The federal government has begun a scoping process that could lead to wide-ranging changes to federal subsistence management in Alaska.
Subsistence is a single word for a complex concept that includes the harvesting, use, and sharing of wild plants and animals for a variety of purposes.
Subsistence is at the core of Alaska Native culture — and of Matthew Anderstrom’s existence. He lives in the rural, Southeast community of Yakutat.
“If we don't have those subsistence foods, then we lose the ability to even live here anymore. It's too expensive,” Anderstrom said. “Our ground beef is at $11 a pound, our milk is about $22 a gallon — I know we're not alone in this struggle.”
But in May, Safari Club International — a conservation and advocacy group for big game hunters – sent an 18-page petition to the federal government asking it to “require deference to and consultation with the State and the Alaska Department of Fish and Game” in its subsistence management decisions. The Federal Subsistence Management Program sets policy and bag limits for hunting, fishing and trapping on federal land in Alaska.
The letter, obtained by Anchorage Daily News, was addressed to Interior Secretary Doug Burgum and the Agriculture Secretary Brooke Rollins.
John Sturgeon, the Alaska chapter of the Safari Club’s chairman of government affairs, is a familiar name in Alaska. He was involved in Supreme Court cases that challenged federal jurisdiction on Alaskan rivers, and Gov. Mike Dunleavy recently honored him in his final state of the state address in late January.
According to Sturgeon, one of the group’s biggest priorities is more state influence on hunting and subsistence management.
The petition’s language lines up with what President Donald Trump said in an executive order last year when he called for the federal government to offer hunting and fishing opportunities in Alaska that are “consistent with similar opportunities on State lands.”
The Safari Club has powerful political influence with the Trump Administration. A 2020 auction for a guided hunt with Donald Trump Jr. raised a quarter million dollars for the club. The most recent estimates from the Center for Responsive Politics show the Safari Club spent nearly $1.4 million on campaign contributions and political lobbying. Burgum – one of the secretaries who will ultimately decide whether to change the federal subsistence program – praised the Safari Club for their conservation efforts in his confirmation speech.
The scoping review set off alarms for subsistence advocates like the Alaska Federation of Natives, which opposes potential changes to the subsistence program.
“I think it's a threat,” said AFN president Ben Mallot. “But also an opportunity to have our aspirations put on the record, as well.”
The dual management system
Alaska is the only state that has a dual management system for subsistence. Hunting and fishing are managed by both the state and the federal governments, and there are key differences between the two systems.
For one, on federal lands, residents of rural Alaska communities have priority when there aren’t enough salmon or caribou or deer to go around. That’s a result of the landmark Alaska National Interest Lands Conservation Act, signed by President Jimmy Carter in 1980.
But on state land, there’s no such priority. The state has an “equal access rule,” which means all Alaskans are given equal access to fish and game whether they live in a large city like Anchorage or in a small community like Kivalina.
That’s because of a 1989 Alaska Supreme Court ruling, McDowell v. State of Alaska, which found that a rural priority on state lands violated the Alaska Constitution. The decision threw the state out of compliance with federal law and led the federal government to take over subsistence management on federal lands and navigable waters.
Calvin Casipit, the vice-chair of the Southeast Regional Advisory council, has been involved with the federal subsistence management program since its inception in 1990. He called the subsistence review “ridiculous” and believes it's an attempt to ultimately strip rural and tribal residents of their subsistence rights.
“A subsistence priority for everybody is a subsistence priority for nobody,” Casipit said.
A spokesperson for the U.S. The Department of Interior said the current scoping process is not rulemaking, in an email to KOTZ news. According to the spokesperson, the agency is gathering feedback, and changes may or may not be proposed after comments are reviewed. Consultation opportunities are available for Alaska Tribal governments and Alaska Native corporations.
Alaska Fish and Game Commissioner Doug Vincent-Lang says the state government supports the review. In an emailed statement, Vincent-Lang said his department will focus their comments on how the program can be “restructured to reflect the statehood compact, the plain language of ANILCA and the President’s Executive Order that acknowledges state primacy over fish and game.”
Potential changes
Sturgeon says the Safari Club doesn't oppose a rural preference. He says the review is “a way to right changes” to the program under the Biden administration.
One of those changes was the addition of three tribally nominated seats to the Federal Subsistence Board, a decision that followed years of consultation with tribes. Originally, the board was dominated by directors of federal agencies – including the U.S. Fish and Wildlife Service, National Park Service, Bureau of Land Management, Bureau of Indian Affairs, and U.S. Forest Service.
Thomas Smith is a Sitka-based subsistence advocate. He is Yup’ik and Athabaskan and said he likes the current makeup of the board.
“Without that representation, who are you making the rules for?” Smith said. “And who would live with the rules if we weren't the ones making them?”
The federal board receives recommendations from ten regional advisory councils across Alaska. Right now, these boards are required to be filled with a majority of subsistence users over sport interests. Advisory board requirements are also one of the topics up for review.
The federal scoping review could lead to the new rulemaking for many areas of federal subsistence management, potentially including:
- Interior Department move of the Office of Subsistence Management to the Office of the Assistant Secretary for Policy, Management and Budget;
- Criteria for regional advisory council membership;
- Membership of the Federal Subsistence Board;
- Federal regulations and State regulations for duplication and inconsistency;
- Regulations governing special actions;
- Role of the State and the Alaska Department of Fish and Game in the Federal Subsistence Management Program; and
- Board's process for rural determinations.
The 60-day comment period began in mid-December. Feb. 13 is the deadline for public comment.
Where to Submit comments:
- Email: subsistence@ios.doi.gov
- Online: regulations.gov (Docket Number DOI-2025-0170)
- Mail: Federal Subsistence Board, Office of Subsistence Management, 1011 East Tudor Road, MS-121, Anchorage, AK 99503-6199
