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Pack Llamas on Alaska's Public Lands

Pack llamas have historically played an important role on our public lands by both recreational and commercial users.  Low environmental impact has long been recognized as the pack llama’s advantage over traditional pack animals.  “A llama’s foot is split into two toes, with a toenail on top and a leathery pad on the bottom. The print left in the soil is quite similar in appearance to that of an elk or deer. The design of a llama’s foot allows it to spread on soft ground, thereby distributing weight over a slightly larger area. They are much smaller than most equine pack stock with the average pack llama weighing between 300-400 pounds.” The Impacts of Llamas as Hiking Companions (An International Llama Association publication ). 

These sure-footed pack animals are also used by public agencies for trail and park maintenance as they are in Rocky Mountain National Park. However, there have been proposals by government agencies to ban llamas from our public lands based on a perceived "disease threat" to wildlife that is not scientifically defensible. 
(Above - Lost Lake Trail, Chugach National Forest)

I.    Proposed Llama Bans in Alaska by Agency (Past and Present)
Alaska Board of Game (BOG):
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. To this day, pack llamas (camelids) are allowed on all state of Alaska public lands without restriction. 

Arctic Valley, Chugach State Park

National Park Service (NPS):
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.

U.S. Fish and Wildlife Service (USFWS):
In October, 2012, USFWS issued a revised Comprehensive Conservation Plan (CCP)followed by the 2015 ROD that banned llamas (along with domestic sheep and goats) as a disease threat to Dall’s sheep in the Artic National Wildlife Refuge (ANWR.) A hypothetical risk assessment (Garde et al. 2005) was cited as the documentation supporting this action. Up until this point, pack llamas had been recognized as historical domestic pack animals (along with horses and mules) in ANWR. USFWS failed to notify the llama community of their proposal to prohibit pack llamas effectively eliminating any objections from the llama community to ban an historic (pack llama) user group from ANWR. More here on the Hypothetical Canadian RAs.

In April 2020 the USFWS Arctic National Wildlife Refuge (ANWR) put forth a comprehensive regulation package (50 CFR: 50 CFR § 36.39 (k) Arctic National Wildlife Refuge) in which it 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." (As per 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.") This most recent USFWS rulemaking included the ANWR pack llama (camelid) prohibition established in the  2015 ROD-Revised Comprehensive Conservation Plan. (More details here - USFWS Attempting to Ban Pack Llamas in ANWR)  

The public comment period for the recent comprehensive regulation package (related to hunting and fishing in refuges) ended June 8, 2020. The llama community participated in a public meeting providing expert testimony and comprehensive comments objecting to USFWS's pack llama prohibition. The comprehensive written comments and public testimony clearly demonstrated the USFWS perceived camelid "disease risk" was not supported by science. Furthermore various procedural errors and omissions (dating back to 2012) were documented in the public record. 

In spite of the llama community's expert testimony, USFWS ignored science and promulgated a final rule effective August 31, 2020 which prohibited the use of pack llamas (camelids) in ANWR. The llama organizations have since mounted a legal defense to reverse this decision by the USFWS. Here's a link to the 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

Bureau of Land Management (BLM):
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 Mountain. 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.

Chugach National Forest (CNF):
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. 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. 

Other discussion topics included the lack of consistency between government agencies. 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. The llama community was puzzled why CNF decided 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 communicated in 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.

Alaska Department of Fish and Game (ADF&G):
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

II.    Historical Use of Pack Llamas in Lower 48 States
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.For more on this go to this article -  Just a Beautiful Day, Gone to Waste (Denver Post).  (Photo - RMNP)

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.”  

III.  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 traditional pack stock such as horses or mules. Ironically traditional pack stock (horses and mules) are the preferred species by federal agencies. However, horses (equine species) are a greater disease risk to wildlife 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 significant endemic diseases. Both llamas and horses have been pen-tested with wild sheep and demonstrated that they do not carry or 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 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 traditional pack stock that develop zoonotic infections (TB, MAP, and CE) which can be transmitted to wild sheep.

IV.    The Llama Community's Response
The North American llama community comprised of 3000+ llama owners and users represented by the Greater Appalachian Llama & Alpaca Association (GALA) formed an ad hoc Public Lands Access Committee to serve as a knowledge base for the llama community. Their website  at www.packllamas.org provides scientific resources concerning the perceived camelid disease issues and also documents the llama community's response to these unfounded proposals. 

V.    Conclusion:
Some government agencies are prohibiting pack llamas on Alaska's public lands due to a perceived "disease risk" hypothesis which is simply not supported by science. The danger is that these Alaskan government agencies may set a precedent that will ultimately cause a "ripple effect" and be applied on public lands nationwide. Therefore it's imperative that pack llama owners and anyone who uses our public lands remain vigilant. Make your voice heard through the public process to protect your right to access our public lands. Let's hold our public land managers accountable for their decisions because you/we are the owners of our public lands. 

***(Updated 9/23/20)***

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 
An earlier version of this article was published in the Llama Association of North America Spring (LANA) Newsletter -

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