Every three years, we, the public have an opportunity to change Alaskan hunting and trapping regulations. Many people don’t realize it, but regulations are not made by the Alaska Department of Fish and Game, but by the Alaska Board of Game (BOG)—seven people appointed by the governor and approved by the legislature.

March 2023 is an important opportunity to improve regulations for the South Central region. Citizens and organizations have submitted proposals to the BOG to change regulations for our region, and the Board will vote on them at a Soldotna meeting March 17 - 21, 2023.

Public comment is a very important part of this process. Sound (and maybe some less-sound) suggestions can become regulation if there is enough public support, and if political winds are blowing the right direction. There is momentum behind a few good proposals and a few bad eggs that need to be stopped. Please take a few minutes to submit comments on proposals to the BOG by March 3, 2023. 

Comments should be submitted using this online form.

State clearly if you OPPOSE or SUPPORT and concisely explain why.

If you are passionate about any of the issues, please contact us, because we will be coordinating carpooling up to Soldotna for in-person testimony—the best kind—on March 17.

Support Proposals 164 and 166 

Reduce the bag limit for goldeneye in Units 7 and 15 as follows: Bag limit for Goldeneye: 4/day, 8 in possession.

Reduce the bag limit for bufflehead in Units 7 and 15 as follows: Bufflehead: 4/day, 8 in possession.

See full proposals here and here. 

• A bag limit reduction on bufflehead and goldeneye is needed to ensure hunt opportunities now and in the future. 
• These limits will not hurt the businesses of hunting guides operating in the bay. They will not hurt the ability of folks to harvest food. 
• Current limits are very high for these species: 8 a day, 24 in possession.
• Anecdotal evidence from long-time residents and statistics from the The U.S. Committee of the North American Bird Conservation Initiative “State of the Birds” 2022 report (which shows a national decline in sea duck populations of 30% from 1970 to 2022) indicates that there was a significant decline in sea duck populations in K-Bay in the 1990s. We should be working to try to recover populations. 
• Populations of sea ducks are slow to recover from over-harvest, unlike other “small game,” because of they have high site-fidelity (they come back to the same place every year), they don’t reproduce until they are 2-3 years old, and they generally only lay one clutch per year.
• Harvest can jump significantly in K-Bay, with the addition of more guides and people, as we saw clearly in the winter of 2021. ADF&G does not have the ability to limit the number of guides operating in K-Bay, and the addition of even one more guide to can do real damage to populations (one boat, five clients, each client harvesting 8 a day, under current regs., 24 birds in 3 days x 5 = 120).
• Limiting harvest is one of our only mechanisms for protecting populations and supporting their recovery.
• Goldeneye and Bufflehead live in inside waters and so are particularly prone to over-harvest.
• While ADF&G managers argue that Pacific Flyway counts are the best way to manage K-Bay sea ducks, we believe local management is useful and necessary because:

• Sea duck populations have exceedingly high levels of site fidelity--they come back to the same place every year.
• Many of Alaska’s sea ducks do not go down to the Lower 48 to nest, where Pacific Flyway surveys are conducted. Instead, many of our birds go up to Alaska's northern boreal forests and deltas to lay their eggs. The Pacific Flyway surveys are not even counting them!
• Kachemak Bay is arguably the easiest place to access sea ducks in all of Alaska. 
• “Kachemak Bay is the most important marine bird habitat in lower Cook Inlet (Erikson 1977) and there are no comparable areas in upper Cook Inlet. During winter months over 90% of the marine birds in lower Cook Inlet are found in Kachemak Bay (Erikson 1977). Few birds inhabit the offshore waters of lower Cook Inlet in winter, and the extensive inshore ice in the upper inlet and along the western shore is avoided by most marine birds…” (“Kachemak Bay and Fox River Flats Critical Habitat Area Management Plan”). 
• Kachemak Bay is an ADF&G Critical Habitat Area, whose legislative purpose is “to protect and preserve habitat” and the Kachemak Bay Management Plan says that “priority should be given to encouraging rehabilitation of depleted indigenous fish and wildlife populations" (5 AAC 95.610).
• "The Board of Fisheries and the Board of Game, where appropriate, shall adopt regulations they consider advisable for conservation and protection purposes governing the taking of fish and game in state fish and game critical habitat areas." (AS 16.20.510).
• We do not have reliable local or national data on populations or harvest of sea ducks, so we should act conservatively.

