Honoring Indigenous Knowledge and Stewardship of Biodiversity
Across the globe, Indigenous communities have long held deep, reciprocal relationships with the lands, waters, and wildlife that sustain us. This traditional dependence on biological diversity is not only cultural, it is foundational to the survival, identity, and sovereignty of Indigenous Peoples.
At Native Movement, we integrate Traditional Ecological Knowledge (TEK) with creative, strategic action to protect fisheries and wildlife.
Making Beautiful Trouble for Salmon Advocacy
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Expose hidden systems of power and injustice.
Visualize the collapse of salmon runs alongside industrial bycatch, climate data, and enforcement disparities.
Example: A “Salmon Family Tree” installation where missing branches represent lost runs.
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Shift the story from scarcity to sovereignty.
Replace “subsistence vs. commercial” with “Indigenous stewardship vs. extractive mismanagement.”
Use storytelling that positions salmon and other wildlife as sovereign relatives, not commodities.
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Move from low-risk to high-impact actions.
Begin with testimony at the Board of Fisheries.
Escalate to public art actions, peaceful protests, a day of prayer for salmon, or traditional ceremony.
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Disarm opponents and draw attention.
Create satirical “awards” for fisheries mismanagement.
Remix pop culture into viral memes that spread awareness.
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Offer multiple entry points for participation.
Low-bar: Share a salmon story on social media.
Mid-bar: Submit testimony using a template.
High-bar: Join a teach-in, testify in person, or help lead strategy sessions.
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Center those directly affected.
Ensure Yukon and Kuskokwim families, especially youth and elders, are the frontline voices.
Support their leadership with policy research, media training, and logistics.
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Force decision-makers into a lose-lose choice.
Host a mock “People’s Board of Fisheries” where Indigenous leaders pass resolutions.
If ignored, the state looks dismissive. If engaged, Indigenous governance is legitimized.
State Fish and Wildlife Management
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What It Is:
The Alaska Board of Game is a seven-member public board that sets hunting and wildlife regulations across the state. Members are appointed by the Governor and confirmed by the legislature. Each serves a three-year term, and there are no term limits. Importantly, there are no seats designated for Tribes or tribal organizations, despite the board’s decisions directly impacting Indigenous lands, wildlife, and subsistence practices.What the Board Does:
The BOG makes decisions that shape wildlife management statewide. These include:Opening and closing hunting and trapping seasons
Setting bag limits and harvest quotas
Defining legal methods and means for hunting
Establishing game management areas and predator control zones
Making allocative decisions—who gets access to wildlife resources and how much
Setting population objectives and management priorities.
These decisions are regulatory, meaning they become law once adopted. The Alaska Department of Fish and Game (ADF&G) is responsible for implementing and enforcing these regulations.
Meeting Cycle & Scope:
The Board meets 2–3 times per year, typically between October and March, rotating locations across Alaska. It follows a three-year regional cycle to review proposals for different wildlife management areas. Emergency actions can be taken outside this cycle if needed.Why It Matters for Tribes:
The Board of Game makes decisions that directly affect moose, caribou, bears, and other culturally and nutritionally vital species. Yet, Tribes currently have no formal representation. Engaging in this system is essential to protect tribal hunting rights, uphold food sovereignty, and ensure that Indigenous knowledge informs sustainable wildlife management. -
What It Is:
The Alaska Board of Fisheries is a seven-member public board that sets regulations for all state-managed fisheries, including subsistence, commercial, sport, guided sport, and personal use. Members are appointed by the Governor and confirmed by the Legislature. Each serves a three-year term, with no term limits. As of now, there are no seats formally designated for Tribes or tribal organizations, though a pending bill (HB 125) proposes adding subsistence and science seats nominated by tribal and federal entities.The BOF is responsible for:
Opening and closing fishing seasons
Setting harvest quotas, bag limits, and escapement goals
Defining legal gear types and fishing methods
Making allocative decisions—who gets access to fish and how much
Establishing fishery management areas and conservation policies
Setting policy and direction for the Alaska Department of Fish and Game (ADF&G) to implement.
