EASTERN INTERIOR SUBSISTENCE REGIONAL ADVISORY COUNCIL Meeting Materials

October 15-16, 2019 Fairbanks

What’s Inside

Page

1 Agenda 4 Roster 5 Draft Winter 2019 Council Meeting Minutes 26 Federal Wildlife Closure Review WCR20-42 47 “Domino Effect” Presentation 56 Federal Subsistence Board 805(c) Report to the Council 61 Presentation Procedure for Federal Wildlife Proposals 62 Wildlife Proposal WP20-48 DRAFT Staff Analysis 98 Wildlife Proposal WP20-49 DRAFT Staff Analysis 124 Wildlife Proposal WP20-50 DRAFT Staff Analysis 146 Wildlife Proposal WP20-51 DRAFT Staff Analysis 156 Wildlife Proposal WP20-19 DRAFT Staff Analysis 174 Wildlife Proposal WP20-08 DRAFT Staff Analysis 187 Fisheries Resource Monitoring Program Overview 196 Fisheries Resource Monitoring Program Yukon Region Overview 219 Annual Report Briefing 221 Federal Subsistence Board FY2018 Annual Report Reply 233 Alaska Board of Game 2019/2020 Cycle Tentative Meeting Dates 234 Drainage Fisheries Association Ongoing Projects Report: 2018-2019

On the cover...

Caribou tagged for monitoring in Wrangell- St. Elias National Park and Preserve NPS photo What’s Inside

239 List of Documents Required for Alaska Real ID 241 Winter 2020 Council Meeting Calendar 242 Fall 2020 Council Meeting Calendar 243 Federal Subsistence Board Subsistence Regional Advisory Council Correspondence Policy 245 Region 9 – Eastern Interior Alaska Region Map 246 Council Charter Agenda

EASTERN INTERIOR ALASKA SUBSISTENCE REGIONAL ADVISORY COUNCIL

Pike’s Waterfront Lodge Fairbanks

October 15-16, 2019 convening at 9:00 a.m. daily

TELECONFERENCE: call the toll free number: 1-877-638-8165, then when prompted enter the passcode: 9060609.

PUBLIC COMMENTS: Public comments are welcome for each agenda item and for regional concerns not included on the agenda. The Council appreciates hearing your concerns and knowledge. Please fill out a comment form to be recognized by the Council chair. Time limits may be set to provide opportunity for all to testify and keep the meeting on schedule.

PLEASE NOTE: These are estimated times and the agenda is subject to change. Contact staff for the current schedule. Evening sessions are at the call of the chair.

AGENDA

*Asterisk identifies action item.

1. Invocation 2. Call to Order (Chair) 3. Roll Call and Establish Quorum (Secretary)...... 4 4. Welcome and Introductions (Chair) 5. Review and Adopt Agenda* (Chair) ...... 1 6. Review and Approve Previous Meeting Minutes* (Chair)...... 5 7. Reports Council Member Reports Chair’s Report 8. Service Awards 9. Public and Tribal Comment on Non-Agenda Items (available each morning) 10. Old Business (Chair) a. Wildlife ClosureDRAFT Review WCR20-42 – information update (OSM Wildlife) ...... 26 b. Status update on the hunter ethics education initiative (Katya Wessels) c. “Domino Effect” clarification of information requestLisa ( Maas) ...... 47 d. 805(c) Report – information update (Council Coordinator) ...... 56

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 1 Agenda

11. New Business (Chair) a. Wildlife Proposals* (OSM Wildlife/Anthropology) ...... 61 Regional Proposals WP20-48: Revise seasons and harvest limits for caribou in Units 20F, 20E, and 25C ...... 62 WP20-49: Rescind closure to non-Federally qualified users for sheep in Units 25A AVSMA ...... 98 WP20-50: Revise hunt areas, seasons, and harvest limits for moose in Unit 12 ...... 124 WP20-51: Revise Customary and Traditional Use Determination for sheep in Unit 12 ...... 146 Crossover Proposals WP20-19: Revise the elder/minor hunt for sheep in Unit 11 ...... 156 Statewide Proposals WP20-08: Require traps or snares to be marked with name or State identification number for all furbearers in Unit 2 ...... 174 b. 2020 Fisheries Resource Monitoring Program (OSM Fisheries/Anthropology) ...... 187 c. Identify Issues for FY2019 Annual Report* (Council Coordinator) ...... 219 d. Alaska Board of Game Proposals ...... 233 12. Agency Reports (Time limit of 15 minutes unless approved in advance)

Tribal Governments Native Organizations USFWS a. Arctic (Vince Mathews) b. Yukon Flats National Wildlife Refuge Update (Vince Mathews) c. 2019 Yukon River Salmon Season Summary (USFWS/ADF&G) NPS a. Yukon-CharleyDRAFT Rivers Update (Marcy Okada) b. Wrangell-St. Elias National Park and Preserve – Staff Report Barbara( Cellarius) BLM Yukon River Drainage Fisheries Association (Catherine Moncrieff) ...... 234

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ADF&G a. Hatchery production since 1990. b. Number of fry released and returns for Chinook, Chum, and Pink Salmon OSM a. Report b. Real ID Act of 2005 information sharing (Council Coordinator) ...... 239 13. Future Meeting Dates* Confirm Winter 2020 meeting date and location...... 241 Select Fall 2020 meeting date and location ...... 242 14. Closing Comments 15. Adjourn (Chair)

To teleconference into the meeting, call the toll free number: 1-877-638-8165, then when prompted enter the passcode: 9060609.

Reasonable Accommodations The Federal Subsistence Board is committed to providing access to this meeting for all participants. Please direct all requests for sign language interpreting services, closed captioning, or other accommodation needs to Zach Stevenson, 907-786-3674, [email protected], or 800-877-8339 (TTY), by close of business on September 30, 2019.

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 3 Roster

REGION 9 Eastern Interior Alaska Subsistence Regional Advisory Council

Seat Year Appointed Member Name and Community Term Expires

1 2001 Susan L. Entsminger Chair 2019 Mentasta

2 2007 Andrew P. Firmin Vice-Chair 2019 Fort Yukon

3 2017 Michael J. Koehler 2019 Dry Creek

4 VACANT 2019

5 2005 William L. Glanz 2020 Central

6 2002 Andrew W. Bassich 2020 Eagle

7 2017 Robert C. Wright, Sr. Secretary 2020 Tanana

8 2017 Charlie Jagow 2021 Porcupine River

9 2004 Donald A. Woodruff 2021 Eagle

10 2018 Timothy McManus 2021 Nenana

4 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Draft Winter 2019 Council Meeting Minutes

EASTERN INTERIOR ALASKA SUBSISTENCE REGIONAL ADVISORY COUNCIL Meeting Minutes

March 5-6, 2019 Binkly Room, Pike's Waterfront Lodge Fairbanks

Invocation: Donald Woodruff provided an invocation.

Call to Order, Roll Call and Quorum Establishment: The meeting was called to order Tuesday, March 5 at 9:00 a.m. Andrew Firmin, Council’s Secretary, conducted a roll call. Council members Sue Entsminger, Michael Koehler, Andy Bassich, Robert Wright, Bill Glanz, Charlie Jagow, Timothy McManus, and Andrew Firmin were present in person. With nine seated Council members present (Council has one vacant seat) during the first day of the meeting the quorum was established. Introductions were made for Council members, staff, and guests.

Attendees: The following persons attended some portion of the meeting either in person or by teleconference, in addition to the Council members.

In person:

Katerina Wessels Anchorage Office of Subsistence Management (OSM) Jennifer Hardin Anchorage OSM Lisa Maas Anchorage OSM Pippa Kenner Anchorage OSM Vince Mathews Fairbanks US Fish and Wildlife Service (USFWS), Yukon Flats National Wildlife Refuge (NWR) Jan Conitz Fairbanks USFWS Nathan Hawkaluk Fairbanks USFWS, Yukon Flats NWR Gerald Maschmann Fairbanks USFWS Fred Bue Fairbanks USFWS Steven Strader USFWS Marcy Okada Fairbanks (NPS), Yukon- Charlie Rivers National Preserve (NP) Judy Putera NPS, Wrangell-St. Elias National Park and Preserve (NPP) Pat Petrivelli Anchorage Bureau of Indian Affairs (BIA), Interagency Staff Committee (ISC) member Jim Herriges Fairbanks BLM, Eastern Interior Field Office Darren Bruning Fairbanks Regional Supervisor, Interior, Alaska Department of Fish and Game (ADF&G)

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Jason Caikoski ADF&G, Division of Wildlife Conservation for Northeast Alaska Brandy Baker Delta Junction ADF&G, Sport Fish Division Lisa Stuby Fairbanks ADF&G, Sport Fish Division Wayne Jenkins Yukon River Drainage Fisheries Association (YRDFA) Debra Lynne Tanana Chiefs Conference (TCC) Jim Simon Fairbanks TCC, Hunting and Fishing Task Force and Ahtna Intertribal Resource Commission (AITRC) Brooke Woods Fairbanks University of Alaska Fairbanks (UAF) student, TCC Brian McKenna TCC Pam Miller public Paul Williams public

Via teleconference: Barbara Cellarius Copper Center NPS, Wrangell-St. Elias NPP Clarence Summers Anchorage NPS Jobe Chakuchin Anchorage NPS David Sarafin NPS Jeff Estensen ADF&G Deena Jallen ADF&G Brooke McDavid Fairbanks ADF&G, Division of Subsistence Mark Burch Palmer ADF&G Daniel Sharp Anchorage BLM Frank Harris Anchorage OSM Orville Lind Anchorage OSM Robbin La Vine Anchorage OSM Carol Damberg Anchorage USFWS Gloria Stickwan AITRC, Southcentral Alaska Subsistence Regional Advisory Council

Review and Adopt Agenda

Motion #1 by Mr. Bassich, seconded by Mr. Glanz, to adopt the agenda as read with the following changes:

 Under the Old Business (10) add topic Representation at the Federal Subsistence Board meetings;  Under the Old Business (10) add topic Update on the Delegation of Authority Letter for the Management of Caribou on Federal Public Lands in Unit 20E and 25C to be presented by OSM;  Under the Agency Reports (12) add presentations from: o Documentation of Salmon Spawning and Rearing in the Upper Tanana River Drainage to be presented by Brandy Baker, ADF&G.

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The motion #1 carried unanimously.

Election of Officers: The Council unanimously elected Susan Entsminger as Council’s Chair (motion #2), Andrew Firmin as Vice-chair (motion #3), and Robert Wright, Sr., as Secretary (motion #4).

Review and Approve Previous Meeting Minutes

Motion #5 by Mr. Bassich, seconded by Mr. Glanz, to approve the fall 2018 meeting minutes as presented.

The motion #5 carried unanimously.

Council Member and Chair Reports:

Bill Glanz (Central) reported on attending the Fortymile Caribou Herd Harvest Management Coalition meeting in Tok. The group voted to maintain the herd growth rage at 2 to 3 percent. Mr. Glanz remarked that a State government representative was requesting to keep the growth rate at 1 percent, which in Mr. Glanz’s mind is unrealistic.

Donald Woodruff (Eagle) said that the hare cycle is on the upswing, but, probably, will not peak for another couple of years. Quite a few lynx were observed in Eagle. Mr. Woodruff also attended the Fortymile Caribou Herd Harvest Management Coalition meeting representing Eagle and echoed Mr. Glanz’s comments on the State government intent to keep the heard growth flat. In Mr. Woodruff’s opinion, the only way herd would move to new grazing ground in through nutritional stress. The results of the 2017 photo census indicated the herd size at 71,000 caribou and now it is probably at 80,000 caribou. The Canadian members of the coalition needed some convincing to agree to flatten the herd a little bit. Mr. Woodruff also reported on the Eagle Fish and Game Advisory Committee (AC) meeting discussion on moose population in Unit 20E south. Mr. Woodruff also would like to hear the Federal and State managers discussing and cooperating on the rebuilding of the Chinook Salmon stock instead of having so much conversation about harvest. If the stock is not rebuilt, there will be no harvest.

Timothy McManus (Nenana) shared that they did not have the Minto/Nenana AC meeting yet but there is a lot concerns on the State shutting down the antlerless moose hunt since the quota was met. Mr. McManus reported that even the hunt for ceremonial purposes was shut down. People do not want to consume a bull moose during wintertime.

Robert Charlie Wright, Sr. (Tanana) echoed the concerns about the shutdown of antlerless moose hunt and the ceremonial hunt for potlaches in the Interior. Mr. Wright also said that the hare population is up in the Interior, and people are catching many marten, which provides an opportunity for additional small income.

Andrew Firmin (Fort Yukon) said that he is sorry he missed the meeting in Tanana and that it is always good to have the meetings in the villages and to hear directly from the users. The Yukon

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Flats AC plans to request a seat on the Fortymile Caribou Herd Harvest Management Coalition since the Porcupine Caribou Herd had changed its migration routes and does not come close to Fort Yukon anymore. People are forced to travel far to harvest a caribou and sometimes need to stay at the border until October to get one. It also can be dangerous, since one might freeze or get stranded there in winter weather, and caribou might not show up at all. More people from Fort Yukon started hunting the Fortymile Caribou; therefore, it would be good to participate in the Coalition to be more informed and provide local input. Mr. Firmin also noted that in his area the hare population picked a few years ago.

Andy Bassich (Eagle) shared his concern regarding the management of fall Chum Salmon run, which is very important for subsistence users in Tanana, Fort Yukon, and Eagle. With the Chinook Salmon runs down, the fall Chum is being used more and more for human food. It is also traditionally used for feeding dog teams; therefore, the fall Chum is an integral part of the lifestyle there. Last fall ice already started forming and the fishwheels were in operation in middle of October and catching about 10-20 fish per day, which is dangerous and unproductive. It is necessary to have a frank discussion with the mangers about balancing the escapement goals with allowing upper river communities to get the necessary harvest. Mr. Bassich also shared the reports from hunters and pilots that there is very little moose in his area. Mr. Bassich also echoed Mr. Woodruff’s concerns regarding low quality of Chinook runs. It is necessary to bring large fecund older female fish to the spawning grounds and try to rebuild the genetics. It is also necessary to build better communication with people harvesting fish and to get them to understand that bigger returns are only 50 percent of the traditional runs.

Michael Koehler (Dry Creek) reported that snow was very low this year, which made it a terrible year for trapping and transportation, but the ice was good. The weight of moose calves is up, sometime 100 pounds over the average. Mr. Koehler informed the Council that the hunter ethics education meeting with military personnel that took place one day before the Council’s meeting was very productive. Mr. Koehler also attended the Fortymile Caribou Herd Harvest Management Coalition meeting and represented the Council. He had a copy of the draft management plan for any Council member to look at, if they wished. Mr. Koehler also informed the Council that the Coalition made alternative plans of management to stabilize the population if necessary if the herd size begins to decrease due to natural stressors. The draft management plan awaits an approval from the Canadian side.

Charlie Jagow (Porcupine River) talked about a mild snow and ice year in his area, due to which it was a rather good trapping season. The lynx population is peaking along with the rabbits (sic.). The Porcupine Caribou Herd did not winter on the Upper Porcupine River or on the Colleen River, which is the second year in a row that they have done this.

Chair Sue Entsminger (Mentasta Pass), Chair, reported that trappers in her area doing an excellent job in reducing wolf population, which in turn helps to increase ungulate population. Chair Entsminger’s son is one of these trappers. There is a lot of guiding taking place on State’s lands in her area, and Chair Entsminger said that the State needs to figure out a better system to regulate guiding so there is less competition in the same areas. Chair Entsminger is engaged in the hunter education program with Mentasta School, and during the past bear season she accompanied two students on a successful black bear hunt. Each of them got one bear. During

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the school year, Chair Entsminger and her son trained students to skin the bear using the most efficient techniques. The students got to practice on a black and then on a grizzly bear. Chair Entsminger stressed that it is important to get the youth involved, learn, and stop spending so much time on cell phones.

Council Coordinator report

Katya Wessels, Council Coordinator for the Council, welcomed the new member, Mr. McManus, and two incumbents, Mr. Jagow and Mr. Woodruff, to the Council. Then she talked about the following topics: 1. the Council’s membership and a vacant seat 2. changes in the Councils and the Federal Subsistence Board (Board) schedule 3. following proper parliamentary procedures for putting in a motion or amending it.

Old Business

Hunter Ethics Education update

Katya Wessels briefly recapped the history of the hunter ethics education initiative of the Council for the benefit of the new member McManus and informed the Council in detail about a presentation of this initiative at the Fur Rendezvous organized by the Safari Club International. Then, Ms. Wessels reported to the Council on having a meeting with the representatives of Fort Wainwright and Eielson Air Force Base as well as the Council, BLM, and USFWS representatives to work out the details of the pilot hunter ethics education project that involves military personnel. Ms. Wessels also relayed to the Council that she is going to present to the Board an update on the initiate development during the Board’s April meeting.

Mr. Bassich made a request for an official explanation on how potential outside funding sources (non-Federal or State money) can be used for the hunter ethics education initiative and if there are any restrictions. He said that it is important to have a clear understanding of this prior to seeking outside funding. He also recommended that there should be a letter from OSM or all agencies (NPS, BLM, USFWS, and ADF&G) supporting the initiative prior to looking for additional funding. Mr. Koehler made a request to continue to include ADF&G in these discussions. Ms. Wessels and Mr. Mathews informed the Council that ADF&G was invited to come to the military pilot project development meeting but chose not to or were not able send a representative.

Jennifer Hardin, Policy Coordinator with OSM, informed the Council, that OSM is working out communication protocol with the new administration at ADF&G and all requests need to go to Benjamin Mulligan, Deputy Commissioner for ADF&G and Mark Burch, Special Project Coordinator for ADF&G.

Lisa Maas with OSM was not able to present her research on the “Domino” effect because it was not reviewed by OSM’s leadership team.

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Council Representation at the April Board Meeting

The Council discussed who would represent it at the April 2019 Board meeting. Mr. Firmin did not want to represent, since he did not attend the Fall 2018 meeting in Tanana when the fisheries proposals were discussed. Mr. Bassich could not be away from his dog team for an extended period and he would be attending a 10-day Yukon River Panel meeting just prior to the Board meeting. He said that he could stand in as an alternate. Mr. Woodruff talked about his experience representing the Council at a previous Board meeting and recommended that everyone on the Council needs take their turn to participate in the Board meetings. Mr. Bassich suggested that if he is on the road system, he could call in. Mr. Firmin said that he could try to go but would not make any promises. It was decided that Mr. Firmin as the Vice Chair, would coordinate among the Council members, who can possibly represent the Council at the Board meeting, since Mr. McManus and Mr. Wright, Sr., would potentially be in Anchorage at the same time.

New Business

Wildlife Closure Review WCR18-42 (Unit 12 within WRST caribou)

Lisa Maas, wildlife biologist with OSM, presented a summary of the analysis of Wildlife Closure Review WCR18-42 pertaining to the closure of caribou hunting in Unit 12. OSM's preliminary recommendation is to maintain the status quo due to conservation concerns. The Mentasta Caribou Herd population remains low and cannot withstand any harvest. The Chisana Caribou Herd population appears stable and current harvest levels are sustainable, indicating no additional restrictions are warranted. The Wrangell-St. Elias National Park and Preserve (WRST) Superintendent has delegated authority to manage the hunt and can respond to yearly conditions. Additionally, the low harvest quota cannot support the harvest pressure that could result from opening the area to all users.

The Council had a detailed discussion on the status of the Mentasta and Nelchina Caribou Herds and their mixing ratios and patterns. It also received some information from ADF&G on radio collaring (satellite GPS collars) that are used to get a better understanding of moving and mixing of the herds. Additionally, ADF&G talked about morphological differences between the two herds, their different calving ranges and migration patterns.

Motion #6 by Mr. Bassich, seconded by Mr. Wright, Sr., to support OSM preliminary recommendation for maintaining status quo on the closure.

After evaluating all of the received information, the Council determined that it would be prudent to maintain the closure for conservation purposes and assess the situation in the future.

The motion #6 carried unanimously.

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Update on 2019-2021 Federal Subsistence Management Regulations for the Harvest of Fish and Shellfish on Federal Public Lands and Waters in Alaska

Jennifer Hardin, Subsistence Policy Coordinator with OSM, informed the Council that typically the updated Federal Subsistence Management Regulations for the Harvest of Fish and Shellfish on Federal Public Lands and Waters in Alaska become effective in March. This year the situation is different due to a lapse in government funding resulting in rescheduling the Board regulatory meeting to be held in April 2019. As a result, OSM plans to suggest to the Board that they consider implementing companion temporary special actions that would allow the Federal Subsistence Management Program to implement immediately the regulatory changes that the Board has just adopted. Dr. Hardin explained in detail the whole process change and said that this is being done to have new regulations in place by the time the fishing season starts. Temporary special action process requires a public process including consultation with the Councils Chairs, tribes, ANSCA corporations, and the State of Alaska, which is planned to be covered during the Board meeting. The Council and public asked some clarifying questions of the process.

BLM Delegation of Authority Letter (Units 20E and 25C caribou), Special Action Request, and Draft Proposal for Caribou in Units, 20E, 20F, and 25C

Ms. Maas provided explanation of a delegation of authority letter issued to BLM manager for caribou in Unit 20E and 25C to modify or restrict harvest limits and season dates. Jim Herriges, wildlife biologist with the Eastern Interior Field Office of BLM, mentioned that this delegation of authority does not include setting sex restrictions and that there are some variations with State seasons. Mr. Herriges prepared a special action request to expand the existing delegation of authority to include sex. He also drafted a regulation proposal to match Federal and State caribou regulations for the Units 20E, 20F, and 25C, which he distributed to the Council members. In a lengthy discussion, the several members of the Council expressed an opinion that opening the season on the proposed date of August 1 would create confusion for the State’s youth hunt and beginning caribou hunt on October 21 is not advisable since bulls are still in rut at this time and meat is not eatable. The Council felt that it is the best to let the Fortymile Coalition provide recommendations for seasons and bag limits.

Motion #7 by Mr. Woodruff to support the delegation of authority letter to BLM to align Federal and State regulations on the Fortymile hunt. The motion was not seconded and died.

The discussion was postponed until ADF&G presentation on the Fortymile Caribou Herd.

Call for Federal Wildlife Proposals

Proposal to Change Federal Regulations for Moose in Unit 12 Remainder

Motion #8 by Mr. Bassich, seconded by Ms. Entsminger, to put in a proposal to align Federal moose hunting regulations on hunting areas and bag limits in Unit 12 with State regulations.

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The Council recommended changing the Federal regulations for moose in parts of Unit 12 remainder to align Federal and State hunt areas, seasons, and harvest limits to reduce user confusion, as follows:

Existing Federal Regulation

Unit 12 — Moose

Unit 12, remainder—1 antlered bull by joint Federal/State Aug. 20-Sep. 20. registration permit only

Proposed Federal Regulation

Unit 12 — Moose

Unit 12, remainder that portion within the Nabesna River drainage west of the east bank of the Nabesna River Aug. 20-Sep. 20. upstream from the southern boundary of Tetlin National Wildlife refuge —1 antlered bull by joint Federal/State registration permit only

Unit 12, that portion within the Tok River drainage upstream of a line from Peak 5885 at 63° 9.243 N. Lat., 143° 24.248 W. long., to MP 105 of the Glenn Highway (Tok Cutoff) at 63° 7.438 N. Lat., 143° 18.135 W. Long., Aug. 24-Aug. 28 then south along the Glenn Highway (Tok Cutoff) to the Sept. 8-Sep. 17 Little Tok River Bridge at mile 98.2; and within the Little Tok River drainage upstream of the Little Tok River Bridge at mile 98.2 – 1 bull with spike-fork or 50-inch antlers or antlers with 4 or more brow tines on at least one side

Unit 12, remainder – one bull Aug. 24-Aug. 28 Sept. 8-Sep. 17

The intention of this proposal is to align Federal and State regulations to reduce user confusion. Currently, the small tracts of BLM lands in the Federal Unit 12 remainder have different seasons and antler restrictions under Federal regulations than under State regulations. However, differentiating land ownership in the field is impractical. This proposal will align Federal and State hunt areas, seasons, and harvest limits for moose in parts of Unit 12 (outlined above) to make it easier for users to understand where and when they can hunt.

The motion #8 carried unanimously.

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Council Charter Review

Katya Wessels, Council Coordinator, presented biennial Council Charter Review process. The Council briefly discussed a possibility of recommending adding additional seats to the Council and adding the language on the geographic member representation balance. A discussion ensued regarding a necessity to solicit applications to serve on the Council from underrepresented northern areas of the Eastern Interior Region. Ms. Wessels appealed to the Council to assist on this matter.

Motion #9 by Mr. Bassich, seconded by Mr. Wright, Sr., to adopt the Council Charter as is.

The motion #9 carried unanimously.

Council’s FY2018 Annual Report

Motion #10 by Mr. Bassich, seconded by Mr. Wright, Sr., to approve Council’s FY2018 Annual Report

The Council reviewed the draft annual report in detail and stressed that capturing the Council’s concerns and providing this information to the Board is one of the main tasks of the Council. Mr. Bassich spoke on the record regarding topic number 4 Concerns over the Alaska Department of Fish and Game Lowering the Biological Escapement Goal and Its Effect on Salmon Stocks. He said that “one of the issues is the sonar doesn't count eggs, the sonar counts fish and they try and guesstimate how many females, but we really don't have a clear understanding of how many eggs were crossing the border in 1985 and how many eggs are crossing the border right now. That is the crux of the management issue. So whenever we get reports on fisheries escapements, we get the number of fish and everybody is patting themselves on the back saying, well, we got greater than what our IMEG was stating, but in fact, if you really do the math, we're probably putting fewer eggs across the border even though we're putting more fish across the border.” The Council also asked to add a language on requesting a letter of support from OSM or the Board for the hunter ethics education initiative. The Council thanked Ms. Wessels for going above and beyond her duties in an effort to capture the Council’s concerns and ideas correctly and drafting a very detailed report.

The motion #10 carried unanimously.

Alaska Board of Game Call for Proposals

Antlerless moose hunt in the Minto Flats Management Area, Unit 20B

Mr. Wright, Sr., shared with the Council the Tanana/Rampart/Manley Fish and Game Advisory Committee (AC) concerns regarding stopping the hunt for antlerless moose for the purposes of memorial and burial potlatches in the Minot Flats Management Area in Unit 20B and in Units 20C, 20F, and 25C. Mr. Wright also distributed a copy of the AC letter addressed to the Alaska Board of Game and to the ADF&G Commissioner. The antlerless moose hunt is shut down every year once the allowed number of animals have been harvested and seasons must be

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reauthorized annually. The Minto/Nenana AC and Tanana/Rampart/Manley AC plan to oppose reauthorization of antlerless moose hunt in Unit 20B (ADF&G proposal 136 to BOG). The Council discussed a potential to develop a BOG proposal opposing reauthorization of antlerless moose hunt, if it prevents taking of the moose for traditional ceremonial purposes. The Council tasked Mr. Wright, Sr., in providing more information and preparing a draft proposal language to discuss during the second day of the meeting.

Proposal to eliminate three sheep limit winter hunt in Unit 25A

Ms. Entsminger temporarily passed the chairmanship to Andrew Firmin to discuss a potential proposal to the BOG. She reminded the Council about the Arctic Village Sheep Management Area (AVSMA) Federal proposal WP18-56 discussion during the fall 2018 meeting. She also reminded the Council that the Alaska Administrative code (92.003) contains a requirement for a specialized ethics education course that a potential hunter would be required to take in case the AVSMA is open to other hunters besides just Federally qualified subsistence users. However, the State had never developed this course because there is no season. Ms. Entsminger suggested to the Council to submit a BOG proposal to create a permit draw for sheep for residents and non- residents and change the harvest limit for the winter season from 3 sheep to one ram with full- curl horn or larger every 4 regulatory years in the newly established State hunt area (State AVSMA). She said that the sheep in the spring have no fat and are extremely tough, so it is hard for her to understand why “we’re running around on snowmachines and shooting sheep in the spring and have a three sheep limit.” Ms. Entsminger also shared with the Council that during the last hunter ethics education meeting she had met two young hunters from Arctic Village who expressed interest in getting into guiding. Ms. Entsminger noted that if the BOG adopts this proposal, the State would need to develop the ethics education course.

The Council had a prolonged discussion of the merits of the proposal and a potential to eliminate the Oct. 1 – Apr. 30 hunt. Acting Chair Firmin expressed an opinion that no one would hunt during that hunting period except a few non-residents. The discussion ensued regarding that if it is a draw hunt, then it is a State sport hunt only, and it would be necessary to have the winter or some other subsistence opportunity at the State level in order to have a fall drawing hunt. The Council also discussed what it takes to become a guide, all the different steps that will need to be taken in order for the AVSMA ever to become open and the necessity of working with the Arctic Village people through this process to achieve mutual understanding. Ms. Entsminger felt that this is an opportunity to begin working together with the Arctic Village residents on resolving the situation. Mark Burch with ADF&G recalled the discussions that took place at the last Board wildlife regulatory meeting during the wildlife proposal WP18-56 deliberations.

Motion #11 by Ms. Entsminger, seconded by Mr. Woodruff, to change the harvest limit for the winter season in the Chandalar River hunt area from 3 sheep to one ram with full-curl horn or larger by permit and establish a draw permit hunt for residents and non-residents within the newly established hunt area (State AVSMA).

Mr. Bassich expressed an opinion that stipulating to have a draw permit every four years is a good conservation measure and if the AVSMA will get really open in the future, he didn’t want it to become a problem for the residents. Acting Chair Firmin agreed with Mr. Bassich. Mr.

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Wright, Sr., said that he wants to know what the residents of the Arctic Village think about this proposal because it is going to affect them.

Motion #12 by Mr. Bassich, seconded by Ms. Entsminger, to amend the original proposal to add the proposed harvest limit of one ram with full-curl horn or larger every 4 regulatory years under RS595 season of Oct. 1-Apr. 30.

The motion #12 to amend carried unanimously.

Ms. Entsminger talked about the history of the establishment of the AVSMA in response to local residents’ requests and how the Cane Creek and Sheep Creek were added. She also mentioned that it would be good to add into the justification all of the history related to the AVSMA and various proposals associated with it. Mr. Entsminger said that “The Federal Board has acknowledged there's no conservation concern, but said that the closure was needed to ensure the continuation of traditional subsistence.”

Gloria Stickwan stated that this proposal should be brought up to the local people for their input.

The motion #11 as amended passed 8 to 1.

Chair Entsminger proposed to write a letter to the Arctic Village residents to work together and get a more in-depth understanding of the situation in the AVSMA.

Motion #13 by Mr. Woodruff, seconded by Mr. McManus, to write a letter to the Arctic Village asking them for their input and to work together with the Council and USFWS.

The discussion ensued on how many and how often residents of Arctic Village attend the Council meetings. The Council stressed an importance to work with the Arctic Village residents regarding any proposals that would affect them.

The motion #13 passed unanimously.

Mr. Firmin, Mr. Woodruff, and Mr. Jagow were selected for a working group to further develop the BOG proposal on sheep. Mr. Wright, Sr., also put forward a suggestion that if the three sheep limit is changed to one ram with full-curl horn or larger to add a requirement of horn destruction. Chair Entsminger said that another possibility is to change the three sheep to a ewe hunt.

Agency Reports

ADF&G Report of the Fortymile Caribou Herd

Jeff Gross, ADF&G Management Biologist for the Fortymile Caribou Herd, provided an update. The Fortymile Caribou Herd Harvest Management Plan is being revised. The herd continues to grow. The 2017 photo census shows the minimum count at 73,000 animals and the modeled estimate is over 80,000. Over the last eight to ten years, there were some obvious signs of

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nutritional impact. The recommendation is to stabilize or possibly even reduce the herd. The harvest quota went from 150 bulls in the 1990s to 2,000 animals during the last 2 years, and if the herd needs to be stabilized the quotas might go up to 4,000 or higher. Increasing the quotas, means that a lot of harvest will occur along the road system, which presents a challenge. Mr. Gross and the Council discussed the early season opening and possibility of the meat smelling and tasting bad because the bulls are in the rut.

Motion #14 by Mr. Bassich, seconded by Mr. Glanz, to draft a letter to the Fortymile Caribou Herd Harvest Management Coalition regarding the Council concerns for the October 21 State opening and the quality of meat. (146-149).

The Council has a concern about early hunting of bulls that could potentially still be in rut and the Council’s end goal is to align State and Federal openings as much as possible for this hunt. The Council would like to see the ADF&G doing a survey of the meat harvested in the early season.

The motion #14 carried unanimously.

Motion #15 by Mr. Bassich, seconded by Mr. McManus, to add to the Fortymile Caribou Herd Harvest Management Coalition letter regarding the youth hunt

The Council wanted to make it clear that the youth hunt should remain a State only hunt from August 1 through August 11.

The motion #15 carried unanimously.

Tribal Governments – Tanana Chiefs Conference

Brian McKenna, Fisheries Biologist with Tanana Chiefs Conference, reported on a new project launched in 2018. It involved the use of unmanned aerial systems (UAS or drones) in combination with photogrammetry to count salmon. UAS is a promising new technology, which can be used in combination with photogrammetry for monitoring salmon escapement. Mr. McKenna also mentioned that most weirs now use video technology. The Council had a discussion that it might be a good idea to close off known salmon-spawning streams/tributaries to boat traffic for two weeks during the spawning season. The Council also was interested in any studies on how many fish might have been hit and if they survived. The Council saw a possible need for public education and outreach regarding not disturbing spawning salmon. Such rivers as Chena and Salcha are two of the most critical streams for the Chinook Salmon spawning, and the boat traffic going by the spawning grounds might be devastating for the Chinook Salmon eggs. On the , there is a problem with mining tractors using the shallow waters to get to the mining sites.

Preliminary 2019 Yukon River Pre-Season Outlook

Gerald Maschmann, Assistant Federal In-season Manager for the Yukon River, presented a report on the 2019 Yukon River Salmon Pre-Season Outlook, jointly prepared by the USFWS

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and ADF&G. Mr. Maschmann reported that Chinook Salmon run outlook is similar to the previous year, so the conservation measures will need to be implemented. At the same time, there will be an available surplus of summer and fall Chum Salmon as well as Coho Salmon for normal subsistence and commercial harvests. This situation presents management challenges similar to the previous year. The management strategies include a combination of windows, subsistence schedules, reduced window schedules, period closures and various gear restrictions.

Mr. Bassich noted that people in Eagle had difficulties harvesting sufficient Chum last fall due to low run. He asked the managers regarding this year’s strategy that can allow residents to harvest enough fish. Three Eastern Interior Region villages, Tanana, Fort Yukon, and Eagle, are well- documented users of fall Chum. Jeff Estensen, Fall In-season Manager with ADF&G, replied that the 2018 fall Chum run was unusually late and a lower than normal portion of the run went to Canada. Mr. Estensen said that it might be possible to reduce the amount of commercial fishing that occurs on the pulses that go into Canada to bring more fish to Tanana, Fort Yukon, and Eagle. It needs to be brought up for discussion at the Yukon River Panel meeting.

The Council and Deena Jallen, Summer In-season Assistant Manager with ADF&G, had a discussion about the summer Chinook Salmon management and going from the surgical openings to windows type of management regime. Ms. Jallen said that if there is enough fish, they want to give people at least some opportunity to get their fish and spread that harvest out and find convenient fishing times. Mr. Bassich expressed his concern regarding protecting large fecund females at this type of management regime. Mr. Maschmann added that they worked hard to spread the harvest throughout all the pulses with short openings with 6-inch gear, then 7.5 and some with just dipnets.

Denali National Park and Preserve Report

Pat Owen, Wildlife Biologist with Denali NPP, provided a wildlife update for the NPP. Ms. Owen talked about:  bear monitoring  bear management  moose monitoring  caribou monitoring  wolf monitoring  sheep population surveys

After her presentation, Ms. Owen answered questions from the Council regarding caribou calf surviving rate and the low ratio between ewes and rams as well as what does bare management in the park entails.

Denali Subsistence Resource Commission

Amy Craver, Subsistence Coordinator with Denali NPP, talked about recruiting members for an appointment to the Denali Subsistence Resource Commission (SRC). She and Barbara Cellarius told the Council that the selection criteria for the SRC seat are outlined in the Section 808 of ANILCA and in order to be eligible the person needs to be a member of either a Regional

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Advisory Council or local Advisory Committee and engaged in subsistence uses within the Park or Park Monument.

Motion #16 by Mr. Bassich, seconded by Mr. Glanz, to appoint Robert C. Wright, Sr., to be the Council’s representative on the Denali SRC and Timothy McManus as an alternate.

Mr. Bassich and Chair Entsminger expressed an opinion that overtime no one will be qualified to be appointed to Denali SRC, since there is very little subsistence activity in that park. Mr. Bassich said that the appointees represent not just themselves but a large group in their advisory capacity; therefore, the personal experience matters only to a certain extent. There was a discussion about the boundaries of the resident zone communities in the WRST and a more restrictive situation in the Denali NPP. Clarence Summers, Subsistence Coordinator with the NPS, talked about their work with the ADF&G AC Regional Coordinator. He said that Minchumina in Unit 20C is a resident zone community, so there is a potential to find the SRC candidates that serve on that AC. He also told the Council that residents, who do not reside in one of the resident zone communities, can apply for permit 13440 with the Superintendent.

Motion #16 carried unanimously.

Yukon Flats National Wildlife Refuge Update

Nathan Hawkaluk, acting Refuge Manager, presented the update. He talked about:  moose survey in Unit 25D West  lynx movement study  waterfowl (scoters, scaup, loons, and swans) survey  Fort Yukon community hunter liaison project in partnership with the Council of Athabaskan Tribal Governments  moose management meetings for the residents of the Yukon Flats  snaring clinic in Venetie and Chalkyitsik

Vince Mathews, Refuge Subsistence Specialist for Arctic, Kanuti, and Yukon Flats NWRs, talked about:  NWR open house project  hunter ethics education project  Native Youth Community Adaptation and Leadership Congress

The U.S. Fish and Wildlife Service and the Alaska Department of Fish and Game migratory bird apology letter

Mr. Mathews presented to the Council the U.S. Fish and Wildlife Service and the Alaska Department of Fish and Game migratory bird apology letter intended to reconcile unintended impacts of past harvest regulations of migratory birds and their eggs.

Arctic National Wildlife Refuge Update

Mr. Mathews presented the Arctic NWR update. He talked about:

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 Coastal Plain Oil and Gas Leasing Program  Research and Monitoring staffing changes  management of Porcupine Caribou Herd  moose on North Slope (Unit 26C)  sheep surveys  Public Use Management staffing changes  commercial permits  Arctic Interagency Visitor Center  Arctic Village youth camp

Mr. Hawkaluk told the Council that about 60 hunters were contacted through the hunter liaison program. Mr. Firmin asked for a report from the program.

Public testimony

Paul Williams, member of the public, talked about moose in Unit 25D, wrongness of hunting just large bulls, necessity of black bear management, moose hunting in Yukon Flats, collaboration, and concerns regarding opening of the Arctic NWR for development.

Yukon-Charlie Rivers National Preserve Update

Marcy Okada, Subsistence Coordinator for Yukon-Charley Rivers NP, presented the update. She spoke about:  moose survey  denning ecology of wolves in Yukon-Charley journal article  sheep population

Scott Sample, Chief Ranger, talked about a regulation (36 CFR 13.160) on use of cabins or building temporary structures for subsistence purposes. Under the compendium, an extended stay in public use cabins is 10 days in a 30-day period. Mr. Sample posed an open-ended question to the Council about what they consider a local rural resident for the purposes of subsistence uses in National Preserves, in case if the Council wants to discuss it at the future meetings. He also distributed a map of Communities with recognized customary and traditional (C&T) use privileges around Yukon-Charley Rivers NP. Chair Entsminger shared her experience of dealing with this issue for Wrangell-St. Elias NPP. The Council had a detailed discussion of the issue. A suggestion was made to put all C&Ts applicable to Yukon-Charley NP on the map. Mr. Woodruff suggested adding this topic to the next meeting’s agenda.

Documentation of Salmon Spawning and Rearing in the Upper Tanana River Drainage

Brandy Baker with ADF&G presented an update on Documentation of Salmon Spawning and Rearing in the Upper Tanana River Drainage project. Ms. Baker reported that they specifically worked in the Chisana and Nabesna Rivers drainages and located some probable rearing areas of Chum Salmon. They used DNA environmental sampling to find salmon DNA in the water. Next step is to conduct key respondent interviews in Northway to target other areas of sampling.

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Wrangell-St. Elias National Park and Preserve Report (WRST)

Judy Putera, Wildlife Biologist with WRST, presented the report. She talked about:  Mentasta Caribou Herd June post-calving census and fall sex and age composition count  GPS radio collars and Chisana Caribou Herd population estimate  planned large-scale brown bear survey in the spring  wolf survey in the Chisana area  Dall sheep sampling survey

Barbara Cellarius, Subsistence Coordinator with WRST, presented an update and spoke about:  Federal subsistence permits  baseline ethnographic reports projects  traditional ecological knowledge projects

The Council discussed with the presenters the low hunter success rates and methods for planned bear and wolf surveys.

David Sarafin, Fisheries Biologist with WRST, presented information on fisheries research, inventory, and monitoring projects and on upper Copper River Federal subsistence fisheries. He talked about:  salmon escapement weirs at Tanada Creek and Long Lake  assessment of Burbot populations in lakes of the upper Yukon/Tanana River drainages  summary of 2018 season on Copper River  2019 pre-season Copper River salmon forecast  2019 early season management strategy for Federal fisheries

BLM Agency Report to the Council

Jim Herriges with the BLM Eastern Interior Field Office presented the report. Mr. Herriges reported on:  BLM support of Fortymile Caribou monitoring  Tribal management plans for the Steese National Conservation Area and the White Mountains National Recreation Area  implementation of the 2016 resource management plan – lifting mineral withdrawals on about a million acres  Fortymile Caribou Herd monitoring

Mr. Herriges and the Council discussed caribou grazing in the burned areas and the need for habitat research.

New Business (resumed)

Special Action Request and Draft Proposal for Caribou in Units, 20E, 20F, and 25C (resumed)

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Mr. Herriges continued a conversation with the Council that was started during the first day of the meeting regarding a possible special action request or/and proposal for caribou in Units, 20E, 20F, and 25C, the draft of which was distributed to the Council. Mr. Herriges was seeking the Council’s input on should it be just a special action request to match up harvest regulations with the State. Mr. Herriges explained his rational on proposed dates and bag limits.

Motion #17 by Mr. Bassich, seconded by Mr. Woodruff, to support the special action request as presented by the BLM to adjust the Federal Fortymile Caribou regulations to match the State to reduce the user confusion.

Mr. Bassich said that the State has a number of methods to adjust the caribou harvest to achieve harvest plan goals recommended by the Fortymile Coalition.

Motion #17 carried unanimously.

Motion #18 by Mr. Bassich, seconded by Mr. Glanz, to support the regulatory proposal as presented by the BLM to change the 2020-2022 Federal Fortymile Caribou regulations.

Mr. Bassich expressed a concern about having season open on August 1, as was suggested in the draft proposal. When one hunts caribou that early, they will need to do some detailed planning because it is still very hot and it is not allowed to hunt along the road, so they will have to pack the meat out. OSM staff reminded the Council that they would have another opportunity to provide an official on-the-record opinion on this proposal during the fall 2019 meeting. Mr. Firmin said that it might be a wrong assumption to think that caribou is starving so half of them needs to be killed, instead of letting them to go hungry and may be finding some other grazing areas and expand. In case this does not work, he said, then “let the wild, wild west on the Taylor Highway take care of it.” Mr. Woodruff said that we do not want to see the Fortymile Herd crashing as it happened with the Mulchatna and Central Arctic Caribou herds, and the reduction doesn’t’ mean that half of caribou needs to be taken. The Council talked about how fast a herd crash might happen.

Motion #18 carried unanimously.

Agency Reports (resumed)

ADF&G Report on Movi Virus

Darren Bruning, Interior and Northeast Region Regional Supervisor, Division of Wildlife Conservation, ADF&G, provided a brief overview of Region 3 (Interior and Northeast Arctic) and its main topics and issues:  potential decline of the Central Arctic Herd and its population monitoring  management of the Fortymile Caribou Herd  diverse public values for the wolf  moose surveys  sustainable harvest of grizzlies

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 movement of pathogens and parasites into Alaska due to climate change and risk of disease

Mr. Bruning provided detailed information on the study of the pathogen called mycoplasma ovipneumoniae, commonly referred to as Movi, and its presence in Alaska’s sheep, mountain goat, moose, and caribou populations. Mr. Bruning noted that the public was of great help in collecting the testing samples; about 2,000 samples have been submitted to the lab.

The Council asked questions about the ways of Movi transmittal and presence of the pathogen on the Kodiak Island.

Antlerless moose hunt in the Minto Flats Management Area, Unit 20B (resumed)

Mr. McManus received an information from ADF&G that clarified that the moose hunt for ceremonial purposes was not shut down everywhere. Mr. Wright, Sr., obtained a copy of the ADF&G Division of Wildlife Conservation letter dated December 4, 2018 that contained a list of areas that are not eligible for ceremonial harvest of wildlife because it would inconsistent with sustained yield principles. The list included Units 20B, Minto Flats Management Area, 20C, 20F, and 25C for cow moose. Mr. Wright, Sr., and Mr. Bassich posed a question to Mr. Bruning regarding why the ADF&G would continue cow harvest in the area, but stop a cultural practice that has been in place long before statehood. Mr. Bruning explained that once the harvestable surplus that has been divided between ceremonial harvest and a Tier I subsistence hunt, is taken, then hunting for cow moose is stopped in a particular area. In this case, this is Minto Flats Management Area; however, outside of this area in other parts of Unit 20 moose cow harvest is available for ceremonial purposes.

Motion #19 by Mr. Bassich, seconded by Mr. Firmin, to support the letter from Tanana/Rampart/Manley AC to the ADF&G and BOG regarding antlerless moose and ceremonial harvest.

Mr. Bassich said that ceremonial harvest of moose is a very traditional longstanding practice that needs to be continued and that perhaps the issue will need to be resolved through a regulatory process.

Motion #19 carried unanimously.

The Council also recommended that Tanana/Rampart/Manley AC should submit a proposal to the BOG on this matter. Mr. McManus said that Nenana/Minot AC was also going to put in a proposal.

Yukon River Drainage Fisheries Association (YRDFA) Report

Wayne Jenkins, Director of Yukon River Drainage Fisheries Association, presented the report. He informed the Council about:  YRDFA in-season teleconference  YRDFA pre-season fishermen’s meeting

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 building and maintaining public support of salmon resource management  in-season harvest interviews  Traditional knowledge of anadromous fish in the Yukon Flats with a focus on the Draanjik Basin  YRDFA and Yukon Salmon Subcommittee Yukon River Panel Educational Exchange  Yukon River Comprehensive Salmon Plan  YRDFA transboundary Efforts  YRDFA’s involvement with BLM regional planning

Mr. Jenkins also presented to the Council a letter from the Tanana Chiefs Conference to the Secretary of the Interior Ryan Zinke on the lack of quality engagement with tribal governments on the Yukon River.

OSM Report

Ms. Hardin presented the OMS report on the upcoming Federal Subsistence Board meeting (April 15-18), extension of the open period to submit proposals to change Federal wildlife regulations, and staffing changes.

Pippa Kenner, Anthropologist with OSM, presented a brief update on the Fisheries Resource Monitoring Program and the Partners for Fisheries Monitoring Program.

Tanana Chiefs Conference (TCC) Report

Jim Simon with the TCC Hunting and Fishing Task Force talked about the deliberations of the wildlife proposals WP18-24 to allow use of snowmachines to position the animals at the Board meeting in April 2018. The Board did not adopt the proposal. Mr. Simon implied that the proposal was not adopted because there was a conflict between Refuge policy and ANILCA. The Bristol Bay Native Association together with the Tanana Chiefs Conference wants to initiate a statewide effort to address this issue of customary and traditional methods of hunting using a snowmachine. The State already allows it in a number of areas in Northwest Alaska and in the Bristol Bay region.

Mr. Simon also said that TCC is very concerned that the Section 810 analysis of the proposed oil and gas exploration of the 1002 area of the Arctic NWR has not adequately addressed the possible impacts to subsistence for the Arctic Village community. TCC requested the Council to get involved to request a complete assessment.

The Council and Mr. Simon had a discussion about the essence of terms “chasing” and “positioning” and the methods of positioning prior to the use of snowmachines. Ms. Kenner contributed to the discussion about the use of “fences” in the Northwest Arctic to direct caribou into the riverbeds, where they were harvested. The Council members shared their knowledge on historical positioning of the caribou. Ms. Hardin informed the Council that the Board plans to discuss this issue at its April 2019 meeting.

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Discussion regarding vacant seats on the Council, nominations process, and thank you letters

Motion #20 by Mr. Firmin, seconded by Mr. Bassich, to write a thankyou letter to Virgil Umphenour for the 17 years of service on the Council.

Mr. Bassich volunteered to contribute to drafting the letter and encouraged the other Council members to write a sentence or two. Mr. Bassich said that Virgil was probably one of “the best highly involved members as far as his wide range of knowledge and his photographic memory of conversations and events.”

Motion #20 carried unanimously.

Motion #21 by Mr. Wright, Sr., seconded by Mr. Glanz, to have the dedication to Lester Erhart framed and given to his family.

Motion #21 carried unanimously.

Future Meeting Dates:

The Council approved the dates of October 15 – 16 for the fall 2019 meeting to be held in Fairbanks.

Ms. Wessels provided the information to the Council on the Federal Real ID Act and talked about the need to hold the winter 2020 meeting in a community that has a Department of Motor Vehicles office that can issue the Real ID.

The Council selected March 3 – 4, 2020, and Fairbanks as preferred winter meeting dates and location.

Closing Comments from the Council

 New members are happy to be at the meeting and learned a lot  Great to have young Council members working on the Council and getting involved  Respect for others opinion is important  Thank you to the staff, respect and admiration for all the hard work despite the shut down  Don’t forget to let your communities know that the call for Federal wildlife proposals is still open  Thank you to the Chair Entsminger  Thank you for all of the information provided through the agency reports.  Effective and interesting meeting  We are attacking the message, not the messenger

Motion #22 to adjourn by Mr. Bassich, seconded by Mr. Glanz.

Motion #22 carried unanimously.

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I hereby certify that, to the best of my knowledge, the foregoing minutes are accurate and complete.

August 19, 2019

______Katerina “Katya” Wessels, DFO USFWS Office of Subsistence Management

______Susan Entsminger, Chair Eastern Interior Alaska Subsistence Regional Advisory Council

These minutes will be formally considered by the Eastern Interior Alaska Subsistence Regional Advisory Council at its October 11 -12, 2018 meeting in Tanana, and any corrections or notations will be incorporated in the minutes at that meeting.

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Federal Wildlife Closure Review WCR20-42

FEDERAL WILDLIFE CLOSURE REVIEW WCR20-42

Closure Location: Unit 12—Caribou

Current Federal Regulation

Unit 12−Caribou This is blank

Unit 12—that portion within the Wrangell-St. Elias National Park that No Federal open lies west of the Nabesna River and the Nabesna Glacier. All hunting of season caribou is prohibited on Federal public lands.

Unit 12—that portion east of the Nabesna River and the Nabesna Aug. 10-Sept. 30 Glacier and south of the Winter Trail running southeast from Pickerel Lake to the Canadian border — 1 bull by Federal registration permit only.

Federal public lands are closed to the harvest of caribou except by Federally qualified subsistence users hunting under these regulations.

Closure Dates: Year-round

Current State Regulation

Unit 12 remainder−Caribou Regulation Season

Residents and Nonresidents No open season

Regulatory Year Initiated:

Mentasta Caribou Herd - 1993

The original closure was for: that portion west of the Nabesna River within the drainages of Jack Creek, Platinum Creek, and Totschunda Creek - The taking of caribou is prohibited on public lands.

Chisana Caribou Herd - 1994 The original closure was for: that portion lying east of the Nabesna River and south of the Winter Trail running southeast from Pickerel Lake to the Canadian border - The taking of caribou is prohibited on public lands.

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Regulatory History Mentasta Caribou Herd (MCH)

In 1991, Federal subsistence hunting regulations for caribou in Unit 12 remainder were one bull from Sept. 1-20 and one caribou during a to-be-announced winter season for residents of Tetlin and Northway only as they had a customary and traditional use determination for the Nelchina Caribou Herd (NCH) in Unit 12 (OSM 1991a). Dates for the September season have remained unchanged since then, however, some of the area has been closed to the harvest of caribou due to conservation concerns.

Also in 1991, the Federal Subsistence Board (Board) approved Special Actions S91-05 and S91-08. Special Action S91-05 opened the winter caribou hunt in Unit 12 remainder on Oct. 28 (OSM 1991b) and S91-08 closed it on Dec. 9 after subsistence needs had been met (OSM 1991c).

In 1992, the Board rejected Proposals P92-105 (OSM 1992a) and P92-106 (OSM 1992b) due to biological concerns. Proposal P92-105 requested abolishing the to-be-announced winter caribou season in Unit 12 remainder and Proposal P92-106 requested lengthening the fall caribou season in Unit 12 remainder from Sept. 1-20 to Aug. 20-Sept. 20. The Board determined that there was no biological reason to eliminate the winter hunt and that extending the September hunt could impact the declining MCH and jeopardize the more popular winter hunt.

Also in 1992, the Board adopted Proposal P92-107, which changed the harvest limit for the winter caribou season in Unit 12 remainder from one caribou to one bull in order to protect the declining MCH, which mixes with the NCH in Unit 12 during the winter (OSM 1992c).

In 1993, the Board adopted Proposal P93-034 to close the area west of the Nabesna River within the drainages of Jack Creek, Platinum Creek, and Totschunda Creek to caribou hunting to protect the declining Mentasta Caribou Herd population (OSM 1993). There has been no Federal open season since 1993 for Unit 12 west of the Nabesna River and Nabesna Glacier.

Chisana Caribou Herd (CCH)

Because of its small population size, the CCH has never supported a large harvest. Between 1989 and1994 under State regulations, the harvest limit was 1 bull caribou and the annual harvest ranged between 16–34 animals (Gross 2005). The Federal subsistence regulation from 1989 to 1994 was one bull, Sept. 1- 20. By 1991, due to declining population numbers, the harvest was reduced through voluntary compliance by guides and local hunters. In 1994, the bull portion of the population declined below the ADF&G’s management objective and hunting of Chisana caribou was closed by both the Alaska Board of Game (BOG) and the Federal Subsistence Board (Board). There was no legal harvest of CCH in Alaska between 1994 and 2011.

In 1989 and 1990 the reported harvest of Chisana caribou in the Yukon was 18 and 11 animals and in Alaska was 34 and 34 animals, respectively (Gross 2005). Gross (2005) also reported that the estimated unreported harvest of Chisana caribou between 1989 through 2002 ranged from 1 – 20 in the Yukon and

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1-3 animals in Alaska each year. After 2001, Yukon First Nation members voluntarily stopped harvesting Chisana caribou and there continues to be no legal harvest of Chisana caribou in the Yukon.

In 1994, the caribou hunt areas in Unit 12 were split from two areas: 1) Unit 12- that portion lying west of the Nabesna River within the drainages of Jack, Platinum, and Totschunda creeks and 2) Unit 12- remainder, to three hunt areas: 1) Unit 12 west of the Nabesna River within the drainages of Jack, Platinum, and Totschunda creeks, 2) Unit 12- that portion lying east of the Nabesna River and south of the Winter Trail running southeast from Pickerel Lake to the Canadian border, and 3) Unit 12-remainder (OSM 1994). In 1994, the Board adopted Proposal P94-71, which closed the area east of the Nabesna River to the Canadian border to the harvest of caribou (OSM 1994). The closure for the Mentasta Caribou Herd remained in effect for the area west of the Nabesna River, and the area east of Nabesna River was closed primarily to protect the declining Chisana Caribou Herd (CSH), resulting in the following hunt areas:

Unit 12 – That portion west of the Nabesna River within the drainages of Jack Creek, Platinum Creek, and Totschunda Creek.

Unit 12 – That portion lying east of the Nabesna River and south of the Winter Trail running southeast from Pickerel Lake to the Canadian border.

In 2000, the areas previously designated west and east of the Nabesna River were combined into one area in Proposal P00-59 (OSM 2000):

Unit 12 – That portion of the Nabesna River drainage within the Wrangell-St. Elias National Park and Preserve and all Federal lands south of the Winter Trail running southeast from Pickerel Lake to the Canadian border.

In 2010, the BOG approved a hunt for residents and nonresidents from September 1 through 30 on the CCH for one bull by drawing permit. The hunt was authorized in the portion of Unit 12 within the White River drainage and that portion within the Chisana River drainage upstream from the winter trail that runs southeast from Pickerel Lake to the Canadian Border. However, on Federal public lands the Federal closure supersedes the existing State regulation and thus Federal public lands effectively remained closed to hunting of the CCH under State regulations at this time.

The entire area remained closed to caribou hunting in the Federal subsistence regulations until 2012, when the areas west and east of the Nabesna River were once again split out into two areas (OSM 2012a).

Unit 12 – that portion within the Wrangell-St-Elias National Park that lies west of the Nabesna River and the Nabesna Glacier.

Unit 12 – that portion east of the Nabesna River and the Nabesna Glacier and south of the Winter Trail running southeast from Pickerel Lake to the Canadian border.

