MANAGING ALASKA'S SUBSISTENCE PROGRAM, 1985-1989 (continued)
C. Managing Subsistence Activities on Alaska's Parklands
During the fifteen-month period between the Madison decision and its resolution by the Alaska legislature, the NPS's presence as it pertained to subsistence questions consisted of one full-time staff person in the Alaska Regional Office, staff in the various Alaska parks who worked on subsistence issues, and the various Alaska subsistence resource commission (SRC) members. Lou Waller, variously known as the subsistence coordinator or the subsistence liaison, was the only agency staff person who worked on subsistence issues on a full-time basis. Working with Waller in Anchorage was Associate Regional Director Michael V. Finley. In the parks, the agency relied on an informal staff networkprimarily superintendents, but also rangers or management assistantswho worked on subsistence issues on an intermittent, ad hoc basis (see Appendix 3).  Providing advice to the NPS staff presence were the various members of the subsistence resource commissions, nine members for each of seven SRCs.
As noted in Chapter 5, the NPS held a series of initial SRC meetings in April and May of 1984; all attracted a quorum except the Aniakchak meeting. At these meetings, NPS officials instructed the various SRC membersin accordance with Section 808 of ANILCAthat their primary duty would be to "devise and recommend to the Secretary [of the Interior] and the Governor a program for subsistence hunting within the park or park monument."
ANILCA, however, gave few specifics about the subsistence hunting program and it provided few additional details about the SRC's role, a fact that was frankly addressed in the various introductory meetings. At the May 3 meeting, for example, Commission members were told that the commissions were "totally unique to the Park Service and the country" and that they
Commission members were to have broad latitude on what they recommended to the Interior Secretary. Aniakchak SRC members, for example, were told that their hunting plan recommendations should be made "as a result of their own independent judgement. They should not be influenced by the appointing agency." And commission members for park units in northern Alaska were similarly instructed that they "shall not be influenced by the appointing authority or by any special interest but will be the result of the Commission's independent judgments." Members were cautioned, however, that the road ahead would not be easy; as one SRC heard it, "it will take time to understand all the rules and regulations the Commission has to operate under." 
Once the hoopla from the first meeting subsided, however, the different SRCs began to express themselves in strikingly different ways. NPS officials were well aware that subsistence activities were greater at some park units than at others; as Table 6-1 (following page) suggests, the potential for subsistence use at Wrangell-St. Elias and the northwestern park units appeared far greater than at Lake Clark, Aniakchak, and the newly-expanded portions of Denali National Park.  The charter of the various SRCs stated that each "meets approximately twice a year or as often as circumstances require." But some SRC members, inevitably, chose to be more participatory than others (see Appendix 5); the Gates of the Arctic and Cape Krusenstern SRCs, for example, held three meetings in 1984, while the Aniakchak SRC met just once. Most SRCs, moreover, experienced a dropoff in interest after their initial meeting, and several follow-up meetings either lacked a quorum or were cancelled prior to their scheduled date.
Table 6-1. Population of Resident Zone Communities for Alaska National Park Units, 1970-2000
Note: Italics indicate resident zone communities for more than one national park unit. The population of these four communities has been counted just once in the statewide total. Population figures are not available for all communities.
Sources: U.S. Census, Number of Inhabitants - Alaska, 1970; Alaska Department of Labor, Alaska Population Overview, 1990; Census and Estimates, July 1991; U.S. Census web page, May 2001.
In order to guarantee their continuing viability, at least one SRC toyed with the idea of lowering its meeting quorum from six to four.  Others floated the idea of having alternate members. The NPS, however, disallowed that option. Instead, SRCs adopted a proxy system; members who knew that they would be unable to attend a meeting made it known that another member (usually the SRC chair) would be able to vote in their stead.  Another method that made it easier to organize a quorum was a change in the various SRC charters, suggested at the March 1986 Gates of the Arctic SRC meeting. The SRC formulated a resolution stating that "a member's three year term should continue until the member resigns, or is removed by the appointment source, or is either reappointed or replaced by a new appointee." The change, finalized in November 1986, made it possible for members who wished to continue their involvement to remain on an SRC after their designated term was over.  Thanks to Gates of the Arctic's resolution, the need to rely on a proxy system proved mercifully brief, and after 1986, most SRCs had little trouble mustering up a quorum. But not all. The Aniakchak SRC, for example, made repeated attempts to meet after March 1985; each attempt, however, resulted in either the lack of a quorum or a cancelled meeting date.
