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Subsistence Comment

Posted

Dear Editor: The deadline to submit public comments regarding the Department of Interior’s review of the Federal Subsistence Management Program is fast approaching. The DOI requests input on the membership of the Federal Subsistence Board (FSB) and the Regional Advisory Councils (RACs), how the FSB ought to make rural determinations, when and how often to close areas to non-subsistence uses, as well as the role of the Alaska Department of Fish & Game in the Federal Subsistence Management Program.

In their petition, Safari Club International requests that the Federal Subsistence Board “defer to the State of Alaska on actions necessary for the conservation of fish and wildlife.”

When it comes to making decisions about whether a fish or wildlife resource can support continued subsistence uses, that determination is better left in the hands of the Federal Subsistence Board. The State of Alaska lost its authority to manage fish and wildlife on federal public lands in Mcdowell v State when it was found that a preference to rural residents for hunting and fishing would violate the Alaska Constitution’s equal access provisions. Alaska’s Constitution mandates that fish and wildlife resources be managed under the principle of maximum sustained yield: the highest number of individuals of a species that can be removed from a population, year after year. The subsistence priority is not only a matter of how many of something there are. Despite a record forecast or population estimate, subsistence harvesters can still find themselves having to travel far from town to find deer, or to set hemlock branches in areas free from human disturbance.

The regional advisory councils relay the kinds of concerns from subsistence harvesters that cannot be adequately considered at the state board of fish and board of game tables. The RAC is composed of commercial fisherman, resident anglers, and subsistence harvesters who want to ensure that people in rural communities can continue to fish, hunt and gather the traditional foods and resources that they rely on. They consider the unique, ever-changing dynamics of subsistence. They consider accessibility for subsistence users in small boats, or with no boats, and can make recommendations to the Federal Subsistence Board that truly prioritize the health and quality of a resource.

 More information and a comment tool can be found at: https://sitkawild.quorum.us/campaign/153239/

 Written comments can be emailed to subsistence@ios.doi.gov, or mailed to: Office of the Secretary, Senior Advisor for Alaska Affairs, 4230 University Dr. Suite 300, Anchorage, AK 99508.

Comments must be received by received or postmarked by Friday, February 13, 2026. 

Devon Calvin, Sitka