Attention Llama Owners & Supporters - Comments Needed!

The comment period ended August 20, 2021. Check back here for updates. 

***Thanks to all who made comments!***

The Alaska Bureau of Land Management (BLM) is proposing to restrict/prohibit the use of pack llamas in the Eastern Interior Resource Management Area (EI–RMA) based on a perceived disease threat to wild sheep through their Travel Management Plans (TMPs) for the Steese and White Mountain subunits which are currently open for public comment. The TMPs are part of the proposed rule making process that take their direction from a planning document BLM approved in 2016 called the Eastern Interior-Resource Management Plan (EI-RMP). This EI-RMP (planning document) prohibits/restricts pack llamas in the Steese and White Mountains subunits of the BLM-Eastern Interior Management Area based on an unsubstantiated disease threat to wild sheep. Consequently, we are asking for an amendment to the 2016 BLM approved Eastern Interior RMP (planning document) because this will also be necessary to allow for the use of pack llamas in the TMPs.

 
This is an opportunity for the pack llama user group to make comment during the prescribed public comment period associated with Travel Management Plans (TMP’s) in the EI-RMA. Your participation in the public process (by submitting comments) has been very effective because BLM listened to you and subsequently removed proposed language prohibiting/restricting pack llamas in other Alaska jurisdictions. We need and very much appreciate your support again. Unless we can turn the tide during the current public comment period, a ban on the use of pack llamas could set a precedent to eliminate the pack llama user group on public lands in the lower 48 states. Please click on the link below for a sample comment and directions on how to submit. Thanks!

Comments must be received by Aug 20, 2021, and can be submitted as follows:

·         Online:     https://eplanning.blm.gov/eplanning-ui/project/120326/510 (click on the “Participate Now” button)

·         By email: blm_ak_fd_tmp@blm.gov

·         By fax:     907-474-2281

·         By mail:   BLM Eastern Interior Field Office, Attn: Eric Yeager, 222 University Avenue,  Fairbanks, AK 99709

It’s always best to craft your own comment and the sample comment below may help get you started. However, if you do not wish to craft an original comment, you are welcome to use the comment below verbatim. Please state that your comments are an objection to the Steese and White Mountains Travel Management Plan prohibitions/restrictions on the use of pack llamas and that you are also requesting BLM to amend the Eastern Interior Resource Management Plan to allow the use of pack llamas in Dall sheep habitat. 

Sample comment:

I object to BLM’s proposed prohibition or restrictions on the use of pack llamas in the Draft Steese and White Mountain Travel Management Plans (TMP’s). I request that BLM allow pack llamas in all areas within BLM’s White Mountain and Steese TMA’s (and all other subunits/TMA’s within the Eastern Interior Resource Management Area). I request these comments be applied to the aforementioned TMPs and planning documents as well as to any existing/approved planning documents pertaining to all subunits in the BLM Eastern Interior RMA.

It is my understanding that an amendment to the approved Eastern Interior Resource Management Plan (EI-RMP) is necessary to allow for the use of pack llamas (camelids) in the Eastern Interior Management Area and associated TMPs. For the record, I am also requesting that BLM amend the approved Eastern Interior RMP to allow for the use of pack llamas (camelids) in all areas of all subunits including Dall sheep habitat within the Eastern Interior Resource Management Area (EI-RMA).

BLM has presented no credible science for their proposed prohibition on the use of pack llamas in the Steese and White Mountain TMPs (and planning documents) based on a risk of disease transmission to wild sheep or other Alaska wildlife:

1)      BLM’s decision to prohibit pack llamas is apparently based on Canadian hypothetical “Risk Assessments.”  From the following quoted text taken directly from these papers, the authors admit the following: (1) “…there is insufficient data available to clearly assess the role of camelids as a source of disease at this time…..” and (2) “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.”

The above statements are significant because, by their own admission the authors state camelid disease transmission is hypothetical and based on conjecture (not science). (See Executive Summaries of BLM references): Furthermore, these studies have not been peer reviewed.