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In 2012, the combined proposals WP10-104 and WP12-65/66 were addressed by the Board (OSM 2012a). Proposal WP10-104 requested establishment of a joint Federal/State draw permit for the CCH in Unit 12 with a harvest limit of one bull and a season of Sept. 1–Sept. 30. Proposal WP12-65 requested establishment of a Federal registration hunt for the CCH with a harvest limit of one bull and a season of Aug. 10 – Sept. 30, while WP12-66 requested establishment of a Federal registration hunt with a harvest limit of one bull and a season of Sept. 1–Sept. 30, with the hunt restricted to Federal public lands in Unit 12 east of the Nabesna River and the Nabesna Glacier. OSM noted in its justification for WP12-66 that restricting the hunt west of the Nabesna River and Nabesna Glacier would protect the MCH with minimal impact to subsistence hunters wanting to harvest caribou from the CCH (OSM 2012a). The Board took no action on WP10-104 and WP12-65 and adopted WP12-66 with modification to list the communities allowed to harvest caribou in Unit 12, that portion east of the Nabesna River and Nabesna Glacier, and lands south of the Winter Trail running southeast from Pickerel Lake to the Canadian border: Northway, Mentasta, Tetlin, Tok, Chisana, and Chistochina. The authority to manage the Federal hunt was granted by delegation of authority to the Wrangell-St. Elias National Park and Preserve Superintendent. The CCH was considered stable in 2010 and the bull:cow and calf:cow ratios were above the minimums set by the Draft Management Plan, which was finalized in the fall of 2011 (OSM 2012a, Chisana Caribou Herd Working Group 2012).

The Board adopted Proposal WP12-68, submitted by the Cheesh’na Tribal Council, which requested the residents of Chistochina be added to the Unit 12 caribou customary and traditional use determination (OSM 2012b).

In 2014, the Board adopted Proposal WP14-15/45 to expand the list of communities eligible to participate in the caribou hunt from the CCH to also include residents of the hunt area and those living in Unit 12 along the Nabesna Road (mileposts 25-46) (OSM 2014a).

In 2014, the Board also adopted Proposal WP14-49 with modification to change the fall season dates from Sept. 1-Sept. 30 to Aug. 10-Sept. 30, so that the bulls would be less likely to be in the rut, and thus, ensure the quality of the meat (OSM 2014b). In 2016, the Board adopted Proposal WP16-60 opening Federal public lands east of the Nabesna Glacier and south of the Winter Trail running from Pickerel Lake to the Canadian border to all Federally qualified users hunting under these regulations (OSM 2016).

Federal public lands comprise approximately 61% of Unit 12 and consists of 48% National Park Service (NPS) managed lands, 11% U.S. Fish and Wildlife Service managed lands (FWS), and 2% Bureau of Land Management (BLM) managed lands (Map 1).

Closure last reviewed:

Mentasta Caribou Herd: 1993 – P93-034

Chisana Caribou Herd: 2014 – WP16-60

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Justification for Original Closure (ANILCA Section 815 (3) criteria):

Section §815(3) of ANILCA states:

Nothing in this title shall be construed as – (3) authorizing a restriction on the taking of fish and wildlife for nonsubsistence uses on public lands (other than national parks and park monuments) unless necessary for the conservation of healthy populations of fish and wildlife, for the reasons set forth in section 816, to continue subsistence uses of such populations, or pursuant to other applicable law;…

The justifications given for the original closure for the MCH and CCH was:

Mentasta Caribou Herd

Council Recommendation for Original Closure: The Federal Subsistence Board’s April 1993 decision, which closed Federal public lands to caribou hunting in Unit 11 and a portion of Unit 12, occurred prior to the establishment of the Federal Subsistence Regional Advisory Councils.

State Recommendation for Original Closure: ADF&G supported the closure because the State season for Mentasta caribou in this area had been closed for several years (OSM 1993).

From 1985-1992, the MCH decreased from a peak population of 3,100 caribou to 1,300 and the fall calf:cow ratio had fallen below the threshold level required to balance the mortality of the adults (≈15%) during the previous 2-3 years. The near total reproductive failure in 1991 and 1992 resulted in the population age structure to be skewed towards the older age classes, which generally results in delayed recovery. Another factor that may have contributed to the population declines was the relatively poor lichen conditions noted throughout a large portion of their range.

Although the fall harvest is relatively easy to track, the MCH is subject to unknown harvest when it mixes with the NCH during the winter. In addition, the extent of the illegal harvest is unknown, but considering the number of small rural communities they pass through during migration, it is likely high. Thus, the potential for over-harvest of this small herd is high. Most subsistence users also have access to the much larger neighboring NCH.

Thus, closing the subsistence hunt on the MCH was necessary to assure the herd’s continued viability.

Chisana Caribou Herd:

30 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Federal Wildlife Closure Review WCR20-42

Council Recommendation for Original Closure: The Eastern Interior Council concluded that the Chisana caribou herd should be protected from all hunting to stop the population decrease (OSM 1994). The justification for their decision was based on the following:

 Over the past 3 years (1990-1993) the CCH population had declined from 1850 to 900 animals.  The fall calf:cow ratio was below that which is required to balance the natural mortality of adults (≈15 %) for at least 4 consecutive years  The potential for overharvest of this small herd was considered high since they cross international boundaries and are subject to an unknown amount of unreported harvest.  This proposal (Wildlife Proposal 14-49) is intended to protect the continued viability of the CCH and allow them to recover more quickly.

State Recommendation for Original Closure: The Alaska Department of Fish and Game (ADF&G) and the Yukon Department of Natural Resources supported closure to caribou hunting of the CCH until calf:cow and bull:cow ratios increased.

Biological Background The ranges of the Mentasta, Chisana, and Nelchina caribou herds overlap in Unit 12 (Map 1). As of July 2018 the NCH is declining and is at the lower end of the State population objectives (ADF&G 2018, Hatcher 2018, pers. comm.). The MCH occurs primarily in the northern portion of Unit 12 (Unit 12- remainder) and the northern portion of Unit 11 within Wrangell-St. Elias National Park and Preserve (WRST). While the NCH and MCH are considered distinct herds because females calve in separate areas, the herds mix during some breeding seasons, resulting in male-mediated gene flow (Roffler et al. 2012). Therefore, the Nelchina and Mentasta herds function as a genetic metapopulation, although Nelchina and Mentasta cows have discrete mitochondrial DNA (Roffler et al. 2012). However, since there are no closures associated with the NCH, the NCH is not considered further in this analysis.

The CCH is a shared population between Alaska and Southern Yukon, Canada. Since this international herd ranges across multiple jurisdictions, multiple land agencies are involved and responsible for the management of the CCH. In Alaska the CCH occurs primarily on Federal public lands within the WRST, although there is some overlap with Tetlin National Wildlife Refuge (TNWR) and adjacent State lands. In the Yukon, the CCH ranges within the boundaries of Kluane Wildlife Sanctuary and Asi Keyi Natural Environmental Park. Since the overlap between the CCH and MCH is minimal, each population will be considered separately in this analysis. The Management Plan for the Chisana Caribou Herd (Chisana Caribou Herd Working Group 2012) is currently being reviewed and updated.

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Map 1. R

Mentasta Caribou Herd

The MCH, the primary herd within Unit 11, calves and summers within the upper Copper River Basin and the northern and western flanks of the Wrangell Mountains (OSM 2018). Barten et al. (2001) found that parturient female caribou from the Mentasta herd used birth sites that lowered the risk of predation and traded-off forage abundance for increased safety. Minimizing risk of predation of neonates may result in ungulates selecting habitats that compromise their ability to optimize foraging (Bowyer et al. 1999, Barten et al. 2001). Female Mentasta herd caribou used sites at higher elevations with sub-optimal forage, presumably to avoid predators, and, when <10 day old neonates were lost, females descended from the higher elevations to join other nonparturient females. In addition, females with neonates >10 days old also descended to join the larger group of females, which coincides with moving out of the riskiest period of predation on ungulate neonates (Adams et al. 1995a).

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The calving grounds for the MCH are located in northern Unit 11 within WRST (MCH Mgmt. Plan 1995, Map 1). The MCH disperses across Unit 12 and southern Unit 20E in winter, often intermingling with the NCH (MCH Mgmt. Plan 1995).

In 1995, Federal and State biologists completed the Mentasta Herd Cooperative Management Plan, which specifies the following management objectives (MCH Mgmt. Plan 1995):

 To the extent possible, allow for human harvest that will have minimal effects on the production, composition, and abundance of Mentasta caribou.  To provide harvest priority to Federally-eligible subsistence users and to allow State authorized hunting to occur whenever possible.  To monitor the herd demographics and harvest such that all pertinent data on the health of the herd are collected and disseminated to all agencies and citizens concerned with their management.

The MCH Management Plan (1995) states “an annual fall harvest quota will be established between 15 and 20 percent of the previous 2-year mean calf recruitment as long as such recruitment is at least 80 calves. In addition, at population levels below 2,000 the harvest limit will be limited to “bulls only” and will be closed if the 2-year mean bull:cow ratio drops below 35 bulls:100 cows.” When fall annual quotas are greater than 70 both non-Federally and Federally qualified users are allowed to hunt the MCH during the fall season. When the fall annual quota falls below 70, only federally qualified users are allowed to hunt the MCH during the fall season. Below 30, a Section 804 analysis will determine the allocation of permits among the Federally qualified subsistence users. Since 2000, managers at the TNWR have used a 20:1 mixing ratio of Nelchina caribou to Mentasta caribou as the minimum threshold for considering winter season openings. The TNWR monitors the location and movement from aerial surveys of radio-collared caribou of the MCH and NCH. This information is used to determine a reliable mixing ratio with the NCH. In 2016 and 2017 the number of active collars in the MCH declined to 10 which was too few to adequately determine a reliable mixing ratio with the NCH. In 2018, staff from the WRST and ADF&G deployed an additional 10 collars, which brings the total to about 20 active collars. Population and composition surveys were conducted during fall of 2018 (Putera 2018, pers. comm.).

The MCH population declined from an estimated 3,160 caribou in 1987 to an estimated 470 caribou in 2018 (Table 1). The extremely low calf :cow ratio of 2-6 calves: 100 cows from 1991 to 1993 (OSM 1992d) resulted in a complete failure of fall recruitment of young in the MCH (Jenkins and Barton 2005). Dale (2000) postulated that this may have been due to poor condition from poor forage quality in the summer. Poor forage quality in the summer can cause cow caribou to skip a breeding season to regain body condition due to being nutritionally stressed. The resulting decrease in body condition in female caribou can have a negative effect on productivity by causing lower weight gain or survival in calves (Crete and Huot 1993, Dale 2000). Between 1990 and 1997, Jenkins and Barten (2005) confirmed predation, particularly by gray wolves and grizzly bears, as the proximate cause of the MCH population decline. Grizzly bears were the most important predators of neonates and gray wolves mostly predated on older juvenile caribou in the MCH. The combined predation by bears and wolves was 86% during the

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neonate and summer periods. In comparison, predation of calves in the Denali Caribou Herd from 1984 to 1987 by wolves and bears, during the same time period, was only 53% (Adams et al. 1995b). Factors such as the timing of birth and habitat at the birth site, particularly snow patterns, affected the vulnerability and survival of neonates and birth mass affected the survival of juveniles through summer (Jenkins and Barten 2005). The MCH declined at the greatest rate from 1990-1993 compared to 1994- 1997. Winter severity was postulated to decrease the birth mass of neonates and, thus, the survival and vulnerability of neonates and juveniles (Jenkins and Barton 2005). The MCH population has remained stable at relatively low levels since 2004 as evidenced by low calf productivity (Putera 2017a, pers. comm.). Between 1987 and 2017, the bull:cow ratio has fluctuated widely, ranging from 35-120 bulls:100 cows and averaging 58 bulls:100 cows. June and fall calf:cow ratios fluctuated over the same time period, ranging from 1-38 calves:100 cows and 0-33 calves:100 cows, respectively (Table 1, OSM 2018). Low calf production and survival and high cow mortality from 1987 and 2009 were the primary causes for the population declines in the MCH. The number of cows observed during the fall surveys declined from 2,065 in 1987 to 79 in 2009 (OSM 2012c).

Fall surveys conducted within the same 23-year period also revealed severe declines in total observed Mentasta bulls from 847 in 1987 to 68 in the fall 2013 survey (Table 1). Although observed fall bull:cow ratios appear high, the number of cows observed is small and the bull component likely includes a significant number of Nelchina bulls. While Nelchina bulls have wintered within the range of the Mentasta herd (OSM 2018), the range of the Nelchina herd has varied widely due to burns and their effect on lichen availability within their traditional area (Collins et al 2011). Thus, there is limited ability to predict the extent or frequency of mixing between Nelchina and Mentasta bulls, and it is impossible to discern whether the harvest of a bull would be from the Nelchina or Mentasta herd. Higher numbers of adult bulls in the population are important as it helps maintain synchrony in parturition. Holand et al. (2003) showed that skewed sex ratio and increased young male age structure of reindeer could result in fewer adult females conceiving during the first estrous cycle due to their hesitation to mate with young bulls. Maintaining synchrony in parturition also provides increased survival chances for calves since parturition is typically timed with the start of plant growth (Bergerud 2000). Late-born offsprings have been shown to have lower body mass than caribou offspring produced earlier in the season (Holand et al. 2003), which can lead to lower juvenile survival rates due to density dependent factors of winter food limitation (Skogland 1985) and deep snows (Bergerud 2000).

The MCH is considered a sedentary and low density ecotype (Bergerud 1996, Hinkes et al. 2005) versus a migratory and high density ecotype, such as the Nelchina herd, and thus more susceptible to extreme random events. The term ecotype designates populations of the same species that evolved different demographic and behavioral adaptations to cope with specific ecological constraints. A key factor in distinguishing between two ecotypes is whether animals were dispersed or aggregated when young were born (Seip 1991, Bergerud 2000). The chronic low calf productivity and recruitment for the Mentasta caribou could make random environmental events a primary driver for a more severe population decline (Tews et al. 2006). Increased winter mortality due to icing events may result in malnutrition and starvation for more susceptible calves and bulls with depleted energy reserves following the rut (Dau 2011, Miller and Gunn 2003). Bull caribou die at a higher rate than cows due to greater energy demands

34 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Federal Wildlife Closure Review WCR20-42 during early winter rutting activities, which greatly reduce their body reserves (Russell et al. 1993, Miller and Gunn 2003).

Table 1 F Fall June Fall Fall Fall Fall Bulls: Fall Population Year Calves:100 Calves: Cows Calves Bulls 100 Estimatec Cowsa 100 cows cowsb 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 F – F F

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Chisana Caribou Herd

The CCH is a small herd that occurs on the Klutan Plateau and near the headwaters of the White River in southwest Yukon Territory and east central Alaska. During the summer the CCH spends most of their time in WRST and during the winter in the Kluane Wildlife Sanctuary and the Asi Keyi Natural Environmental Park (Chisana Caribou Herd Working Group 2012).

The CCH is a genetically distinct population (Zittlau et al. 2000, Zittlau 2004). Genetic analysis of the CCH found large genetic distances between the CCH and the other 5 adjacent herds, which suggests that the herd has been unique for thousands of years and that the CCH is correctly classified as a woodland caribou (Zittlau et al. 2000). The CCH acts and looks like woodland caribou, but the herd’s classification is ambiguous. Behaviorally, the CCH is typical of other mountain herds, particularly with respect to calving females, where, rather than aggregating in certain areas, they disperse up in elevation away from other calving females as an anti-predator strategy (Farnell and Gardner 2002). In Canada, the CCH is classified as woodland caribou, whereas in Alaska the CCH is classified a barren-ground caribou (Miller 2003). Occasionally the CCH mix with the Nelchina and Mentasta caribou herds during the winter in Alaska and Yukon in the vicinity of Beaver Creek, Yukon Territory. For example in 1989/1990, a large portion of the CCH shifted northeast into the upper and middle portions of Beaver Creek, where some mixing between the CCH, Nelchina, and Mentasta caribou herds occurred (Lieb et al. 1994).

In Canada, the Canadian Wildlife Service (CWS) has designated the Northern Mountain Caribou population, which includes the CCH, as a species of “Special Concern” under the Canadian Federal Species at Risk Act (SARA). In 2002, the CCH was designated as “Specially Protected” under the Yukon Wildlife Act, which prohibits all licensed harvest of the CCH and requires a regulation change to initiate a harvest. A cooperative draft CCH Management Plan and Yukon CCH Recovery Plan were developed for the CCH in 2001 and 2002, respectively. In 2009, a working group consisting of members from the Government of Yukon, ADF&G, White River First Nation, Kluane First Nation, the National Park Service, and the U.S. Fish and Wildlife Service developed a five-year management Plan for the CCH (Chisana Caribou Herd Working Group 2012). The working group is now in the process of updating the plan.

The CCH Management Plan guidelines for harvest are:

 A bull:cow ratio greater than 35 bulls: 100 cows  A calf:cow ratio greater than 15 calves: 100 cows based on a 3-year average  A stable or increasing population trend

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The Management Plan guidelines for a harvest include a maximum allocation of 2% of the herd size, a bull-only harvest, and an allocation equally distributed between Yukon Territory and Alaska (Chisana Caribou Herd Working Group 2012).

Information about the CCH prior to 1970s is limited. The population estimate from first survey conducted in 1977 was about 1000 caribou (Kellyhouse 1990). In 1988, the CCH reached a peak of 1,900 caribou (Kellyhouse 1990) and then declined to an estimated low of 315 in 2002 (Farnell and Gardner 2002). Since 1988, a majority of the CCH have been located east of the Nabesna River (Bentzen 2011). Adverse weather conditions, poor habitat, predation, and harvest pressure were factors for the low calf recruitment and high adult mortality associated with the decline (Farnell and Gardiner 2002). From 2003- 2006, a recovery effort, which included an intensive captive rearing program to increase recruitment and calf survival, was conducted by the U.S. Geological Survey and CWS. The recovery effort involved capturing pregnant cows and enclosing them in holding pens during the last weeks of gestation and for a few weeks following calving. An intensive radio-collaring program was also initiated in 2003 along with the captive rearing program, which resulted in more reliable population and composition data. Therefore, sex and age composition and herd size estimates prior to 2003 are not directly comparable to those after 2003 (Table 2) (Bentzen 2011, 2013; Gross 2015, Putera 2017b). In 2010, the CCH population was stable at 696 animals and the 3-year average for the bull:cow and calf:cow ratios were 45: 100 cows and 20: 100 cows, respectively (Bentzen 2011, Gross 2015). The 2017 bull:cow ratio of 32 bulls per 100 cows was below the minimum threshold of 35 bulls:100 cows set by the Chisana Caribou Management Plan, triggering a meeting of the management authorities. This occurred as part of the conversations regarding updating the plan, and the consensus of the group was that a 3 year running average was a more appropriate threshold and that the 2018 hunt could occur (Cellarius 2018a). From 2014-2019, the calf:cow ratio averaged 21 calves:100 cows which was above the minimum threshold set by the Plan of 15 calves: 100 cows based on three year average (Chisana Caribou Herd Working Group, 2012). In April 2019, another 15 GPS/Iridium and 10 VHF collars are scheduled for deployment in Alaska and Yukon (Putera 2018, pers. comm.).

Table 2 F T Total Calves Regulatory Calves Cows Bulls Composition Estimated Bulls:100 :100 Year (%) (%) (%) Sample Size Herd Size Cows Cows A A A A A A A A

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Total Calves Regulatory Calves Cows Bulls Composition Estimated Bulls:100 :100 Year (%) (%) (%) Sample Size Herd Size Cows Cows A A A A A A A A A A A A A A A A ADF

Harvest History Mentasta Caribou Herd

There has been no Federal open season since 1993 for the area west of the Nabesna River and Nabesna Glacier in Unit 12. There has been no reported harvest from the MCH since 1998 as there has been no State or Federal season. However, some incidental harvest of Mentasta caribou may take place during winter hunts targeting the NCH and Forty-mile caribou herd in Unit 12-remainder. While the MCH management plan does not specify an appropriate mixing ratio, the 20:1 ratio has been used to determine winter season openings by the Board since at least 2000 (OSM 2000). The MCH management plan suggests that incidental harvest of Mentasta caribou is usually minimal (MCH Management Plan 1995). In 2012, the Board excluded the area west of the Nabesna River and Nabesna Glacier to protect the MCH, when it established a Federal registration hunt for the CCH in Unit 12 east of the Nabesna River and Nabesna Glacier (OSM 2012a).

Chisana Caribou Herd

The CCH has historically been an important food source for the Athabascans of Alaska and the First Nations of the Yukon in Canada (Gross 2007). During the early to mid-1900s, the CCH was used as a subsistence food source by the Ahtna and Upper Tanana Athabascans. Although subsistence hunting has declined in recent years, the CCH continues to be an important aspect of Upper Tanana and Ahtna Athabascan culture. Subsistence use of the CCH declined after 1929. For the last 60 years, few people in Alaska or the Yukon have depended on the CCH as a food source (Bentzen 2011), although First Nation members continued to harvest from the CCH in the Yukon through the 1990s.

In addition to providing an important subsistence resource, in the late 1920s, Chisana caribou became economically important to local hunters as guided hunting became common in the Chisana area. Caribou from the Chisana herd were harvested by nonresident hunters guided by local guides until 1994, when hunting was closed. Primarily five guide/outfitters hunted the herd (4 operated in Alaska and 1 in the Yukon). Bulls were desired by sport hunters, because of their large stature. From 1990 to1994, 43% of the hunters participating in hunting were nonresidents, who were responsible for 58% of the harvest. Local subsistence users accounted for 9% of the harvest during that time period (Gross 2005).

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At its January 2012 meeting, the Board authorized a limited harvest of the CCH consistent with the herd’s management plan. The Board delegated authority to the Wrangell-St. Elias National Park and Preserve Superintendent to open and close the season to announce the harvest quota, the number of permits to be issued and the reporting period. Based on the estimated population size and the guidance in the management plan, the harvest quota for the 2012 was set at seven animals.

The National Park Service met with participating communities and associated tribal governments and other stakeholders to ask for their input regarding permit distribution. As a result, a decision was made to allocate two permits to each of the four eligible communities with Federally recognized tribal governments (Chistochina, Mentasta Lake, Northway, and Tetlin) with the understanding that all community residents, not just tribal members, would be considered for permit distribution. Any remaining permits would be made available to Tok and Chisana residents on a first come-first served basis. The number of permits was limited to fourteen and the reporting period requirement was set at within three days of harvest. In 2017, nine permits were issued, three people hunted, and no animals were harvested (FWS 2018). Currently the CCH appears stable at approximately 700 animals and the quota for the 2018-2019 Federal subsistence hunt for the CCH is set at seven bull caribou (Cellarius 2018b). Preliminary reports (as of October 5, 2018) indicate that six permits were issued in 2018 and two caribou were harvested (FWS 2018).

Since 2012, ten caribou have been taken (Table 3).

Table 3 F F 2012 2013 2014 2015 2016 2017a 2018b Permits Issued Individuals Hunting Caribou Harvest Success Ratec

OSM Preliminary Conclusion: X maintain status quo – Maintain closure for the MCH and the limited hunt for the CCH _ modify or eliminate the closure _ other recommendation

Justification Mentasta Caribou Herd:

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The Mentasta Caribou herd, as currently defined, exists in low numbers and their distribution is small groups in the summer and winter ranges has resulted in a fragmented population. Because of this, total numbers and composition can be significantly affected by sightability when searching for small groups of caribou over vast terrain. Mixing of the Nelchina and Mentasta caribou bulls makes interpreting fall composition surveys difficult and there is limited ability to predict the extent, timing or frequency of mixing between the two herds. It would be impossible for most hunters to discern whether the bull was from the Mentasta herd or the Nelchina herd. In addition, there is the possibility of increased winter mortality due to icing events, which may result in malnutrition and starvation for more susceptible bulls with depleted energy reserves following the rut furthering the decline of the Mentasta caribou population. Calf production and survival remain critically low and have resulted in low numbers of adult cows and bulls observed during recent fall population surveys. Calf production and recruitment in particular remains below the management objective. These declines are indicative of low production, poor recruitment, and low survival rates among cohorts within the population.

In addition, the MCH has not increased much, despite a moratorium on hunting since 1993. This may be due to a variety of factors including low calf production and recruitment due to relatively poor range quality, predation, and susceptibility to severe weather events. The MCH population has remained at relatively low levels of approximately 400 (mean = 413) caribou since 1998 (Table 1). The relatively low number of active collars presently in the MCH (≈ 10) makes it difficult for biologists and managers to adequately monitor the location and movements of the MCH in relation to the much more numerous NCH. Without a reliable mixing ratio, Federal public lands within WRST in Unit 12 should continue to remain closed to caribou hunting, west of the Nabesna River and Nabesna Glacier, for the conservation of a healthy population.

Chisana Caribou Herd:

Historically very few Chisana caribou have migrated west of the Nabesna River and Nabesna Glacier in Unit 12. Restricting the current hunt to east of the Nabesna River and Nabesna Glacier will protect the Mentasta Caribou herd with minimal impact to subsistence hunters wanting to harvest a caribou from the CCH. The relatively few caribou harvested from the CCH in WRST since 2012 do not seem to be having a negative population level effect on the CCH. In addition, the WRST Superintendent has Delegated Authority to open and close the season, and to announce the harvest quota, the number of permits and the reporting period. Thus, the current season and limited harvest by Federally qualified subsistence users in that portion east of Nabesna River and the Nabesna Glacier and south of the winter trail running southeast from Pickerel Lake to the Canadian border in Unit 12 are consistent with recommendations and management guidelines in the CCH Management Plan (Chisana Caribou Herd Working Group 2012).

Literature Cited Adams, L. G., F.J. Singer, and B.W. Dale. 1995a. Caribou calf mortality in Denali National Park, Alaska. Journal of Wildlife Management 59:584-594.

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Adams,L.G., B.W. Dale, B. Shults, and L.D. Mech. 1995b. Wolf predation on caribou calves in Denali National Park, Alaska. in Ecology and conservation of wolves in a changing world. Eds. S.H. Fritz, and D.R. Seip. Occasional Publications No. 35., Canadian Circumpolar Institute, University of Alberta, Edmonton. Pp. 245-260. Alaska Department of Fish and Game (ADF&G). 2018. News Release: 04-07-18 – Winter Seasons closed for the Nelchina Caribou Hunts RC561, RC562, and DC485. ADF&G, Glenallen, AK.

Barten, N.L., R.T. Bowyer, and K.J. Jenkins. 2001. Habitat use by female caribou: tradeoffs associated with parturition. Journal of Wildlife Management 65:77-92.

Bentzen, T.W. 2011. Unit 12 caribou. Pages 60-73 in P. Harper, editor. Caribou management report of survey and inventory activities 1 July 2008-30 June 2010. Alaska Department of Fish and Game. Project 2.0. Juneau, AK.

Bentzen, T.W. 2013. Unit 12 caribou. Pages 76-88 in P. Harper, editor. Caribou management report of survey and inventory activities 1 July 2010-30 June 2012. Alaska Department of Fish and Game, Species Management Report ADF&G/DWC/SMR-2013-3, Juneau, AK. Bergerud, A.T. 1996. Evolving perspectives on caribou population dynamics, have we got it right yet? Rangifer 9:95–115.

Bergerud, A.T. 2000. Caribou. Pages 658–693 in S. Demarais and P.R. Krausman, editors. Ecology and Management of Large Mammals in North America. Prentice Hall Press. Upper saddle River, NJ. 778 pages.

Bowyer, R.T., V. Van Ballenberghe, J.G. kie, and J.A.K. Maier. 1999. Birth-site selection in Alaska moose: maternal strategies for coping with a risky environment. Journal of Mammalogy 80: 1070-1083.

Cellarius, B. 2013. Fall Subsistence Report. Wrangell-St. Elias National Park and Preserve. Copper Center, AK. 3 pp.

Cellarius, B. 2018a. Cultural Anthropologist. Personal communication: e-mail. Wrangell-St. Elias National Park and Preserve. Copper Center, AK

Cellarius, B. 2018b. News Release. NPS announces plans for 2018 Federal subsistence hunt of Chisana Caribou Herd. Wrangell-St. Elias National Park and Preserve, Copper Center, AK.

Chisana Caribou Herd Working Group. 2012. Management Plan for the Chisana Caribou Herd: 2010-2015. Government of Yukon, Department of Environment, Whitehorse, YT. 48 pp.

Collins, W.B., B.W. Dale, L.G. Adams, D.E. McElwain, and K. Joly. 2011. Fire, grazing history, lichen abundance, and winter distribution of caribou in Alaska’s Taiga. Journal of Wildlife Management 75:369-377.

Crete, M. and J. Huot. 1993. Regulation of a large herd of caribou: Summer nutrition affects calf growth and body reserves of dams. Canadian Journal of Zoology 71:2291-2296.

Dale, B. 2000. The influence of seasonal spatial distribution on growth and age of first reproduction of Nelchina caribou with comparisons to the Mentasta herd, Research Perfomance Report. 1 July 1999 – 30 June 2000. Federal Aid Annual Performance Report Grant W-27-3. Study 3.44. Anchorage, AK.

Dau, J. 2011. Units 21D, 22A, 22B, 22C, 22D, 22E, 232, 24, and 26A caribou management report Pages 187-250 in P.Harper, editor. Caribou management report of survey and inventory activities 1 July 2008-30 June 2010. Alaska Department of the Fish and Game, Juneau, AK.

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Farnell, R., and C. Gardner. 2002. Chisana caribou herd-2002. Yukon Department of Environment. Whitehorse, Yukon, Canada. FWS. 2018. Harvest database. Office of Subsistence Management, USFWS, Anchorage, AK.

Gross, J.A. 2005. Unit 12 caribou management report. Pages 61-69 in C. Brown, editor. Caribou management report of survey and inventory activities 1 July 2002-30 June 2004. Alaska Department of Fish and Game, Division of Wildlife Restoration, Project 3.0. Juneau, AK.

Gross, J.A. 2007. Unit 12 caribou. Pages 56-64 in P. Harper, editor. Caribou management report of survey and inventory activities 1 July 2004-30 June 2006. Alaska Department of Fish and Game, Project 3.0. Juneau, AK.

Gross, J.A. 2015. Unit 12 caribou. Chapter 7, Pages 7-1 through 7-11 in P. Harper and L.A. McCarthy, editors. Caribou management report of survey and inventory activities 1 July 2012-30 June 2014. Alaska Department of Fish and Game, Species Management Report ADF&G/DWC/SMR-2015-4, Juneau, AK. Hatcher, Heidi. 2018. 2018 Nelchina Caribou Herd minimum count and population estimate. Alaska Department of Fish and Game, Glennallen, AK. 4 pp.

Hinkes, M.T., G.H. Collins, L.J. Van Daele, S.D. Kovach, A.R. Aderman, J.D. Woolington, R.J Seavoy. 2005. Influence of Population Growth on Caribou Herd Identity, Calving Ground Fidelity, and Behavior. Journal of Wildlife Management 69(3):1147–1162.

Holand, O., K.H. Roed, A. Mysterud, J. Kumpula, M. Nieminen, and M.E. Smith. 2003. The effect of sex ratio and male age structure on reindeer calving. Journal of the Wildlife Management 67:25-33.

Jenkins, K.J., N.L. Barten. 2005. Demography and decline of the Mentasta caribou herd in Alaska. Canadian Journal of Zoology. 83: 1174-1188.

Kellyhouse, D.G. 1990. Unit 12 caribou. Pages 46-54 in C. Healy, editor. Caribou annual report of survey and inventory activities 1 July 1988-30 June 1989. Alaska Department of Fish and Game. Project 3.0. Juneau, AK

Lieb, J.W., B.W. Cella and R.W. Tobey 1994. Population dynamics of the Mentasta caribou herd. Alaska Department of Fish and Game, Division of Wildlife Conservation, Research Final Report, Juneau, AK. 72 pp. Mentasta Caribou Herd Cooperative Management Plan. 1995. Wrangell St.-Elias National Park and Preserve, Glennallen, AK 17 pp.

Miller, F.L. 2003. Caribou. Pages 965-977 in G.A. Feldhamer, B.C. Thompson, and J.A. Chapman eds. Wild Mammals of North America, Second edition. John Hopkins University Press, Baltimore, MD.

Miller, F.L. and A. Gunn. 2003. Catastrophic Die-off of Peary Caribou on the Western Queen Elizabeth Islands, Canadian High Arctic. Arctic 56:381–390.

OSM 1991a. Staff analysis P91-130. Pages 35-36 in Federal Subsistence Board Meeting Materials March 4–8, 1991. Office of Subsistence Management, FWS. Anchorage, AK. 246 pp.

OSM. 1991b. Staff analysis S91-05. Office of Subsistence Management, FWS. Anchorage, AK.

OSM. 1991c. Staff Analysis S91-08. Office of the Subsistence Management, FWS. Anchorage, AK.

42 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Federal Wildlife Closure Review WCR20-42

OSM 1992a. Staff analysis P92-105. Pages 584-585 in Federal Subsistence Board Meeting Materials April 6–10, 1992. Office of Subsistence Management, FWS. Anchorage, AK. 1254 pp.

OSM 1992b. Staff analysis P92-106. Pages 592-593 in Federal Subsistence Board Meeting Materials April 6–10, 1992. Office of Subsistence Management, FWS. Anchorage, AK. 1254 pp.

OSM 1992c. Staff analysis P92-107. Pages 588-589 in Federal Subsistence Board Meeting Materials April 6–10, 1992. Office of Subsistence Management, FWS. Anchorage, AK. 1254 pp.

OSM 1992d. Staff analysis P92-18. Pages 94-95 in Federal Subsistence Board Meeting Materials April 6–10, 1992. Office of Subsistence Management, FWS. Anchorage, AK. 1254 pp.

OSM. 1993. Staff analysis P93-034. Pages 283–290 in Federal Subsistence Board Meeting Materials April 5–8, 1993. Office of Subsistence Management, FWS. Anchorage, AK. 622 pp.

OSM. 1994. Staff analysis P94-71. Pages 593–600 in Federal Subsistence Board Meeting Materials April 11–15, 1994. Office of Subsistence Management, FWS. Anchorage, AK. 726 pp.

OSM. 2000. Staff analysis P00-59. Pages 628–638 in Federal Subsistence Board Meeting Materials May 2–4, 2000. Office of Subsistence Management, FWS. Anchorage, AK. 661 pp.

OSM. 2012a. Staff analysis WP10-104 and WP12-65/66. Pages 255–274 in Federal Subsistence Board Meeting Materials January 17–20, 2012. Office of Subsistence Management, FWS. Anchorage, AK. 1021 pp.

OSM. 2012b. Staff analysis WP12-68. Pages 275–287 in Federal Subsistence Board Meeting Materials January 17– 20, 2012. Office of Subsistence Management, FWS. Anchorage, AK. 1021 pp.

OSM. 2012c. Staff analysis WP12-24. Pages 575–588 in Federal Subsistence Board Meeting Materials January 17– 20, 2012. Office of Subsistence Management, FWS. Anchorage, AK. 1021 pp.

OSM. 2014a. Staff analysis WP14-15/45. Pages 465–484 in Federal Subsistence Board Meeting Materials April 15– 17, 2014. Office of Subsistence Management, FWS. Anchorage, AK. 680 pp.

OSM. 2014b. Staff analysis WP14-49. Pages 322–335 in Federal Subsistence Board Meeting Materials April 15–17, 2014. Office of Subsistence Management, FWS. Anchorage, AK. 680 pp.

OSM 2016. Staff analysis WP18-60. Pages 354-370 in Federal Subsistence Board Meeting Materials April 12-14, 2016. Office of Subsistence Management, FWS, Anchorage, AK 948 pp.

OSM 2018. Staff analysis WP18-54. Pages 1195-1227 in Federal Subsistence Board Meeting Materials April 10-13, 2018. Office of Subsistence Management, FWS, Anchorage, AK 1488 pp.

Putera, J. 2014. Wrangell-St.-Elias National Park and Preserve March 2014 Wildlife Report. Wrangell-St. Elias National Park and Preserve. Copper Center, AK. Putera, J. 2017a. Wildlife Biologist. Personal communication: e-mail. Wrangell-St. Elias National Park and Preserve. Copper Center, AK.

Putera, J. 2017b. Wrangell-St. Elias National Park and Preserve Fall 2017 Wildlife Report. Wrangell-St. Elias National Park and Preserve, Copper Center, AK. 5 pp.

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 43 Federal Wildlife Closure Review WCR20-42

Putera, J. 2018. Wildlife Biologist. Personal communication: e-mail, phone Wrangell-St. Elias National Park and Preserve. Copper Center, AK.

Roffler, G.H., L.G. Adams, S.L. Talbot, G.K. Sage, and B.W. Dale. 2012. Range overlap and individual movements during breeding season influence genetic relationships of caribou herds in south-central Alaska. Journal of Mammalogy 93(5): 1318-1330.

Russell, D.E., A.M. Martell, and W.A.C. Nixon. 1993. Range ecology of the porcupine caribou herd in Canada. Rangifer Special Issue 8:1– 167.

Seip, D.R. 1991. Predation and caribou populations. Rangifer 7:46–72.

Skogland, T. 1985. The effects of density-dependent resource limitations on the demography of wild reindeer. Journal of Animal Ecology 54:359–374.

Taylor, S. 2018. Kluane Regional Biologist. Personal communication: e-mail. Yukon Environment – Fish and Wildlife Branch, Yukon, Canada.

Tews, J., M.A.D. Ferguson, L. Fahrig. 2006. Potential net effects of climate change on High Arctic Peary caribou: Lessons from a spatially explicit simulation model. Ecological Modelling 207:85–98.

Zittlau, K.J. Coffin, R. Farnell, G. Kuzyk, and C. Strobeck. 2000. Genetic relationships of the Yukon woodland caribou herds determined by DNA typing. Rangifer Special Issue 12:59-62. Zittlau, K. 2004. Population genetic analyses of North American caribou (Rangifer tarandus). Ph.D. Dissertation. University of Alberta, Edmonton, Canada.

44 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Federal Wildlife Closure Review WCR20-42

SOUTHCENTRAL ALASKA SUBSISTENCE REGIONAL ADVISORY COUNCIL RECOMMENDATIONS

The Council voted (10-1) to maintain the status quo to retain the closure for the Mentasta Caribou Herd and the closure to non-Federally qualified users for Chisana Caribou herd for conservation concerns.

EASTERN INTERIOR ALASKA SUBSISTENCE REGIONAL ADVISORY COUNCIL RECOMMENDATIONS

The Council voted unanimously to maintain the status quo and reconsider when more information on movements, degree of mixing with other caribou herds, particularly the Nelchina Caribou Herd, and population status is available in the future. Ten collars were placed on caribou in the Mentasta Caribou Herd during the fall of 2018 and more (≈ 15) are scheduled for deployment during the fall of 2019.

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 45 Federal Wildlife Closure Review WCR20-42

WRITTEN PUBLIC COMMENTS

46 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting “Domino Effect” Presentation t c e f f Council Meeting E o n i October 2019 m Interior Alaska Alaska Interior o D Eastern Eastern

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 47 “Domino Effect” Presentation 2 2 5 9 3 9 1 1 1 1 1 2 1 5 3 3 1 69 39 13 47 12 96 19 124 Total Grand 7 3 1 1 1 2018 1 1 13 8 1 1 2 2 4 13 10 1 1 2 1 1 2 1 1 1 1 1 2 1 1 1 1 10 10 13 5 2 7 8 8 1 138 210 238 271 276 250 192 91 3782 1 1 1 166 4 12 1 1 2 11 1 19 6 1 4 1 1 3 31 42 5 1 9 6 62 3 5 1 6 8 7 1 1 8 1 1 4 7 1 8 1 6 1 1 3 9 1 3 4 4 2 153 172 214 192 1 3 3 1 1 3 7 1 1 4 2 130 2005200620072008200920102011201220132014201520162017 2 3 1 3 1 1 1 4 2 1 2004 2 3 3 7 1 1 1 1 5 1 350 205 2003 4 2 2 1 1 6 134 2002 9 3 1 3 11 14 38 35 26 15 20 22 20 22 15 28 32 36 29 26 30 16 447 2001 7 2 3 4 2000 1 5 2 1 1999 1 6 3 1 2 1 4 5 1 3 5 32 95 65 208 1998 AK - Community ADAK AK NON RESIDENT, CITY AKUTAN AMCHITKA POINT ANCHOR ANCHORAGE ANDERSON ANGOON ANIAK AUKE BAY BETHEL BIG LAKE BIRCHWOOD BIRD CREEK BORDER BOUNDARY BUCKLAND BUTTE CENTRAL CHATANIKA CHENEGA BAY CHICKALOON CHICKEN CHIGNIK CHINIAK CHISANA CHITINA CHUGIAK CHULITNA = Only Harvests Harvests *Reported *Reported # of # of Hunters Columns Caribou Unit 20E

48 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting “Domino Effect” Presentation % Non-Federally qualified users Unit 20E Caribou (%) Hunters % Federally qualified subsistence users 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 0.00 80.00 60.00 40.00 20.00 120.00 100.00 Non-Federally qualified users Unit 20E Caribou (#) Hunters Federally qualified subsistence users 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 0 500 2500 2000 1500 1000

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 49 “Domino Effect” Presentation

50 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting “Domino Effect” Presentation

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 51 “Domino Effect” Presentation

52 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting “Domino Effect” Presentation

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 53 “Domino Effect” Presentation

54 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting “Domino Effect” Presentation

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 55 Federal Subsistence Board 805(c) Report to the Council Federal Subsistence Board USDA 1011 East Tudor Road, MS 121 Anchorage, Alaska 99503 - 6199

FISII 11nd WILULIFE SERVICE FOREST SERVICE IIUREAU of LAND MANAGEI\IENT NATIONAL PARK SEIWICE IIUREAlJ of INUIAN AFFAIRS

OSM 19037 KW JUN 19 2019

Susan L. Entsminger, Chair Eastern Interior Alaska Subsistence Regional Advisory Council c/o Officeof Subsistence Management 1011 E. Tudor Road, M/S 121 Anchorage, Alaska 99503-6199

Dear Ms. Entsminger,

The Federal Subsistence Board (Board) met on April 15-18, 2019 regarding proposed changes to subsistence fishand shellfishregulations. This letter and the enclosed report identify action taken on proposals affectingresidents of the Eastern Interior Region.

Section 805(c) of the Alaska National Interest Lands Conservation Act (ANILCA) provides that the Board will accept the recommendations of a Regional Advisory Council regarding take unless (1) the recommendation is not supported by substantial evidence, (2) the recommendation violates recognized principles of fishand wildlife management, or (3) adopting the recommendation would be detrimental to the satisfactionof subsistence needs. When a Council's recommendation is not adopted, the Board is required by Secretarial regulations to set forththe factualbasis and reasons forthe decision. This letter and enclosure satisfy that requirement.

Out of twenty proposals submitted, one was withdrawn by a proponent and the Board accepted the majority recommendations of the Regional Advisory Councils, in whole or with modifications, on 18 of the 19 proposals. Details of these actions and the Boards' deliberations are contained in the meeting transcriptions. Copies of the transcripts may be obtained by calling toll freenumber, 1- 800-478-1456, and are available online at the Federal Subsistence Management Program website, https://www.doi.gov/subsistence.

The Board uses a consensus agenda on those proposals where there is agreement among the affectedSubsistence Regional Advisory Council(s), a majority of the Interagency Staff Committee, and the Alaska Department of Fish and Game concerninga proposed regulatory action. These proposals were deemed non-controversial and did not require a separate discussion. The consensus agenda contained six proposals affectingthe Eastern Interior Region,

56 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Federal Subsistence Board 805(c) Report to the Council

Federal Subsistence Board Entsminger 2 USDA which the Board deferred to the Eastern Interior Alaska Subsistence Regional Advisory Council 1011 East Tudor Road, MS 121 (Council) recommendation as follows: the Board rejected fisheries proposal to modify Anchorage, Alaska 99503 - 6199 closures to subsistence salmon fishing before the commercial season opening in Yukon River FISII 11nd WILULIFE SERVICE FOREST SERVICE Districts, rejected to modify closures to subsistence salmon fishingbefore, during, IIUREAU of LAND MANAGEI\IENT NATIONAL PARK SEIWICE and after commercial openings in Yukon River Districts l, 2, and 3; and to protect the IIUREAlJ of INUIAN AFFAIRS first pulse of Chinook Salmon in Federal waters of Yukon River Districts l through 5; adopted JUN 19 2019 fisheriesproposal to move the requirement to check fishwheels from fish wheel owners OSM 19037 KW to fishwheel operators:, and adopted with OSM modificationsfisheries proposals to remove restrictions requiring fin-clippingof subsistence caught Chinook Salmon in Lower Yukon River Districts l, 2, and 3 and to add dip net as a gear type forsubsistence harvest of salmon forthe Yukon River.

Susan L. Entsminger, Chair The remaining two proposals affectingthe Eastern Interior Region appeared on the non-consensus Eastern Interior Alaska Subsistence Regional Advisory Council agenda. Proposals clarified gear usage for the Upper Copper River District subsistence c/o Officeof Subsistence Management salmon fishingpermits and consistent with the Council's recommendations, the Board adopted it. 1011 E. Tudor Road, M/S 121 However, the Board differed fromthe Council's recommendation to oppose proposal to Anchorage, Alaska 99503-6199 allow use of gillnets and rescind net depth restrictions in Yukon River Sub-Districts 4B and 4C and adopted it with a modification presented by the USFWS Board member. The Board's action Dear Ms. Entsminger, is discussed in the enclosed report.

The Federal Subsistence Board (Board) met on April 15-18, 2019 regarding proposed changes to The Federal Subsistence Board appreciates the Eastern Interior Alaska Subsistence Regional subsistence fishand shellfishregulations. This letter and the enclosed report identify action taken Advisory Council's active involvement in and diligence with the regulatory process. The ten on proposals affectingresidents of the Eastern Interior Region. Regional Advisory Councils continue to be the foundationof the Federal Subsistence Management Program, and the stewardship shown by the Regional Advisory Council chairs and Section 805(c) of the Alaska National Interest Lands Conservation Act (ANILCA) provides that their representatives at the Board meeting is always, truly appreciated. the Board will accept the recommendations of a Regional Advisory Council regarding take unless (1) the recommendation is not supported by substantial evidence, (2) the recommendation violates If you have any questions regarding the summary of the Board's actions, please contact recognized principles of fishand wildlife management, or (3) adopting the recommendation would Katerina "Katya" Wessels, Council Coordinator, at 1-907-786-3885 or be detrimental to the satisfactionof subsistence needs. When a Council's recommendation is not [email protected]. adopted, the Board is required by Secretarial regulations to set forththe factualbasis and reasons forthe decision. This letter and enclosure satisfy that requirement. Sincerely, Out of twenty proposals submitted, one was withdrawn by a proponent and the Board accepted the FPl 9-02 majority recommendations of the Regional Advisory Councils, in whole or with modifications, on 18 of the 19 proposals. Details of these actions and the Boards' deliberations are contained in the FP19-03/04 �Cb=-Anthony Christianson, Chair meeting transcriptions. Copies of the transcripts may be obtained by calling toll freenumber, 1- Federal Subsistence BoardFPl 9-06 800-478-1456, and are available online at the Federal Subsistence Management Program website, https://www.doi.gov/subsistence. Enclosure FP19-15 FP19-05 The Board uses a consensus agenda on those proposals where there is agreement among the affectedSubsistence Regional Advisory Council(s), a majority of the Interagency Staff FP19-07 Committee, and the Alaska Department of Fish and Game concerninga proposed regulatory action. These proposals were deemed non-controversial and did not require a separate discussion. The consensus agenda contained six proposals affectingthe Eastern Interior Region, FP19-16

FP19-01 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 57 Federal Subsistence Board 805(c) Report to the Council

Entsminger 3

cc: Federal Subsistence Board Eastern Interior Subsistence Regional Advisory Council members Thomas Doolittle, Acting Assistant Regional Director, Office of Subsistence Management FEDERAL SUBSISTENCE BOARD 805(c) REPORT Jennifer Harding, PhD, Acting Deputy Assistant RegionalDirector, Office ofSubsistence Management April 15-18, 2019 George Pappas, State Subsistence Liaison, Office of Subsistence Management Anchorage, Alaska Greg Risdahl, Fisheries Division Supervisor, Officeof Subsistence Management Katerina Wessels, Acting Council CoordinationDivision Supervisor, Officeof Subsistence Management Section 805(c) of the Alaska National Interest Lands Conservation Act provides that the Interagency StaffCommit tee "Secretary ... shall consider the report and recommendations of the regional advisory councils Administrative Record concerning the taking of fish and wildlife on the public lands within their respective regions for subsistence uses." The Secretary has delegated authority to issue regulations forthe take of fish and wildlife to the Federal Subsistence Board. Pursuant to this language in Section 805(c), the Board defers to the Council's recommendations. However, Section 805(c) also provides that the Board "may choose not to followany recommendations which [it] determines is not supported by substantial evidence, violates recognized principles of fishand wildlifeconservation, or would be detrimental to the satisfactionof subsistence needs." The purpose of this report is to detail how the Board's action differed fromthe Council's recommendations based on these criteria.

YUKON-NORTHERN AREA PROPOSALS

Proposal FP19-01: to allow use of gillncts and rescind net depth restrictions in Yukon River Sub-Districts 4B and 4C

DESCRIPTION: Proposal FP19-01 requests an expansion of the area and fishing time forthe Federal subsistence driftgillnet fisheryin Subdistricts 4B and 4C of the Yukon/Northern Federal Subsistence Fishery Management Area. The proponent also requests repealing the maximum mesh depth restriction of 35 meshes fordrift gill nets used in Subdistricts 4B and 4C in the fishery. Submitted by Jack Reakoff.

COUNCIL RECOMMENDATIONS: Eastern InteriorAlaska Subsistence Regional Advisory Council - Opposed Yukon-Kuskokwim Delta Subsistence Regional Advisory Council - Supported Western Interior Alaska Subsistence Regional Advisory Council - Supported Seward Peninsula Subsistence Regional Advisory Council - Supported

BOARD ACTION: Adopt with modification as presented by the USFWS Board member

Modification: to mirror the liberalization of the Yukon River drainage salmon fisheriesin District 4 enacted by the Alaska Board of Fisheries in January of 2019. This includes allowing driftgillnet fishing forsalmon in all of District 4 and removing season dates so it is legal to harvest all salmon species with driftgillnets in this area. This also includes the removal of the net mesh depth restriction of 35 meshes currently in Federal regulations but absent from State regulations in this district.

1

58 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Federal Subsistence Board 805(c) Report to the Council

Entsminger 3 cc: Federal Subsistence Board Eastern Interior Subsistence Regional Advisory Council members Thomas Doolittle, Acting Assistant Regional Director, Office of Subsistence Management FEDERAL SUBSISTENCE BOARD 805(c) REPORT Jennifer Harding, PhD, Acting Deputy Assistant RegionalDirector, Office ofSubsistence Management April 15-18, 2019 George Pappas, State Subsistence Liaison, Office of Subsistence Management Anchorage, Alaska Greg Risdahl, Fisheries Division Supervisor, Officeof Subsistence Management Katerina Wessels, Acting Council CoordinationDivision Supervisor, Officeof Subsistence Management Section 805(c) of the Alaska National Interest Lands Conservation Act provides that the Interagency StaffCommit tee "Secretary ... shall consider the report and recommendations of the regional advisory councils Administrative Record concerning the taking of fish and wildlife on the public lands within their respective regions for subsistence uses." The Secretary has delegated authority to issue regulations forthe take of fish and wildlife to the Federal Subsistence Board. Pursuant to this language in Section 805(c), the Board defers to the Council's recommendations. However, Section 805(c) also provides that the Board "may choose not to followany recommendations which [it] determines is not supported by substantial evidence, violates recognized principles of fishand wildlifeconservation, or would be detrimental to the satisfactionof subsistence needs." The purpose of this report is to detail how the Board's action differed fromthe Council's recommendations based on these criteria.

YUKON-NORTHERN AREA PROPOSALS

Proposal FP19-01: to allow use of gillncts and rescind net depth restrictions in Yukon River Sub-Districts 4B and 4C

DESCRIPTION: Proposal FP19-01 requests an expansion of the area and fishing time forthe Federal subsistence driftgillnet fisheryin Subdistricts 4B and 4C of the Yukon/Northern Federal Subsistence Fishery Management Area. The proponent also requests repealing the maximum mesh depth restriction of 35 meshes fordrift gill nets used in Subdistricts 4B and 4C in the fishery. Submitted by Jack Reakoff.

COUNCIL RECOMMENDATIONS: Eastern InteriorAlaska Subsistence Regional Advisory Council - Opposed Yukon-Kuskokwim Delta Subsistence Regional Advisory Council - Supported Western Interior Alaska Subsistence Regional Advisory Council - Supported Seward Peninsula Subsistence Regional Advisory Council - Supported

BOARD ACTION: Adopt with modification as presented by the USFWS Board member

Modification: to mirror the liberalization of the Yukon River drainage salmon fisheriesin District 4 enacted by the Alaska Board of Fisheries in January of 2019. This includes allowing driftgillnet fishing forsalmon in all of District 4 and removing season dates so it is legal to harvest all salmon species with driftgillnets in this area. This also includes the removal of the net mesh depth restriction of 35 meshes currently in Federal regulations but absent from State regulations in this district.

1

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 59 Federal Subsistence Board 805(c) Report to the Council

JUSTIFICATION: Adopting this modifiedproposal would insure that Federal regulations are not more restrictive than State regulations forthis fisheryand will also fullyalign State and Federal regulations pertaining to drift gill netting of salmon in District 4 of the Yukon northern fishery management area.

This modifiedproposal will increase the efficiencyand opportunity for Federally-qualified subsistence users to harvest salmon and will have minimal biological impacts. The modified language does not prevent the managers fromspecifying mesh size to target differentsalmon species, which is important for salmon conservation. Potential conservation concerns for salmon expressed by the Eastern Interior Regional Advisory Council can be addressed via restrictions implemented by the in-season management if required. This would align State and Federal regulations, which is helpfulto reduce confusionfor user groups and, finally, the proposal supports the position of the Western Interior, the Yukon Delta and the Seward Peninsula Regional Advisory Councils.

2

60 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Presentation Procedure for Federal Wildlife Proposals

Presentation Procedure for Proposals

1. Introduction and presentation of analysis 2. Report on Board Consultations: a. Tribes; b. ANCSA Corporations 3. Agency Comments: a. ADF&G; b. Federal; c. Tribal 4. Advisory Group Comments: a. Other Regional Council(s); b. Fish and Game Advisory Committees; c. Subsistence Resource Commissions 5. Summary of written public comments 6. Public testimony 7. Regional Council recommendation (motion to adopt) 8. Discussion/Justification  Is the recommendation consistent with established fish or wildlife management principles?  Is the recommendation supported by substantial evidence such as biological and traditional ecological knowledge?  Will the recommendation be beneficial or detrimental to subsistence needs and uses?  If a closure is involved, is closure necessary for conservation of healthy fish or wildlife populations, or is closure necessary to ensure continued subsistence uses?  Discuss what other relevant factors are mentioned in OSM analysis 9. Restate final motion for the record, vote

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 61 Wildlife Proposal WP20-48 DRAFT Staff Analysis

WP20–48 Executive Summary Wildlife Proposal WP20-48 requests alignment of Federal and State General Description regulations for the Fortymile Caribou Herd and expanding the delegated authority of the BLM Eastern Interior Field Office manager. Submitted by: Bureau of Land Management, Eastern Interior Field Office.

Proposed Regulation Unit 20E−Caribou

Unit 20E—1 up to 3 caribou, to be announced, Aug. 10-Sept. 30 by a joint State/Federal registration permit. Fall season between Aug. 1 and Sept. 30, to During the Aug. 10-Sep. 30 season, the harvest be announced. is restricted to 1 bull. The harvest quota for the

period Aug. 10-29 in Units 20E, 20F, and 25C is 100 caribou. During the Nov. 1-Mar. 31 Nov. 1-Mar. 31. season, area closures or hunt restrictions may Winter season be announced when Nelchina caribou are between Oct. 21 present in a mix of more than 1 Nelchina and Mar. 31, to caribou to 15 Fortymile caribou, except when be announced. the number of caribou present is low enough that fewer than 50 Nelchina caribou will be harvested regardless of the mixing ratio for the two herds

Unit 20F--Caribou

Unit 20F east of the Dalton Highway and south Aug. 10-Sept. 30 of the Yukon River—1 up to 3 caribou, to be Fall season announced, by a joint State/Federal between Aug. 1 registration permit. and Sept. 30, to be announced.

During the Aug. 10 - Sept. 30 season, the Nov. 1-Mar. 31. harvest is restricted to 1 bull. The harvest quota for the period Aug. 10 - 29 in Units 20E, 20F, Winter season and 25C, is 100 caribou. between Oct. 21 and Mar. 31, to be announced.

62 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting

Wildlife Proposal WP20-48 DRAFT Staff Analysis

WP20–48 Executive Summary Unit 25C—Caribou

Unit 25C—1 up to 3 caribou, to be announced, Aug. 10-Sept. 30 by a joint Federal/State registration permit. Fall season between Aug. 1 and Sept. 30, to During the Aug. 10 - Sept. 30 season the harvest be announced. is restricted to 1 bull. The harvest quota

between Aug. 10 - 29 in Units 20E, 20F, and Nov. 1-Mar. 31. 25C is 100 caribou. Winter season between Oct. 21 and Mar. 31, to be announced.

