Newsletter 12 - December 2022
In This Issue
Dall Sheep Declines & Our Future Sheep Hunting Opportunities
Cassell Lawsuit Update – Kodiak Nonresident Draw Permit Allocations
RHAK 2023 Banquets
RHAK Annual Banquet in Anchorage at Egan Center March 25th, 2023
Save the date! Our annual fundraising banquet in Anchorage at the Egan Center will be Saturday, March 25th. Doors open 5pm, dinner at 6:30. Live auctions, Governor tags, raffles, cash bar, and more! We will auction off the 2023 Delta Controlled Use Area Dall Sheep (SS202) and Revillagigedo Mountain Goat (SG056) Governor Tags. The SS202 sheep permit allows the winner to hunt the early and/or late season motorized or nonmotorized draw hunts (DS203/204). Click here to get Anchorage Banquet tickets/tables and raffle packages
New! RHAK 1st Annual Banquet in Fairbanks January 28th, 2023 at Birch Hill Rec Area
We wanted to put something together for our Interior members during the winter doldrums of below zero temperatures and little sunlight and are holding our first-ever banquet in Fairbanks! Join us on Saturday, January 28th at the Birch Hill Recreation Area for dinner and a fun evening with friends and family in support of RHAK! Doors open at 5pm, dinner at 6:30. Wall of guns and gear, raffle packages, cash bar, and more! Get Fairbanks Banquet tickets/tables and raffle packages here
Executive Director Report:
Dall Sheep Declines And Our Future Sheep Hunting Opportunities
By Mark Richards
We live in the only state in the country with a wild population of Dall sheep – a species highly coveted by hunters from across the world – and the way we have managed those sheep in many areas was to allow unlimited hunting of mature rams by both resident and nonresident sheep hunters, require that most all nonresident sheep hunters hire a licensed big game guide to the tune of $20,000+, and placed no limits on the number of guides.
What could go wrong?
That’s how Alaska continues to manage our declining sheep populations on state lands in the central and western Alaska Range in Game Management Units 20A and 19C, where nonresident guided sheep hunters have consistently harvested 60-80 percent of legal rams annually. In 2022 nonresident guided sheep hunters took 90 percent of the sheep harvest in Unit 19C.
The Alaska Department of Fish & Game (Department) says the reason it’s okay, sustainability wise, to allow unlimited Dall sheep hunting on limited Dall sheep populations, is because Full-Curl (FC) harvest management – only full-curl rams or rams 8 years or older can be harvested – is biologically sustainable under all conditions. Dall rams with full-curl horns or those 8 years or older are known to be near the end of their life cycle, thus the harvest of mature rams is more compensatory mortality than additive mortality. Data also shows that not all the legal rams are harvested out of a population every year, thus there is always a “harvestable surplus” of legal rams.
The Board of Game has continued to justify the allowance of unlimited nonresident sheep hunting in certain areas based on the Department position that the FC harvest strategy is indeed sustainable. Everything else – the known conflicts in the field between guides, their clients, and resident sheep hunters, guides essentially locking up areas, guide on guide conflicts, and the vast majority of the annual sheep harvest in these areas continually going to nonresident guided hunters – is justified on the basis that nonresident dollars from hunting license and tag sales are needed to help fund the Department, and that guides need to make a living.
But with our Dall sheep populations now in a severe decline statewide – the declines are mostly weather related, caused by climate change, and are happening across the state in areas where sheep hunting is prohibited, and in draw and general hunting areas – things are coming to a head. Many, including at least one Board of Game member, are questioning whether the FC harvest strategy really is sustainable under all conditions.
The Federal Subsistence Board wasn’t buying the Department’s position that unlimited sheep hunting under FC harvest management was always sustainable, when just prior to the fall 2022 sheep hunting season, due to sheep conservation concerns, they closed all sheep hunting for everyone in parts of the central Brooks Range for two years in areas where the Board of Game continued to allow unlimited sheep hunting opportunities for all. The key reason they questioned the sustainability of FC harvest management was based on the Department itself contradicting its validity when in 2015 they recommended a complete sheep hunting closure in Unit 23 – Unit 23 is still closed to all sheep hunting – and in 2008 recommended that Units 13D/14A in the Chugach go to draw only hunts with a limited allocation for everyone. These were areas where unlimited sheep hunting had been allowed based on the ostensible sustainability of FC harvest management…until the Department suddenly had sheep conservation concerns.