These decisions are regulatory, meaning they become law once adopted. The ADF&G then manages fisheries based on these regulations, including in-season adjustments to protect spawning and ensure sustainability.
Meeting Cycle & Scope:
The Board meets 4–6 times per year, typically between October and March, rotating locations across Alaska. It follows a three-year regional cycle to review proposals for different fishery areas. Emergency actions can be taken outside this cycle if needed.Why It Matters for Tribes:
The Board of Fisheries makes decisions that directly affect salmon, whitefish, and other culturally and nutritionally vital species. Yet, Tribes currently have no formal representation. Engaging in this system is essential to protect tribal fishing rights, uphold food sovereignty, and ensure that Indigenous knowledge informs sustainable management. -
What They Are:
Advisory Committees (ACs) are local, volunteer-based groups that provide grassroots input on fish and wildlife management. There are 84 ACs across six regions of Alaska, each representing the unique knowledge, needs, and priorities of their communities. ACs are established by the Joint Board of Fisheries and Game and supported by the Alaska Department of Fish & Game (ADF&G).What ACs Do:
Develop and review regulatory proposals for the Board of Fisheries and Board of Game
Make formal recommendations on fish and wildlife issues
Provide a local forum for discussion, education, and advocacy
Consult with agencies, organizations, and the public
Share traditional, local, and technical knowledge to inform state decisions.
ACs meet at least twice a year, and meetings are open to the public. Many ACs now offer hybrid or virtual options, making it easier for tribal members and rural residents to participate.
How ACs Influence State Decisions:
ACs are the first line of input into Alaska’s fish and wildlife regulatory system. Their recommendations are forwarded to the Board of Fisheries or Board of Game for consideration. While boards are not required to adopt AC recommendations, they must formally respond if they choose not to follow them.ACs also play a role in emergency closures during established seasons. The ADF&G Commissioner may delegate this authority to ACs, giving them a direct role in protecting local resources.
Why It Matters for Tribes:
ACs are one of the most accessible and impactful ways for Tribes to engage in state fish and wildlife management. They offer a platform to:Advocate for subsistence protections
Elevate Indigenous knowledge and stewardship
Influence decisions before they reach the state boards
Build coalitions with other local users and allies
Tribal members can join ACs, attend meetings, submit proposals, and help shape the future of fish and wildlife management in their region.
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What It Is:
The Alaska Department of Fish and Game is the state agency responsible for managing Alaska’s fish, wildlife, and habitat resources. ADF&G operates under the Alaska Constitution’s sustained yield principle, meaning it must ensure long-term sustainability of fish and wildlife populations while supporting public use and economic benefit.ADF&G is not a regulatory body, it does not make laws or regulations. Instead, it implements the decisions made by the Board of Fisheries and Board of Game, using biological data, monitoring, and enforcement to manage fish and wildlife across the state.
What the Department Does:
Conducts biological research and stock assessments
Manages hunting, fishing, and trapping seasons based on board regulations
Issues licenses, permits, and harvest reports
Protects habitat through permitting and restoration programs
Provides public education, outreach, and safety training
Supports over 80 local Fish & Game Advisory Committees
Upholds Alaska’s sovereignty in managing its natural resources
ADF&G is organized into five divisions:
Commercial Fisheries
Sport Fish
Wildlife Conservation
Subsistence
Administrative Services
It also includes the Boards Support Section, which facilitates the public process for the Board of Fisheries and Board of Game.
Why It Matters for Tribes:
ADF&G plays a central role in how fish and wildlife are managed day-to-day, including subsistence access, predator control, and habitat protection. While the agency does consult with Tribes, there is no formal co-management structure at the state level. Tribal advocates can work with ADF&G staff, biologists, and regional coordinators to share Indigenous knowledge, raise concerns, and build relationships that influence management decisions. -
What It Is:
The proposal process is how Alaska residents, including Tribes, tribal organizations, advisory committees, and individuals, can formally suggest changes to state regulations governing hunting, trapping, and fishing. These proposals can address subsistence access, conservation concerns, predator control, gear types, seasons, quotas, and more.This is one of the most direct ways to influence wildlife and fisheries policy and assert tribal stewardship.