This language would be issued to the in-season manager (BLM Eastern Interior Field Office Manager) via a delegation of authority letter and added to the table at the back of the Federal regulations handy-dandy booklet:

For Units 25C, 20E, 20F – Caribou: Open and close seasons and set harvest limits, including any sex restrictions.

OSM Preliminary Conclusion Support Proposal WP20-48.

Eastern Interior Alaska Subsistence Regional Advisory Council Recommendation

Interagency Staff Committee Comments

ADF&G Comments

Written Public Comments None

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 63

Wildlife Proposal WP20-48 DRAFT Staff Analysis

DRAFT STAFF ANALYSIS WP20-48

ISSUES

Wildlife Proposal WP20-48, submitted by the Bureau of Land Management (BLM), Eastern Interior Field Office, requests alignment of Federal and State regulations for the Fortymile Caribou Herd and expanding the delegated authority of the BLM Eastern Interior Field Office manager.

DISCUSSION

Harvest of Fortymile caribou in Units 20E, 25C, and a portion of Unit 20F is managed through a joint State/Federal registration permit. The proponent states Federal regulations in these units are currently more restrictive than State regulations resulting in confusion among hunters. The proponent’s intent is to align and adapt Federal regulations with State regulations, which can change frequently, to increase opportunity for Federally qualified subsistence users and reduce regulatory complexity and user confusion. The proponent states this proposal would also provide the flexibility and responsiveness needed to manage the rapidly increasing Fortymile Caribou Herd (FCH), which may be reaching carrying capacity.

The BLM Eastern Interior Field Office manager currently has delegated authority to modify or restrict harvest limits and season dates for caribou in Unit 20E and 25C. This proposal requests adding authority to set sex restrictions in these units and delegating authority to modify harvest limits, season dates, and set sex restrictions for a portion of Unit 20F.

Existing Federal Regulation

Unit 20E−Caribou This is blank

Unit 20E—1 caribou; a joint State/Federal registration permit is required. Aug. 10-Sept. 30

During the Aug. 10-Sep. 30 season, the harvest is restricted to 1 bull. The Nov. 1-Mar. 31. harvest quota for the period Aug. 10-29 in Units 20E, 20F, and 25C is 100 caribou. During the Nov. 1-Mar. 31 season, area closures or hunt restrictions may be announced when Nelchina caribou are present in a mix of more than 1 Nelchina caribou to 15 Fortymile caribou, except when the number of caribou present is low enough that fewer than 50 Nelchina caribou will be harvested regardless of the mixing ratio for the two herds.

64 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting

Wildlife Proposal WP20-48 DRAFT Staff Analysis

Unit 20F--Caribou

Unit 20F east of the Dalton Highway and south of the Yukon River—1 Aug. 10-Sept. 30 caribou; a joint State/Federal registration permit is required. Nov. 1-Mar. 31. During the Aug. 10 - Sept. 30 season, the harvest is restricted to 1 bull. The harvest quota for the period Aug. 10 - 29 in Units 20E, 20F, and 25C, is 100 caribou.

Unit 25C—Caribou

Unit 25C—1 caribou; a joint Federal/State registration permit is required. Aug. 10-Sept. 30

During the Aug. 10 - Sept. 30 season, the harvest is restricted to 1 bull. The Nov. 1-Mar. 31. harvest quota between Aug. 10 - 29 in Units 20E, 20F, and 25C is 100 caribou.

Proposed Federal Regulation Unit 20E−Caribou This is blank

Unit 20E—1 up to 3 caribou, to be announced, by a joint State/Federal Aug. 10-Sept. 30 registration permit. Fall season between Aug. 1 During the Aug. 10-Sep. 30 season, the harvest is restricted to 1 bull. The and Sept. 30, to harvest quota for the period Aug. 10-29 in Units 20E, 20F, and 25C is 100 be announced. caribou. During the Nov. 1-Mar. 31 season, area closures or hunt restrictions may be announced when Nelchina caribou are present in a mix of more than 1 Nov. 1-Mar. 31. Nelchina caribou to 15 Fortymile caribou, except when the number of Winter season caribou present is low enough that fewer than 50 Nelchina caribou will be between Oct. 21 harvested regardless of the mixing ratio for the two herds and Mar. 31, to be announced.

Unit 20F--Caribou

Unit 20F east of the Dalton Highway and south of the Yukon River—1 up to 3 Aug. 10-Sept. 30 caribou, to be announced, by a joint State/Federal registration permit. Fall season between Aug. 1 During the Aug. 10 - Sept. 30 season, the harvest is restricted to 1 bull. The and Sept. 30, to harvest quota for the period Aug. 10 - 29 in Units 20E, 20F, and 25C, is 100 be announced. caribou. Nov. 1-Mar. 31. Winter season between Oct. 21 and Mar. 31, to be announced.

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 65

Wildlife Proposal WP20-48 DRAFT Staff Analysis

Unit 25C—Caribou

Unit 25C—1 up to 3 caribou, to be announced, by a joint Federal/State Aug. 10-Sept. 30 registration permit. Fall season between Aug. 1 During the Aug. 10 - Sept. 30 season the harvest is restricted to 1 bull. The and Sept. 30, to harvest quota between Aug. 10 - 29 in Units 20E, 20F, and 25C is 100 be announced. caribou. Nov. 1-Mar. 31. Winter season between Oct. 21 and Mar. 31, to be announced.

This language would be issued to the in-season manager (BLM Eastern Interior Field Office Manager) via a delegation of authority letter and added to the table at the back of the Federal regulations handy-dandy booklet:

For Units 25C, 20E, 20F – Caribou: Open and close seasons and set harvest limits, including any sex restrictions.

Existing State Regulation

Note: State regulations for the FCH change annually within the sideboards of the codified regulations. The codified regulations are included in this analysis because the proponent requests aligning Federal regulations with the State’s codified regulation.

Codified Regulations (5 AAC 85.025) This is blank

Unit 20E−Caribou

Residents – 1 caribou per lifetime by youth drawing permit only; up to 30 Aug. 1-Aug. 21 total permits may be issued OR Residents – up to 3 caribou by registration permit only Aug. 1-Sep. 30 OR Oct. 21-Mar. 31 Residents – 1 caribou by registration permit only, during a season for up to Season to be three days that may be announced by emergency order within a portion of the announced by area during the period Oct. 20-Nov. 30. emergency order OR Residents – 1 caribou by targeted permit only, during a season that may be Season to be announced by emergency order within a portion of the area during Dec. announced by 1-Mar. 31 emergency order.

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Nonresidents – 1 caribou per lifetime by youth drawing permit only; up to 30 Aug. 1-Aug. 21 total permits may be issued OR Nonresidents – 1 bull by registration permit only. Aug. 10-Sep. 30

Unit 20F--Caribou

Units 20(B) and 20F, those portions south of the Yukon River, and north and east of a line formed by the Richardson Highway from the Unit 20(D) boundary to its intersection with the Steese Highway, north along the Steese Highway to its intersection with the Elliot Highway, then northwest along the Elliot Highway to its intersection with the Dalton Highway, then north along the Dalton Highway to the Yukon River. Residents – 1 caribou per lifetime by youth drawing permit only; up to 30 Aug. 1-Aug. 21 total permits may be issued OR Residents – up to 3 caribou by registration permit only Aug. 1-Sep. 30 OR Oct. 21-Mar. 31 Residents – 1 caribou by targeted permit only, during a season that may be Season to be announced by emergency order within a portion of the area during Dec. announced by 1-Mar. 31 emergency order

Nonresidents – 1 caribou per lifetime by youth drawing permit only; up to 30 Aug. 1-Aug. 21 total permits may be issued OR Nonresidents – 1 bull by registration permit only. Aug. 10-Sep. 30

Unit 25C--Caribou

Residents – 1 caribou per lifetime by youth drawing permit only; up to 30 Aug. 1-Aug. 21 total permits may be issued OR Residents – up to 3 caribou by registration permit only Aug. 1-Sep. 30 OR Oct. 21-Mar. 31 Residents – 1 caribou by targeted permit only, during a season that may be Season to be announced by emergency order within a portion of the area during Dec. announced by 1-Mar. 31 emergency order

Nonresidents – 1 caribou per lifetime by youth drawing permit only; up to 30 Aug. 1-Aug. 21 total permits may be issued OR Nonresidents – 1 bull by registration permit only. Aug. 10-Sep. 30

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2019/20 Regulations This is blank

Unit 20E−Caribou

Residents – 1 caribou per lifetime, youth hunt by permit only YC831* Aug. 1-Aug. 21 OR Residents – 1 caribou by permit. May not possess RM865 at the RC860 Aug. 11-Sep. 30 same time as RC860. OR Residents – 1 caribou by permit RC867 Oct. 27-Mar. 31

Residents – 1 caribou by permit AC999 May be announced

Nonresidents – 1 caribou per lifetime, youth hunt by permit only YC831* Aug. 1-Aug. 21 OR Nonresidents – 1 bull by permit. May not possess RM865 at the RC860 Aug. 11-Sep. 30 same time as RC860.

Unit 20F--Caribou

Unit 20F east of the Dalton Highway and south of the Yukon River Residents – 1 caribou by permit. RC860 Aug. 11-Sep. 30 OR Residents – 1 caribou by permit RC867 Oct. 27-Mar. 31

Nonresidents – 1 bull by permit RC860 Aug. 11-Sep. 30

Unit 25C--Caribou

Residents – 1 caribou per lifetime, youth hunt by permit only YC831* Aug. 1-Aug. 21 OR Residents – 1 caribou by permit. RC860 Aug. 11-Sep. 30 OR Residents – 1 caribou by permit RC867 Oct. 27-Mar. 31

Residents – 1 caribou by permit AC999 May be announced

Nonresidents – 1 caribou per lifetime, youth hunt by permit only YC831* Aug. 1-Aug. 21 OR Nonresidents – 1 bull by permit. RC860 Aug. 11-Sep. 30

* The youth hunt is only open in portions of Units 20E and 25C

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Extent of Federal Public Lands/Waters

Unit 20E is comprised of 27% Federal public lands and consist of 20% National Park Service (NPS) and 7% BLM managed lands.

Unit 20F east of the Dalton highway and south of the Yukon River (Unit 20F SE) is comprised of 6% Federal public lands, which consist of 5.7% U.S. Fish and Wildlife Service (USFWS) and 0.3% BLM managed lands.

Unit 25C is comprised of 73% Federal public lands and consist of 63% BLM, 9% NPS, and 2% USFWS managed lands.

Customary and Traditional Use Determinations

Residents of Units 20D, 20E, 20F, 25, 12 (north of Wrangell-St. Elias National Preserve), Eureka, Livengood, Manley, and Minto have a customary and traditional use determination for caribou in Unit 20E and 25C.

Residents of Units 20F, 25D, and Manley Hot Springs have a customary and traditional use determination for caribou in Unit 20F.

Regulatory History

Since the inception of the Federal Subsistence Management Program in 1990, Unit 20E and 25C caribou hunting regulations have targeted the FCH and often coincided whereas Unit 20F SE regulations targeted the White Mountain Herd until 2012 when the FCH expanded its range into that hunt area.

In 1990, Federal regulations were adopted from State regulations. Unit 20E consisted of two hunt areas. Both had seasons from Aug. 10-Sept. 30 and Dec. 1-Feb. 28 with a one caribou harvest limit. Unit 20F remainder (of which Unit 20F SE was then a part), had a caribou season from Aug. 10-Sept. 30 with a one bull harvest limit. Unit 25C had caribou seasons from Aug. 10-Sept. 20 and Feb. 15-Mar. 15 with a one bull harvest limit.

In 1994, the Federal Subsistence Board (Board) adopted Proposal P94-73 with modification to create a unified regulation for the Fortymile caribou herd in Units 20E and 25C southeast of the Steese Highway. Specifically, the Board combined the Unit 20E hunt areas, changing the harvest limit to one bull by Federal registration permit. The Board separated Unit 25C into two hunt areas: Unit 25C southeast and Unit 25C northwest of the Steese highway. Caribou seasons and harvest limits for the Unit 25C southeast hunt area were directed at the FCH and mirrored those for Unit 20E. The Board also determined that harvest quotas for the FCH would be announced annually in coordination with the Alaska Department of Fish and Game (ADF&G) to help recover the caribou population.

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Also in 1994, the Board adopted Proposal P94-74 to close the caribou season in Unit 20F south of the Yukon River to protect the White Mountain Caribou Herd. This change modified hunt area descriptors, resulting in Unit 20F SE becoming part of Unit 20F south of the Yukon River in 1994.

In 1995, the FCH Harvest Management Coalition (Coalition) formed to develop recommendations for managing the herd. Representatives from seven Fish and Game Advisory Committees (ACs), the Eastern Interior Alaska Subsistence Regional Advisory Council (Eastern Interior Council), the Yukon Fish and Wildlife Management Board, the Yukon government, and Tr’ondek Hwech’in (First Nation) comprise the Coalition. Staff from BLM, NPS, USFWS, Office of Subsistence Management (OSM), and ADF&G provide technical support. The Coalition completed a Fortymile Caribou Herd Management Plan in 1995, which guided FCH management from 1995-2000 (HMC 2012). The plan recommended establishing a harvest quota of 150 bulls per year (HMC 2012).

Also in 1995, the Board adopted Proposal P95-56 with modification to change Unit 20E winter season dates from Dec. 1-Feb. 28 to Nov. 15-Feb. 28 to provide additional subsistence harvest opportunity. The Board and the Alaska Board of Game (BOG) also established a harvest quota of 150 caribou as recommended by the FCH Management Plan (HMC 2012). This specific quota was not reflected in Unit 25C southeast Federal regulations.

In 1996, the Board adopted Proposal P96-60 with modification to open a season in Unit 20F south of the Yukon River to provide additional subsistence harvest opportunity. Season dates were Dec. 1-Dec. 31 with a one caribou harvest limit.

In 1999, the BOG changed the fall harvest allocations of the FCH for Units 20D (no Federal lands), 20E, and 25C. Units 20D, 20E, and 25C received allocations of 15 bulls, 55 bulls and 30 bulls, respectively, for a total fall harvest allocation of 100 bulls. The combined fall and winter State/Federal harvest quota remained 150 bulls.

In 1999, the Board adopted Proposal P99-55 with modification to specify fall harvest quotas for Unit 20E (55 bulls) and 25C southeast (30 bulls) to align with the recently adopted State regulations and to abide by the FCH Management Plan. The Board delegated authority to the BLM Eastern Interior field office manager to announce season closures after consultation with the NPS and ADF&G.

From 1999-2001, the Coalition updated the FCH Management Plan in response to a growing herd. The plan recommended increasing harvest quotas to expand harvest opportunities. The BOG and the Board both endorsed the plan, adopting higher harvest quotas (HMC 2012). The fall State/Federal harvest quota increased to 320 caribou in Unit 20E and 225 caribou in Unit 25C remainder. The combined harvest quotas for the winter season in these units was 210 caribou.

In 2001, the Board adopted Proposals WP01-38 with modification and WP01-40 to liberalize caribou hunting regulations in Units 20E and 25C due to increases in the FCH. Unit 25C southeast became part of Unit 25C remainder. The Board extended the winter season in Units 20E and 25C remainder from Nov. 15-Feb. 28 to Nov. 1-Feb. 28 and changed the harvest limit from one bull to one caribou. The Board also increased harvest quotas as described above.

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Also in 2001, the Board adopted Proposal WP01-37, modifying caribou hunting regulations in Unit 20F to align with recently adopted State regulations, reduce user confusion, and provide additional subsistence harvest opportunity. Unit 20F south of the Yukon River became Unit 20F, east of the Dalton Highway and south of the Yukon River (Unit 20F SE). The season was Aug. 10-Sept. 20 and Nov. 1-Mar. 31 with a one caribou harvest limit. A State registration permit was required during the winter season.

In 2002, the Board adopted Proposal WP02-42 with modification to increase harvest quotas in Units 20E and 25C remainder to align with State harvest quotas and increase opportunity for Federally qualified subsistence users as the FCH population was increasing. The combined State/Federal harvest quotas in Unit 20E and 25C remainder increased to 900 caribou and 600 caribou, respectively. The Board also specified that area closures or hunt restrictions may be announced for Unit 20E during the winter season when Nelchina caribou are present in a mix greater than 1 Nelchina caribou:15 Fortymile caribou except when less than 50 Nelchina caribou would be harvested regardless of the mixing ratio. This was to prevent overharvest from the Nelchina Caribou Herd.

In 2004, the Board adopted Proposal WP04-79, specifying that cow caribou may be taken only from Nov. 1-Mar. 31 in Unit 20F SE to promote calf production and herd growth in the White Mountain Caribou Herd and to better align Federal and State regulations.

In 2010, the BOG adopted Proposal 14 to implement recommendations from the Coalition to mitigate safety issues associated with heavy roadside harvests. This included changing the opening date of the fall season from Aug. 10 to Aug. 29 to allow the herd to disperse away from roads, and changing the fall harvest limit to bulls-only to force hunters to more carefully identify an animal and its surrounding before shooting (HMC 2012).

Also in 2010, the Board adopted Proposal WP10-105 with modification to delegate authority to the BLM Eastern Interior field office manager to modify or restrict harvest limits, season dates, and methods and means for caribou in Units 20E and 25C via delegation of authority letter only (stricken from unit specific regulations). The Board also intended for the BLM in-season manager to consult with ADF&G, OSM, USFWS, NPS, and the Chairs of the affected Subsistence Regional Advisory Councils prior to taking any actions. Delegating authority enabled State and Federal in-season managers to work together to reduce heavy roadside harvest as the FCH population was stable but not increasing. The Board also specified that harvest in Units 20E and 25C remainder would be restricted to one bull during the fall season and that harvest between Aug. 10 and Aug. 29 would not exceed 100 caribou. The Board intended these harvest restrictions to help grow the FCH population and to ensure the overall harvest quota was not met before the State hunting season opened.

In 2012, the Board adopted Proposal WP12-74, aligning caribou seasons, harvest limits, permit requirements, and harvest quotas in Units 20E, 20F SE, and 25C, resulting in Unit 25C becoming a single hunt area. Unit 20F SE had historically been managed for the White Mountains Caribou Herd, but the FCH had expanded its range into the area. Season dates were Aug. 10-Sept. 30 and Nov. 1-Mar. 31 with a one caribou harvest limit, although during the Aug. 10-Sept. 30 season, harvest was restricted

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to one bull. The Board required a joint State/Federal registration permit in all three of the hunt areas, and specified the harvest quota from Aug. 10-29 as 100 caribou. However, Unit 20E maintained restrictions concerning the Nelchina caribou herd. These regulation changes provided more flexibility to managers, increased harvest opportunity for Federally qualified subsistence users, and supported efforts of the FCH Management Coalition, which also updated its harvest plan in 2012, effective 2012-2018 (HMC 2012).

In 2013, the BOG adopted Proposal 177 as amended to establish a targeted hunt (limited registration hunt) and a youth permit hunt for the FCH (Gross 2015). The intent of the targeted hunt was to allow a few hunters to harvest caribou along the Steese or Taylor highways when large numbers of caribou are present and the unlimited registration permit hunt (RC867) closes because the harvest quota may be exceeded (Gross 2015). The BOG established the youth hunt to provide opportunity for youth hunters in accordance with the BOG’s legal mandates (Gross 2015).

In 2018, the BOG adopted Proposal 166 with ADF&G’s modification to modify the hunt structure for the Fortymile herd, including longer seasons and higher harvest limits. ADF&G recommended modifying the State’s codified regulations by changing the opening date for the youth hunt and the resident fall registration permit hunt from Aug. 10 to Aug. 1, changing the opening date for the resident winter registration permit hunt from Dec. 1 to Oct. 21, changing the resident harvest limit from one caribou to up to three caribou, and changing the closing date for the nonresident hunt from Sept. 20 to Sept. 30 (ADF&G 2018a). These changes allow ADF&G the flexibility to annually adjust seasons and harvest limits for each zone within the season dates and harvest limits specified in the codified regulations.

Current Events Involving the Species

At the Eastern Interior Council’s winter 2019 meeting, the BLM Eastern Interior Field Office (the proponent for WP20-48) expressed intentions of also submitting a special action request for the FCH for the 2019/20 regulatory year (EIRAC 2019). The special action request would be similar to this proposal with the overall intention of aligning Federal and State regulations and expanding in-season management flexibility. Council members and BLM staff thoroughly discussed changes to Federal regulations for the FCH, and the Council voted to support the special action request and WP20-48 as presented by BLM staff during its meeting (EIRAC 2019).

The BLM Eastern Interior Field Office submitted Temporary Wildlife Special Action WSA19-06 in May 2019. During a teleconference in July 2019, the Board voted unanimously to approve WSA19-06 as it provides management flexibility to Federal managers, allowing in-season alignment of State and Federal regulations for the complex management of the FCH. The Board also noted support by the Eastern Interior Council and the State of Alaska.

Biological Background

The Coalition identified the following management objectives for the FCH (HMC 2012):  Increase the population by approximately 2-3% annually between 2012 and 2018  Increase the harvest to 1,000-4,000 annually between 2012 and 2018

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 Achieve a population of 50,000-100,000 caribou  Achieve harvest of 1,000-15,000 caribou  Manage Alaska harvest to provide at least 14 days of hunting during each of the fall and winter seasons to ensure reasonable opportunity for State and Federally qualified subsistence hunters  Manage Alaska harvest to provide at least 7 days of hunting during the fall season for nonresident hunters

State management objectives for the FCH include (Gross 2015):  Provide conditions for the FCH to grow at an annual rate of 5-10%, until population indices indicate the herd is becoming nutritionally stressed, to provide increased caribou hunting and viewing.  Manage for a herd size of 50,000-100,000 caribou, unless nutrition indices indicate a lower sustainable limit.  Manage the herd to sustain an annual harvest of 1,000-15,000 caribou.  Maintain an October bull:cow ratio of at least 35 bulls:100 cows.

The FCH’s range and distribution have expanded and contracted over time (Gross 2015). Generally, the FCH ranges across Units 20 and 25C in eastern interior Alaska as well as west-central Yukon Territories (Map 1). During the 1920s, the FCH’s range encompassed approximately 85,000 mi2 but declined to approximately 35,000 mi2 by the mid-1950s (Skoog 1956). The high 1920s estimate could have included some Nelchina and Porcupine herd caribou (Valkenburg et al. 1994). Since the 1970s, the FCH’s range has remained approximately 19,300 mi2 (Gross 2015). However, since 2001, the herd has been expanding its range, possibly because of increased herd size. In 2012, the FCH expanded into the White Mountains of Unit 20F SE, which was part of its historic range. The White Mountains herd also resides in Unit 20F, and managers anticipate that the FCH will eventually absorb the White Mountains Herd (HMC 2012). The FCH also mixes with the Nelchina herd during winter in Unit 20E (Map 1).

Similar to other caribou herds in Alaska, the FCH’s population has fluctuated over time (Gross 2015). During the 1920s, the FCH was the largest caribou herd in Alaska with an estimated population of 260,000-500,000 caribou (Gross 2015, Boertje et al. 2012). These coarse estimates may have counted some Nelchina caribou, although “the FCH was undoubtedly considerably larger in the 1920s than since that time” (Valkenburg et al. 1994, p. 17). The FCH likely attained such high and unsustainable abundance due to the unusual scarcity of wolves during that time (possibly because of diseases introduced by sled dogs) (Boertje et al. 2012). The FCH then declined during the 1930s to <20,000 caribou, likely because of reduced nutrition from overabundance and emigration (Skoog 1956, Boertje et al. 2012). By the 1950s, the herd had recovered to 50,000 caribou, remaining relatively stable throughout the 1960s. A Federal predator control program that began in 1947 likely aided herd recovery (Gross 2015).

By 1973, the FCH had declined to an estimated 5,740-8,610 caribou, likely due to high harvests, unfavorable weather, and wolf predation, resulting in contraction of its historical range. The FCH population began increasing after 1976, likely due to favorable weather conditions, reduced harvests, and

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a natural decline in wolf numbers (Valkenburg et al. 1994, Gross 2015). The FCH grew slowly during the 1980s, reaching about 20,000 caribou in 1990 (HMC 2012). The herd remained stable for several years due to low calf survival, and then continued growing from 1997-present (Figure 1) (Gross 2015, ADF&G 2018a). The substantial population increases since 1997 are attributed to intensive private wolf trapping efforts, nonlethal predator management, favorable weather conditions, and conservative harvest rates (<2% of herd size annually) (HMC 2012, Boertje et al. 2012). However, Boertje et al. (2017) concluded too few wolves were affected by wolf control efforts to have a measurable effect on FCH abundance.

ADF&G attempts annual photocensus counts of the FCH during the summer when caribou tend to be tightly aggregated. However, photocensus counts are not possible in some years due to weather, smoke from wildfires, loosely aggregated caribou, or caribou occupying areas below treeline, which obscures counting (Gross 2015, ADF&G 2019b). The most recent FCH population estimate (2017) was 71,425 caribou, which is well within management objectives and represents a 20,000 caribou increase from the last photocensus in 2010 (Figure 1) (Gross 2015, ADF&G 2018a). ADF&G suspects the FCH population remained stable in 2018 due to low reproduction and slightly above average calf mortality (EIRAC 2019).

ADF&G also conducts fall composition surveys annually to estimate calf:cow and bull:cow ratios. Between 1985 and 2018, calf:cow ratios averaged 30 calves:100 cows, ranging from 16-41 calves:100 cows (Figure 2). Over the same time period, bull:cow ratios averaged 44 bulls:100 cows, ranging from 27-59 bulls:100 cows (Figure 2) (Gross 2015, ADF&G 2019b). Bull:cow ratios met State management objectives in all years except 1989 and 2014. However, Gross (2015) attributes the lower bull:cow ratio in 2014 to uneven distribution of bulls in the herd rather than an actual change in their proportion.

Parturition (birth) rates, particularly those of 3-year-old cows, provide a useful index to assess herd nutrition (Boertje et al. 2012, 2016, Gross 2015). Caribou usually first give birth at 3-years of age, which is influenced by their weight and previous years’ nutrition (ADF&G 2019b). Thus, the fewer parturient 3-year-old cows, the more nutritionally stressed the caribou herd is likely to be. Boertje et al. (2012) determined a 5-year moving average of 3-year-old cow parturition rates of <55% as a threshold for indicating nutritional stress, potential overgrazing, and justification for liberalizing harvests. However, liberalizing harvest because of low parturition rates is only justifiable when a caribou herd is increasing (Boertje et al. 2012). Annual fluctuations in parturition rates may also be explained by changes in distribution. However, Boertje et al. (2012) also cautions that low parturition rates could occasionally result from extended adverse weather rather than overgrazing.

ADF&G measures parturition rates by tracking known-aged radio-collared cows (ADF&G 2018b). Between 1997 and 2018, the 5-year moving average of 3-year-old cow parturition rates (parturition rate) in the FCH has declined substantially (Figure 3). Peaking at 94% in 2000, the FCH parturition rate declined to 66% in 2005, then remained fairly stable until 2011. Since 2011, the parturition rate has hovered around the 55% threshold, dipping below it in 2016 and 2018, indicating nutritional stress is affecting the FCH (Figure 3) (Gross 2015, ADF&G 2019b).

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Additionally, Boertje et al. (2012) note changes in the FCH’s distribution between 1990 and 2010, suggesting the FCH may be overgrazing its core summer habitat. (The FCH forage mostly in tundra in the summer and in taiga in the winter). For example, during the summer of 2008, the FCH moved into spruce-moss taiga rather than onto its usual upland tundra. They also note the FCH’s rapid range expansion may indicate localized overgrazing of previously used habitats. Widespread overgrazing of summer range may be the single factor most likely to cause a pronounced and prolonged decline in caribou herd nutrition and abundance (Bergerud et al. 2008 as cited in Boertje et al. 2012). Conversely, as of 2004, the condition of the FCH’s winter range appeared in excellent condition based on analysis of fecal samples, and was likely not limiting growth of the FCH (Gross 2015).

Several studies describe wolf predation as the primary factor limiting herd growth from 1996-2000 (Boertje and Gardner 1998, 1999, 2000; Gardner 2001 as cited in Gross 2015), and Gross (2015) stated it continues to influence the FCH. Between 2004 and 2017, ADF&G conducted wolf control in Units 12, 20B, 20D, 20E, and 25C to benefit the FCH (ADF&G 2019b, Gross 2015). During this time, 1800 wolves were removed from the area, although the estimated wolf population remained relatively stable at 235-451 wolves (380 wolves in 2004 and 391 wolves in 2017) (ADF&G 2019b). ADF&G suspended the program in 2018 to evaluate the effects of predator control on the FCH and wolves in the area (ADF&G 2019b). Boertje et al. (2017) found wolf predation to be a predominant cause of FCH mortality, but concluded that herd size is likely a function of favorable nutrition and weather.

Possible land disposal by the Alaska Department of Natural Resources for residential and commercial development within key habitat and hunt areas of the FCH have raised concerns for the health of the FCH and its habitat. The Coalition recommended removing these sites from consideration (HMC 2012).

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Map 1. A F T F F

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80,000

70,000

60,000

50,000

40,000

30,000 Number Caribouof 20,000

10,000

0 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Figure 1. F ADF

70

60

50

40

30

20 Number of bulls/calves Number bulls/calves of : 100 cows 10

Bulls: 100 Cows Calves: 100 Cows 0 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Figure 2. F ADF

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100

90

80

-old cow 70

year 60

50

40

parturition rates (%) 30

20 5-year 5-year average 3-of 10

0

Figure 3. F R ADF

Cultural Knowledge and Traditional Practices

Only rural residents of the wildlife management units and/or communities described in Table 1 are eligible to harvest caribou in Units 20E, 20F, and/or 25C during Federal seasons. About 5,300 people live in these areas (Table 2).

These villages are culturally affiliated with Koyukon, Gwich’in, Han, Tanacross, and Tanana Atha- bascans. For centuries, caribou comprised a large part of the harvest of wild resources for food (Hosley 1981). Historically, large numbers of migratory caribou were available from the Porcupine, Fortymile, and other caribou herds (such as, Macomb, Nelchina, Chisana, Mentasta, White Mountain, and smaller herds in Unit 20F). Communities established more recently were originally supply sites for construc- tion of the Alaska Highway, such as, Northway Junction and Tok; mining operations, such as, Eagle City and Chicken; and telegraph line maintenance, such as Manley (Hosley 1981).

Subsistence users search for caribou in areas they can access based on means available to them, such as, on foot or using highway vehicles, off-road vehicles, boats, or airplanes. Subsistence users harvest caribou year round. Years when herds migrate near villages, harvests of caribou by residents of these villages increase. When caribou do not migrate locally, caribou harvests decrease, and people sometimes travel great distances searching for caribou.

The focus on recent community hunting patterns on Federal public lands in Units 20E, 20F, and 25C is based on readily available sources. For example, subsistence users accessing caribou search areas by way of the Taylor Highway in Unit 20E can access Federal public lands, for example, in the Fortymile Wild and Scenic River conservation unit. It is important to understand that the collapse of the FCH

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However, as herd migrations has become increasingly unpredictable, fewer subsistence users report traveling long distances to harvest caribou as in the past (Caulfield 1983, Godduhn and Kostick 2016, Van Lanen et al. 2012). For example, in Northway, caribou were absent from the immediate vicinity for decades following declines that occurred around 1935. Northway’s access to caribou was extremely limited until the Alaska Highway was improved and local residents acquired cars and trucks. Some travelled north on the Taylor Highway (in Unit 20E) in search of caribou in the 1950s and 1960s. Generally, Northway residents no longer go up the Taylor Highway in pursuit of caribou due to the large number of nonlocal hunters and Northway residents’ low hunting success. Northway residents have said their use of caribou has declined for several reasons. Annual harvest limits have decreased from three to one caribou annually, and competition with nonlocal harvesters has increased. Consequently, Northway residents report having grown accustomed to eating moose (Godduhn and Kostick 2016). Northway residents’ comments during recent research included “Keep guided hunts away from Native communities. Limit or ban them because they take all the resources. Local only hunts. Lots of outsiders hunting” (Godduhn and Kostick 2016:108).

Tetlin residents have observed increasing hunting pressure in the vicinity of their community (in Unit 12). In the 1980s, inadequate transportation and a limited period during which caribou were accessible along the Taylor Highway (in Unit 20E) discouraged most people in Tetlin from hunting there. Resi- dents of Tetlin primarily search for caribou in nearby areas (in Unit 12) when and if Mentasta or Nelchina herds migrate into the area (Halpin 1987).

Fewer Dot Lake residents hunt for caribou today because of difficulty accessing the Macomb Plateau Controlled Use Area (in Unit 20D) due to restrictions on motorized access. These State-managed lands are closed to any motorized vehicle use for hunting. The Macomb Plateau, adjacent to the community, has been the focus of caribou hunting for Dot Lake. Fewer Dot Lake residents have been searching for caribou along the Taylor Highway (in Unit 20E) because of crowding on the road system making it unsafe (Holen et al. 2012).

Most hunting by Tok residents is done largely along the Taylor Highway (Unit 20E) and Alaska Highway. Tok residents have expressed concern about the number of nonlocal hunters coming to the area to hunt for moose and caribou, and residents from Anchorage and Fairbanks enjoying easy road access to local hunting areas and competing with local hunters (Holen et al. 2012).

Healy Lake residents access hunting areas including up the Volkmar River into the Yukon Charley Rivers National Preserve (Unit 20E). Only small numbers of Fortymile caribou have migrated through the Healy Lake area recently (Holen et al 2012). Healy Lake is not on the road system.

Tanana residents search for several small local herds in areas including the Tanana-Allakaket Trail, Ptarmigan Creek, and Tozitna River (Unit 20F BLM lands) (Case and Halpin 1990). Residents have

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commented that too many hunters use airplanes, radios, and air boats in areas where Tanana residents hunt (Brown et al. 2004). Tanana is also not on the road system.

Gwich’in villages focused on the Porcupine caribou herd following the decline of the FCH. Since the 1970s, however, the Porcupine herd has seldom entered the Yukon Flats (in Units 25B and 25D). Porcupine caribou are more accessible to Arctic Village and Venetie residents in areas such as the Upper Chandalar River (Unit 25A). In Beaver, Stevens Village, and Birch Creek, residents no longer search for caribou and generally harvest only occasionally and opportunistically while searching for other re- sources. The Porcupine herd has started crossing the Porcupine River farther upriver, above Old Crow and into Canada, than in the past. The overall declining harvest of Porcupine caribou by Gwich’in is due to increased fuel costs and inconsistent migration patterns making caribou harder to find. The area along the Steese Highway (Unit 25C) continues to be the focus of some caribou hunting by these villages (Van Lanen 2012). Circle, at the end of the Steese Highway, is the only Gwich’in community on the road system.

Information provided by Gwich’in indicate Fortymile caribou habitat quality has diminished. For example: “In the early 1980s, the areas south and west of the community of Venetie had become ‘too brushy’ for caribou feeding habitat” (Caulfield 1983:195). “Wildfires had destroyed caribou browse and had caused caribou to shift migration patterns out of the area” (Nelson 1973:113). Additionally, traditional laws instruct hunters to allow the first group of caribou to pass unbothered in order to ensure that greater numbers of caribou follow the lead group, along the same path (Van Lanen 2012).

Villages have documented their efforts to harvest caribou in household surveys conducted with the Di- vision of Subsistence, ADF&G, as shown in Table 3 and Table 4 (ADF&G 2019). For the region as a whole, the information shows that subsistence users continue to rely on caribou. Consistently, house- holds that successfully harvest caribou share their harvests with unsuccessful households (Caulfield 1983, Godduhn and Kostick 2016, Holen et al 2012, Van Lanen et al. 2012).

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Table 1 R F

Communities with customary and traditional Unit 20E Unit 20F Unit 25C use determinations for caribou

in Units 20E, 20F, and/or 25C

D—D D D D F — F— R T A—A — — D— F — T T T

Table 2 F ADD 2010 2010 2010 2010 Unit of Number of Unit of Number Number of Community Number Community residence house- residence of house- of people holds people holds T T F R T T A A D D D D D D F F Total 5,338 2,189

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Table 3. F ADF Percentage Percentage Percentage of of Unit of Study of Community households households Residence Year households attemping to harvesting using caribou harvest caribou caribou D D D D D F R T T T T T T T D F T T T T T T T

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Table 4 F ADF

Estimated Lower Upper Per Person Unit of Study Community Harvest of Harvest Harvest Lbs Residence Year Caribou Estimate Estimate Harvested

D D D D D F R T T T T T T T D F T T T T T T T

Harvest History

The FCH is a very important herd for both consumptive and non-consumptive uses in Interior Alaska due to its road accessibility, and experiences high hunting pressure (Boertje et al. 2012, EIRAC 2019). The high public use and accessibility of this herd has resulted in a complex suite of regulations and harvest management strategies designed to manage harvest, herd growth, hunter opportunity, and safety. Due to this complexity and the need for annual adjustments in season lengths and harvest limits, Federal and State in-season managers have authority to modify or restrict season dates and harvest limits, providing management flexibility. The FCH hunt has traditionally been split into fall and winter hunts, which

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allows some nonresident harvest and for some communities to take advantage of the proximity of caribou during the winter season (HMC 2012).

From the mid-1970s through the 1980s, FCH hunting regulations were designed to benefit local hunters and to prevent harvest from limiting herd growth (HMC 2012). To that end, ADF&G deliberately timed hunting seasons to avoid periods when road crossings were likely, shifting hunters away from roads and onto trail and river systems (HMC 2012). After the Federal government assumed management of the Federal subsistence program in 1990, many people became frustrated with the sometimes conflicting dual sets of regulations and because the FCH was not growing. This led to the formation of the Coalition and development of cooperative management plans, which are endorsed by both the BOG and the Board (HMC 2012).

Since 1995, management plans developed by the Coalition have guided FCH harvest, which is primarily managed through fall and winter registration permit hunts and harvest quotas. From 1996-2000, the 1995 FCH Management Plan directed FCH harvest, which was limited to a quota of 150 bulls under a joint state-federal registration permit. This low quota was below sustainable levels to promote herd growth and intended to garner support for a nonlethal wolf control program (HMC 2012).

In both the 2001 and 2006 Harvest Plans, the Coalition recommended increasing the harvest quota from 150 bulls to 2-3% of the estimated FCH population, which was still considered conservative and allowed for continued herd growth (HMC 2012). These plans also allocated 65% of the harvest quota to Alaska and 35% to Canada, specifying that unused allocations would be re-allocated to the other country (HMC 2012). Alaska’s allocation was further divided with 75% for the fall hunt and 25% for the winter hunt. The BOG and Board adopted these recommendations. However, since 2001, no harvest occurred in Canada (HMC 2012).

Since 2004, one fall and one winter registration permit has been used for all FCH hunts, reducing user confusion and eliminating issues of multiple permits being issued to individuals wanting to hunt Fortymile caribou in more than one area (HMC 2012). From 2005-2009, Fortymile caribou became increasingly available along roads, resulting in harvest quotas being met or exceeded in 1-10 days. These short seasons precipitated crowding of hunters along roadways, raising concerns about excessive wounding loss, “flock-shooting,” hunter safety, and the overall quality of the hunt (HMC 2012). In response to these concerns, the Coalition recommended delaying opening the fall season in roaded areas, giving the herd time to disperse away from roads. The Coalition also recommended changing the fall harvest limit to bulls-only to force hunters to identify an animal more carefully before shooting.

The Coalition revised its plan again in 2012, effective 2012-2018 (HMC 2012). The 2012 Harvest Plan outlines different strategies for the FCH depending on population size. When the FCH population is below 70,000, the Coalition recommends a 3% harvest rate with bulls-only harvest during the fall season and either sex harvest during the winter season, but only 25% of total annual harvest being cows. When the FCH population exceeds 70,000 caribou, the Coalition recommends a 4% harvest rate with 3% of Alaska’s allocation being bulls-only in the fall and either sex in the winter with a maximum of 19% of total annual harvest being cows. The remaining 1% of Alaska’s allocation of the FCH population

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The 2012 Harvest Plan recommends maintaining a Federal subsistence priority by opening the Federal fall and winter seasons earlier than State seasons (HMC 2012). It recommends managing heavy hunting pressure along roadways when large numbers of caribou are present through temporary closures and openings in specified zones or through limited registration (targeted) hunts. Management tools include establishing subzones, temporary openings, delayed openings, patterned openings (e.g. Sundays through Wednesdays), distributing limited permits on a first-come, first-served basis, and establishing multiple permit periods for different hunt dates, allowing hunters to enter certain areas at specified times (HMC 2012). The Coalition has drafted an updated Harvest Management Plan, but it is not yet finalized (EIRAC 2019).

ADF&G manages State hunts for the FCH in four zones that contain portions of Units 20 and 25 (Map 2). These zones are intended to distribute harvest, so that hunters across the FCH’s range are afforded hunting opportunity (HMC 2012, Gross 2015). Zones are primarily based on historical harvest, herd migrations, and access (HMC 2012). Zone 1 is accessed via Chena Hot Spring Road and the Steese Highway. Zone 2 is accessed by plane or by boating up the Goodpaster or Salcha Rivers. Zone 3 is accessed via the Taylor Highway or the and contains a no-hunt corridor within 100 feet of the Top of the World Highway and between mileposts 75.3 and 117.2 of the Taylor Highway. Zone 4 is accessed via the Elliot and Dalton Highways and was added in 2012 because of the expansion of the FCH range into the White Mountains of Unit 20F SE where White Mountain Caribou are also present (HMC 2012).

ADF&G issues emergency orders to close and reopen State-managed hunting areas in response to caribou distribution and expected harvest and hunting pressure. Each zone has a harvest quota (recommended by the 2012 FCH Harvest Plan) and is closed when its harvest quota is met. Zone 4 includes separate harvest quotas for the FCH and the White Mountains herd (HMC 2012). Hunters must report harvest within 3 days of harvest and can call the Fortymile hotline for updated information on zone openings and closures (ADF&G 2019a). ADF&G further monitors harvest through hunters check stations and registration permit reports (Gross 2015). The State’s codified regulations provide sideboards for setting complex annual seasons and harvest limits in the various zones. The codified regulations allow regulations to be adjusted annually according to changing hunt conditions, herd size and distribution (ADF&G 2019b).

The vast majority of FCH harvest occurs in Alaska by registration permit (Figure 4). Unreported and illegal harvest of the FCH is minimal and estimated at 10 caribou/year (Gross 2015, ADF&G 2019b). Since 2000, harvest has generally increased as the FCH population and therefore harvest quotas have increased. Quotas increased from 150 bulls in the mid-1990s to over 2,000 caribou in 2018 (EIRAC 2019). Correspondingly, total FCH harvest ranged from 146 bulls in 1996 to 2,421 caribou in 2018 (Figure 4) (ADF&G 2019b, Gardner 2003).

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Nonlocal residents harvest the majority of FCH caribou. ADF&G defines local residents as residents of Unit 12 north of Wrangell-St. Elias National Park, Unit 20D, Unit 20E, and Unit 25C (Gross 2015). Between 2002 and 2017, local residents, nonlocal residents, and nonresidents accounted for 11%, 80%, and 9% of the FCH harvest, respectively (Figure 5) (Gross 2015, 2019 pers. comm.). Over the same time period, total FCH hunter numbers ranged from 2,088-4,680 hunters per year (Figure 5). The vast majority of the harvest occurs during the opening two weeks of the fall season. Harvest during the winter season is more evenly distributed throughout the season (Gross 2015).

As the FCH population now exceeds 70,000, the Coalition recommends a 4% harvest rate to allow for increased harvest opportunity and for the herd to continue growing at a reduced rate (ADF&G 2019b). ADF&G intends to slow herd growth while it’s at the mid-point of its population objective (ADF&G 2019b). While the current intention is to continue herd growth but at a slower rate, harvest quotas of 4,000 or more caribou would likely be necessary to achieve herd stabilization or reduction (EIRAC 2019). Achieving such high harvests may require allowing very high harvests along roadways, which could turn into a challenging management scenario (EIRAC 2019).

Boertje et al. (2012) suggest 6.1% may be a sustainable harvest rate for the FCH with moderate and declining nutrition, which is comparable to a 6% sustainable harvest rate for the Nelchina caribou herd with lower and increasing nutrition. Boertje et al. (2017) suggest substantially increasing harvest to curtail herd growth when caribou herds approach carrying capacity because, once ungulates overshoot carrying capacity, long-lasting negative effects on sustainable yield can occur.

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Map 2. Zones used by ADF&G to manage State caribou hunts for the Fortymile caribou herd (map from ADF&G 2018a).

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3000

Quota Registration permit harvest Total harvest

2500

2000

1500

Number Caribouof 1000

500

0

Figure 4. F T T T A ADF

5000 Local Residents Nonlocal Residents Nonresidents 4500

4000

3500

3000

2500

2000 Number Huntersof 1500

1000

500

0 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017

Figure 5. F

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Effects of the Proposal

If WP20-48 is adopted, Federal and State codified hunting regulations for the FCH will be aligned, which will reduce user confusion and preclude Federal regulations from being more restrictive than State regulations. Additionally, the authority delegated to the Federal in-season manager will be expanded, providing the flexibility required to annually adjust season dates and harvest limits in response to changing herd and hunt conditions and in coordination with State managers. Aligning State and Federal regulations for the FCH may be especially prudent due to the complexity of harvest management for this herd (e.g. hunt zones, harvest quotas, emergency closures and openings, heavy hunting pressure). Additionally, harvest management and regulations are guided by the Coalition’s FCH Harvest Plans, which both the Board and the BOG endorsed. One of the recommendations in the 2012 plan is for State and Federal managers to continue cooperatively managing FCH hunts (HMC 2012).

Furthermore, Federal regulations are currently more restrictive than State regulations, which violates the rural subsistence priority mandated by ANILCA and results in possible law enforcement concerns. For example, in Sept. 2018, the State and Federal harvest limits were one caribou and one bull, respectively. When the State closed its season, the Federal season remained open. Therefore, if Federally qualified subsistence users harvested a cow caribou (as permitted under State but not Federal regulations) on Federal public lands after the State season closed, they could have received a ticket (EIRAC 2019). Additionally, the State winter season opened Oct. 21, whereas the Federal winter season did not open until Nov. 1.

While the Eastern Interior Council voted unanimously to support this proposal at their 2019 winter meeting, Council members also expressed many concerns about FCH management and regulations with the intent of informing management and regulatory decisions. One concern was changing the opening date of the Federal fall season from Aug. 10 to Aug. 1 (EIRAC 2019). Their primary concern was that a State youth hunt occurs in early Aug., and they did not think a Federal season should interfere with the youth hunt. A Council member also expressed concern about meat care during early August as temperatures can be very warm, causing meat to spoil quickly.

Council members also expressed concerns about changing the opening date of the Federal winter season from November 1 to October 21 due to potential wanton waste from bulls being in rut and therefore unpalatable. A Council member from Central stated he found 6-7 bulls last October with just their heads missing because the caribou were too stinky from the rut. However, the Council also discussed opening the October season to cow harvest, which would help control herd growth and would avoid the rut issue (EIRAC 2019). Additionally, the ADF&G area biologist stated he spoke with many hunters last season who harvested Fortymile caribou in late October, and none said the meat was unusable. Furthermore, the Coalition recommended an opening date of October 21 because it mirrors the winter season opening date for the Nelchina herd whose bulls are mostly palatable again by late October (EIRAC 2019). Council members continued to express reservations about the early winter season opener due to the potential for inexperienced hunters to improperly process an animal, ruining its meat.

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However, whether or not the Federal fall and winter seasons for the FCH open on Aug. 1 or Oct. 21, respectively is up to the Federal in-season manager who has delegated authority to announce season openings and closures. Aligning Federal season dates with State codified regulations provides flexibility for in-season managers to manage harvest such as (for example) announcing a cow only season during late October to curtail herd growth or delaying opening the fall season until the State youth hunt ends. A Federal subsistence priority could be maintained by keeping Federal seasons open after State seasons close by emergency order because harvest quotas have been met (EIRAC 2019).

Council members were also concerned about liberalizing regulations and increasing harvest quotas because of heavy harvest pressure along the Steese and Taylor highways, which results in dangerous situations and discourages Federally qualified subsistence users from hunting. Additionally, Council members cautioned against liberalizing regulations too quickly as this could result in severe and unpopular restrictions in the future (EIRAC 2019).

Furthermore, Council members pointed out that nutritional stress may encourage the FCH to expand its range into areas the herd used historically. An expanded range could allow the herd to continue growing and potentially avoid the heavy hunting pressure along the highways that could result from liberalizing harvests (EIRAC 2019). However, the Council acknowledged population crashes in other caribou herds (e.g. Western Arctic, Central, Mulchatna) and a desire to prevent the FCH population from crashing. One Council member pointed out the Mulchatna herd crashed even though its range expanded substantially (EIRAC 2019).

While the FCH is at the mid-point of management objectives, it may have already reached or exceeded carrying capacity based on nutritional indices and peak numbers in the 1960s. The low parturition rates, changes in FCH distributions, and increasing populations suggest nutritional stress and overgrazing are affecting the FCH, recommending liberalizing harvest regulations. Boertje et al. (2017) encourages managers to increase harvest to curtail growth before the FCH reaches carrying capacity. If caribou populations exceed carrying capacity, their populations can crash with long-lasting decreases in sustained yield (Boertje et al. 2017).

Assuming these trends in declining nutrition continue, ADF&G anticipates substantial increases in harvest during the 2019/20 season (EIRAC 2019). ADF&G announced 2019/20 season dates and harvest limits for the upcoming season after it received results from spring parturition surveys and calf birth weights. Changes from 2018/19 regulations include a resident harvest limit of one caribou during August rather than one bull and opening the winter season on October 27 rather than on October 21. Adopting this proposal does not guarantee more liberal harvest regulations, but rather expands the season and harvest limit sideboards to match State codified regulations and expands the authority delegated to the in-season manager to annually adjust seasons and harvest limits as needed (in consultation with ADF&G, OSM, USFWS, NPS, and the Council Chair).

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OSM PRELIMINARY CONCLUSION

Support Proposal WP20-48.

Justification

Harvest management for the FCH is complex and primarily guided by the Coalition’s Harvest Plans, which are endorsed by the BOG and the Board. Delegating authority to the Federal in-season manager to modify season dates and harvest limits, including sex restrictions (Appendix 1) provides management flexibility to respond to annually changing herd and hunt conditions as recommended by the harvest plans and in coordination with State regulations. Aligning State codified and Federal regulations reduces user confusion and precludes Federal regulations from being more restrictive than State regulations. Rural priority for Federally qualified subsistence users could be maintained if Federal seasons remain open after State seasons close; however, this will occur at the discretion of the Federal in-season manager.

LITERATURE CITED

ADCCED (Alaska Department of Commerce, Community, and Economic Development). 2013. Community Information. Online database accessed April 22, 2013. http://www.commerce.state.ak.us/cra/DCRAExternal/community.

ADF&G. 2018. Alaska Board of Game meeting information. Central/Southwest Region: Feb. 16-23, 2018. RC4: Tab 8. http://www.adfg.alaska.gov/static/regulations/regprocess/gameboard/pdfs/2017-2018/csw/tab8.pdf. Accessed April 4, 2019.

ADF&G. 2018b. Meeting audio. Alaska Board of Game meeting information. Central/Southwest Region: Feb. 16-23, 2018. http://www.adfg.alaska.gov/static/regulations/regprocess/gameboard/swf/2017-2018/20180216_febcsw/index.ht ml?mediaBasePath=/Meeting%2002-23-18%20BOG%20%28Feb-27-18%2010-22-03%20AM%29. Accessed May 13, 2019.

ADF&G. 2019a. Caribou Hunting in Alaska. Hunting Fortymile-White Mountains Caribou. Alaska Department of Fish and Game. http://www.adfg.alaska.gov/index.cfm?adfg=caribouhunting.40mile. Accessed May 10, 2019.

ADF&G. 2019b. Annual Report to the Alaska Board of Game on Intensive Management for Fortymile Caribou with Wolf Predation Control in the Upper Yukon–Tanana Predation Control Area of Game Management Units 12, 20B, 20D, 20E and 25C. Alaska Department of Fish and Game, Division of Wildlife Conservation. http://www.adfg.alaska.gov/static/research/programs/intensivemanagement/pdfs/2019_uytpcp_intensive_manage ment_annual_report.pdf. Accessed May 13, 2019.

ADF&G. 2019c. Community Subsistence Information System. Online database, accessed May 20, 2019. ADF&G Division of Subsistence. Anchorage, AK.

Boertje, R.D., C.L. Gardner, K.A. Kellie, and B.D. Taras. 2012. Fortymile caribou herd: Increasing numbers, declining nutrition, and expanding range. Alaska Department of Fish and Game, Wildlife Technical Bulletin 14, ADF&G/DWC/WTB-2012-14, Juneau.

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Boertje, R.D., C.L. Gardner, M.M. Ellis, T.W. Bentzen, J.A. Gross. 2017. Demography of an Increasing Caribou Herd with Restricted Wolf Control. The Journal of Wildlife Management. 81(3): 429-448. DOI: 10.1002/jwmg.21209

Brown, C.L., R. Walker, and S.B. Vanek. 2004. The 2002-2003 harvest of moose, caribou, and bear in Middle Yukon and Koyukuk River communities. Alaska Department of Fish and Game Division of Subsistence Tech- nical Paper No. 280. Fairbanks, AK.

Case, M., and L. Halpin. 1990. Contemporary wild resource use patterns in Tanana, Alaska, 1987. Alaska Department of Fish and Game Division of Subsistence Technical Paper No. 178. Fairbanks, AK.

Caulfield, R. 1983. Subsistence land use in Upper Yukon Porcupine communities, Alaska: Dinjii Nats'aa Nan Kak Adagwaandaii. Alaska Department of Fish and Game Division of Subsistence Technical Paper No. 16. Fair- banks, AK.

EIRAC. 2019. Transcripts of the Eastern Interior Alaska Subsistence Regional Advisory Council proceedings. March 5-6, 2019. Fairbanks, AK. Office of Subsistence Management, USFWS. Anchorage, AK.

Gardner, C.L. 2003. Units 20 and 25 caribou management report. Pages 160–189 in C. Healy, editor. Caribou management report of survey and inventory activities 1 July 2000–30 June 2002. Alaska Department of Fish and Game. Juneau, Alaska.

Godduhn, A.R., M.L. Kostick. 2016. Harvest and use of wild resources in Northway, Alaska, 2014, with special attention to nonsalmon fish. Alaska Department of Fish and Game Division of Subsistence Technical Paper No. 421. Fairbanks, AK.

Gross, J.A. 2015. Units 20B, 20C, 20D, 20E, and 25C caribou. Chapter 12, 12-1 through 12-34 [In] P. Harper and L.A. McCarthy, editors. Caribou management report of survey and inventory activities. 1 July 2012-30 June 2014. Alaska Department of Fish and Game, Species Management Report ADF&G/DWC/SMR-2015-4, Juneau.

Gross, J.A. 2019. Wildlife Biologist. Personal Communication: e-mail. Alaska Department of Fish and Game. Tok, AK.

Halpin, L. 1987. Living off the land: contemporary subsistence in Tetlin, Alaska. Alaska Department of Fish and Game Division of Subsistence Technical Paper No. 149. Fairbanks, AK.

Harvest Management Coalition (HMC). 2012. Fortymile caribou herd harvest plan 2012-2018. Alaska Department of Fish and Game, Fairbanks, Alaska.

Holen, D., S.M. Hazell, and D.S. Koster, editors. 2012. Subsistence harvests and uses of wild resources by communities in the eastern interior of Alaska, 2011. Alaska Department of Fish and Game Division of Subsistence Technical Paper No. 372. Anchorage, AK.

Hosley, E.H. 1981. Intercultural relations and cultural change in the Alaska Plateau. Pages 546–555 in J. Helm, editor. Handbook of North American Indians, Vol. 6, Subarctic. Smithsonian Institution, Washington, D.C.

Marcotte, J.R. 1992. Wild fish and game harvest and use by residents of five Upper Tanana communities, Alaska, 1987-88. Alaska Department of Fish and Game Division of Subsistence Technical Paper No. 168. Fairbanks, AK.

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Skoog, R.O. 1956. Range, movements, populations, and food habits of the Steese-Fortymile caribou herd. Thesis, University of Alaska Fairbanks.

Valkenburg, P., D.G. Kelleyhouse, J.L. Davis, J.M. Ver Hoef. 1994. Case history of the Fortymile Caribou Herd, 1920-1990. Rangifer. 14(1) pp. 11-22.

Van Lanen, J.M., C. Stevens, C.L. Brown, K.B. Maracle, and D.S. Koster. 2012. Subsistence land mammal harvests and uses, Yukon Flats, Alaska: 2008–2010 harvest report and ethnographic update. Alaska Department of Fish and Game Division of Subsistence Technical Paper No.377. Anchorage, AK.

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Appendix 1

Eastern Interior Field Office Manager Bureau of Land Management 222 University Avenue Fairbanks, Alaska 99709

Dear Field Office Manager:

This letter delegates specific regulatory authority from the Federal Subsistence Board (Board) to the manager of the Bureau of Land Management (BLM) Eastern Interior Field Office to issue emergency or temporary special actions if necessary to ensure the conservation of a healthy wildlife population, to continue subsistence uses of wildlife, for reasons of public safety, or to assure the continued viability of a wildlife population. This delegation only applies to the Federal public lands subject to Alaska National Interest Lands Conservation Act (ANILCA) Title VIII jurisdiction within Units 20E, 20F and 25C for the management of caribou on these lands.