Immediately after the various SRCs' initial meetings, work began on considering recommendations for a subsistence hunting plan. One of the first questions that the SRCs considered was the role of these recommendations in various evolving general management plans (GMPs). The NPS, at the time, was compiling draft GMPs for each of the parks that had been established or expanded by ANILCA. (Section 1301 of the act demanded that "a conservation and management plan" for each park unit be completed "within five years from the date of enactment of this Act.") NPS staff, moreover, told the various SRC members that any recommendations they made would be included in the subsistence sections of the various GMPs. 
The SRCs' opportunity to influence the general management planning process, however, was more apparent than real. At Lake Clark National Park and Preserve, for example, the GMP planning process by May 1984 was already so far along that the park's SRC had no substantive opportunity to influence the final GMP, which was published just three months later.  As for the other ANILCA park units, the draft GMPs were issued in March 1985. That same month, the first SRCs passed suggested hunting plan resolutions. Because an extensive public comment period followed the issuance of the various draft GMPs, SRC members were hopeful that these and other resolutions would be considered and perhaps implemented as part of that public comment period.
Such hopes, however, proved overly optimistic. There was, as expected, a public comment period between the issuance of the draft GMPs (in March 1985) and the revised draft GMPs (in December 1985), and the public was given another opportunity to provide comments prior to the December 1986 issuance of the final GMPs.  Two factors, however, effectively prevented the SRCs' recommendations from being incorporated into the various GMPs. First, the SRCsprimarily because of the attendance problems cited abovewere often slow to formulate subsistence recommendations; just one SRC passed recommendations during 1984, and by August 1985 only four others had done so.  A more important factor that delayed the hunting plan recommendation process was a belated recognition that a public process was required before any such plans could be implemented. That process demanded input from local residents, the State of Alaska, and the Interior Secretary, and written approval of the Interior Secretary had to be obtained before an SRC recommendation could be incorporated into a park's GMP.
Because virtually everyone involvedNPS staff, SRC members, and other interested partieswas unaware at the outset that the approval of hunting plan recommendations would be such a time-consuming process, the agency's inability to immediately incorporate the SRCs' recommendations into the developing GMPs produced some of the first conflicts on the SRCs. The Alaska Federation of Natives' Janie Leask, for example, made the following complaint to the NPS in August 1985:
The Wrangell-St. Elias SRC, in an August 1985 resolution, echoed the AFN's statement; it recommended that the comment period for the park's draft GMP be extended "until the subsistence management plan has been submitted and accepted by the Secretary of Interior."  But the NPS, which was under severe pressure to meet the December 1985 deadline outlined in Section 1301 of ANILCA, rejected such an extension. Instead, it beefed up the verbiage in the December 1985 drafts regarding subsistencethe March 1985 draft GMPs for both the Denali and the Wrangell-St. Elias units had failed to address subsistence in a subsistence sectionand the agency stated that it intended, at some future date, to complete a subsistence management plan for each park unit. This promise was reiterated in each of the final GMPs that was issued in December 1986. 
Another problem that both the SRCs and NPS staff faced during the planning process that preceded the issuance of the final GMPs was what specifically the SRCs should produce. Section 808 of ANILCA stated that the various SRCs were to "devise and recommend ... a subsistence hunting program," but it gave no real direction regarding what that program should contain. Left to their own devices, the various SRCs passed a series of resolutions that were applicable to the users, use patterns and needs at each park unit, but there was no consistency or comparability between the themes that these resolutions addressed.
