Submitted Electronically via eRulemaking Portal

Document ID: FWS-R7-ES-2012-0033-0005
Document Type: Public Submission
Agency: Fish And Wildlife Service
Received Date: January 18 2013, at 12:00 AM Eastern Standard Time
Date Posted: January 18 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: January 18 2013, at 12:00 AM Eastern Standard Time
Comment Due Date: March 19 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-836n-bk63
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Your analysis is fundementally flawed. The last reported physical evidence of bison being in Alaska is more than 1300 years old (unless you count a skull found in a person's backyard midden in Anchorage that could have come from anywhere but Anchorage). Huge animals have huge bones. Where are the bison bones? After the 1300 year old bone, there is one 1700 years old and remains don't become "common" until they are 2300 years old or older. Clearly this is an introduction of what should be considered an exotic animal - it is NOT a reintroduction as envisioned by the ESA. This introduction is about hunting opportunity and revenue for the state, not conservation of a threatened species. A requirement to hand management, including harvest, to the state highlights this inconsistency. Sustained yield hunting is not scientifically accpetable manner to manage a threatened species. Giving primacy to the state may impact Federal Subsistence Hunting of this species if it was allowed to be hunted. FWS Refuges, including Yukon Flats, have expressed their desire not to have these animals on their lands because they may impact the ecological integrity of these Refuges. As noted in Canada, bison may compete with native ungulates, such as moose.

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