Subsistence Is Not “Overreach”: Stand With Rural Alaska and Support the Federal Subsistence Board

Safari Club International Alaska is trying to frame recent Federal Subsistence Board decisions as a fight over “fair access” to hunting. But that framing misses what is actually at stake.

For rural Alaska communities, subsistence is part of a much larger reciprocal relationship among people, animals, fish, lands, waters, habitat, and future generations. Moose are not just units of harvest. They are part of living ecosystems and cultural responsibilities that cannot be separated from food security, community care, and stewardship.

That is why NAEC strongly supports the Federal Subsistence Board’s actions on Wildlife Proposals WP26-31 and WP26-75, and why we oppose efforts to overturn them.

SCI Alaska is urging hunters to submit requests for reconsideration asking the Federal Subsistence Board to reverse its recent moose decisions in Game Management Units 13 and 25. Their template claims the Board relied on incorrect information, conflicted with Alaska Department of Fish and Game recommendations, and exceeded the limits of federal law.

NAEC strongly disagrees.

The Federal Subsistence Board acted within its authority under Title VIII of the Alaska National Interest Lands Conservation Act. These actions were not arbitrary. They were not “overreach.” They were grounded in the federal rural subsistence priority, the administrative record, Tribal and Regional Advisory Council support, and documented concerns from rural residents who are struggling to meet subsistence needs.

Now, rural subsistence protections are under attack. We are asking Alaskans to stand with rural communities and support NAEC’s petition urging the Departments of the Interior and Agriculture to reject the State of Alaska’s request for Secretarial review and allow the Federal Subsistence Board’s decisions to stand.

What SCI’s Letter Gets Wrong

SCI’s template says the Board should reverse its decisions because they supposedly relied on incorrect information, conflicted with state recommendations, and exceeded federal law. That framing leaves out the heart of ANILCA.

Title VIII of ANILCA does not protect subsistence only when wildlife populations are in collapse. It protects the continuation of rural subsistence uses. That means federal decision-makers must look beyond broad population numbers and ask whether rural residents can actually access and harvest the animals they rely on for food, culture, household needs, and community sharing.

A moose population can appear stable on paper while rural families still face serious barriers to harvesting food. Competition from non-local hunters, aircraft and riverboat disturbance, displacement from traditional areas, lack of access to equipment and fuel, incomplete harvest reporting, outdated survey data, and the broader food-security crisis caused by salmon declines all matter. That is the reality the Federal Subsistence Board considered.

Science Includes Local Knowledge, Tribal Evidence, and Food Security

SCI says wildlife management should be based on science, not politics. But science and evidence do not stop at population counts.

The record before the Federal Subsistence Board included biological information, harvest information, Tribal input, Regional Advisory Council recommendations, local testimony, and evidence of rural subsistence need. That full record matters.

For WP26-75 in Unit 25D Remainder, the record included evidence that moose density is sparse, that no aerial surveys for moose had been conducted in Unit 25D Remainder since 2015, and that federally qualified subsistence users face difficulty meeting their needs because of low moose numbers and competition from non-federally qualified users.

The record also showed that harvest data are incomplete. Reported harvest numbers do not necessarily show who is harvesting, who is going without, or whether rural families are able to meet their needs.

Local and Tribal support was clear. The Council of Athabascan Tribal Governments supported WP26-75 by resolution. The Eastern Interior Regional Advisory Council supported the original proposal and later unanimously supported a narrower modified version focused on river corridors where conflict was most likely to occur.

That is not politics. That is the federal subsistence process working as it should: listening to affected communities, reviewing the record, and adopting a targeted response.

Competition and Displacement Threaten Rural Subsistence

SCI’s reconsideration template invites people to argue that subsistence needs are being met. But the record shows that many rural users are facing real barriers.

For WP26-75, rural users described outside hunters flying in during the fall, buzzing moose and caribou, camping near local hunters, and interfering with local hunting. They described aircraft activity affecting villages, funerals, and subsistence activities. They explained that this disturbance makes it harder for families to harvest food.

For rural households, this is not abstract. When a family cannot harvest moose in the fall, that affects whether they have meat for winter. When outside competition pushes people out of traditional hunting areas, that affects food security, cultural continuity, and the ability to pass knowledge from one generation to the next.

ANILCA requires the Federal Subsistence Board to consider these impacts.