Recognizing that Congress's instructions were vague at best, the Gates of the Arctic SRC in November 1984 stated that their park's hunting plan componentsall of which the SRC "would like to see in the GMP"should encompass some thirty subject areas. The Gates of the Arctic SRC, perhaps the most active of the seven similarly-constituted bodies, passed a January 1986 resolution stating that the SRCnot the NPSshould write the park's subsistence management plan.  NPS officials rebuked that notion and wrote their own seven-page "subsistence use management" section in the final (December 1986) Gates of the Arctic GMP. Regarding the other ANILCA parks, NPS officials kept a hands-off attitude (as they promised they would do) regarding which subjects the SRCs should address in their hunting plan recommendations, and the agency provided little policy direction in this area. As a result, some SRCs' "hunting programs" were limited to just one or two resolutions, while the most active SRC, for Gates of the Arctic, passed twenty-four resolutions.
As noted above, Section 808 of ANILCA required that all SRC resolutions be subject to a public comment period before being submitted to the Secretary of the Interior for approval. During the comment period, which typically lasted several months, the resolution was presented to local advisory committees, subsistence regional advisory councils, State of Alaska officials, and to the general public. NPS staff also worked in an advisory capacity with the various SRCs and encouraged them to submit broadly-defined hunting plan recommendations (which needed to be directed to the Interior Secretary) instead of recommendations in a diversity of other subject areas (that were primarily intended for NPS staff). Because of this process, the first SRC recommendations were not forwarded to the Interior Secretary until mid-March 1986.  The various SRCs, in coordination with NPS staff, continued to submit hunting plan recommendations for the next eighteen months. By September 1987, five of the seven SRCs had submitted formal recommendations:  Aniakchak had sent five recommendations (four in 1986, one in 1987), Denali had sent three recommendations (all in 1986), Gates of the Arctic seven (all in 1987), Lake Clark one (in 1986), and Wrangell-St. Elias four (three in 1986, one in 1987). 
According to Section 808 of ANILCA, all recommendations emanating from the various SRCs were to be responded to by either the Interior Secretary or his designated appointee; NPS officials could not serve as signatories. That separation between the SRCs and the NPS, however, was more apparent than real, because Alaska-based NPS personnel were in a far better position to evaluate the technical merits of the various SRC recommendations than Interior Department bureaucrats in Washington, D.C. Moreover, it was Alaska Regional Office personnelspecifically Lou Waller, the region's subsistence coordinatorwho organized the NPS response to each recommendation. Working in concert with the various park superintendents and the regional director, Waller compiled the various agency responses, then forwarded them to Interior Department officials in Washington. Officials in the office of Interior Secretary Donald P. Hodel spent several months mulling over the recommendations; between March and May 1988, they responded to those recommendations.  The responses that were finalized in March 1988 were signed by William P. Horn, who served as the Assistant Secretary for Fish and Wildlife and Parks; responses finalized in April or May were signed by Susan Reece, who served in an acting capacity for Assistant Secretary Horn. 
In order to provide proper deference to the SRCs' efforts, Section 808 of ANILCA stated that the Interior Secretary was obligated to accept each SRC recommendation
Such a stipulation might suggest that many if not most of the SRCs' recommendations would be accepted by the Interior Secretary without modification. Such, however, was not the case. In fact, the Interior Secretary accepted without question a fairly small proportion of the recommendations he received; he either partially accepted, or accepted in modified form, a number of other recommendations; and he rejected many others, either because of their perceived irrelevance to a "subsistence hunting program" or because they were in direct contradiction to federal laws or regulations. The Interior Department, in most if not all cases, maintained a "strict constructionist" interpretation of subsistence laws and regulations; that is, it was likely to approve of any SRC actions that voluntarily limited subsistence activity (either the number of species, its means of access, or its geographical extent), but it took a dim view of any proposals that condoned a real or perceived expansion of subsistence activity. A specific analysis of the various recommendations, and the Interior Department's responses to them, is included below.
Last Updated: 14-Mar-2003