It is the intent of the Board that actions related to management of caribou by Federal officials be coordinated, prior to implementation, with the Alaska Department of Fish and Game (ADF&G), representatives of the Office of Subsistence Management (OSM), the U.S. Fish and Wildlife Service (USFWS), the National Park Service (NPS), and the Chair of the affected Council(s) to the extent possible. The Office of Subsistence Management will be used by managers to facilitate communication of actions and to ensure proposed actions are technically and administratively aligned with legal mandates and policies. Federal managers are expected to work with managers from the State and other Federal agencies, the Council Chair or alternate, local tribes, and Alaska Native Corporations to minimize disruption to subsistence resource users and existing agency programs, consistent with the need for special action.

DELEGATION OF AUTHORITY

1. Delegation: The BLM Eastern Interior Field Office manager is hereby delegated authority to issue emergency or temporary special actions affecting caribou on Federal lands as outlined under the Scope of Delegation. Any action greater than 60 days in length (temporary special action) requires a public hearing before implementation. Special actions are governed by Federal regulation at 36 CFR 242.19 and 50 CFR 100.19.

2. Authority: This delegation of authority is established pursuant to 36 CFR 242.10(d)(6) and 50 CFR 100.10(d)(6), which state: “The Board may delegate to agency field officials the authority to set harvest and possession limits, define harvest areas, specify methods or means of harvest, specify permit requirements, and open or close specific fish or wildlife harvest seasons within frameworks established by the Board.”

3. Scope of Delegation: The regulatory authority hereby delegated is limited to the following authorities within the limits set by regulation at 36 CFR 242.26 and 50 CFR 100.26:

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 To modify or restrict harvest limits, including sex restrictions, season dates, and methods and means for caribou on Federal public lands in Units 20E, 20F and 25C. Prior to any modifications to any methods and means, you will seek pre-approval from OSM to assure that such modifications are allowed under the existing Code of Federal Regulations.

This delegation also permits you to close and reopen Federal public lands to nonsubsistence hunting, but does not permit you to specify permit requirements or harvest and possession limits for State-managed hunts.

This delegation may be exercised only when it is necessary to conserve caribou populations, to continue subsistence uses, for reasons of public safety, or to assure the continued viability of the populations. All other proposed changes to codified regulations, such as customary and traditional use determinations, shall be directed to the Board.

The Federal public lands subject to this delegated authority are those within Units 20E, 20F and 25C.

4. Effective Period: This delegation of authority is effective from the date of this letter and continues until superseded or rescinded.

5. Guidelines for Delegation: You will become familiar with the management history of the wildlife species relevant to this delegation in the region, with current State and Federal regulations and management plans, and be up-to-date on population and harvest status information. You will provide subsistence users in the region a local point of contact about Federal subsistence issues and regulations and facilitate a local liaison with State managers and other user groups.

You will review special action requests or situations that may require a special action and all supporting information to determine (1) consistency with 50 CFR 100.19 and 36 CFR 242.19, (2) if the request/situation falls within the scope of authority, (3) if significant conservation problems or subsistence harvest concerns are indicated, and (4) what the consequences of taking an action or no action may be on potentially affected Federally qualified subsistence users and non-Federally qualified users. Requests not within your delegated authority will be forwarded to the Board for consideration. You will maintain a record of all special action requests and rationale for your decision. A copy of this record will be provided to the Administrative Records Specialist in OSM no later than sixty days after development of the document.

For management decisions on special actions, consultation is not always possible, but to the extent practicable, two-way communication will take place before decisions are implemented. You will also establish meaningful and timely opportunities for government-to-government consultation related to pre-season and post-season management actions as established in the Board’s Government-to-Government Tribal Consultation Policy (Federal Subsistence Board Government-to-Government Tribal Consultation Policy 2012 and Federal Subsistence Board Policy on Consultation with Alaska Native Claim Settlement Act Corporations 2015).

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You will immediately notify the Board through the Assistant Regional Director for OSM, and coordinate with the Chair(s) or alternate of the affected Council(s), local ADF&G managers, and other affected Federal conservation unit managers concerning emergency and temporary special actions being considered. You will ensure that you have communicated with OSM to ensure the special action is aligned with ANILCA Title VIII, Federal Subsistence regulations and policy, and that the perspectives of the Chair(s) or alternate of the affected Council(s), OSM, and affected State and Federal managers have been fully considered in the review of the proposed special action.

If the timing of a regularly scheduled meeting of the affected Council(s) permits without incurring undue delay, you will seek Council recommendations on the proposed temporary special action(s). If the affected Council(s) provided a recommendation, and your action differs from that recommendation, you will provide an explanation in writing in accordance with 50 CFR 100.10(e)(1) and 36 CFR 242.10(e)(1).

You will issue decisions in a timely manner. Before the effective date of any decision, reasonable efforts will be made to notify the public, OSM, affected State and Federal managers, law enforcement personnel, and Council members. If an action is to supersede a State action not yet in effect, the decision will be communicated to the public, OSM, affected State and Federal managers, and the local Council members at least 24 hours before the State action would be effective. If a decision to take no action is made, you will notify the proponent of the request immediately. A summary of special action requests and your resultant actions must be provided to the coordinator of the appropriate Council(s) at the end of each calendar year for presentation to the Council(s).

You may defer a special action request, otherwise covered by this delegation of authority, to the Board in instances when the proposed management action will have a significant impact on a large number of Federal subsistence users or is particularly controversial. This option should be exercised judiciously and may be initiated only when sufficient time allows for it. Such deferrals should not be considered when immediate management actions are necessary for conservation purposes. The Board may determine that a special action request may best be handled by the Board, subsequently rescinding the delegated regulatory authority for the specific action only.

6. Support Services: Administrative support for regulatory actions will be provided by the Office of Subsistence Management.

Sincerely,

Anthony Christianson Chair

Enclosures

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Wildlife Proposal WP20-48 DRAFT Staff Analysis cc: Federal Subsistence Board Assistant Regional Director, Office of Subsistence Management Deputy Assistant Regional Director, Office of Subsistence Management Subsistence Policy Coordinator, Office of Subsistence Management Wildlife Division Supervisor, Office of Subsistence Management Subsistence Council Coordinator, Office of Subsistence Management Chair, Eastern Interior Alaska Subsistence Regional Advisory Council Commissioner, Alaska Department of Fish and Game Special Assistant to the Commissioner, Alaska Department of Fish and Game Interagency Staff Committee Administrative Record

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WP20–49 Executive Summary

General Description Proposal WP20-49 requests to open the Arctic Village Sheep Management Area in Unit 25A to the harvest of sheep by non- Federally qualified users. Submitted by: Alaska Department of Fish and Game

Proposed Regulation Unit 25A—Sheep

Unit 25A —Arctic Village Sheep Management Aug. 10–Apr. 30 Area, 2 rams by Federal registration permit only.

Federal public lands are closed to the taking of sheep except by rural Alaska residents of Arctic Village, Venetie, Fort Yukon, Kaktovik, and Chalkyitsik hunting under these regulations.

OSM Preliminary Conclusion Oppose

Eastern Interior Alaska Subsistence Regional Advisory Council Recommendation

North Slope Subsistence Regional Advisory Council Recommendation

Interagency Staff Committee Comments

ADF&G Comments

Written Public Comments None

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DRAFT STAFF ANALYSIS WP20-49

ISSUES

Proposal WP20-49, submitted by the Alaska Department of Fish and Game, requests to open the Arctic Village Sheep Management Area in Unit 25A to the harvest of sheep by non-Federally qualified users.

DISCUSSION

The proponent states that the restriction of sheep hunting to only residents of a few communities (Arctic Village, Chalkyitsik, Fort Yukon, Kaktovik, and Venetie) is not necessary to accommodate local subsistence uses. Harvest records indicate residents of these communities rarely hunt sheep. Furthermore, there is no biological reason to preclude sheep hunting opportunities by the public in the Arctic Village Sheep Management Area. The proponent states that this restriction is not necessary to provide for subsistence uses.

The proponent continues there is no conservation concern associated with hunting opportunity in the Arctic Village Sheep Management Area. Sheep populations across the eastern Brooks Range appear to be stable. Because this is a full curl only harvest area during the fall hunting season, any harvest associated with this change would have no effect on the sheep population. On average, during the winter registration permit season, four hunters harvest a total of three sheep per year throughout the entire hunt area. Ninety-five percent of these sheep are males. Travel to the registration permit hunt area is difficult and methods are limited by regulations and statutes. The proponent states it has no concerns that harvest would increase to levels that could be of concern, should this area be opened to non-Federally-qualified users.

The proponent further states that it is unknown if Federally qualified subsistence users will be impacted from adoption of this proposal. Based on biological data, Federally qualified subsistence users will retain opportunity to meet their subsistence needs. Non-Federally qualified users will regain an opportunity to harvest sheep in the Arctic Village Sheep Management Area. This change would provide additional harvest opportunity for non-Federally qualified users. It would also provide some opportunity for guide businesses in the area.

Existing Federal Regulation

Unit 25A—Sheep

Unit 25A —Arctic Village Sheep Management Area, 2 rams by Federal Aug. 10–Apr. 30 registration permit only.

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Federal public lands are closed to the taking of sheep except by rural Alaska residents of Arctic Village, Venetie, Fort Yukon, Kaktovik, and Chalkyitsik hunting under these regulations.

Proposed Federal Regulation

Unit 25A—Sheep

Unit 25A —Arctic Village Sheep Management Area, 2 rams by Federal Aug. 10–Apr. 30 registration permit only.

Federal public lands are closed to the taking of sheep except by rural Alaska residents of Arctic Village, Venetie, Fort Yukon, Kaktovik, and Chalkyitsik hunting under these regulations.

Existing State Regulation

Unit 25A Sheep

Resident hunters, 1 ram with full-curl horn or larger may be HT Aug. 10–Sept. 20 taken only from Aug. 10–Sept. 20; up to 3 sheep may be taken by registration permit only Oct. 1–Apr. 30; RS595 Oct. 1–Apr. 30

or

Resident hunters, 1 ram with full-curl horn or larger, by HT Aug. 1–5 youth hunt only.

Nonresident hunters, 1 ram with full-curl horn or larger HT Aug. 10–Sept. 20 every 4 regulatory years.

or

Nonresident hunters, 1 ram with full-curl horn or larger, by HT Aug. 1–5 youth hunt only; every 4 regulatory years.

Note: Codified regulations are shown above. Concerning the Arctic Village Sheep Management Area in Unit 25A, the Alaska Department of Fish and Game has used its discretion to allow the distribution of RS595 registration permits only after September 12, to prohibit the use of aircraft for access to hunt sheep, and to close the nonresident youth hunt. HT=harvest ticket, RS=registration permit.

5 AAC 92.003 Hunter education and orientation requirements

(i) Before a person hunts sheep within the Red Sheep and Cane Creek drainages within the Arctic Village Sheep Management Area of Unit 25(A), that person must possess proof of completion of a

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department-approved hunter ethics and orientation course, including land status and trespass information.

Extent of Federal Public Lands Federal public lands comprise approximately 99% of the Arctic Village Sheep Management Area in Unit 25A and consist of U.S. Fish and Wildlife Service managed lands that are within the Arctic National Wildlife Refuge (Figure 1).

Figure 1 T A A A

Customary and Traditional Use Determination

Rural residents of Arctic Village, Chalkyitsik, Fort Yukon, Kaktovik, and Venetie have a customary and traditional use determination for sheep in Unit 25A.

Regulatory History

Knowledge of regulatory history necessary to analyze Proposal WP20-49 is extensive. It is described in Appendix 1.

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Current Events

The Eastern Interior Alaska Council submitted Proposal 82, concerning the Arctic Village Sheep Management Area, to the Alaska Board of Game to take up at its March 6–14, 2020, meeting in Fairbanks (ADF&G 2019b: 94–97). The Council is requesting that the State recognize the Management Area and implement new harvest limits by changing the resident harvest limit from 3 sheep every regulatory year to 1 ram with full curl horn or larger every 4 regulatory years and replacing harvest tickets (HT) with drawing permits (DS). Additionally, the Council is requesting the nonresident youth hunt be eliminated in the Management Area. The Council states in the proposal that it “intends for this proposal to become a joint effort between the Alaska Board of Game, the Federal Subsistence Board, and Arctic Village residents to find a workable solution to a historically contentious issue and build mutual respect between parties” (ADF&G 2019: 95). The proposed changes to the State regulation are described below.

Unit 25A Sheep—Arctic Sheep Management Area

Resident hunters, 1 ram with full-curl horn or larger every 4 DSXXX Aug. 10–Sept. 20 regulatory years by permit; may be taken only from Aug. 10–Sept. 20; up to 3 sheep may be taken by registration HT permit only Oct. 1–Apr. 30;

or

Resident hunters, 1 ram with full-curl horn or larger every 4 RS595 Oct. 1–Apr. 30 regulatory years by permit may be taken only from Aug. 10– Sept. 20; up to 3 sheep may be taken by registration permit only Oct. 1–Apr. 30;

or

Resident hunters, 1 ram with full-curl horn or larger, by HT Aug. 1–5 youth hunt only.

Nonresident hunters, 1 ram with full-curl horn or larger DSXXX Aug. 10–Sept. 20 every 4 regulatory years by permit HT or

Nonresident hunters, 1 ram with full-curl horn or larger HT Aug. 1–5 every 4 regulatory years by permit by youth hunt only; every 4 regulatory years.

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Biological Background

Sheep populations across the eastern Brooks Range of Alaska have appeared relatively stable at low densities since the late 1990s (Caikoski 2014). However, geographic barriers such as large valleys and rivers naturally limit sheep movements and distribution, resulting in discrete subpopulations (Arthur 2013, Caikoski 2014). Therefore, repeated, fine-scale surveys are necessary to understand sheep population status and trends in a specific area such as the Arctic Village Sheep Management Area. State management goals and objectives for sheep in Unit 25A (Caikoski 2014) include:

 Protect, maintain, and enhance the sheep population and its habitat in concert with other components of the ecosystem.

 Provide for continued general sheep harvest and subsistence use of sheep.  Provide an opportunity to hunt sheep under aesthetically pleasing conditions.  Maximize hunter opportunity using a full-curl harvest strategy.  Maintain an average harvest of rams ≥ 8 years old. The State manages sheep using a full-curl harvest strategy, a conservative approach (ADF&G 2017a). Once sheep are eight years old, their chances of surviving each additional year is much lower. Harvesting older, full-curl rams (8+ years old) allows younger rams in their prime to continue breeding (ADF&G 2017a). The Arctic National Wildlife Refuge conducts periodic aerial sheep surveys of the Arctic Village Sheep Management Area and surrounding areas. Due to differences in survey areas, comparisons across years are difficult. Sheep densities within the Management Area have generally been low compared to some other areas in the Brooks Range (Payer 2006 in OSM 2014a). Within the Management Area, sheep densities north of Cane Creek have been much higher than sheep densities south of Cane Creek, presumably because habitat quality is lower in that area (Mauer 1990 in OSM 2014a, Wald 2012). This is probably related to shale formations supporting more vegetation and therefore more sheep that are more common north (versus south) of Cane Creek, (Smith 1979 in OSM 2014a). The presence of mineral licks south of Cane Creek also influences sheep densities as most sheep observed by Mauer (1996) and Payer (2006) were clustered around such licks (OSM 2014a). In 1991, sheep densities in the Management Area north and south of Cane Creek averaged 2.25 sheep/mi2 and 0.2 sheep/mi2, respectively (Mauer 1996 in OSM 2014a). In 2006, sheep density north of Cane Creek averaged 1.7 sheep/mi2 (Wald 2012). The observed decline in density is thought to be weather related (OSM 2014). The sheep population in the Management Area likely declined between 2012 and 2015 due to several years of poor lamb production and severe winters (particularly the winters of 2012-13 and 2013-14). In 2012, surveys within and near the Management Area indicated an average sheep density of 0.79 sheep/mi2 and 27 lambs:100 ewes (Arthur 2017, pers. comm.). Density north and south of Cane Creek ranged from 1.5–1.8 sheep/mi2 and 0.25–0.7 sheep/mi2, respectively (Wald 2012). In 2015, estimated sheep density for the

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same areas averaged 0.67 sheep/mi2 and the lamb:ewe ratio was 34 lambs:100 ewes. The 2015 survey also indicated a decline in rams of all age classes (Arthur 2017, pers. comm.). In 2016, a larger area was surveyed, including the Hulahula River drainage in Unit 26C, which contains higher sheep densities than the Management Area. While the 2016 overall sheep density averaged 0.86 sheep/mi2, density within the Management Area was likely 0.70-0.75 sheep/mi2 (Arthur 2017, pers. comm.). The ram:ewe ratio for the entire survey area averaged 28 rams:100 ewes, and the density of full- curl rams was 0.005/mi2. Due to improved lamb production in 2015 and 2016 (>30 lambs:100 ewes), the sheep population in the Management Area has likely not declined below 2015 levels and may be increasing. However, it will be at least 3–5 years before an increase in mature (8+ year old) rams are observed in the population (Arthur 2017, pers. comm., 2019 pers. comm.). No surveys have been conducted since 2016.

Cultural Knowledge and Traditional Practices

The Arctic Village Sheep Management Area was traditionally occupied by Netsi Gwich’in whose traditional territory was the northern reaches of the East Fork Chandalar, Koness, and Sheenjek rivers. Netsi Gwich’in continued their nomadic way of life into the 1950s when they established more permanent settlements at Arctic Village and Venetie taking extended trips to seasonal harvesting sites (McKennan 1965).

Netsi Gwich’in followed to the arctic coast routes that were situated within the Arctic Village Sheep Management Area. Gwich’in regularly visited the arctic coast for the purposes of trade (Burch 1979). Hadleigh-West, writing in the late 1950s, spoke with people who had made the trip over the Brooks Range to the arctic coast. They said that families went into the mountains to hunt sheep and caribou. Traders went forward to the Barter Island area to exchange hides for Western goods from whalers. Hadleigh-West reported people preferring the Phillip Smith Mountains for sheep hunting, which is the source of many East Fork Chandalar tributaries including Red Sheep and Cane creeks and other drainages situated within the Arctic Village Sheep Management Area. This trade continued irregularly until 1928. In 1938, Albert Tritt took two grandchildren to the ridge to look down on the north face of the Brooks Range, probably the last such trip by Netsi Gwich’in (Hadleigh-West 1963: 256–259).

The Sheenjak River to Hulahula River and arctic coast was a common route, and Red Sheep Creek was a recognized favorite sheep hunting area on a route to the arctic coast (Hadleigh-West 1963: 257). At the Eastern Interior Alaska Regional Advisory Council (Eastern Interior Alaska Council) meeting in 2017, Hollis Twitchell related an onsite conversation with Trimble Gilbert who said that food and tools were cached in the mountains in the Red Sheep Creek drainage for the returning traders and for future trips, indicating the cultural importance of the area (EIASRAC 2017: 286)

While located approximately 45 miles from Arctic Village, Red Sheep Creek is situated well within the historical territory of Netsi Gwich’in. Native allotments cover the confluence of Red Sheep and Cane creeks with the East Fork Chandalar River; a Native allotment is situated further up Red Sheep Creek, and a native allotment is situated upriver at the confluence of an unnamed creek and the East Fork Chandalar River. The Red Sheep Creek allotments were not conveyed until 1996 (FWS 2019). Prior to this time, the

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Netsi Gwich’in possessed specialized skills for traveling in mountainous areas, as described below by Hadleigh-Smith (1963):

The extent to which the Netsi Kutchin are adapted to their mountainous environment is evidenced by the willingness and agility with which they attack it. Hiking trails usually take the shortest route between two points. This always entails some climbing. Another evidence is inherent in their knowledge of the country; it is “impossible” to become lost in Netsain. Hunting mountain sheep, nowadays viewed as a kind of family outing, often demands of the hunter an agility approaching that of the quarry. In this connection, too, the former use of a special climbing staff, surely is indicative of a mountaineering people (Hadleigh-Smith 1963:270).

Traditionally, after caribou, mountain sheep were the most important large land mammal for food. Moose were scarce (Hadleigh-West 1963: 172). Netsi Gwich’in relied upon sheep as a food source primarily in late summer or whenever caribou were scarce. Hadleigh-West (1963: 138) identified four very specific sheep hunting areas used by Arctic Village residents along the Junjik River, East Fork Chandalar River, Cane Creek, and Red Sheep Creek. All are within the Arctic Sheep Management Area.

The customary and traditional use determination for sheep in Unit 25A, including the Arctic Village Sheep Management Area, consists of five communities with a total population of roughly 1,200 people according to the 2010 U.S. Census (Table 1).

Table 1 T A ADD Community 1960 1970 1980 1990 2000 2010 A F T

Of the five communities with recognized customary and traditional uses of sheep in Unit 25A, the residents of Arctic Village have the strongest ties to and are the primary users of the area (OSM 1993; see also Dinero 2003, Gustafson 2004, and Reed et al. 2008). Sheep hunting is a longstanding tradition for Arctic Village residents, most of whom are Gwich’in Athabascan (Caulfield 1983:68; Dinero 2003; EISRAC 2006:110–137, 2007, 2011; Gustafson 2004), and the Cane Creek and Red Sheep Creek drainages have been a longstanding focus of this activity. Sheep are a prestigious subsistence resource, and

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providing sheep meat to the community is highly respected (cf. Caulfield 1983 and Dinero 2003 for discussion). Sheep are also known as an important “hunger food,” that is, a food source that is critical when caribou are unavailable (Caulfield 1983, Dinero 2011, pers. comm.; Gilbert 2011, pers. comm.). Local people report increasing uncertainty of caribou migrations in recent years, declining quality of caribou meat, and increasing difficulty and travel distance to obtain moose in recent years: in light of this, local residents say that sheep are an increasingly important resource (Gilbert 2011, pers. comm.; Swaney 2011, pers. comm.). As noted by one prominent elder, “When we have no caribou, that’s the time we have to go up [to get sheep]” (Gilbert 2011, pers. comm.).

The public record supports the fact that Arctic Village residents have a long history of using the Cane Creek and Red Sheep Creek drainages, which continue be a culturally significant area. Extensive discussion included in previous proposal analyses (OSM 1993, 1995a, 2014a and 2018) pointed to regular use of these drainages by residents of Arctic Village. Gustafson (2004), in a study of traditional ecological knowledge, discusses the importance and continued use of the Red Sheep Creek drainage for sheep hunting. Testimony by Arctic Village residents in 2006, 2007, 2011, and 2017 at the Eastern Interior Alaska Council meeting about hunting in Cane Creek and Red Sheep drainages demonstrates continued hunting in these areas. Discussions with Refuge Information Technicians from Arctic Village, other Arctic National Wildlife Refuge staff, researchers working in the area, and subsistence hunters from Arctic Village also confirm continued sheep hunting in the Cane Creek and Red Sheep drainages (Bryant 2011, pers. comm.; Dinero 2011 pers. comm.; Mathews 2011, pers. comm.; John 2011, pers. comm.).

The trip from Arctic Village to Red Sheep Creek and back is about 90 miles and residents use great effort both physically and economically to hunt sheep in this area (Bryant 2011, pers. comm.; John 2011, pers. comm.; Gilbert 2011, pers. comm.; Swaney 2011, pers. comm.). The residents of Arctic Village have repeatedly expressed concerns about non-Federally qualified users hunting sheep in Red Sheep Creek and Cane Creek drainages. These residents have provided testimony and public comment at numerous Council and Board meetings to attest to the importance of Red Sheep Creek, to describe their use of the area, and to explain that the presence of non-Federally qualified users has affected their access and reduced their harvest opportunities (EIASRAC 2006, 2007, 2011, and 2017; FSB 1991a:291-311, 1995, 2006a, 2007:292–306, and 2012; (OSM 1993, 1995a, 1996, 2006b, 2007a, and 2014a; Swaney 2011, pers. comm.; Gilbert 2011, pers. comm.; John 2011, pers. comm.). Additionally, in their 2018 annual report to the Board, the Eastern Interior Alaska Council noted their concern about existing sheep harvest limits and seasons in State regulations: “The Council is . . . troubled by the possibility that with the three sheep harvest limit, a lot of ewes and lambs can be taken during the late winter [to] early spring seasons. The Council believes that the existing three sheep harvest limit in both State and Federal regulations could potentially result in overharvest and a conservation issue” (EIASRAC 2018:4).

Among the Gwich’in, there is a story about how Red Sheep Creek was named, which illustrates the link between subsistence and religious practices and beliefs. It also underscores the importance of this area to the residents of Arctic Village. The story relates Red Sheep Creek to the Episcopalian Church, an influential factor in establishing Arctic Village, and sheds some light on why Arctic Village residents consider Red Sheep Creek a revered place (Dinero 2007; Dinero 2011, pers. comm.). The story begins with people who were hungry. One day at the church someone spotted caribou moving in the brush. Upon closer inspection

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people realized they were looking at unusual sheep with red markings, or what many say were crosses on their coats. The next day, people followed these red sheep far into the mountains where they were finally able to harvest them. The hides of these sheep were kept and passed down because of their distinctive markings (Dinero 2011, pers. comm.). The story of the red sheep links a prestigious subsistence resource (sheep) to traditional and modern beliefs and practices, and demonstrates the complementary nature of subsistence to place, tradition, culture, and modern beliefs.

Traditionally, Arctic Village residents have harvested sheep in early fall (late August or early September) or in early winter (November) (Caulfield 1983, FSB 2007:292–306). “Sheep taste best in the fall,” as documented in earlier research (OSM 1995a:353). Residents generally travel to hunt sheep by boat, then by foot from hunting camps in the fall or by snowmachine in late fall, but not in winter given the dangerous terrain and winter weather (OSM 1993).

Arctic Village residents have commented that allowing non-Federally qualified users to harvest sheep in Red Sheep Creek and Cane Creek drainages during the time when Arctic Village residents customarily and traditionally harvested sheep affects Arctic Village residents’ ability to access an important sheep hunting area. Since 1993, Arctic Village residents have noted to the Board that plane traffic by non-Federally qualified users have interfered with their ability to successfully hunt sheep in the Red Sheep and Cane Creek drainages. Residents reported that plane fly-overs “spooked” sheep and that “older rams can climb to higher elevations, making them more difficult to hunt” (OSM 1993, see also OSM 1995a for additional discussion). Gideon James from Arctic Village explained that Red Sheep and Cane Creek are both very narrow valleys, and consequently flights through the area disturb sheep (FSB 2012:201). These disturbances have continued to be described by Arctic Refuge staff (Mathews 2011, pers. comm.), and local residents (Swaney 2011, pers. comm., John 2011 pers. comm., Gilbert 2011, pers. comm.). Frid (2003) found that fixed-wing aircraft disrupted resting or caused fleeing behavior in Dall sheep in the Yukon Territory during overflights. This disruption was of a longer duration during direct flight approaches. Results of this study could help provide managers with guidelines for determining spatial and temporal restrictions to aircraft in areas frequented by this species.

Harvest History

A Federal closure to the harvest of sheep in the Arctic Village Sheep Management Area by non-Federally qualified users has been in effect since 1991. In 1995, the Management Area was expanded to include the area from Cane Creek north to, and including, the Red Sheep Creek drainage. The closure to the take of sheep in the area north of Cane Creek by non-Federally qualified users was rescinded for a portion (from August 10 through September 30) of the season from 2006 through 2011 regulatory years Data on the reported use of the Management Area by Federally qualified subsistence users is sparse, and just how many sheep are harvested by Federally qualified subsistence users in the Management Area is unknown. It is likely that many Gwich’in hunters have not reported their harvest efforts (Van Lanen et al. 2012, Anderson and Alexander 1992). One source of data is the U.S. Fish and Wildlife Service harvest reporting system.

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Since 1995, Federally qualified subsistence users have been required to get a Federal registration permit to hunt for sheep in the Management Area. Table 2 shows data kept by the U.S. Fish and Wildlife Service from permits issued from 1995 through 2018. Federally qualified subsistence users have requested 40 permits to hunt for sheep in the Management Area. Only some hunters returned their permits so these following data are incomplete. Seventeen hunters reported hunting sheep, and 9 hunters reporting harvesting sheep in the Management Area. Hunters did not always report areas they used to hunt for sheep within the Management Area. Of these incomplete data, three hunters reported using the Red Sheep Creek drainage to hunt for sheep and one sheep harvest was reported. Sixteen hunters reported the type of transportation they used to reach hunt areas: one by boat, 14 by airplane, and one reported using no transportation. Of those reporting, hunting trips were a median average of 5 days (OSM 2019).

Table 2 Federal permits only R A A A F F Number of Federal Number of hunts Number of sheep Community permits issued reported harvests reported A

F

Total 40 17 9

The Alaska Department of Fish and Game maintains a harvest reporting database where hunters using State harvest tickets and permits report their hunting efforts (ADF&G 2019a). Complete records were not kept until the mid-1980s, and it is likely that many Gwich’in hunters have not reported their harvest efforts or have reported their harvest efforts on Federal permits (see above). The following description of hunter effort and success begins with Unit 25A. This is the finest level of reporting in the State harvest reporting system. A description of hunter effort and success within the Management Area at the uniform coding unit level is also described, although harvest site documentation is much less precise and is an approximation. Another reason that hunter effort and harvest in Unit 25A is described here is that the Board justified the original closure, in part, because the remainder of Unit 25A supported a substantial opportunity for all hunters (FSB 1991b:150–164).

From 1983 to 2017 regulatory years, hunters with State harvest tickets and permits reported harvesting 1,746 sheep (about 50 sheep annually) from within the entire Unit 25A area (see Table 3, ADF&G 2019a).

The Arctic Village Sheep Management Area is a small area with Unit 25A (see Unit 25 Map). From 1983 to 1990 regulatory years, approximately 61 sheep harvests (about 8 sheep annually) were reported on State harvest tickets and permits in an area approximating the Arctic Village Sheep Management Area using uniform coding units, including the area north of Cane Creek and the Red Sheep Creek drainage, before most of this area was closed to the harvest of sheep by non-Federally qualified users in 1991 (OSM 2019, 4 of these 61 sheep harvests were reported by Federally qualified subsistence users). The Arctic Village

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Table 3 State harvest tickets and permits only R A ADF Federally Federally Non- Non- qualified qualified Other Other residents residents subsistence subsistence Alaska Alaska of of users: users: residents: residents: Alaska: Alaska: Total: Total: Year Reported Reported Reported Reported Permits sheep Permits sheep Permits sheep Permits sheep issued harvest issued harvest issued harvest issued harvest T

1 Four or fewer reports were received in any given year. Only the total is provided to protect confidentiality of Federally qualified subsistence users reporting their effort and harvest.

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Sheep Management Area does not have the same boundaries as uniform coding units and harvest site reporting at the uniform coding unit level is often imprecise and is an approximation.

From 1983 to 1994 regulatory years, approximately 27 sheep harvests (about 2 sheep annually) were reported on State harvest tickets and permits in the area north of Cane Creek and in the Red Sheep Creek drainage, before it closed to the harvest of sheep by non-Federally qualified users in 1995 (OSM 2019, none was reported by Federally qualified subsistence users).

From 2006 to 2010 regulatory years, approximately 22 sheep harvests (about 4 sheep annually) were reported on State harvest tickets and permits in the area north of Cane Creek and in the Red Sheep Creek drainage while it was open to the harvest of sheep from August 10 through September 30 by non-Federally qualified users (OSM 2019, harvest site information is not readily available after the 2011 regulatory year). One sheep harvest was reported in 2005 by a non-Federally qualified user when the area was closed.

Effects of Proposal

If adopted, Proposal WP20-49 would open the Arctic Village Sheep Management Area to the harvest of sheep under State regulations.

Adopting this proposal and opening the Management Area to non-Federally qualified users may adversely affect subsistence users’ access and ability to harvest sheep in the Management Area and thereby fail to provide a meaningful preference for Federally qualified subsistence users.

If adopted, this proposal could negatively impact the sheep population in the Management Area, especially south of Cane Creek where sheep density estimates are low.

If Proposal WP20-49 is not adopted, sheep hunting in the Management Area by non-Federally qualified users will remain closed.

OSM PRELIMINARY CONCLUSION

Oppose Proposal WP20-49.

Justification

Federal public lands in the Arctic Village Sheep Management Area should remain closed to the harvest of sheep except by Federally qualified subsistence users. Sheep densities within the Management Area have generally been low compared to other areas in the Brooks Range, which is likely due to poor habitat quality (Payer 2006 in OSM 2014a). In 1991, when the closure was adopted by the Board, portions of the area did not appear to be able to support more sheep than were present, and the Board said that the remainder of Unit 25A supported a substantial opportunity for all hunters (FSB 1991b:150–164). Sheep populations in the Management Area situated south of Cane Creek continue to exist at low densities (Arthur 2017, pers. comm.) and should remain closed to nonsubsistence uses in order to protect healthy populations of sheep, as mandated in ANILCA Section 815(3).

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Since 1995 the Board has continued to hear substantial testimony and ethnographic evidence demonstrating the importance of Cane Creek and Red Sheep Creek drainages to Federally qualified subsistence users, especially Netsi Gwich’in who occupied the area historically and continue to occupy the area today. In 2012, the Board reiterated that the closure was needed to ensure the continuation of traditional subsistence uses of sheep by Arctic Village hunters (OSM 2012b:7), and again in 2014 (OSM 2014a:350), and 2018 (OSM 2018b). This area should remain closed to nonsubsistence uses in order to protect subsistence uses, as mandated in ANILCA Section 815(3).

LITERATURE CITED

ADF&G (Alaska Department of Fish and Game). 2017a. Dall sheep hunting full-curl identification guide. ADF&G, Division of Wildlife Conservation. http://www.adfg.alaska.gov/static/hunting/dallsheephunting/pdfs/dall_sheep_hunting_full_curl_identification_guide.p df.

ADF&G. 2019a. Harvest general reports. Online database, accessed August 20, 2019. https://secure.wildlife.alaska.gov/index.cfm?fuseaction=harvestreports.main

ADF&G 2019b. 2019/2020 Proposal Book. Alaska Board of Game. http://www.adfg.alaska.gov/index.cfm?adfg=gameboard.main, accessed August 26, 2019. Juneau.

ADCCED (Alaska Department of Commerce, Community, and Economic Development). 2017. Community index. https://www.commerce.alaska.gov/dcra/DCRAExternal/community, accessed August 24, 2017. Division of Community and Regional Affairs. Juneau, AK.

Anderson, D.B., and C.L. Alexander. 1992. Subsistence hunting patterns and compliance with moose harvest reporting requirements in rural interior Alaska. ADF&G, Division of Subsistence Technical Paper No. 215. Juneau, AK. 30 pages. http://www.adfg.alaska.gov/sf/publications/index.cfm?ADFG=addLine.home

Arthur, S.M. 2013. Demographics and spatial ecology of Dall sheep in the central Brooks Range. ADF&G, Division of Wildlife Conservation, Final research performance report 1 July 2007-30 June 2013. Federal Aid in Wildlife Restoration Project 6.15, Juneau, AK.

Arthur, S.M. 2017. Wildlife Biologist. Personal communication: e-mail. Arctic National Wildlife Refuge. Fairbanks, AK.

Arthur, S. 2019. Supervisory Wildlife Biologist. Personal communication: e-mail and telephone. Arctic National Wildlife Refuge. U.S. Fish and Wildlife Service. Fairbanks, AK.

Burch, E.J. 1979. Indians and Eskimos in North Alaska, 1816–1977: A study in changing ethnic relations. Arctic Anthropology 16(2): 123–151.

Bryant, J.G. 2011. Refuge Information Technician, Arctic National Wildlife Refuge, former resident Arctic Village. Personal communication: phone. July 2011.

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Caikoski, J.R. 2014. Eastern Unit 24A and Units 25A, 26B, and 26C Dall sheep. Chapter 16 pages 16-1 through 16- 18 in P. Harper and L.A. McCarthy, editors. Dall sheep management report of survey and inventory activities 1 July 2010-30 June 2013. ADF&G, Species Management Report ADF&G/DWC/SMR-2014-4, Juneau, AK.

Caulfield, R. 1983. Subsistence land use in upper Yukon Porcupine communities, Alaska. Dinjii Nats’aa Nan Kak Adagwaandaii. ADF&G, Division of Subsistence Technical Paper No.16. Fairbanks, AK. 252 pages.

Dinero, S. 2003. Analysis of a “mixed economy” in an Alaskan Native settlement: the case of Arctic Village. The Canadian Journal of Native Studies XXII, 1:135–164.

Dinero, S. 2007. Globalization and development in a post-nomadic hunter/gatherer Alaskan village: a follow-up assessment. Polar Record 43(226): 225–269.

Dinero, S. 2011. PhD. Anthropologist conducting research in Arctic Village. Personal communication: phone. July/August 2011. Philadelphia University, PA.

EIASRAC 1995. Transcripts of the Eastern Interior Alaska Subsistence Regional Advisory Council proceeding. March 3, 1995. Northway, AK. Office of Subsistence Management, USFWS. Anchorage, AK.

EIASRAC. 2006. Transcripts of the Eastern Interior Alaska Subsistence Regional Advisory Council Meeting. March 21, 2006. Fairbanks, AK. Office of Subsistence Management, USFWS. Anchorage, AK.

EIASRAC. 2007. Transcripts of the Eastern Interior Alaska Subsistence Regional Advisory Council Meeting. March 20, 2007. Arctic Village, AK. Office of Subsistence Management, USFWS. Anchorage, AK.

EIASRAC. 2011. Transcripts of the Eastern Interior Alaska Subsistence Regional Advisory Council Meeting. March 3, 2011. Fairbanks, AK. Arctic Village, AK. Office of Subsistence Management, USFWS. Anchorage, AK.

EIASRAC. 2017. Transcripts of the Eastern Interior Alaska Subsistence Regional Advisory Council Meeting. November 9 in Fairbanks, AK. Office of Subsistence Management, USFWS. Anchorage, AK.

EIASRAC. 2018. Annual Report. Office of Subsistence Management, USFWS. Anchorage, AK.

Frid, A. 2003. Dall’s sheep responses to overflights by helicopter and fixed-wing aircraft. Biological Conservation 110: 387–399.

FSB. 1991a. Transcripts of Federal Subsistence Board proceeding. June 5, 1991. Office of Subsistence Management, USFWS. Anchorage, AK.

FSB. 1991b. Transcripts of Federal Subsistence Board proceeding. March 6, 1991. Office of Subsistence Management, USFWS. Anchorage, AK.

FSB. 1991c. Transcripts of Federal Subsistence Board proceeding. March 4, 1991. Office of Subsistence Management, USFWS. Anchorage, AK.

FSB. 1993. Transcripts of Federal Subsistence Board proceeding. April 8, 1993. Office of Subsistence Management, USFWS. Anchorage, AK.

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FSB. 1995. Transcripts of Federal Subsistence Board proceeding. April 14, 1995. Office of Subsistence Management, USFWS. Anchorage, AK.

FSB. 1996. Transcripts of Federal Subsistence Board proceeding. May 2, 1996. Office of Subsistence Management, USFWS. Anchorage, AK.

FSB. 2006. Transcripts of Federal Subsistence Board proceeding. May 17, 2006. Office of Subsistence Management, USFWS. Anchorage, AK.

FSB. 2007. Transcripts of the Federal Subsistence Board. May 1, 2007. Office of Subsistence Management, USFWS. Anchorage, AK.

FSB. 2012. Transcripts of the Federal Subsistence Board. January 19, 2012. Office of Subsistence Management, USFWS. Anchorage, AK.

FWS (U.S. Fish and Wildlife Service). 2019. Land status within the National Wildlife Refuges of Alaska. https://fws.maps.arcgis.com/apps/webappviewer/index.html?id=3eed8d6b30ea443dafe4380d70d0fa5e, accessed August 29.

Gilbert, T. 2011. Elder, resident of Arctic Village. Personal communication: phone. August 2011.

Gustafson, J. 2004. Traditional ecological knowledge of subsistence harvests and fishes, Old John Lake, Alaska. Final Report No. FIS01-003. Office of Subsistence Management, USFWS. Anchorage, AK.

Hadleigh-West, R. 1963. The Netsi Kutchin: an essay in human ecology. PhD dissertation. Louisiana State University. Ann Arbor, Michigan.

John, J. 2011. Arctic Village Council, First Chief, elder, resident. Personal communication: phone. August 2011.

Mathews, V. 2011. Refuge Subsistence Specialist. Personal communication: email, phone. Arctic National Wildlife Refuge. Fairbanks, AK.

Mauer, F.J. 1990. Dall sheep investigations in the Chandalar River drainage of the Arctic National Wildlife Refuge, 1990. ANWR Progress Report No. FY90-03. USFWS. Fairbanks, AK.

Mauer, F.J. 1996. Dall sheep investigations in the Arctic Village area. Arctic National Wildlife Refuge. Unpublished Report. USFWS. Fairbanks, AK.

McKennan, R.A. 1965. The Chandalar Kutchin. Arctic Institute of North America Technical Paper No. 17, Montreal.

NSSRAC 1995. Transcripts North Slope Subsistence Regional Advisory Council proceeding. February 17, 1995. Barrow, AK. Office of Subsistence Management, USFWS. Anchorage, AK.

OSM (Office of Subsistence Management). 1991. Staff Analysis P91-21 in Federal Subsistence Board Meeting Materials. April 5–8, 1993. Office of Subsistence Management, USFWS. Anchorage, AK.

OSM. 1993. Staff Analysis P93–58. Pages 1–9 in Federal Subsistence Board Meeting Materials. April 5–8, 1993. Office of Subsistence Management, USFWS. Anchorage, AK.

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OSM. 1995a. Staff analysis P95-54. Pages 352–359 in Federal Subsistence Board Meeting Materials. April 10–12, 15, 1995. Office of Subsistence Management, USFWS. Anchorage.

OSM. 1995b. Requests for reconsideration 1992–2000: summary of Federal Subsistence Board actions. On file, Office of Subsistence Management, USFWS. Anchorage.

OSM. 1996. Staff analysis of Proposal 55. Pages (Eastern Interior) 2–12 in Federal Subsistence Board Meeting Materials. April 29–May 3, 1996. Office of Subsistence Management, USFWS. Anchorage.

OSM. 2006a. Federal Subsistence Board action report: Eastern Interior proposals. Meeting held May 16–18 in Anchorage, AK. Office of Subsistence Management, USFWS, Anchorage, AK.

OSM. 2006b. Staff analysis of WP06-57. Pages 452–459 in Federal Subsistence Board Meeting Materials. May 16– 18, 1996. Office of Subsistence Management, USFWS. Anchorage.

OSM. 2007a. Staff Analysis WP07-56. Pages 529–538 in Federal Subsistence Board Meeting Materials April 30– May 2, 2007. Office of Subsistence Management, USFWS. Anchorage, AK. 622 pages.

OSM. 2007b. Federal Subsistence Board action report: Eastern Interior proposals. Meeting held April 30–May 2 in Anchorage, AK. Office of Subsistence Management, USFWS, Anchorage, AK.

OSM. 2012a. Staff analysis of WP12-76. Pages 529–538 in Federal Subsistence Board Meeting Materials. January 17–20, 2012. Office of Subsistence Management, USFWS. Anchorage.

OSM. 2012b. Federal Subsistence Board action report: Eastern Interior proposals. Meeting held January 17–20 in Anchorage, AK. Office of Subsistence Management, USFWS, Anchorage, AK.

OSM. 2014a. Staff analysis of WP14-51. Pages 336–351 in Federal Subsistence Board Meeting Materials. April 15– 17, 2014. Office of Subsistence Management, USFWS. Anchorage.

OSM. 2014b. Federal Subsistence Board non-consensus action report: Eastern Interior Proposals. Meeting held April 15–18 in Anchorage, AK. Office of Subsistence Management, USFWS, Anchorage, AK.

OSM. 2017. Proposal document Library: regulatory actions. Electronic database. Office of Subsistence Management, USFWS, Anchorage, AK.

OSM. 2018a. Staff analysis of WP18-56. Supplemental materials in Federal Subsistence Board Meeting Materials. April 10–13. Office of Subsistence Management, USFWS. Anchorage.

OSM. 2018b. Federal Subsistence Board non-consensus action report: Eastern Interior Proposals. Meeting held April 10-13 in Anchorage, AK. Office of Subsistence Management, USFWS, Anchorage, AK.

OSM. 2019. Federal harvest reporting database. Electronic database. Office of Subsistence Management, USFWS, Anchorage, AK.

Payer, D.C. 2006. Dall sheep survey in the Arctic Village Sheep Management area and vicinity. Arctic National Wildlife Refuge. Unpublished report. USFWS. Fairbanks, AK.

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Reed, J., C. Villa, and T. Underwood. 2008. Red Sheep Creek airstrip public use monitoring, Arctic National Wildlife Refuge, Alaska, 2006–2007. Report for Arctic National Wildlife Refuge. USFWS. Fairbanks, AK. 10 pages.

Smith, T. 1979. Distribution and abundance of Dall sheep in the Arctic National Wildlife Range. Unpublished report. USFWS. Fairbanks, AK.

Swaney, C. 2011. Subsistence user, resident Arctic Village. Personal communication: phone. July 2011.

Van Lanen, J.M., C. Stevens, C.L. Brown, K.B. Maracle, and D.S. Koster. 2012. Subsistence land mammal harvests and uses, Yukon Flats, Alaska: 2008–2010 harvest report and ethnographic update. ADF&G, Division of Subsistence Technical Paper No. 377. Juneau, AK. http://www.adfg.alaska.gov/sf/publications/index.cfm?ADFG=addLine.homeVoss 2011, pers. comm.

Wald, E. 2012. Sheep survey summary for the Arctic Village Sheep Management Area, June 2012. Arctic National Wildlife Refuge. Unpublished Report. USFWS. Fairbanks, AK.

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APPENDIX 1 REGULATORY HISTORY

At the beginning of the Federal Subsistence Management Program in Alaska in 1990, existing State regulations were adopted into Temporary Subsistence Management Regulations (55 Fed. Reg. 126. 27117 [June 29, 1990]). The customary and traditional use determination for sheep in Unit 25A was for residents of Arctic Village, Chalkyitsik, Fort Yukon, Kaktovik, and Venetie. The Board has not received a proposal to modify the determination.

In 1991, Proposal 75 was submitted by the Yukon Flats Fish and Game Advisory Committee and Proposal 100A by the Arctic National Wildlife Refuge. The Board met in March 1991 and based on the submitted proposals took action to propose new regulations and published them in the Federal Register (56 Fed. Reg. 73 15433 [April 16, 1991]2). At its meeting in March 1991, the Board acted on Proposals 100A and 75.

The Chair stated,

As far as the Board’s concerned, our first compliance is—or obligation—is compliance with the Federal [regulations], that will be its guiding principle that will be used by the Board. It considers this responsibility for various recommendations and proposals. The policy is that the State will reassume full responsibility to manage fish and game subsistence use on Federal lands, and that will be a principle that will guide the coming decisions of the Board. In keeping with that, we will want to minimize actions that will duplicate or complicate the State’s resumption of the program. However, there are certain things that are happening that will cause us to make some decisions that may do that to some extent, but those will be well-discussed, well-considered, and well-calculated before we have to do that. So those are some of the general guidance policies that the Board will function under (FSB 1991c:5–6).

Proposal 100A requested the Board to close Federal public lands in an area of Unit 25A encompassing most of the contemporary Arctic Village Sheep Management Area, modify the harvest limit from one mature ram to 2 rams and extend the hunting season to April 20. The northern boundary of the area was the mainstem of Cane Creek. The area did not include areas north of Cane Creek, including Red Sheep Creek. Regional Advisory Councils did not meet until fall 1993, and there were no Council recommendations for the Board to consider. The Board adopted the Interagency Staff Committee recommendation and adopted the proposal with modification. The modification was to extend the hunting season to April 30. The justification was that portions of the area did not appear to be able to support more sheep than were currently present, the population of sheep in the Red Sheep Creek drainage was of much higher densities and could continue to support the then existing seasons and harvest limits, the Red Sheep Creek drainage

2 The Federal Register notice mistakenly included both the existing regulation (1 ram with 7/8 curl horn or larger, Aug. 10–Sept. 20) as well as the proposed regulation.

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received quite a bit more effort than other areas of Unit 25A, and the remainder of Unit 25A supported a substantial opportunity for all hunters (FSB 1991b:150–164; 56 Fed. Reg. 123. 29344 [June 26, 1991]).

Proposal 75 requested that the Board close to the harvest of sheep except by Federally qualified subsistence users the drainages of Junjik River, East Fork Chandalar River, Red Sheep Creek, Cane Creek, Water Creek, Spring Creek, Ottertail Creek, and Crow Next Creek. The Board adopted the Interagency Staff Committee recommendation and rejected the proposal because of its earlier action taken on Proposal 100A, described above (FSB 1991b:164–168).

In June 1991, the Board met and considered comments (called “proposals”) received during the public comment period on the specific season and harvest limit changes which were a part of the proposed rule resulting from the March 1991 meeting. Proposals 09, 10, and 11 were submitted by the Arctic Village Council and Proposal 21 was submitted by Brooks Range Arctic Hunts.

In Proposal 09, the Arctic Village Council requested the Board to include Cane Creek and Red Sheep Creek drainages in the Arctic Village Sheep Management Area that was closed to the harvest of sheep except by Federally qualified subsistence users. The proponent said that the area set aside did not include all of the areas that must be included to accommodate customary and traditional uses of sheep by residents of Arctic Village (OSM 1991). The Board adopted the Interagency Staff Committee recommendation and rejected the proposal. The Board said Arctic Village residents used Cane Creek and Red Sheep Creek only for a short time when air taxi service was available. These two areas could support both subsistence and sport harvest (FSB 1991a:297–299). Proposals 10 and 11 requested that the Board eliminate harvest limits in the Arctic Village Sheep Management Area (Proposal 10) or increase the harvest limit to 3 sheep (Proposal 11). The Board adopted the Interagency Staff Committee recommendations and rejected both proposals. The Board said the sheep population in the Sheep Management Area was extremely low and the proposed regulations would jeopardize the continuation of healthy populations of sheep (FSB 1991a:299– 301). The Board adopted the Interagency Staff Committee recommendation and also rejected Proposal 21, which requested the Board to open the Sheep Management Area to the harvest of sheep by non-Federally qualified users. The Interagency Staff Committee said that the sheep population was extremely low, and subsistence users must be afforded a priority (OSM 1991).

In 1992, Wildlife Request for Reconsideration (WRFR) 92-23 was submitted by the Arctic Village Council requesting that the Board reconsider its decision on Proposal 9, which if adopted would have added Cane Creek and Red Sheep Creek drainages to the Arctic Village Sheep Management Area. The Board did not act on the request until 1993 when it received Proposal 58 from the Arctic Village Council requesting that the Board add Cane Creek and Red Sheep Creek drainages to the Management Area and implement a community harvest limit. At its meeting in April 1993, the Board adopted the Interagency Staff Committee recommendation and rejected the proposal. The Board said that Cane Creek and Red Sheep Creek drainages supported adequate sheep to support harvest by non-Federally qualified users and that not enough data was available on harvest levels to support community harvest or reporting systems (FSB 1993:140–512).

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In 1995, Proposal 54 was submitted by the Arctic Village Council requesting that the Board add Cane Creek and Red Sheep Creek drainages to the Arctic Village Sheep Management Area. The Eastern Interior Council took no action on the proposal (EIASRAC 1995:88–97, OSM 1995a:359). The North Slope Subsistence Advisory Council (North Slope Council) recommended that the Board adopt the proposal (NSSRAC 1995:206, OSM 1995a:359). The Board adopted the proposal with modification. The modification was that the Board would revisit the proposal in another year. The Board said that although there was no biological reason for closing Cane Creek and Red Sheep Creek drainages to the harvest of sheep except by Federally qualified subsistence users, it had heard substantial testimony regarding the fact that due to the customary and traditional hunting practices of the residents of Arctic Village, not adopting the proposal would deny a subsistence opportunity to the residents of Arctic Village (FSB 1995:611–634, 686–693; 60 Fed. Reg. 115. 31545 [June 15, 1995]).

In 1995, WRFR 95-06 was submitted by the Alaska Department of Fish and Game (ADF&G) requesting that the Board reconsider its decision on Proposal 54. The Board rejected the request in July 1995 (OSM 1995b). ). The Board determined that the request was not based on information that was not previously considered by the Board, or that demonstrated that the existing information used by the Board was incorrect, or that demonstrated that the Board’s interpretation of information, applicable law, or regulation was in error or contrary to existing law. One of these factors would need to be present for the Board to reconsider its decision, as described in regulation (50 CFR 100.20).

In 1996, Proposal 55 was submitted by ADF&G. It requested that the Board open Cane Creek and Red Sheep Creek drainages to the harvest of sheep by non-Federally qualified users. The Eastern Interior Council recommended opposing the proposal. The Eastern Interior Council said it had heard no compelling evidence to overturn recent Board action closing these drainages. Opposition to the proposal came before the Council from an Arctic Village resident’s testimony, a letter from the Arctic Village Council, and from the Council’s representative from Arctic Village. The Council affirmed its support for the existing Arctic Village Management Area. The North Slope Council recommended deferring action for one year until more information concerning Kaktovik residents’ use of the Management Area was available, however, the Council expressed desire to “defer to wishes of their neighbors to the south” (OSM 1996:12). The Board rejected the proposal referring to its action on Proposal 54 the previous year in 1995, described above, and that there had still been no dialogue between the State and Arctic Village (FSB 1996:20).

This Regulatory History contains more information on each regulatory proposal below than above. This is because official records of Council and Board justifications were kept after 1995. Justification for Board actions that were provided in letters to the Councils, as mandated in ANILCA Section 805(c), were reviewed and compared to transcripts and provide an accurate description of the Board’s justifications.

In 2006, Proposal WP06-57 was submitted by ADF&G. It requested that the Board open the Arctic Village Sheep Management Area to the harvest of sheep by non-Federally qualified users. The Eastern Interior Council recommended opposing the proposal and said that it needed to see results from sheep population surveys before considering reopening to non-Federally qualified hunters. The Council said that people of Arctic Village were totally dependent on the land for food for their nutritional and cultural needs. The Council said managers cannot only depend on harvest tickets for harvest information. It continued that

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In 2006, Wildlife Special Action Request WSA06-03 was submitted by the U.S. Fish and Wildlife Service. It requested that the Board open Cane Creek and Red Sheep Creek drainages to the harvest of sheep by non-Federally qualified users from Aug. 10 through Sept. 20, 2006. The Board approved the request. It said it reviewed new information on sheep abundance in the Arctic Village Sheep Management Area from a survey conducted by the Service in June 2006 and presented in an assessment report. During the course of its consideration, the Board said it received an excerpt from the transcript of the May 2006 meeting of the Board relative to consideration of this issue concerning Proposal WP06-57, a staff analysis prepared by OSM, ADF&G comments, and written and telephonic public testimony (OSM 2017).

In 2007, Proposal WP07-56 was submitted by ADF&G. It requested that the Board open Cane Creek and Red Sheep Creek drainages to the harvest of sheep by non-Federally qualified users from Aug. 10 through Sept. 20. The Eastern Interior Council recommended the Board defer action on the proposal for one year to allow formation of a working group of representatives from affected villages, hunting interests, and agencies to decide what an acceptable sheep harvest or number of sheep hunters would be in this area, and then draft a proposal to the Alaska Board of Game for its March 2008 meeting. The Council said the proposal could contain the number of non-Federally qualified hunters to be allowed to hunt in the Cane Creek and Red Sheep Creek area. The Council said the working group timeline would give the Federal Subsistence Board time to monitor the progress of the working group, the Board of Game proposal(s), and the actions of the Board of Game before the Federal Subsistence Board met later in the spring of 2008. The Council said it had received testimony from Arctic Village sheep hunters, local elders, and Arctic Village Tribal Council members who all had requested the closure of the Red Sheep and Cane Creek area remain in effect. Testimony included the cultural importance of the area because of burial sites, allotments, and a traditional area where they hunt sheep, and that they would not be able to compete with other hunters if the area was opened to other hunters. The Council said testimony also included the high cost of accessing the area and the difficulty reaching the area other than by aircraft. Council members discussed the relationship of caribou migrations and the need to hunt for sheep as well as the desired time to harvest sheep. When

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caribou and moose are plentiful, local hunters do not hunt for sheep, but when caribou and moose are not plentiful, they depend on sheep. The Council shared that the last time a similar proposal to open the area to other hunters was submitted, the Council had unanimously opposed it and was overridden by the Board. The Council sympathized with Arctic Village concerns, but it believed the closure of the Cane Creek and Red Sheep Creek drainages would be lifted by the Board based on its action with the recent special action to open the area (WSA06-03, which the Board approved). Several Council members worked with village leaders to see what options were available to limit the number of other hunters allowed to hunt in the area, hence the recommendation to defer to a working group (OSM 2007a). The North Slope Council recommended the Board oppose the proposal. The Council said that there was no evidence that passage of this proposal would not impact villages. The Council said resource needs should be assessed to ensure subsistence users’ needs were being met at each village. The sheep population was so small, it could not support harvest by commercial and sport hunters (OSM 2007a).

The Board adopted the proposal. The Board said that Section 815(3) of ANILCA only allows restrictions on the taking of fish and wildlife for nonsubsistence uses on Federal public lands if necessary for the conservation of healthy populations of fish and wildlife, to continue subsistence uses of such populations, or pursuant to other applicable law. Maintaining the Federal closure to nonsubsistence hunting of sheep in the Red Sheep Creek and Cane Creek drainages was no longer necessary for the conservation of a healthy sheep population. Allowing sheep hunting by non-Federally qualified users in these drainages would not adversely affect the sheep population because these hunters would be limited to taking one full-curl ram in the fall season. Removal of some full-curl rams from the population was not expected to reduce the reproductive success of the sheep population. Maintaining the closure to nonsubsistence hunting of sheep in these drainages was also not necessary to provide for continued subsistence use of sheep. The sheep population could support harvest by both subsistence and nonsubsistence hunters. The existing closure was also not justified for reasons of public safety, administration, or pursuant other applicable law (OSM 2007b).