And now, the Board of Game itself – after over a decade of complaints and proposals (all voted down!) from resident sheep hunters and RHAK expressing sheep conservation concerns and fears that resident sheep hunters would lose opportunity if unlimited nonresident opportunity continued – has submitted a Board-generated proposal to completely close Unit 19C in the western Alaska range to all sheep hunting for five years!
The audacity of the Board of Game now proposing this is still hard to comprehend. And that’s further compounded by the fact that the Board of Game rejected an Agenda Change Request proposal from RHAK – expressing conservation concerns for sheep in 19C and asking to limit nonresident sheep hunters there to draw only permits with a limited allocation – stating that our request did not meet the criteria for “sheep conservation concerns” at the same meeting they voted to propose a complete sheep hunting closure in Unit 19C based on “sheep conservation concerns!”
The result of this overtly hypocritical decision by the Board of Game is that next March the public will only be able to weigh in on whether to support or oppose a complete sheep hunting closure in 19C. The RHAK proposal that unquestionably met the criteria for acceptance and offered an alternative that would limit nonresident sheep hunters in 19C as a first step, will purposely not be before the public.
So where do we go from here? RHAK has real conservation concerns for our sheep populations, but there’s little in the state’s toolbox to turn things around. We can’t change the weather, which is and will continue to be the main factor in sheep declines, nor can we control avalanches and drownings. It’s possible to do predator control to benefit sheep in specific areas, but the cost is high and it doesn’t seem there would be efficacy in such a program when the main predator is the federally protected Golden Eagle.
The one thing we can control is the number of hunters. While it’s true there is always a harvestable surplus of legal rams after each hunting season, that number of legal rams each fall has greatly diminished to the point we are seeing unacceptable levels of sub-legal harvests (by guided and unguided hunters) and it just isn’t prudent to continue to allow unlimited nonresident sheep hunting opportunity anywhere it is currently granted.
At some point, RHAK may support some type of limits on resident sheep hunters if things don’t improve. But we cannot support any new limits or restrictions on resident sheep hunters if nonresident sheep hunting isn’t strictly limited or restricted first.
RHAK Heritage Foundation Recognized
The RHAK Heritage Foundation (RHAKHF) has been instrumental in helping to fund construction of a cover for the Rabbit Creek Rimfire Range. RHAKHF is a 501c3 non-profit dedicated to youth hunter education and conservation efforts. Donations are tax-deductible. See https://www.rhakheritage.org/
Board of Game Report
The Board of Game will hold regulatory meetings in 2023 for Southeast Alaska Region I, and Southcentral Alaska Region II.
January 20-24, 2022 – Ketchikan Southeast Region I Meeting
Meeting Information and proposals can be found here: http://www.adfg.alaska.gov/index.cfm?adfg=gameboard.meetinginfo&date=01-20-2023&meeting=ketchikan
Comment deadline Jan. 6th
March 17-22, 2023 – Soldotna Southcentral Region II Meeting
Meeting Information and proposals are here: http://www.adfg.alaska.gov/index.cfm?adfg=gameboard.meetinginfo&date=03-17-2023&meeting=kenai
Comment deadline March 3rd
Note: The Board-Generated Proposal to completely close Unit 19C to all sheep hunting for five years (Proposal 204) will be heard at the Southcentral meeting in Soldotna in March.
Summary of the October 19, 2022 Dall Sheep Informational Meeting
A more complete summary was sent out to members on October 20th. The Board of Game met last October to hear information from the Alaska Department of Fish & Game about the status of our Dall sheep populations. The slides from the Department presentation that detail historical sheep population levels, number of hunters and harvests over time, and more:
Federal Subsistence Board Report
Wildlife Proposal 22-07 Admiralty Island Deer Hunting Closure Request
The FSB will meet January 31 – February 2, 2023 in Anchorage to hear and take action on deferred Wildlife Proposal 22-07, which requests that the Federal public lands of Admiralty Island draining into Chatham Strait between Point Marsden and Point Gardner in Unit 4 be closed to deer hunting Sept. 15 – Nov. 30, except by Federally qualified subsistence users.
RHAK strongly opposes this proposal and has previously sent in written comments in opposition. There is absolutely no basis for this proposal as the deer population is healthy and abundant, and subsistence needs are being met.
The Department has detailed information and data in their ADF&G Draft Comments on WP 22-07 as to why this closure request is not warranted.
RHAK will be at the meeting in person to again relay our opposition. The FSB is no longer taking written comments but oral testimony via phone and in person will be taken during the meeting. The call-in number has not yet been released. See this link for more information: https://www.doi.gov/subsistence/board
Wildlife Special Action Request 22-02 Sheep Hunting Closure Central Brooks Range
The Federal Subsistence Board (FSB) met in late July in Anchorage and voted unanimously to approve Wildlife Special Action Request WSA 22-02 to close Federal public lands in Unit 24A and a portion of Unit 26B to sheep hunting by all users for the 2022–2023 and 2023–2024 wildlife regulatory years. Click here to read the FSB statement on the closure.
