Pack Animal Magazine

Arctic National Wildlife Refuge Alternative Pack Animal Ban Objection

by Alexa Metrick, Editor (June 2020)

I would like to express my objection to the proposed ban of alternative pack animals in the Arctic National Wildlife Refuge (ANWR).

Specifically, I would ask that the last sentence of the Summary on page 20030 be removed, in addition to the description of the proposed change (found on page 20033) and the specific wording of the proposed change (on page 20084). The deletions I am requesting are the following:
page 20030: “Lastly, we propose to prohibit domestic sheep, goat, and camelid pack animals on the Arctic National Wildlife Refuge.”
page 20033:
Other Updates to the Regulations for NWRs
We propose one change to 50 CFR part 36, the regulations concerning Alaska NWRs. Specifically, we propose to prohibit domestic sheep, goats, and camelids on the Arctic National Wildlife Refuge. The purpose of this prohibition is to prevent the spread of diseases and parasites to native wildlife populations, including mountain goats, musk oxen, and especially Dall’s sheep. Dall’s sheep in Alaska, including on the Arctic National Wildlife Refuge, are free of domestic livestock diseases and are believed to have very low immunity to many of these diseases. Domestic sheep, goats, and camelids (e.g., llamas and alpacas) are recognized as being at high risk for carrying disease organisms, often asymptomatically, that are highly contagious and cause severe illness or death in Dall’s sheep.
page 20084:
PART 36—ALASKA NATIONAL WILDLIFE REFUGES

■ 48. The authority citation for part 36 continues to read as follows:
Authority: 16 U.S.C. 460(k) et seq., 668dd–668ee, 3101 et seq., Pub. L. 115–20, 131 Stat.86.
■ 49. Amend § 36.39 by revising paragraph (d) to read as follows:
§ 36.39 Public use.
* * * * *
(d) Arctic National Wildlife Refuge.
We prohibit all domestic sheep, goats, and camelids on the refuge.

I request these deletions because this document fails to provide credible scientific evidence that implicates either pack goats or pack llamas and alpacas (or pack sheep, if that is a user group I am unaware of) as a credible disease threat in ANWR. It also fails to restrict access of other pack stock such as horses or mules. It does, however, contain wild speculations about theoretical dangers posed by alternative pack animals. All domesticated livestock, including horses, carry disease organisms that pose a possible threat to wildlife; however, there is there is no legitimate, statistically significant research that shows that the risk posed by pack lamas (llamas and alpacas, i.e. camelids) or pack goats is larger than the risk posed by pack horses.

Sheep, goats, and camelids are three distinct species, each with their own biology and attendant pathogens. Furthermore, pack animals and free-range grazing livestock carry distinctly different risk levels to native wildlife. Each user group must undergo its own risk analysis rather than be lumped together when a ban is being proposed. And as far as I am aware, there is no scientific basis for banning either pack goats or pack llamas and pack alpacas from the Arctic National Wildlife Refuge.

I have been the editor of Pack Animal Magazine, a publication highlighting the use of alternative pack animals, since 2013. I have extensive experience packing with llamas, as I have been out on the trail with them since I was four years old. I have also packed with goats several times. The amount of work, training, and bonding that goes into raising packstock is significant. These animals cannot simply be lumped in with free-range grazing animals in a risk assessment.

Please remove these mentions of alternative pack stock in a document otherwise dedicated to expanding hunting and fishing opportunities. I am sure that members of our goat packing and llama/alpaca packing communities would be happy to discuss guidelines and parameters regarding the use of packstock with U.S. Fish and Wildlife Service scientists in order to clarify the user groups and identify pack goats, pack llamas, and pack alpacas as being separate from free-range grazing livestock, just as horses are.

Thank you for your consideration of this objection.

Sincerely,
Alexa Metrick, Editor
Pack Animal Magazine