Skip to main content

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 were recognized as historical domestic pack animals along with horses and mules, and were all accepted as “Other Domestic Animals” on the ANWR for all 
alternatives A-F. (Chapter 2: Goals, Objectives, Management Policies, and Guidelines, Public Access, page 2-82, Chapter 3: Issues and Alternatives, page 3-49,)

There were no comments or issues developed by non-government organizations, agencies, nor public comments to this DCCP plan, specifically for pack llamas during this time frame. Pack llamas were identified, as they should be, in the DCCP along with horses and mules as acceptable. Both domestic animals, horses and llamas, have been used for decades on our public lands to assist in recreational packing, professional packing, packing supplies and game meat for hunters, and government agencies to assist them in managing our public lands. Pack llamas are a part of North American culture and have been utilized efficiently, safely, and disease free for generations.


Abruptly, without consultation or open discovery, the ANWR internal planning team arbitrarily took out the pack llama from the approved domestic animals list with horses, mules, and dogs for Public Access, Public Use, and Recreation. Inexplicitly, the ANWR added them with goats and sheep falsely claiming parallel phylogenetic families and a significant threat to ANWR wildlife, not allowing their historical use, and published this in the Arctic National Wildlife Refuge Revised Comprehensive Conservation Plan (CCP) and the Record of Decision (ROD). This has harmed our llama packing and animal husbandry groups, as it falsely, without science, arbitrarily claimed pack llamas are a disease-ridden animal harmful to our wildlife.

The ANWR staff did not consult the experts in disease epidemiology, read the historical research, or adequately consult other agencies with knowledge on this issue. Most importantly, the llama industry was excluded, and could have helped, have a meaningful opportunity to participate in our public land management. This is paramount, because we were, and continue to be negatively affected by these decisions. According to the DCCP there was no need to participate in development of the CCP, as pack llamas were good to go, and the ANWR posed no threat to our user group. Through the ANWR EIS procedures, they received no negative information on pack llamas, from any comments, throughout the whole process. Even so, when your staff then arbitrarily chose to prohibit the pack llama on our public lands, while ignoring other non ruminates, such as horses and mules, it set precedence. It was harmful, and could have been avoided with proper participation of the affected national residents and non-governmental organizations (NGO’s) during the EIS NEPA process.

Page 2, paragraph 5 of the 2015 CCP Record of Decision (ROD): ..."The service must ensure adequate and effective inter agency coordination and public participation during the planning process. Interested and affected parties such as State agencies, tribal governments, Native organizations, non-governmental organizations, and local and national residents who may be affected by decisions in the Plan must be provided meaningful opportunists to present their views."

We are allowed to participate now to correct a wrong. For this non inclusive decision, the research ANWR cited was one hypothetical non-peer reviewed nor published paper, crafted in Canada which has since been refuted by many in the professional fields of veterinarian and wildlife science called: “Examining the Risk of Disease Transmission between Wild Dall’s Sheep and Mountain Goats, and Introduced Domestic Sheep, Goats, and Llamas in the Northwest Territories” (Garde, E., et al. 2005).

ANWR excluded the llama packing and animal husbandry business along with well-established Llama NGO’s for meaningful opportunities to comment, provide information, research, and legal precedence. ANWAR chose not to seek guidance on this specific issue prior to the ROD in 2015, and inexplicitly missed the following research, readily available to find, study, and make informed scientifically based decisions. But not limited to:
Public Scoping’s and/or Environmental Assessments on commercial use permits, and the general public use and issuance of pack llama inclusion for public land management. All across this country including Alaska, going back as far as 1977, including using wild sheep habitat, pack llamas have been used on public lands.

Go here for entire comment on www.regulations.gov - Comment by Scott Woodruff

WE NEED YOUR HELP! Time is running out. Please go to this link for directions on how to object to this ANWR pack llama ban & submit a comment by June 8th. Thanks!

Links and directions on how to make a comment:
How to Make a Comment

Comments