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Response to the USFWS Proposal to Ban Pack Llamas in the Arctic National Wildlife Refuge


The U.S. Fish and Wildlife Service (USFWS) is proposing a regulatory addition to 50 CFR § 36.39 (k) Arctic National Wildlife Refuge (ANWR) stating that all domestic camelids are prohibited. USFWS concerns that camelids present a disease risk to wildlife in ANWR are clearly misguided and lack scientific evidence. The USFWS proposal to ban pack llamas unfairly eliminates a user group based on the false and misleading portrayal of pack llamas as a "disease threat" to wildlife. Although we have never packed for profit, the USFWS policy implicating pack llamas as a disease threat unnecessarily harms all of us that use pack llamas, including commercial llama packing enterprises in the lower 48 states. Rumor mongering knows no regional boundaries.

The references cited by the USFWS as a basis for this proposed camelid prohibition in ANWR are not credible nor have they been peer reviewed. These same references have been evaluated and dismissed by the Alaska Department of Fish and Game (ADF&G), the Western Association of Fish and Wildlife Agencies – Wild Sheep Working Group (WAFWA-WSWG), and the American Association of Small Ruminant Practitioners (AASRP) representing more than 1000 wildlife experts and veterinary professionals. USFWS concerns for camelids transmitting disease to wildlife are in direct opposition to the regulations and recommendations of these leading wildlife authorities.

HOW THIS PROPOSAL FAILS TO ADHERE TO THE USFWS PURPORTED GOAL OF APPLYING THE BEST SCIENTIFICALLY BASED INFORMATION POSSIBLE IN DECISION MAKING:

As per USFWS website and various communications: “Our goal in promulgation of any regulations is to ensure the use of the best scientifically based information possible in decision making” and “Excellence in science and its application to natural resource decision-making is the hallmark of the U.S. Fish and Wildlife Service.”

USFWS has identified three references as a basis for this proposed camelid prohibition. #1) Garde et al. 2005 #2) Schwantje et al. 2003 and #3) Centre for Coastal Health 2017. The credibility of these USFWS references has been questioned by ADF&G, WAFWA-WSWG, and recognized camelid experts Dr. Murray Fowler and Dr. Larue Johnson. Those issues were adequately addressed in a letter from ADF&G to the Greater Appalachian Llama and Alpaca Association (GALA) dated June 11, 2018, a letter from the late Dr. Murray Fowler to ADF&G dated April 9, 2012, and a letter from Dr. Larue Johnson to British Columbia (BC) Ombudsman dated May 26, 2016.  All three of these letters were provided to USFWS as attachments to a letter from GALA to the Alaska Regional Director dated June 28, 2018. These letters are also posted on the www.packllamas.org website. Alternatively, the ADF&G and Fowler letters can be obtained directly from ADF&G (public record).

A closer look at each of the three reference documents used by USFWS as the basis for this proposed camelid ban reveals that credibility is compromised by the author’s own admission (within each reference document itself):
  1. Garde et al. 2005 on page 2 states, “……there is insufficient data available to clearly assess the role of camelids as a source of disease at this time…..”
  2. Schwantje et al. 2003 on page v Executive Summary states, “Risks from camelids to wildlife in British Columbia remain hypothetical after this risk assessment, as no direct evidence was found to implicate camelids as sources of significant diseases in wildlife in BC or elsewhere.”
  3. Centre for Coastal Health 2017 (CCH-17) per paragraph 3 of the Executive Summary states, ”We found no peer-reviewed publications documenting pathogen transmission from camelids to wild ungulates or to domestic sheep and goats for the identified pathogens.
Reference #1 is the sole reference in the Arctic National Wildlife Refuge Revised Comprehensive Conservation Plan (CCP). References #2 and #3 were included in “Questions and Answers on Proposed Regulation to Protect Dall’s Sheep on Arctic National Wildlife Refuge” on the www.fws.gov website:
Questions and Answers on Proposed Regulation to Protect Dall’s Sheep on Arctic National Wildlife Refuge

None of these USFWS references have been peer reviewed or published in any scientific journals. They are not credible, rather they are hypothetical risk scenarios. To look only for information in support of a USFWS theory (pack llama disease threat) while ignoring all evidence that does not support this theory defies fundamental principles in applying science to decision making. USFWS is apparently focused on supporting their hypothesis and they have closed the door to any degree of objectivity with respect to scientific evaluation of the camelid prohibition proposal. USFWS has chosen to ignore the wealth of US scientific literature that llamas do not pose a disease threat to wildlife. The lack of peer review and credibility questions surrounding these USFWS reference documents in support of a camelid prohibition indicate that USFWS has wandered off course from their stated goal of applying science to decision making.