Step-by-Step Overview:
1. Call for Proposals
Each board operates on a three-year regional cycle, reviewing regulations by geographic area. A Call for Proposals is issued before each cycle, outlining:
What topics are open for change
Which regions or species are under review
The submission deadline
2. Write Your Proposal
Use the official proposal form for the relevant board. You’ll need to:
Clearly describe the issue and your proposed change
Explain why the change is needed (biological, cultural, or practical reasons)
Include your name, organization (if applicable), contact info, and specify the region or Game Management Unit (GMU) or fishery affected
Tip: Work with your local Fish & Game Advisory Committee to strengthen your proposal. These committees often submit proposals and their support can influence the Board’s decisions.
3. Submit Your Proposal
You can submit proposals:
Online via the Boards Support website
By mail to ADF&G Boards Support Section, P.O. Box 115526, Juneau, AK 99811-5526
By fax to (907) 465-6094
Attachments like maps or photos are allowed, but web links and multimedia will not be included in the official proposal book.
4. Proposal Review & Publication
After the deadline:
Proposals are compiled into a Proposal Book and distributed statewide
Advisory Committees, ADF&G staff, and the public review and comment
Written comments are accepted up to two weeks before the meeting where the proposal will be heard
5. Board Meetings & Deliberation
At the board meeting:
ADF&G staff present biological and management info
Advisory Committees share recommendations
The public can testify in person
The Board deliberates and votes to adopt, reject, or amend proposals
Approved proposals become regulations after legal review.
Other Ways to Submit Proposals
Agenda Change Requests (ACRs)
If your issue is urgent and not part of the current cycle, you can submit an ACR. These are reviewed in a special teleconference meeting.
Emergency Petitions
In rare cases, you can submit an emergency petition if a situation meets strict criteria for immediate action. These are rarely approved but can be powerful when justified.
Why It Matters for Tribes:
This process allows Tribes to advocate for subsistence protections, integrate Traditional Ecological Knowledge (TEK), and challenge inequitable regulations. Tribal proposals can shape policy, assert sovereignty, and ensure Indigenous voices are heard in wildlife and fisheries management. -
What It Does:
This article enshrines Alaska’s commitment to public access and sustainable use of natural resources. Key provisions include:§ 2: Resources must be managed for the maximum benefit of the people.
§ 3: Fish and wildlife are reserved for common use.
§ 4: Resources must be managed on a sustained yield basis.
§ 15: No exclusive right of fishery, though limited entry is allowed for conservation and economic reasons.
Why It Matters for Tribes:
While the Constitution supports public access and sustainability, it does not recognize a subsistence priority for rural or Indigenous users under state law, creating tension with ANILCA. -
Key Sections:
AS 16.05.221: Establishes the Boards of Fisheries and Game, each with seven members appointed by the Governor.
AS 16.05.251 (BOF) & AS 16.05.255 (BOG): Grants regulatory authority to adopt rules on seasons, bag limits, gear types, and conservation areas.
AS 16.05.260: Establishes the Advisory Committee system for local input.
AS 16.05.258: Addresses subsistence use areas and joint board actions.
Why It Matters for Tribes:
These statutes define how fish and wildlife are managed at the state level. They do not guarantee tribal representation on the boards, and Alaska’s subsistence law does not align with ANILCA’s rural priority. Tribal advocates must engage through proposals, testimony, and advisory committees to influence these systems.
Advocacy Tools
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[Your Tribal Organization’s Letterhead]
[Date]To:
[Agency Name or Board Name]
[Address or Email]
[Subject Line: Comment on Proposal/Regulation – [Proposal Number or Title]]Dear [Board Chair / Agency Official / Federal Subsistence Board / NOAA Regional Administrator],
My name is [Your Full Name], and I am writing on behalf of [Tribe or Tribal Organization Name], a federally recognized Tribe located in [Region/Community Name]. We appreciate the opportunity to provide comments on [Proposal Title or Regulatory Action], which directly affects our community’s access to and stewardship of fish and wildlife resources.
