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| Lost Lake Trail - Chugach National Forest, Alaska |
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. For example, llamas do not have hooves but instead a leathery pad on the bottom of their foot. (The print left in the soil is quite
similar in appearance to that of an elk or deer.) Llama foot anatomy allows it's foot to spread on soft ground, thereby distributing weight over a larger area. Llamas are much smaller than most equine pack stock with the average pack llama weighing between 300-400 pounds.”
Therefore it comes as no surprise that these sure-footed pack animals are used by public agencies for trail and park maintenance as they are in Rocky Mountain National Park. However, there has been a campaign of misinformation by special interest groups and subsequent proposals by government agencies to ban llamas from our public lands based on a perceived "disease threat" to wildlife that is not scientifically defensible.
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.
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| 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 Canadian 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 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 Canadian 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.
The USFWS elected to ignore science and promulgated a final rule effective August 31, 2020 which prohibited the use of pack llamas (camelids) in ANWR. The llama organizations 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 (RM)9A). 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.
The BLM Central Yukon Draft Resource Management Plan (RMP) & Environmental Impact Statement (EIS) is currently open for public comment ending March 10, 2021. At issue is BLM's proposal to hold camelids to a different standard than horses by allowing horses without a permit but requiring a permit for pack llamas in this BLM jurisdiction.
What Can I Do? Submit a comment of objection to BLM by March 10th. Go to this link for information and details on how to submit comment -
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 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. (Public meeting discussion/details.)
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 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. (Public meeting discussion/details.)
On January 28, 2020 Chugach National Forest (CNF) announced their decision to rescind the llama ban in Chugach National Forest. CNF Llama Ban Rescinded. This was a significant "win" for the pack llama user group. 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:
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:
II. Historical Use of Pack Llamas in Lower 48 States
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| 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.
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 clearinghouse for camelid (llama and alpaca) disease information. 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. This group of volunteers is fighting hard to retain public access for the llama user group.
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. Pack llama owners in Arizona and Utah have already been denied commercial packing permits by federal agencies that are perceiving camelids as a wildlife disease threat. 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. If you care to volunteer and provide assistance with this effort, send me a message via the blog contact form or message me on Facebook.
***(Last Updated 1/14/21)***
Chugach State Park, Alaska (Photo by Linda Nuechterlein)
Related reading at these links-
An earlier version of this article was published in the Llama Association of North America Spring (LANA) Newsletter -
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