The KSP work group has been attempting to have a written protocol approved by Katmai National Park for commercial users. The following is a letter from KSP President Brian Kraft to Katmai Park superintendent Mark Sturm requesting a site-specific protocol for Moraine & Funnel Creek.
Dear Mark:
I am writing to you on behalf of Katmai Service Providers (KSP) in response to your email on March 4, 2020, regarding KSP’s request for “Proposed Park-Wide Wildlife Distance Conditions Protocol” outside of the Brooks Camp Developed Area (BCDA). KSP’s Board has reviewed and discussed your email and in the spirit of cooperation with the National Park Service (NPS), KSP would like to scale back the request to just include a written protocol for the Moraine Drainage and Funnel Creek Area.
KSP is making this request on behalf of its membership for the following reasons:
The latest NPS interpretation of the 36 CFR § 13.1206 which for CUAs and the public has become a moving target, as it continues to evolve over time ,encompassing larger areas within Katmai, while also becoming more restrictive to the point it is causing significant visitor safety concerns especially on Moraine and Funnel Creeks. On multiple occasions CUA holders have been forced to make a choice between following the NPS’s latest interpretation of a “concentrated food source” or keeping visitors safe. The safety of park visitors is at risk so this needs to be resolved before someone is injured.
Katmai National Park and Preserve’s definition and enforcement of a “concentrated food source” did not really become an issue until the 2016 season, when NPS Katmai appeared to redefine its interpretation or definition of a “concentrated food source” to mean any river, creek or stream with salmon in the water. Our proposed protocol will minimize disturbance to bears and their habitat, reduce unsafe behavior around bears, while also adding clarity and avoid confusion between NPS personnel and park visitors.
This newer interpretation of how individuals or groups should act around a salmon stream considered to be a “concentrated food source” is in conflict with the “Best Bear Viewing Practices” document jointly developed by the NPS and the Alaska Department of Fish and Game. For decades bears and humans have coexisted without issue in the McNeil River State Game Sanctuary (MRSGS) using these “Best Practices” protocols in a wilderness setting.It is well known that many of the bears viewed and photographed at MRSGS, also utilize Moraine and Funnel Creeks in the Katmai Preserve, so they are already human habituated and have learned to expect certain consistent human behaviors.
The Geographic Harbor protocol has allowed visitors and CUAs to occupy an area within 50 yards of a bear utilizing a “concentrated food source” This protocol has also proven to be safe for bears and bear viewers.
Again, by not following the “Best Bear Viewing Practices” KSP sees this as a significant visitor safety issue and one which can also negatively impact bears along the salmon creeks and rivers by displacing bears who are reacting to unwarranted movements of a group or individual.
For the reasons stated KSP is asking Katmai Superintendent Sturm to approve the written protocol below.
Proposed Moraine Creek and Funnel Creek Wildlife Distance Conditions Protocol.
Within the Katmai National Park Preserve Unit, the areas designated as the Moraine Drainage and Funnel Creek Area on the “Katmai Visitor Use Monitoring Areas Map” occupying an area within 50 yards of a bear utilizing a concentrated food source may occur under the limits of the following protocol:
1. People or groups must respect bears “personal space” and should never approach to less than 50 yards, crowd or displace bears.
a) A person or group occupying a position near Moraine or Funnel Creeks, that is approached within 50 yards by a bear will (1) respond as needed with safety as the primary concern and (2) take reasonable action to avoid displacing or restricting the bear’s feeding behavior. This specific protocol would NOT apply when the concentrated food source being utilized by the bear/s is a mammal or mammal carcass.
b) A person or group will not intentionally block a bear’s path of travel to a localized source of food.
2. Activities of a person or group will be conducted consistently with the “Best Bear Viewing Practices” document jointly developed by the National Park Service and the Alaska Department of Fish and Game.