In 2012, Proposal WP12-76 was submitted by the Eastern Interior Council. It requested that the Board close Cane Creek and Red Sheep Creek drainages to the harvest of sheep by non-Federally qualified users from Aug. 10 through Sept. 20. The Eastern Interior Council recommended the Board support the proposal. The Council said the proposal enhanced the ability of the residents of Arctic Village to pursue subsistence opportunities and might reduce incidents of trespass and resource damage. The Council said it appreciated the information provided during public testimony and recognized the powerful connection between residents of Arctic Village and the subject area as one that was deeply culturally rooted. The Council said it was compelled by extensive and detailed public testimony and that subsistence users were concerned that nonsubsistence users were interfering with subsistence users, particularly the people of Arctic Village. The North Slope Council recommended the Board support the proposal. The Council said that the amount of travel time by rural residents was a concern due to distance required to travel and the cost of fuel. The Board adopted the proposal (OSM 2012a:355). The Board said there was no conservation concern, and the closure was needed to ensure the continuation of traditional subsistence uses of sheep by Arctic Village hunters (OSM 2012b:7).

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In 2014, Proposal WP14-51 was submitted by the State of Alaska. It requested the Board to open Cane Creek and Red Sheep Creek drainages to the harvest of sheep by non-Federally qualified users from Aug. 10 through Sept. 20. It also requested that hunters be required to complete a course on hunter ethics and an orientation course, including land status and trespass information. The Eastern Interior Council recommended the Board oppose the proposal. The Council said it had heard extensive testimony from tribal and community members form Arctic Village and Venetie expressing the importance of sheep in this area to their culture and community. The Council said that the public testimony also noted that air traffic disturbance and hunter activity was pushing sheep further away and higher. The Council said that the cultural importance of the sheep and the area to Arctic Village and other residents for this hunt area was their overriding concern. The North Slope Council recommended the Board oppose the proposal. The Council said deflection or disturbance of sheep by sport hunters and aircraft flights made it difficult for Arctic Village residents to reach sheep for subsistence hunting. The Council said these sheep were a very important subsistence food that was shared in the community, and even if local harvest numbers were not high, effort to reach the animals was considerable and the sharing of the meat and organs was widespread and important. The Council said these sheep and this location had special cultural and medicinal value due to the history and relationship of the community as well the mineral licks that the sheep frequented in this area, which made their meat contain unique qualities (OSM 2014a:350).

The Board rejected Proposal WP14-51. The Board rejected this proposal based on the OSM analysis and conclusion, the recommendations of the North Slope and Eastern Interior Councils, and overwhelming public comment over the years and the testimony presented to the Board in the 2012 review of a similar proposal. The Board referenced extensive public testimony of local community concerns and cultural importance of this area and the long established administrative record on this issue. The Board recognized the cultural importance of the Cane Creek and Red Sheep Creek areas for subsistence harvest of sheep for the residents of Arctic Village and Venetie. The Board said the importance of this area was also known by the number and location of Native allotments, cultural sites, and ethnographic studies documenting the long history of use in this area (OSM 2014b:3).

Furthermore, the Board said it had heard testimony and reports that subsistence users attempts to harvest sheep in this area may have been interfered with by aircraft and nonsubsistence hunter activity. The Board concurred with this testimony that the activities in this area by nonsubsistence users had resulted in the displacement of sheep, pushing them out of range and preventing subsistence hunters from being able to harvest sheep. The Board supported keeping the closure in place to help insure the continued subsistence use of sheep for residents of Artic Village, Venetie, and the several other villages with customary and traditional use determinations for sheep in this area: Chalkyitsik, Fort Yukon, and Kaktovik. The Board said that this closure was based on ANILCA Section 815(3), which allows for a restriction on the taking of fish and wildlife for nonsubsistence uses on public lands when necessary to continue Federal subsistence uses (OSM 2014b:3).

In 2014, WRFR14-01 was submitted by the State of Alaska requesting that the Board reconsider its actions on Proposal WP14-51, described above. In September 2015, the Board denied the request (OSM 2017). The Board determined that none of the claims in the request met the criteria to warrant further reconsideration, as set forth in 50 CFR Part 100.20.

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In 2018, Proposal WP18-56 was submitted by Frank Bishop of Fairbanks requesting that the Board open the Arctic Village Sheep Management Area to the harvest of sheep by non-Federally qualified users. The Eastern Interior Council supported the proposal with modification to open the area north of Cane Creek only. The Council said that the only legitimate reasons under Title VIII of ANILCA to restrict or eliminate the use of a resource on Federal public lands by nonsubsistence users are conservation concerns and/or detrimental effects on satisfaction of subsistence needs. The Council recognized that the issue was of cultural concern and felt that “cultural or social issues” are not a legitimate reason to close the area under provisions of ANILCA. The closing of the Arctic Village Sheep Management Area to the harvest of sheep by nonsubsistence users only affects sheep hunters. All other types of visitors to the area, including hikers, wildlife photographers, and flight site-seers, have been allowed to use the area. The Council stated that they consider this issue to be a “political football” and were very disappointed to find out that it was not resolved and was on the table again. The Council felt that sheep conservation was very important and encouraged Federal and State governments to work together on this regulatory issue. The Council also suggested requiring a specially designed, respectful hunter education course for users who would hunt in this area. The Council felt that learning respect for other people uses and for the resource is very important, as well as learning and understanding other cultures. The Red Sheep Creek area is an important cultural place, and Alaska Native cultures value the world and wildlife very differently than Euroamerican culture. The importance of a certain area in the Alaska Native culture does not have to manifest itself in a substantial harvest. To alleviate some potential conservation concerns the Council modified the proposal to only open the area north of Cane Creek, including the Red Sheep Creek drainage (OSM 2018a).

The North Slope Council opposed Proposal WP18-56. The Council found this proposal alarming in that it could potentially take away a very important subsistence priority on Federal land that despite being small in size, has been vital to the community of Arctic Village for generations and was very important to other rural communities in the region with cultural and traditional use of sheep in this area. The Council said it would be detrimental to subsistence users to open up the area to non-Federally qualified user hunting, and it was necessary to restrict these other uses in order to provide for subsistence needs. The Council highlighted that there is a considerable amount of historical discussion, and the importance of this area to the local communities is well-supported. There was need for stability and for food security in these communities. The importance of protecting the subsistence opportunity in this area was well documented and recognized even through repeated proposal reviews. The historic and contemporary hunting patterns exist to provide food security to the community, and the closure had allowed for the continued traditional harvest of sheep. The Council also stressed that the concern was not only the harvest of sheep by non- Federally qualified users, but also the deflection of these sheep with the nonresident hunting activity and plane access pushing sheep further and higher up into the mountains, displacing them away from the local community. The Council stated it had heard testimony from Arctic Village as well as Kaktovik in the past. It was noted that hunters from Kaktovik hunted in this area when other animals were not available, and it was an important area because sheep have been reliably found around the natural mineral formations in that small area (OSM 2018a).

North Slope Council members spoke to the cultural importance of this area and that the sheep not only provided important subsistence food but were also considered medicinal, providing minerals and special nourishment for elders and helpful for recovery from illness. It was noted that sheep become more

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Wildlife Proposal WP20-49 DRAFT Staff Analysis important for survival food when caribou do not come around the community, and even if harvest is low in some years it is critical to maintain the population for food security when people need to shift harvest to more sheep in low caribou years. The Council stressed that the sheep population needs to be higher in order to provide for opening up the hunt and currently the census data is incomplete and unreliable. It was noted that even though non-Federally qualified users would be required to take a full-curl ram, the pressure of numerous hunters traveling into the area to harvest those rams would displace animals that locals would otherwise have been able to hunt. Additionally, the breeding impact of that lone, full-curl ram was important in a sheep population that was struggling, and when there were concerns about recruitment and stabilizing the population (OSM 2018a).

The Federal Subsistence Board rejected Proposal WP18-56. The Board stated that the Arctic Village Sheep Management Area needs to remain closed because of the significant religious and cultural importance of that area and to support the continuation of the subsistence uses by the area’s residents. The Board also encouraged the State to come up with suggestions or a proposal to resolve this issue during the next wildlife regulatory cycle (OSM 2018b).

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WP20–50 Executive Summary

General Description Wildlife Proposal WP20-50 requests that Federal and State hunt areas, seasons, and harvest limits for moose in Unit 12 remainder be more closely aligned to reduce user confusion. Submitted by: Eastern Interior Alaska Subsistence Regional Advisory Council.

Unit 12—Moose Proposed Regulation

Unit 12, that portion within the Tetlin Aug. 24–Sep. 30. National Wildlife Refuge and those lands Nov. 1–Feb. 28. within the Wrangell-St. Elias National Preserve north and east of a line formed by the Pickerel Lake Winter trail from the Canadian border to Pickerel Lake—1 antlered bull by Federal registration permit

Unit 12, that portion east of the Nabesna Aug. 24–Sep. 30. River and Nabesna Glacier, and south of the Winter Trail running southeast from Pickerel Lake to the Canadian border—1 antlered bull

Unit 12, remainder that portion within the Aug. 20–Sep. 20. Nabesna River drainage west of the east bank of the Nabesna River upstream from the southern boundary of Tetlin National Wildlife refuge—1 antlered bull by joint Federal/State registration permit only

Unit 12, that portion within the Tok River Aug. 24–Aug. 28. drainage upstream of a line from Peak Sept. 8–Sept. 17. 5885 at 63° 9.243 N. Lat., 143° 24.248 W. long., to MP 105 of the Glenn Highway (Tok Cutoff) at 63° 7.438 N. Lat., 143° 18.135 W. Long., then south along the Glenn Highway (Tok Cutoff) to the Little Tok River Bridge at mile 98.2; and within the Little Tok River drainage up-stream of the Little Tok River Bridge at mile 98.2 – 1

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WP20–50 Executive Summary

bull with spike-fork or 50-inch antlers or antlers with 4 or more brow tines on at least one side.

Unit 12, remainder – one bull Aug. 24–Aug. 28. Sept. 8–Sept. 17.

OSM Preliminary Conclusion Support Proposal WP20-50.

Southcentral Alaska Subsistence Regional Advisory Council Recommendation

Eastern Interior Alaska Subsistence Regional Advisory Council Recommendation

Interagency Staff Committee Comments

ADF&G Comments

Written Public Comments 1 Support

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DRAFT STAFF ANALYSIS WP20-50

ISSUES

Wildlife Proposal WP20-50, submitted by the Eastern Interior Alaska Subsistence Regional Advisory Council (Council), requests that Federal and State hunt areas, seasons, and harvest limits for moose in Unit 12 remainder be more closely aligned to reduce user confusion.

DISCUSSION

The Council states that currently, Bureau of Land Management (BLM) lands in Unit 12 remainder have different seasons and antler restrictions under State and Federal regulations. The proponent affirms that because these BLM lands encompass small areas and are dispersed throughout the Unit 12 remainder hunt area, it is impractical for users to attempt to differentiate land ownership. The Council mentions that this proposal would further align Federal and State hunt areas, seasons, and harvest limits, which would reduce user confusion in the unit.

Existing Federal Regulation

Unit 12—Moose

Unit 12, that portion within the Tetlin National Wildlife Refuge and Aug. 24–Sep. 30. those lands within the Wrangell-St. Elias National Preserve north and Nov. 1–Feb. 28 east of a line formed by the Pickerel Lake Winter trail from the Canadian border to Pickerel Lake—1 antlered bull by Federal registration permit

Unit 12, that portion east of the Nabesna River and Nabesna Glacier, Aug. 24–Sep. 30. and south of the Winter Trail running southeast from Pickerel Lake to the Canadian border—1 antlered bull

Unit 12, remainder—1 antlered bull by joint Federal/State registration Aug. 20–Sep. 20. permit only

Proposed Federal Regulation

Unit 12—Moose

Unit 12, that portion within the Tetlin National Wildlife Refuge and Aug. 24–Sep. 30. those lands within the Wrangell-St. Elias National Preserve north and

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east of a line formed by the Pickerel Lake Winter trail from the Nov. 1–Feb. 28. Canadian border to Pickerel Lake—1 antlered bull by Federal registration permit

Unit 12, that portion east of the Nabesna River and Nabesna Glacier, Aug. 24–Sep. 30. and south of the Winter Trail running southeast from Pickerel Lake to the Canadian border—1 antlered bull

Unit 12, remainder that portion within the Nabesna River drainage Aug. 20–Sep. 20. west of the east bank of the Nabesna River upstream from the southern boundary of Tetlin National Wildlife refuge—1 antlered bull by joint Federal/State registration permit only

Unit 12, that portion within the Tok River drainage upstream of a line Aug. 24–Aug. 28. from Peak 5885 at 63° 9.243 N. Lat., 143° 24.248 W. long., to MP 105 Sept. 8–Sept. 17. of the Glenn Highway (Tok Cutoff) at 63° 7.438 N. Lat., 143° 18.135 W. Long., then south along the Glenn Highway (Tok Cutoff) to the Little Tok River Bridge at mile 98.2; and within the Little Tok River drainage up-stream of the Little Tok River Bridge at mile 98.2 – 1 bull with spike-fork or 50-inch antlers or antlers with 4 or more brow tines on at least one side.

Unit 12, remainder – one bull Aug. 24–Aug. 28. Sept. 8–Sept. 17. Existing State Regulation

Unit 12—Moose

Unit 12, that portion including Residents—One bull with spike-fork Aug 24–Aug 28 all drainages into the west bank or 50-inch antlers or antlers with 4 Sept 8–Sept 17 of the Little Tok River, from its or more brow tines on at least one head-waters in Bear Valley at side the intersection of the unit boundaries of Units 12 and 13 to Residents—One bull with spike-fork Aug 24–Aug 28 its junction with the Tok River, or 50-inch antlers or antlers with 4 Sept 8–Sept 17 and all drainages into the south or more brow tines on at least one

bank of the Tok River from its side, by permit, available only by 2 junction with the Little Tok River application.

to the Tok Glacier 1 Nonresidents—One bull with Sept 8–Sept. 17

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50-inch antlers or antlers with 4 or more brow tines on at least one side

Unit 12, remainder of that Residents—One bull with spike-fork Aug 24–Aug 28 portion within the Tok River or 50-inch antlers or antlers with 4 Sept 8–Sept 17 drainage upstream of a line from or more brow tines on at least one Peak 5885 at 63° 9.243 N. Lat., side

143° 24.248 W. long., to MP 105 of the Glenn Highway (Tok Nonresidents—One bull with Sept 8–Sept 17 Cutoff) at 63° 7.438 N. Lat., 143° 50-inch antlers or antlers with 4 or 18.135 W. Long., then south more brow tines on at least one side along the Glenn Highway (Tok Cutoff) to the Little Tok River Bridge at mile 98.2; and within the Little Tok River drainage up-stream of the Little Tok River Bridge at mile 98.2

Unit 12, east of the Nabesna Residents and Nonresidents—One Sept 1–Sept 30 River and south of the winter bull with 50-inch antlers or antlers trail running southeast from with 4 or more brow tines on at Pickerel Lake to the least one side U.S./Canada border

Unit 12, that portion within the Residents—One bull with spike-fork Aug 20–Sept 17 Nabesna River drainage west of antlers or antlers with 3 or more the east bank of the Nabesna brow tines on at least one side by

River upstream from the permit available in person in southern boundary of Tetlin Anchorage, Fairbanks, Glennallen, National Wildlife Refuge Palmer, Slana Ranger Station, and Tok beginning Aug 2 – Permit RM291

Nonresidents—One bull with Aug 20–Sept 17 50-inch antlers or antlers with 3 or more brow tines on at least one side by permit available in person in Anchorage, Fairbanks, Glennallen, Palmer, Slana Ranger Station, and Tok beginning Aug 2 – Permit

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RM291

Unit 12, remainder – one bull Residents—One bull Aug 24–Aug 28 Sept 8–Sept 17

Nonresidents—One bull with Sept 8–Sept 17 50-inch antlers or antlers with 4 or more brow tines on at least one side

1 T R T R F A T T R T R

2 T

Extent of Federal Public Lands

Unit 12 is comprised of approximately 60% Federal public lands and consist of 48% National Park Service (NPS), 11% Fish and Wildlife Service (FWS), and 1% BLM managed lands (Figure 1).

Note: For more information pertaining to hunt area boundaries and Federal public lands located in the current Unit 12 remainder hunt area and the proposed hunt areas, please see the “Effects of the Proposal” section of this document.

Customary and Traditional Use Determinations

Rural residents of Units 11 north of the 62nd parallel, 12, 13A, 13B, 13C, 13D and residents of Chickaloon, Dot Lake, and Healy Lake have a customary and traditional use determination for moose in Unit 12 remainder.

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Figure 1. F

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Regulatory History

Federal and State moose hunting regulations in Unit 12 have changed numerous times since 1989. Federal seasons and harvest limits have most often been changed in response to the State’s establishment, modification, and/or subsequent discontinuance of spike-fork seasons. State and Federal regulations for the remote hunt area south of the Pickerel Lakes Winter Trail remained consistent until the Alaska Board of Game (BOG) added the unit-wide Aug. 20–28 spike-fork season in 1995, and the Federal Subsistence Board (Board) followed suit in 1996. In 1998, the BOG opened the Unit 12 spike-fork season on August 15 — five days earlier. In 1999, the Board aligned Federal regulations with the longer State season.

The BOG continued to modify moose regulations in Unit 12 throughout the 2000s. In March of 2000, the BOG adopted Proposal 38, submitted by the Alaska Department of Fish and Game (ADF&G), which changed the State’s Unit 12 moose hunting season into a five day August season and a ten day September season. In March of 2012, the BOG adopted Proposal 186 with modification, to change the hunting seasons and harvest limit of moose in portions of Units 11 and 12. In Unit 12, this added a resident and nonresident bull (with antler restrictions) registration hunt (RM291) season from Aug. 20–Sept. 17 in a new hunt area located in the western portion of the Nabesna River Drainage (Wells 2014). In 2017, the BOG adopted Proposal 88, which clarified the antler-restricted moose hunting area within the Tok River drainage.

Federal regulations have also changed multiple times since 2000. Due to conservation concerns expressed by ADF&G and the Tetlin National Wildlife Refuge (NWR), the Council submitted Proposal WP01-41, requesting changes to the fall season dates (from Aug. 15–Aug. 28 and Sept. 1–Sept. 15 to Aug. 24–Aug. 28 and Sept. 8–Sept. 17) and removal of the August spike-fork season from the Tetlin NWR hunt area (FM1203 hunt area) portion of Unit 12. The Board adopted the proposed regulations for the 2001/02 regulatory year.

Throughout the subsequent years, the Board took action on many proposals concerning moose in Unit 12. In May 2003, the Board adopted Proposal WP03-45 with modification, establishing new dates for the fall moose season (from Aug. 15–Aug. 28 and Sept. 1–Sept. 30 to Aug. 24–Sept. 30) and paralleled State actions eliminating the spike-fork season, in that portion of Unit 12 east of the Nabesna River and the Nabesna Glacier, and south of the Winter Trail running southeast from Pickerel Lake to the Canadian border (Unit 12 southern hunt area). The Board adopted Proposal WP06-59 in 2006 to clarify moose regulations in Unit 12. This proposal simplified the language for hunt area boundaries within the unit to reduce user confusion. In 2006, WP06-60 was also adopted with modification to eliminate the spike fork antler restriction in Unit 12 remainder during the Aug. 24–28 and Sept. 1–17 portion of the season while maintaining the restriction during the Aug. 15–23 season. In 2007, the Board adopted WP07-57 with modification, which changed the winter season dates (from Nov. 20–Nov. 30 to Nov. 20–Dec. 10) in the FM1203 hunt.

The Board addressed multiple proposals concerning moose in Unit 12 during the 2012 regulatory cycle. The Board adopted Proposal WP12-71/72 with modification to extend the winter season in the Tetlin NWR hunt area portion of Unit 12 from Nov. 20–Dec. 10 to Nov.1–Feb. 28 and extend the fall season from Aug.

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24–Aug. 28 and Sept. 8–Sept. 17 to Aug. 24–Sept. 20, while also maintaining the Federal registration permit requirement for the winter season. The same year, Proposal WP12-70/73 was also adopted with modification to align the Unit 11 and Unit 12 remainder moose seasons to Aug. 20–Sept. 20, and create a joint-State/Federal registration permit for a portion of Unit 11 (that portion draining into the east bank of the Copper River upstream from and including the Slana River drainage) and Unit 12 remainder. At the time this was adopted, this (and BOG Proposal 186) aligned the hunt areas in which the joint-State/Federal registration permit would be used. This is because, in 2012, NPS lands were the only Federal public lands located in Unit 12 remainder because the BLM lands currently located in this hunt area were still selected lands, at that time. Additionally in 2012, a Wildlife Special Action Request (WSA12-05) was submitted by Wrangell-St. Elias National Park and Preserve (WRST) to extend the moose season for the Batzulnetas Culture Camp (applies to both Unit 11 and Unit 12) by 31 days, changing the season end date from July 31 to August 31, 2012. This request was unanimously approved by the Board.

In 2018, the Board rejected Proposal WP18-55, which requested a longer harvest season for the Tetlin NWR hunt area. This proposal was opposed due to the low bull:cow ratios east of the Nabesna River.

Biological Background

Habitat

Moose rely on willow and shrub habitats for browsing and for cover from predators, and typically select areas with habitat heterogeneity (Maier et al. 2005) to meet their nutritional and shelter needs. Wildfire (the primary driver of boreal forest succession and habitat heterogeneity; Maier et al. 2005) frequency is forecast to increase as the Arctic climate warms, causing projected moose habitat to increase (Joly et al. 2012). Moose occur in greater densities in areas where fire has occurred within the past 11-30 years (Maier et al. 2005). Due to changes in climate, connectivity between moose populations is expected to increase as populations expand to make use of habitat expansion (Schmidt et al. 2008, Tape et al. 2016).

In Unit 12, moose typically inhabit areas below 4,500 feet with extensive river margin (Maier et al. 2005, Wells 2014, 2016). Approximately 6,000 mi2 is categorized as suitable moose habitat within the unit, with approximately 5,250 mi2 available in the winter and 6,572 mi2 available in the summer (Wells 2014, 2016, 2018a). The southern and western portions of Unit 12 include more high elevation mountainous areas and lowland valleys that are dominated by spruce forest that transition to shrub communities (Wells 2018a). Past research has shown that the Tok River drainage contains important habitat for moose in Unit 12 and that the lower Tok River valley, specifically, serves as an important wintering area for the species (Wells 2018a).

Ecosystems can be modified by moose foraging (Maier et al. 2005, Schmidt et al. 2009) and thus, habitat and browse surveys are an important component of wildlife monitoring and management. In Unit 12, browse surveys have been conducted periodically since the 1970s (Wells 2014). Although fire suppression has led to many areas of potentially good moose habitat becoming dominated by spruce forest, browse surveys have shown that use of preferred browse species in the unit is low relative to availability (Wells 2014). During these surveys, it was noted that early successional species of browse were used far more than species in undisturbed areas. Habitat was not found to be a limiting factor on the moose

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Population Management

State moose management goals for Unit 12 include protecting the moose population in conjunction with enhancing ecosystem function, maintaining subsistence use of moose, maximizing moose hunting opportunities, and maximizing nonconsumptive use opportunities for moose (Wells 2014, 2016, 2018a). The State management objective for moose in Unit 12 is to maintain a post hunt ratio of 40 bulls:100 cows east of the Nabesna River, and a bull:cow ratio of 25:100 in the remainder portion of the unit (Wells 2014, 2016, 2018a).

Tetlin NWR began collaborating with ADF&G to collect moose population data in Unit 12, shortly after the refuge was established in 1981 (Collins et al. 2005: 3). Similarly, the NPS also collaborates and assists with moose survey efforts throughout Unit 12 (Wells 2018a). An estimate of 4,300–5,600 moose was determined in 2008 using fall Geospatial Population Estimation (GSPE) survey data extrapolated to unsurveyed areas (ADF&G 2017a). This is a slight increase from the 2003 estimate of 2,900–5,100 moose (ADF&G 2017a). Moose densities vary widely throughout the unit, ranging from approximately 0.03 moose/mi2 in Northway Flats to >2 moose/mi2 by the north side of the Nutzotin Mountains, in the Chisana survey area (Figure 2; ADF&G 2017a).

Region and habitat specific surveys have been conducted since the 2008 population survey (Table 1), with unit-wide estimates being extrapolated from regional data. The Tetlin NWR portion (included in the southeastern Unit 12 survey area; Figure 2) of Unit 12 was surveyed in November of 2012 along with the northern and northwestern sections (excluding WRST) of the unit. GSPE surveys conducted in these areas produced an estimate of 4,773 moose (Wells 2014). This data was then extrapolated to the rest of the 6,000 mi2 of estimated moose habitat within Unit 12 to develop an observable moose population estimate of 4,883–6,571 (0.8-1.1 moose/mi2) (Wells 2014). Similarly, data collected throughout the unit from 2010– 2014 was summarized to develop a unit-wide observable November population estimate of 4,492–6,444 moose (Wells 2016, 2018a). However, it should be noted, that this should be considered a rough estimate of the overall Unit 12 moose population.

Surveys are only conducted in each survey area approximately every three or four years, which can make it difficult to determine and respond to population trends in a timely manner (Wells 2016, 2018a). In 2017, a population survey was conducted in the Northwestern survey area in Unit 12. This survey produced a population estimate of 4,081 (1.47 moose/mi2). In 2018, a survey was completed in the Northwestern Unit 12 any-bull analysis area, which is a subsection of the Northwestern survey area. This survey produced a lower moose population estimate, for this specific area, than previous surveys, but overall the moose population in this area appeared to be stable (ADF&G 2019a; Table 1). Moose densities appear to have been relatively stable within the Southeastern and Northwestern survey areas since 2008, and are expected to remain stable throughout most of the unit (Wells 2016, ADF&G 2017a).

Current estimated unit-wide bull:cow ratios are below the management goal of 40:100 east of the Nabesna River and above the management goal of 25:100 in the remainder of the unit (Wells 2016, 2018b pers.

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comm., ADF&G 2017a). A majority of the moose harvest takes place near the highway system and the Tok, Little Tok, and Tanana Rivers due to easy access. In these heavily hunted areas, the bull:cow ratio dropped in the past, but this ratio has improved since antler restrictions were put in place in portions of the unit in 1993(ADF&G 2017a).

The most recent comprehensive composition surveys took place in November 2017 and included the portion of Unit 12 east of the Nabesna River and the Unit 12 Northwestern survey area. These surveys produced an estimate of 28 bulls:100 cows east of the Nabesna River, which is below the objective of 40 bulls:100 cows, and is much lower than the 2012 estimate of 46 bulls:100 cows (ADF&G 2018, Wells 2018b pers. comm.). These surveys also produced an estimate of 27 bulls: 100 cows in the Northwestern survey area, which is slightly above the objective of 25 bulls: 100 cows (ADF&G 2018, Wells 2018b pers. comm., Table 2).

A scaled down composition survey took place in a condensed Northwestern survey area, referred to as the Northwestern Unit 12 any bull analysis area, in 2018. This survey produced a bull:cow ratio of 30 bulls: 100 cows, which is above the State objective, and is very similar to estimates from the larger Northwestern area surveyed in 2012 and 2017 (Table 3; ADF&G 2019a). Composition appeared to remain stable since 2012 in the Northwestern survey area, although it may be important to track bull:cow ratios in this portion of Unit 12 in the future to ensure that bull:cow ratios remain above current objectives (ADF&G 2018, 2019a).

Table 1. T F – F ADF

Population Population Estimate Moose/mi² Survey Area Year Estimate (±90% CI) w/SCF with SCF R A

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Table 2. F ADF

Bulls:100 Calves:100 Percent Calves Adults Survey Area Year Cows Cows Calves Observed Observed Northwestern Unit 12 2003 25 32 19 111 464 2005 22 30 18 69 315 2006 37 41 21 185 688 2008 46 35 20 218 899 2012 29 27 16 133 650 2017 27 29 ------Southeastern Unit 12 2003 89 33 16 89 475 2004 70 48 20 89 351 2008 62 24 13 81 552 2012 52 18 9 65 634 2017 35 25 16 64 395 Nabesna Road 2011 34 27 14 75 476 Chisana Alaska Portion 2014 50 11 ------

Table 3. ADF

Population Estimate Bulls:100 Calves:100 Year Moose/mi² (±90% CI) Cows Cows

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Figure 2. ADF

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Harvest History

The State sustainable harvest rate for moose in Unit 12 is 3–4% (Wells 2014, 2018a). The Tok River drainage receives a considerable amount of the overall moose harvest in Unit 12 (Wells 2018a). Most of the unit is difficult to access, which leads to those areas near roads and rivers receiving higher harvest pressure than the rest of the unit. In Unit 12, an average of 130 moose have been harvested annually over the last 13 years, with 99 moose being harvested in 2018, the last year for which data are available (Table 4 and Figure 3; ADF&G 2017b, 2019b). This falls within the State sustainable harvest rate for the unit. Only one cow moose was reported harvested during the fall and winter seasons in this 13 year period, due to regulatory restrictions that only allow bull harvest and include antler restrictions, although an average of four cow moose were taken annually between 2011 and 2014 for use in potlatches (Wells 2016). In 2018, approximately 32% of the moose harvest was taken by users residing in Unit 12 and 35% was taken by all local users who have a cultural and traditional use determination for portions of Unit 12 (ADF&G 2017b, 2019b).

Table 4. R ADF ADF

Unit Non-Unit Total Unknown Nonresident Total Bull Cow Unknown Year Species Resident Resident Resident Residency Harvest Harvest Harvest Harvest Gender Harvest Harvest Harvest Harvest Total: 572 696 1268 317 9 1694 1677 1 16 Average: 44 54 98 32 1 130 129 0 1

Since 2012, an average of seven of the moose harvested in Unit 12 were harvested under the RM291 joint Federal/State registration permit, and an average of 121 moose were harvested under the general hunt, using a harvest ticket (Table 5, Table 6; ADF&G 2019b). These are the two main options for users harvesting moose in Unit 12 remainder (although the general hunt also covers the hunt area east of the Nabesna River and south of the Pickerel Lake winter trail, as well as the Unit 12 FM1203 hunt area if harvesting under State regulations). In 2018, only six moose were harvested under the RM291 permit in Unit 12 (ADF&G 2019b). Four of these moose were harvested by Federally qualified subsistence users

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and two were harvested by residents of Wasilla and Peters Creek (ADF&G 2019b). Conversely, 93 moose were harvested in Unit 12 under the general hunt in 2018, and only 31 of those moose were harvested by Federally qualified subsistence users (ADF&G 2019b).

180 Nonresident Harvest

160 Non-Unit Resident Harvest Unit Resident Harvest

140

120

100

80 Moose Harvested Moose

60

40

20

0 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 Regulatory Year

Figure 3. R ADF

Table 5. R R F ADF

Successful Unsuccessful Bulls Cows Unknown Year RM291 RM291 Hunters Harvested Harvested Gender Hunters

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Table 6. R ADF

Unsuccessful Successful Bulls Cows Unknown Year Hunters Hunters Harvested Harvested Gender

Harvest tickets are mandatory within Unit 12 when State or Federal registration permits are not required. These tickets require users to submit a report to track harvest throughout the unit. To increase the reporting rate for harvest tickets, ADF&G sends reminder letters to users who did not initially report their harvest (Wells 2014, 2018a). The State also conducts community household surveys in local communities, which helps assess unreported harvest.

A community household survey was completed in Unit 12 for 2011 in Tok. Based on this survey, 48 moose were recorded as being harvested by Tok residents (ADF&G 2011). This is greater than the overall harvest recorded (45 moose) in harvest reports for all local users in Unit 12 for 2011. Due to only 26% of Tok households being surveyed, the State used a conversion factor to develop an estimated harvest of 187 moose taken by Tok residents in 2011, some of which may not have been harvested in Unit 12 (ADF&G 2011, Holen et al. 2012).

Effects of the Proposal

The Unit 12 remainder hunt area, which would be split into multiple hunt areas if this proposal is adopted, is currently comprised of 25% Federal public lands (Figure 4). This includes 23% NPS lands and 2% BLM lands. This proposal would divide this hunt area into three separate hunt areas. These new hunt areas would include the Unit 12 RM291 permit hunt area, the Tok River drainage hunt area, and the new Unit 12 remainder hunt area (Figure 5). National Park Service lands would comprise 99% of lands in the new RM291 permit hunt area, where regulations would stay the same. Bureau of Land Management lands would comprise 3% of the new Tok River drainage hunt area. The new Unit 12 remainder hunt area would be comprised of 2% BLM lands.

Harvest limit and season changes that would be implemented throughout the new hunt areas may appear to be more complicated than current Federal regulations, but the proposed changes are what a majority of local users already follow due to the large percentage of non-Federal lands located in this area. Although this proposal would introduce antler restrictions and a shorter season in the new Tok River drainage hunt area under Federal regulations, it may not have a noticeable effect on Federally qualified subsistence users, due to the small amount of Federal public lands in this hunt area. Similarly, moose populations would most likely not be impacted by the more lenient harvest limit restrictions in the new Unit 12 remainder hunt area, due to the small amount of Federal public lands in this hunt area, and the proposed shorter harvest season. This would also limit the area where the RM291permit can be used under Federal regulations, to align with

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the State’s RM291 permit hunt area, and would leave the seasons for the RM291 hunt area misaligned under State and Federal regulations. Overall, these modifications would simplify regulations by further aligning with current State harvest limits, seasons, and hunt areas and, therefore, would allow users to reference landscape features as hunt area boundaries, rather than trying to determine the boundary between Federal and non-Federal lands in this area.

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Figure 4.

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Figure 5.

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OSM PRELIMINARY CONCLUSION

Support Proposal WP20-50.

Justification

This proposal would simplify regulations in a manner that should not negatively impact moose populations in this area. Moose populations in Unit 12 remainder appear to be stable and habitat is not found to be a limiting factor. Adopting this regulatory change would simplify regulations for Federally qualified subsistence users by aligning Federal and State regulations (except for the State and Federal seasons in the RM291 permit hunt area). This proposal would limit the area where an RM291 permit would be necessary, which would reduce complexity for those users harvesting moose in the northern portion of the current Unit 12 remainder, while keeping the permit requirements in place in the area that contains a majority of Federal lands. This proposal would also add antler restrictions in the Tok River drainage, which would help protect moose populations in the area, while simplifying the harvest limit in the new Unit 12 remainder to “one bull”, which would limit complexity in a hunt area with very limited Federal lands. It is unlikely that harvest will increase dramatically by modifying the harvest limits, seasons, and hunt area boundaries as proposed, but it will simplify regulations for users in the area and allow users to reference landscape features for hunt area boundaries.

LITERATURE CITED

ADF&G. 2011. Community subsistence information system: Unit 12. ADF&G, Division of Subsistence, Anchorage, AK. http://www.adfg.alaska.gov/sb/CSIS/ Retrieved: May 3, 2017.

ADF&G. 2017a. Board of Game Interior/Northeast Region Meeting Materials. February 17-25, 2017. Fairbanks, AK.

ADF&G. 2017b. General harvest reports. https://secure.wildlife.alaska.gov/index.cfm. Retrieved: May 1, 2017.

ADF&G. 2018. Memorandum. 2017 Northwestern Unit 12 moose survey. Tok, AK. 6 pp.

ADF&G. 2019a. Memorandum. 2018 Northwestern Unit 12 moose survey. Tok, AK. 7 pp.

ADF&G. 2019b. General harvest reports. https://secure.wildlife.alaska.gov/index.cfm. Retrieved: July 19, 2019.

Bayless, S. 2017. Tetlin National Wildlife Refuge Manager. Personal communication: email. USFWS. Tok, AK.

Collins, G.H., W.N. Johnson, H.K. Timm, and M.R. Cebrian. 2005. Moose population survey, 2004: Tetlin National Wildlife Refuge. USFWS. Tok, AK. 15 pp.

Germain and Berg. 2018. Moose population survey in the Upper Tanana Valley, Game Management Unit 12, Alaska, 2017: Tetlin National Wildlife Refuge. USFWS. Tok, AK. 16 pp.

Holen, D., S.M. Hazell, and D.S. Koster, editors. 2012. Subsistence harvests and use of wild resources by communities in the eastern Interior of Alaska, 2011. ADF&G, Division of Subsistence Technical Paper No. 372, Anchorage, AK.

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Joly, K., P.A. Duffy, and T.S. Rupp. 2012. Simulating the effects of climate change on fire regimes in Arctic biomes: implications for caribou and moose habitat. Ecosphere 3(5): 36.

Maier, J.A.K., J.M. Ver hoef, A.D McGuire, R.T. Bowyer, L. Saperstein, and J.A. Maier. 2005. Distribution and density of moose in relation to landscape characteristics: effects of scale. Canadian Journal of Forest Research 35: 2233-2243.

Schmidt, J.I., K.J. Hundertmark, R.T. Bowyer, and K.G. McCracken. 2009. Population structure and genetic diversity of moose in Alaska. Journal of Heredity 100(2):170-180.

Stout, G. W. 2010. Unit 21D moose. Pages 477–521 in P. Harper, editor. Moose management report of survey and inventory activities 1 July 2007–30 June 2009. ADF&G, Division of Wildlife Conservation, Federal Aid in Wildlife Restoration Project 1.0, Juneau, AK.

Tape, K.D., Gustine, D.D., Ruess, R.W., Adams, L.G. and Clark, J.A., 2016. Range Expansion of Moose in Arctic Alaska Linked to Warming and Increased Shrub Habitat. PLoS ONE 11(4): 1-12.

USFWS. 2017. Federal Subsistence Permit System. https://ifw7asm-orcldb.fws.gov. Retrieved: May 2, 2017.

Wells, J.J. 2014. Unit 12 moose. Chapter 11, pages 11-1 through 11-17 in P. Harper and L.A. McCarthy, editors. Moose management report of survey and inventory activities 1 July 2011-30 June 2013. ADF&G, Species Management Report ADF&G/DWC/SMR-2014-6, Juneau, AK.

Wells, J.J. 2016. In prep. Moose management report and plan, Game Management Unit 12: Report period 1 July 2010–30 June 015 and plan period 1 July 2015–30 June 2020. ADF&G, Division of Wildlife Conservation, Species Management Report and Plan, Juneau, AK.

Wells, J.J. 2018a. Moose management report and plan, Game Management Unit 12: Report period 1 July 2010–30 June 2015 and plan period 1 July 2015–30 June 2020. ADF&G, Division of Wildlife Conservation, Species Management Report and Plan, Juneau, AK.

Wells, J.J. 2018b. Wildlife biologist. Personal Communication: email. ADF&G. Tok, AK.

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WRITTEN PUBLIC COMMENTS

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WP20–51 Executive Summary

General Description Proposal WP20-51 asks the Federal Subsistence Board to recognize customary and traditional uses of sheep in Unit 12 by rural residents of the community of Slana. Submitted by: Bob Medinger of Slana, Alaska.

Proposed Regulation Customary and Traditional Use Determination—Sheep

Unit 12 Rural residents of Unit 12, Chistochina, Dot Lake, Healy Lake, Mentasta Lake, and Slana

OSM Preliminary Conclusion Support

Southcentral Alaska Subsistence Regional Advisory Council Recommendation

Interagency Staff Committee Comments

ADF&G Comments

Written Public Comments 1 Oppose

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DRAFT STAFF ANALYSIS WP20-51

ISSUES

Proposal WP20-51, submitted by Bob Medinger of Slana, Alaska, asks the Federal Subsistence Board (Board) to recognize the customary and traditional uses of sheep in Unit 12 by rural residents of the community of Slana.

DISCUSSION

The proponent states that Slana residents hunt for sheep along the Nabesna Road. Slana is situated where the Nabesna Road intersects with the Tok Cutoff of the Glenn Highway. Travelling along the Nabesna Road, after approximately 25 miles, the road crosses the Unit 11/12 boundary. The proponent states Slana residents are hunting for sheep in Unit 12 under State regulations. The Board approved an elder hunt for sheep in Unit 12. Slana residents would like to participate in this hunt, but they can’t because their customary and traditional uses of sheep in Unit 12 have not been recognized by the Board.

When asked by staff, Mr. Medinger explained that Slana consists of people living in the Slana area including on both sides of the Nabesna Road and the Glenn Highway Tok Cutoff (Medinger 2019, pers. comm.).

The definition of the boundary between Unit 11 and 12 on the Nabesna Road is the boundary between the Copper River drainage (in Unit 11) and the Tanana River drainage (in Unit 12) at Milepost 25.2 on the Nabesna Road. According to The Milepost magazine, Mile 25.2 on the Nabesna Road is just before the Little Jack Creek culvert, where the creek flows under the road (Valencia 2019:324; Figure 1).

Customary and traditional uses of sheep by rural residents of Slana have already been recognized by the Board, in Unit 11. Consequently, the focus of this analysis is expanding the existing customary and traditional use determination for Slana to the proposed management unit, Unit 12.

Existing Federal Regulation

Customary and Traditional Use Determination—Sheep

Unit 12 Rural residents of Unit 12, Chistochina, Dot Lake, Healy Lake, and Mentasta Lake.

Note: Unit 12 communities: Northway, Northway Junction, Tanacross, Tetlin, Tok, and Nabesna.

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 147 Wildlife Proposal WP20-51 DRAFT Staff Analysis

Proposed Federal Regulation

Customary and Traditional Use Determination—Sheep

Unit 12 Rural residents of Unit 12, Chistochina, Dot Lake, Healy Lake, Mentasta Lake, and Slana.

Extent of Federal Public Lands

Unit 12 is comprised of approximately 60% Federal public lands and consists of approximately 48% National Park Service, 11% U.S. Fish and Wildlife Service, and 1% Bureau of Land Management lands. Federal public lands are within Wrangell-St. Elias National Park and Preserve and Tetlin National Wildlife Refuge (although sheep are not observed in the Refuge).

There are special requirements for National Park Service Lands. Under the guidelines of the Alaska National Interest Conservation Act, National Park Service regulations identify qualified local rural subsistence users in National Parks and Monuments: (1) by identifying resident zone communities, which include a significant concentration of people who have customarily and traditionally used subsistence resources on park lands; and (2) by identifying and issuing subsistence use permits to individuals residing outside of these resident zone communities who have a personal or family history of subsistence uses.

Regulatory History

At the beginning of the Federal Subsistence Management Program in Alaska in 1992, the Board adopted a customary and traditional use determination of “no subsistence priority” in the Tok Management Area of Unit 12, and no rural residents were eligible to hunt sheep under Federal subsistence regulations. In the remainder of Unit 12, the Board did not adopt a customary and tradition use determination, so all rural residents were eligible to harvest sheep under Federal regulations (72 FR 22961, May 29, 1992).

In 1997, the Board received many proposals requesting changes to customary and traditional use determinations for sheep in Units 11, 12, and 13. These proposals were combined in Proposal P97-25, and Proposals affecting Unit 12 are described in Table 1. The Board adopted the Southcentral Alaska Subsistence Regional Advisory Council recommendation to include rural residents of only Unit 12 as eligible to harvest sheep in the remainder area of Unit 12, based on positive evidence of strong ties between Unit 12 residents and the remainder area of Unit 12 (FSB 1997: 58, OSM 1997:159; 62 FR 29021, May 29, 1997).

In the 1997 analysis, Nabesna Road and Slana were defined as two distinct areas for the purposes of recognizing customary and traditional uses. Additionally, Slana, Slana Homestead North, and Slana Homestead South were defined as three separate areas, and each were analyzed separately. Slana was described as one of “several smaller communities with some Native presence (Gakona, Nabesna Road, Slana, Paxson, and Mentasta).” Slana Homestead North and Slana Homestead South were described as “overwhelmingly non-Native households connected only by roads (Lake Louise, Slana North, Slana South, McCarthy Road, West Glenn and East Glenn Highway)” (OSM 1997:168).

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D Figure 1

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In 1998, the Healy Lake Traditional Council submitted Proposal P98-100 seeking to add rural residents of Unit 12 and Chistochina, Mentasta Lake, and Healy Lake to the customary and traditional use determination for sheep in Unit 12. The Eastern Interior Alaska Council and Southcentral Alaska Council supported the proposal with modification to add rural residents of adjacent Units 11, 12, 13C, 20D, and 20E. The Board adopted the proposal with modification to include rural residents of only Unit 12 and Chistochina, Dot Lake, Healy Lake, and Mentasta Lake. The Board said that there was insufficient evidence available during its deliberations to support including other rural residents. The Board clarified that rural residents of the community of Dot Lake would include rural residents of the village of Dot Lake and Dot Lake Junction (OSM 1998: 7; 63 FR 35338, June 29, 1998).

Community Characteristics

Slana is situated where the Nabesna Road intersects with the Tok Cutoff of the Glenn Highway, at the junction of the Slana and Copper rivers, and borders the northwest corner of Wrangell-St. Elias National Park and Preserve. An Ahtna village and fish camp site existed here, named Stl’aa Caegge in Ahtna. The Valdez Trail and a telegraph line were built along the route of the modern-day Richardson Highway and

Table 1 A R A F Interagency Staff Council Proposal No./Proponent Proposed C&T Committee Recommendations Recommendation A— R T R D D A—R T R D — R A A R— A R D D— TF — R F A R D — A — R D D

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Wildlife Proposal WP20-51 DRAFT Staff Analysis brought people into the Slana area. A trading post and roadhouse were built in 1914. The Nabesna Gold Mine, located in Nabesna at what is now the end of the Nabesna Road, 46 miles from its junction with the Tok Cutoff, was open from 1923 through the 1940s and at its peak employed 60 people. The road to the mine opened to summer vehicle traffic in 1946. The Glenn Highway Tok Cutoff was built in the early 1940s connecting Slana to the Alaska Highway System (LaVine et al. 2013). Significant numbers of homesteaders arrived in the 1980s after two tracts of land on the north side of the Nabesna Road near Slana were opened for non-agricultural homesteading, one of the last homesteading opportunities provided by the Federal government in the United States (BLM 2016). They consist of 119 five-acre homesites (personal dwellings), 30 headquarter sites (for businesses), and eight trade and manufacturing sites (up to 80 acres for trade and manufacturing purposes for business needs). Many homesteads are not road connected.

LaVine and others (2013) identified three resident areas in the Slana area. First was the Roadhouse, around which the oldest road-based community was built. Second was the Nabesna Road settled by mine workers and more recently guides. Third was a homesteading community, described above.

LaVine and others continue:

In 1983 Stratton and Georgette (1984) found 43 residents living in Slana year-round with an additional 37 residents living in the Nabesna Road area. According to Hunt, by the early 1990s the total population had increased to approximately 150 people (1991:179); however, McMillan and Cuccarese (1988) found a combined population of 333 when all area communities and recently settled homesteads were surveyed in 1988—Slana (49), Nabesna Road (37), Slana Homestead South (186), and Slana Homestead North (61). None but Slana were a CDP [Census Designated Place] at the time. By 2000, Nabesna Road became its own CDP and Slana Homestead South was wrapped into the Slana CDP. Slana Homestead North remains outside of any CDP (LaVine et al. 2013: 77).

The 2010 U.S. Census identified 147 people living in 77 households within the boundary of the Slana Census Designated Place (CDP) (2019a and 2019b, Figure 1). The Slana CDP eastern boundary begins at the junction of the Nabesna Road and Lost Creek. It includes either side of the Nabesna Road to its junction with the Tok Cutoff highway. It continues on both sides, north and south, of the Tok Cutoff highway. Its northern boundary is the junction of the highway with Carlson Creek. Its southern boundary is the junction of the highway and the Cobb Lake turn off. There is a post office and store. Tok is approximately 65 road miles northeast of Slana.

For the purposes of this analysis, Slana consists of rural residents within the Slana CDP plus homesteaders north of the Nabesna Road that are north of the Slana CDP boundary.

Eight Factors for Determining Customary and Traditional Use

Customary and traditional uses in a community or area is generally exemplified through the eight factors: (1) a long-term, consistent pattern of use, excluding interruptions beyond the control of the community or area; (2) a pattern of use recurring in specific seasons for many years; (3) a pattern of use consisting of

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methods and means of harvest which are characterized by efficiency and economy of effort and cost, conditioned by local characteristics; (4) the consistent harvest and use of fish or wildlife as related to past methods and means of taking: near, or reasonably accessible from the community or area; (5) a means of handling, preparing, preserving, and storing fish or wildlife which has been traditionally used by past generations, including consideration of alteration of past practices due to recent technological advances, where appropriate; (6) a pattern of use which includes the handing down of knowledge of fishing and hunting skills, values, and lore from generation to generation; (7) a pattern of use in which the harvest is shared or distributed within a definable community of persons; and (8) a pattern of use which relates to reliance upon a wide diversity of fish and wildlife resources of the area and which provides substantial cultural, economic, social, and nutritional elements to the community or area.

The Board makes customary and traditional use determinations based on a holistic application of these eight factors (50 CFR 100.16(b) and 36 CFR 242.16(b)). In addition, the Board takes into consideration the reports and recommendations of any appropriate Regional Advisory Council regarding customary and traditional use of subsistence resources (50 CFR 100.16(b) and 36 CFR 242.16(b)). The Board makes customary and traditional use determinations for the sole purpose of recognizing the pool of users who generally exhibit the eight factors. The Board does not use such determinations for resource management or restricting harvest. If a conservation concern exists for a particular population, the Board addresses that concern through the imposition of harvest limits or season restrictions rather than by limiting the customary and traditional use finding.

As mentioned previously, the customary and traditional uses of sheep by rural residents of Slana have already been recognized by the Board in Unit 11. Consequently, the focus of this analysis is expanding the existing customary and traditional use determination for Slana residents to the proposed management unit, Unit 12.

Between 1964 and 1983, residents of Slana searched for sheep in a wide area including the Gold Hill/Nabesna Glacier area (south of Nabesna in Unit 12), the Sikonsina Pass area (situated south of the Tok River in Unit 12), and the Nutzotin Mountains in Unit 12. In 1984, few new homesteaders lived in the area; opportunities to homestead had only recently opened (ADF&G 1985 and Stratton and Georgette 1984).

Slana residents have documented their harvests of sheep during household harvest surveys. Slana residents reported harvesting an estimated 7 sheep (CI 95% 7–17) in 1982, 2 sheep in 1987 (CI 95% 2–4), and none in 2010. However, 16% of households reported using sheep that was shared with them during the 2010 study year, and a small number of households reported attempting to harvest sheep. Their search area in 2010 was northeast of the Nabesna Road in Unit 11, bordering Unit 12 (LaVine 2019, pers. comm.). Additionally, Slana Homestead North and South residents reported harvesting 2 sheep in 1987 (ADF&G 2019a and LaVine et al. 2013).

Between 1985 and 2017 cumulative, based on the ADF&G and OSM reporting systems, Slana hunters reported harvesting 30 sheep in Unit 12. Over this time period, Slana residents averaged 4.8 hunters and

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0.9 sheep per year in Unit 12. Other sheep harvests by Slana residents occurred mainly in Unit 11 (ADF&G 2019b and OSM 2019).

Effects of the Proposal

If this proposal is adopted, residents of Slana will be eligible to harvest sheep during Federal sheep hunts in Unit 12.

If this proposal is not adopted, residents of Slana will continue to ineligible to participate in Unit 12 sheep hunts under Federal regulations, including the Federal Unit 12 elder sheep hunt.

OSM PRELIMINARY CONCLUSION

Support Proposal WP20-51.

Justification

Residents of Slana exemplify customary and traditional uses of sheep in Unit 12. Residents of Slana have harvested sheep in Unit 12 since at least 1982, as documented in household surveys and the State and Federal harvest reporting systems (ADF&G 1985; ADF&G 2019a, 2019b; and OSM 2019). The geographic extent of Slana has been described in various ways by different sources. The area description used in a 1997 for a proposal seeking recognition of Slana’s customary and traditional uses of sheep did not include Slana Homestead North or Slana Homestead South (OSM 1997). In 2010 for the purposes of the U.S. Census, the Slana Census Designated Place (CDP) included households on either side of the Tok Cutoff highway, encompassing the population of the Slana area, and households on either side of the Nabesna Road up to Lost Creek (U.S. Census 2019b, Figure 1). Slana is defined here as the Slana CDP, plus homesteaders north of the Nabesna Road who are north of the Slana CDP boundary (Figure 1).

LITERATURE CITED

ADF&G (Alaska Department of Fish and Game). 1985. Alaska habitat management guide. Southcentral region: reference maps. Alaska Department of Fish and Game Division of Habitat, Juneau.

ADF&G. 2019a. Community Subsistence Information System. Online database, accessed May 29. Alaska Department of Fish and Game Division of Subsistence, Anchorage.

ADF&G. 2019b. Harvest General Reports. Online database, accessed May 30. Alaska Department of Fish and Game Division of Wildlife Conservation, Anchorage.

BLM (Bureau of Land Management). 2016. History of Alaska Homesteading: the Last Chapter in America’s Homestead Experience Brochure. Anchorage, AK. 12 pages https://www.blm.gov/documents/alaska/public- room/brochure/history-alaska-homesteading-last-chapter-americas-homestead.

FSB (Federal Subsistence Board). 1997. Transcripts of Federal Subsistence Board proceedings. April 7. Fish and Wildlife Service Office of Subsistence Management. Anchorage.

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Hunt, W.R. 1991. Mountain wilderness: historic resource study for Wrangell-St. Elias National Park and Preserve. National Park Service, Alaska Region. Anchorage.

LaVine, R., M. Kukkonen, B. Jones, and G. Zimpelman. 2013. Subsistence harvests and uses of wild resources in Copper Center, Slana/Nabesna Road, Mentasta Lake, and Mentasta Pass, Alaska, 2010. Alaska Department of Fish and Game Division of Subsistence, Technical Paper No. 380. Anchorage.

LaVine, R. 2019. Anthropologist. Personal communication: by email. U.S. Fish and Wildlife Service, Office of Subsistence Management, Anchorage.

McMillan, P.O., and S.V. Cuccarese. 1988. Alaska over-the-horizon backscatter radar system: characteristics of contemporary subsistence use patterns in the Copper River Basin and Upper Tanana Area. Volume I: synthesis. Draft report. Prepared for Hart Crowser, Inc. Arctic Environmental Information and Data Center, University of Alaska Anchorage in cooperation with the Alaska Department of Fish and Game and U.S. National Park Service, Anchorage.

OSM (Office of Subsistence Management). 1997. Staff analysis P97-25. Pages (Southcentral) 140–205 in Federal Subsistence Board Meeting Materials. April 7–11. Fish and Wildlife Service. Anchorage. 1,034 pages.

OSM. 1998. Staff analysis P98-100. Pages (Eastern Interior) 76–90 in Federal Subsistence Board Meeting Materials. May 4–8. U.S. Fish and Wildlife Service Office of Subsistence Management. Anchorage, AK. 1,449 pages.

OSM. 2019. Federal Subsistence Permit System. Online database, accessed May 31, 2019. Fish and Wildlife Service Office of Subsistence Management, Anchorage.

Stratton, L., and S. Georgette. 1984. Use of fish and game by communities in the Copper River Basin, Alaska: a report on a 1983 household survey. Alaska Department of Fish and Game Division of Subsistence, Technical Paper No. 107. Anchorage. 224 pages.

U.S. Census. 2019a. https://factfinder.census.gov/faces/nav/jsf/pages/community_facts.xhtml, accessed May 29.

U.S. Census. 2019b. CDP maps—https://www2.census.gov/geo/maps/dc10map/GUBlock/st02_ak/place/ (use Chrome), accessed May 29.

Valencia, Kris, editor. 2019. The Milepost 2019: Alaska travel planner. MCC Magazines, Augusta, GA.

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WP20–19 Executive Summary

General Description Wildlife Proposal WP20-19 requests revisions to the elder/minor sheep hunt in Unit 11. Submitted by: Robert Cyr, Glennallen.

Proposed Regulation Unit 11—Sheep

Elder Hunt: (Bag limit 1 ram) 1 sheep by Federal Aug. 1 – registration permit (FS1104) only by persons 60 years Oct. 20 of age or older. Ewes accompanied by lambs or lambs may not be taken.

Youth Hunt: (Bag limit 1 ram) 1 sheep by Federal Aug. 1-Oct. registration (ii) A joint permit (FS1103) may be issued 20 to a pair of a minor and an elder to hunt sheep during the Aug. 1 – Oct. 20 hunt. Ewes accompanied by lambs or lambs may not be taken. The following conditions apply:

(A) The permittees must be a minor aged 8 to 157 years oldand an accompanying adult. 60 years of age or older;

(B) Both the elder and The minor must be Federally qualified subsistence users with a positive customary and traditional use determination for the area they want to hunt;

(C) The minor must hunt under the direct immediate supervision of the accompanying adult, who is responsible for ensuring that all legal requirements are met, and;

(D) Only one animal may be harvested with this permit. The sheep harvested will count against the harvest limits of both the minor and accompanying adult.

OSM Preliminary Oppose Conclusion

Southcentral Alaska Subsistence Regional

156 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Wildlife Proposal WP20-19 DRAFT Staff Analysis

WP20–19 Executive Summary Advisory Council Recommendation

Eastern Interior Alaska Subsistence Regional Advisory Council Recommendation

Interagency Staff Committee Comments

ADF&G Comments

Written Public Comments 4 Support, 1 Oppose

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DRAFT STAFF ANALYSIS WP20-19

ISSUES

Wildlife Proposal WP20-19, submitted by Robert Cyr from Glennallen, requests revisions to the elder/minor sheep hunt in Unit 11.

