Mulchatna Predator Control | Alaska Wildlife Alliance (AWA)

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MULCHATNA BEARS UPDATE

On March 14, Judge Guidi of the Superior Court of Alaska ruled in favor of the Alaska Wildlife Alliance, finding that the Mulchatna Bear Control program—through which the State has aerially gunned nearly 200 brown bears—was “unlawfully adopted and, therefore, void and without legal effect.”

At the Board of Game Meeting the following week, ADFG petitioned the Board to adopt an emergency regulation to reinstate Mulchatna bear control so it could take place in spring 2025, in spite of the court ruling. Despite extensive public opposition, the Board voted to re-open Mulchatna bear control for 2025. We are currently exploring all our legal options to counter the State’s efforts to circumvent a court order.

The Mulchatna Predator Control Program

About 100 miles west of Katmai’s Brook Falls, famous for its "Fat Bear Week", and just next to the Togiak National Wildlife Refuge, lies Wood-Tikchik State Park, the largest state park in the United States. Created to protect the area’s fish and wildlife, the state park is home to all five salmon species, black and brown bears, and caribou. 

In 2022, the State of Alaska created a bear-control program in the Wood-Tikchik basin, hiring State employees and contractors to aerially gun down nearly 200 bears from helicopters and spotting planes, despite opposition from dozens of biologists and the public.

The proposal that established this program was developed behind closed doors, and the public did not have a chance to comment before it was passed. 

As a result, 99 bears, including 20 cubs, were killed by the State’s aerial gunners in less than a month in 2023.

In 2024, the State killed 81 brown bears in one month.

The program is scheduled to continue every Spring until 2028.

The State’s Board of Game and/or the Commissioner of ADF&G can stop the program but have so far denied the requests of countless biologists and the public.

AWA filed a lawsuit against the State for unlawfully adopting this bear control program without biological, fiscal, or public review. In March 2025, the Superior Court of Alaska ruled in favor of the Alaska Wildlife Alliance, finding that the Mulchatna Bear Control program was “unlawfully adopted and, therefore, void and without legal effect.”

At the Board of Game Meeting the following week, ADFG petitioned the Board to adopt an emergency regulation to reinstate the Mulchatna predator control so that bear control could take place in spring 2025 in spite of the court ruling. Despite extensive public opposition, the Board voted to re-open Mulchatna bear control for 2025.

The Issue

The driving factor behind the Mulchatna predator control program is the decline of the Mulchatna caribou herd. At its peak in 1997, the Mulchatna caribou herd reached over 200,000 animals. During this time, around 4,770 caribou a year were harvested from the herd for the subsistence needs of more than 48 local communities, providing a vital food source for rural southwest Alaska.

Image taken from the ADF&G Mulchatna Newsletter, 2021.

However, in the late 1900s and early 2000s, the herd began to decline steeply. By 2009, the herd numbered 30,000 animals. By 2019, it consisted of just 13,000 - a 94 percent decline from its peak. The population objective set by the State for the Mulchatna herd is between 30,000 and 80,000 animals; the population remains far fewer today.

In 2020, a group of State biologists were tasked with studying the vanishing herd. They found that the main reasons for the decline were disease and a lack of food. Brucellosis, a relative of mad cow disease, has decimated the herd, causing lameness, infertility, and lower birth rates. Over a third of the caribou tested at the time were infected. Likewise, climate change has slowly shifted the Mulchatna herd’s habitat. The lichen that caribou depend upon is disappearing, and the landscape is becoming more and more shrubby; prime moose habitat, but poor caribou habitat. Overpopulation and habitat damage when the herd numbered 200,000 may have also contributed to the sharp decline.

To try and save the Mulchatna herd, the State enacted a predator control program, operating under an Intensive Management law passed in 1994 that allows ADF&G to take action to manage struggling populations. One of the tools under Intensive Management is predator control, which allows the increased killing of large carnivores like wolves and bears to increase ungulate populations for hunter harvests. Despite AWA’s persistence and the overwhelming evidence that these predator control programs do not work to recover struggling moose and caribou populations, the State Board of Game continuously approves these programs. To read AWA’s full position on Intensive Management and predator control, please read our position paper.

