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We all have an opportunity to have our voices heard by the Alaska Department of Fish and Game’s Board of Game on potential changes to hunting regulations in Alaska. The most important change, we feel, is to increase the proportional allotment of non-resident Emperor Goose permits. If the allocation of permits to non-residents is not raised, most of you will never have the honor of hunting an Emperor Goose in your lifetime.

Starting in 2017, the US Fish & Wildlife Service gave the Alaska Department of Fish and Game a quota of 1,000 Emperor Geese for sport harvest. For the first year, all 1,000 were allocated to Alaska resident hunters; in 2018 and 2019 just 25 of the 1,000 permits were allotted for non-residents. For the past three years, Alaska has undergone a trial Emporer Goose sport hunting season and Alaska residents have shown limited interest in the sport harvest of Emperor Geese. Resident harvest in those years has been 129 (2017), 125 (2018), and 122 (2019).

Meanwhile, the interest by non-residents has grown each year, as evidenced by the number of those applying for the non-resident Emperor Goose permit draw.

If you’re a non-resident of Alaska and ever want to hunt Emperor Geese, now is the time to act.

Please take just a few minutes to fill out a submission to the Board of Game HERE to have your voice heard. Below, I am providing language and a step-by-step guide in case it is helps you to navigate your submission.

The deadline for submissions is this Friday, May 15, 2020. Please submit your public comment today.


Drafted by Jeff Wasley, feel free to reuse all or a portion of these comments for your submission to the Board of Game:

Board of Game Online Proposal Submission Form Step-by-Step Guide

GMU: leave blank
Regulation book page number: leave blank
CHECK: Hunting
CHECK: Resident AND Nonresident
UPDATE: CHECK: Central & Southwest Region (GMUs 9, 10, 11, 13, 14A, 14B, 16 & 17)

1. Code: 5 AAC 85.065

2. What is the issue you would like the board to address and why?


The recovery of the Emperor Goose is a success story in modern wildlife management.  The Alaska population of this goose crashed in the mid-1980’s, prompting a hunting closure that lasted 30 years.  The three-year estimated population average from 2014 to 2016 rose above the population threshold set in 2016 by the US Fish and Wildlife Service (USFWS) to reestablish a hunting season for Emperor Geese in Alaska.  USFWS oversees migratory bird management and develops frameworks for states to set harvest regulations to establish hunting seasons, rules, and limits.  Given the potentially fragile nature of the population’s recovery, USFWS rightfully set a conservative 1,000 bird quota for a sport hunting season starting in fall 2017, on a trial basis, to be reevaluated after three years.

The State of Alaska Department of Fish and Game (ADF&G) and the Alaska Board of Game established a resident sport hunting season for fall/winter 2017 with seven zones, each zone having its own quota.  The total of these zones equaled the 1,000 bird quota under regular USFWS harvest quotas based off of the population index.  The total quota would be reduced to 500 if the previous year’s population index fell within the moderate harvest prescription.  A game management unit (GMU) will close after shooting hours on the last day of the season, or by Emergency Order when the GMU quota is met.  The Emperor Goose hunt was set up as a registration hunt and the limit has been one bird per person per season for the entire state.  Also established in 2017 was an application for non-residents to apply for a drawing to hunt Emperors during the fall/winter 2018 season. In 2017, all of the 1,000 bird quota was allotted to Alaska residents; for fall/winter 2018 and 2019 seasons, the number allotted to non-residents was 25 of the total 1,000 quota.

Statewide, harvest for fall and winter sport-hunted Emperor Geese was 129 for 2017 (Alaska residents only), 150 for 2018, and 147 for 2019.  For 2018 and 2019, those numbers are a sum of the resident and non-resident sport harvested Emperor Geese.  Sport hunters have only harvested 12.9% to 15% of the allocated quota over the three years of sport hunting.  Harvest has declined steadily over these first three years as interest from Alaska residents appears to be on the decline. Alaska resident harvest was: 129 (2017), 125 (2018), 122 (2019).

There is no evidence to support any expectation resident sport harvest of Emperor Geese will increase. Alaska has only 6,500 licensed waterfowl hunters in the entire state.  Current estimates put the number of active waterfowl hunters in the lower 48 states at about 1.2 million.

The number of annual Emperor permits available to Alaskan resident waterfowl hunters (975) vs non-residents (25) is drastically different from actual demand and interest in hunting Emperor Geese.  Roughly 400 non-residents applied in November 2019 for the 25 non-resident permits for the 2020 fall/winter Emperor hunt.  We believe the number of interested non-resident hunters is much higher, but many do not apply due to the poor odds of being drawn.  Because Emperor Goose hunting was closed for 30 years, most active non-resident hunters have never had the opportunity to hunt them.  If the current regulations stay in effect, most non-resident hunters will never get an opportunity to hunt this migratory species.