For Reference:
36 CFR § 13.1206 - Wildlife distance conditions.(a) Approaching a bear or any large mammal within 50 yards is prohibited.(b) Continuing to occupy a position within 50 yards of a bear that is using a concentrated food source, including, but not limited to, animal carcasses, spawning salmon, and other feeding areas is prohibited.(c) Continuing to engage in fishing within 50 yards of a bear is prohibited.(d) The prohibitions in this section do not apply to persons—(1) Engaged in a legal hunt;(2) On a designated bear viewing structure;(3) In compliance with a written protocol approved by the Superintendent; or(4) Who are otherwise directed by a park employee.[71 FR 69333, Nov. 30, 2006, as amended at 73 FR 3186, Jan. 17, 2008]
KSP is making this request on behalf of its membership for the following reasons:
The latest NPS interpretation of the 36 CFR § 13.1206 which for CUAs and the public has become a moving target, as it continues to evolve over time ,encompassing larger areas within Katmai, while also becoming more restrictive to the point it is causing significant visitor safety concerns especially on Moraine and Funnel Creeks. On multiple occasions CUA holders have been forced to make a choice between following the NPS’s latest interpretation of a “concentrated food source” or keeping visitors safe. The safety of park visitors is at risk so this needs to be resolved before someone is injured.
Katmai National Park and Preserve’s definition and enforcement of a “concentrated food source” did not really become an issue until the 2016 season, when NPS Katmai appeared to redefine its interpretation or definition of a “concentrated food source” to mean any river, creek or stream with salmon in the water. Our proposed protocol will minimize disturbance to bears and their habitat, reduce unsafe behavior around bears, while also adding clarity and avoid confusion between NPS personnel and park visitors.
This newer interpretation of how individuals or groups should act around a salmon stream considered to be a “concentrated food source” is in conflict with the “Best Bear Viewing Practices” document jointly developed by the NPS and the Alaska Department of Fish and Game. For decades bears and humans have coexisted without issue in the McNeil River State Game Sanctuary (MRSGS) using these “Best Practices” protocols in a wilderness setting.It is well known that many of the bears viewed and photographed at MRSGS, also utilize Moraine and Funnel Creeks in the Katmai Preserve, so they are already human habituated and have learned to expect certain consistent human behaviors.
The Geographic Harbor protocol has allowed visitors and CUAs to occupy an area within 50 yards of a bear utilizing a “concentrated food source” This protocol has also proven to be safe for bears and bear viewers.
Again, by not following the “Best Bear Viewing Practices” KSP sees this as a significant visitor safety issue and one which can also negatively impact bears along the salmon creeks and rivers by displacing bears who are reacting to unwarranted movements of a group or individual.
For the reasons stated KSP is asking Katmai Superintendent Sturm to approve the written protocol below.
Proposed Moraine Creek and Funnel Creek Wildlife Distance Conditions Protocol.
Within the Katmai National Park Preserve Unit, the areas designated as the Moraine Drainage and Funnel Creek Area on the “Katmai Visitor Use Monitoring Areas Map” occupying an area within 50 yards of a bear utilizing a concentrated food source may occur under the limits of the following protocol:
1. People or groups must respect bears “personal space” and should never approach to less than 50 yards, crowd or displace bears.
a) A person or group occupying a position near Moraine or Funnel Creeks, that is approached within 50 yards by a bear will (1) respond as needed with safety as the primary concern and (2) take reasonable action to avoid displacing or restricting the bear’s feeding behavior. This specific protocol would NOT apply when the concentrated food source being utilized by the bear/s is a mammal or mammal carcass.
b) A person or group will not intentionally block a bear’s path of travel to a localized source of food.
2. Activities of a person or group will be conducted consistently with the “Best Bear Viewing Practices” document jointly developed by the National Park Service and the Alaska Department of Fish and Game.
For Reference:
36 CFR § 13.1206 - Wildlife distance conditions.(a) Approaching a bear or any large mammal within 50 yards is prohibited.(b) Continuing to occupy a position within 50 yards of a bear that is using a concentrated food source, including, but not limited to, animal carcasses, spawning salmon, and other feeding areas is prohibited.(c) Continuing to engage in fishing within 50 yards of a bear is prohibited.(d) The prohibitions in this section do not apply to persons—(1) Engaged in a legal hunt;(2) On a designated bear viewing structure;(3) In compliance with a written protocol approved by the Superintendent; or(4) Who are otherwise directed by a park employee.[71 FR 69333, Nov. 30, 2006, as amended at 73 FR 3186, Jan. 17, 2008]