This is my formal notice of objection to the proposed regulation that prohibits pack llamas (camelids) in Arctic National Wildlife Refuge (ANWR). I request that the U.S. Fish and Wildlife Service refrain from identifying camelids (pack llamas) as a disease threat and remove all reference in the proposed regulations and planning documents that implicate them as a disease threat, especially on page 20084:
§ 36.39 Public use.
(d) Arctic National Wildlife Refuge.
We prohibit all domestic sheep, goats, and camelids on the refuge.
Pack llamas are a historical user group in the ANWR. However, we were not informed of the 2015 public review process. We should have been included in the discussion that resulted in losing our access to this public land.
Last fall, the Chugach National Forest Land Management Plan included language that banned pack llamas. Our community raised objections, and the reviewing officer, David E. Schmid, Regional Forester, responded by removing the ban. Furthermore, he wrote:
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.
The CNF reviewing officer recognized that there was no scientific basis for the ban. The idea that camelids are a disease threat to wildlife is scientifically untenable—as our community has proven, time and time again and to every division of our public land managers. This current attempt to prohibit a historical user group from recreating on the ANWR is arbitrary and has no scientific basis. It does not align with the recommendations of the Western Association of Fish and Wildlife Agencies (WAFWA) and does not match the Alaska Department of Fish and Game (ADF&G) regulations, neither of which prohibits the use of camelids in Alaska. And yet, not only did the USFWS, in this current proposal, fail to provide credible scientific evidence that implicates camelids as a disease threat in ANWR or prove that camelids pose a greater disease transmission risk than horses, but the document instead included wild speculations about theoretical dangers posed by camelids (see page 20033).
The fact that alternative pack animals were banned in a document overwhelmingly focused on opening up hunting and fishing opportunities also seems disingenuous. If domestic livestock are considered to be such a risk to the wild animals to which you are opening access, then horses and mules should logically also be banned from the ANWR. And if those wild populations are so threatened by livestock, perhaps they are not robust enough to warrant this document’s main priority in the first place: to open up National Wildlife Refuges to hunting.
I have been a recreational llama packer in the state of Colorado since the age of 4 and my family has been in the pack equipment manufacturing business since 1985. I have been the editor of Pack Animal Magazine, a publication highlighting the use of alternative pack animals, since 2013. I am well acquainted with llamas as pack animal and we, as an industry, would be happy to provide the Objection Reviewing Officer with further documentation regarding the lack of risk posed to wildlife by pack llamas. Extensive documentation can also be found on the website www.packllamas.org.
Please remove any accusations of camelids as being a disease threat from this document. Thank you for your consideration of this objection.
Alexa Metrick, Editor
Pack Animal Magazine