wp18 28 executive summary - united states department of ... · (aderman 2014). harvest history...

WP18–28 Executive Summary

General Description Proposal WP18–28 requests the addition of a winter may-be-announced

moose season in the portion of Unit 18 in the Goodnews River drainage

and south to the Unit 18 boundary. Submitted by: Togiak National

Wildlife Refuge.

Proposed Regulation Unit 18—Moose

Unit 18—Goodnews River drainage and south to

the Unit 18 boundary—1 antlered bull by State

registration permit. Any needed closures will be

announced by the Togiak National Wildlife Refuge

Manager after consultation with BLM, ADF&G,

and the Chair of the Yukon-Kuskokwim Delta

Subsistence Regional Advisory Council

or

1 moose by State registration permit

Sep. 1 – Sep. 30

A season may be

announced

between Dec. 1

and the last day

of Feb.

OSM Preliminary Conclusion Support with modification to remove the unit specific language

referencing closures and delegate authority to the Togiak National

Wildlife Refuge Manager to close the fall season and to open and close

the “may be announced” winter season, and to set harvest quotas and

restrictions via a delegation of authority letter only.

The modified regulation should read:

Unit 18—Moose

Unit 18—Goodnews River drainage and south to

the Unit 18 boundary—1 antlered bull by State

registration permit. Any needed closures will be

announced by the Togiak National Wildlife Refuge

Manager after consultation with BLM, ADF&G,

and the Chair of the Yukon-Kuskokwim Delta

Sep. 1 – Sep. 30


Subsistence Regional Advisory Council

or


A season may be

announced

between Dec. 1

and the last day

of Feb.

Southeast Alaska Subsistence

Regional Advisory Council

Recommendation

Southcentral Alaska

Subsistence Regional

Advisory Council

Recommendation

Kodiak/Aleutians Subsistence


Recommendation

Bristol Bay Subsistence


Recommendation

Yukon-Kuskokwim Delta


Advisory Council

Recommendation

Western Interior Alaska


Advisory Council

Recommendation


Seward Peninsula


Advisory Council

Recommendation

Northwest Arctic Subsistence


Recommendation

Eastern Interior Alaska


Advisory Council

Recommendation

North Slope Subsistence


Recommendation

Interagency Staff Committee

Comments

ADF&G Comments

Written Public Comments None

DRAFT STAFF ANALYSIS

WP18-28

ISSUES

Proposal WP18-28, submitted by the Togiak National Wildlife Refuge (Refuge), requests the addition of a

winter may-be-announced moose season in the portion of Unit 18 in the Goodnews River drainage and

south to the Unit 18 boundary.

DISCUSSION

The proponent notes that the moose population in the Goodnews drainage has grown substantially in recent

years, from less than 10 moose in 2002, to an estimated 600 moose in 2017. It reports that the bull:cow and

calf:cow ratios are adequate, and that the combined State/Federal quota of 20 bulls has not been met in the

fall season for several years. This hunt is administered by State registration permit, which ensures good

reporting and harvest management, with permit distribution occurring in the communities of Goodnews

Bay and Platinum, which limits participation. The proponent reports that access to moose hunting during

fall is limited in this area, and that the addition of a winter season will increase opportunities for Federally

qualified subsistence users to harvest moose.

The proponent’s written request is to establish a may-be-announced season between December 1 and the

last day of February, with a harvest limit of one antlered bull. However, after additional correspondence

with the proponent, the request was amended to include a harvest limit of one moose, rather than one

antlered bull for the winter season. It believes this allows maximum flexibility in managing the dynamic

moose population, which may become increasingly important considering the rapid growth Unit 18 moose

populations are experiencing. It also notes that it will reduce regulatory complexity between State and

Federal regulations, simplifying use of the State registration permit and improving opportunity for parallel

in-season management.

Existing Federal Regulation

Unit 18—Moose

Unit 18—Goodnews River drainage and south to the Unit 18

boundary—1 antlered bull by State registration permit. Any needed

closures will be announced by the Togiak National Wildlife Refuge

Manager after consultation with BLM, ADF&G, and the Chair of the

Yukon-Kuskokwim Delta Subsistence Regional Advisory Council

Sep. 1 – Sep. 30

Proposed Federal Regulation

Unit 18—Moose






or


Sep. 1 – Sep. 30

A season may be

announced between

Dec. 1 and the last

day of Feb.