RHAK Executive Director Mark Richards represented us at the meeting (RHAK was the only organization present) and testified that while RHAK also had the same sheep conservation concerns outlined in the proposal, we must oppose it because the FSB has no means to address the unlimited nonresident sheep hunting opportunity allowed by the Board of Game in these areas. And if/when the units opened again, we’d still have the same problems with unlimited nonresident sheep hunting opportunity.
Mr. Richards requested an amendment to the proposal to exempt bowhunters, as the sheep harvest success rate for bowhunters was quite low and the archery only areas within the Dalton Highway Corridor Management Area were one of the few places to hunt sheep accessible via the road system. The board denied the amendment.
Yukon River just upstream of the Nation River
RHAK July 2023 Yukon River Float Trip!
We’d like to get a dozen or so members together this summer for a five-day float trip on the Yukon River from Eagle to Circle. It’s 160 river miles through the beautiful and historic upper-Yukon country and Yukon-Charley Rivers National Preserve. Mark Richards will help lead the group downriver and share some of the places and stories he knows so well from his 30 years living and traveling in the upper-Yukon area. We’ll fish the clearwater streams for grayling and pike, see some wildlife, camp out each night under the midnight sun, share meals and have a great time!
We’re looking at the second week in July, so if that works for you and you’d like to join us, drop Mark Richards a line and we’ll start planning logistics on travel to Eagle and from Circle. If you don’t have a raft, canoe or kayak, it’s likely that with enough participation we can fit you in somewhere, and help you with a ride as well.
Let’s do it, there is nothing like being on the Yukon in July! The only requirements for participation are that you must be able to tolerate mosquitoes and maintain a good attitude! Bug dope helps : )
Membership Renewals Going Out
Please Renew and Spread the Word!
Membership renewal is quick and easy using the RHAK renew page
But you can always contact Mark Richards at 371-7436 or email@example.com
Share the RHAK membership newsletters with friends and family
RHAK Board of Directors Vacancies
A big thank you to RHAK Board members Brian Watkins and Adam Grenda, who are leaving the board in 2023. Brian joined our board in 2018 and Adam in 2019, and are among the hardest-core hunters we know. We will greatly miss their knowledge and input but are happy they both will now be able to spend a bit more time with friends and family!
The RHAK Board typically meets once a month via phone/internet from November – March, and we hold one in-person meeting each year. We also communicate via phone/email on issues that come up.
We know it’s hard with a busy schedule to volunteer your time, but if you’d like to serve on our Board of Directors, get more in-depth insight into the issues and get more involved in moving RHAK forward, please drop RHAK Executive Director Mark Richards a line at firstname.lastname@example.org
Cassell Lawsuit Update:
Case Appealed and Before Alaska Supreme Court
RHAK VP Bob Cassell took it upon himself to stand up for all Alaskan hunters when he filed suit against the State and Board of Game over the high Kodiak brown bear permit allocations to nonresidents. RHAK has joined as Amicus curiae in support of the Cassell complaint.
Up to 40% of the Kodiak brown bear permits are awarded to nonresident guided hunters, who have significantly higher odds of drawing a permit than residents. Unlike residents, nonresidents don’t even have to go through the permit process; they can make a deal with a guide, sign a contract, and show up in Kodiak and pick up an over-the-counter permit. Cassell argues that any exclusive granting of draw permits to nonresidents is unconstitutional under Article 8 of our state constitution.
The Alaska Superior Court ruled against Cassell, who has appealed. The case will now be before the Alaska Supreme Court in 2023. Of note in the Cassell brief to the Supreme Court is what the crux of this case is about:
“Given the clear edicts in Article VIII, one would expect that when confronted with scarce game resources, the Board of Game would allocate hunting access in a manner that ensured Alaskans have access to Alaska’s game. But the Board has chosen the opposite approach, repeatedly choosing to mandate that nonresidents be guaranteed a certain (often high) percentage of permits at the direct expense of Alaskans. These nonresident preferences constitute an impermissible exclusive grant of Alaska’s game and turn the common use and maximum benefit principles on their heads.”
Mr. Cassell has spent a lot of money on attorney fees to stand up for all Alaskans. If you’d like to donate toward his attorney fees and have a stake in this, you can do so via our website. Click to learn how to donate, and read all the past and current court documents.