Chugach National Forest (CNF) "short circuited" the NEPA process by providing no pubic notice to eliminate commercial use of pack llamas based on a perceived disease threat to wild sheep and goats. Since CNF's ban identifies pack llamas as a disease threat, this opens the door to eliminate them for all uses (including recreational) in the future. The public process was "short circuited" because CNF did not include verbiage that banned llamas in their draft Chugach National Forest Land Management Plan that was open for public comment in 2018. However, this pack llama ban was added to the Final Chugach National Forest Land Management Plan after the public comment period was over which effectively eliminated comment by the pack llama user group. Now the pack llama user group is faced with protesting the final CNF decision during the objection period. Your comments on past proposals to ban llamas on pubic lands has been very effective and we need your support again. We need to turn the tide on this CNF “Final” decision otherwise this may establish a precedent to eliminate the pack llama user group in the lower 48 states. Our last chance to comment is now.
Please send your comments in objection to the Chugach
National Forest Land Management Plan during the 60 day objection period ending
October 28, 2019. See the sample comments
below to assist you in crafting your comments. Feel free to use any or all of the verbiage in the sample comment. Be sure to state that your comments are an objection to the Final Chugach
National Forest Land Management Plan as signed by Jeff E. Schramm, Forest
Supervisor and provide your full name with telephone number and/or email
address. To view documents associated with the CNF Land Management Plan go to this link - https://www.fs.usda.gov/project/?project=40816.
Objections must be submitted to the Objection Reviewing Officer by one of the following methods:
Objections must be submitted to the Objection Reviewing Officer by one of the following methods:
• Electronically to the Objection Reviewing Officer via the
CARA objection web form:
https://cara.ecosystem-management.org/Public//CommentInput?Project=40816
Electronic submissions must be submitted in a format (Word, PDF, or Rich Text) that is readable and searchable with optical character recognition software. An automated response will confirm that the electronic objection was received.
• Via regular mail, carrier, or hand delivery to the
following address: USDA Forest Service, Attn: Objection Reviewing Officer,
Alaska Region, 709 W. 9th Street, Juneau, AK 99801, or P.O. Box 21628, Juneau,
AK 99801. Note that the office hours for submitting a hand-delivered objection
are 8:00 a.m. to 4:30 p.m., Alaska Time, Monday through Friday, excluding
federal holidays.https://cara.ecosystem-management.org/Public//CommentInput?Project=40816
Electronic submissions must be submitted in a format (Word, PDF, or Rich Text) that is readable and searchable with optical character recognition software. An automated response will confirm that the electronic objection was received.
• Via fax to (907) 586-7840. Faxes must be addressed to “Objection Reviewing Officer.” The fax coversheet should specify the number of pages being submitted.
• Individuals who use telecommunication devices for the deaf (TDD) may call the Federal Information Relay Service (FIRS) at 1-800-877-8339 between 8:00 a.m. and 8:00 p.m., Eastern Standard Time, Monday through Friday.
An objection must include the following (36 CFR 219.54(c)):
1. The objector’s name and address along with a telephone number or email address if available—in cases where no identifiable name is attached to an objection, the Forest Service will attempt to verify the identity of the objector to confirm objection eligibility;
2. Signature or other verification of authorship upon request (a scanned signature for electronic mail may be filed with the objection);
3. Identification of the lead objector when multiple names are listed on an objection. The Forest Service will communicate to all parties to an objection through the lead objector. Verification of the identity of the lead objector must also be provided if requested;
4. The name of the land management plan revision or Regional Forester’s list of species of conservation concern being objected to, and the name and title of the responsible official;
5. A statement of the issues and/or parts of the land management plan revision or Regional Forester’s list of species of conservation concern to which the objection applies;
6. A concise statement explaining the objection and suggesting how the draft record of decision may be improved. If the objector believes that the plan revision or Regional Forester’s list of species of conservation concern is inconsistent with law, regulation, or policy, an explanation should be included;
7. A statement that demonstrates the link between the objector’s prior substantive formal comments and the content of the objection, unless the objection concerns an issue that arose after the opportunities for formal comment; and
8. Documents referenced in the objection must be included with the objection (include the document, web link to document, or both), except for the following list of items that may be referenced by including the name, date, page number (where applicable), and relevant section of the cited document.
(a) All or any part of a federal law or regulation,
(b) Forest Service Directive System documents and land management plans or other published Forest Service documents,(c) Documents referenced by the Forest Service in the planning documentation related to the proposal subject to objection, and
(d) Formal comments previously provided to the Forest Service by the objector during the plan amendment comment period.
The final CNFLMP decision states on page 55, “Personnel conducting Forest Service management actions or authorized activities (employees, contractors, cooperators, and special use permit holders)” shall not use or keep “lamas”. While this apparently does not apply to public recreational pack llama users, it does not allow “lamas” for these specified activities (to include commercial llama packing). CNF’s point of introduction through use by sanctioned personnel leaves the door wide open for banning private recreational use in a predictable, logical progression. If they are established as a threat in official use, it would follow they are a threat in all types of use. Therefore I strongly object to the “final” Chugach National Forest Land Management Plan (CNFLMP) restrictions/prohibitions on pack llamas for the following reasons-
1.