Support Proposal 169 

Reduce the bag limit for harlequin in Unit 15C as follows: 1 Harlequin per day, 2 in possession. 

See full proposal here. 

See comments for Proposals 164 and 168 above.

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Support Proposal 171 

Direct the Department of Fish and Game to institute means and methods to record sea duck harvest as accurately as possible in Units 6, 7 and 15.

See full proposal here.

• We should keep tabs on harvest, so that we can know if there is a spike and respond to protect populations. It's like a flag that goes up. 
• Regulatory language could be modeled on similar regulations in the State of Washington, which has a mandatory online hunt report system: fishhunt.dfw.wa.gov
• Harvest can jump significantly in K-Bay with the addition of even one more guide, (one boat, five clients, each client harvesting 8 a day, under current regs., 24 birds in 3 days x 5 = 120). But F&G does not have the ability to limit the number of guides working in K-Bay. 
• Using harvest data to manage populations is common and common-sense. For example, black bear populations are managed though harvest data alone (since the buggers are hard to count from the air). 
• The existing reporting system, HIP, does not give managers nearly enough information. It invites voluntary reporting from a very small, randomized group of hunters from all across the state. ADF&G staff have acknowledged that HIP doesn’t give us enough information to make decisions.
• Local hunting guides are in favor of this proposal, because they keep track of harvest anyway, and because it may even dispel some of the concerns of over-harvest.
• ADF&G has said that they do not manage sea ducks based on local populations or harvest because they are migratory waterfowl. They would rather use data from the Pacific Flyway and extrapolate from these counts. Sea ducks, however, have a very high degree of site fidelity; many of our local species are not even included in the Pacific Flyway counts; many of our populations never even go to the lower 48, where most of the flyway data comes from, and many are nesting in boreal tree cavities when surveys are done (pretty hard to see a duck in a tree). 
• Anecdotal evidence from long-time residents and statistics from the The U.S. Committee of the North American Bird Conservation Initiative “State of the Birds” 2022 report (which shows a national decline in sea duck populations of 30% from 1970 to 2022) indicates that there was a significant decline in sea duck populations in K-Bay in the 1990s. We should be working to try to recover populations. We should monitor harvest within K-Bay because populations will not recover from consecutive years of over-harvest—high site-fidelity and low reproduction rate.
• It is ideal to pair harvest data with population trends. Homer residents would like to work with ADF&G to pair harvest data with our K-Bay citizen science population surveys to improve harvest management in our Critical Habitat Area and State Park waters. 2023 was our 3rd Annual Sea Duck Survey, with 10 boats and almost 40 participants, the accuracy of our data is evident in the fact that we always double count an area with two different boats and get very similar survey results.  
• While ADF&G managers argue that Pacific Flyway counts are the best way to manage K-Bay sea ducks, we believe local management is useful and necessary because:
• Sea duck populations have exceedingly high levels of site fidelity--they come back to the same place every year.
• Many of Alaska’s sea ducks do not go down to the Lower 48 to nest, where Pacific Flyway surveys are conducted. Instead, many of our birds go up to Alaska's northern boreal forests and deltas to lay their eggs. The Pacific Flyway surveys are not even counting them!
• Kachemak Bay is arguably the easiest place to access sea ducks in all of Alaska. 
• “Kachemak Bay is the most important marine bird habitat in lower Cook Inlet (Erikson 1977) and there are no comparable areas in upper Cook Inlet. During winter months over 90% of the marine birds in lower Cook Inlet are found in Kachemak Bay (Erikson 1977). Few birds inhabit the offshore waters of lower Cook Inlet in winter, and the extensive inshore ice in the upper inlet and along the western shore is avoided by most marine birds…” (“Kachemak Bay and Fox River Flats Critical Habitat Area Management Plan”). 
• Kachemak Bay is an ADF&G Critical Habitat Area, whose legislative purpose is “to protect and preserve habitat” and the Kachemak Bay Management Plan says that “priority should be given to encouraging rehabilitation of depleted indigenous fish and wildlife populations.” 
• We do not have reliable local or national data on populations or harvest of sea ducks, so we should act conservatively. 

Oppose Proposal 163 

Rescind the bag limit restrictions for sea duck hunting in Unit 15C as follows: In effect, eliminate special sea duck restrictions for Unit 15C, restoring seasons and bag limits applicable to the entire Gulf Coast Zone. 
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See full proposal here. 