Existing State Regulation

Unit 18—Moose

Unit 18—South of and including the Goodnews

drainage—One antlered bull by permit available in person in

Goodnews Bay and Platinum Aug. 1 – 25. Season closed by

emergency order when 20 bulls are taken.

or

One moose by permit available in person in Goodnews Bay

and Platinum – may be announced.

RM620

RM621

Sep. 1 – Sep. 30

May be announced

Extent of Federal Public Lands

Federal public lands comprise approximately 68% of the portion of Unit 18 in the Goodnews drainage and

south to the Unit 18 boundary and consist of 62% U.S. Fish and Wildlife Service (USFWS) managed lands

and 6% Bureau of Land Management (BLM) managed lands (Map 1).

Customary and Traditional Use Determinations

Residents of Unit 18, Upper Kalskag and Lower Kalskag have a customary and traditional use

determination for moose in the Unit 18 remainder customary and traditional use area, which includes the

Goodnews drainage hunt area.

Map 1. The Unit 18 moose hunt area described as the Goodnews River drainage and south to the Unit 18

boundary.

Regulatory History

Federal public lands south of and including the Goodnews River drainage were closed to all moose harvest

until 2008. However, under State regulation, a Sep. 1 – 30 moose season remained open on lands outside

of Federal jurisdiction until 2004. This season was closed by emergency order in 2004 and 2005. By

2006, there was agreement among USFWS, the Alaska Department of Fish and Game (ADF&G), and the

communities of Goodnews Bay and Platinum to impose a moratorium on moose harvest. The moratorium

began in 2006 and was intended to remain in place for 3 years, or until 100 moose were counted within the

Goodnews River drainage (Aderman 2014).

By 2008, the moose population had exceeded 100 moose and Proposal WP08-34 was adopted with

modification by the Federal Subsistence Board (Board). This action established a Federal moose season in

the Goodnews River hunt area. The Alaska Board of Game (BOG) also established a moose season in

2008. Both Federal and State seasons were open Aug. 25 – Sep 20, had a harvest limit of one antlered bull,

and required the use of a State registration permit (BOG 2017; OSM 2017).

In 2009, the BOG adopted Proposal 1, which shifted the State season to Sep. 1 – 30. This change became

effective in regulatory year 2010. In 2012, the Board adopted WP12-46. This action shifted the Federal

season to Sep. 1 – 30, resulting in realignment of State and Federal seasons (BOG 2017; OSM 2017).

In January 2017, the BOG established an additional may-be-announced season with the adoption of

Proposal 21. This hunt requires the use of a registration permit and has a harvest limit of one moose.

Intended as a winter hunt, the BOG gave ADF&G the authority to determine the length and timing of the

opening, and to establish harvest quotas for the hunt. There was some concern by members of the BOG

that, although the moose population is increasing, additional harvest opportunity may result in high harvest

rates relative to the current population size. However, the BOG ultimately agreed that there was a realistic

possibility that this population would be able to support additional harvest prior to 2020, the next time they

will consider proposals for this region, and agreed that it was prudent to give ADF&G the authority to

manage the harvest (BOG 2017).

Biological Background

Prior to the early 2000s, moose were not reliably observed in the Goodnews River drainage. Early

population growth is attributed to emigration from adjacent Unit 17A, with high calf recruitment sustaining

growth (Aderman 2014). Population estimates, obtained by the Togiak National Wildlife Refuge as part

of their Refuge-wide moose monitoring program, show substantial growth of the moose population in this

area (Figure 1). In 2004, the population within this hunt area was estimated to be just 10 moose. By

2012, it had exceeded a minimum count of at least 200 moose (Aderman 2014).

Figure 1. Estimated moose population size in the Goodnews River drainage hunt area, 2004 – 2017.

2004 – 2012 estimates are minimum counts. 2016 – 2017 estimates are derived from GSPE surveys.