1. Background & Tribal Interest
[Tribe Name] has a long-standing cultural, nutritional, and spiritual relationship with [species or resource], which is central to our subsistence way of life. Our community relies on [species] for food security, cultural continuity, and intergenerational knowledge transfer.
We have actively participated in [Board/Agency processes, RACs, co-management agreements, etc.] and continue to advocate for Indigenous-led stewardship and equitable access to fish and wildlife.
2. Position on the Proposal
We [support / oppose / recommend changes to] Proposal [Number or Title] for the following reasons:
[Reason 1]: [Explain how the proposal affects subsistence access, conservation, or tribal rights]
[Reason 2]: [Include Traditional Knowledge, local observations, or community impacts]
[Reason 3]: [Reference relevant laws or policies, such as ANILCA, MMPA, EO 13175]
3. Recommendations
We respectfully request the following actions:
[Adopt / Amend / Reject] Proposal [Number]
Incorporate Traditional Ecological Knowledge (TEK) from [Tribe Name]
Consult with our Tribe prior to final decisions
Ensure that any regulatory changes do not disproportionately impact rural or Indigenous communities
4. Closing
We thank you for considering our comments and urge you to uphold the principles of tribal consultation, subsistence protection, and co-stewardship. Please contact us at [Phone Number] or [Email Address] if you have questions or would like to schedule a meeting.
Sincerely,
[Your Name]
[Title]
[Tribe or Tribal Organization Name]
[Contact Information] -
Submit to:
Alaska Department of Fish and Game – Boards Support Section
Email: dfg.bog.comments@alaska.gov
Fax: (907) 465-6094
Mail: P.O. Box 115526, Juneau, AK 99811-55261. Name and Contact Information
Submitted by: [Your Full Name or Tribal Organization Name]
Mailing Address: [Street, City, State, Zip]
Phone: [Phone Number]
Email: [Email Address]
Representing: [Self / Tribe / Advisory Committee / Organization]
2. Proposal Title
Brief Title: [e.g., “Establish a Cultural and Subsistence Moose Hunt in GMU 4”]
3. Regulation Citation
Current Regulation Number (if applicable): [e.g., 5 AAC 85.045(a)(4) – Hunting Seasons and Bag Limits for Moose]
4. What is the Problem?
Describe the issue with the current regulation or management practice.
Example:
“Current regulations do not provide adequate subsistence access for tribal members in GMU 4, where moose populations are stable but harvest opportunities are limited.”5. What is Your Proposed Solution?
Clearly state the change you are proposing.
Example:
“Create a new cultural and subsistence hunt for federally recognized tribal members in GMU 4 from October 1–15, with a bag limit of one antlered bull moose per household.”6. What is the Justification for Your Proposal?
Explain why this change is needed. Include biological, cultural, conservation, or equity-based reasons.
Example:
“This proposal supports food sovereignty, cultural continuity, and equitable access for Alaska Native communities. It aligns with sustained yield principles and does not conflict with conservation goals.”7. What Will Happen if Nothing is Done?
Describe the consequences of inaction.
Example:
“Tribal members will continue to face barriers to subsistence harvest, leading to food insecurity and erosion of cultural practices.”8. Does Your Proposal Address a Specific Area or Species?
Species: [e.g., Moose]
Game Management Unit (GMU): [e.g., GMU 4]
9. Additional Information or Attachments
Include maps, photos, harvest data, TEK, or letters of support if available.
Submission Checklist
Proposal is clearly written and complete
Regulation citation is included
Justification includes cultural and biological context
Proposal is submitted before the deadline (typically May 1)
Supporting materials are attached (if applicable)
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Submit to:
Alaska Department of Fish and Game – Boards Support Section
Email: dfg.bof.comments@alaska.gov
Fax: (907) 465-6094
Mail: P.O. Box 115526, Juneau, AK 99811-55261. Name and Contact Information
Submitted by: [Your Full Name or Tribal Organization Name]
Mailing Address: [Street, City, State, Zip]
Phone: [Phone Number]
Email: [Email Address]
Representing: [Self / Tribe / Advisory Committee / Organization]
2. Proposal Title
Brief Title: [e.g., “Establish a Cultural and Subsistence Salmon Fishery in the Yukon River”]
3. Regulation Citation
Current Regulation Number (if applicable): [e.g., 5 AAC 01.240 – Subsistence Fishing Schedules]
4. What is the Problem?
Describe the issue with the current regulation or management practice.