• This proposal would change the bag limit restrictions put in place in 2010 to protect vulnerable populations of sea ducks. They want to change the current regulation that says  “2 per day, 4 in possession of harlequin or long-tailed ducks, and no more than 1 per day, 2 in possession of eiders (king or common). In addition, nonresidents may not take or possess more than 4 each of any scoter or merganser species.”
• This proposal not supported by the Homer Fish and Game Advisory Committee. It is not supported by local sea duck hunters or commercial guides, because it is not necessary or prudent to increase harvest on these populations. 
• Anecdotal evidence from long-time local residents and statistics from the The U.S. Committee of the North American Bird Conservation Initiative “State of the Birds” 2022 report (which shows a national decline in sea duck populations of 30% from 1970 to 2022) indicates that there has been a significant decline in sea duck populations in K-Bay. We should be working to recover these populations, and bag restrictions are one of our only tools.
• Kachemak Bay is an ADF&G Critical Habitat Area, whose legislative purpose is “to protect and preserve habitat” and the Kachemak Bay Management Plan says that “priority should be given to encouraging rehabilitation of depleted indigenous fish and wildlife populations.”
• Hunters here are happy with the status quo. There is no need for change. 
  
  

Oppose Proposal 162

Extend the ptarmigan season in a portion of Unit 15C to March 31 as follows: I propose leaving the bag limit at five and ten in possession with the hunt dates increased back to original that were August 10th - March 31st. The spring hatch has been good, and the numbers are high. 

See full proposal here.

• We shortened the season for a good reason in 2014-2015 for a good reason, and there is not a good reason to revert back to a long season.
• The harvest that is advocated in this proposal is what is known as “additive”—that means that when you harvest a ptarmigan in the fall, you don’t have such a big impact on the population, since the winter is the biggest killer, but if you harvest in the spring, you are taking the birds from the population that survived the winter, the ones that  should reproduce, and you have a way bigger impact on the population health. 
• The impetus for a shorter season came when the late Bruce Willard submitted a proposal to the BOG for their 2014-2015 meeting cycle to shorten the ptarmigan hunting season in a portion of 15C because of a “significant decline in ptarmigan numbers has occurred in Unit 15C north of Kachemak Bay”. The ADF&G 2014 ptarmigan breeding survey validated that very low breeding densities in this area was a long-term trend, not just a one year event.
• Springtime is way too easy to hunt ptarmigan in 15C—snow machines with plenty of snow, warmer temperatures and more light can cover enormous distances and really cut down the ptarmigan population. That’s what happened in the early 2000s when the reduced season was instituted, and that is what will happen again if we go back to the way things were. 
• After several years of no spring ptarmigan hunt, it appears as if the ptarmigan population in the hills above Homer is increasing. The plan is working. Keeping the status quo should result in greater abundance of ptarmigan in this area, to the benefit of both hunters and bird watchers. Going back to allowing a spring hunt could quickly revert to low populations of ptarmigan and limited opportunity for outdoors people to enjoy our state bird.
• Bag limits have little effect as most hunters take an average of 3 birds/trip.  So it is the number of hunters, timing of season, and access that really drives effects from hunting.  
• The current regulation allows for a good hunt on ptarmigan in 15C. It is August 31 – January 31; 5 ptarmigan per day, 10 in possession.
• The season we have now allows for a healthy fall/early winter hunt. If ptarmigan populations are healthy, those hunts will be very good. And that’s how it should work.
  

Support Proposal 146

100 yd. setbacks for traps from 3 popular winter trails in Kachemak Bay State Park.

Read the proposal here.

• Require a 100-yard setback of traps from the Diamond Creek Trail, Grewingk Glacier Lake Trail and the Grewingk Saddle Trail within Kachemak Bay State Park. These trails are heavily used by the public during trapping season, accompanied by their dogs. 

• More than 8 pet dogs have been trapped recently on popular Homer trails. This is a real problem!

•With a growing population on the lower Kenai Peninsula, and particularly in Homer, an increase in non-consumptive users on multi-use trails, conflict in trapping areas is becoming more common in Unit 15C. If nothing is changed, more dogs will be trapped, causing unnecessary harm to State Park users and dogs, and huge public outcry.

• User conflicts are time consuming and energy draining for all involved. Already overtaxed and underfunded, ADF&G employees and State Park staff will be increasingly burdened. 