Error bars represent 95% confidence intervals (Aderman 2014, Aderman 2017, pers. comm.).

More recently, the Refuge has begun using a geospatial population estimator technique (GSPE) to estimate

abundance. This approach results in a statistical estimate of abundance, taking into account spatial

0

100

200

300

400

500

600

700

800

2004 2005 2006 2006 2008 2009 2009 2011 2012 2013 2014 2015 2016 2017

Po

pu

lati

on

esti

mate

(N

um

ber

of

mo

ose)

correlation among moose on the landscape (Kellie and DeLong 2006). Using these methods, abundance of

the Goodnews River drainage moose population was estimated to be 361 moose in October 2016 and 505

moose in March 2017. Corrected for sightability, the 2017 estimate is 607 moose. While the precision of

these estimates is poor, the population is believed to have grown since 2012 (Aderman 2017, pers. comm.).

A survey in October 2016 indicated that there were 47 bulls:100 cows and 43 calves:100 cows in this

population (Aderman 2017, pers. comm.). Refuge-wide, for the 1998 – 2013 time period, calf production

averaged 128 calves:100 cows and yearling recruitment averaged 60 calves:100cows, which has been

sufficient for steady growth in this population. Average weight of 10 month old female calves for 2002 –

2013 was 190 – 216 kg, indicating a high plane of nutrition relative to some other parts of the State

(Aderman 2014).

Harvest History

Moose hunting has been legal in the Goodnews hunt area since 2008, when the moose population exceeded

100 animals and the BOG and the Board established moose hunting seasons. Since then, reported harvest

has averaged 13.5 moose annually (Table 1). The harvest quota has been set at 20 bulls since 2011. In

every year since, reported harvest has remained below this threshold, without the use of closures by

Emergency Order (BOG 2017; ADF&G 2017).

Since 2008, moose in the Goodnews hunt area have been harvested exclusively by Federally qualified

subsistence users, with the exception of a single moose taken in 2009 by a resident of Dillingham.

Seventy-five percent of the reported harvest has been by residents of Goodnews Bay, while residents of

Platinum have taken 15% of the harvest. The residency of successful moose hunters in 2014 who

harvested 8% of the total harvest since 2008 is unknown. However, it is expected that residency patterns

in 2014 are consistent with other years. If so, residents of Goodnews Bay and Platinum, the two

communities within the hunt area, account for approximately 98% of the total harvest in this area (ADF&G

2017).

Table 1. Reported moose harvest in the Goodnews hunt area 2008 – 2016, by resident community

(ADF&G 2017)

Resident Community 2008 2009 2010 2011 2012 2013 2014 2015 2016

Bethel - - - 1 - - - - -

Dillingham - 1 - - - - - - -

Goodnews Bay 10 8 10 15 11 10 - 13 14

Platinum 3 1 1 2 2 4 - 2 3

Quinhagak - - - 0 - 1 - - -

Unknown - - - 0 - - 10 - -

Total Harvest 13 10 11 18 13 15 10 15 17

Effects of the Proposal

If this proposal is adopted, Federally qualified subsistence users will have additional opportunities to

harvest moose in the portion of Unit 18 in the Goodnews River drainage south to the Unit 18 boundary.

The addition of a winter season is not expected to affect the moose population in this area because it does

not expand the pool of eligible users, all of whom can participate in State’s winter hunt. The use of quotas

and registration permits further guards against overharvest.

The addition of a Dec. 1 – last day of Feb. may-be-announced season does not align fully with recent

changes in State regulation. However, the aim of the State’s recent regulation change was to give local

managers the flexibility to open a winter hunt, consistent with the aim of this proposal. Adoption of this

proposal will improve opportunity for parallel State and Federal in-season management and will reduce

regulatory complexity.

OSM PRELIMINARY CONCLUSION

Support Proposal WP18-28 with modification to remove the unit specific language referencing closures

and delegate authority to the Togiak National Wildlife Refuge Manager to close the fall season and to open

and close the “may be announced” winter season, and to set harvest quotas and restrictions via a delegation

of authority letter only (Appendix A).