Example:
“Current fishing schedules do not reflect the cultural timing and needs of tribal communities along the Yukon River, limiting access to salmon during traditional harvest periods.”5. What is Your Proposed Solution?
Clearly state the change you are proposing.
Example:
“Amend the fishing schedule to allow a tribal subsistence opening from June 15–20 in District 4, with gear types limited to set gillnets and fish wheels operated by tribal members.”6. What is the Justification for Your Proposal?
Explain why this change is needed. Include biological, cultural, conservation, or equity-based reasons.
Example:
“This proposal supports food sovereignty, cultural continuity, and equitable access for Alaska Native communities. It aligns with escapement goals and does not conflict with conservation objectives.”7. What Will Happen if Nothing is Done?
Describe the consequences of inaction.
Example:
“Tribal members will continue to face barriers to salmon harvest, leading to food insecurity and loss of cultural practices tied to seasonal fishing.”8. Does Your Proposal Address a Specific Area or Species?
Species: [e.g., Chinook Salmon]
Fishery District or Area: [e.g., Yukon River District 4]
9. Additional Information or Attachments
Include maps, harvest data, TEK, photos, or letters of support if available.
Submission Checklist
Proposal is clearly written and complete
Regulation citation is included
Justification includes cultural and biological context
Proposal is submitted before the deadline (typically April 10)
Supporting materials are attached (if applicable)
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[Tribe or Organization Name]
Meeting Title: [e.g., Co‑Management Readiness Planning Session]
Date: [MM/DD/YYYY]
Time: [Start – End Time]
Location: [Physical or Virtual Meeting Location]
Facilitator/Chair: [Name]
Recorder: [Name]🗓️ Agenda
Opening & Welcome
Invocation or cultural opening (if applicable)
Roll call / attendance
Approval of previous meeting minutes
Review of Agenda
Additions or changes
Updates & Reports
[e.g., Tribal Council updates, agency correspondence, funding status]
Discussion Items
[Topic 1: e.g., Drafting BOG/BOF Proposal]
[Topic 2: e.g., Co‑Management Readiness Goals]
[Topic 3: e.g., Youth & Elder Engagement Strategy]
Action Items
[e.g., Assign drafting team for resolution]
[e.g., Schedule consultation with NOAA or FSB]
Public or Member Comments
Open floor for input
Next Steps & Meeting Date
Confirm action items
Set next meeting date/time
Adjournment
📝 Meeting Minutes
Attendance:
[List names and affiliations of attendees]Summary of Key Discussions:
Topic 1: [Brief summary of discussion and perspectives shared]
Topic 2: [Include any decisions made or consensus reached]
Decisions Made:
[e.g., Approved draft proposal for GMU 4 moose hunt]
[e.g., Agreed to submit comment letter to BOF by April 10]
Action Items:
[Write the task, who its assigned to, and a deadline]
Next Meeting:
[Date, time, location]Adjourned at: [Time]
UPCOMING MEETING
Area M Board of Fish Meeting (Alaska Peninsula/Aleutian Islands/Chignik)
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This briefing equips tribal advocates and allies with analysis and talking points for the Alaska Board of Fisheries meeting on Area M proposals. These proposals aim to reduce interception of Arctic-Yukon-Kuskokwim (AYK) salmon stocks, critical for subsistence and cultural survival. Yukon River communities have faced five consecutive years of closures, while Area M continues unrestricted harvest. Our recommendations prioritize conservation, cultural use, and equitable management under Alaska’s Sustainable Salmon Policy (5 AAC 39.222).
Scientific Evidence Supporting Conservation
Genetic Stock Composition Studies (ADF&G 2023): Area M June fishery intercepted ~28% Coastal Western Alaska (CWAK) chum, including Yukon/Kuskokwim-bound fish.
