Proposal to Eliminate Plugging Program

Rationale for the Alaska FNAWS Proposal #74 (Board of Game number) to eliminate the plugging program for some Dall rams in Alaska:

First, the plugging requirement is inconsistent and confusing across Alaska. Plugging of all sheep (or even all rams) harvested is not required. Plugging is only required where there are horn size restrictions, basically for full-curl rams. This means plugging doesn't include all the sheep or even all the rams harvested in Alaska. In the "Anchorage Region" (which we call "Region II" for Wildlife Conservation Division purposes), plugging is required only for rams harvested from the Kenai Mountains (which produce a small harvest), the Talkeetna Mountains (again, a relatively small harvest), and the Tonsina Management Area (a walk-in only area where harvest is small). With the newly passed "any ram" hunt in the Chugach, the only required plugging of rams from the Chugach Mountains might be for rams taken in portions of GMU 14C where (and when) the harvest limit happens to be a full-curl ram, and rams taken from GMU 14A and 13D when and where full curl bag limits are in effect. Seasons, bag limits, and methods and means in GMU 14C are also variable by area and season dates. Hence, when/where plugging is required is quite confusing, and probably does not foster a respect for (let alone an understanding) of the regulation. Also in Region II, it is possible that sheep from the southwest corner of the Wrangell Mountains (in GMU 11 where state regulations prescribe a 3/4 curl ram minimum for Alaska residents and a full-curl minimum for nonresidents, it seems that hunters harvesting either size ram (we'll not even consider federally recognized subsistence hunteres here) are required to have to have their horns plugged. If hunters are required to have rams "down to" 3/4 curl plugged from this area, and if hunters harvesting full-curl rams (either from this area or from other full-curl areas) must have their horns plugged, what does a "plug" show about the legality of a ram from anywhere in Alaska? It seems to "prove" very little about the legality of any given sheep. Alaska FNAWS thinks the program must either be standardized or deleted. It fulfills neither of the purposes for which it was promulgated. It does not limit illegal traffic in Dall sheep horns, it does not curtail the harvest of legal rams, and it provides no information on biological data relevant to management of sheep. Additionally, it is unnecessarily confusing, and confusion tends to erode the potential for effective management.

Second, for a regulation to be "embraced" as a matter of conservation and become colloquially codified as one of the "mores" of sheep hunting which assures enthusiastic, voluntary compliance, it must serve some well-defined conservation purpose. The plugging regulation does not. As you know, the original purpose of the plugging was to prevent illegal traffic in bighorn horns. We know of no illegal traffic in Dall sheep horns, which are common in Alaska. Additionally, if there were illegal traffic, it would be most likely from subsistence areas because, in Alaska Native communities where sheep were historically part of the seasonal subsistence round, histories of trading in sheep meat and horn products have been well-documented. Sheep from these areas are not considered "trophies," hence they may be traded; and they are exempt from plugging. Other Alaska sheep hunters are not heirs to this tradition of trading in sheep parts. They tend to prize and keep sheep meat and horns rather than bartering meat, hides, and artifacts created from horns which have been worked into traditional household implements.

Third, the present plugging program does nothing to assess harvest or gather biological data. Hence it serves no management or research purpose. With respect to harvest assessment, the plugging requirement is internally designed to be incomplete because it excludes sheep from areas with no horn size requirement. All hunters hunting within the "non-subsistence" system are already required to report on their harvests through the harvest ticket program. On this report, hunters must give horn length, base circumfrence, and age (as well how long they hunted, where they hunted, how they got there, and their residence status). Plugging is just a matter of having an ADF&G employee (most often a technician who is neither a biologist or manager) look at the horn, declare it "legal" (the incidence of "catching" sublegal rams in this program was less than 1% of those inspected according to data reported from the program to date), drill a hole in the horns and affix a plug (too-frequently through the sheath into the core--which complicates taxidermy considerably) and sending the hunter out the door. The program isn't much like plugging in other jurisdictions where photos and extensive measurements are taken and kept on file as permanent records.

Fourth, because plugging is only required where there are horn size restrictions. It completely neglects the most biologically significant sheep harvests in Alaska, subsistence sheep harvests. Where there are lengthy (seven months is typical) "any sheep" seasons with liberal bag limits (three sheep is typical for subsistence areas on federal public lands) no harvest reporting is really required. "Paper" reporting requirements exist, but they have been traditionally ignored; and there is no significant harvest assessment effort (unless it is new). Alaska FNAWS would prefer that ADF&G biologists and wildlife enforcement officers put effort into assessing this more biologically significant harvest of ewes etc. than be occupied with a redundant partial certification of the full curl ram harvest.

Fifth, supporters of the plugging program (based on interviews with some ADF&G staffers, leaders from the Alaska Outdoor Council, and Alaska Professional Hunters Association) intuitively feel that "forcing the Department" to actually touch sheep horns and interact with those successful hunters who must present horns for plugging somehow provides an undefined management benefit to sheep. This seems unlikely, as the ADF&G employees who typically do the plugging work are technicians or seasonal employees who have little influence in the management process. The program in one form or another has now been in effect for four years. To date, has produced no benefit for sheep. Alaska FNAWS doubts it ever will, or would support its retention. Defenderts of the program assert it is good because it "gets hunters and managers together (just discussed)," and it "makes a hunter think twice before pulling the trigger." Neither of these post hoc rationalizations really makes any sense. One biologist in Region II, where sheep management is highly variable and based more on "instinct" than in any other area of Alaska, claims a benefit because of a paper which came out of the Yukon Territory seven years ago. In this study, an analysis of 30 years of annular segment length and curcumfrence data gathered through the plugging of about 2,500 sheep over the 30-year period indicated a statistical association of horn growth with an apparent decade-long climate cycle. This finding is interesting, but has yet to affect management at any level. There have also been allegations that the "drillings" could be sources of DNA for genetic studies or forensic use. This sounds good in the abstract, but careful evaluation of where DNA science really is today shows this is nothing but a "pipe dream" now, and will probably remain so for years to come. Even if forensic advantages in prosecution were to accrue from the "drillings," what would they accomplish, and at what cost? After having sp;oken with a recognized expert in the field of molecular forensics, I can see nothing of management significance from the DNA claim. If there were a common need to match horns to meat, DNA from the drillings would do it. At present there is no need for this level of technical forensic work. If there were, it is likely both horns and meat would be available anyway. The drillings are not needed for any practical use.

In summary, the plugging program was originally designed to eliminate illegal traffic in poached bighorn heads. To achieve this goal, each head must be rendered absolutely identifiable. Consequently, each segment length and annular circumfrence was recorded and kept as a permanent record. Also, photographic records of each head were made, permanently recorded, and linked to the hunter via the plug number. There is no way of knowing whether the collective efforts have actually reduced trafficking in poached bighorns. Much data has been amassed, but never analyzed and never applied to a mangement program. In Alaska, well-intentioned hunters proposed a plugging program for many years because "everyone else was doing it." A former Alaska FNAWS Board eventually sold the program to the Board of Game as a means of stopping the alleged harvest of sub-legal rams. The program has had no discernible or even inferential impact on horn size or a significant effect on the number of successful prosecutions for harvesting sub-legal rams. It has certainly had no beneficial effect on sheep hunting or management. Consequently, it is time to either fix or eliminate this diversionary and wasteful program and get serious about Dall sheep management. Alaska FNAWS sees no practical hope for "fixing" the program, and suggest the rational course is to delete it before it distracts us from actual sheep management any longer.

W. Heimer, Pres. Alaska FNAWS