The modified regulation should read:

Unit 18—Moose






or


Sep. 1 – Sep. 30

A season may be

announced between

Dec. 1 and the last

day of Feb.

Justification

Establishing a winter season provides an additional opportunity for Federally qualified subsistence users to

harvest moose if they are unsuccessful in the fall. Relative to a preset season, a may-be-announced season

poses little risk to the moose population in the area, since it allows local managers to be responsive to

changing population and harvest dynamics. Setting the winter harvest limit at one moose, and delegating

authority to the Federal manager to set harvest restrictions, provides maximum flexibility. This is an

important consideration when managing dynamic populations such as this one, particularly in a region

experiencing rapid moose population growth like Unit 18. Administration of this hunt though registration

permits, and use of harvest quotas, provides additional protection against overharvest.

Moose harvest within the Goodnews drainage hunt area occurs almost exclusively by local hunters, all of

whom are eligible to harvest moose during the State’s resident season. Consequently, the addition of a

Federal season, while it represents additional opportunity, is not expected to have any realized effect on the

moose population in the area. However, this proposal does improve the ability of State and Federal

managers to jointly implement in-season management, which will simplify compliance for local users.

LITERATURE CITED

Aderman, A.R. 2014. Demographics and Home Ranges of Moose at Togiak National Wildlife Refuge, Southwest

Alaska, 1998 – 2013. Unpublished report. USFWS, Togiak National Wildlife Refuge, Dillingham, AK.

Aderman, A.R. 2017. Wildlife biologist. Personal communication: phone & email. Togiak National Wildlife

Refuge. Dillingham, AK.

ADF&G. 2017. WinfoNet. https://winfonet.alaska.gov/. Retrieved: April 27, 2017.

BOG. 2017. Audio transcripts of the Alaska Board of Game proceedings. January 9, 2017. Bethel, AK. Alaska

Department of Fish and Game. Juneau, AK

Kellie, K.A., and R.A. DeLong. 2006. Geospatial survey operations manual. , ADF&G. Fairbanks, AK, USA.

OSM, 2017. Federal Subsistence Permit System. Microcomputer database. Retrieved: April 2017. Anchorage,

AK.

https://winfonet.alaska.gov/

APPENDIX A

Refuge Manager

Togiak National Wildlife Refuge

P.O. Box 270 MS 569

Dillingham, Alaska 99576

Dear Refuge Manager:

This letter delegates specific regulatory authority from the Federal Subsistence Board (Board) to the

Togiak National Wildlife Refuge Manager to issue emergency or temporary special actions if necessary to

ensure the conservation of a healthy wildlife population, to continue subsistence uses of wildlife, for

reasons of public safety, or to assure the continued viability of the population. This delegation only applies

to the Federal public lands subject to Alaska National Interest Lands Conservation Act (ANILCA) Title

VIII jurisdiction within Unit 18, Goodnews River drainage and south to the Unit 18 boundary, for the

management of moose on these lands.

It is the intent of the Board that actions related to management of moose by Federal officials be coordinated,

prior to implementation, with the Alaska Department of Fish and Game (ADF&G) and the Chair of the

Yukon Kuskokwim Delta Subsistence Regional Advisory Council and the Chair of the Western Interior

Alaska Subsistence Regional Advisory Council to the extent possible. Federal managers are expected to

work with managers from the State and other Federal agencies, the Council Chairs, and applicable Council

members to minimize disruption to subsistence resource users and existing agency programs, consistent

with the need for special action.

DELEGATION OF AUTHORITY

1. Delegation: The Togiak National Wildlife Refuge Manager is hereby delegated authority to issue

emergency or temporary special actions affecting moose on Federal lands as outlined under the Scope of

Delegation. Any action greater than 60 days in length (temporary special action) requires a public hearing

before implementation. Special actions are governed by regulation at 36 CFR 242.19 and 50 CFR 100.19.

2. Authority: This delegation of authority is established pursuant to 36 CFR 242.10(d)(6) and 50 CFR

100.10(d)(6), which state: “The Board may delegate to agency field officials the authority to set harvest and

possession limits, define harvest areas, specify methods or means of harvest, specify permit requirements,

and open or close specific fish or wildlife harvest seasons within frameworks established by the Board.”