Support Proposal 147

100 yd. setbacks for traps from mapped KNSC ski & mapped multi-use Snomads trails in Homer area. 

Read the proposal here.

• More than 8 pet dogs have been trapped recently on popular Homer trails. This is a real problem!
• Trappers in these areas are on snow machines and it is not a significant inconvenience for them to set traps off the trail.
• With a growing population on the lower Kenai Peninsula and an increase in non-consumptive users on multi-use trails, conflict in trapping areas is becoming more common in Unit 15C. 
• Local trappers and other trail users worked together to develop these proposals. 
• If a 100-yard setback is not implemented, there will be more user conflicts on public trails.

Support Proposal 145

Close areas to hunting and trapping within 1/4 mile of parts of the Sterling Highway in Units 7 and 15.

See full proposal here.  

• The highway construction plans include multiple wildlife underpasses and Alaska's first wildlife overpass. Fencing is meant to keep wildlife off the road and funnel them through crossings, but current regulations allow for hunting and trapping on these crossings. Make these multi-million dollar crossings safe passages for wildlife.

• Without a change in regulation, hunting and trapping would be permitted on and at the entrance/exit of multi-million dollar structures meant to create safe passage across the highway; underpasses and bypasses that are meant to benefit wildlife, could turn into a population sink. 

• Ensure that the $10+ million investment of public funds to help wildlife navigate an increasingly congested part of the Kenai Peninsula is honored by State hunting and trapping regulations. 

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Suport Proposal 160 

Limit beaver trapping to one set per lodge and only one beaver may be removed per lodge in Units 7 and 15. All lodges that have been or are being trapped in the current season must be visually marked with a pole set vertically in the ice. 

See full proposal here.

• Trapping appears to be a major factor in the extirpation of beavers in many areas of the Kenai Peninsula. 
• Trapping records in Units 7 and 15 show that beaver populations have declined significantly from historic times (1950-1970) to now is significant. 
• This is a carefully crafted proposal to allow for beaver trapping to continue (as many members of the Board of Game want to see) but to try to make sure that we do not continue to over-harvest. It has been tested in the Kenai National Wildlife Refuge to good effect. 
• Multiple trappers in one area can contribute to over-harvest of beaver lodges.
• The low numbers of beavers around the road system is a strong indicator that access (trappers using the roads) is driving down beaver populations. 
• It is in the public interest to rehabilitate beaver populations on the Kenai Peninsula for the following reasons:
• Beavers make critical habitat for baby salmon and trout.
• The habitat beavers create is good for moose populations.
• Beavers improve water quality and mitigate flooding (and associated erosion and landslides) and everyone wins!
• They store water during drought - remember 2019? Summers on the Kenai are  on a warming and drying trend. The water that beavers store and habitat that beavers create are essential for humans, healthy salmon and trout populations, and help mitigate the risk of large-scale wildfire.

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Support Proposal 156

Close beaver trapping in the Anchor River and Deep Creek Drainages in Unit 15C for six years with a required review before re-opening.
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• The Anchor River beaver population needs some time to recover.

• According to ADF&G, historically the Anchor River drainage has supported a significant harvest of beavers. In 1976, almost half (64 of 136) of the beavers taken in Unit 15 came from the Anchor River drainage system. The last documented harvest of beavers in this unit was 1 beaver in 2011; prior to this, a beaver had not been harvested since 2006 when 4 beaver were taken, despite active trappers in the area.
• Beaver harvest across Unit 15C has declined significantly in recent years, from an average of 22 beavers per year (2012-2016) to 5 in 2017. Trappers reported to local staff low numbers and poor recruitment along traditional trap lines in 2017.

• ADF&G does not conduct surveys for beavers on a regular basis on the Kenai Peninsula. In
2018, a beaver survey was flown covering the Anchor River and surrounding drainages. One active site was found within the Anchor River drainage. Surrounding drainages held multiple active sites.

• It is in the public interest to rehabilitate beaver populations on the Kenai Peninsula for the following reasons:

• Beavers make critical habitat for baby salmon and trout.
• The habitat beavers create is good for moose populations.
• Beavers improve water quality and mitigate flooding (and associated erosion and landslides) and everyone wins!
• They store water during drought - remember 2019? Summers on the Kenai are  on a warming and drying trend. The water that beavers store and habitat that beavers create are essential for humans, healthy salmon and trout populations, and help mitigate the risk of large-scale wildfire.

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