NPS SUBSISTENCE MANAGEMENT ACTIVITIES, 1990-PRESENT (continued)
J. Wildlife Management Issues
As noted in Chapter 6, the various park SRCs during the 1980s played a minimal role in making wildlife-allocation decisions. When the SRCs met for the first time in the spring of 1984, NPS officials told several SRCs that they could either recommend changes to the state subsistence hunting regulations (on seasons and bag limits or methods and means of harvesting), or they could comment on wildlife management proposals affecting the park areas. But as the decade wore on, the lack of support that the NPS provided to the SRCs made it difficult to have members provide regular advice on wildlife allocation questions, and when the Gates of the Arctic SRC, in 1986, recommended that it be a "sounding board" for NPS recommendations and proposals, the Interior Secretary replied that it was "not practicable" to use the Commission in that capacity. Perhaps as a result, almost the only specific wildlife management actions that SRCs made during the 1980s were occasional protests against the Alaska Game Board's negative C&T determinations. (As noted in Chapter 6, above, and in Section M, below, Denali was the only SRC to file any such protests.) During this period, most specific wildlife proposals that affected NPS lands were either proposed or supported by agency officials.
A meeting of the SRC chairs in December 1989, however, apparently resulted in a change of attitudeby both subsistence users and federal regulators. Just a month later, a Gates of the Arctic SRC member asked chairman Raymond Paneak "if there was a consensus on what is a hunting plan" and Paneak, who had discussed the issue at the chairs' meeting, replied that "there was no clear answer." Members were also well aware that their recent hunting plan recommendations to the Interior Secretary had taken fourteen months for a response. On the heels of those discussions, member Bill Fickus recommended that the subsistence moose hunt in the Wiseman area be moved from December to November. Superintendent Roger Siglin, in response, perhaps surprised those in attendance by saying he "thought that such a suggestion may be more readily responded to by the [state] Game Board rather than being addressed in the hunting plan," and the SRC decided to assemble information on the proposal for the upcoming Game Board meeting. 
The federal assumption of authority over subsistence wildlife management on federal lands, which took place on July 1, 1990, had the practical effect of shifting subsistence decision making from the state Game Board to the newly-created Federal Subsistence Board. Before long, several SRCs considered wildlife management issues. At a May 1991 SRC meeting, Gates of the Arctic Superintendent Siglin encouraged his park's SRC to become more involved:
Later at the same meeting, Stan Leaphart, head of the Citizens' Advisory Commission on Federal Areas, agreed with Siglin but became more specific. As paraphrased, he noted that the Park Service and the Federal Subsistence Board had an opportunity to outline a role for the Subsistence Resource Commission in the review and development of the annually-revised regulations. Leaphart thought that it would be appropriate to draw a more formal mechanism for putting the proposed regulations in front of the Subsistence Resource Commission so that they could respond to them in a timely fashion. He suggested that the commission make such a recommendation to the Secretary.
Immediately afterward, NPS subsistence specialist Clarence Summers chimed in; he added that "nothing prevents the subsistence resource commission from making recommendations on methods and means, seasons and bag limits." Given that newly-conferred role, the SRC quickly generated three resolutions (a moose proposal and two brown bear proposals) for submittal to the Federal Subsistence Board and approved all three by unanimous votes.  To be valid, the proposals needed to be presented to the board by May 16; NPS staff, however, let the proposal "slip through the cracks." The error was not discovered until SRC members asked about the proposals at the September 1991 SRC meeting. SRC members, upon hearing of the snafu, merely asked the NPS Subsistence Coordinator to "make sure that commission recommendations get to the board." Five months later, the SRC passed a resolution in which it expressed its approval of four different board proposals. 
Other SRCs got involved, too. In November 1991, Wrangell-St. Elias SRC member John Vale asked Summers, "Can we make proposals to the Federal Subsistence Board about seasons and bag limits?" Summers replied that "If the SRC feels it is important to make proposals to the FSB, then you should go ahead and do it." Jay Wells of the park staff agreed, and shortly afterward the SRC voted to submit a wildlife recommendation to the board. (Regional Director Morehead had made it known that he supported the SRC's move.) Hoping to become a more prominent part of the advisory process, the SRC made two actions. First, it sent the board a note asking the NPS to consult with the SRC before it submitted any proposals to the board. In addition, the SRC proposed that its charter be changed "to authorize travel to Federal Board meetings regarding subsistence hunting plan/season or bag limits on park lands." The measure passed unanimously, and a letter to that effect was sent to Interior Secretary Manuel Lujan, Jr. The Secretary, however, squelched the idea. Taking a narrow view, he noted that while "I understand the importance of seasons and bag limits to subsistence users of park areas ... representation [of SRCs at board meetings] is unnecessary [because of the] unique, interlocking system of representation" between the Interior Secretary, the SRCs and the state-sponsored regional advisory councils. Lujan, therefore, may have had no problem with the SRCs either generating, or commenting upon, specific Federal Subsistence Board proposals. He seemed unwilling, however, to sanction any economic subsidy that might encourage the SRCs' participation in the proposal process. That unwillingness set him apart from at least some NPS regional and park officials. 