WASSIP Findings: Confirmed mixed-stock interception in Area M, with AYK chum and Chinook harvested in South Peninsula fisheries.
Travel Time & Closure Justification (Eggers 1989): Chum salmon require ~4.6 days to transit South Peninsula; closures must be ≥10 days.
AYK Salmon Crisis: Yukon River Chinook escapement in 2025 was 23,806 fish, far below the 71,000 rebuilding target; subsistence fishing remained closed.
Alaska Sustainable Salmon Policy (5 AAC 39.222): Requires shared burden of conservation and prioritization of subsistence uses when stocks are depleted.
Advocacy Talking Points
Emphasize five years of Yukon River closures while Area M remains unrestricted.
Highlight WASSIP genetic evidence of AYK stock interception in June fishery.
Stress Alaska law requiring shared conservation burden (5 AAC 39.222).
Push for fixed closures during peak migration (June 12–23) and gear restrictions to reduce bycatch.
Advocate for mandatory genetic sampling and observer coverage in Area M fisheries.
Call to Action
Tribal advocates should:
Support June closures (Props 127,129,131,132,136) and gear restrictions (Props 147,148,152).
Oppose proposals expanding Area M fishing time (Prop 134).
Demand enforcement, genetic monitoring, and equitable conservation measures to protect AYK salmon and subsistence rights.
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Proposal 127 (10-day closure June 10–23) - Support
Increases Yukon/Kuskokwim subsistence opportunity
High conservation benefit that aligns with peak AYK chum migration
Chum “caps” depend on precise reporting; Trooper cases and fleet testimony showed non‑retention/under‑reporting risks after RC 190 introduced triggers. Longer closures are easier to enforce and immune to under‑count games.
2023 BOF action RC 190 (shorter June openers, 300k/450k chum triggers, Sanak closure).
Burden sharing is policy: 5 AAC 39.222 says conserve stocks and protect customary & traditional uses; AS 16.05.258 requires a subsistence preference when harvestable surpluses are limited. June windows are the least complex way to share conservation burden between river closures (already borne by AYK families) and marine fleets.
Passage biology & geometry: The South Peninsula fishing corridor spans ~220 miles. Tagging & analyses indicate ~4.5–5+ days travel from Shumagins to Unimak; windows must be longer than a single transit time to pass a meaningful fraction across the whole area without double‑exposure. Fixed, multi‑day closures mid‑June (12–23) match the well‑documented peak of CWAK chum passage (WASSIP years) and protect depressed king stocks at the same time.
Proposal 128 (Bycatch-triggered closures) - Support w/ amendment
Potential benefit but enforcement risk (reasoning for amendment)
Moderate Conservation benefit depending on accurate reporting
Amendment: Replace triggers with fixed closures
Proposal 129, 131,1 32 (Later start dates & extended closures) - Support
Strong positive for subsistence
High conservation benefit, reduces Area M harvest during peak migration
Suggested Amendment: Align closure windows with WASSIP data
Proposal 130, 133 (Reduce fishing time for seine/drift) - Support
Positive impact on subsistence
High conservation benefit, reduces interception
Suggested Amendment: Add gear depth limits
Proposal 134 (Increase fishing time) - Oppose
Negative impact on subsistence and worsens interception
Suggested amendment if passed: Require genetic monitoring + hard caps
Proposal 135 (Non-retention of king salmon) - Support
Neutral impact for subsistence but positive for conservation as it protects Chinook salmon
Suggested amendment if passed: Add mandatory release reporting
Proposal 147,1 48, 152 (Gear restrictions) - Support
Neutral impact on subsistence
High conservation benefit, reduces killing power of seine fleet.
Suggested amendment: Align with Kodiak/Chignik standards
February 18-24, 2026 @ Egan Convention Center, Anchorage.
The comment deadline is February 3, 2026.
Recent threats to Tribal Sovereignty
Safari Club International (SCI), in coordination with Alaska state leadership, is actively pursuing legal and policy changes that undermine tribal sovereignty and subsistence rights in Alaska.