DISCUSSION

The proponent seeks to change the Unit 11 elder/minor sheep hunt to a stand-alone elder sheep hunt and a stand-alone youth sheep hunt, and to change the allowable age of youth from ages 8-15 to ages 8-17. The proponent seeks to allow youth to hunt with an adult Federally qualified subsistence user who has the strength and stamina to physically participate. The proponent notes that this change would allow Federally qualified subsistence users to take their children and other youth sheep hunting during the best weather before school begins. The proponent notes the importance of passing on tradition and culture to youth, the importance of being able to teach youth when there is less competition, and the belief that establishing a youth hunt would create no conservation concerns.

Existing Federal Regulation

Unit 11—Sheep

1 sheep by Federal registration permit only by persons 60 years of age Aug. 1-Oct. 20 or older. Ewes accompanied by lambs or lambs may not be taken.

(ii) A joint permit may be issued to a pair of a minor and an elder to hunt sheep during the Aug. 1 – Oct. 20 hunt. The following conditions apply:

(A) The permittees must be a minor aged 8 to 15 years old and an accompanying adult 60 years of age or older;

(B) Both the elder and the minor must be Federally qualified subsistence users with a positive customary and traditional use determination for the area they want to hunt;

(C) The minor must hunt under the direct immediate supervision of the accompanying adult, who is responsible for ensuring that all

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legal requirements are met;

(D) Only one animal may be harvested with this permit. The sheep harvested will count against the harvest limits of both the minor and accompanying adult.

Proposed Federal Regulation

Unit 11—Sheep

Elder Hunt: (Bag limit 1 ram) 1 sheep by Federal registration permit Aug. 1-Oct. 20 (FS1104) only by persons 60 years of age or older. Ewes accompanied by lambs or lambs may not be taken.

Youth Hunt: (Bag limit 1 ram) 1 sheep by Federal registration (ii) Aug. 1-Oct. 20 A joint permit (FS1103) may be issued to a pair of a minor and an elder to hunt sheep during the Aug. 1 – Oct. 20 hunt. Ewes accompanied by lambs or lambs may not be taken. The following conditions apply:

(A) The permittees must be a minor aged 8 to 157 years oldand an accompanying adult. 60 years of age or older;

(B) Both the elder and The minor must be Federally qualified subsistence users with a positive customary and traditional use determination for the area they want to hunt;

(C) The minor must hunt under the direct immediate supervision of the accompanying adult, who is responsible for ensuring that all legal requirements are met, and;

(D) Only one animal may be harvested with this permit. The sheep harvested will count against the harvest limits of both the minor and accompanying adult.

Existing State Regulation

Unit 11 sheep-

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Resident- Youth hunt only- Aug. 1-5, one ram with full-curl horn or larger. General hunt- Aug. 10-Sept. 20, one ram with full-curl horn or larger.

Non-resident- Youth hunt only- Aug. 1-5, one ram with full-curl horn or larger every four years. General hunt- Aug. 10-Sept. 20, one ram with full-curl horn or larger every four years

Definitions:

Youth hunt- a hunt limited to a child aged 10-17 and an accompanying adult that is a licensed hunter 21 years of age or older.

Extent of Federal Public Lands/Waters

Unit 11 is comprised of 81% Federal public land and consists of 78.9% National Park Service (NPS) managed lands and 2.1% USDA, Forest Service (USFS) managed lands.

Customary and Traditional Use Determinations

Rural residents of Unit 12, Chistochina, Chitina, Copper Center, Dot Lake, Gakona, Glennallen, Gulkana, Healy Lake, Kenny Lake, Mentasta Lake, Slana, McCarthy/South Wrangell/South Park, Tazlina, Tonsina, residents along the Nabesna Road milepost 0–46 (Nabesna Road), and residents along the McCarthy Road milepost 0–62 (McCarthy Road) have a customary and traditional use determination for sheep in Unit 11, north of the Sanford River.

Rural residents of Chisana, Chistochina, Chitina, Copper Center, Gakona, Glennallen, Gulkana, Kenny Lake, Mentasta Lake, Slana, McCarthy/South Wrangell/South Park, Tazlina, Tonsina, residents along the Tok Cutoff Road- Milepost 79–110 (Mentasta Pass), residents along the Nabesna Road milepost 0–46 (Nabesna Road), and residents along the McCarthy Road milepost 0–62 (McCarthy Road) have a customary and traditional user determination for sheep in Unit 11, remainder.

Special requirements for NPS lands: Under the guidelines of ANILCA, NPS regulations identify Federally qualified subsistence users in National Parks and Monuments by: 1) identifying resident zone communities which include a significant concentration of people who have customarily and traditionally used subsistence resources on park lands; and 2) identifying and issuing subsistence use permits to individuals residing outside of the resident zone communities who have a personal or family history of subsistence use.

Regulatory History

In 1997, Wildlife Proposal 68 was submitted by Robert Marshall of Tazlina to allow a Federal sheep hunt in Unit 11 from Sep. 21–Oct. 20. The proponent noted that, “Most of my Tribe and myself are up in age where the mountain climbing is too hard and dangerous. During the early season, the sheep are almost to the top of the mountain. Later in October they move to lower areas.” The Southcentral Alaska Subsistence Regional Advisory Council supported Proposal 68 with a Federal registration permit. This proposal was deferred by the Federal Subsistence Board (Board) until the following regulatory cycle for further analysis and development (FSB 1997).

160 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Wildlife Proposal WP20-19 DRAFT Staff Analysis

In 1998, Wildlife Proposal 28 (deferred and amended Proposal 68 from 1997) was considered by the Southcentral and Eastern Interior Alaska Subsistence Regional Advisory Councils. Wildlife Proposal 28 requested to extend the sheep season in Unit 11 from Aug. 10 – Sep. 20 to Sep. 21 – Oct. 20 for persons 60 years of age or older. Based on Council recommendations and Solicitor’s Office support, the proposal was adopted by the Board (FSB 1998).

In 2004, Wildlife Proposal WP04-24 was submitted by the Wrangell-St. Elias Subsistence Resource Commission, and requested that designated hunters be allowed for the late season elder sheep hunt in Unit 11. This proposal was opposed by both the Southcentral and Eastern Interior Councils and rejected by the Board (EIRAC 2004, SCRAC 2004, FSB 2004). It was noted that the special season for elders was established in 1998 to allow elders the opportunity to hunt and pass on their knowledge. There was discussion during the Council meetings regarding an opportunity for youth to accompany the elders, but it was realized that the proposal under consideration dealt only with designated hunting provisions and there was a lack of detail about the provisions for allowing youth to accompany elders during the late sheep season.

In 2005, the Cheesh’na Tribal Council submitted Wildlife Proposal WP05-06, which requested adding a provision for a joint elder/minor permit in the late sheep seasons in Units 11 and 12. Based on agreement between the Councils, Interagency Staff Committee and the State, the proposal was adopted by the Board as part of the consensus agenda and established the elder/minor hunt season of Sep. 21 – Oct. 20 (FSB 2005).

In 2012, Wildlife Proposal WP12-32, submitted by the Cheesh’na Tribal Council, requested that the season dates for the elder/minor sheep hunts in Units 11 and 12 be changed from Sep. 21-Oct. 20 to Aug. 1-Aug. 9. Based on Council and Wrangell-St. Elias Subsistence Resource Commission recommendations, the Board adopted season dates of Aug. 1-Oct. 20 while prohibiting the take of ewes accompanied by lambs in Unit 11 (FSB 2012).

Biological Background

Dall sheep are recognized as an integral part of the ecosystem throughout alpine and subalpine areas in Unit 11. Sheep numbers in the Wrangell Mountains prior to the 1950s are unavailable. Surveys done in the late 1950s and 1960s are generally not comparable to recent surveys due to changes in survey methodology. Specific sheep count areas and techniques were established in 1973, when sex and age composition surveys were flown over large portions of the Wrangell and Chugach mountains. Given the size of Unit 11, unit-wide sheep population data are limited. The NPS estimated 26,286 sheep ± 4,473 (95% CI) in 1990, 27,796 ± 6,448 (95% CI) in 1991, and 17,445 ± 3,883 (95% CI) in 1993 within the entire Wrangell-St. Elias National Park and Preserve (WRST) (McDonald et al. 1991; Strickland et al. 1993). In 2010 and 2011, a sheep population estimate of 12,428 (10,780-14,470 95% CI) was determined for WRST (NPS 2013). It should be note that there are many subpopulations of sheep in Unit 11 (Figure 1) and the population trends within the subpopulations are variable. Although there is some overlap between sheep populations, each count area basically represents a discreet population; geographic barriers such as large valleys and rivers naturally limit sheep movement and distribution, resulting in discrete subpopulations (Arthur 2013, Caikoski 2014).

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 161 Wildlife Proposal WP20-19 DRAFT Staff Analysis

Sheep survey areas are reported by Hatcher (2018) Figure 1. These surveys still continue in selected areas. Surveys represent minimum counts (Putera 2019, pers. comm.). For the surveys, Hatcher (2018) reported that, “Adult male sheep are recorded as rams, and young male sheep and ewes are recorded as ewe-like sheep. Lambs are differentiated from adults.”

Northern Unit 11- Sheep population information is determined from count areas (CAs) 2, 3W, and 10. CAs 2 and 3W were surveyed in 2013 (Figure 1). Counts were conducted in CA 2 only in 2002 and 2013, and the 2013 survey was incomplete. Composition data showed that there were sufficient rams to breed ewes in CA 2 in 2013 (54 rams:100 ewes), but the percent of rams having full curl horns may have declined from the 20% observed in 2002 to 7% observed in 2013. The number of sheep observed in CA 3W in 2013 was 41% lower than the 565 sheep observed in 2007 and 34% lower than the 502

Figure 1 D

sheep observed in 2001. The percent of the population represented by lambs was 8% in 2013, which was below the 20% observed in 2007. CA 3W is popular to hunt among Federally qualified subsistence sheep hunters. While the percent of rams had dropped from 46% in 2001 and 50% in 2007 to 11% in 2013; the

162 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Wildlife Proposal WP20-19 DRAFT Staff Analysis ratio of rams:100 ewe-like sheep remained adequate at 46:100. Due to the location of the sheep counted in the previous survey of CA 3W, it is plausible that the declines observed in 2013 compared to previous surveys are reflective of sheep locations during the survey (being just over the ridgetop, for example) rather than actual population trends (Figure 1, Hatcher 2018).

Central Unit 11- The central portion of the Wrangell Mountains, is represented in CAs 11 and 12, which are the most frequently surveyed CAs, as well as CAs 13, 14, 15, and 16 (Figure 1). CA 11 was surveyed in 2011, 2013, 2015 and 2017. CA 12 was surveyed in 2011, 2013 and 2015, while CAs 13 and 14 were surveyed only in 2013. Sheep observations in CA 11 slowly declined after the late 1980s, when 400–560 sheep were observed, until 2002. Since 2008 (2008, 2009, 2011, 2013, 2015 and 2017), the population has remained fairly stable with an average of 177 sheep being observed (the range was 124-251 (Putera 2019, pers. comm.). Rams:100 ewe-like sheep ranged between 30–44 animals, with an average of 35. During regulatory years RY 2011–2015, an average of 16% of rams were full-curl or greater. Lambs represented an average of 17% of the flock. Survey results from 2017 for CA 11 were 251 total sheep, 37 rams, and 74 lambs (Putera 2019, pers. comm.).

Sheep numbers in adjoining CA 12 began to decline in the late 1990s, falling from a high of 601 sheep observed in 1996 to a low of 113 sheep observed in 2006. The counts appeared to stabilize from 2004 to 2009, when on average 166 sheep were observed annually. During RY 2011–2015, the number of sheep observed in CA 12 averaged 282, with observations ranging from 258 to 322 sheep. On average, lambs represented 17% of the observed flock, which was above the average from previous surveys of 14%. The ratio of rams to 100 ewe-like sheep ranged from 45 to 61, with an average of 51, which is similar to the overall average of 50 rams:100 ewes from all previous surveys. CA 13 was surveyed in 2013 for the first time since 1999. While the total of 124 sheep observed was lower than the 369 observed in 1999, it was not far from the 150 sheep observed during the only earlier survey of the area, in 1984. Of the rams observed, 14% were full-curl or greater (Hatcher 2018).

The number of sheep observed in 2013 in CA 14 (94 sheep) was above the 10-year average from previous surveys (75 sheep; Schwanke 2011). None of the rams observed were full-curl or larger, which was also the case in 2003 and 2005. The total number of rams observed in 2006 (31) was greater than in any previous survey. The ram to ewe-like sheep ratio was 39:100, and lambs made up only 5% of the population (Hatcher 2018).

Southwestern Unit 11- Population information for the southwest portion of the Saint Elias Mountains is collected from CA 17, CA 21, CA 22, CA 23, CA 24, and CA 32 in the upper Chitina River drainage (Figure 1). Most recently, CA 22 was surveyed in 2017 and CA 23 was surveyed in 2013. In CA 22 total sheep numbers since the early 1980s have ranged from 197 to 304 (average = 252). Counts have stabilized since 2005 (2005, 2011, 2013 and 2017) with an average of 237 sheep observed (range 234- 359; Putera 2019, pers. comm.). An average of 49 rams:100 ewe-like sheep were observed, and an average of 27% of rams observed were full-curl or greater. On average, lambs made up 18% of the subpopulation. Survey results from 2017 for CA 22 were 359 total sheep, 76 rams and 92 lambs (Putera 2019, pers. comm.). Counts in CA 23 have fluctuated between 244 sheep and 375 sheep since the early 1980s, with an average of 309 sheep observed. During RY 2011–2015, 250 sheep were observed in CA

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23 with 56 rams:100 ewe-like sheep, 17% of rams were full-curl or greater, and 9% of the flock made up of lambs (Hatcher 2018).

Based on surveys in Unit 11 from RY 2011 to RY 2015, the sheep populations are currently stable (Hatcher 2018). Since large amounts of sheep habitat in Unit 11 are Federally-protected, which either restrict hunter access or are difficult for hunters to access the habitat, Hatcher (2018) observed that it is unlikely that the hunter harvest will cause the sheep population to decline. She noted that the Unit 11 sheep population is largely driven by uncontrollable factors such as weather, habitat quality, and predation, rather than hunter harvest.

Cultural Knowledge and Traditional Practices

Written documentation of the special relationships between all ages and the teaching of hunting and fishing skills is provided in summaries prepared by the National Park Service (NPS 1995). Examples of these practices are provided in the curriculum guide materials prepared by the Mt. Sanford Tribal Consortium. This curriculum guide provides guidance to teachers in traditional learning and identifies areas where adults can be consulted for traditional knowledge on the local resources and customs (MSTC 2004).

Simeone (2006) provided some ethnographic and historical information on the use of large land mammals in the Copper River Basin. In the Ahtna language, Dall sheep are called debai, ewes are c’edzedzi, lambs are ghesdacy, adult male sheep are ses yaane’, and large rams are called de’aeli (Kari 1990). In years past, Ahtna living on the Copper River spent the late summer and fall on the slopes of the Wrangell Mountains hunting Dall sheep and Arctic ground squirrels. Before they had rifles, the Ahtna snared sheep on sheep trails in the mountains and dispatched the sheep with a knife or spear. According to Simeone (2006), “Gene Henry’s father…said in late summer the family moved from their home at Batzulnetas into the hills and spent most of the winter trapping and living on sheep meat. Gene said that his family killed approximately 30 sheep a year.” According to Simeone (2006), “Katie John’s father…spent the late summer and fall hunting. She estimated that her family killed 30 sheep in a good year.” Ahtna hunters paid particular attention to ritual observations that were thought to be equally essential for hunting success. In a recollection of many Ahtna elders, sheep were, “almost more important than any other resources except salmon” (Simeone 2006).

Alaska Department of Fish and Game (ADF&G), Division of Subsistence conducts household subsistence harvest surveys periodically throughout Alaska. Though this survey data is only available for some communities in some years, it is an additional source for documenting patterns of harvest and use in rural Alaska. Recent surveys conducted in the communities of the Copper River basin and upper Tanana River watershed note that large land mammal harvest is high and comprised between 21% and 88% of the total community harvests by weight (Godduhn & Kostick 2016; Holen, et al. 2012; Holen, et al. 2015; Kukkonen & Zimpleman 2012; La Vine, et al. 2013; La Vine & Zimpleman 2014). While the majority of the large land mammal harvest was moose and caribou, most communities reported some use or attempted harvest of Dall sheep during the year that were surveyed.

164 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Wildlife Proposal WP20-19 DRAFT Staff Analysis

Harvest History

The harvest of Dall sheep in WRST is limited to Federally qualified subsistence users in NPS WRST resident zone communities. Rural residents can also hunt under Federal subsistence regulations and any Alaska resident can hunt under State regulations in the WRST National Preserve. On WRST National Preserve lands, non-residents can hunt sheep under State regulations if accompanied by an Alaska licensed guide or an Alaska resident 19 years of age or older who is within the second degree of kindred.

In the 21 years (1998–2018) since the Unit 11 elder-only subsistence sheep hunt was established, a total of 392 Federal permits were issued; 148 of the permit holders hunted and 17 sheep (16 male and 1 female) were harvested (USFWS 2019).

In the 14 years (2005-2018) since the Unit 11 elder/minor hunt was established, only 14 Federal permits were issued; five permit holders hunted and no sheep were harvested (USFWS 2019).

The State of Alaska reported that an average of 127 people per year engaged in sheep hunts in Unit 11 from RY2011-2015. During the same timeframe, the average annual harvest under State harvest tickets was 43 sheep (Hatcher 2018).

Effects of the Proposal

If adopted, this proposal would maintain the current elder permit (FS1104) for sheep in Unit 11 and replace the current elder/minor permit (FS1103) with a standalone sheep permit for youth.

The Alaska National Interest Lands Conservation Act (ANILCA) provides a subsistence priority for rural Alaska residents that have a customary and traditional use determination for a particular resource. Customary and traditional use determinations are made to identify and protect subsistence uses and are not intended to restrict harvest or allocate resources. In the event subsistence uses need to be restricted due to conservation concerns or to continue subsistence uses, a prioritization among Federally qualified subsistence users is implemented through Section 804 of ANILCA.

Wildlife Proposal WP20-19 would create a preference for a small select group out of the general population of qualified rural residents, and there is no legal basis for doing so under Title VIII of ANILCA. Section 804 of ANILCA states that, “Whenever it is necessary to restrict the taking of a populations of fish and wildlife on such lands for subsistence use in order to protect the continued viability of such populations, or to continue such uses, such priority shall be implemented through appropriate limitations based on application of the following criteria:(1) customary and direct dependence upon the population as the mainstay of livelihood; (2) local residency; and (3) the availability of alternate resources.” While the historic Unit 11 elder/minor sheep hunts may be justified based on the educational value and longstanding tradition of passing down knowledge from generation to generation, there is no legal justification for an age-based hunt, which gives preference and stand-alone permits for youth hunters.

Opportunity for youth hunts might be addressed through Federal Subsistence Management Program cultural/educational permits. A modification of Wildlife Proposal WP20-19 to provide consideration of a

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cultural/educational permit would be beyond the scope of the originally submitted proposal. As such, there would have to be a separate requests for cultural/educational permits. Cultural/educational permits would give greater flexibility to not only the user, but to Federal land and in-season managers. However, cultural/educational permits are given to an organization, not to individuals. Regulations concerning cultural/educations permits [_.25(g)] state that, “(1) A qualifying program must have instructors, enrolled students, minimum attendance requirements, and standards for successful completion of the course. Applications must be submitted to the Federal Subsistence Board through the Office of Subsistence Management and should be submitted 60 days prior to the earliest desired date of harvest. Harvest must be reported, and any animals harvested will count against any established Federal harvest quota for the area in which it is harvested. (2) Requests for follow up permits must be submitted to the in-season or local manager and should be submitted 60 days prior to the earliest desired date of harvest.” The cultural/educational permit process has been developed by the Alaska Federal Subsistence Management Program since the Unit 11 elder and elder/minor sheep hunts were originally adopted by the Board in 1998 and 2005 respectively.

OSM PRELIMINARY CONCLUSION

Oppose Proposal WP20-19.

Justification

Wildlife Proposal WP20-19 would create a preference for a small select group out of the general population of qualified rural residents, and there is no legal basis for doing so under ANILCA. Youth hunts might, however, be addressed through cultural/educational subsistence permits.

LITERATURE CITED

Arthur, S.M. 2013. Demographics and spatial ecology of Dall sheep in the central Brooks Range. ADF&G, Division of Wildlife Conservation. Final research performance report 1 July, 2007-30 June, 2013, Federal Aid in Wildlife Restoration Project 6.15. Juneau, AK.

Caikoski, J.R. 2014. Eastern Unit 24A and Units 25A, 26B and 26C Dall sheep. Chapter 16, pages 16-1 through 16- 18 in P. Harper and L.A. McCarthy, editors. Dall sheep management report of survey and inventory activities 1 July, 2010-30 June, 2013. ADF&G, Species Management Report ADF&G/DWC/SMR-2014-4. Juneau, AK.

EIRAC. 2004. Transcripts of the Eastern Interior Alaska Subsistence Regional Advisory Council proceedings, February 27, 2004. Office of Subsistence Management. USFWS. Anchorage, AK.

FSB. 1997. Transcripts of the Federal Subsistence Board proceedings, April 7, 1998. Office of Subsistence Management, USFWS. Anchorage, AK.

FSB. 1998. Transcripts of the Federal Subsistence Board proceedings, May 6, 1998. Office of Subsistence Management, USFWS. Anchorage, AK.

FSB. 2004. Transcripts of the Federal Subsistence Board proceedings, May 21, 2004. Office of Subsistence Management, USFWS. Anchorage, AK.

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FSB. 2005. Transcripts of the Federal Subsistence Board proceedings, May 5, 2005. Office of Subsistence Management, USFWS. Anchorage, AK.

FSB. 2012. Transcripts of the Federal Subsistence Board proceedings, January 19, 2012. Office of Subsistence Management, USFWS. Anchorage, AK.

Godduhn, Anna R., and M. L. Kostick. 2016. Harvest and Use of Wild Resources in Northway, Alaska, 2014, with special attention to nonsalmon fish. ADF&G, Division of Subsistence. Technical Paper No. 421. Fairbanks, AK.

Hatcher, H. L. 2018. Dall sheep management report and plan, Wrangell and St. Elias Mountains, Game Management Unit 11: Report period 1 July, 2011–30 June, 2016, and plan period 1 July, 2016–30 June, 2021. ADF&G, Species Management Report and Plan ADF&G/DWC/SMR&P-2018-39. Juneau, AK.

Holen, D., S. M. Hazell, and D. S. Koster, editors. 2012. The Harvest and Use of Wild Resources by Communities in the Eastern Interior, Alaska, 2011. ADF&G, Division of Subsistence. Technical Paper No. 372. Anchorage, AK.

Holen, D., S. M. Hazell, and G. Zimpelman, editors. 2015. The Harvest and Use of Wild Resources in Selected Communities of the Copper River Basin and East Glenn Highway, Alaska, 2013. ADF&G, Division of Subsistence. Technical Paper No. 405. Anchorage, AK.

Kari, James. 1990. Ahtna Athabaskan Dictionary. Alaska Native Language Center, University of Alaska, Fairbanks, AK.

Kukkonen, M. and G. Zimpelman. 2012. Subsistence Harvests and Uses of Wild Resources in Chistochina, Alaska, 2009. ADF&G, Division of Subsistence, Technical Paper No. 370. Anchorage, AK

La Vine, R., M. Kukkonen, B. Jones, and G. Zimpelman, editors. 2013. Subsistence Harvests and Uses of Wild Resources in Copper Center, Slana/Nabesna Road, Mentasta Lake, and Mentasta Pass , Alaska, 2010. ADF&G, Division of Subsistence. Technical Paper No. 380. Anchorage, AK.

La Vine, R., S. and G. Zimpelman, editors. 2014. Subsistence Harvests and Uses of Wild Resources in Kenny Lake/Willow Creek, Gakona, McCarthy, and Chitina, Alaska, 2012. ADF&G, Division of Subsistence. Technical Paper No. 394. Anchorage, AK.

McDonald, L.L., D. Strickland, D. Taylor, J. Kern, and K. Jenkins. 1991. Estimation of Dall sheep numbers in Wrangell-St. Elias National Park and Preserve-July 1991. Technical Research Work Order prepared for the National Park Service, Alaska Region. Anchorage, AK

Mt. Sanford Tribal Consortium. 2004. Whouy sze kuinalth, “Teaching our many Grandchildren “, A Curriculum Guide. Internet: http://www.ankn. uaf.edu/curriculum/Whouy_Sze_Kuinalth/index.html

NPS. 1995. Customary and traditional use reference for the Copper River Basin Area. Reference prepared by the National Park Service for the Federal Subsistence Board.

NPS. 2013. Monitoring Dall’s sheep in the Central Alaska Network. Alaska Region Inventory and Monitoring Program, Resource Brief 2197712, No. 44. Fairbanks, AK.

Putera, J. 2019. Wildlife Biologist. Personal Communications (email, June 14). Wrangell-St. Elias NP&P, Copper Center, AK.

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Schwanke, R.A. 2011. Unit 11 Dall sheep management report, Pages 13-29 in P. Harper, editor. Dall sheep management report of surveys and inventory activities 1 July 2007-30 June 2010. ADF&G, Project 6.0. Juneau AK.

SCRAC. 1998. Transcripts of the Southcentral Alaska Subsistence Regional Advisory Council proceedings, March 18, 1998. Office of Subsistence Management. FWS. Anchorage, AK.

SCRAC. 2004. Transcripts of the Southcentral Alaska Subsistence Regional Advisory Council proceedings, March 10, 2004. Office of Subsistence Management. FWS. Anchorage, AK.

Simeone, W.E. 2006. Some ethnographic and historical information on the use of large land mammals in the Copper River Basin, Resource Report, NPS/AR/CRR-2006-56, National Park Service, Alaska Region, 50pp.

Strickland, D.L., L.L. McDonald, J. Kern, and K. Jenkins. 1993. Estimation of the number of Dall sheep in the Wrangell-St. Elias National Park and Preserve-July 1992. National Park Service, Alaska Region, Technical Research Work Order. Anchorage, AK.

USFWS. 2019. Federal permit database, Office of Subsistence Management, microcomputer data-base. Retrieved May 21, 2019.

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WRITTEN PUBLIC COMMENTS

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 169 Wildlife Proposal WP20-19 DRAFT Staff Analysis

F D F TRA T

T T T

T “gathering period”. The problem lies with strict attendance policies at school (no more than 15 T

T

170 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Wildlife Proposal WP20-19 DRAFT Staff Analysis

June 16, 2019

From: Russell and Sherri Scribner

Dear Federal Subsistence Board and Regional Advisory Committees,

I am in favor of WP 20-19 because it makes sense. I believe that adopting this recommendation will realistically provide what the current elder/youth combination regulation intends- to encourage the passing on of hunting traditions from one generation to the next. Under the current regulation, waiting until I'm sixty to take my son and daughter sheep hunting would be a disadvantage. Subsistence backpack hunts starting at river level and carrying 60 pounds of food and camp over mountains is very physically demanding. Adding gear too heavy for youth to carry and 80 pounds of meat and horns on the way back out requires stamina better suited for middle aged mentors. As WP 20-19 proposes, I believe that separating the elder and youth hunt into two distinct hunts is a great idea. My father took me on my first backpacking sheep hunt when I was 11 and thankfully he was strong enough to pack out most of the meat since I only weighed 70 pounds at the time.

Sincerely,

Russell Scribner

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From: Jim Lorence Date: Tue, Jun 18, 2019 at 5:25 PM Subject: [EXTERNAL] comments on proposal WP 20-19 To: [email protected] Dear Federal Subsistence Board and Regional Advisory Committee:

WP 20-19 Proposal Comments

I am in support of this proposal for the following reasons:

1. The current regulation incorporates a special provision (Federal Joint permit FS1103) which would inherently be for the intent of the elder being able to pass down traditional sheep hunting knowledge and experience to a youth. Anyone who has hunted sheep is well aware of the intense physical demands it requires. By requiring an elder to be 60 or older to take a youth just about negates the current special provision. Youth would be far better served in being able to learn and gain traditional skills and knowledge from an experienced middle aged adult that is far more capable of taking a youth safely on a sheep hunt.

2. Separating the current regulation into two parts makes sense in that it still maintains an elder hunt, but also allows for a youth hunt (for the reasons stated in #1).

3. Increasing the youth age range from 8-15 to 8-17 also makes sense in that it allows for the stronger youth to have this opportunity (the youth aged 16 and 17). Sheep hunting is very challenging and physically strenuous, and opening it to ages 8-17 makes sense.

Thank you. Sincerely, Jim Lorence

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From: Rebecca Schwanke Date: Wed, Jun 26, 2019 Subject: [EXTERNAL] WP 20-19 comments To: [email protected]

Dear Mr. Matuskowitz,

Please accept my written comments on WP 20-19, an amended version of the elder sheep hunt for Unit 11.

I would like to offer my support for this proposal.

I firmly believe in what the proposal author states "Youth hunters are the most critical component of maintaining a strong cultural awareness of our hunting heritage. Local youth begin hunting small game and waterfowl. As they learn effective hunting techniques, respect and skill, they slowly graduate to hunting big game species".

The opportunity for kids to hunt sheep is limited for several reasons. Relatively speaking, there are a limited pool of parents with the knowledge, interest, ability and time to sheep hunt. For those of us already hunting with our young kids, we have learned that it takes extra time, patience and luck for a kid to successfully harvest a big game animal. The rigors of competing with other sheep hunters in relatively accessible federal hunting areas makes taking a kid on a sheep hunt that much more daunting. The result is that few kids get to hunt sheep.

The elder hunt in Unit 11 in Wrangell St. Elias National Park and Preserve is a great concept, offering elders and kids the opportunity to get into the mountains together, but it rarely works out. Only a small number of elders are still able to hunt sheep, and fewer yet are in a position to take a kid. I have participated in Unit 11 elder sheep hunts, and I will likely do this again. I would also like the opportunity to accompany an elder and my own son on a sheep hunt some day, both with the opportunity to harvest a sheep.

This proposal allows elders to continue to utilize the longer hunting season, while also allowing middle aged parents who are often more able, to take their own kids sheep hunting during the same time frame with limited competition.

The main benefit of youth-specific hunts is so these kids have great hunting experiences when they're young. This is the best way to help a kid enjoy hunting. There is no biological reason not to allow kids to have their own permit and their own bag limit. It's hard to explain, but kids get really excited about harvesting their own game.

Sheep hunting can be physically demanding. Some 8 year olds are ready to hunt sheep, some kids not until they're a bit older. This is a decision that parents have to make for their own kids. Youth hunts have the biggest impact if all youth are able to participate, when they are ready.

Allowing kids to sheep hunt prior to school starting and prior to other local sheep, caribou and moose hunts is really helpful so families can do both if need be to harvest enough game for the year. The opportunity to hunt late in the season may not be utilized often, but it will afford families a chance to get their kids sheep following the regular season.

I appreciate your time and efforts. Thank you for the opportunity to comment.

Regards, Becky Schwanke

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WP20–08 Executive Summary

General Description Proposal WP20–08 requests implementing a statewide requirement that traps and snares be marked with either the trapper’s name or State identification number. Submitted by: East Prince of Wales Advisory Committee.

Proposed Regulation Statewide— Trapping (General Provisions)

Traps or snares must be marked with trapper’s name or state identification number (Alaska driver’s license number or State identification card number).

OSM Preliminary Conclusion Oppose

Southeast Alaska Subsistence Regional Advisory Council Recommendation

Southcentral Alaska Subsistence Regional Advisory Council Recommendation

Kodiak/Aleutians Subsistence Regional Advisory Council Recommendation

Bristol Bay Subsistence Regional Advisory Council Recommendation

Yukon-Kuskokwim Delta Subsistence Regional Advisory Council Recommendation

Western Interior Alaska Subsistence Regional Advisory Council Recommendation

Seward Peninsula Subsistence Regional Advisory Council Recommendation

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Wildlife Proposal WP20-08 DRAFT Staff Analysis

WP20–08 Executive Summary

Northwest Arctic Subsistence Regional Advisory Council Recommendation

Eastern Interior Alaska Subsistence Regional Advisory Council Recommendation

North Slope Subsistence Regional Advisory Council Recommendation

Interagency Staff Committee Comments

ADF&G Comments

Written Public Comments 1 Support, 1 Oppose

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Wildlife Proposal WP20-08 DRAFT Staff Analysis

DRAFT STAFF ANALYSIS WP20-08

ISSUES

Wildlife Proposal WP20-08, submitted by the East Prince of Wales Fish and Game Advisory Committee, requests implementing a statewide requirement that traps and snares be marked with either the trapper’s name or State identification number.

DISCUSSION

The proponent believes that current regulations do not allow for accountability if a trapper leaves their traps out and set after the close of the season, or chooses to use illegal baits (i.e., whole chunks of deer meat or whole migratory birds). The proponent believes requiring trap identification (Alaska issued driver’s license number or personal identification number) would make enforcement easier and may prevent these issues. Clarification with the proponent indicated that the proposed marking requirement is to apply Statewide.

Existing Federal Regulation

There are no statewide trap marking requirements under Federal regulations.

Proposed Federal Regulation

Statewide— Trapping (General Provisions)

Traps or snares must be marked with trapper’s name or state identification number (Alaska driver’s license number or State identification card number).

Existing State Regulation

There are no statewide trap marking requirements under State regulations.

Extent of Federal Public Lands/Waters

Alaska is comprised of 65% Federal public lands and consist of 23% Bureau of Land Management (BLM) managed lands, 21% U.S. Fish and Wildlife Service (USFWS) managed lands, 15% National Park Service (NPS) managed lands, and 6% U.S. Forest Service (USFS) managed lands.

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Wildlife Proposal WP20-08 DRAFT Staff Analysis

Customary and Traditional Use Determinations

Customary and traditional use determinations for specific areas and species are found in subpart C of 50 CFR 100, §___.24(a)(1) and 36 CFR 242 §___.24(a)(1).

Regulatory History

The Alaska Board of Game (BOG) adopted a marking requirement for traps and snares in Units 1–5 in 2006. Federal regulations were aligned with the State requirements in Units 1–5 when the Federal Subsistence Board (Board) adopted Proposal WP12-14 in 2012. The rationale of the Board was that the BOG adopted trap marking requirements for Units 1-5 in 2006 in response to concerns by Alaska Wildlife Troopers, the Alaska Department of Fish and Game (ADF&G), and members of the public, that trapping as a whole would benefit from having some way of identifying ownership of traps and snares. This was prompted by incidences of traps being placed in areas where trapping was not allowed, pets being caught in traps, and unattended snares still capable of capturing a passing deer, bear, or wolf, being found following the close of season (FSB 2012).

The Southeast Alaska Subsistence Regional Advisory Council (Council) expressed concern that there was a lack of evidence why traps should be marked in either State or Federal regulations, and stated that regulations should be adopted for a good reason and not because of “one bear caught in a snare, set by an unknown person for an unknown reason”. However, the Council supported the proposal, stating the benefit of aligning Federal and State regulations, and reducing the uncertainty about whether current regulations required traps to be marked (SEASRAC 2011).

In 2014, the Board considered Proposal WP14-01, requesting new statewide Federal provisions requiring trapper identification tags on all traps and snares, the establishment of a maximum allowable time limit for checking traps, and establishment of a harvest/trapping report form to collect data on non-target species captured in traps and snares. The proposal analysis indicated statewide application would be unmanageable, would require substantial law enforcement and public education efforts, and could cause subsistence users to avoid the regulation by trapping under State regulations. The proposal was unanimously opposed by all ten Federal Subsistence Regional Advisory Councils, ADF&G, and the public as reflected in written public comments. The Board rejected the proposal as part of its consensus agenda (FSB 2014).

In March 2016, the BOG removed trap marking requirements in response to Proposal 78. The BOG determined that trappers are generally responsible and that the 2006 regulation was not addressing the reasons why it was implemented, noting that marking traps does not prevent illegal trapping activity or prevent dogs from getting trapped.

In 2018, the Board considered Proposal WP18-13, requesting removal of the trap marking requirement in Units 1-5. The proposal was submitted to remove an unnecessary and burdensome requirement on Federally qualified subsistence users and to realign State and Federal regulations. While ADF&G was neutral on the proposal, it was unanimously supported by the Council (SEASRAC 2017). The proposal was adopted by the Board as part of its consensus agenda (FSB 2018).

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Wildlife Proposal WP20-08 DRAFT Staff Analysis

Current Events Involving the Species

Wildlife proposal WP20-20 has been submitted requesting that trap sites be marked with brightly colored surveyor's tape in plain view on a nearby tree or overhanging branch in Unit 7.

Effects of the Proposal

The proposal will not result in any positive or negative effects to furbearer or other non-furbearer wildlife populations.

If the proposal is adopted, Federally qualified subsistence users trapping under Federal regulations throughout the State will be required to mark traps and snares with identification tags. The proposed requirement could potentially benefit law enforcement by allowing easier identification of traps and snares set in the field. However, differences in land ownership, population concentrations, terrain, and habitats would limit the effectiveness of the proposed statewide regulation. Individual traplines can span across Federal and State managed lands and, therefore, could have different regulatory requirements along the line. Alternatively, Federally qualified subsistence users could simply choose to trap under State regulations and avoid the proposed requirement, as both Federal and State trapping regulations are applicable on most Federal public lands, as long as the State regulations are not inconsistent with or superseded by Federal regulations, or unless Federal lands are closed to non-Federally qualified users.

Within portions of Unit 15, over 60 percent which lies within Kenai National Wildlife Refuge, and those portions of Unit 7 that are contained within Kenai NWR, a trapping permit is required and a stipulation of Kenai NWR’s permit includes the marking of traps and snares. Also, under State regulations, all snares within a quarter mile of a public road in Units 12 and 20E are required to be marked. Federally qualified subsistence users trapping on Federal public lands outside of these specific areas would be required to mark traps and snares with identification tags that include the trapper’s name and license number. However, Federally qualified subsistence users trapping on Federal public lands would not be required to mark traps and snares under State regulations.

The requirement to mark traps and snares would also result in additional burden and cost for Federally qualified subsistence users trapping under Federal subsistence regulations. Copper tags stamped with a trapper’s identification information, including fasteners, cost approximately $26 per 100 tags (including shipping) or less (approximately $15–$20) for “write-your own” tags (FWS 2012). In addition, trappers often trade or borrow equipment from family members or friends, and changes of identification tags on large numbers of traps or snares would require significant effort (FWS 2014).

Re-implementation of a mandatory requirement to mark traps under Federal regulations creates unnecessary divergence of State and Federal regulations, which may create confusion for Federally qualified subsistence users. Although adoption of the proposal could allow law enforcement to more easily identify trappers that have traps deployed outside the open season or have otherwise violated regulations, mandatory trap marking does not necessarily prevent illegal trapping activity or prevent dogs from getting trapped. Also, adoption of this proposal will not affect State regulations, which would allow Federally qualified subsistence users to operate traps under State regulations to avoid this requirement.

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Wildlife Proposal WP20-08 DRAFT Staff Analysis

OSM PRELIMINARY CONCLUSION

Oppose Proposal WP20-08.

Justification

Requiring Federally qualified subsistence users to mark traps is an unnecessary burden, as mandatory marking does not prevent illegal trapping activity. With State regulations being less restrictive, Federally qualified subsistence users could avoid the requirement by trapping under those regulations, essentially rendering a Federal marking requirement unenforceable. There is no anticipated conservation concern to furbearers with opposing this proposal, as there is no established correlation between furbearer harvest levels and trap marking requirements. Adoption of this proposal also creates unnecessary divergence between State and Federal regulations.

LITERATURE CITED

FSB. 2012. Transcripts of Federal Subsistence Board proceedings, January 17-20, 2012. Office of Subsistence Management, USFWS. Anchorage, AK.

FSB. 2014. Transcripts of Federal Subsistence Board proceedings, April 15-17, 2014. Office of Subsistence Management, USFWS. Anchorage, AK.

FSB. 2018. Transcripts of Federal Subsistence Board proceedings, April 11-13, 2018. Office of Subsistence Management, USFWS. Anchorage, AK.

FWS. 2012. Staff Analysis WP12-14. Pages 969-976 in Federal Subsistence Board Meeting Materials January 17– 2012. Office of Subsistence Management, USFWS. Anchorage, AK. 1,020 pages.

FWS. 2014. Staff Analysis WP14-01. Pages 352-367 in Federal Subsistence Board Meeting Materials April 15-17, 2014. Office of Subsistence Management, USFWS. Anchorage, AK. 628 pages.

SEASRAC. 2011. Transcripts of the Southeast Alaska Subsistence Regional Advisory Council, September 27-29, 2011 in Wrangell, Alaska. Office of Subsistence Management, USFWS. Anchorage, AK.

SEASRAC. 2017. Transcripts of the Southeast Alaska Subsistence Regional Advisory Council, October 31- November 2, 2017 in Juneau, Alaska. Office of Subsistence Management, USFWS. Anchorage, AK.

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Wildlife Proposal WP20-08 DRAFT Staff Analysis

WRITTEN PUBLIC COMMENTS

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Fisheries Resource Monitoring Program Overview

FISHERIES RESOURCE MONITORING PROGRAM

BACKGROUND

Section 812 of the Alaska National Interest Lands Conservation Act (ANILCA) directs the Departments of the Interior and Agriculture, cooperating with other Federal agencies, the State of Alaska, and Alaska Native and other rural organizations, to research fish and wildlife subsistence uses on Federal public lands; and to seek data from, consult with, and make use of the knowledge of local residents engaged in subsistence. When the Federal government assumed responsibility for management of subsistence fisheries on Federal public lands and waters in Alaska in 1999, the Secretaries of the Interior and Agriculture made a commitment to increase the quantity and quality of information available to manage subsistence fisheries, to increase quality and quantity of meaningful involvement by Alaska Native and other rural organizations, and to increase collaboration among Federal, State, Alaska Native, and rural organizations. The Fisheries Resource Monitoring Program (Monitoring Program) is a collaborative, interagency, interdisciplinary approach to enhance fisheries research and data in Alaska and effectively communicate information needed for subsistence fisheries management on Federal public lands and waters.

Every two years, the Office of Subsistence Management announces a funding opportunity for investigation plans addressing subsistence fisheries on Federal public lands. The 2020 Notice of Funding Opportunity focused on priority information needs developed by the Subsistence Regional Advisory Councils with input from strategic plans and subject matter specialists. The Monitoring Program is administered through regions to align with stock, harvest, and community issues common to a geographic area. The six Monitoring Program regions are shown below.

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Strategic plans sponsored by the Monitoring Program have been developed by workgroups of fisheries managers, researchers, Subsistence Regional Advisory Councils, and by other stakeholders for three of the six regions: Southeast, Southcentral (excluding Cook Inlet Area), and Southwest Alaska, and for Yukon and Kuskokwim drainages whitefish (available for viewing at the Monitoring Program webpage at https://www.doi.gov/subsistence/frmp/plans). These plans identify prioritized information needs for each major subsistence fishery. Individual copies of plans are available from the Office of Subsistence Management by calling (907) 786-3888 or toll Free: (800) 478-1456 or by email [email protected]. An independent strategic plan was completed for the Kuskokwim Region for salmon in 2006 and can be viewed at the Alaska-Yukon-Kuskokwim Sustainable Salmon Initiative website at https://www.aykssi.org/salmon-research-plans/.

Investigation plans are reviewed and evaluated by Office of Subsistence Management and U.S. Forest Service staff, and then scored by the Technical Review Committee. The Technical Review Committee’s function is to provide evaluation, technical oversight, and strategic direction to the Monitoring Program. Each investigation plan is scored on the following five criteria: strategic priority, technical and scientific merit, investigator ability and resources, partnership and capacity building, and cost/benefit.

Project executive summaries are assembled into a draft 2020 Fisheries Resources Monitoring Plan. The draft plan is distributed for public review and comment through Subsistence Regional Advisory Council meetings, beginning in September 2019. The Federal Subsistence Board will review the draft plan and will accept written and oral comments at its January 2020 meeting. The Federal Subsistence Board forwards its comments to the Assistant Regional Director of the Office of Subsistence Management. Final funding approval lies with the Assistant Regional Director of the Office of Subsistence Management. Investigators are subsequently notified in writing of the status of their proposals.

HISTORICAL OVERVIEW

The Monitoring Program was first implemented in 2000 with an initial allocation of $5 million. Since 2000, a total of $117 million has been allocated for the Monitoring Program to fund a total of 452 projects (Figure 1 and Figure 2).

During each two-year funding cycle, the Monitoring Program budget funds ongoing multi-year projects (2, 3, or 4 years) as well as new projects. Budget guidelines are established by geographic region (Table 1). The regional guidelines were developed using six criteria that included level of risk to species, level of threat to conservation units, amount of subsistence needs not being met, amount of information available to support subsistence management, importance of a species to subsistence harvest, and level of user concerns regarding subsistence harvest. Budget guidelines provide an initial target for planning; however, they are not final allocations and are adjusted annually as needed (Figure 3).

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Figure 1. Monitoring Program Funds Distributed, by Organization Type, Since 2000

State of Alaska $30,630,000 $19,461,000 Alaska Rural

US Department of the Interior $15,876,000 US Department of Agriculture

$46,180,000 Other

$4,766,000

Figure 2. Number of Monitoring Program Projects Funded, by Organization Type, since 2000

200 183

150 135

100 75 Number of Projects Funded

50 33 26

0 State of Alaska Alaska Rural US Department of US Department of Other the Interior Agriculture

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Fisheries Resource Monitoring Program Overview

Table 1 R F R F

U.S. Department of the U.S. Department of Region Interior Funds Agriculture Funds A D D A A A R

Figure 3. Percentages of Monitoring Program Funding Distributed to Each Region since 2000

Yukon 18% Kuskokwim 22%

Multi-Regional Southwest 2% 10% Northern 10%

Southeast 22% Southcentral 16%

The following three broad categories of information that are solicited for the Monitoring Program: (1) harvest monitoring, (2) traditional ecological knowledge, and (3) stock status and trends. Projects that combine these approaches are encouraged. Definitions of these three categories of information are listed below.

Harvest monitoring studies provide information on numbers and species of fish harvested, locations of harvests, and gear types used. Methods used to gather information on subsistence harvest patterns may

190 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Fisheries Resource Monitoring Program Overview include harvest calendars, mail-in questionnaires, household interviews, subsistence permit reports, and telephone interviews.

Traditional ecological knowledge studies are investigations of local knowledge directed at collecting and analyzing information on a variety of topics, including: the sociocultural aspects of subsistence, fish ecology, species identification, local names, life history, taxonomy, seasonal movements, harvests, spawning and rearing areas, population trends, environmental observations, and traditional management systems. Methods used to document traditional ecological knowledge include ethnographic fieldwork, key respondent interviews with local experts, place name mapping, and open-ended surveys.

Stock status and trends studies provide information on abundance and run timing; age, size, and sex composition; migration and geographic distribution; survival of juveniles or adults; stock production; genetic stock identification; and mixed stock analyses. Methods used to gather information on stock status and trends include aerial and ground surveys, test fishing, towers, weirs, sonar, video, genetics, mark-recapture, and telemetry.

PROJECT EVALUATION PROCESS

In the current climate of increasing conservation concerns and subsistence needs, it is imperative that the Monitoring Program prioritizes high quality projects that address critical subsistence questions. Projects are selected for funding through an evaluation and review process that is designed to advance projects that are strategically important for the Federal Subsistence Management Program, are technically sound, administratively competent, promote partnerships and capacity building, and are cost effective. Projects are evaluated by a panel called the Technical Review Committee. This committee is a standing interagency committee of senior technical experts that is foundational to the credibility and scientific integrity of the evaluation process for projects funded by the Monitoring Program. The Technical Review Committee reviews, evaluates, and makes recommendations about proposed projects, consistent with the mission of the Monitoring Program. Fisheries and Anthropology staff from the Office of Subsistence Management provide support for the Technical Review Committee. Recommendations from the Technical Review Committee provide the basis for further comments from Subsistence Regional Advisory Councils, the public, the Interagency Staff Committee, and the Federal Subsistence Board, with final approval of the Monitoring Plan by the Assistant Regional Director of the Office of Subsistence Management.

To be considered for funding under the Monitoring Program, a proposed project must have a nexus to Federal subsistence fishery management. Proposed projects must have a direct association to a Federal subsistence fishery, and the subsistence fishery or fish stocks in question must occur in or pass through waters within or adjacent to Federal public lands in Alaska (National Wildlife Refuges, National Forests, National Parks and Preserves, National Conservation Areas, National Wild and Scenic River Systems, National Petroleum Reserves, and National Recreation Areas). A complete project package must be submitted on time and must address the following five specific criteria to be considered a high quality project.

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1. Strategic Priorities—Studies should be responsive to information needs identified in the 2020 Priority Information Needs available at the Monitoring Program webpage at https://www.doi.gov/subsistence/frmp/funding. All projects must have a direct linkage to Federal public lands and/or waters to be eligible for funding under the Monitoring Program. To assist in evaluation of submittals for projects previously funded under the Monitoring Program, investigators must summarize project findings in their investigation plans. This summary should clearly and concisely document project performance, key findings, and uses of collected information for Federal subsistence management. Projects should address the following topics to demonstrate links to strategic priorities:

 Federal jurisdiction—The extent of Federal public waters in or nearby the project area  Direct subsistence fisheries management implications  Conservation mandate—Threat or risk to conservation of species and populations that support subsistence fisheries

 Potential impacts on the subsistence priority—Risk that subsistence harvest users’ goals will not be met

 Data gaps—Amount of information available to support subsistence management and how a project answers specific questions related to these gaps

 Role of the resource—Contribution of a species to a subsistence harvest (number of villages affected, pounds of fish harvested, miles of river) and qualitative significance (cultural value, unique seasonal role)

 Local concern—Level of user concerns over subsistence harvests (upstream vs. downstream allocation, effects of recreational use, changes in fish abundance and population characteristics)

2. Technical-Scientific Merit—Technical quality of the study design must meet accepted standards for information collection, compilation, analysis, and reporting. To demonstrate technical and scientific merit, applicants should describe how projects will:

 Advance science  Answer immediate subsistence management or conservation concerns  Have rigorous sampling and/or research designs  Have specific, measurable, realistic, clearly stated, and achievable (attainable within the proposed project period) objectives

 Incorporate traditional knowledge and methods

Data collection, compilation, analysis, and reporting procedures should be clearly stated. Analytical procedures should be understandable to the non-scientific community. To assist in evaluation of submittals for continuing projects previously funded under the Monitoring

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Program, summarize project findings and justify continuation of the project, placing the proposed work in context with the ongoing work being accomplished.

3. Investigator Ability and Resources—Investigators must show they are capable of successfully completing the proposed project by providing information on the ability (training, education, experience, and letters of support) and resources (technical and administrative) they possess to conduct the work. Investigators that have received funding in the past, via the Monitoring Program or other sources, are evaluated and scored on their past performance, including fulfillment of meeting deliverable and financial accountability deadlines. A record of failure to submit reports or delinquent submittal of reports will be taken into account when rating investigator ability and resources.

4. Partnership and Capacity Building—Investigators must demonstrate that capacity building has already reached the communication or partnership development stage during proposal development and, ideally, include a strategy to develop capacity building to higher levels, recognizing, however, that in some situations higher level involvement may not be desired or feasible by local organizations.

Investigators are requested to include a strategy for integrating local capacity development in their study plans or research designs. Investigators should inform communities and regional organizations in the area where work is to be conducted about their project plans, and should also consult and communicate with local communities to ensure that local knowledge is utilized and concerns are addressed. Investigators and their organizations should demonstrate their ability to maintain effective local relationships and commitment to capacity building. This includes a plan to facilitate and develop partnerships so that investigators, communities, and regional organizations can pursue and achieve the most meaningful level of involvement. Proposals demonstrating multiple, highly collaborative efforts with rural community members or Alaska Native Organizations are encouraged.

Successful capacity building requires developing trust and dialogue among investigators, local communities, and regional organizations. Investigators need to be flexible in modifying their work plan in response to local knowledge, issues, and concerns, and must also understand that capacity building is a reciprocal process in which all participants share and gain valuable knowledge. The reciprocal nature of the capacity building component(s) should be clearly demonstrated in proposals. Investigators are encouraged to develop the highest level of community and regional collaboration that is practical including joining as co-investigators.

Capacity can be built by increasing the technical capabilities of rural communities and Alaska Native organizations. This can be accomplished via several methods, including increased technical experience for individuals and the acquisition of necessary gear and equipment. Increased technical experience would include all areas of project management including logistics, financial accountability, implementation, and administration. Other examples may include internships or providing opportunities within the project for outreach, modeling, sampling design,

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or project specific training. Another would be the acquisition of equipment that could be transferred to rural communities and tribal organizations upon the conclusion of the project.

A “meaningful partner” is a partner that is actively engaged in one or more aspects of project design, logistics, implementation and reporting requirements. Someone who simply agrees with the concept or provides a cursory look at the proposal is not a meaningful partner.

5. Cost/Benefit—This criterion evaluates the reasonableness (what a prudent person would pay) of the funding requested to provide benefits to the Federal Subsistence Management Program. Benefits could be tangible or intangible. Examples of tangible outcomes include data sets that directly inform management decisions or fill knowledge gaps and opportunities for youth or local resident involvement in monitoring, research and/or resource management efforts. Examples of possible intangible goals and objectives include enhanced relationships and communications between managers and communities, partnerships and collaborations on critical resource issues, and potential for increased capacity within both communities and agencies.

Applicants should be aware that the Government shall perform a “best value analysis” and the selection for award shall be made to the applicant whose proposal is most advantageous to the Government. The Office of Subsistence Management strives to maximize program efficiency by encouraging cost sharing, partnerships, and collaboration.

POLICY AND FUNDING GUIDELINES

Several policies have been developed to aid in implementing funding. These policies include:

 Projects of up to four years in duration may be considered

 Proposals requesting Monitoring Program funding that exceeds $215,000.00 in any one year are not eligible for funding

 Studies must not duplicate existing projects

 Long term projects will be considered on a case by case basis

Activities that are not eligible for funding include:

 Habitat protection, mitigation, restoration, and enhancement

 Hatchery propagation, restoration, enhancement, and supplementation

 Contaminant assessment, evaluation, and monitoring

 Projects where the primary or only objective is outreach and education (for example, science camps, technician training, and intern programs), rather than information collection

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The rationale behind these policy and funding guidelines is to ensure that existing responsibilities and efforts by government agencies are not duplicated under the Monitoring Program. Land management or regulatory agencies already have direct responsibility, as well as specific programs, to address these activities. However, the Monitoring Program may fund research to determine how these activities affect Federal subsistence fisheries or fishery resources.

The Monitoring Program may fund assessments of key Federal subsistence fishery stocks in decline or that may decline due to climatological, environmental, habitat displacement, or other drivers; however, applicants must show how this knowledge would contribute to Federal subsistence fisheries management. Similarly, the Monitoring Program may legitimately fund projects that assess whether migratory barriers (e.g., falls, beaver dams) significantly affect spawning success or distribution; however, it would be inappropriate to fund projects to build fish passes, remove beaver dams, or otherwise alter or enhance habitat.

2020 FISHERIES RESOURCE MONITORING PLAN

For 2020, a total of 28 investigation plans were received and all are considered eligible for funding. For 2020, the Department of the Interior, through the U.S. Fish and Wildlife Service, will provide an anticipated $1.5 million in funding statewide for new projects. The U.S. Department of Agriculture, through the U.S. Forest Service, has historically provided some funding. The amount of U.S. Department of Agriculture funding available for 2020 projects is uncertain.

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FISHERIES RESOURCE MONITORING PROGRAM YUKON REGION OVERVIEW

Since the inception of the Monitoring Program in 2000, a total of 114 projects have been undertaken in the Yukon Region costing $20.6 million (Figure 1). Of these, the State of Alaska received funds to conduct 26 projects, Alaska rural organizations conducted 19 projects, the Department of the Interior conducted 49 projects, and other organizations conducted 20 projects (Figure 2). See Appendix 1 for more information on Yukon Region projects completed since 2000.

Figure 1. Monitoring Program Funds Distributed, by Organization Type, in the Yukon Region since 2000 $1,030,000

State of Alaska $5,150,000 Alaska Rural

US Department of the Interior $11,536,000 $2,884,000 Other

Figure 2. Number of Monitoring Program Projects Funded, by Organization Type, in the Yukon Region since 2000 60

49 50

40

30 26 19 20 20 Number of Projects 10

0 State of Alaska Alaska Rural US Department of the Other Interior

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PRIORITY INFORMATION NEEDS

The 2020 Notice of Funding Opportunity for the Yukon Region identified the following 17 priority information needs:

 Reliable estimates of Chinook, Summer Chum, Fall Chum, and Coho salmon escapements, particularly sub-stocks that are large contributors to the total run.

 In-season estimates of genetic stock composition of Chinook, Summer Chum, and Fall Chum salmon runs and harvests.

 Baseline information about geographic distribution, migration patterns, run timing, genetic structure, and tributary escapements of Yukon River Coho Salmon. Projects might focus on those portions of the Yukon River drainage downriver from and including the Tanana River.

 Reliable assessment of Porcupine River Fall Chum Salmon, for example, migration characteristics, abundance, escapement, and harvest quantities.