 2)      In this proposed rulemaking, BLM has lumped domestic pack llamas (camelids) with domestic sheep (bovids) and domestic goats (bovids) as a common disease threat to wild sheep (bovids). As pointed out by several widely recognized camelid experts (including Dr. Murray Fowler and Dr. Larue Johnson), it is inappropriate for any land management agency to “lump” bovids and camelids together as a common disease threat to wildlife (as BLM has done in this proposal). Camelids are widely separated from bovids taxonomically over more than 40 million years of evolution. This taxonomic separation (camelids as compared to bovids) is very significant as it relates to disease epidemiology.  As stated by Dr. Fowler in a letter of public record to the Alaska Department of Fish and Game (April 9, 2012), it is important for wildlife management agencies to understand that camelids are not reservoirs of disease that are common to bovids. The reservoir host (bovid) is where the pathogens of concern to wild sheep (as identified in BLM references) normally live and reproduce. Camelids are not a reservoir host for such diseases.

3) BLM has assigned horses “disease free” status with access “free gratis.” However, horses have several identified significant diseases that can be transmitted and fatal to wild sheep. (Click here for  Dr. Michelle Kutzler/Oregon State University public testimony )

In contrast, llamas have no identified significant endemic diseases. ADF&G has identified M. ovi as a primary pathogen of concern to wild sheep. Unlike domestic bovids, llamas (camelids) are not known to carry M. ovi (case in point - see item 3 above relating to taxonomic separation and its role in the science of disease epidemiology). Other pathogens of concern to wild sheep as identified by ADF&G such as Johnes’ disease (MAP) and contagious ecthyma (CE) are extremely rare in llamas (camelids are not a reservoir for MAP and CE). MAP and CE pathogens are apparently far more prevalent in humans than in llamas.

4) The America Association of Small Ruminant Practitioners (AASRP) which represents approximately 1000 veterinarians issued a policy statement in February 2020 that specifically addresses the same pathogens identified by BLM references and disagrees with BLM’s assertion that pack llamas pose a threat of transmitting these diseases to wild sheep. See AASRP Policy Statement

5) The Draft Steese Travel Management Plan 3.1.2.1 erroneously states that State hunting regulations prohibit the use of pack llamas for hunting Dall sheep, caribou, and muskox.

Contrary to what BLM states in this proposal, 2021-2022 State of Alaska hunting regulations do not prohibit the use of llamas for hunting Dall sheep, caribou, and muskox (see page 19 of the state hunting regulations - Additional Hunting Restrictions Specific to Big Game). Furthermore, the Alaska Department of Fish and Game (ADF&G) openly stated in a letter to the Greater Appalachian Llama and Alpaca Association (GALA) dated June 11, 2018 that the Department’s position is “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 and this letter was made available to BLM. Despite this, BLM published information that misrepresents the official ADF&G (State of Alaska) position on the pack llama “disease issue” on the their website (page 23 under 3.1.2.1 Effects Common to All Alternatives). It is important to note that ADF&G manages the wildlife within the BLM Steese and White Mountain jurisdictions. ADF&G has the staff and the resources to properly evaluate the “pack llama disease issue” yet BLM is proposing to override the State of Alaska position on this matter and misrepresent the State’s position on the use of pack llamas for hunting. This amounts to "federal overreach."

In conclusion, BLM has presented no scientific or credible basis for prohibiting pack llamas on the basis of disease transmission to wild sheep. Therefore, by this public comment I request that the BLM change these TMP’s and amend the 2016 Eastern Interior – EI RMP/ROD as follows:

1. Allow the use of pack llamas in BLM White Mountain and Steese TMA’s (and all other subunits/TMA’s within the Eastern Interior Resource Management Area including those areas that are Dall sheep habitat.

2. Remove all references concerning camelid disease risk to wild sheep, goats or other Alaska wildlife in Eastern Interior planning and or regulatory documents.

3. Strike from the record (in same TMAs and planning documents) that State of Alaska (ADF&G) hunting regulations prohibit the use of pack llamas for Dall sheep, caribou, and muskox hunting.