We understand that the ADF&G were rightfully cautious when restarting the Emperor Goose hunt for a three-year trial.  We have learned that most Alaskan hunters are simply not that interested in hunting Emperors and that the demand for this species is largely from non-resident hunters.  These non-residents would be extremely grateful to harvest just one Emperor Goose in their life and would spend a large sum to accomplish this.  Emperors’ habitat borders rural communities that could put vital tourism dollars to good use to support their local economies.  Larger municipalities’ airports, hotels, restaurants, taxis, retail stores, and more would also see increased business from September through January as non-residents would spend time in Anchorage and elsewhere before and after their hunts in rural communities.



The State of Alaska closed Emperor Goose hunting in 1986 in response to a drastic drop in population.  Emperor Goose population surveys from 1964-1986 were intermittent, with some years skipped completely.  The Emperor Goose remained off limits to US hunters for roughly 30 years as the population slowly increased.  Surveys for Emperor Geese have been conducted by USFWS in different areas of Alaska to estimate the overall Emperor Goose population.  These different surveys have included fall and spring surveys along portions of the Aleutian Islands, Alaska Peninsula, and Bristol Bay region.  Other surveys have been focused on the main nesting areas of the Emperors on the Yukon-Kuskokwim Delta (Y-K Delta) area of Southwest Alaska.  Current management has focused on using a total bird index from the Y-K Delta Coastal Zone Survey to assess population status relative to setting regulations for Emperor Goose Harvest.  The harvest strategy defines a regulatory harvest closure threshold of 23,000 birds. This represents approximately 120,000 emperor geese based on a theta-logistic population model currently in development (USFWS, R7-Migratory Bird Management). A recent three-year average population index (2014–2016) is 30,965 birds; equivalent to approximately 161,000 emperor geese.

With the overall population estimate at 161,000 for the three-year average of 2014-2016 USFWS and ADF&G started management action for the creation of a hunting season for Emperor Geese.

The most similar population of geese in Alaska to Emperors for the sake of management is the Pacific Black Brant.  2019 fall counts conducted on the Izembek Lagoon near Cold Bay, AK produced an estimate of 157,000 Brant.  Both species nest in Alaska and rely on marine environments exclusively for their annual life cycle.  All other species of geese that nest in Alaska utilize agricultural waste grain in their wintering grounds and most utilize waste grain at some point on staging areas for their spring and fall migrations. Pacific Black Brant, for these reasons and more, are the most similar goose population for comparison to the Emperor Goose population for management purposes.

In 2019, the season dates for Brant in Alaska were September 1 through December 16 in the Southcentral GMUs where most Brant hunting occurs.  The daily limit is three Brant and possession limit is nine for both residents and non-residents.  There are no seasonal limits for any geese species in Alaska (or anywhere else in North America) except Emperors.  In comparison, the season dates are the same for Emperor Geese, but the Emperor Goose limit is one per season for both residents and non-residents.  However, non-residents must apply for a permit the previous year and face long odds in drawing one of the 25 available permits for the entire state.  Current regulations for an arguably similar species with similar populations (Pacific Black Brant) are drastically different.

For example, a non-resident can travel to Alaska to hunt Brant for a week and legally shoot a possession limit of nine Brant and there are no restrictions on the number of individual non-residents allowed to hunt Brant.  By comparison, only 25 individual non-resident hunters are permitted to harvest an Emperor for the entire season for the entire state of Alaska. These 25 hunters can only shoot one Emperor Goose each per season for the entire state.  Again, USFWS has estimated the Emperor Goose population to be about 150,000 geese and authorized a fall/winter sport harvest of 1,000 geese.  This very conservative number of 1,000 is less than 1% of the overall USFWS-estimated Emperor Goose population.

Both residents and non-residents were unable to hunt Emperors for 30+ years and the state of Alaska rightfully gave much more of the 1,000 available permits to residents.  It was impossible for anyone to know exactly how much interest Alaska residents would have in this hunt.  After the three-year initial trial, we now know that Alaska residents have shown far less interest in the hunting of Emperor Geese.  Fall/winter resident sport harvest of Emperors dropped each year from an initial harvest of 129 in 2017 and had fallen to 122 by 2019.  In comparison, the number of non-residents applying for Emperor Goose permits has gone up each year.  It is important to remember that non-resident interest in hunting Emperor Geese is much higher than application numbers suggest, as many non-residents do not apply given their very low probability of being drawn.