Regarding the apparent USFWS misunderstanding of fundamental taxonomic principles and how that relates to disease epidemiology - It is incorrect to combine llamas with domestic sheep and goats as a common disease threat to wildlife as USFWS has done throughout this proposal. Taxonomically, camelids are Camelidae family and both domestic and wild sheep/goats are Bovidae family (bovids). Consequently strong species barriers make Camelidae highly unlikely to transmit diseases to Bovidae. The letter from Dr. Murray Fowler to ADF&G adequately addresses this issue. USFWS states that they don’t consider horses to be a disease threat because they have natural species barriers but fails to recognize that camelids enjoy the same reputation having diverged from bovids down separate evolutionary pathways beginning more than 40 million years ago.

Camelids are not new or exotic to North America. They originated in North America before migrating to South America. USFWS favors horses even though pack llamas are much easier on the fragile ANWR environment than horses. USFWS has not offered any scientific evidence that the pack llama user group poses more disease risk to wildlife than the pack horse user group. USFWS proposes to eliminate the very pack animal that according to science presents no more risk than pack horses (probably less) and is the friendliest to the ANWR environment.

Regarding the USFWS assertion of supporting “scientific evidence” for this proposal having been published and peer reviewed, per a letter from the ANWR Deputy Refuge Manager to the Greater Appalachian Llama and Alpaca Organization (GALA) dated April 10, 2020 "the CCH-17 reference has been published and peer reviewed." This is incorrect. I have received written confirmation from the Centre for Coastal Health that CCH-17 ("Risk Assessment on the Use of South American Camelids for Back Country Trekking in British Columbia" - Final Report October 24, 2017) has not been peer reviewed. Furthermore, the remainder of the Canadian references used by USFWS as a basis for this proposal have never been formerly peer reviewed or published in a scientific journal. This has also been confirmed in writing from co-author Dr. Helen Schwantje.

Regarding the USFWS assertion that pack llamas are asymptomatic carriers - USFWS asserts that according to Garde et al. 2005, pack llamas are recognized as asymptomatic carriers of highly contagious disease organisms causing severe illness or death in Dall’s sheep. This appears to be a USFWS misinterpretation of what is stated in Garde et al. 2005. What Garde does say on page 2 is that “…..there is insufficient data available to clearly assess the role of camelids as a source of disease at this time…..”

Regarding the USFWS statement “The risk of disease transfer may be low but the potential impacts could be significant and therefore represents unreasonable risk." In the absence of scientific evidence, USFWS has arbitrarily associated risk with pack llamas and ignored the risk posed by horses that are allowed in ANWR. The potential impacts of disease transfer from mammals other than pack llamas (including horses) are just as significant.

Regarding the USFWS statement “The lack of scientific studies investigating pathogen transmission between camelids and wild sheep does not mean that transmission does not or cannot occur.” This statement is misleading because the same statement can be made regarding other mammals (including horses) that are allowed in ANWR. Pack llamas have been pen tested with wild sheep (Besser, Foreyt – Washington State University).

Regarding the USFWS statement “There is consensus among wildlife biologists and veterinarians that maintaining healthy sheep populations requires that we error on the side of caution by preventing contact between domestic sheep, goats, camelids and wild sheep throughout their ranges.” – The USFWS assertion that there is a “consensus among wildlife biologists and veterinarians” to prohibit camelids in wild sheep ranges is in direct conflict with the ADF&G regulations, the Western Association of Fish and Wildlife Agencies (WAFWA) - Wild Sheep Working Group (WSWG) stated position, and the (AASRP) policy/position statement (see AASRP.org) Policy Statement Concerning Camelid Ban in National Parks regarding camelids. These are leading wildlife biologists and veterinary authorities representing more than 1000 professionals.

Regarding the USFWS statement “USFWS is guided by their own unique set of mandates and policies” “that may differ from ADF&G and WAFWA.” - Principles of disease epidemiology are the same in ANWR as they are elsewhere. USFWS appears to be taking “unique ANWR mandates and policies” as liberty to decide what is “safe” and what is “not safe enough” without any accountability as to whether their decision actually reduces overall risk. Does USFWS know something that ADF&G or WAFWA doesn’t know? If so, then USFWS should reveal what it is and open the conversation with these other agencies. If not, we ask that USFWS refrain from identifying pack llamas as a disease threat and refrain from prohibiting pack llamas unless USFWS also prohibits horses. Any real or perceived mandate to apply the precautionary principle should be applied to all equally. “Unique mandates and policies” should not arbitrarily place an impossible burden of proof on pack llamas in the absence of scientific evidence that they are a greater disease threat than other animals such as horses that are allowed “free gratis” access to ANWR.

Regarding the USFWS statement “The proposed prohibition better aligns the Service with ADF&G hunting regulations……we are also seeking to align with 2012 WAFWA recommendations.” - The statement is in direct conflict with the regulations and recommendations of those agencies. They have no regulations or recommendations that prohibit pack llamas and they have studied this issue extensively. ADF&G even helped fund the CCH-17 study that USFWS cites as a reference in support of this proposal. ADF&G has stated that in CCH-17 “there is no significant new information presented” and “we will continue to focus and enhance our evaluation of disease risk from species other than llamas or related camelids” (per letter from ADF&G to GALA dated June 11, 2018).