In areas known as Predator Control Areas, ADFG is authorized to shoot bears and wolves from helicopters and fixed-wing aircraft, as well as kill predators of any sex and age. While a wolf control program has existed in the Wood-Tikchik area for years, it wasn’t until 2023 that the State adopted a bear control program as well. In the last two years, the bear control program has resulted in the killing of 175 brown bears.

However, bear predation isn’t even in the top three identified causes of mortality among the Mulchatna herd (and golden eagles have carried off more caribou calves than bears and wolves in some study years). There is no data to support that predator control programs, and the mass killings of wolves and bears, will recover the Mulchatna herd.

Instead, studies, including one on moose harvests in GMU 13 and another on wolf predation on the Nushagak Peninsula caribou herd, have shown that reducing predators doesn’t lead to an increase in ungulates. Further, wolves and bears are known to prey on weaker animals, which may have helped keep brucellosis levels down in the Mulchatna herd. By 2017, 250 wolves had been killed in the original Mulchatna Predator Control program; the caribou herd declined rapidly at nearly the same time.

Timeline of the recent predator control program

January 2022:

At the Board of Game Meeting in Wasilla, Proposal 21, submitted by the ADFG, requested that the Board extend the existing wolf control program for Mulchatna onto Togiak National Wildlife Refuge. AWA opposed the proposal because the State can’t enact predator control on federal lands and predators are not the main problem facing the Mulchatna caribou herd. Our comments cited research from both State and Federal agencies supporting our argument.

The Board was presented with a report from the area biologists about their Mulchatna studies. Researchers suggested that the Board reconsider the wolf program, and ADFG biologists said the predator control program wasn’t working. Listen to the biologists’ audio report here.

The Board deliberated on Proposal 21 in a closed-door meeting, where it was rewritten by an amendment, and then carried 7-0. There was no chance to comment on the amended proposal.

  • The amended proposal:

    • Created a second predator control area for the Mulchatna caribou on Federal lands in Game Units 17 and 18. Game Unit 17 was not on the agenda for the meeting, so the amendment created a proposal with impacts out-of-cycle.

    • RC 47 amended the proposal to include Units 17A and 18 in the intensive management plan.

    • Removed 10,000 sq. mi. limitation to allow control to be conducted over a larger area if warranted.

    • Extended the plan until 2028.

    • Allowed predator control of both wolves and bears, despite the Board having no data on how many bears are in the area. The goal set by the program is to kill every bear, regardless of age or sex, within a nearly 3,000 square mile “control area” each year.

Following the meeting, the ADFG wrote a Operational Plan, without any public input.

March 2023:

On the last day of the Board of Game Meeting in Soldotna. ADFG reported to the Board about the development of the predator control program and presented their Operational Plan.

  • The operational plan stated:

    • ADFG would fly over a nearly 3,000 square mile area in the Tikchik Basin, half of which is in Wood-Tikchik State Park, between May 10th and June 5th.

    • They would fly 2 fixed wings and 1 helicopter for 30 days, weather permitting.

    • They would aerially shoot every wolf, black bear, and brown bear they saw, regardless of sex and age classes. They estimated 15 to 25 brown bears would be killed. They estimated that 54 to 112 brown bears use the “control area” annually.

    • All hides and heads would be salvaged and shipped to Anchorage for an auction. Bristol Bay native community would identify communities who wanted brown bear meat.

    • Over $415,000 of State money was allocated for the planned spring predator control program removal.

Listen to the audio of the Operational Plan presentation.

May through June 2023:

ADFG completed their first cull. They had estimated killing 15 to 25 brown bears. In under four weeks, they killed 94 brown bears, as well as 5 black bears and 5 wolves.

Alaska Wildlife Alliance filed a lawsuit against the State for unlawfully adopting a bear control program on the Mulchatna caribou calving grounds without public, biological, or fiscal review.

Public outcry against the program was overwhelming:

Alaska Federation of Natives (AFN) passed a resolution in support of the predator control program at the fall 2023 meeting. Outside of the AFN meeting, communities near the control area are divided - some in support and others opposed.

Spring 2024:

ADFG completed its second year of the Mulchatna predator control program, killing 81 brown bears and 14 wolves. Read the press release here. Read the memorandum released following the 2024 predator control program here.