In addition, prior to the Emperor Goose closure in 1986, daily bag limits were six per day with no restrictions for non-residents.  The daily bag limit did drop to two per day for the two years prior to the closure. There is no history of permits, nor discrimination upon non-residents.  In addition, there are no other waterfowl restrictions with discrimination to non-residents in any other U.S. state.  When there are permits, for example tundra swan hunts, none of the nine participating states discriminate for non-residents.  All tundra swan hunt states have a permit system.  Most have a drawing as there are more applicants than available permits.  But some states, like Nevada, sell them over the counter as it has been difficult to hand out their full allotment of available permits.  This case in Nevada seems the most like the Emperor situation in Alaska in that in the past three years, no more than 15% of the quota has been killed.  This suggests that permit allocation could be increase by 570% to attain the USFWS authorized kill.  We find this discrepancy to be exceptionally large; it should be addressed now after this three-year period has ended.  Basically, given the past three-year history of resident and non-resident permit applications, all applications (including non-residents) could be awarded.

As the outlook for Alaska’s economy remains uncertain due to a variety of reasons, we as a state must look for ways to support our local economies with responsible uses of the resources available to us.  Tourism is an increasingly important part of the overall Alaskan economy for both rural and urban areas – this is made obvious in a 2014 study by the ADF&G Division of Wildlife Conservation. Two years of research led to the publication of The Economic Importance of Alaskas Wildlife in 2011, which indicates that spending on hunting and wildlife viewing totaled $3.4 billion in 2011 and generated $4.1 billion in economic activity in Alaska.  The importance of wildlife to Alaska’s economy has grown steadily in the last six years since the results were published.  If Alaska increased non-resident permits to a total of 500, it could easily see another 1,000 visitors, since most hunters want to experience this opportunity of a lifetime with friends and family.  If the average visiting hunter spends $5,000 per person on their trip, this reallocation of total Emperor permits could conservatively result in an additional $5 million supporting Alaska’s economy every fall.  Some would certainly spend much more, but others could go on budget-friendly DIY trips.  This money would help struggling airlines, restaurants, retail stores, hotels, small businesses, guides, and small rural communities where hunters would have to travel to hunt these geese.



We believe that it is time to change the regulations to allow far more non-residents to participate in the Emperor Goose hunt.  We applaud the ADF&G for initially being cautious with this precious resource.  We also understand that Alaska residents should be given priority if there is a conflict over hunting opportunities.  Furthermore, we understand that the three-year trial is up, and we need to reevaluate how we allocate Emperor Goose permits.  Clearly, Alaska residents have not shown the anticipated interest in hunting Emperor Geese and there is a huge demand for Emperor Goose permits by non-residents.  Science indicates that an additional harvest of 500 more Emperor Geese should have no effect on a population of 150,000.  The money generated by allowing more non-resident Emperor Goose hunters will be substantial revenue for many Alaskan small businesses and rural communities.  With the recent drop in oil prices and complications from the COVID-19 pandemic, Alaska must act now to provide more sustainable options for economic growth.


3. What solution do you recommend? In other words, if the board adopted your solution, what would the new regulation say? (Please provide draft regulatory language, if possible.)

We propose that 50% of all allotted Emperor Goose permits go to non-resident hunters.   This would be 500 non-resident permits when Emperor Goose counts are high enough for regular seasons.  If counts dipped to restrictive seasons, then the non-resident quota would drop to 250 permits.  This should result in no Alaska residents being left out, since Alaska residents have shown decreased interest in this hunt and their total harvest in 2019 was 122 Emperors statewide.

We propose continuing the current drawing process for non-residents as it generates income for ADF&G. The current process allows for a non-resident with an Alaska hunting license to apply up to six times ($5 per try up to $30) to be drawn for a non-resident Emperor permit. We believe that by having individuals spend $60 on a non-resident small game license and an additional $30 on the drawing it will keep individuals out of the drawing that really have no interest or financial capacity to travel to Alaska.


Proposed breakdown of available permits:

Regular season:

AK Residents: 500 permits //  non-residents: 500 permits

Restrictive season:

AK Residents: 250 permits //  non-residents: 250 permits

NOTE:   Alaska resident sport harvest was less than 129 birds each year from 2017-2019 with lower harvest reported each consecutive year.

Flock of Emperor Geese - can you spot the Stellar's Eiders?

Photo by Jeff Wasley