ELECTRONIC TRANSMISSION – NO HARD COPY TO FOLLOW
Submitted online via: https://www.regulations.gov/commenton/NPS-2026-0034-0001
Submitted by email to: Di******@*ps.gov, AK*************@*ps.gov, Do*********@*ps.gov
March 10, 2026
Jessica Bowron
Comptroller, Exercising the Delegated Authority of the Director
National Park Service
1849 C Street, NW
Washington, DC 20240
Don Striker, Acting Regional Director
Alaska Regional Office
240 West 5th Avenue
Anchorage, AK 99501
Subject: NPS Proposed Rule: Hunting and Trapping in National Preserves in Alaska Regulation Identifier Number (RIN) 024-AE96
Dear Acting Director Bowron and Acting Regional Director Striker:
I am writing on behalf of the Coalition to Protect America’s National Parks (Coalition), which represents nearly 5,000 current, former, and retired employees and volunteers of the National Park Service.
Collectively, our membership represents over 50,000 years of national park management and stewardship experience. Our members include former National Park Service directors, deputy directors, regional directors, and park superintendents, as well as a variety of program specialists and field staff. Recognized as the Voices of Experience, the Coalition educates, speaks, and acts for the preservation and protection of the National Park System, and mission-related programs of the National Park Service (NPS). We also count among our members many former NPS employees of national parks and preserves in Alaska, as well as NPS retirees who served on the Alaska Task Forces in 1979 and 1980 just prior to the passage of the Alaska National Interest Lands Conservation Act (ANILCA)1https://www.nps.gov/locations/alaska/upload/ANILCA-Electronic-Version.PDF
We are writing to call your attention to an apparent discrepancy between the Department of the Interior (DOI) press release2 https://www.doi.gov/pressreleases/interior-proposes-restore-state-aligned-hunting-regulations-alaska-national-preserves issued on March 6, 2026 for the subject proposed rule; and the Federal Register (FR) Notice3https://www.federalregister.gov/documents/2026/03/10/2026-04606/alaska-hunting-and-trapping-in-national-preserves issued on March 10, 2026 for the very same regulations. Whereas the DOI press release indicates there will be a 60-day public comment period on the proposed rule, the FR Notice indicates there will only be a 30-day public comment period.
We ask that NPS issue an immediate clarification regarding the actual intended length of the public comment period for this latest iteration of Alaska national preserve hunting regulations that have been revised multiple times, with much controversy, over the past 10+ years. If the NPS intent it to limit public comment to only 30 days this time, we hereby request a 30-day extension of the comment period, so that it allows for at least 60 days of public comment, similar to the lengths of the comment periods allowed on multiple previous versions of the proposed rule.
BACKGROUND
The potential for conflicts under ANILCA between the State’s approach to managing wildlife harvest and NPS wildlife management policies and values was recognized early on. For example, in addressing wildlife harvest, the Act’s legislative record described that “the Secretary shall manage National Park System units in Alaska to assure the optimum functioning of entire ecological systems in undisturbed natural habitats. The standard to be met in regulating the taking of fish and wildlife and trapping, is that the preeminent natural values of the Park System shall be protected in perpetuity, and shall not be jeopardized by human uses.” 126 Cong. Rec. H10549 (Nov. 12, 1980) (Statement of Rep. Udall).
The occurrence of conflicts between State and NPS wildlife harvest policies increased significantly after the State enacted its Intensive Management Law4Alaska Statute 16.05.255 (e)-(g) and (k) with the implementing regulations for predator control programs in Alaska Administrative Code 5 AAC 92.106, 108, 110-113, 115-116, 118, 121-124 and 127 (formerly all under 5 AAC 92.125) in 1994. Thereafter, the Alaska Board of Game (BOG) and the Alaska Department of Fish and Game (ADFG) began to adopt into the State’s sport hunting regulations a variety of so-called “liberalized” predator hunting practices that directly conflicted with NPS management policies related to wildlife. Despite numerous communications from NPS over the years to BOG and/or ADFG expressing concerns and requesting that the national preserves be excluded from such practices under the applicable State regulations, the BOG declined to take such action.