SCI claims that tribal co-management and Indigenous representation on the Federal Subsistence Board would create a “Native preference,” which is a mischaracterization of tribal sovereignty and self-determination. Tribal governments are political entities, not racial groups, and our inclusion is consistent with federal Indian law.
Advocacy Tools & Info
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Note: Until the docket is posted, you can still submit comments via email:
Email: subsistence@fws.gov
Subject line: “Public Comment on SCI Petition to Revise Subsistence Regulations”
Subject: Opposition to Safari Club International Petition to Revise Federal Subsistence Regulations
To Whom It May Concern,
My name is [Insert Name], and I am a citizen of [Insert Tribal Affiliation]. I am writing to express my strong opposition to the petition submitted by Safari Club International on May 5, 2025, seeking to revise federal subsistence regulations under 36 C.F.R. pt. 100 and pt. 242.
Subsistence is not a sport, it is survival, culture, and sovereignty. The proposed changes would undermine the rural priority established under Title VIII of ANILCA and threaten the food security and cultural practices of Alaska Native communities.
I urge the U.S. Departments of Interior and Agriculture to reject this petition and uphold the federal protections that support Indigenous subsistence rights and tribal co-management.
Sincerely,
[Insert Name]
[Insert Address or Community]
[Insert Date]How to Submit a Public Comment
You can submit your comment in three ways:
1. Online (Preferred Method)
Visit www.regulations.gov
Search for the relevant docket (e.g., “Federal Subsistence Board” or “Subsistence Rulemaking”)
Click on the petition or proposed rule
Use the “Comment” button to submit your feedback
You may attach documents or write directly in the comment box
2. By Email
Send your comment to: subsistence@fws.gov
Subject line: “Public Comment on SCI Petition to Revise Subsistence Regulations”
Include your name, tribal affiliation, and community (optional)
3. By Mail or Hand Delivery
Address:
Federal Subsistence Board Office of Subsistence Management Attn: Theo Matuskowitz 1011 E. Tudor Road, MS-121 Anchorage, AK 99503
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Key Actions:
2025 Petition to Revise Federal Subsistence Regulations
SCI seeks changes to 36 C.F.R. pt. 100 and pt. 242, threatening Title VIII of ANILCA.
Strong opposition from AVCP, KRITFC, and Alaska Native organizations.
State–SCI Collaboration:
Alaska Department of Fish and Game has echoed SCI’s positions in federal rulemaking.
Joint opposition to adding Native seats to the Federal Subsistence Board.
Support for SB 97, restructuring big game guide concessions to favor corporate outfitters over tribal guides.
Legal Challenges:
SCI v. Haaland: Attempt to overturn federal predator control rules in Kenai Refuge.
Amicus Brief in Sturgeon v. Frost: Challenged federal authority over navigable waters, impacting tribal access.
Implications:
Reduced Indigenous representation in subsistence governance.
Threats to rural and tribal hunting and fishing access.
Erosion of federal protections for Native subsistence rights.
Recommendations for Tribal Leaders:
Monitor and respond to federal rulemaking.
Coordinate with tribal organizations for unified advocacy.
Advocate for Indigenous representation on subsistence boards.
Prepare testimony and community briefings.
Sources:
AVCP/KRITFC Response (2025)
SCI Comments on FSB Membership (2024)
Alaska Legislative Records (SB 97)
Ninth Circuit and Supreme Court rulings
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Overview:
This briefing summarizes current legal and policy actions by Safari Club International (SCI) in Alaska that impact tribal sovereignty and subsistence rights.
Active Petitions and Policy Actions:
1. Petition to Revise Federal Subsistence Regulations (May 2025):
SCI seeks changes to 36 C.F.R. pt. 100 and pt. 242.
Tribal groups argue this undermines Title VIII of ANILCA.
Response submitted by AVCP and KRITFC.
(https://www.documentcloud.org/documents/26187690-2025-06-09-avcp-kritfc-response-to-safari-club-subsistence-rulemaking-petition-of-may-5-2025/)
2. Opposition to Native Seats on Federal Subsistence Board (April 2024):
SCI opposed adding three Native seats.
Claimed ANILCA supports rural, not Native, preference.