The 2024 program consisted of two periods, both scheduled to coincide with peak caving dates for optimal predator detection. The first period was held from April 11 to 14, and the search area was broadened to 5,955km² to target historic wolf pack locations and dens. The primary objective was to target wolves in order to reduce adult caribou mortality during the migration to the calving grounds and reduce newborn calf mortality. A Cessna 185 and a PA-18 Supercub were used to locate wolves and wolf-sign, while an R44 helicopter was used to kill them. Eleven wolves were killed, including 6 females and five males from two packs.

The second and principal period was held from May 10 to June 5, and its focus was “lethally removing all bears to increase calf survival when calves are most vulnerable.” The ADFG also collared caribou calves to assess neonate survival. A Cessna 185 and Maule airplane were used to find bears and calves, and an R44 helicopter was used to kill bears and capture calves for collaring. Bear hides and skulls were salvaged and removed. No bear meat was salvaged, with ADFG citing a lack of interest from local communities. Additionally, no wolf hides were salvaged due to poor hide qualities.

  • 81 brown bears were killed, including 47 females and 34 males. No black bears were seen in the calving grounds.

    • Among the killed bears were 2 two-year-olds, 11 one-year-old cubs, and 5 cubs born in 2024.

  • 3 wolves were killed, including 1 female and 2 males.

  • 12 caribou radio-marked caribou calves, out of the original 55, died between May 11 and June 4.

    • 3 calves were abandoned.

    • 3 were predated; 2 by eagles and 1 by a bear.

    • Other causes of death include drowning, failure to thrive, and a puncture wound (possibly caused by antlers).

    • An additional 32 dead, non-radio-marked calves were observed for a total of 44 mortalities. 20 calves (69%) died from starvation or dehydration. 29 calves had an unclear cause of death and were submitted for necropsy. All calves submitted for necropsy had been born alive but had little to no fat.

An average of 6 predators were killed each day that the 2024 predator control program ran. The total cost of the operations was $507, 743.64 of State of Alaska General Fund money, with the primary expense coming from aircraft and fuel costs.


March 2025

On March 3, the Alaska Superior Court heard oral arguments for the Mulchatna bear control lawsuit. On March 14, Judge Guidi ruled in favor of the Alaska Wildlife Alliance, finding that the Mulchatna Bear Control program was “unlawfully adopted and, therefore, void and without legal effect.”

On March 21, on the first day of the Statewide Board of Game Meeting in Anchorage, ADFG petitioned the Board to adopt an emergency regulation to reinstate the Mulchatna predator control so that bear control could take place again in Spring 2025, despite the court ruling. ADFG's request was published online almost simultaneously with its announcement and can be found here.

Immediately following the announcement of ADFG’s emergency regulation, AWA put out an action alert, asking people to come to Anchorage to testify in person against the emergency regulation and to submit written comments (record copies) opposing it. Over ten public testimonies were given and nearly 200 record copies opposing the emergency regulation were submitted.

Despite extensive public opposition, on March 27 the Board passed ADFG’s petition for an emergency regulation to reopen Mulchatna bear control for the 2025 season. After passing the emergency regulation, there was some discussion on holding the required hearing about adopting the regulation to open Mulchatna bear control at a later date to allow time for the public to comment. However, it was noted that the public does not have to be afforded the chance to comment on the passing of an emergency regulation.

The hearing was held immediately after the emergency regulation deliberations, and the Board voted to re-open Mulchatna bear control for 2025.

how you can help us

We are currently exploring all our legal options to counter the State’s efforts to circumvent a court order. The ruling of the court was that bear control was enacted illegally, and that has not be rectified. We believe that the Board of Game’s passage of an emergency regulation to reopen bear control for this spring damages the trust the public has in State fish and game management and erodes the public process that the Board has claimed they put so much stock in.

While we continue to pursue legal action, AWA is reaching out to Native communities, hunters, biologists, and the public to support actions that protect southwest Alaska’s bears and help the Mulchatna herd recover.

Here's how you can help:

If you’d like to become a voice for southwest Alaska’s bears, consider supporting us with a donation. Thanks to the generosity of our donors, all pledges to our Wildlife Defense Fund will be matched up to $40,000.

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