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U.S. Fish and Wildlife Service Responds to State Concerns About Caribou Management

On May 20, 2010 the Alaska Department of Fish and Game sent a letter to
U.S. Fish and Wildlife Service's Acting Director Rowan Gould announcing the
State's intention to begin a predator control operation on Unimak Island on
or about June 1, 2010. The Service today responded to that letter. Unimak
Island is part of the Alaska Maritime National Wildlife Refuge and National
Wilderness Preservation System. In 1980, the Alaska National Interest Lands
Conservation Act set forth major purposes for establishing and managing
Alaska Maritime National Wildlife Refuge. Among these are to conserve the
refuge's animal populations and habitats in their natural diversity, and to
provide opportunities for continued subsistence uses by local residents.
Among other points, Director Gould's letter included the following:

The State first raised concerns about the viability of the caribou
herd on Unimak Island to the U.S. Fish and Wildlife Service in
December 2009. Since that time, the Service's Alaska Region has
worked closely with Alaska Department of Fish and Game to better
understand the biological issues at hand. The Service has issued
permits to allow additional radio collaring and biological sampling
of wolves and caribou; and has discussed, at length, the process
federal land managers must follow prior to initiating new management
programs.

The Service's Alaska Region has begun that process, including working
toward National Environmental Policy Act compliance, to determine
appropriate management alternatives and actions.

Although we acknowledge the sense of urgency facing the Unimak Island
caribou herd, we, as a federal agency, are required to be transparent
in our actions. Completing the NEPA process will provide that
transparency.

We have used the NEPA process in every instance where we conducted
predator control on National Wildlife Refuge lands in Alaska,
including the Rat Island invasive rat eradication project and the
trapping of foxes to protect brant colonies on the Yukon Delta.

The proposed predator management by the State of Alaska, or its
agents, on Unimak Island requires a special use permit from the U.S.
Fish and Wildlife Service and is considered a significant action
since aerial predator control has not been conducted on National
Wildlife Refuge lands in Alaska in recent history. Conducting any
such activity without a special use permit from the U.S. Fish and
Wildlife Service would be a violation of the National Wildlife Refuge
System Administration Act, as amended, and considered as a trespass
on the Refuge; and would be immediately referred to the United States
Attorney.

Director Gould concluded that the agency values greatly its
relationships and tradition of partnership with the Alaska Department
of Fish and Game, and encouraged the State to continue to work with
the Alaska Region on this issue following the path required for major
actions taken by federal agencies. He reaffirmed the Service's belief
that the amount of time needed to utilize a sound and legally
supportable decision-making process will allow state and federal
agencies to better understand desired wildlife population outcomes
and to define the management actions necessary to attain those
outcomes.

The Service shares the State's concern for caribou populations on Unimak
Island, and will continue to conduct its management activities in
accordance with the refuge mandates of ANILCA. We believe the Unimak Island
caribou population and the public are best served by continuing the
enviable history of cooperation and communication between the Alaska
Department of Fish and Game and the U.S. Fish and Wildlife Service.

The mission of the U.S. Fish and Wildlife Service is working with others to
conserve, protect and enhance fish, wildlife, plants and their habitats for
the continuing benefit of the American people. We are both a leader and
trusted partner in fish and wildlife conservation, known for our scientific
excellence, stewardship of lands and natural resources, dedicated
professionals and commitment to public service. For more information on our
work and the people who make it happen, visit www.fws.gov.

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