Finally, in 2015, NPS promulgated its own regulation5https://www.federalregister.gov/documents/2015/10/23/2015-26813/alaska-hunting-and-trapping-in-national-preserves based, in part, on a provision in Executive Order 141536https://www.whitehouse.gov/presidential-actions/2025/01/unleashing-alaskas-extraordinary-resource-potential/, which directs NPS to rescind its 2024 final hunting rule and reinstate the 2020 rule “in its original form.”
Based on our collective knowledge of the Alaska National Interest Lands Conservation Act (ANILCA), the legislative and administrative history of the management of national park units in Alaska under ANILCA, and litigation involving the 2020 hunting rule, we are very concerned about the harmful precedent and potential adverse impacts of this latest NPS proposed rule change. The proposed rule is fundamentally in conflict with longstanding NPS position(s) regarding the State’s liberalized sport hunting methods for harvesting predator species. Given the level of controversy surrounding this issue and the fact that NPS allowed at least 60 days of public comment on multiple previous iterations of the proposed rule, it is both inexplicable and concerning that NPS would now limit public comment to only 30 days.
1. JUSTIFICATION FOR 30-DAY EXTENSION OF THE PUBLIC COMMENT PERIOD
This latest proposed rule marks the 3rd time in the past 8 years that NPS has changed (or proposed to change) its 2015 Alaska national preserve hunting and trapping rule. It is a complex, controversial topic with considerable public and stakeholder interest. As such, it would serve the public interest to allow interested parties adequate time to review and prepare comments on the latest proposed rule change and EA. Since promulgating the 2015 hunting rule, NPS has already changed the rule twice as follows: 2018 proposed rule/2020 final rule; and 2023 proposed rule/2024 final rule. Now, NPS proposes to change the rule again for the third time in the past 8 years.
As evidence of the high level of public interest in this issue, the NPS received approximately 70,000 comments during the public comment period for the 2014 proposed rule that would become the 2015 final rule. These included unique comment letters, form letters, and signed petitions. Approximately 65,000 comments were form letters. The NPS also received three petitions with a combined total of approximately 75,000 signatures7https://www.federalregister.gov/documents/2015/10/23/2015-26813/alaska-hunting-and-trapping-in-national-preserves, with the vast majority of comments supporting the NPS proposed rule. In 2018, the NPS received approximately 211,780 pieces of correspondence on the proposed amendment of the 2015 rule with a total of 489,101 signatures. Of the 211,780 pieces of correspondence, approximately 176,000 were form letters and approximately 35,000 were unique comments.8https://www.federalregister.gov/documents/2020/06/09/2020-10877/alaska-hunting-and-trapping-in-national-preserves In that instance, the vast majority of public comments opposed the NPS proposed rule change. And for the 2023 proposed rule change, the NPS received 199,494 pieces of correspondence on that proposed rule, including 196,158 form letters and 3,336 unique pieces of correspondence.9https://www.federalregister.gov/documents/2024/07/03/2024-14701/alaska-hunting-and-trapping-in-national-preserves
With each subsequent proposed change to the 2015 rule, NPS has made significant changes back and forth in key provisions of the rule related to “sport hunting” methods that are allowed for taking predator species. At issue in each rule change has been which of the State’s so-called liberalized sport hunting methods for predators are in conflict or not with NPS management policies and therefore could be allowed or should be prohibited within the national preserves. These changes have occurred despite there being no substantive changes in applicable statutes (such as ANILCA or the NPS Organic Act, as amended10https://uscode.house.gov/view.xhtml?path=/prelim@title54/subtitle1&edition=prelim) or the related legislative history; no substantive changes in applicable NPS management policies; and no substantive changes in the extensive administrative history documenting NPS’s longstanding concerns about certain State-authorized liberalized sport hunting practices related to the take of predator species.
Meanwhile, the only substantive changes that have occurred during the past 8 years that would explain NPS changing the rule back and forth and now apparently back again have been changes in the respective Administrations that have overseen each rule change. In essence, the rule changes since 2015 have been based largely on political direction, rather than on meaningful changes in applicable statutes, management policies, or administrative history. With each new proposed rule change NPS has reinterpreted and reapplied the same unchanged guidance in order to try to explain or justify whatever each new rule change has proposed. As a result, NPS has not presented a consistent position in it interpretation of its own statutory and management policy guidance related to hunting in national preserves over the past 8 years, despite presenting a relatively consistent interpretation during the previous 35+ years. The changing NPS position(s) on predator hunting over the past 8 years have sometimes been at odds with NPS’s well documented and longstanding concerns about the State’s liberalized predator hunting techniques. While such concerns are well documented in the administrative history, the inconsistencies in NPS’s position(s) over the past 8 years makes the current proposed rule particularly challenging for the public to understand and/or to prepare comments about.