(Source: safariclub.org)
3. Support for Senate Bill 97 – Big Game Permit Program:
SCI Alaska Chapter supports restructuring guide concessions.
Critics say it marginalizes tribal and subsistence users.
(Source: akleg.gov)
Litigation:
4. SCI v. Haaland (Kenai Rule Challenge):
Challenged federal predator control restrictions.
Ninth Circuit upheld federal authority under ANILCA.
(Source: law.justia.com)
5. Amicus Brief in Sturgeon v. Frost:
SCI supported challenge to federal authority over navigable waters.
Supreme Court ruled in favor of Sturgeon.
(Source: supremecourt.gov)
Recommendations for Tribal Leaders:
Monitor federal rulemaking and submit formal comments.
Engage with Alaska Native organizations to coordinate responses.
Advocate for Indigenous representation on subsistence boards.
Prepare testimony and briefing materials for legislative hearings.
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Legal Arguments in the AVCP & KRITFC Response
1. Violation of Title VIII of ANILCA
SCI’s petition seeks to revise federal subsistence regulations in a way that undermines the rural subsistence priority guaranteed under Title VIII of the Alaska National Interest Lands Conservation Act (ANILCA).
The response argues that SCI’s framing of subsistence as a “privilege” rather than a “right” contradicts federal law and decades of legal precedent.
2. Misrepresentation of Tribal Authority
SCI claims that tribal co-management and Indigenous representation on the Federal Subsistence Board would create a “Native preference,” which the response refutes as a mischaracterization of tribal sovereignty and self-determination.
The response emphasizes that tribal governments are political entities, not racial groups, and their inclusion is consistent with federal Indian law.
3. Improper Rulemaking Petition
The response asserts that SCI’s petition fails to meet the standards of administrative rulemaking under the Administrative Procedure Act (APA), lacking sufficient legal justification, stakeholder consultation, and evidence of harm.
4. Threat to Food Security and Cultural Survival
The proposed changes would disproportionately harm Alaska Native communities by restricting access to traditional hunting and fishing grounds, violating federal trust responsibilities and tribal consultation requirements.
Powerful excerpts:
“This petition is a direct attack on the subsistence rights of our people and the legal protections we fought to secure under ANILCA.”
— AVCP Leadership Statement“SCI’s proposal would erase decades of progress toward tribal co-management and Indigenous representation in federal subsistence governance.”
— KRITFC Board Member“Subsistence is not a sport. It is survival, culture, and sovereignty.”
— Joint AVCP/KRITFC Comment“We reject the false narrative that tribal inclusion creates racial preference. Our governments are sovereign, and our voices must be heard.”
— AVCP Legal Counsel -
TRIBAL RESOLUTION NO. [Insert Number Here]
A RESOLUTION OPPOSING SAFARI CLUB INTERNATIONAL'S PETITION TO REVISE FEDERAL SUBSISTENCE REGULATIONS
WHEREAS, the [Insert Tribal Government Name] is a federally recognized tribe with inherent sovereignty and a responsibility to protect the subsistence rights and cultural survival of its citizens;
WHEREAS, Safari Club International (SCI) has submitted a petition dated May 5, 2025, seeking to revise federal subsistence regulations under 36 C.F.R. pt. 100 and pt. 242;
WHEREAS, the proposed revisions threaten the rural subsistence priority established under Title VIII of the Alaska National Interest Lands Conservation Act (ANILCA);
WHEREAS, the petition misrepresents tribal co-management and Indigenous representation as racial preference, undermining tribal sovereignty and federal trust responsibilities;
NOW THEREFORE BE IT RESOLVED, that the [Insert Tribal Government Name] formally opposes SCI's petition and calls upon the U.S. Departments of Interior and Agriculture to reject the proposed rulemaking;
BE IT FURTHER RESOLVED, that this resolution shall be transmitted to federal agencies, tribal organizations, and advocacy partners to affirm our commitment to protecting subsistence rights and tribal governance.
CERTIFIED this [Insert Date] by the [Insert Tribal Council Name].
[Insert Name], Tribal Council Chair
[Insert Name], Tribal Council Secretary