Unit 13 Shows Why Broad Harvest Numbers Are Not Enough

For WP26-31 in Unit 13, the record included evidence from the Ahtna Intertribal Resource Commission’s Community Harvest System showing that federally qualified users in GMUs 11, 12, and 13 are not meeting customary and traditional moose needs.

In fall 2025, AITRC reported 290 hunter-days by 24 registrants with no successful harvests. AITRC also identified persistent challenges, including access limitations, increased traffic, and competition from non-local and urban hunters.

The Southcentral Regional Advisory Council supported WP26-31 as the home-region Council, citing an extreme level of competition with state users. The record also described cultural harm: when families are pushed out of places they have hunted for generations, it becomes harder to pass along knowledge and traditions.

Those facts directly rebut the claim that “subsistence needs are being met.” Generalized population or harvest numbers cannot tell the whole story. They can mask unequal access, displacement, crowding near access corridors, and the reality that some households are successful while others are left without meat.

Federal Law Prioritizes Rural Subsistence on Federal Public Lands

SCI’s template argues that the Board’s authority is limited and that these restrictions should be rescinded. But ANILCA Title VIII is clear: rural subsistence uses receive a priority on federal public lands.

That priority exists because Congress recognized that rural residents have unique dependence on wild foods and that subsistence is central to culture, food security, and community life.

The Federal Subsistence Board’s actions on WP26-31 and WP26-75 are targeted federal-land measures. They do not close all hunting statewide. They do not erase state management authority. They apply within the federal subsistence framework Congress created.

The State and SCI may disagree with the outcome, but disagreement is not a reason to overturn the Board’s decision.

“Fair Access” Cannot Come at the Expense of Rural Food Security

SCI frames its campaign around “fair access.” But ANILCA does not treat all uses the same on federal public lands. It establishes a rural subsistence priority.

That priority matters most when competition is high, when local hunters are being displaced, and when rural families are struggling to meet food needs.

A national sport-hunting organization should not be given greater weight than the testimony, lived experience, food-security needs, and customary and traditional uses of rural Alaskans.

Federal subsistence decisions must be guided by the rural priority, Tribal consultation, Regional Advisory Council recommendations, the federal trust responsibility, and the administrative record developed from affected communities.

Support NAEC’s Petition

NAEC has submitted a petition opposing the State of Alaska’s request for Secretarial review and urging the Departments of the Interior and Agriculture to allow the Federal Subsistence Board’s actions on WP26-31 and WP26-75 to stand.

We are asking supporters to help counter SCI’s campaign by standing with rural Alaska.

The record supporting the Federal Subsistence Board’s actions includes:

Incomplete harvest data;
Lack of recent survey information for Unit 25D Remainder;
Tribal support for WP26-75;
Eastern Interior Regional Advisory Council support for WP26-75, including unanimous support for the modified proposal;
Evidence of river-corridor conflict, aircraft disturbance, and displacement;
Community testimony that rural users are struggling to meet moose needs;
AITRC evidence that federally qualified users in GMUs 11, 12, and 13 are not meeting customary and traditional moose needs;
Evidence of non-local and urban competition in Unit 13;
Southcentral Regional Advisory Council support for WP26-31 as the home-region Council; and
Evidence that cultural practices and intergenerational subsistence knowledge are being harmed by loss of meaningful harvest opportunity.

That is substantial evidence. It is more than enough to support the Federal Subsistence Board’s actions under ANILCA Title VIII.

Take Action

Please support NAEC’s petition opposing the State of Alaska’s request for Secretarial review and help defend the Federal Subsistence Board’s actions on WP26-31 and WP26-75.

Tell the Office of Subsistence Management: rural subsistence is not overreach. It is law. It is food security. It is culture. And it must be protected.

Support NAEC’s petition:
06.24.2026_Petition-Opposing-the-State-of-Alaskas-Request-for-Secretarial-Review-of-Federal-Subsistence-Board-Actions-on-Wildlife-Proposals-WP26-31-and-WP26-75.pdf

You can also submit comments directly to the Office of Subsistence Management and urge the Departments to deny the State’s request for Secretarial review and allow the Federal Subsistence Board’s decisions to stand.

Email: subsistence@ios.doi.gov
Mail: Office of Subsistence Management, Attn: Subsistence Policy Coordinator, 1011 East Tudor Road, Mail Stop 121, Anchorage, AK 99503-6199