Now, based largely on the political directive in Executive Order 1415311https://www.federalregister.gov/documents/2025/01/29/2025-01955/unleashing-alaskas-extraordinary-resource-potential, rather than any substantive changes in applicable statutes or policies, NPS has issued another proposed rule change that is similar in many aspects to the 2020 rule that the U.S. District Court of Alaska12See Alaska Wildlife Alliance v. Haaland, 632 F. Supp. 3d 974 (D. Alaska 2022). found to be legally deficient. This means that the NPS will need to be particularly careful and creative in how it explains the rationale for its latest rule change, which further complicates the difficulties faced by the public in trying to understand and /or to prepare comments on the proposed rule. For these reasons, the current 30-day public comment period is insufficient time for public input on these complicated, controversial regulations; and we believe that a 30-day extension of the current 30-day public comment period would be reasonable and appropriate under the circumstances.
2. During the three (3) previous rulemakings (2014, 2018, 2023), NPS established the precedent of allowing at least 60 days initially for public comment; and in each instance NPS also granted extension requests during each public comment period to allow additional time (i.e., more than 60 days) for public comment. Specifically:
a) The original 2014 proposed rule (which resulted in the 2015 final rule) had a 90-day comment period plus a 30-day extension (open for comment for a total of 120 days).
On September 4, 2014, the National Park Service (NPS) published the proposed rule in the Federal Register (79 FR 52595). The rule was open for public comment for 90 days, until December 3, 2014. The NPS reopened the comment period from January 15, 2015 through February 15, 2015 (80 FR 2065). https://www.federalregister.gov/documents/2015/10/23/2015-26813/alaska-hunting-and-trapping-in-national-preserves
b) The subsequent 2018 proposed rule change of the 2015 rule (which resulted in the legally deficient 2020 final rule) had an initial 60-day comment period that was extended twice (open for comment for a total of 168 days).
On May 22, 2018, the NPS published the proposed rule in the Federal Register (83 FR 23621). This rule was open for an initial 60-day public comment. The NPS extended the comment period twice, first on July 19, 2018, 83 FR 34094, and again on September 6, 2018, 83 FR 45203, in response to requests from the public for more time to review the proposal. In total, the comment period was open for 168 days including both extensions. The comment period closed on November 6, 2018. https://www.federalregister.gov/documents/2020/06/09/2020-10877/alaska-hunting-and-trapping-in-national-preserves
c) The subsequent 2023 proposed rule change (which resulted in the 2024 final rule) had an initial 60-day comment period followed by a 17-day extension (open for comment for a total of 77 days).
On January 9, 2023, the NPS published the proposed rule in the Federal Register (88 FR 1176). The proposed rule was open for an initial 60-day public comment period. The NPS extended the comment period on March 10, 2023 (88 FR 14963), in response to requests from the public and the State for more time to review the proposal. In total, the comment period was open for 77 days including the extension. The comment period closed on March 27, 2023. https://www.federalregister.gov/documents/2024/07/03/2024-14701/alaska-hunting-and-trapping-in-national-preserves
In light of these precedents and given the fact that this, the third proposed rule change in the past 8 years, is no less complex or controversial than the previous rulemakings, all of which allowed greater than 60 days for public comment, it would be very reasonable and appropriate for NPS extend the public comment period by at least 30 days, thus allowing a total of at least 60 days of public comment on the 2026 proposed rule.
In closing, we would appreciate your careful consideration of this request.
Sincerely,
Cheryl A. Schreier, Chair
Executive Council
Coalition to Protect America’s National Parks
Email: Ed****@********ps.org
Mail: 2 Massachusetts Ave NE, Unit 77436, Washington, DC 20013
Web: www.protectnps.org
Phone: (202) 819-8622