In 1992, more SRCs became involved with specific wildlife proposals. In late March, the Aniakchak SRC passed a draft hunting plan recommendation for an extended moose-hunting season, and two months later, the Denali SRC passed a similar recommendation (which also called for a modification of the moose hunting season). That year the Lake Clark SRC did not propound any of its own proposals; it did, however, review various proposed board regulations for the upcoming (1992-1993) season.  That fall, an NPS officials told the Aniakchak SRC that "the Regional Director wants us to make sure [that the] Commission is aware of proposals that NPS makes" because proposals with joint SRC-NPS sponsorship had a greater chance of passage at the board than proposals with just a single sponsor. (The commission, in response, wrote a letter of support to the board; the specific NPS proposal dealt with caribou harvesting in and near the monument.)  The NPS, by this time, appeared to be clearly advocating an increased role for the SRCs in the annual hunting-regulations revision process.
During the next two years, few SRCs took an active part in the revision of wildlife management regulations. But despite this lull in activity, a key change took place in the federal government's attitude toward SRCs. In June 1993 the Denali SRC made further actions on its moose-season proposal, and that October it forwarded its proposal to the Interior Secretary. But this time, the Secretary's office did not reject the SRC's proposal out of hand, as in 1992; instead, it "direct[ed] the NPS to investigate the biological ramifications of the additional hunting season on the moose population ... and the customary and traditional basis of any possible late fall moose hunt in the area." The NPS was to present a report on the matter to the Federal Subsistence Board "as soon as possible." The Interior Secretary, at long last, acted much as the Game Board would have acted in a similar situation; it quickly responded to the SRC's proposal and demanded a brief study that included both biological and anthropological viewpoints.  Denali, however, was virtually the only SRC during this period that was active in the wildlife-management arena. It may be recalled (from Chapter 7) that there were no regional advisory councils (at either the state or federal levels) between June 1992 and September 1993, and during the winter of 1993-94, the ten federally-charted regional advisory councils were just getting started. Given 1) the lack of a regional advisory network, 2) the fact that the federal board was largely unaware of the SRCs' role and expertise, and 3) the fact that recommendations to the Interior Secretary were simply redirected back to the federal board, there was little encouragement for the SRCs to advance wildlife management proposals to either the Interior Secretary or to the Federal Subsistence Board.
By the winter of 1994-1995 (see Appendix 2), the various regional advisory councils had gained a year's experience, and the SRCs recognized the propriety of forwarding comments on federal wildlife management recommendations to the appropriate regional advisory councils. The Denali and Gates of the Arctic SRCs, and perhaps others as well, played an active role in the newly-evolving system that winter, and within a year the other active SRCs were taking part as well. 
In February 1996, the Wrangell-St. Elias SRC recognized the practical reality of the new system and asked Interior Secretary Babbitt to amend the various charters so that the SRC would be allowed "to report not only to the park Superintendent, but to the Federal Subsistence Board and the Federal Regional Subsistence Advisory Councils." Park staff backed the plan; they said that the SRC's proposal "is in effect what is happening right now," and further noted that "the FSB and the Regional Councils are very concerned about getting the input of the SRCs before they make decisions...." The agency's Office of Policy, asked to comment on the proposal, recognized that the idea, if approved, should apply to all of the state's SRCs. Its response, however, was cautious; because of language in the Federal Advisory Committee Act, it felt that "there is no basis by which we could have [the SRCs] 'report' to [a regional] council." The NPS's "issues paper," completed in August 1997, urged that the SRC's recommendation be adopted, and the agency's regional director contacted the Secretary's office twice that year in hopes of resolving the matter. The Secretary, however, did not respond to the Commission's recommendation. In lieu of a formal, written response, NPS officials decided instead to informally respond to the Wrangell-St. Elias SRC's request at a subsequent SRC chairs' conference; at that conference, agency officials informally told the assembled chairs that it had approved the SRC's request. All of the SRCs would henceforth have full authority to submit subsistence-related hunting or fishing recommendations to the regional advisory councils; for legal reasons, however, the agency did not feel it necessary to alter any verbiage in the various SRC charters. The various SRC chairs accepted that decision, and the issue has apparently been resolved. 
Last Updated: 14-Mar-2003