Alaska) to ban camelids as a disease threat to wildlife that is scientifically untenable. Because of your help earlier this year we were able to defeat a similar proposal by the U.S. Forest Service in Alaska (Chugach National Forest). Your participation will be critical in order to win this next battle. Again, this could set a precedent and adversely affect our future access on public lands throughout all of the United States if allowed to stand. Please object to this proposal by submitting a comment as per the instructions below.  Thank you in advance for your support!

You can submit a comment on this
to the U.S. Fish and Wildlife Service in one of two ways described below. All comments need to be submitted on or before the June 8, 2020 deadline. (USFWS will not accept emails or faxes.)

1) By letter (hard copy): 
Letters must be received/postmarked on or before June 8, 2020 & sent to:
          Public Comments Processing, Attn: FWS-HQ-NWRS-2020-0013
          U.S. Fish and Wildlife Service
          5275 Leesburg Pike, MS: PRB/PERMA (JAO)
          Falls Church, VA 22041-3803

2) Electronically:  
-Go to In the search box, type in FWS-HQ-NWRS-2020-0013, which is the docket number for this rulemaking. Then, click on the search button. On the resulting screen, find the correct document "2020–2021 Station-Specific Hunting and Sport Fishing Regulations" and submit a comment by clicking on “Comment Now!”

-Or go directly to the document at this link: & click on “Comment Now!”

Note*** On Tuesdays and Thursdays users will be redirected to a beta site. To make a comment on those days use this link instead  -

To view comments made by others concerning the pack llama ban click - Llama Ban Comments

See Tips For Submitting Effective Comments.pdf.
NOTE: It's best to submit an original comment. However, if you are not able to do so, you may use the sample comment (below) verbatim or use it as a starting point to craft your own comment (preferred).

1) We (as a user group) were not informed of the 2015 public review process that prohibited our historical user group, llama packing, from recreating on the ANWR. We should have been included in that discussion and NEPA process that takes away this public land use.
2) Llamas and horses are both widely separated from wild sheep taxonomically and consequently enjoy strong species barriers against disease transmission. The U.S. Fish and Wildlife Service (USFWS) failed to recognize this by miscategorizing camelids with domestic sheep and goats as a common disease risk. Domestic sheep and goats (bovids) are not widely separated from wild sheep (also bovids) taxonomically, consequently they do not enjoy the same species barriers against disease transmission to wild sheep that horses and llamas do.
3) The USFWS failed to provide credible scientific evidence that implicate camelids as a disease threat to wildlife in ANWR or that camelids pose a greater disease transmission risk than horses. (Horses are not prohibited in ANWR). U.S. scientific literature regarding the pack llama’s excellent safety record (including bovid disease resistance and historical federal land use) is well documented but is not cited in this proposal. Wild sheep are bovids. It appears that the USFWS may have arbitrarily chosen to prohibit one of the least likely animals to spread disease to wildlife in ANWR in their effort to pursue precautionary measures.
4) The USFWS states that this proposed ANWR regulation is better aligned with Alaska Department of Fish and Game (ADF&G) regulations. This is not an accurate statement regarding camelids because ADF&G regulations do not prohibit the use of camelids anywhere in Alaska including ANWR. ADF&G has the staff, expertise, and resources to properly evaluate disease threats to wildlife. They have studied the camelid disease issue extensively and have elected to allow camelids (pack llamas) statewide without restrictions.
5) Furthermore, the USFWS states the proposed prohibition better aligns with the 2012 recommendations from the Western Association of Fish and Wildlife Agencies (WAFWA). WAFWA 2012 recommendations do not include a prohibition of camelids. So this proposed regulation is not aligned with state regulations nor the WAFWA as claimed by the USFWS.

In conclusion, this proposed regulation does not expand public use opportunities as intended. It instead restricts these activities in remote areas where pack animals might be necessary for public access. By this letter I am providing formal notice of objection to the proposed regulation that prohibits pack llamas (camelids) in ANWR.

Resolution: Specifically, I request that USFWS refrain from identifying camelids (pack llamas) as a disease threat and remove all reference in the proposed regulations and planning documents that implicate them as a disease threat.

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