Regarding the USFWS statement “Dall’s sheep in Alaska are free of domestic livestock diseases”. - This appears to be a false statement. ADF&G has identified domestic livestock diseases in Alaska Dall’s sheep populations to include contagious ecthyma and M. ovi. in the following articles posted on their website-
Mycoplasma ovipneumoniae (M. ovi) in AK Wildlife: Answers to FAQs
Parasites and Diseases

Regarding the USFWS statement “Tragedies such as the continued spread of chronic wasting disease in lower 48 states remind us of the value of a cautious approach to these issues on our largely intact ecosystems of Alaska.” - This statement was included in a letter from the USFWS Alaska Regional Director to GALA dated May 2, 2019. Any mandate to exercise a “cautious approach” in ANWR is not intended to be abused in a way that is arbitrarily applied to eliminate one user group while ignoring the risk presented by another user group that is allowed free access. Chronic wasting disease is a disease of cervids. Pack llamas are not cervids. This is a very poor analogy to apply to pack llamas. So why does USFWS apply this analogy to pack llamas but not to pack horses?

HOW THIS PROPOSAL VIOLATES THE ACCESS PROVISIONS OF THE ALASKA NATIVE CLAIMS SETTLEMENT ACT (ANILCA):

ANILCA provisions require the USFWS to provide public access to ANWR in the absence of scientific evidence that pack llamas present a threat to the wildlife in this jurisdiction. USFWS has not identified scientific evidence that would support a prohibition on camelids for the reasons previously stated.

HOW THIS PROPOSAL CURTAILS HUNTING AND FISHING OPPORTUNITIES IN ANWR:

The pack llama prohibition proposal is part of a regulation package that is intended to provide more hunting and fishing opportunities in NWR’s. This prohibition is in direct opposition to the intent of these proposed regulations. Due to the remoteness and associated difficulty of access to ANWR, I would not be able to access my hunting and fishing areas without the use of pack llamas. This prohibition stifles hunting and fishing opportunities in ANWR by using false and misleading information to justify a pack llama prohibition. 

HOW  USFWS SHORT-CIRCUITED THE NEPA PLANNING PROCESS:

For the record, we began taking our pack llamas into the Sag and Ivishak headwaters within ANWR via the Dalton Highway (Haul Road) before the 1988 Comprehensive Conservation Plan (CCP) was approved. It appears that the 1988 CCP officially recognized pack llamas as approved for all uses in all of ANWR thereby identifying pack llamas as an historic approved pack animal.

Pack llamas were still allowed for all uses in the draft of the current CCP that was put forth for public comment. However pack llamas were mysteriously eliminated in the final 2015 CCP.  We are working with the Alaska congressional delegation to get answers to the following questions. Did USFWS notify the llama community or the public at large? If so, how and when did USFWS notify the pack llama user group so that we could object to pack llamas (camelids) being prohibited in ANWR in the final CCP? It's important to note that pack llama users would not have been aware of a need to comment since llamas were recognized in the Draft ANWR CCP as an historic pack animal. Furthermore, USFWS apparently did not reveal any intentions to eliminate the pack llama user group. 

Ironically, the llama community first found out about the 2015 ANWR CCP pack llama prohibition from BLM in 2018. By all appearances there was no notification and the pack llama user group was prevented from participating in the planning process. A simple internet search any time since the mid- 90’s, would have revealed our website and contact information concerning Alaska pack llamas. Had we been notified, we could have addressed any concerns that USFWS staff may have had with respect to camelids so that we could pursue a remedy. We immediately alerted the llama organizations to the ANWR situation in 2018.

The llama community/organizations (represented by GALA) promptly sent a letter (dated June 28, 2018) to the USFWS Alaska Regional Director requesting that a multitude of CCP pack llama prohibition problems be addressed. It took almost a year and pressure from the congressional delegation to make USFWS respond to that request. The response letter from USFWS failed to address those issues or concerns. In addition USFWS chose to ignore all of the scientific information that was presented.

In summary, I strongly object to the proposed regulatory addition to 50 CFR § 36.39 (k) Arctic National Wildlife Refuge (ANWR) stating that all domestic camelids are prohibited. I request that USFWS refrain from identifying camelids (pack llamas) as a disease threat and remove any and all prohibitions and references in proposed regulations and CCP documents that implicate camelids as a disease threat.

Signed -  Phil Nuechterlein, Recreational llama owner/packer in Alaska since 1983

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To view all comments go to https://beta.regulations.gov/document/FWS-HQ-NWRS-2020-0013-0001/comment?filter=llamas

Comments

Leigh said…
I would like to go on record in full agreement and support of all the points that Phil Nuechterlein has made regarding the ban of pack llamas on public lands.

I am recreational, private llama packer and owner since 1997. I live in Colorado, but did live in Alaska previously.

There just isn't the any science to prove that there is a risk to wildlife from llamas any more than from people or horses or dogs.

Leigh DiNatle