3. Scope of Delegation: The regulatory authority hereby delegated is limited to the following authorities

within the limits set by regulation at 36 CFR 242.26 and 50 CFR 100.26:

To close the Sep. 1 – 30 season, and to open and close a season between December 1 and the last

day of February and set harvest quotas and restrictions for moose on Federal public lands within the

portion of Unit 18 in the Goodnews River drainage and south to the Unit 18 boundary.

This delegation may be exercised only when it is necessary to conserve moose populations, to continue

subsistence uses, for reasons of public safety, or to assure the continued viability of the population.

All other proposed changes to codified regulations, such as customary and traditional use determinations,

adjustments to methods and means of take, or closures and restrictions for take by only non-Federally

qualified users shall be directed to the Federal Subsistence Board.

The Federal public lands subject to this delegated authority are those within Unit 18 in the Goodnews River

drainage and south to the Unit 18 boundary.

4. Effective Period: This delegation of authority is effective from the date of this letter and continues

until superseded or rescinded.

5. Guidelines for Delegation: You will become familiar with the management history of the wildlife

species relevant to this delegation in the region, with current State and Federal regulations and management

plans, and be up-to-date on population and harvest status information. You will review special action

requests or situations that may require a special action and all supporting information to determine: (1)

consistency with 36 CFR 242.19, (2) if the request/situation falls within the scope of authority, (3) if

significant conservation problems or subsistence harvest concerns are indicated, and (4) what the

consequences of taking an action or no action may be on potentially affected subsistence users and

non-Federally qualified users. Requests not within your delegated authority will be forwarded to the

Federal Subsistence Board for consideration. You will maintain a record of all special action requests and

rationale for your decision. A copy of this record will be provided to the Administrative Records

Specialist in the Office of Subsistence Management (OSM) no later than sixty days after development of

the document.

You will notify OSM and coordinate with local ADF&G managers and the Chairs of the Yukon

Kuskokwim Delta Subsistence Regional Advisory Council and Western Interior Alaska Subsistence

Regional Advisory Council regarding special actions under consideration. You will issue decisions in a

timely manner. Before the effective date of any decision, reasonable efforts will be made to notify the

public, OSM, affected State and Federal managers, law enforcement personnel, and Council

representatives. If an action is to supersede a State action not yet in effect, the decision will be

communicated to the public, OSM, affected State and Federal Managers, and the local Council

representatives at least 24 hours before the State action would be effective. If a decision to take no action

is made, you will notify the proponent of the request immediately. A summary of special action requests

and your resultant actions must be provided to the coordinator of the appropriate Subsistence Regional

Advisory Council(s) at the end of each calendar year for presentation to the Council(s).

You may defer a special action request, otherwise covered by this delegation of authority, to the Federal

Subsistence Board in instances when the proposed management action will have a significant impact on a

large number of Federal subsistence users or is particularly controversial. This option should be exercised

judiciously and may be initiated only when sufficient time allows for it. Such deferrals should not be

considered when immediate management actions are necessary for conservation purposes. The Federal

Subsistence Board may determine that a special action request may best be handled by the Board,

subsequently rescinding the delegated regulatory authority for the specific action only.

6. Support Services: Administrative support for regulatory actions will be provided by the Office of

Subsistence Management, U.S. Fish & Wildlife Service, Department of the Interior.

Sincerely,

Anthony Christianson

Chair, Federal Subsistence Board

cc:: Commissioner, Alaska Department of Fish and Game

Assistant Regional Director, Office of Subsistence Management

Deputy Assistant Regional Director, Office of Subsistence Management

Chair, Yukon Kuskokwim Delta Subsistence Regional Advisory Council

Chair, Western Interior Alaska Subsistence Regional Advisory Council

Federal Subsistence Liaison Team Leader, Alaska Department of Fish and Game

Subsistence Council Coordinator, Office of Subsistence Management

Federal Subsistence Board

Interagency Staff Committee

Administrative Record

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