My name is Phil Nuechterlein and my wife Linda and I have been packing with llamas in Alaska on public lands for more than 30 years. The National Park Service (NPS) is proposing to ban llamas from most of the National Parks in Alaska because of a perceived risk of disease transmission to wild animals. If we allow this to happen this will most certainly set a precedent and we can expect public land managers to follow the NPS lead to ban pack llamas on both federal and state lands all across the United States. If you care about being able to pack with llamas on public lands anywhere in the US, then this NPS decision could eventually affect you. The NPS proposal to ban llamas is currently open to public comment (until February 15, 2015). The NPS website to see their proposed ban and the link to make comments is as follows:
When you comment, please note that 9 separate identical submittals are necessary to cover all of the NPS parklands affected by the proposed llama ban (See 1-9 below). This is so that each of the 9 different NPS Superintendents will see your comments as they relate to their park. I suggest that you “copy and paste” to submit for each of the 9 parks to make things easier. By submitting identical comments for each of the following NPS parks you will have covered all of the areas encompassed in this NPS proposed llama ban.
1) Denali National Park and Preserve
2) Gates of the Arctic National Park and Preserve
3) Glacier Bay National Park and Preserve
4) Kenai Fjords National Park
5) Kobuk Valley National Park (Western Arctic National Parklands)
6) Klondike Gold Rush National Historic Park
7) Lake Clark National Park and Preserve
8) Wrangell-St. Elias National Park and Preserve
9) Yukon-Charley Rivers National Preserve
Here are some of my thoughts and opinions with respect to this proposed llama ban. Feel free to use my ideas (below) when commenting if you agree but it would be best to edit them to your tastes as opposed to using the material verbatim. When commenting, I suggest that you make it very clear that your comments pertain only to llamas (South American Camelids (SAC)) because domestic goats, sheep, and Bovidae are also included in this NPS proposed ban. These other animals are much harder to defend from a disease transmission risk standpoint.
– No one has ever documented the transmission of any disease from a llama to another species of animal, wild or domestic.
– The NPS and the Alaska Chapter of The Wildlife Society (an organization referenced in this NPS proposal) have not provided any scientific evidence of a llama disease transmission risk. All of their assertions are hypothetical. (The Alaska Chapter of The Wildlife Society web address ishttp://drupal.wildlife.org/Alaska/sites/wildlife.org.Alaska/files/red_disease_risk_statement.pdf)
– To date, I am not aware of any public lands in the US where pack llamas are prohibited on the basis of a disease transmission risk. If they are prohibited it is for other reasons.
– Historically, llama bans based on a risk of disease transmission have been proposed by the government agencies to include the US Fish & Wildlife Service (KOFA National Wildlife Refuge) and the National Park Service (Canyonlands and Glacier National Parks). After looking at the science, these agencies dismissed their concerns.
– Alaska hunting regulations effective beginning with regulatory year 2013-2014 imposed a ban on the use of domestic goats and domestic sheep as pack animals for Dall sheep, mountain goat, and muskox hunting. Llamas were specifically excluded from the ban after the Alaska Department of Fish & Game (ADF&G) studied the science of llama disease transmission risk and concluded that the risk was insignificant. The Alaska Board of Game agreed with ADF&G’s conclusion and adopted the new hunting regulation that allows the use of pack llamas for hunting.
– NPS states that they are not concerned about any disease transmission risk from horses. Horses can carry some of the diseases that NPS has identified as diseases of concern in their proposal. Is NPS not concerned about horses because they are not ruminants, more distantly related to the wildlife, and therefore less likely to transmit disease? If so, llamas are also not ruminants. Llamas are not even pseudo-ruminants according to “Medicine & Surgery of Camelids” third edition 2010 by Dr. Murray E. Fowler, DVM. See chapter 1.
– “Medicine & Surgery of Camelids” third edition 2010 by Murray E. Fowler, DVM dispels myths with regard to llamas and disease transmission. See chapter 7.
– The diseases of concern identified in the NPS proposal are either rare in llamas, not transmittable from llamas to wild game, or they do not occur in llamas.
– Any decision by the NPS should be based in science, fact, and truth. NPS offers no scientific evidence of a disease transmission risk. NPS offers only hypothetical risk scenarios. NPS concerns are misguided.
– If NPS chooses to take a zero risk policy with regard to disease transmission, this is unrealistic in today’s society and would serve to undermine the legitimacy and credibility of the decision-making policy.
Please let me know your thoughts, share any advice that you may have, and let me know if you think I am mistaken in any of my observations or conclusions. Please comment to NPS before the February 15th deadline. Maybe it would help to contact your US Senators and Representatives.
Eagle River, Alaska