Chugach
National Forest (CNF) has demonstrated an alarming lack of transparency. CNF avoided
the intent of the NEPA process by not providing any public notice of their
intent to prohibit/restrict pack llamas during the prescribed public comment
process associated with the draft CNFLMP. The draft CNFLMP says
nothing about llamas so the public would assume that the CNFLMP would not
change anything with regard to the use of pack llamas in CNF. Now the public is
suddenly faced with a final CNFLMP that contains pack “lama”
prohibitions/restrictions. Consequently, the public is now being forced by CNF to
protest the final decision as opposed to being offered a fair opportunity to
comment during the prescribed NEPA public comment processes. To further support
the very underhanded and secretive draft CNFLMP process, CNF successfully
thwarted further public comment by misspelling llama as “lama”. If CNF had intended to refer to the llama by genus rather than common name, then logic would have it that CNF would also have referred to goats and sheep by genus rather than by common name.
2.
CNF
provides no evidence of a pack llama disease risk. The sole reference
in the final Environmental Impact Statement (EIS) for the CNFLMP is a Canadian
publication (Garde, E., et al. 2005) that discredits itself (within the
document itself on page 2) as unscientific by stating that there is
insufficient data to clearly assess the role of camelids as a source of
disease. CNF essentially “cherry picked” one unscientific document that
consists of a hypothetical risk scenario to support their position that “lamas”
present a disease risk to wild sheep and goats. The authors of Garde publication
ignored the overwhelming amount of US scientific data that specifically identifies
llamas as extremely low risk for disease transmission due to taxonomic
characteristics that widely separate them from wild sheep over 40 million years
of evolution. Wild sheep and goats are afforded strong disease barrier protection
associated with this widely separated taxonomy. Llamas are from the family Camelidae while wild sheep, domestic sheep,
and goats are from the family Bovidae. CNF has demonstrated lack of
understanding of fundamental taxonomic principles and disease epidemiology by
categorizing “lamas” in with sheep and goats with complete disregard of the
wealth of US scientific literature that is available on this subject.
3.
Given the
overwhelming amount of US scientific data that demonstrates the safety record
of llamas (see packllamas.org) and given the taxonomic separation of llamas from
wild sheep and goats, if CNF follows through with their arbitrary
identification of pack llamas as a disease threat, CNF will be required to impose these same restrictions on pack horses (Equidae
family) that they have placed on pack llamas (Camelidae family). Horses
(equine species) are a greater disease risk than llamas as they have a number
of endemic disease susceptibilities (equine influenza, equine
encephalomyelitis, equine herpesvirus rhinopneumonitis-EHV, Potomac Horse
Virus, vesicular stomatitis, strangles, etc.). Llamas have no identified
endemic diseases and are naturally healthy and disease free. Additionally,
llamas have an exceptionally strong, broad spectrum immunologic system such
that their serum is being considered in development of flu vaccines for humans
that give a wider spectrum and more enduring protection. See https://www.health.com/cold-flu-sinus/llama-flu-vaccine
. All current information and history indicate llamas present less disease
threat to wild sheep than horses and humans. Humans develop zoonotic infections
(TB, MAP, and CE) which can be transmitted to wild sheep. In view of these considerations, it is
arbitrary and prejudiced to eliminate llamas on the basis of “precautionary
principle” while allowing continued access to horses and humans.
4.
The final
CNFLMP position on pack llamas is at odds with the official position of the Alaska
Department of Fish and Game (ADF&G) and the Western Association of Fish and
Wildlife Agencies (WAFWA). Per a letter from ADF&G dated June 11, 2018,
(see packllamas.org website) ADF&G’s position is “at this time we have no
intention to promote or support limiting the use of South American camelids on
public land in the State of Alaska”. This decision was made by ADF&G
despite the fact that they supported and helped pay for a camelid disease study
(RA) report. The ADF&G letter states “there is no significant information
in the RA. After discussing the document internally and with other biologists
from several jurisdictions (including the Western Association of Fish and
Wildlife Agency Wild Sheep Work Group - WSWG), we will continue to focus and
enhance our evaluation of disease risk from species other than llamas or
related camelids. There is not enough information presented in this report or
other current publications to warrant spending additional resources on this
issue.” Furthermore, the ADF&G letter states “we understand that the WSWG
pulled the RA report from their website partially due to some concerns about
the report itself.”
The Western Association of Fish and
Wildlife Agencies (WAFWA) positions are foundational to ADF&G’s stated
policy. WAFWA is widely recognized among state and federal wildlife agencies as
the scientific reference for wildlife disease issues. The CNFLMP position on
“lamas” is in direct conflict with wildlife disease management recommendations
of WAFWA wildlife researchers and veterinary authorities.
5.
The
CNFLMP appears to be inconsistent with USDA - Forest Service research and
policy regarding the "pack llama disease issue" in other Forest
Service jurisdictions. The Shoshone
National Forest Land Management Plan Revision FEIS Volume II states "Pack
animals that do not pose disease transference issues including llamas, horses,
donkeys, and assistance dogs are not restricted for use by elderly forest
visitors." Also see USDA - Forest Service research/technical publications
entitled "A Review of Disease Related Conflicts between Domestic Sheep and
Goats and Bighorn Sheep", also see "A Process for Finding Management
Solutions to the Incompatibility between Domestic and Bighorn Sheep". Both Forest Service publications specifically
address pack llamas with disease research that is favorable to their use in
wild sheep habitat.
In summary, I request that CNF refrain from identifying “lamas” (pack llamas) as a disease threat and remove all reference in the final CNFLMP that implicate them as a disease threat. By this letter I am providing formal notice of objection to the Final Chugach National Forest Land Management Plan (signed by Jeff E. Schramm, Forest Supervisor) during the 60 day objection period ending October 28, 2019.
***If you are submitting a comment electronically, don't include personal info in your online comment as this can be viewed by anyone.
Go to this link if you want to see posted for comments- Comments by Others- CNF Reading Room