 Reliable quantitative and/or qualitative estimates of age-sex-length and genetic composition of salmon harvested in the subsistence fishery. Applicants are encouraged to focus on Chinook and Fall Chum Salmon.

 Advance genetic baselines for Chinook, Summer Chum, and Fall Chum salmon by screening novel genetic markers to improve the accuracy, precision, and scale of stock-composition estimates to inform stock assessment.

 Reliable methods of forecasting Chinook, Summer Chum, Fall Chum, and Coho salmon run abundance.

 Quality of escapement measures for Chinook Salmon, for example, potential egg deposition, age, sex, and size composition of spawners, percentage of females, percentage of jacks, and spawning habitat utilization.

 Bering Cisco population assessment.

 Information sharing between stakeholders and agencies concerning management of subsistence fisheries.

 Baseline information about lamprey populations, migration patterns, and harvest quantities.

 Baseline information about whitefish populations, migration patterns, and harvest, particularly those where habitat and traditional harvest practices could be affected by proposed road and mine development.

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 Quantify and qualify the barter and cash exchange of salmon within the context of the social, cultural, and economic life of people in the middle and lower Yukon drainage.

 Assessment of incidental mortality with gillnets, dip nets, and seines, with particular consideration for delayed mortality from entanglement from drop-outs and live release of Chinook Salmon (for example, loss of Chinook Salmon from 6-inch mesh nets during Chum Salmon fisheries and the live release of Chinook Salmon from dip nets and seines).

 Strategic evaluation of existing and needed information concerning Chinook Salmon and Summer Chum Salmon run timing, escapement, and population in the middle and upper Yukon drainage, particularly the Middle Fork Koyukuk River.

 Analysis of recent regulations changes and effects on salmon escapement in the Yukon River drainage.

 Reliable quantitative and/or qualitative estimates of in-season salmon harvest to support management.

AVAILABLE FUNDS

Federal Subsistence Board guidelines direct initial distribution of funds among regions. Regional budget guidelines provide an initial target for planning. For 2020, the Department of the Interior, through the U.S. Fish and Wildlife Service, will provide an anticipated $1.5 million in funding statewide for new projects in 2020. The U.S. Department of Agriculture, through the U.S. Forest Service, has historically provided some funding. The amount of U.S. Department of Agriculture funding available for 2020 projects is uncertain.

ROLE OF THE TECHNICAL REVIEW COMMITTEE

The mission of the Monitoring Program is to identify and provide information needed to sustain subsistence fisheries on Federal public lands for rural Alaskans through a multidisciplinary and collaborative program. It is the responsibility of the Technical Review Committee to develop the strongest possible Monitoring Plan for each region and across the entire state.

For the 2020 Monitoring Program, eight proposals were submitted for the Yukon Region. The Technical Review Committee evaluated and scored each proposal on Strategic Priority, Technical and Scientific Merit, Investigator Ability and Resources, Partnership and Capacity Building, and Cost/Benefit (Table 1). These scores remain confidential. An executive summary for each proposal submitted to the 2020 Monitoring Program for the Yukon Region is in Appendix 2.

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Table 1 R Total Average Project Title Project Annual Number Request Request R R T

A R

R A

A R T A R A

F R

R

T R

R T

Total

TECHNICAL REVIEW COMMITTEE JUSTIFICATION FOR PROPOSAL SCORES

Project Number: 20-200 Project Title: Yukon River Coho Salmon Radio Telemetry

Technical Review Committee Justification: The investigators seek funding for a three-year project to conduct a Coho Salmon radio telemetry project on the Yukon River and its tributaries. The objectives are to identify migration routes, spawning locations, run timing, migration rates, distribution, and proportional contributions of fish from different spawning stock groups to the overall Yukon River Coho Salmon population. Radio tracking will only occur during the second year of the project, and will not document the inter-annual variability in run timing and stock productivity, increasing the risk of funding a project of this magnitude. This project fully addressed one priority information need. Information from this project will lead investigators to locations to focus on escapement monitoring and sample collection to add to the genetic baseline; however, the proposal does not adequately describe how the project addresses subsistence concerns. The project has objectives that are clear, measurable, and achievable, with well thought out logistics. The investigators have experience with these types of projects, and have successfully performed them in this drainage in the past. However, as in the 2018 project proposal, there is little information on how they determined sample size, or if it will have the resolution to meet objective 3 (Estimate proportional contributions of fish from five drainage groups to the overall Yukon River Coho Salmon population with 95% confidence interval bounds which will be no wider than 7% of the mean). There has been significant partner involvement with the development of this proposal by the Alaska

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Department of Fish and Game, Yukon Delta Fishermen’s Association, and the U.S. Fish and Wildlife Service. Capacity will be built by training local hires in sampling techniques and data entry. The total projected cost is $771,251 for the three years of the project. The investigators are asking for a total of $456,219 from the Fisheries Resource Monitoring Program with an average annual cost to the Monitoring Program of $152,073. The remainder would come from the Alaska Department of Fish and Game, the United States Fish and Wildlife Service, and Yukon Delta Fishermen’s Association.

Project Number: 20-201 Project Title: Application of Mixed-Stock Analysis for Yukon River Chum Salmon

Technical Review Committee Justification: Investigators seek funding to resume in-season mixed stock genetic analysis of Yukon River summer and fall Chum Salmon. The samples, collected in conjunction with the Pilot Station sonar run by the Alaska Department of Fish and Game, are shipped to the U.S. Fish and Wildlife Service Genetics Conservation Lab in Anchorage for analysis, providing stock composition estimates to fisheries managers within 24-48 hours, and supporting the in-season management of Chum Salmon. This project directly addresses one priority information need. The objectives are clear, measurable, and achievable with a sampling design that is rigorous. The investigation plan includes reporting procedures, although the annual reports would not be completed for almost two years after the field season is completed, which may be an excessive delay. No letters of support were submitted with this project and it is suggested that the investigators ask their partners and other entities in the region to submit letters of support in the future. There is very little capacity built with this project, however, some technical capacity will be built by training a local hire in proper sampling techniques. The investigation plan suggests a total project cost of $628,128 for four years of the project, of which $110,000 is a match from the U.S. Fish and Wildlife Service Conservation Genetics Lab. The average annual cost to the Monitoring Program is $129,532. The cost of the proposal is reasonable throughout all agreement periods and is reasonable for the work being proposed.

Project Number: 20-202 Project Title: Evaluating Dart and Telemetry Tags in an Effort to Track Run Timing and Migration Patterns of Yukon River Arctic Lamprey

Technical Review Committee Justification: Investigators propose a two-year project to determine the tag retention and optimal radio transmitter size to mark and track Arctic Lamprey. This project has a direct link to Federal public waters on the Yukon River, however, geographic implications are relatively small. This project fully addresses one priority information need. The proposed project would not have immediate management applications; however, it would give researchers necessary information regarding tag use for mark/recapture or distribution for future studies. The objectives for this project are clear, measurable, and achievable. The science they propose is proven; however, some of the logistics need to be described in more detail. The methods have a rigorous sampling design and have been proven to achieve technical results in previous studies using Pacific Lamprey that will likely transfer over to the slightly smaller Arctic Lamprey. Investigators have substantial resources available to accomplish a project of this nature. The Yukon Delta Fisheries Development Association and the Asa’carsarmiut Tribal Council submitted letters of support for this project proposal. This project has four partners, three of which will be involved in a meaningful way. This project will build very little capacity since the Yukon

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Delta Fisheries Development Association has fishermen already sampling most years. The proposal included both the budget justification and budget tables and suggests a total project cost of $107,940 for 2 years of the project, of which $74,104 is in-kind services and voluntary uncommitted resources from the U.S. Fish and the Alaska Department of Fish and Game. The average annual cost to the Monitoring Program is $16,918, with in-kind services and voluntary uncommitted resources equal approximately 69% of the total project cost.

Project Number: 20-204 Project Title: Abundance and Run Timing of Adult Salmon in Henshaw Creek, Kanuti National Wildlife Refuge

Technical Review Committee Justification: The investigation plan is requesting four more years of funding, starting in 2020, to continue operation of the Henshaw Creek weir to monitor salmon escapement. This weir documents daily escapement, run timing, and age, sex, and length composition of adult salmon. Henshaw Creek weir is located within Federal public waters on the Yukon River drainage and contains wide geographic implications. The Henshaw Creek weir is the only upper Koyukuk River drainage escapement project and is valuable for providing stock-specific population demographic information for managing fisheries stocks throughout the drainage, but the value of the weir data for in- season management is limited due to its location in the upper Koyukuk River drainage, The project objectives are clear, measurable and achievable, but do not provide adequate justification for continuing this project given other information needs. The methods used produce technically sound results and the sampling design is rigorous and includes clear procedures for data collection, compilation, analysis and reporting. The investigators have the resources and ability to fully complete this project and have demonstrated their ability in the past. Three letters of support were supplied from the following agencies: Alaska Department of Fish and Game, U.S. Fish and Wildlife Service, Fairbanks Fish and Wildlife Conservation Office, and Kanuti National Wildlife Refuge. Capacity will be built by hiring from local villages and training employees, as has been done in the past. The proposal included a budget table and justification with a total project cost of $782,056 for the four years of the project, of which $48,800 is an in-kind match from Tanana Chiefs Conference. The average annual cost to the Monitoring Program is $183,314, a decrease over the average annual amount of $212,345 in the 2016 project budget.

Project Number: 20-250 Project Title: Fall Chum Salmon Community Outreach along the Yukon River

Technical Review Committee Justification: This project seeks to addresses a Monitoring Program 2020 Priority Information Need for the Yukon Region: “Information sharing between stakeholders and agencies concerning management of subsistence fisheries.” The investigators plan to facilitate meetings between Alaska Department of Fish and Game managers and communities. Specifically, one staff member from Division of Subsistence and one staff member from Division of Commercial Fisheries would travel to upper Yukon communities of Kaltag, Galena, Tanana, Beaver, Fort Yukon, and Eagle to meet with community members immediately prior to or during the Fall Chum Salmon run and administer a short survey on management concerns. Ms. Trainor has the experience and ability to carry out the proposed work. The Alaska Department of Fish and Game has a demonstrated track record of successfully completing Monitoring Program projects. The project objectives are tangible, but may be

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difficult to measure. The proposal could have been strengthened through planning of concrete meetings in early consultation with tribal communities. Letters of support were not included. Inclusion of Federal managers and partnership with prominent rural organizations are missing. As written, the project comes with a relatively large cost in proportion to the short period of interaction between managers and fishing communities.

Project Number: 20-251 Project Title: In-season Yukon River Subsistence Salmon Survey Program

Technical Review Committee Justification: This proposal is to maintain and build upon the existing In-season Yukon River Subsistence Salmon Survey Program. The program hires local surveyors from 10 Yukon River drainage communities to collect in-season salmon harvest information and fishery observations that are shared with communities and managers in real time. This information has been critical to managing the Yukon River salmon fishery and in providing critical information needed to make management and fishing decisions. The proposal directly addresses several 2020 Priority Information Needs in the region. It develops essential partnerships between communities and managers to strengthen the capacity of each in making decisions in support of both conservation and the continuation of subsistence uses. The program provides local employment opportunities and builds capacity through training on both biological and anthropological research methods. Investigator organizations have a long history of providing substantial resources for Monitoring Program projects. Investigators have a proven record of completing Monitoring Program projects and in delivering high quality research products. The costs associated with this program appear reasonable, especially given the scope of data and anticipated impact on this fisheries’ management and local participation in the fishery.

Project Number: 20-252 Project Title: Customary Trade in the Lower and Middle Yukon River

Technical Review Committee Justification: This project sets out to address a Monitoring Program 2020 Priority Information Need for the Yukon Region: “Quantify and qualify the barter and cash exchange of salmon within the context of the social, cultural, and economic life of people in the middle and lower Yukon drainage.” In 2013, a regulation was adopted that prevents customary trade of salmon between Federally qualified users and non-Federally qualified users. Investigators have planned a study of customary trade combining surveys, participant observation, and semi-structured interviews in the middle and lower Yukon River communities of Mountain Village, Nunam Iqua, Kaltag, and Galena. Ms. Trainor plans to extend the approach used in recent Alaska Department of Fish and Game research on customary trade on the upper Yukon to the lower and middle Yukon River, creating a comparable dataset. The project is technically well-designed and has scientific merit. The investigators recognize and make provisions for the sensitive nature of customary trade. Although costs are high, the budget appears to be reasonable for the work proposed across all periods of the proposed study. No letters of support were provided. The project would increase capacity through training community members in research methods.

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Project Number: 20-256 Project Title: Yukon River In-Season Salmon Management Teleconferences

Technical Review Committee Justification: This project hosts weekly teleconferences, bringing people together from remote and rural villages that share salmon resources. The project has operated for 17 years and has become a fixture of in-season salmon management along the Yukon River. Study design is appropriate and builds capacity by involving local subsistence users and providing them a voice to participate in the management of the Chinook Salmon fishery. The budget and project duration are reasonable for the proposed work and to accomplish project objectives. Investigators are highly qualified and fully capable of addressing and achieving the objectives, and reporting results in a timely manner.

APPENDIX 1 PROJECTS FUNDED IN THE YUKON REGION SINCE 2000

Project Project Title Investigators Number Salmon Projects Ichthyophonus T R F ADF T F ADF T A F F T R T RDFA R T RDFA T A F A R FA R FA R R T F R F R D F A F A R F R D T F ADF R T ADF R R F R R T F TT R T AT T A

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Project Project Title Investigators Number R R F F R A F R F ADF DF R F T R R F RDFA F F A R F R A T F F T R F A R F R F F R R F A F R F R D T F ADF R T ADF A F T TAT ADF R F T T TT F R T RDFA R T T F RDFA ADF T R F A R ADF T R F A ADF T F R F R A F F A R F R D T F ADF R F T R R T RDFA DA T F A R RA A A T A R ADF

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Project Project Title Investigators Number R T RDFA R R R R A F R A T R F A A T A R ADF A T RDFA R F F A F R F R F R F R F T A T ADF R R RDFA F T RDFA F A R F D R R F R A D ADF T R D T F T D R ADF Nonsalmon Fish Projects F AT T ADF AT D R ADF T R F T F ADF A F A F F ADF A F F T ADF T F ADF A F A F F ADF R ADF T T F A ADF

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Project Project Title Investigators Number T F T FAF ADF R T R T F R F T ADF F AT R T ADF T R R T F ADF F ADF F F D R A D A F F R A R F T F ADF T RDFA A F ADF F A T R D F R A A A ADF A D F A A A A F F FA F A AT A T DF D F A T T R R R R A R T T TT T T AF A F F F RDFA R D F A

APPENDIX 2 EXECUTIVE SUMMARIES

The following executive summaries were written by principal investigators and were submitted to the Office of Subsistence Management as part of proposal packages. They may not reflect the opinions of the Office of Subsistence Management or the Technical Review Committee. Executive summaries may have been altered for length.

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Project Number: 20-200 Title: Yukon River Coho Salmon Radio Telemetry Geographic Region: Yukon Region Data Type: Stock Status and Trends Principal Investigator: Bonnie Borba, Fisheries Biologist III, Alaska Department of Fish and Game, Division of Commercial Fisheries Co-investigators: Andrew Padilla, Fisheries Biologist II, Alaska Department of Fish and Game, Division of Commercial Fisheries, Fairbanks Raymond Hander, United States Fish and Wildlife Service, Fairbanks Randy Brown, United States Fish and Wildlife Service, Fairbanks

Project Cost: 2020: $212,957 2021: $214,727 2022: $28,535 2023: $0 Total Cost: $456,219 Issue: This is a proposal for a conducting a one-year radiotelemetry study to track coho salmon (Oncorhynchus kisutch) in the Yukon River drainage to gain knowledge about their migratory distribution patterns, run timing, and identify spawning areas. Coho salmon occur and are harvested for subsistence throughout the Yukon River drainage including many waters adjacent to or within Federal public lands. Alaska Department of Fish and Game (ADF&G) and U.S. Fish and Wildlife Service (USFWS) have broad overlap in management authority pertaining to coho salmon fisheries within the Yukon River drainage. Coho salmon harvests occur within the federal conservation units beginning in August in the lower river and through ice up well into October in the upper river areas. Currently, there is a deficit of baseline information for coho salmon in the Yukon River drainage and this radiotelemetry project will be informative in many aspects. Information on migratory distribution patterns, run timing, and spawning areas is critical to both habitat protection and sustainability of coho salmon in the Yukon River drainage for subsistence use. The project will address priority needs identified for the Yukon Region by providing baseline information about geographic distribution, migration patterns, run timing, genetic structure, and tributary escapements of Yukon River Coho Salmon. Geographic distribution information will be used to make nominations to the Anadromous Waters Catalog (AWC) to provide habitat protection and direct future genetic baseline sampling.

Objectives:

1. Estimate run timing, migration rate, movement patterns, and distribution of coho salmon based on date/time tags deployed relative to date/time fish passes each successive tower/aerial receiver and detected at final locations.

2. Identify migration routes and spawning areas within the Yukon River drainage and provide nominations to the Anadromous Waters Catalog to directly preserve habitat used by coho salmon.

3. Estimate proportional contributions of fish from five drainage groups to the overall Yukon River coho salmon population with 95% confidence interval bounds which will be no wider than 7% of the mean.

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4. Identify areas to add to the genetic baseline.

Methods: This proposal seeks funding to apply esophageal radio tags in coho salmon in the lower Yukon River, just upstream of Russian Mission, and track them via an array of radiotracking stations located strategically along the mainstem and main tributaries of the Yukon River. These radiotracking stations will provide information needed to evaluate inriver migration corridors and quantify migration timing and speed. Tracking stations and aerial survey tracking flights will be used in combination to determine the final fate of each tag fish and locate fish within tributaries. Analysis of the tower and aerial data together will address the information needs outlined in the objectives (i.e. migration routes, stock specific run timing, migration rates, movement patterns, and distribution).

Partnerships/Capacity Building: This project will build capacity and develop partnerships by working with Yukon Drainage Fisheries Development Association, Tanana Chiefs Conference (TCC) and Iqurmuit Traditional Council in Russian Mission. ADF&G will work with YDFDA to contract local fishing crews to capture and assist with coho salmon tagging. Training will provide opportunities to learn techniques in capture, handling, tagging, biological sampling, data recording, and release of live fish. Conversely, the local fishermen share their traditional knowledge of fishing techniques and fishing areas that will be necessary to target and capture coho salmon while minimizing the capture of other fish species. Additional partnerships and capacity with TCC will assist with collection of radio tags from subsistence harvested coho salmon. Integrating YDFDA and TCC into this project follows precedent to include rural and Alaska Native organizations into future fisheries research that is directly connected to Federal subsistence fisheries throughout the Yukon River drainage.

Project Number: 20-201 Title: Application of mixed-stock analysis for Yukon River chum salmon Geographic Region: Yukon Region Data Type: Stock Status and Trends Principal Investigator: Blair Flannery, Conservation Genetics Laboratory, U.S. Fish and Wildlife Service, Anchorage Co-investigators: John Wenburg, Conservation Genetics Laboratory, U.S. Fish and Wildlife Service, Anchorage

Project Cost: 2020: $129,532 2021: $219,532 2022: $129,532 2023: $129,532 Total Cost: $518,128 Issue: This project relates to the following priority information need identified in the 2020 Office of Subsistence Management (OSM) Request for Proposals: In-season estimates of genetic stock composition of summer chum and fall chum salmon runs and harvests. This proposal is a continuation of Fisheries Resource Monitoring Program (FRMP) projects 04-228, 06-205, 10-205, and 14-207, which have provided in-season stock composition estimates of chum salmon to fishery managers within 24 to 48 hours of receiving samples from the Pilot Station sonar test fishery. The disparate strength of individual stocks within and among years makes it clear that in-season stock return data assists management to meet escapement. It provides a real-time tool that allows for informed decisions on regulating fisheries to meet escapement and harvest allocations.

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Objective: The goal is to provide fishery managers with data that will assist them in meeting escapement, passage, and harvest allocations to ensure that the fishery is managed in a sustainable and equitable manner. The following objective will be executed to achieve this goal.

1) Estimate the stock compositions of summer and fall chum salmon sampled from the Pilot Station test fishery each year (June 1 – September 7).

Methods: Genetic samples will be collected from every chum salmon caught in the Pilot Station sonar test fishery from June 1 – September 7, and sent to the CGL every week and at the conclusion of each run pulse. Samples will be stratified by time period or run pulse and a subsample of size 288, selected so that daily sample size is proportional to the daily sonar passage estimate within a stratum, will be genotyped for each stratum of the run. Stock composition will be estimated using Bayesian mixture modeling and reported to fishery managers as soon as practicable. Stock abundance estimates will be derived by combining the sonar passage estimates with the stock composition estimates.

Partnerships/Collaboration: We have worked with ADFG biologists to coordinate sample collection. We have contracted with the Association of Village Council Presidents (AVCP) to hire a local to collect the genetic samples. We completed the baseline in partnership with the DFOC. We have consulted, with ADFG, USFWS, and DFOC managers.

Project Number: 20-202 Title: Evaluating dart and telemetry tags in an effort to track run timing and migration patterns of Yukon River Arctic lamprey Geographic Region: Yukon Region Data Type: Stock Status and Trends Principal Investigator: Katie Shink, U.S. Fish and Wildlife Service, Fairbanks Fish and Wildlife Conservation Office Co-investigators: Trent Sutton, University of Alaska Fairbanks, College of Fisheries and Ocean Sciences Sabrina Garcia, Alaska Department of Fish and Game, Division of Commercial Fisheries, Anchorage

Project Cost: 2020: $20,913 2021: $12,923 2022: $0 2023: $0 Total Cost: $33,836 Issue: Arctic lamprey (Lethenteron camtschaticum) are an important subsistence and commercial resource for native Alaskan communities along the lower Yukon River drainage. Despite annual harvests, a lack of basic run timing, relative abundance, and migration data increases the uncertainty of this fishery and complicates quantitative impact estimates of harvests on spawning populations. Within the past three years, subsistence users and local communities have expressed concerns in meeting subsistence needs. As a result, there has been an increased interest in identifying the run timing and migratory patterns of Arctic lamprey through the use of mark-recapture and telemetry methods. Arguably, these data would provide a benchmark from which to begin tracking Arctic lamprey population dynamics. Although mark-recapture

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and telemetry methods are widely applied and useful tools in fisheries management, the major assumption of this methodology is that tagged and non-tagged fish exhibit similar behavior, physiological responses, and survival rates. To date, this assumption has not been validated in a controlled laboratory setting for Arctic lamprey. It is critical to assess the effects of tagging on physiology and survival before a basin- wide markrecapture or telemetry study can be conducted. Without an objective assessment of tag performance under controlled conditions, time-intensive and high-cost mark-recapture and telemetry studies may yield inaccurate representations of migratory behavior or risk little to no data collection due to poor tag retention and/or survival. The deliverable of this project is a determination if external dart tags and surgically implanted radio transmitters can be used as a tool to monitor run-timing, estimate relative abundance, and identify the migration patterns of Yukon River Arctic lamprey to inform management.

Objectives:

1. Assess the retention rate of external and internal tags over a 180-d study period. 2. Evaluate the effects of surgically implanted transmitter size on wound healing. 3. Determine if tag type (external or internal) or size of internal tags affects survival over a 180-d 1. study period. 4. Determine the effects of different tags on short (24-h) and long-term (30-d) swimming performance.

Methods: Arctic lamprey (N = 225) will be captured in fyke nets at test fish sites operated by local contracted fishermen, transported live to the UAF Fish Laboratory, and held in 890-L circular tanks for a one week acclimation period. Before the start of the experiment, lamprey will be tagged with a Passive Integrated Transponder (PIT) tag to track individuals for the duration of the experiment. Lamprey will be assigned to one of six treatment groups: 1) control; 2) sham (surgery but no transmitter); 3) an external plastic-dipped dart tag; 4) a surgically implanted small dummy transmitter; 5) a surgically implanted medium dummy transmitter; and 6) a surgically implanted large dummy transmitter. Tagging and subsequent swim trials will be staggered over a period of three months (November 1 – January 31). A surgical protocol developed for Pacific lamprey (Entosphenus tridentatus) by Moser et al. (2002) will be used as a guide for surgically implanted dummy transmitters. External tags will be injected below the left side of the anterior dorsal fin using a Floy pistol-grip implanter. After tagging, a subset of lamprey from each treatment group (n = 20, 120 total across all six treatments) will undergo swimming performance assessment trials to assess the impact of different tags on swimming performance. The first swim trial will occur 24 hours after tagging to assess short-term effects; the second will occur 30 days after tagging to assess long-term effects. Lamprey will be monitored daily for expelled tags and mortalities for the duration of the 180 day study. Every 14 days post-tagging, lamprey will be anesthetized and examined to evaluate wound healing. Wound healing will be scored on a scale of one to six following the criterial described by Wagner et al. (2000). At the end of the experiment (May 31), all lamprey will be given a lethal dose of methanesulfonate (MS-22) and necropsies will be performed.

Partnerships/Capacity Building: This project will be a collaborative effort among federal and state agencies (FFWCO; ADF&G), Alaska Native organizations (Yukon Delta Fisheries Development

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Association; YDFDA), and research institutions (UAF) to address (1) a 2020 Priority Information Need identified by the Office of Subsistence Management (OSM) and (2) concerns regarding declining lamprey harvests by local subsistence users. Local YDFDA Community Development Quota (CDQ) fishermen will have a significant role in the project, for they have agreed to lead lamprey collection efforts. These collection efforts will also provide an additional opportunity for ADF&G to monitor run timing and track the location of the lamprey run for subsistence users. Further, both the YDFDA and the Asa’carsarmiut Tribal Council have expressed support for this project. Ultimately, the overarching goal of this project is to ensure a diverse group of stakeholders have the information necessary to select the most efficient and effective monitoring tool(s) to collect baseline information and inform the management of Yukon River Arctic lamprey, a poorly studied subsistence species.

Project Number: 20-204 Title: Abundance and Run Timing of Adult Salmon in Henshaw Creek, Kanuti National Wildlife Refuge, Alaska Geographic Region: Yukon Region Data Type: Stock Status and Trends Principal Investigator: Nicole Farnham, Tanana Chiefs Conference, Fairbanks Co-investigators: Brian McKenna, Tanana Chiefs Conference, Fairbanks

Project Cost: 2020: $185,813 2021: $182,481 2022: $182,481 2022: $182,481 Total Cost: $733,256 Issue: Management of the Koyukuk River salmon fishery is complex. The Alaska Department of Fish and Game, Division of Commercial Fisheries (ADF&G-DFC) has conducted aerial surveys within this drainage since 1960 (Barton, 1984) but the usefulness and reliability of that information is limited. This project addresses the priority information needs outlined for Yukon River salmon, including maintaining reliable estimates of Chinook and chum salmon escapement over time, and assessment of trends in Chinook age, sex and length.

Both Chinook Oncorhyncus tshawytscha and chum O. keta salmon from Henshaw Creek contribute to the harvests of subsistence and commercial fisheries occurring in the Yukon River. Information collected at Henshaw Creek weir is important to fisheries managers who have the difficult task in managing the complex mixed stock subsistence and commercial salmon fisheries in the Yukon River. In-season management and post-season evaluations of management actions are enhanced by the data from this project. Further, the Henshaw Creek weir is the only upper Koyukuk River drainage salmon escapement monitoring project and its information can facilitate comparisons with lower drainage escapement projects (Berkbigler and Elkin 2006). In more recent years, subsistence and commercial harvesters have identified a concern with the apparent decrease in the size of Chinook salmon (JTC 2013). The continuation of reliable escapement estimates and the collection of age, sex, and length data at Henshaw Creek will assist in future analyses of trends in Chinook salmon and summer chum salmon run timing, escapements, gender composition, and size and age structure over time. In addition, this project aids the Kanuti National Wildlife Refuge (KNWR) in meeting objectives outlined in the 1993 KNWR Fishery Management Plan, and addresses the priority information needs outlined for Yukon Region salmon by

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providing reliable estimates of Chinook and chum escapements. With the Tanana Chiefs Conference (TCC) as the primary investigator and through the hire of local residents, this project will enhance capacity building to allow local communities a continued role in the management of the resources

Objectives:  Determine daily escapement and run timing of adult salmon;  Determine age, sex and length (ASL) composition of adult salmon;  Determine the number of resident fish species passing through the weir;  Consult with and provide outreach and communication for the village of Allakaket; and  Serve as an outreach platform for KNWR staff and TCC staff to conduct an on-site science camp.

Methods: A resistance board weir will be installed and operated on Henshaw Creek located 721 km upriver from the mouth of the Koyukuk River in north central Alaska (see Figure 1, Map of Project Area). A live trap, installed near mid-channel, will allow salmon and resident species to move through the weir. Their passage will be enumerated daily and will provide an area where fish will be sampled to collect biological information. The daily counting period will begin at midnight and end at midnight the following day. Sampling will begin at the beginning of each week and will be conducted over a 3-4 day period to collect 160 fish per week for each species. Sample size goals were established so that simultaneous 90% interval estimates of the sex and age composition for each week have maximum widths of 0.20 (Bromaghin 1993). The sample size obtained using this method was increased to account for the expected number of unreadable scales. Lengths of Chinook salmon will be measured to the nearest 1 mm and chum measured to the nearest 5mm from mid-eye to fork of the caudal fin (MEFL). Sex ratios will be determined by visual inspection of secondary sexual characteristics. Scales will be used for aging salmon, with ages being reported using the European technique (Foerster 1968). Three scales will be collected from Chinook salmon and one scale will be collected from summer chum salmon. Scales will be taken from the area located on the left side of the fish, two rows above the lateral line on a diagonal line from the posterior insertion of the dorsal fin to the anterior insertion of the anal fin (Price, ADF&G, personal communication). Once the scales are removed, they will be placed on scale gum cards for later analysis with ADF&G.

The staff at KNWR and TCC will continue to work with the local schools to identify students from each of the four villages, Bettles/Evansville, Allakaket, Alatna, and Hughes to be participants in the Henshaw Creek science camp. Students will be exposed to the operations of a weir and will receive lessons in fisheries management, stream ecology, aquatic invertebrates, fish identifications, natural resources career opportunities, the plants and wildlife in the KNWR, and traditional and cultural knowledge.

Partnerships/Capacity Building: The partnerships TCC has developed with the USFWS, KNWR, ADF&G and local tribal councils presents a great opportunity to build capacity within the TCC and the local communities of the Upper Koyukuk River. The relationships TCC already has with federal and state resource management agencies will continue to be strengthened through the continuation of this project and will be an important asset to the fishery program at TCC. The local communities of the upper Koyukuk River will be strengthened through this project as well. TCC plans to continue to hire weir staff

212 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Fisheries Resource Monitoring Program Yukon Region Overview from within these communities, which will provide much needed employment opportunities and will expose people to the project and different aspects of fishery management. Additionally, the annual science camp will engage local youth with the issues facing fishery resource managers and will provide elders a chance to interact with the students and teach them traditional skills.

Project Number: 20-250 Title: Fall Chum Salmon Community Outreach along the Yukon River Geographic Region: Yukon Data Type: Information Sharing and Outreach Principal Investigator: Alida Trainor, Division of subsistence, Alaska Department of Fish and Game, Fairbanks Co-investigators: Jeff Estensen, Division of Commercial Fisheries, Alaska Department of Fish and Game, Fairbanks

Project Cost: 2020: $27,760 2021: $29,347 2022: $13,234 2022: $0 Total Cost: $70,341 Issue: Communities located above the confluence with the Tanana River, primarily have access to two types of salmon; Chinook and fall chum. For subsistence fishermen in the upper portions of the Yukon River, the strength of the fall chum run during times of Chinook salmon conservation has created a level of anxiety. At AC meetings and, during public testimony at the Board of Fisheries, round table discussions at the Yukon River Drainage Fisheries Association preseason planning meeting and during discussions at the Yukon River Panel, stakeholders from this region worry that the increased harvest pressure on fall chum during times of Chinook salmon conservation could jeopardize subsistence fishermen’s ability to harvest any salmon if the fall chum begin to decline as well.

While there is no known factors or data that indicates Yukon River fall chum are certain to crash again, it is possible that fall chum might experience a dip in productivity and abundance. Consequently, it is critical that managers preemptively meet with a variety of communities to hear from fishermen and discuss ways to mitigate these impacts if a crash does occur.

Objectives: This three-year project will address the following objectives:

1. Develop and maintain more effective ways to reach Yukon River subsistence fishers throughout the middle and upper portions of the Yukon River drainage in-season so communities in these regions have access to timely and accurate information about fall season management decisions in their district;

2. Facilitate community meetings that will allow managers, research biologists, and Commercial Fisheries staff to interact directly with local stakeholders and provide meaningful opportunities for stakeholder input

Methods: Subsistence Division staff will coordinate community visits with tribal councils and/or city councils prior to the beginning of the fall chum fishing season. Community visits will occur slightly before or at the beginning of the fall chum fishing effort in each community in order to maximize the

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opportunity to listen to concerns and provide information about the salmon runs, management actions, and other related issues. Subsistence Division staff will travel with Commercial fisheries managers to help facilitate positive and effective meetings by building off the relationships and knowledge of the local communities that Subsistence Division staff already possess. During community visits/ meetings, staff will:

• Attend a community meeting or otherwise be accessible to community members throughout each two-day visit • Administer a short survey to meeting attendees to ask about and document local concerns • Document and answer questions about the fisheries and management issues • Promote direct contact with fisheries managers by providing their contact information, the toll free 1-800 number and ADF&G Facebook page • Facilitate discussions to identify local issues and brainstorm possible solutions with managers that could be implemented immediately or in the future depending upon regulatory constraints • Visit local fishing and/or processing sites to further facilitate discussions of local issues and concerns and to expand managers understanding of the local fishing profile

Partnerships/Capacity Building: The principal investigators will work with tribal councils in the project communities to facilitate community meetings and fishing site visits. Time spent with managers will add to local involvement and local understanding of the Yukon River fall chum salmon management.

Project Number: 20-251 Title: In-season Yukon River Subsistence Salmon Survey Program Geographic Region: Yukon Region Data Type: Harvest Monitoring and Traditional Ecological Knowledge Principal Investigator: Catherine Moncrieff, Staff Anthropologist, Yukon River Drainage Fisheries Association Co-investigator: Gerald Maschmann, U.S. Fish and Widlife Service, Fairbanks Field Office

Project Cost: 2020: $77,234 2021: $81,210 2022: $80,033 2023: $82,280 Total Cost: $320,756 Issue/Need: This project addresses the need for inclusive in-season management for Chinook salmon fisheries on the Yukon River. Salmon are a critical resource for subsistence and commercial users in this region, which includes 14 Federal conservation units, and fisheries managers must have a means to gather input, assess harvests, and share information with these fishermen and fisheries stakeholders throughout the fishing season. Through this program, fishers report their concerns, fishery success, observations, and concerns to a locally hired surveyor, weekly, during the Chinook salmon run in their community. This information is shared anonymously by village with state and federal managers in preparation for the weekly in-season management teleconference.

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Goal: To contribute local information into fisheries management discussions and build capacity along the Yukon River to participate in fisheries management.

Objectives: 1. Hire 10 local surveyors in 10 Yukon River drainage villages to work in-season to conduct interviews on an annual basis; 2. Build capacity of local surveyors in 10 Yukon River villages to participate in in-season fisheries management; 3. Conduct annual reviews pre-season and post-season to evaluate survey program and design for next season to maximize effectiveness of program

Methods: Methods for this project include communication, outreach, survey instrument, annual trainings, data analysis, and annual evaluations. Participating communities were selected based on the needs and goals of the managers as well as the geographic location and interest of the communities. The local hire surveyors will be selected based on tribal council recommendations, rehire of high performing past surveyors, and other recommendations for quality local hire candidates.

The survey methodology follows the National Academy of Science’s Principles for Conduct of Research in the Arctic and will include informed consent for participants, to be conducted prior to the first interview. Privacy and confidentiality will be protected in the reporting. The survey methodology and instrument will be reviewed and revised annually as needed to ensure that the recording and reporting formats and content are useful for managers and fishermen. The project investigators (PI) and co-PI will work with managers prior to each summer season to identify priority information to be collected and shared for the upcoming season and will update data collection forms, surveyor training and protocols, and reporting on the teleconferences. The in-season subsistence salmon survey methodology focuses on interviewing fishers weekly to collect qualitative information to provide managers with a real time assessment of the run. The survey form includes qualitative questions designed in consultation with the managers and aimed at gathering fishers’ observations about changes in their subsistence harvest related to species targeted, fishing locations, fish quality, harvest methods and means, and methods of preservation. In addition to collecting information from fishers, surveyors will disseminate relevant information to fishers.

Surveyors will receive focused training at an annual training event to build their capacity and enhance their ability to communicate with local fishers, river-wide fishers, and managers on the teleconferences and through the surveys. The annual training event will cover interview methods, appropriate research ethics, and reporting requirements. Additionally, the training event will focus on enhancing listening and communication skills. As part of capacity building and to maximize the experience of some long-term surveyors, two to three of the top performing surveyors will be trained as “train the trainers.” The surveyors will also attend the annual pre-season summer fishery preparation meeting to gain important information to share with fishers in their communities about the pre-season outlook. Surveyors will submit their data weekly and report a summary on the in-season salmon management teleconferences. For the data analysis, at the end of the season the PI will review all the survey forms and compile a MS Excel spreadsheet and produce summary narrative reports.

YRDFA staff will attend two federal regional advisory council meetings in person annually to provide project reports and listen to RAC priorities. Attendance at the other Yukon River RAC meetings will be

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 215 Fisheries Resource Monitoring Program Yukon Region Overview

accomplished by teleconference or with funds from other programs. Annual pre-season and post-season evaluations of the program will be conducted with the state and federal managers, with the surveyors and with community representatives. This will include the priority information to share and collect and create an adaptive program that will allow maximum communication efforts. YRDFA will evaluate each in- season subsistence salmon surveyor, their participation and effectiveness at sharing and gathering information, and their reliability in delivering a report on the teleconferences as well as their ability to engage in productive fisheries management discussions on the teleconferences.

Partnerships/Capacity Building: This project will build the capability and expertise of rural and Alaska Native individuals and organizations by providing an opportunity to learn about Yukon River fisheries management, participate in local reporting and building their skills through focused annual trainings on communication with local fishers, river-wide fishers, and managers. Surveyors also attend the annual preseason fisheries preparation meeting, increasing their fisheries knowledge and enhancing their ability to participate in the management of federal subsistence fisheries. Partnerships will continue with the state and federal managers, village tribal councils, and individuals working as a part of the project. YRDFA will consult annually with the tribal councils of the 10 communities invited to participate in the in-season harvest interview portion of the project. As part of the consultation the tribal councils are invited to provide suggestions for improvement of the program. All of the communities participating in 2018 have been contacted and their knowledge of, support of, and suggestions for this proposal were discussed. The communities have expressed interest to continue their participation in the project, noting the value they find it for their community. With the decline in Chinook salmon and the need to conserve, the feedback received from both managers and fishers is that the strength of this program is its ability to enhance productive river-wide communication between fishers and managers. Additionally, consistent participation and representation from 10 key villages on the teleconferences was noted as an important contribution and notably missed when the Chinook season ends. There is value in having local surveyors participate in each teleconference and leads to better understanding in those communities and engaging more people prior to the teleconference.

Project Number: 20-252 Title: Customary Trade in the Lower and Middle Yukon River Geographic Region: Lower and Middle Regions of the Yukon River Data Type: Harvest Monitoring and Traditional Ecological Knowledge Principal Investigator: Alida Trainor, Division of Subsistence, Alaska Department of Fish and Game, Fairbanks Co-investigators: David Koster, Division of Subsistence, Alaska Department of Fish and Game, Anchorage

Project Cost: 2020: $163,558 2021: $71,549 2022: $75,380 2023: $0 Total Cost: $310,487 Issue: In recent years, the Yukon River has seen a significant decline in the number of returning Chinook salmon. These declining salmon returns greatly affect subsistence salmon harvests and uses by community residents and require more conservative management by federal and state agencies. Regional

216 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Fisheries Resource Monitoring Program Yukon Region Overview

Advisory Councils and community members remain concerned about these declines and the role of customary trade in changing patterns of salmon use. This study will document traditional and contemporary practices of customary trade in lower and middle Yukon River communties with particular attention to understanding the nature and scope of customary trade and its role in a larger continuum of exchange practices.

The commercial fishing that largely occurs in the lower parts of the river supports subsistence economies by providing much needed cash to buy equipment and supplies that are often reinvested in subsistence activities. Because of this revenue source, residents in the lower river may not consider customary trade a means to support their subsistence activity. Participation in customary trade in the lower river likely will have different justifications than that in the upper river. In the middle river, some residents participate in commercial fishing while others solely subsistence fish. Recent research on customary trade (Fienup- Riordan 1986, Magdanz et. al 2007, Moncrieff 2007) suggests that customary trade plays a long-term and important role in the continuum of exchange that serves to distribute subsistence resources within and between communities. However, the importance of customary trade varies by area (Krieg et al. 2007). Buying or selling fish, is not solely an economic consideration. The presence of a commercial fishery is not a likely predictor of the extent of customary trade in any given community. Conducting this research in the lower and middle river regions will expand our understanding of the social, economic, and cultural factors that drive participation in this practice.

This project seeks to build on earlier research by administering the same methods used in Brown (2017) in the lower and middle Yukon River regions in order to establish comparable data sets across all regions of the Yukon River.

Objectives: This two-year study will develop case studies, addressing the following objectives:

1. Through ethnographic methods, describe how customary trade practices fit within the overall subsistence use of salmon in the lower and middle Yukon area, both historically and in present times of declining salmon.

2. Using a survey on barter and exchange practices, document the scope and local nature of customary trade in four Yukon River communities. Describe exchange networks and transaction in terms of the species and types (e.g. processing) of fish traded. Where possible, quantify transactions.

3. Improve understanding of the role of customary trade within a continuum of exchange practices, including any potential effects on customary trade resulting from declining runs within the context of subsistence management and uses.

Methods: Community-level characterizations of customary trade will be made through the use of a short, confidential survey on barter and trade practices by community households. The survey will be primarily designed to document local views and prevalence of different types of exchange involving salmon, in addition to quantifying or estimating the actual extent of those practices on a household or community level. However given the politicized nature of customary trade practices in the present moment, it may be

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 217 Fisheries Resource Monitoring Program Yukon Region Overview

challenging to quantify exchanges in all of the communities. The survey will include questions about the frequency of different types of exchanges, including sharing (analyzed through forms of reciprocity), barter, and customary trade.

The ethnographic research for this project will include anthropological methods of participant observation and semi-structured interviews. In each study community, individuals will be identified who are active in customary trade and, or barter. Generally, it is well known within a community who is active or skilled in an activity such as fishing or trade (Usher 2000) and these individuals will be identified through a snowball sampling design.

Partnerships/Capacity Building: The principal investigators will work with tribal councils in the study communities to hire local project assistants, to select key respondents, and facilitate community meetings. The local research assistants will be trained in anthropological sampling methods. This adds to local involvement and local understanding of the Yukon River Chinook salmon management issues. This also increases coordination between agencies, Tribal entities, and community members – working together in data collection increases communication and leads to better understanding of local issues and local understanding of science and management issues.

Project Number: 20-256 Title: Yukon River In-Season Salmon Management Teleconferences Geographic Region: Yukon Region Data Type: Harvest Monitoring and Traditional Ecological Knowledge Principal Investigator: Wayne Jenkins, Executive Director, Yukon River Drainage Fisheries Association Co-investigators: Catherine Moncrieff, Anthropologist, Yukon River Drainages Fisheries Association

Project Cost: 2020: $19,713 2021: $19,713 2022: $19,713 2023: $19,713 Total Cost: $78,854 An executive summary was not submitted for this project.

218 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Annual Report Briefing

ANNUAL REPORTS

Background

ANILCA established the Annual Reports as the way to bring regional subsistence uses and needs to the Secretaries' attention. The Secretaries delegated this responsibility to the Board. Section 805(c) deference includes matters brought forward in the Annual Report.

The Annual Report provides the Councils an opportunity to address the directors of each of the four Department of Interior agencies and the Department of Agriculture Forest Service in their capacity as members of the Federal Subsistence Board. The Board is required to discuss and reply to each issue in every Annual Report and to take action when within the Board’s authority. In many cases, if the issue is outside of the Board’s authority, the Board will provide information to the Council on how to contact personnel at the correct agency. As agency directors, the Board members have authority to implement most of the actions which would effect the changes recommended by the Councils, even those not covered in Section 805(c). The Councils are strongly encouraged to take advantage of this opportunity.

Report Content

Both Title VIII Section 805 and 50 CFR §100.11 (Subpart B of the regulations) describe what may be contained in an Annual Report from the councils to the Board. This description includes issues that are not generally addressed by the normal regulatory process:

 an identification of current and anticipated subsistence uses of fish and wildlife populations within the region;  an evaluation of current and anticipated subsistence needs for fish and wildlife populations from the public lands within the region;  a recommended strategy for the management of fish and wildlife populations within the region to accommodate such subsistence uses and needs related to the public lands; and  recommendations concerning policies, standards, guidelines, and regulations to implement the strategy.

Please avoid filler or fluff language that does not specifically raise an issue of concern or information to the Board.

Report Clarity

In order for the Board to adequately respond to each Council’s annual report, it is important for the annual report itself to state issues clearly.

 If addressing an existing Board policy, Councils should please state whether there is something unclear about the policy, if there is uncertainty about the reason for the policy, or if the Council needs information on how the policy is applied.  Council members should discuss in detail at Council meetings the issues for the annual report and assist the Council Coordinator in understanding and stating the issues clearly.

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 219 Annual Report Briefing

 Council Coordinators and staff should assist the Council memers durin the meetin in ensurin that the issue is stated clearly.

hus, if the Councils can e clear aout their issues of concern and ensure that the Council Coordinator is relayin them sufficiently, then the Board and staff will endeavor to provide as concise and responsive of a reply as is possile.

Report Format

hile no particular format is necessary for the Annual Reports, the report must clearly state the followin for each item the Council wants the Board to address . umerin of the issues, . A description of each issue, . hether the Council seeks Board action on the matter and, if so, what action the Council recommends, and . As much evidence or eplanation as necessary to support the Council’s request or statements relatin to the item of interest.

220 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Federal Subsistence Board FY2018 Annual Report Reply

Federal Subsistence Board 1011 East Tudor Road, MS 121 USDA Anchorage, Alaska 99503 - 6199

r •�n UIHt 11n .. u1 ..1r•� :o,r.,I\1CE v IIUREAU of LANI> MANAGEMENT NATIONAi, PARK SERVICE IIUREAU of INl>IAN Al'l•'AIR AUG 1 6 2019

1. Hunter displacement and the "Domino Effect" contribution to changinghunting patternsand user conflict

Over the last few years, the Council has become increasingly concerned about the displacement of local hunters from their home region by hunters from other regions. The displacement often happens due to the various Federal and State wildlifemanagement decisions, including closures, which forcehunters to hunt in a differentregion. This phenomenon, also known as the "Domino Effect," is an underlying reason for some of the user conflict in the State.

The issue of user conflictand findingways to preempt and mitigate the conflicthas been a long­ standingOSM 19062.KW concern for the Council. The Council requests that the Officeof Subsistence Management provide a report with data on hunter communities of residency and harvest locations for various species. This information can be obtained from the harvest ticket reports filedwith the Alaska Department of Fish and Game, including data on what percentage of hunters were Federally qualifiedsubsistence users. The Council suggests that OSM also seek outSue other Entsminger, potential Chair sources of information. Eastern Interior Alaska Subsistence Regional Advisory Council c/o Officeof SubsistenceEastern ManagementInterior Alaska Subsistence Regional Advisory Council Meeting 221 1101 East Tudor Road, MS 121 Anchorage, Alaska 99503-6119

Dear Chairwoman Entsminger:

This letter responds to the Eastern Interior Alaska Subsistence Regional Advisory Council's (Council) fiscalyear 2018 Annual Report. The Secretariesof the Interior and Agriculture have delegated to the Federal Subsistence Board (Board) the responsibility to respond to these reports. The Boardappreciates your effortin developing the Annual Report. Annual Reports allow the Board to become aware of the issues outside of the regulatory process that affectsubsistence users in your region. We value this opportunity to review the issues concerning your region.

(OSM) Federal Subsistence Board FY2018 Annual Report Reply

The Council understands that collecting the requested data for the entire state is a large project, but notes that it is needed to understand hunter movement patterns and changing harvest pressures in differentareas. This data will help wildlifemanagers gain a comprehensive picture of displacement, address the impacts of the "Domino Effect," and find approachesto mitigate it in the future.

Also, this data would assist the Council in proposing better informed regulatorychanges to hunting seasons or other changes that would redistribute and lessen hunting impacts to Federally qualifiedsubsistence users.

The Council considers this research a priorityand suggests that OSM collaborate with the State to collect the information. This may be a good research project for a University of Alaska Anchorage or University of Alaska Fairbanks graduate student, such as an Alaska Native Science and Engineering Programstudent, and has the potential to be his or her graduation thesis as well. The Council feels strongly that this information will also help the Federal Subsistence Board and the Alaska Board of Game understand the impacts of closing hunting in one area and the pressure that it may put on other areas. It might also result in developing better regulations that provide harvest opportunities on more equitable basis. There is the potential for long-term positive impacts to State and Federal wildlife management from this research.

Response:

Chairwoman Entsminger 2

222 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting

The Board acknowledges the Council's concernabout the "Domino Effect." Data on hunters' resident community for wildlifespecies and locations across Alaska exist in State and Federal databases. Hunting locations are only specificto the subunit level and, of course, these databases only reflect reported harvest.

While these databases likely contain the informationneeded to examine what the Council describes as the "Domino Effect,"further clarification is needed beforea useful report can be generated. First, what is the time frame? Is the Council interested in hunting trends over the last 10, 20 or 30 years? Also, are any species (e.g. caribou, moose), units (e.g. Unit 20E), or closed areas of particular interest or priority to the Council or does the Council want a comprehensive report including every species and subunit in Alaska? Is the Council only concernedabout the "Domino Effect"of hunting or also of trapping? Is the Council concernedabout the displacement of non-local and non-Federally qualifiedhunters or only of local, Federally qualified subsistence users?

The Board encourages the Council to work further with your Council Coordinator in order to refine and clarify your request. Federal Subsistence Board FY2018 Annual Report Reply

3

The Council understands that collecting the requested data for the entire state is a large project, 2. Accurate reporting of the customary trade of all subsistence-caught Yukon River but notes that it is needed to understand hunter movement patterns and changing harvest Chinook Salmon pressures in differentareas. This data will help wildlifemanagers gain a comprehensive picture of displacement, address the impacts of the "Domino Effect," and find approachesto mitigate it in the future.

Also, this data would assist the Council in proposing better informed regulatorychanges to - hunting seasons or other changes that would redistribute and lessen hunting impacts to Federally qualifiedsubsistence users.

The Council considers this research a priorityand suggests that OSM collaborate with the State to collect the information. This may be a good research project for a University of Alaska Anchorage or University of Alaska Fairbanks graduate student, such as an Alaska Native Science and Engineering Programstudent, and has the potential to be his or her graduation thesis as well. The Council feels strongly that this information will also help the Federal Subsistence Board and the Alaska Board of Game understand the impacts of closing hunting in one area and the pressure that it may put on other areas. It might also result in developing better regulations that provide harvest opportunities on more equitable basis. There is the potential for long-term positive impacts to State and Federal wildlife management from this research.

Response:

Chairwoman Entsminger 2 Chairwoman Entsminger

Response: The Council doubts the accuracy of subsistence harvest data for Chinook Salmon on the Yukon River. There is significantdisparity in numbers between the total recorded run coming into the Yukon River, the reported commercial catch and subsistence harvest. In reviewing the data, the Council observed that approximately 20,000 25,000 Chinook Salnwn were unaccounted for in 20/8, which in the Council's opinion more than likely indicates that these salmon were not reported in the harvest.

Joint concerns about Chinook Salmon harvest and whether customarytrade has been legally conducted led to the formation of an Eastern Interior, Yukon-Kuskokwim Delta, and Western Interior Alaska Subsistence Regional Advisory Council Customary TradeSubcommittee. This Subcommittee developed several proposals addressing customarytrade regulations and made recommendations to the Board at its January2013 meeting. The Board adopted one of these proposals limiting customarytrade of Yukon River Chinook Salmon to those with a current customaryand traditionalEastern useInterior determination Alaska Subsistence for Yukon Regional River Advisory Chinook Council Salmon. Meeting 223

Under State regulations, exchange of subsistence-caught fishfor cash is illegal unless specifically authorized by the Alaska Board of Fisheries. Currently, the customarytrade of Yukon River salmon stocks for cash has not been authorized by the Alaska Board of Fisheries. Council members have personal knowledge that subsistence users regularly make harvested salmon into strips, but do not report to the State the correct number offish thathave been harvested for strips to avoid being prosecuted. The Board acknowledges the Council's concernabout the "Domino Effect." Data on hunters' resident community for wildlifespecies and locations across Alaska exist in State and Federal The Council would like the Board to work with the State to findways to improve the accurate databases. Hunting locations are only specificto the subunit level and, of course, these databases reporting of the customary tradeof salmon on the Yukon River. The Council would like to stress only reflect reported harvest. that accurate information and understanding of the harvest is essential to managers to be able to correctly manage the Yukon River Chinook Salmon, especially in the times of low abundance or While these databases likely contain the informationneeded to examine what the Council during rebuilding efforts. describes as the "Domino Effect,"further clarification is needed beforea useful report can be generated. First, what is the time frame? Is the Council interested in hunting trends over the last 10, 20 or 30 years? Also, are any species (e.g. caribou, moose), units (e.g. Unit 20E), or closed areas of particular interest or priority to the Council or does the Council want a comprehensive report including every species and subunit in Alaska? Is the Council only concernedabout the The Council describes several observations concerning the harvest of Yukon Chinook Salmon "Domino Effect"of hunting or also of trapping? Is the Council concernedabout the forsubsistence. The Board understands that the Council questions the accuracy of harvest displacement of non-local and non-Federally qualifiedhunters or only of local, Federally estimates that are derived fromhousehold harvest surveys conducted by the Alaska Department qualified subsistence users? of Fish and Game each fall. However, the Council's observation that 20,000 to 25,000 Chinook Salmon were unaccounted forin 2018 does not appear to be accurate. The Yukon Chinook The Board encourages the Council to work further with your Council Coordinator in order to Salmon run-size estimate in 2018 was 161,800 fish+/- 24,539. This run size estimate was in a refine and clarify your request. range of almost 50,000 fisharound the point estimate of 161,800 fish. Due to this uncertainty in these data, we cannot estimate the amountof unreported Chinook Salmon harvest based on the run size estimate. Federal Subsistence Board FY2018 Annual Report Reply

Chairwoman Entsminger 4

Additionally, the estimate of the harvest of Chinook Salmon for subsistence is considered accurate by fishery managers and the Yukon Panel. Each fall, a sample of households in the Alaska portion of the Yukon River drainage report their harvests of salmon to surveyors fromthe Alaska Department of Fish and Game Division of Commercial Fisheries. The questionnaire includes questions concerning how many salmon each household harvested. The survey does not ask people what they did with their harvests, whether they bartered it or exchanged it forcash. Participation in this survey is voluntary and confidential and personal names are not used. Based on these surveys, staff estimate the harvest of Chinook Salmon forsubsistence at the community level only.

Currently, Federally qualified subsistence users are not required to report the customary trade of fish. The Council can request the Board to implement a customary trade reporting system; although, meetings of the Customary Trade Subcommittee representing the Eastern Interior, Yukon-Kuskokwim Delta, and Western Interior Councils did not support requiring a permit. A person engaging in customary trade would have to enter all sales on a Customary Trade Record Keeping Form and would have to return the formto the Federal agency that issued it. This would ensure that all legal trades are recorded, making illegal trades easier forenforcement officersto identify. The next call for proposals to change fishery regulations begins in January 2020. As the Council has pointed out, any Federally qualified subsistenceuser exchanging Chinook Salmon, their parts, or their eggs forcash with anyone other than a Federally qualified subsistence user in the Yukon River drainage is illegal, and if observed, should be reported to U.S. Fish and WildlifeService's offices in Fairbanks.

3. Etfects of releasing 1.6 billion hatcherysalmon into the marine environment

Over the course of last I 5-20 years, private non-profithatcheries in Alaska have released an average of 1.6 billion hatchery salmon annually into the marine environment. The Council continues to have concerns over the effectsof hatchery-released salmonon wild salmon stocks. The Council notes that some major institutions and agencies, such as University of Washington, University ofHokkaido, Universityof Alaska Fairbanks, Oregon State University, National Oceanic and Atmospheric Administration, U.S. Fish and WildlifeService, State of Alaska, and others have conducted and published a substantial amount of scientificresearch on the hatchery­ versus-wild fishinteractions in the marine environment.

The Council notes that significantevidence in the research shows that the decline of salmon stocks in Alaska is a marine phenomenon. The Council's two major concernsare:

I). Competition for foodin the marine environment. There is substantial evidence that hatchery­ released salmon compete directly with wild salmon stocks for food in the marine environment. This might result in significantadverse effects on the wild salmon populations, especially if food resources are limited and competition is high. Consequently, this can greatly contribute to the decline of wild stocks.

