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Showing posts from May, 2020

NEPA Violations by USFWS Exposed - Arctic National Wildlife Refuge

Excerpt from Objection to ANWR Pack Llama by Scott Woodruff (Lander Llamas)

Thank you for this one and only meaningful opportunity to publicly comment on the prohibition of pack llamas on our public land in the Arctic National Wildlife Refuge (ANWR) based upon the threat of disease transfer to wildlife. Specifically, the proposed regulation change to 50 CFR part 36 published in the Federal Register on April 9th, 2020 with relationship to cited justification in the 2015 Record of Decision (ROD) for the Arctic National Wildlife Refuge Revised Comprehensive Conservation Plan (CCP), and also new and recent submitted information and research outside of the ROD in 2015, by USFWS and ANWR.

In 2010, the ANWR sent out a notice of intent to revise the 1988 Arctic National Wildlife Refuge Comprehensive Conservation Plan (1988-CCP). The subsequent public development of the new document Artic Refuge Draft Revised Comprehensive Conservation Plan (DCCP) was submitted for comments. In the DCCP, llamas …

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

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 llam…

Precautionary Principle and Pack Llamas

The "precautionary principle" originated as a strategy to deal with possible risks where scientific understanding/study was not yet complete (i.e. nano technology and genetically modified foods.) However, the precautionary principle (precautionary approach) has also been used by policy makers to justify discretionary decisions in situations where there is a possibility of harm from making a certain decision when they deem there is inadequate scientific knowledge.

Why Should I Care?
The danger is that a precautionary (no risk) principle/approach fails to recognize there is no such thing as zero risk. For example, a scientific risk assessment recognizes the existence of "risk" and attempts to quantify it. The objective is to determine the likelihood of something happening and the consequences. Although science can provide a high level of confidence it can never provide absolute certainty. The precautionary principle places an impossible burden of proof on the user gr…

Rendezvous Ridge

Here's a hike in Chugach State Park (Southcentral Alaska) with spectacular views on a clear day. I prefer to access this hike from the South Fork trailhead although there is also access in Arctic Valley.

To get to the South Fork trailhead access, take the Eagle River Loop/Hiland Road exit off the Glenn Highway just past the weigh station. Turn right at the traffic light onto Hiland and continue about eight miles up the road. Take a right onto South Creek and follow it to West River Drive and take another right. The parking lot is on your left.

The trail starts out on a boardwalk for a short distance and then turns into a trail that traverses the right side of the South Fork valley as you head away from the parking area. (If you continue on the main trail, it drops down to a bridge that crosses the South Fork of the Eagle River and continues to Eagle and Symphony Lakes at the end of the valley.)

To access Rendezvous Ridge, stay to the right at the junction where the main trail tur…