224 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Federal Subsistence Board FY2018 Annual Report Reply

5

2). Predation oflarger hatcheryiuveniles on other salmon smolt. According to the research, hatchery-releasedjuvenile Pink Salmon spend one year in the ocean with the majority of their growth (80 percent) occurring during the last three to four months. This growth period coincides with the migration of other salmon species' smolt. Thus, there is the possibilityof extensive predation by larger hatchery juvenile Pink Salmon on smaller wild juveniles (fryand smolt) in the marine environment.

These two interactions may have potentially significantadverse impacts on wild salmon stocks resulting in decreased growth and survival. That is why it becomes increasingly important to understand the effectsof the interaction of hatchery-released salmon with the wild stocks.

From previous Board responses on issues of concern brought uf by the Council, we understand that OSM staff"generally does not plan or conduct research." In view of this, the Council requests that the Board seek cooperation with other agencies or organizations to compile and analyze the results of the above-mentioned research. This would provide a comprehensive picture of the long- and short-term effects of hatchery releasedsalmon on the wild salmon stocks.

Response:

Chairwoman Entsminger

Environmental Biology of Fishes

I Federal Subsistence Board Reply to the Eastern Interior Alaska Subsistence Regional Advisory Council's Fiscal Year 2018 Annual Report, p. 4.

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 225

Although research about interactions of hatchery rearedand wild salmon in the marine environment is outside the purview of the Board, we do sharethe Council's concern. The Board's authority is limited to providing a subsistence priority forthe use of fish and wildlifetaken from Federal public lands under Title VIII of the Alaska National Interest Lands Conservation Act (ANILCA). The only research the Board can authorize pertains to the Fisheries Resource Monitoring Program (FRMP). Activities not eligible forfunding under the FRMP include: (1) habitat protection, mitigation, restoration, and enhancement; (2) hatchery propagation, restoration, enhancement, and supplementation; and (3) contaminant assessment, evaluation, and monitoring. The rationale behind this approach is to ensure that existing responsibilities and effortby governmentagencies are not duplicated under the FRMP. Land management or regulatory agencies already have direct responsibility, as well as specificprograms, to address these activities. Additionally, the Board has jurisdiction over very little marinewaters.

One of the most thorough literature reviews on this topic is still the May 2012 special issue of the journal (Volume 94, Number I, Ecological Interactions of Hatchery and Wild Salmon). This article compiles published results fromnumerous studies and reviews presented at a conferenceorganized by the Wild Salmon Center in Portland, Oregon. This publication contains a collection of 22 studies conducted by various university scientists and governmentagency fisheriesresearchers that address potential impacts of hatcheries to wild salmon stocks throughout the PacificRim in Russia, Japan, Canada, and the United States. Most of the articles pertain to hatchery management in other regions, but a couple of papers report on Federal Subsistence Board FY2018 Annual Report Reply

Chairwoman Entsminger investigations of hatchery fish interactions at sea that may be applicable to Western Alaska wild salmon stocks. The Board refersthe Council to this journal forfurther details. The Board would also like to direct the Council to the more recent publication New Research Quantifies Record­ Setting Salmon Abundance in North PacificOcean (https://fisheries.org/2018/04/new-research­ guantifies-record-setting-salmon-abundance-in-north-pacific-ocean/). The Board highly encourages the Council to invite subject matter experts to speak about the research findings. 4. Concerns over the Alaska Department of Fish and Game lowering the biological escapement goal and its effecton salmon stocks

The Council was troubled by a report titled Another side of Meeting Canadian Border Escapement in 2018: US/Canada Border Escapement Cuts prepared by Tanana/Rampart/Manley Advisory Council ( enclosed). The report states that, over time, the Alaska Department of Fish and Game has been effectivelylowering the cross-border interim management escapement goal (lMEG) for Chinook Salmon by shiftingthe unit of measure from a mark-recapture metric to one based on units produced by the Eagle Yukon River sonar. Historically, the original escapement goals set under the U.S. - Canada Yukon River Salmon Agreement of 2001 (200/ Agreement) were adjustedbased on the Canadian-run mark recapture projects. In 2005, ADF &G began using Didson and split-beam sonar technology at the Eagle Yukon River site, which counted passing salmon more accurately. Statistics show that during the period between 2005-2007, the Eagle sonar counted approximately 1. 7 times more Chinook Salmon than the simultaneously operated Canadian mark-recapture projects. However, the sonar counts fishin general and cannot distinguish between male and female fish, thusit does not count how many fecund females pass across the border.

Yearly Passage Estimate/ Year DFO Tag/Recap Eagle Sonar Times higher at Eagle 2005 45,000 81,529 1.81 2006 47,965 73,691 1.54 2007 22,958 41,697 1.82 6

The Council feels that despite the higher Chinook Salmon passage numbers gathered at the Eagle sonar, which provides a scientificbasis for increasing the escapement numbers under the 2001 Agreement, the unit conversion did not appropriately translatethe relative order of magnitude, which is now set significantlylower than specifiedin the Agreement. Moreover, in 2008 the Yukon River Panel adopted 45,000 as the reduced /MEG for Chinook Salmon. In 2010, it was reduced further to 42,500 fish. It is the Council's understanding that that some managers would like to. reduce it even furtherto 30,000 fishfor the upcoming season.

In 2014 over 64,000 Chinook Salmon returnedto their spawning groundsin Canada, which is 21,500 over the lower margin on the /MEG range (42,500-55,000). A similar situation

2 Another side of Meeting Canadian Border Escapement in 2018: US/CanadaBorder Escapement Cuts report prepared by Tanana/Rampart/ManleyAdvisory Council (Attachment I).

226 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Federal Subsistence Board FY2018 Annual Report Reply

Chairwoman Entsminger Chairwoman Entsminger 7 investigations of hatchery fish interactions at sea that may be applicable to Western Alaska wild repeated in with spawning escapement reaching which was about over the salmon stocks. The Board refersthe Council to this journal forfurther details. The Board would lower escapement goal However, Chinook Salmon are returning at younger also like to direct the Council to the more recent publication New Research Quantifies Record­ ages with smaller average sizes. Consequently, there are fewer eggs being deposited in the Setting Salmon Abundance in North PacificOcean (https://fisheries.org/2018/04/new-research­ gravel than in the past because smaller fishcarry fewer eggs, lowering the reproductive guantifies-record-setting-salmon-abundance-in-north-pacific-ocean/). The Board highly potential. Thus, though the estimated passage was above the lower end of the /MEG, the actual encourages the Council to invite subject matter experts to speak about the research findings. spawning potential was the same as if the passage was much lower. 4. Concerns over the Alaska Department of Fish and Game lowering the biological escapement goal and its effecton salmon stocks The Council poims to scientific research showing that the average size of Pacific salmon have declined over the past few decades. This decrease over the past 30 years may be "because of a The Council was troubled by a report titled Another side of Meeting Canadian Border decline in the predominalll age at maturityand because of a decrease in age-specific length, "3 Escapement in 2018: US/Canada Border Escapement Cuts prepared by but the Council also feels the selective large mesh gillnet fisheryhas compounded impacts. Tanana/Rampart/Manley Advisory Council ( enclosed). The report states that, over time, the Further research indicates that "the relationship between mean fecundityand length differed Alaska Department of Fish and Game has been effectivelylowering the cross-border interim among broad regions within the [Yukon River] drainage. . . . In the middle and upper portions of management escapement goal (lMEG) for Chinook Salmon by shiftingthe unit of measure from the drainage, Chinook salmon tended to have fewer eggs and fecunditywas more strongly a mark-recapture metric to one based on units produced by the Eagle Yukon River sonar. dependent on fish length." 4 When making decisions, managers need to consider that populations Historically, the original escapement goals set under the U.S. - Canada Yukon River Salmon in the middle and upper portions of the drainage do not have the same reproductive potential as Agreement of 2001 (200/ Agreement) were adjustedbased on the Canadian-run mark recapture the fishin the lower river and "may be more dependent on the size of reproducing individuals. "5 projects. In 2005, ADF &G began using Didson and split-beam sonar technology at the Eagle The Council is veryconcerned that the returning fish are now younger ages and have smaller Yukon River site, which counted passing salmon more accurately. Statistics show that during the average sizes and that the number of older, larger, fecund females have decreased. The Council period between 2005-2007, the Eagle sonar counted approximately 1. 7 times more Chinook believes that because of the decline in age classes and fecundity, management needs to Salmon than the simultaneously operated Canadian mark-recapture projects. However, the compensate by increasing escapement goals with a focuson the number of eggs in the gravel. sonar counts fishin general and cannot distinguish between male and female fish, thusit does not count how many fecund females pass across the border. According to the Agreement, the Yukon River Panel "shall establish and modifyas necessary interim escapementobjectives of the rebuilding program" and ''for any year when a Yearly Passage Estimate/ strong run is anticipated, the Yukon River Panel may recommend a spawning escapement Year DFO Tag/Recap Eagle Sonar Times higher at objective greater than the agreed level." Moreover, the Agreement mandatesthat "in any Eagle year of a strong run, the United States agrees to consider increasing the border escapement to a 2005 45,000 81,529 1.81 level greater than agreed in order to allow a higher spawning escapement for that year." The 2006 47,965 73,691 1.54 Council is concerned that /MEG had not been set at its optimum based on solid science, and that 2007 22,958 41,697 1.82 6 the decisions made had been influenced by politics. Additionally, the Council is concernedthat the restorationof salmon stocks have been significantlyaffected by these decisions. The Council The Council feels that despite the higher Chinook Salmon passage numbers gathered at the would like to2015 request that the Board direct OSM to take82,674, a closer look at these matters40,000 and (42,500-55,000). Eagle sonar, which provides a scientificbasis for increasing the escapement numbers under the prepare a report for the Council that: 1) describes the transition ofunits of measure of salmon 2001 Agreement, the unit conversion did not appropriately translatethe relative order of crossing the U.S./Canada Border from mark-recapture to sonar units; and 2) evaluates whether magnitude, which is now set significantlylower than specifiedin the Agreement. Moreover, in the current /MEG appropriately reflectsthe intent of the Agreement toward rebuilding the 2008 the Yukon River Panel adopted 45,000 as the reduced /MEG for Chinook Salmon. In 2010, it was reduced further to 42,500 fish. It is the Council's understanding that that some managers 3 Changes in Size and Age of Chinook Salmon Oncorhynchus tshawytschaReturning toAlaska (Bert Lewis, W. would like to. reduce it even furtherto 30,000 fishfor the upcoming season. Stewart Grant, Richard E. Brenner, and Toshihide Hamazaki; 2015, PLOS One). Also see Demographic changes in Chinook salmon across the Northeast Pacific Ocean (Jan Ohiberger, Eric J. Ward, Daniel E. Schindler, and Bert In 2014 over 64,000 Chinook Salmon returnedto their spawning groundsin Canada, which is Lewis; 2018, Wiley Online Library (access provided by NOAA Library Network). 21,500 over the lower margin on the /MEG range (42,500-55,000). A similar situation 4 Effects ofMarine Growth on Yukon River Chinook Salmon Fecundity (Kathrine G. Howard and Jeffrey Bromaghin; Yukon River Salmon Research and Management Fund Report #21-10). 5 Differential Fecundity among Yukon River Chinook Salmon Populations Revealed by a Generalized Genetic 2 Another side of Meeting Canadian Border Escapement in 2018: US/CanadaBorder Escapement Cuts report Mixture Model (JeffreyF. Bromaghin, Danielle F. Evenson, Thomas H. McLain, and Blair G. Flannery; Arctic­ prepared by Tanana/Rampart/ManleyAdvisory Council (Attachment I). Yukon-Kuskokwim Sustainable Salmon Initiative).

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 227

2001

200/

2001 Federal Subsistence Board FY2018 Annual Report Reply

8

Response:

(FRMP) FRMP

FRMP. ChairwomanCanadian origin Entsminger Chinook Salmon stocks, given that fewer eggs are being deposited in the gravel proportionally than at the time of the Agreement when Chinook were of larger size.

5. Advancing the hunter ethics education and outreach program

The Federal Board's authority is limited to providing a subsistence priority forthe use of fish and wildlife taken fromFederal public lands under Title VIII of the Alaska National Interest Lands Conservation Act. The Board does not comment on Treaty obligations such as the IMEG.

The methodology forsalmon crossing the U.S./Canada border changed when the border mark/recapture program ended in 2007. Data collected fromthe Eagle sonar and the Yukon River drainage-wide mark-recapture with telemetry from 2002-2004 suggested that the border and escapement estimates derived fromthe mark/recaptureprogram at the border were biased low. In 2008, an estimate of historical Canadian spawning escapements was derived using a combination of estimatesEastern fromInterior mark-recapture Alaska Subsistence data, Regional sonar, Advisory radio telemetry, Council Meeting and aerial survey data.228 In order to produce the historical Canadian spawning escapements, the border passage estimates fromthe Eagle sonar (2005-2007) and radio telemetry data (2002-2004) was used as the basis to estimate the total escapement from 2002-2007. Age-specificreturns were then calculated based on sampling data in the return years. This created a basis for a stock-recruitment model that began in 20 I 0. Currently, the passage of Chinook Salmon into Canada is estimated by the Eagle sonar, located just downstream of the U.S./Canada Border.

Data is lacking to accurately estimate the number of eggs deposited in the gravel now in comparison to what may have been deposited in 2001. The Board feels that this request wouldbe best addressed through a Fisheries Resource Monitoring Program project, or perhaps through the Yukon River Panel Research & Enhancement fund. The is a primary mechanism forfunding research about subsistence fisheries. The best way for the Council to direct researchon this subject is through action on Priority InformationNeeds (PINs) forthe The Board encourages the Council to work with the other Yukon River Councils and in­ season managers and biologists through joint PIN working groups to develop a unified list of PINsfor the Yukon FRMP region that addresses these important research questions. The Council is veryencouraged by the progress made in the development of the hunter ethics education and outreach pilot program and expresses its continuing appreciation and support. The Council would like relay to the Board that its support has a meaningful effecton the progress of this project. It is evident by the number of participants and their enthusiasm that this is a timely and important effort.

It is the Council's understanding that forming partnerships is crucial at the current stage of the program's development. The Council also realizes that in order for a pilot project or projects to be successfulthey need to have funding sources. Federal Subsistence Board FY2018 Annual Report Reply

8 Chairwoman Entsminger 9

Prior to seeking partners, the Council would like to have a clear understanding of the mechanisms of how this Council can form partnerships to advance a pilot project and ifthere are any government policies or limitations associated with e/llering partnerships and receiving Response: funding. These partnerships can potentially include Federal and State agencies, tribal organizations, and private entities and businesses that can contribute resources through technical expertise, research, funding, knowledge, outreach and education, and stafftime.

The Council formally requests that the Board direct OSM to prepare a written report on the various mechanisms available to this Council for forming partnerships and receiving funding. The Council also would like to enquire ifthe Federal agencies represellted on the Board have any funding that can be directed towards implementing a pilot project (or projects).

The Council also requests that either the Board or OSM prepare a letter of support for the hunter ethics education and outreach initiative that can be used when seeking partnerships.

Response:

The Board was briefed on the progress of the hunter ethics education and outreach initiative during its April 2019 regulatory meeting and was favorablyimpressed by the progress and the amount of work that was done during the year and a half that has transpired since the last update. The Board commends the Council on diligently working to advance the initiative and develop true partnerships to implement a pilot project or projects. Considering the extensive interest shown by various stakeholders in this initiative, it is clear that this work is timely and important.

(FRMP) The Board would like to clarify that the Council is an advisory body to the Board and has no FRMP legal authority or legal mechanism to seek and/or accept funding or assume any duties related to the management of any such funding. The Board sees that the best way to advance the pilot projects is for the other entities that are a part of each projects' working group to assume a FRMP. ChairwomanCanadian origin Entsminger Chinook Salmon stocks, given that fewer eggs are being deposited in the gravel responsibility forobtaining any necessaryoutside fundingand handling accounts and reporting. proportionally than at the time of the Agreement when Chinook were of larger size. Under this scenario, the Council members can still contribute their knowledge, expertise, and time to the project in-kind.

5. Advancing the hunter ethics education and outreach program Other potential opportunities to leverage funding are through cooperative agreements and contracts with another agency or tribal or hunter organization that the OSM is a party to; however, there needs to be a concrete pilot project with set goals, timelines, and deliverables. OSM will prepare a letter to the Council with a detailed explanation on what is within their The Federal Board's authority is limited to providing a subsistence priority forthe use of fish and wildlife taken fromFederal public lands under Title VIII of the Alaska National Interest Lands purview and what are the legal avenues for advancing the hunter ethics education initiative. The Conservation Act. The Board does not comment on Treaty obligations such as the IMEG. Federal agencies represented on the Board will need to see pilot project(s) developed in detail with an itemized budget, in order to consider contributing any funding towards it. The methodology forsalmon crossing the U.S./Canada border changed when the border mark/recapture program ended in 2007. Data collected fromthe Eagle sonar and the Yukon River drainage-wide mark-recapture with telemetry from 2002-2004 suggested that the border and escapement estimates derived fromthe mark/recaptureprogram at the border were biased low. In 2008, an estimate of historical Canadian spawning escapements was derived using a combination of estimates from mark-recapture data, sonar, radio telemetry, and aerial survey Eastern Interior Alaska Subsistence Regional Advisory Council Meeting data. In order to produce the historical Canadian spawning escapements, the border passage 229 estimates fromthe Eagle sonar (2005-2007) and radio telemetry data (2002-2004) was used as the basis to estimate the total escapement from 2002-2007. Age-specificreturns were then calculated based on sampling data in the return years. This created a basis for a stock-recruitment model that began in 20 I 0. Currently, the passage of Chinook Salmon into Canada is estimated by the Eagle sonar, located just downstream of the U.S./Canada Border.

Data is lacking to accurately estimate the number of eggs deposited in the gravel now in comparison to what may have been deposited in 2001. The Board feels that this request wouldbe best addressed through a Fisheries Resource Monitoring Program project, or perhaps through the Yukon River Panel Research & Enhancement fund. The is a primary mechanism forfunding research about subsistence fisheries. The best way for the Council to direct researchon this subject is through action on Priority InformationNeeds (PINs) forthe The Board encourages the Council to work with the other Yukon River Councils and in­ season managers and biologists through joint PIN working groups to develop a unified list of PINsfor the Yukon FRMP region that addresses these important research questions. The Council is veryencouraged by the progress made in the development of the hunter ethics education and outreach pilot program and expresses its continuing appreciation and support. The Council would like relay to the Board that its support has a meaningful effecton the progress of this project. It is evident by the number of participants and their enthusiasm that this is a timely and important effort.

It is the Council's understanding that forming partnerships is crucial at the current stage of the program's development. The Council also realizes that in order for a pilot project or projects to be successfulthey need to have funding sources. Federal Subsistence Board FY2018 Annual Report Reply

Chairwoman Entsminger IO

As for the Council's request that the Board or OSM prepare a letter of support for the hunter ethics education and outreach initiative, the Board will consider directing OSM to prepare such letter; however, the Council needs to be aware that it would be a general endorsement for the initiative, not a letter of support for funding.

In closing, I want to thank you and your Council foryour continued involvement and diligence in matters regarding the Federal Subsistence Management Program. I speak for the entire Board in expressing our appreciation for your effortsand our confidence that the subsistence users of the Eastern Interior Region are well represented through your work.

Sincerely,

�� Anthony Christianson Chair

Enclosure

cc: Federal Subsistence Board Thomas Doolittle, Acting Assistant Regional Director, Office of Subsistence Management Thomas Whitford, Acting Deputy Assistant Regional Director Officeof Subsistence Management Jennifer Hardin, PhD, Subsistence Policy Coordinator, Officeof Subsistence Management Steven Fadden, Acting Council Coordination Division Supervisor, Officeof Subsistence Management Chris McKee, WildlifeDivision Supervisor, Officeof Subsistence Management Greg Risdahl, Fisheries Division Supervisor, Officeof Subsistence Management George Pappas, State Subsistence Liaison, Office of Subsistence Management Zachary Stevenson, Council Coordinator, Officeof Subsistence Management EasternInterior Alaska Subsistence Regional Advisory Council Benjamin Mulligan, Deputy Commissioner, Alaska Departmentof Fish and Game Mark Burch, Special Project Coordinator, Alaska Department of Fish and Game lnteragency Staff Committee Administrative Record

230 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Federal Subsistence Board FY2018 Annual Report Reply

Another side of Meeting Canadian Border Escapement In 2018 US/Canada Border Escapement Cuts Tanana/Rampart /Manley Advisory Council

Since 2010 we have had our present US/Canada treaty agreement to pass a basic minimum of king into Canada. That number is now determined by the Eagle Sonar project. Basic spawning minimum is 42,500 kings and with some fish for Canada the harvest minimum is 51,000. So the present range is from a basic spawning minimum of 42,500 to a harvest minimum for Canada of 51,000

Going back for some history

For 3 years the new Eagle sonar project ran at the same time as the older mark recapture project run by the Canadians. Originally prior to 2008 the mark recapture project determined the border escapement. The US Canada Spawning escapement goal was 33,000 to 43,000 kings and with some fish for Canada the harvest minimum was 45,700. So to compare with later years it's correct to say the range was from a basic spawning minimum of 33,000 to a harvest minimum for Canada of 45,700.

Now no two projects count the same and the mark recapture project was probably doing some undercounting, because when the more accurate Eagle sonar came on line and ran at the same time as the mark recapture one it counted higher.

Yearly Passage Estimates

DFO Eagle % Higher at Eagle Year Tag/Recap Sonar

2005 45,000 81,529 1.81 2006 47,965 73,691 1.54 2007 22,958 41,697 1.82

Eagle Sonar for those 3 years counted an average of 1.72% more king salmon. Now when the time came after these three year to transition over to making Eagle Sonar the official escapement counting project it would seem natural and

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 231 Federal Subsistence Board FY2018 Annual Report Reply fair and scientific to increase all the US/Canada agreement numbers by 1.72% but that was not done. And it was not expected for years that it would be done that way. As a matter of fact since the first time the idea of Eagle Sonar project came about many agency people and fishermen feared that while the project would probably be more accurate, that the State would just use the moment to slip in a lower escapement. And so the state did. Instead of using their best science at the time to arrive at a range 1.72 times greater, or 56,760 to 78,604, the US portion of the Yukon River Panel (ADF&G controlled) forced Canada to accept a minimum goal of 45,000 kings. In 2010 that was reduced further to 42,500. ADF&G currently wants to further reduce this as far as 30,000.

Now for some perspective: In 2014 official escapement was 64,500 kings (84,000 in 2015). This was 22,000 (41,500 in 2015) over the lower end of the goal. If one considers the reduced spawning capabilities of the two run years due to genetic loss of the older age classes of king (which many experts say could be 50% of eggs in the gravel as historically) we could have only put the equivalent of 32,250 kings across the border in 2014 and 42,000 in 2015. That is 24,510 less kings in 2014 (14,760 in 2015) than the lower end of the escapement would be if ADF&G had not succeeded in lowering it in 2008 and 2010. Amazing how lead can be turned into gold.

One of managements pet reasons for lower escapements, voiced many times publically by the last Regional Director of AYK Commercial Fisheries Div., was we were putting to many eggs on the spawning grounds and it was causing over escapement and poor survival. This sentiment was also given as a possible reason for the declining King runs and voiced publically by the present AYK Regional Director in 2009 at a meeting in front of many people at the Rampart Rapids. This is the mindset within some of upper management as it concerns king salmon.

Without considering the smaller king (fewer eggs) going to the spawning grounds today and where our escapement goals used to be in the past our management of king salmon today is based on politics and a whim, instead of science. (10/11/2018) TRM approved)

232 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Alaska Board of Game 2019/2020 Cycle Tentative Meeting Dates

Alaska Board of Game P.O. Box 115526 Juneau, AK 99811-5526

(907) 465-4110

www.boardofgame.adfg.alaska.gov

ALASKA BOARD OF GAME 2019/2020 Cycle Tentative Meeting Dates

Comment Meeting Dates Topic Location Deadline

January 16, 2020 Work Session Nome TBD (1 day)

January 17-20, 2020 Arctic/Western Region Nome January 3, 2020 (4 days) Game Management Units 18, 22, 23, & 26A

March 6-14, 2020 Interior/Northeast Arctic Fairbanks February 21, 2020 (9 days) Region Game Management Units 12, 19, 20, 21, 24, 25, 26B, and 26C

Total Meeting Days: 15 Agenda Change Request Deadline: Thursday, November 1, 2019 (The Board of Game will meet via teleconference to consider Agenda Change Requests following the November 1 deadline.) Proposal Deadline: Tuesday, May 1, 2019

February 2019

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 233 Yukon River Drainage Fisheries Association Ongoing Projects Report: 2018-2019

YRDFA Ongoing projects: 2018-2019

Pre-Season Fishermen’s Meeting Purpose: To conduct an annual meeting of active Yukon River fisheries and fishery managers to build ​ an aware public constituency that is motivated to maintain and protect Yukon River salmon stocks and meeting the Yukon River escapement goal with Canada as directed by the Yukon River Agreement.. ● All Yukon River Fishing Districts and communities represented Funding Source: Yukon River Panel: Restoration and Enhancement Fund (R&E) ​ ● Funding through September 30, 2019 ● We will be applying for funding from the Yukon River Panel which will be reviewed & decided on in December 2019. What we have Learned: The Pre-season Fishermen’s meeting continues to be valued by Yukon River ​ fishers as the primary meeting for Yukon River managers and fishers to prepare for the upcoming fishing season and an important opportunity to discuss and plan for the key management goal of meeting escapement targets for Canadian origin Chinook salmon.. Accomplishments: For 10 years the Pre-season meeting has brought Yukon River fishers and ​ community representatives, fishery managers and research scientists and other stakeholders together for a full day of presentations and discussions designed to prepare fishers for the management approaches being considered and to supply insight and guidance to managers from the breadth of the Yukon River. Fishers and managers share that they feel these meetings are key to the relationships built over time for understanding and dealing with the challenges of this complex fishery. The 2019 meeting was held in Fairbanks on April 25th with an attendance of 90 plus fishers and stakeholders and 14 fishery and management staff. Representatives from Yukon River Delta Fishermans Assoc., Yukon River Inter-Tribal Fish Commission, Yukon River Tribal and community members plus two Department of ​ ​ Fisheries & Oceans Canada management staff attended the full day meeting. Next steps: The 2020 Pre-season meeting proposal is due Oct 1. If funded we will be working with our ​ partners and stakeholders to meet in Anchorage in April or May.

In-season Teleconferences Purpose: To provide a forum for people from the Yukon River to engage with fisheries managers on ​ sharing information about subsistence harvests during the fishing season. Funding Source: OSM: Fisheries Resource Monitoring Program (FRMP) ​ ​ ● Funded through March 31, 2020 What we have Learned: We continue to hear from both Yukon River fishers and the managers how ​ much they value the information and conversations shared on the summer fishing calls. The multiple fish species, complex management approaches, ever changing river conditions and over 40 communities who fish make these “real-time” calls during the fishing season an important tool for meeting subsistence, escapement and conservation goal.

234 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Yukon River Drainage Fisheries Association Ongoing Projects Report: 2018-2019

Accomplishments: The Teleconferences held every Tuesday, June through August provides the forum ​ and service for continued cooperative management. The need for the calls was very evident this year, ​ ​ one for the record books. Changes in returns of Summer chum and Chinook salmon, high and low water conditions, extreme air and water temperatures combined to challenges and hardships for the fish, fishers and managers as they worked through the details of providing for subsistence harvest and meeting critical escapement goals. Next steps: We have submitted a proposal to OSM through the FRMP for continued funding and request that you support it if you believe, as we do, that the Teleconferences are an important communications tool for subsistence fishers on the Yukon and managers tasked with the complex and challenging work of maintaining a sustainable fishery.

In-Season Subsistence Salmon Survey: Purpose: Provide an important communication tool that qualitatively informs managers how fishers in ​ ​ key locations throughout the drainage are doing in-season, enabling managers to make timely decisions allowing the maximum number of fishers to meet their subsistence needs. Include local hire of one surveyor in 10 communities which currently are: Alakanuk, Mountain Village, Marshall, Russian Mission, Anvik, Huslia, Ruby, Tanana, Fort Yukon, and Eagle. Funded by: OSM: Fisheries Resource Monitoring Program (FRMP) through March 31, 2020. ​ Preliminary summary of 2019 season: Our season began in the spring with outreach to the previous ​ surveyors, tribal councils, community members, and Yukon River managers to gather additional feedback and suggestions for the 2019 season. Key suggestions were incorporated into the survey forms, training protocol and reporting format. Then surveyors were hired in all 10 communities and travel was set for the annual training event and attendance at the Yukon River Pre-Season Planning meeting in Fairbanks. These events are very helpful to the surveyors and program because surveyors are able to educate themselves on current Yukon River fishery issues, network and meet other surveyors and fishers, and refresh or receive training for the in-season survey program. Surveyors then returned to their communities to prepare for the fishing season. Each surveyor conducted informed consent with local fishers and invited them to participate in the surveys during the appropriate time for their community to capture Chinook salmon fishing observations and results. The table below shows preliminary results of the 2019 season.

Preliminary 2019 In-season Salmon Survey Results:

Years # of # of employe Households Interviews Community Surveyor d Interviewed total date range Alakanuk Pamela Cook 4 29 78 May 30 - July 8 Mountain Village Nita Stevens 1 10 38 June 6 - July 15 Marshall Norma Evan 11 14 64 June 6 - July 15 Russian Mission Basil Larsen 5 21 54 June 6 - July 15 Anvik Sherry Kruger 3 8 12 June 6 - June 20 Ruby Rachael Kangas 2 17 26 June 13 - July 15 Zoe Huslia Ballard-Huffman 1 6 3 July 4 -July 22 Ariella Derickson/ 2 Tanana Stan Zuray 1 8 39 June 13 - July 29

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 235 Yukon River Drainage Fisheries Association Ongoing Projects Report: 2018-2019

Andrew Firmin/ 11 Fort Yukon Kara'lisa Tremblay 1 23 52 June 20 - July 29 Eagle Ruby Becker 1 6 11 July 4 - Aug 19

To wrap up the season, the surveyors have a final interview form which asks the fishers if they met their needs this year; how their fishing/harvest compared to last year; if they think opportunity was provided and if they have suggestions; and if they received enough notice of openings. Results show the following: Alakanuk – Most participants met their needs but it was mixed about comparisons to last year. They all ​ felt they had enough notice of openings. Mountain Village- About half of participants met their needs for Chinook but all participants said they ​ ​ ​ did have enough notice of openings. They liked being able to use nets instead of dipnets and most said fishing was better than last year for kings but light on chum salmon. Marshall- Fishers in Marshall reported the fishing was about the same as last year but some thought ​ there were more and bigger Chinook. They were concerned about the dead sea mammals. They also commented about the very hot summer. Russian Mission- About half of the participants in Russian Mission met their needs according to the ​ survey but those that did not had personal issues that prevented their success. More than half requested to stay on their weekly schedule and reported they did NOT receive enough notice about openings. Anvik – Surveyor was unable to complete her contract this year. ​ Ruby - All participants reported meeting their needs this year and most said fishing was the same as ​ last year and two said it was better. They noted the low water, larger Chinook, good quality fish, and parasites. Huslia – Three fishers participated in the final interview and two of them did NOT meet their needs. ​ One of these two had personal issues and the other said it was poor fishing. The one who met their needs said it was better fishing this year. Tanana/Rapids – All participants in the final interview said that they met their needs this year and ​ most said fishing was better than last year. There were low water problems for nets and travel issues. They also noted larger Chinook and the slow start to the run. Most are opposed to the use of 7.5” mesh nets until the run is healthy again. Fort Yukon – Most participants met their needs here and said fishing was good but the fires prevented ​ them from getting more salmon. The only suggestion they have for management was no closures. Eagle – report to come . ​ … This project, funded by the Fisheries Resource Monitoring Program, is important because it provides a voice for Yukon River fishers to anonymously share their observations, fishing success or challenges, and suggestions for management on a weekly basis to a local contact. This information is shared, anonymously by YRDFA, with Yukon River managers on Mondays. Local surveyors share a summary of their weekly report with the entire river and answer questions on Tuesday through the YRDFA teleconferences.

236 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Yukon River Drainage Fisheries Association Ongoing Projects Report: 2018-2019

Traditional Knowledge of Anadromous Fish in the Yukon Flats with a focus on the Draanjik Basin Purpose: To provide information critical to the management of anadromous fish and the habitat that ​ supports them. This will be accomplished through Traditional Ecological Knowledge (TEK) interviews and mapping activities with knowledgeable fishers and hunters in Chalkyitsik, Fort Yukon, Venetie, and Fairbanks to identify areas in the Yukon Flats and Draanjik basin with salmon and whitefish spawning and rearing areas. This will then be verified by helicopter and river boat field work and finally nominations of new areas will be submitted to the anadromous waters catalog. Partnership with Tanana Chiefs Conference, YRDFA, and communities. Parallel project in coordination with ADF&G in Tanana River drainage. Funded by: OSM: Fisheries Resource Monitoring Program (FRMP) through March 31, 2021 ​ Accomplishments: ● Fieldwork conducted in Fort Yukon, Venetie, and Chalkyistik August 2018 through February 2019. Twelve interviews and mapping activities conducted. Local research assistants hired in each community. ● Interviews transcribed and draft results summarized. ● Biological fieldwork conducted October 2018- preliminary eDNA results show samples all positive for salmon species. ● 2019 biological field work planned and detailed for all salmon species but postponed due to heavy fire activity in the region. Next steps include a few more key interview participants and TCC biological team ground truthing ​ locations identified by participants. Biological field work planned for 2019 will be rescheduled due to 2019 fire activity.

Educational Exchange Purpose: The Yukon River Educational Exchange is a way for people who live and use the Yukon River ​ in the US and Canada to increase their understanding of their neighbor’s experiences and challenges relating to supporting and maintaining sustainable salmon runs to the spawning grounds in Canada. Funding Source: Yukon River Panel: Restoration and Enhancement Fund (R&E) ​ ● Funding through March 31, 2019 ● 2020 proposal to be submitted by October 1, 2019, with a decision at the April Yukon River Panel meeting in Anchorage. What we have Learned: For over a decade the Education Exchange has brought Yukon River fishers, ​ community members, fishery managers and other stakeholders together for information and experience sharing for building understanding with the goal of supporting sustainable care and use of Yukon River salmon runs with an emphasis on Chinook salmon escapement to the critical Canadian spawning grounds. As the YRDFA Pre-season Meeting and Teleconferences are the immediate, real-time communication tools for bringing key constituents together, the Education Exchange provides long-term outreach and support for creating a deeper appreciation between people and communities that share the same resource and the challenge to use it sustainably. Those who have participated in the Yukon River Educational Exchange describe their experience, whether in Alaska or Canadian Yukon, as unforgettable, very informative and deeply meaningful. Meeting people face-to-face, sharing cultures, meals, stories, fears and joys educates and bonds people in very memorable ways. These experiences are

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 237 Yukon River Drainage Fisheries Association Ongoing Projects Report: 2018-2019

shared when folks return home, rippling outward in small communities and building relationships of deeper understanding about the shared fishery resource belonging to Alaska and Canadian communities. Accomplishments: Next steps: The 2019 Education Exchange had challenges of a shorter planning ​ period so attendees could attend the April Yukon River Panel meeting in Whitehorse and the last minute loss of two attendees due to family emergencies. Despite this, the Alaskan and Canadian participants queried felt the trip was very useful for better understanding of the work of the Yukon River Panel, Canadian fishery management, First Nation’s culture and relations to fish, and the same issues from the Alaskans perspective. If funded, we look forward to hosting our far upriver friends with visits to lower river villages, monitoring stations, commercial and subsistence fishing observing and shared meals and stories in Alaskan Yukon River communities in 2020.

Building & Maintaining Public Support of Salmon Resource Management Purpose: Build and maintain public support and meaningful participation in Yukon River salmon ​ resource management by maintaining community capacity to participate, by developing mutual understanding between management agencies and the public for encouraging conservation and stewardship of salmon resources. Funding Source: USFWS: Restoration and Management Fund (R&M) ​ ● Funding through June 30, 2019 ● 2020 proposal to be submitted early January for a decision at April Yukon River Panel meeting. What we have Learned: This project supports communications and outreach to Yukon River ​ communities through maintaining a collective voice and organization of Yukon River fishers for developing, refining and improving public knowledge, participation and support of Yukon River fisheries management. This approach has developed a cadre of fisherman able to share community level fisheries concerns with managers and inform local fishers on the importance of conservation approaches and other key fisheries management guidance. Accomplishments: For over a decade YRDFA has played a key role through this program by convening ​ fishers representing all of the Yukon River fishing districts and agency managers responsible for overseeing the Yukon River fisheries, both commercial and subsistence. Over time a working relationship and better understanding of all sides of fisheries issues have been developed, leading to cooperation and success in conserving declining stocks for meeting escapement, commercial and subsistence harvest goals. Next steps: The 2019 YRDFA Board meeting was held April 23 & 24 in Fairbanks. Some key ​ accomplishments were an initial meeting with the new Alaska ADFG Commissioner Douglas Vincent-Lang, in depth discussions about large scale hatcheries and the draft Comprehensive Salmon Plan, the decision to create two young fisher advisor positions on the YRDFA Board, the passage of eight fishery associated resolutions and more. Board members participated in the Pre-season Planning meeting which followed on April 25th in Fairbanks.

Thank you! YRDFA Board & staff.

238 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting List of Documents Required for Alaska Real ID T e 9 . 1 . 6 redacted balances and : esidency R A R A F A below: esidency have account numbers account have may to see if you are eligible! are you see if to in Principal uments elements oc ust One document must have been issued within 90 days within issued been have must document One d m Two documents must be presented and cannot be handwritten cannot and be presented must documents Two Primary R R AT T T TR T D R R D D D D R D T F A R T AD A T R A A A F A A A A T R A T R A A T D D T A T AT F ATA T A D A D D Resident Resident Status                 D , and may be used to prove more than one element) one than more prove be used to may Lawful uments A SSN SSN Complete SSN D F FATDF A A A Go ALASKA.GOV/DMV to following documents: following –       the A A F F Residentwith need U.S. Citizens, Permanent Residents, Residents, Permanent Citizens, U.S. Temporary U.S. the A A D D D A T D Name Change Real IDReal         of documents that prove the elements (some doc (some elements the prove that documents of Real ID Real T A T D combination combination R A T R R A RA R AD Lawful Status Lawful          To ensure your application process is as smooth as possible, please complete all complete please possible, as as smooth is process application To ensure your Proof Name, of Identity,your Date of Birth, Lawful Status You can provide any any provide canYou For Renewals, you may be able to skip the office completely completely office the skip to able be may you Renewals, For Identity Name / Date of Birth of Date / Name RA R T R R A A D D D RA D pplying for an an Alaska pplying for A License, Permit or ID Card? The Alaska DMV must electronically verify documents to determine validity and status before Issuance of an ID / Driver Licens Driver / ID an of Issuance before status and validity determine to documents verify electronically must DMV The Alaska          D www.Alaska.gov/DMV

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 239 List of Documents Required for Alaska Real ID F D 6 19 A F R R T T A ) T T A R A T T APPLY T R T T R T D T F A D D T T D R R A T R R Cannot Be Handwritten Be Cannot ( rincipal Residency A A F A A P T A DT T T FEDERALLIMITS below: R D D D D R A A A T A D D D A T A A R A A A T A A to see if you are eligible! are you see if to                

A elements A

F A SSN A Complete SSN A A F F A A D R        . ALASKA.GOV/DMV A D A R D D T D T Go to A – A A A D F F D FATDF Lawful Status in the U.S. need the need U.S. in the Status Lawful D Name Change A A D D A TA A R D T A R D F D D D T T         F A A T U.S. Citizens, Permanent Residents, Temporary Residents, Permanent Citizens, U.S. Resident with documents: following Status Lawful R A R F R A A R A A A A R A D          A D of documents that prove the elements (some docs may be used to prove more than one element) one than more prove to used be may docs (some elements the prove that documents of tandard R R S T D T combination combination Identity Secondary A Proof of your Name, Identity, Date of Birth, Lawful Status and Primary Residency: and Primary Status Lawful Birth, DateIdentity, of Name, Proof your of DD To ensure your application process is as smooth as possible, please complete all A D T T D T F D D R T R D T T T A A D D T DT A                    D You can provide any any provide canYou D A F F For Renewals, you may be able to skip the office completely completely office the skip to able be may you Renewals, For R R Identity laska DMV must electronically verify documents to determine validity and status before Issuance of an ID / Driver License Driver / ID an of Issuance before status and validity determine to documents verify electronically must DMV laska Name / Date of Birth of Date / Name pplying for an an Alaska pplying for www.Alaska.gov/DMV R D RA A A A A T A A A RA R A D A A D R A A License, Permit or ID Card? D            The A

240 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Winter 2020 Council Meeting Calendar

Winter 2020 Regional Advisory Council Meeting Calendar

Due to travel budget limitations placed by Department of the Interior on the U.S. Fish and Wildlife Service and the Office of Subsistence Management, the dates and locations of these meetings will be subject to change. Sunday Monday Tuesday Wednesday Thursday Friday Saturday

Feb. 2 Feb. 3 Feb. 4 Feb. 5 Feb. 6 Feb. 7 Feb. 8

Window BB — Naknek Opens

Feb. 9 Feb. 10 Feb. 11 Feb. 12 Feb. 13 Feb. 14 Feb. 15 YKD — Bethel

WI — Fairbanks

Feb. 16 Feb. 17 Feb. 18 Feb. 19 Feb. 20 Feb. 21 Feb. 22

NS — Utqiaġvik PRESIDENT’S DAY NWA — Kotzebue HOLIDAY

Feb. 23 Feb. 24 Feb. 25 Feb. 26 Feb. 27 Feb. 28 Feb. 29 SE — Petersburg

KA — Kodiak

Mar. 1 Mar. 2 Mar. 3 Mar. 4 Mar. 5 Mar. 6 Mar. 7 EI — Fairbanks SC — Anchorage

Mar. 8 Mar. 9 Mar. 10 Mar. 11 Mar. 12 Mar. 13 Mar. 14

SP — Nome Window Closes

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 241 Fall 2020 Council Meeting Calendar

Fall 2020 Regional Advisory Council Meeting Calendar

Due to travel budget limitations placed by Department of the Interior on the U.S. Fish and Wildlife Service and the Office of Subsistence Management, the dates and locations of these meetings will be subject to change.

Sunday Monday Tuesday Wednesday Thursday Friday Saturday

Aug. 16 Aug. 17 Aug. 18 Aug. 19 Aug. 20 Aug. 21 Aug. 22 Window opens Aug. 23 Aug. 24 Aug. 25 Aug. 26 Aug. 27 Aug. 28 Aug. 29

Aug. 30 Aug. 31 Sep. 1 Sep. 2 Sep. 3 Sep. 4 Sep. 5

Sep. 6 Sep. 7 Sep. 8 Sep. 9 Sep. 10 Sep. 11 Sep. 12 LABOR DAY HOLIDAY Sep. 13 Sep. 14 Sep. 15 Sep. 16 Sep. 17 Sep. 18 Sep. 19

Sep. 20 Sep. 21 Sep. 22 Sep. 23 Sep. 24 Sep. 25 Sep. 26

Sep. 27 Sep. 28 Sep. 29 Sep. 30 Oct. 1 Oct. 2 Oct. 3

Oct. 4 Oct. 5 Oct. 6 Oct. 7 Oct. 8 Oct. 9 Oct. 10

Oct. 11 Oct. 12 Oct. 13 Oct. 14 Oct. 15 Oct. 16 Oct. 17 COLUMBUS DAY HOLIDAY Oct. 18 Oct. 19 Oct. 20 Oct. 21 Oct. 22 Oct. 23 Oct. 24

Oct. 25 Oct. 26 Oct. 27 Oct. 28 Oct. 29 Oct. 30 Oct. 31

Nov. 1 Nov. 2 Nov. 3 Nov. 4 Nov. 5 Nov. 6 Nov. 7 Window closes

242 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Federal Subsistence Board Subsistence Regional Advisory Council Correspondence Policy Subsistence Regional Advisory Council Correspondence Policy

The Federal Subsistence Board (Board) recognizes the value of the Regional Advisory Councils' role in the Federal Subsistence Management Program. The Board realizes that the Councils must interact with fish and wildlife resource agencies, organizations, and the public as part of their official duties, and that this interaction may include correspondence. Since the beginning of the Federal Subsistence Program, Regional Advisory Councils have prepared correspondence to entities other than the Board. Informally, Councils were asked to provide drafts of correspondence to the Office of Subsistence Management (OSM) for review prior to mailing. Recently, the Board was asked to clarify its position regarding Council correspondence. This policy is intended to formalize guidance from the Board to the Regional Advisory Councils in preparing correspondence.

The Board is mindful of its obligation to provide the Regional Advisory Councils with clear operating guidelines and policies, and has approved the correspondence policy set out below. The intent of the Regional Advisory Council correspondence policy is to ensure that Councils are able to correspond appropriately with other entities. In addition, the correspondence policy will assist Councils in directing their concerns to others most effectively and forestall any breach of department policy.

The Alaska National Interest Lands Conservation Act, Title VIII required the creation of Alaska's Subsistence Regional Advisory Councils to serve as advisors to the Secretary of the Interior and the Secretary of Agriculture and to provide meaningful local participation in the management of fish and wildlife resources on Federal public lands. Within the framework of Title VIII and the Federal Advisory Committee Act, Congress assigned specific powers and duties to the Regional Advisory Councils. These are also reflected in the Councils' charters. (Reference: ANILCA Title VIII §805, §808, and §810; Implementing regulations for Title VIII, 50 CFR 100 _.11 and 36 CFR 242 _.11; Implementing regulations for FACA, 41 CFR Part 102- 3.70 and 3.75)

The Secretaries of Interior and Agriculture created the Federal Subsistence Board and delegated to it the responsibility for managing fish and wildlife resources on Federal public lands. The Board was also given the duty of establishing rules and procedures for the operation of the Regional Advisory Councils. The Office of Subsistence Management was established within the Federal Subsistence Management Program's lead agency, the U.S. Fish and Wildlife Service, to administer the Program. (Reference: 36 CFR Part 242 and 50 CFR Part 100 Subparts C and D)

Policy

1. The subject matter of Council correspondence shall be limited to matters over which the Council has authority under §805(a)(3), §808, §810 of Title VIII, Subpart B §___.11(c) of regulation, and as described in the Council charters.

2. Councils may, and are encouraged to, correspond directly with the Board. The Councils are advisors to the Board.

3. Councils are urged to also make use of the annual report process to bring matters to the Board’s attention.

1 6/15/04 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 243 Federal Subsistence Board Subsistence Regional Advisory Council Correspondence Policy

4. As a general rule, Councils discuss and agree upon proposed correspondence during a public meeting. Occasionally, a Council chair may be requested to write a letter when it is not feasible to wait until a public Council meeting. In such cases, the content of the letter shall be limited to the known position of the Council as discussed in previous Council meetings.

5. Except as noted in Items 6, 7, and 8 of this policy, Councils will transmit all correspondence to the Assistant Regional Director (ARD) of OSM for review prior to mailing. This includes, but is not limited to, letters of support, resolutions, letters offering comment or recommendations, and any other correspondence to any government agency or any tribal or private organization or individual. a. Recognizing that such correspondence is the result of an official Council action and may be urgent, the ARD will respond in a timely manner. b. Modifications identified as necessary by the ARD will be discussed with the Council chair. Councils will make the modifications before sending out the correspondence.

6. Councils may submit written comments requested by Federal land management agencies under ANILCA §810 or requested by regional Subsistence Resource Commissions (SRC) under §808 directly to the requesting agency. Section 808 correspondence includes comments and information solicited by the SRCs and notification of appointment by the Council to an SRC.

7. Councils may submit proposed regulatory changes or written comments regarding proposed regulatory changes affecting subsistence uses within their regions to the Alaska Board of Fisheries or the Alaska Board of Game directly. A copy of any comments or proposals will be forwarded to the ARD when the original is submitted.

8. Administrative correspondence such as letters of appreciation, requests for agency reports at Council meetings, and cover letters for meeting agendas will go through the Council’s regional coordinator to the appropriate OSM division chief for review.

9. Councils will submit copies of all correspondence generated by and received by them to OSM to be filed in the administrative record system.

10. Except as noted in Items 6, 7, and 8, Councils or individual Council members acting on behalf of or as representative of the Council may not, through correspondence or any other means of communication, attempt to persuade any elected or appointed political officials, any government agency, or any tribal or private organization or individual to take a particular action on an issue. This does not prohibit Council members from acting in their capacity as private citizens or through other organizations with which they are affiliated.

Approved by the Federal Subsistence Board on June 15, 2004.

2 6/15/04 244 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Region 9 – Eastern Interior Alaska Region Map

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Houston Palmer Federal Public Lands Open to Subsistence Use Susitna Region 9 Unit Boundaries NPS Administered Preserves Knik Special Use Areas USFWS Administered Lands Big LakeEastern Interior Region F Eklutna Closed to Subsistence BLM Administered Lands Miles Valdez Created by OSM: 10/3/2017 NPS Administered Parks USFS Administered Lands For reference purposes only. Not to be used for navigation. Anchorage0 50 100 6D Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 245 Council Charter

Department of the Interior U. S. Fish and Wildlife Service

EasternInterior Alaska Subsistence RegionalAdvisory Council

Charter

I. Committee's Official Designation. The Council's officialdesignatio n is the Eastern Interior Alaska Subsistence Regional Advisory Council (Council).

2-. Authority. The Council is renewed by virtueof the authority set out in the Alaska National Interest Lands ConservationAct (ANILCA) (16 U.S.C. 3115 (1988)), andunder the authority of the Secretaryof the Interior, in furtherance of 16 U.S.C. 410hh-2. The Council is regulatedby the FederalAd visory CommitteeAct (FACA), as amended, 5 U.S.C. Appendix 2.

3. Objectives and Scope of Activities. The objective of the Council is to provide a forum forthe residentsof the Region with personal knowledge of local conditions and resource requirementsto have a meaningfulrole in the subsistence management of fishand wildlifeon Federal lands andwa ters in the Region.

4. Descriptio,n of Duties. Council duties andresponsibilities, where applicable, areas follows:

a. Recommend the initiation of, review, and evaluate proposals forregulations, policies, management plans,and othermatters relating to subsistence uses of fish andwildlife on public lands withinthe Region.

b. Provide a forumfor the expression of opinions andrecommendations by persons interested in any matterrelated to thesubsistence uses of fish and wildlife on public lands withinthe Region.

c. Encouragelocal andregional participation in the decision-makingprocess affectingthe taking of fishand wildlife on the public landswithin the Region for subsistence uses.

d. Preparean annual report to the Secretarycontaining the following:

(1) An identificationof current and anticipatedsubsistence uses offish and wildlife populations withinthe Region.

(2) An evaluation of currentand anticipated subsistence needs forfish and wildlifepopulations within the Region.

246 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Council Charter

(3) A recommended strategy for the management offish and wildlife populations within the Region to accommodate such subsislence uses and needs.

(4) Recommendations concerning policies, standards, guidelines, and r egul ations to implement the s trat egy.

I e. Appoinl one member to the Wrangell-St. Elias National Park Subsistence Resource Commission and one member to the Denali National Park S u b s i s t enc Resource Commission in accordance with Section808 of the ANILCA. f. Make recommendations on determinations of customary and traditional useof subsistence resources. g. Make recommendations o n de te rmina tion s ruralof status. h. Provide recommendations o n the establishment and membership of Federal local advisory committees.

i. Provide recommendations for implementation of S e cr e tar y' s Order 3347: Conservation Stewardship and Outdoor Recreation, and Secretary's Order 3356: Hunting, F i s hi n g , Recreational Shooting, and Wildlife Conservation Opportunities and Coordination with States, Tribes, andTerritories. Recommendations shall include, but are not limited to:

(1) Assessing and quantifying implementation of the Secretary's Orders, and recommendations to enhance and expand their implementation as identified;

(2) Policies and programs that:

(a) increase outdoor recreation opportunities for all Americans, with afocus on engaging youth, veterans, minorities, and other communities that traditionally have low participation in outdoor recreation;

(b) expand access for hunting and fishing on Bureau of Land Management, U.S. Fish and Wild1ife Service, and National Park Service )ands in a manner that respects the rights and privacy of the owners of non-public lands;

(c) increase energy, transmission, infrastructure, or other relevant projects while avoiding or minimizing potential negative impacts o n wildlife; and

(d) create greater collaboration wi t h states, tribes, and/or territories. -2-

Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 247 Council Charter

j. Provide recommendations for implementation of the regulatory reforminitiatives and policies specifiedin section 2 of Executive Order 13777: Reducing ReguJation and Controlling Regulatory Costs; Executive Order 12866: Regulatory Planning andReview, as amended; and section 6 of Executive Order 13563: Improving Regulation andRegulatory Review. Recommendations shall include, but arenot limited to:

Identifying regulations for repeal, replacement, or modification considering, at a minimum, those regulations that:

( l) eliminate jobs, or inhibit job creation;

(2) areoutdated, unnecessary, or ineffective;

(3) impose costs that exceed benefits;

(4) create a serious inconsistency or otherwise interferewith regulatory reformin itiative andpolicies;

(5) rely, in part or in whole, on data or methods thatare not publicly available or insufficiently transparent to meet the standard for reproducibility; or

(6) derive fromor implement Executive Orders or other Presidential and Secretarial directives that have been subsequently rescinded or substantially modified.

At theconclusion of each meeting or shortly thereafter,provide a detailed recommendation meeting report, including meeting minutes, to the Designated Federal Officer (DFO).

5. Agency or Official toWhom the Council Reports. The Council reports to the Federal Subsistence Board Chair, who is appointed by the Secretary of the Interior with the concurrenceof the Secretaryof Agriculture.

6. Support. The U.S. Fish and WildlifeService will provide administrative support forthe activities of theCouncil through the Officeof Subsistence Management.

7. Estimated Annual Operating Costs and Staff\'ears. The annual operating costs associated with supporting the Council's functions are estimated to be $175,000, including all direct and indirect expenses and 1.15 staffyears.

8. Designated Federal Officer. The DFO is the Subsistence Council Coordinator forthe Region or such other Federal employee as may be designated by the Assistant Regional Director-Subsistence, Region 7, U.S. Fish and Wildlife Service. The DFO is a full-time Federal employee appointed in accordance with Agency procedures. The DFO will:

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248 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting Council Charter

(a) Approve or call all of the advisory committee's and subcommittees' meetings;

(b) Prepare and approve all meeting agendas;

( c) Attend all committee and subcommittee meetings;

{d) Adjourn any meeting when the DFO determines adjournment to be in the public interest; and

(e) Chair meetings when directed to do s o by the official to whom the advisory committee reports.

9. Estimated Number and Frequency of Meetings. The Council will meet 1-2 times per year, and at such times as designated by the Federal Subsistence Board Chair or the DFO.

10. Duration. Continuing.

11. Termination. The Council will be inactive 2 years from the date the Charter is filed, unless, prior to that date, it is rene wed in accordance with the provisions of section 14 of the F ACA. The Council will not meet or take any action without a valid current charter.

12. Membership and Designation. T h e Cowicil's membership is composed of representative members as follows:

Ten members who arc knowledgeable and experienced in matters relating to subsistence uses of fish and wildlife and who are residents of the Region represented by the Council.

To ensure that each Cowicil represents a diversity of interests, the Federal Subsistence Board in their nomination recommendations to the Secretary will strive to ensure that seven of the members (70 percent) represent subsistence interests within the Region and three of the members (30 percent) represent commercial and sport interests within the Region. The portion of membership representing commercial and sport interests must include, where possible, at least one representative from the sport community and one representative from the commercial community.

The Secretary of the Interior will appoint members based on the recommendations from the Federal Subsistence Board and with the concurrence of the Secretary of Agriculture.

Members will be appointed for 3 -y e ar terms. A vacancy on the Council will be filled in the same manner in which the original appointment was made. Members serve atthe discretion of the Secretary.

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Eastern Interior Alaska Subsistence Regional Advisory Council Meeting 249 Council Charter

Council memberswill elect a Chair, Vice-Chair, andSecretary for a 1-year term. Members of the CounciJ will servewithout compensation. However,while away from theirhomes or regular places of business, Council andsubcommittee members engaged in Council, or subcommittee business,approved by the DFO, may be allowedtravel expenses, including per diem in lieu of subsistence, in the samemanner as persons employed intermittentlyin Governmentservice under section5 703 of title 5 of the United States Code.

13. Ethics Responsibilities of Members. No Council or subcommittee member will participatein any Council or subcommittee deliberationsor votes relating to a specific party matterbefore the Department or its bureausand officesincluding a lease,license, permit,contract, grant, claim, agreement, or litigation in which the member or the entity the member represents has a direct financial interest.

14. Subcommittees. Subject to the DFOs approval, subcommitteesmay be formedfor the pwposeof compiling information and conducting research. However, such subcommitteesmust act only under the direction of the DFO and must report their recommendationsto the fullCouncil forconsideration. Subcommitteesmust not provide advice or work products directlyto the Agency. Subcommittees wiU meet as necessary to accomplish their assignments, subject to the approvalof the DFO and the availability of resources.

15. Recordkeeping. Records of the Council,and formallyand informally established subcommitteesor other subgroups of the Council, shall behandled in accordance with GeneralRecords Schedule6.2, andother approved Agency recordsdisposition schedule. These records shall be available forpublic inspection and copying, subject to the Freedom oflnfonnationAct, 5 U.S.C. 552.

DEC O 1 2017

Date Signed DECO 4 2017 Date Filed

250 Eastern Interior Alaska Subsistence Regional Advisory Council Meeting

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