Alaska Subsistence A National Park Service Management History

Notes — Chapter 8

¹ Collins to Lou Waller, October 18, 1990, in DENA SRC files. The only two SRCs that held a legally-binding meeting in 1990 were those representing Gates of the Arctic National Park (which met three times) and Lake Clark National Park (which met once).

² As noted below, the Aniakchak, Denali, Gates of the Arctic, and Wrangell-St. Elias SRCs all sent in hunting plan recommendations that, to a greater or lesser extent, resembled recommendations that had been rejected in 1988. The Interior Secretary, however, did not receive the revised recommendations until 1992 or 1993.

³ Walter Sampson to Boyd Evison, January 15, 1990; David B. Ames to Sampson, February 5, 1990; Frank Stein to Manuel Lujan, March 12, 1991; all in CAKR SRC folder.

⁴ Lou Waller email, December 18, 2000. As noted in Chapter 7, new Subsistence Division employees included John Hiscock, Clarence Summers, and Betty Barlond (all hired in 1989), along with Janis Meldrum and Bob Gerhard (hired in 1991).

⁵ GAAR SRC minutes, January 14, 1998, 3; Shirley L. Lee to "To Whom it May Concern," May 8, 1991, in GAAR SRC folder. The first quote, made at a 1998 meeting, is by Jack Reakoff, who joined the Gates of the Arctic SRC in 1990; he noted that "the NPS has changed for the better since the early days."

⁶ John Vale of the Wrangell-St. Elias SRC complained in March 1991, "Why are we limited to $10,000? [W]e have to meet two times a year to be effective." Raymond Paneak of the Gates of the Arctic SRC, on the other hand, wanted more; he stated in May 1991 that he'd "like to see a commission meeting more than twice a year because the commission doesn't get anywhere with just two meetings." The NPS inexplicably rejected the Wrangell-St. Elias SRC's request, but the NPS's Clarence Summers responded to the Gates of the Arctic request by stating that "the budget allows for another one or two meetings this year." Indeed, Appendix 5 indicates that the Gates of the Arctic SRC—in the 1980s as well as the 1990s—often met three times per year. Beginning in January 1993, moreover, the budget for the Gates SRC—alone among Alaska SRCs—was raised from $10,000 to $25,000 per year. WRST SRC minutes, March 19, 1991, 1; Bill Ellis to Jack Morehead, October 21, 1991; WRST SRC meeting, November 13, 1991, 1; GAAR SRC minutes, May 8, 1991, 20; February 25-26, 1992, 1, 5; GAAR SRC newsletter, February 9, 1993, 1.

⁷ In October 1990, the Denali SRC chair requested an SRC newsletter; that same year, the Gates of the Arctic SRC spoke out in favor of a joint meeting of all seven SRCs. Neither idea was implemented. During the first half of the 1990s, the SRC chairs (despite protests to the contrary) did not meet; and for most SRC members, informal conversations with regional subsistence staff (such as Clarence Summers, who attended SRC meetings throughout Alaska during this period) appears to be the only way in which SRC members heard about other SRCs' activities. For some reason—perhaps it was coordinator Steve Ulvi's involvement—Gates of the Arctic SRC members stayed better informed than other commission members on statewide subsistence issues; they received periodic updates on the actions of the other SRCs, and in July 1992, Ulvi distributed the first of several detailed newsletters to his SRC. Collins to Waller, October 18, 1990; Collins to Clarence Summers, July 9, 1993, both in DENA SRC files; GAAR SRC minutes, January 27, 1990, 6; Raymond Paneak to All Subsistence Resource Commissions, January 31, 1990, in GAAR SRC file; GAAR SRC minutes, May 6, 1992, 6; NPS, GAAR SRC Newsletter, July 22, 1992.

⁸ In the fall of 1991, the Wrangell-St. Elias SRC requested funds to travel to Federal Subsistence Board meetings, and several months later the Denali SRC made an identical request. In both cases, the Interior Secretary rejected the SRC's request, arguing that "such representation is unnecessary because the interest and involvement of the Commission are already reflected in the process" by which SRC members are chosen. Bill Ellis to Manual Lujan, November 14, 1991; Lujan to Ellis, February 21, 1992, both in WRST SRC file; Florence Collins to Lujan, March 9, 1992, 2; Lujan to Collins, May 28, 1992, both in DENA SRC file. Also see ANIA SRC minutes, January 11, 1990, 3.

⁹ Gates of the Arctic SRC member Shirley Lee, who resigned in May 1991, rued that the "NPS ignores and pressures the commission," and that "the NPS has also failed to keep the Commission apprised of its budget." SRC member Delbert Rexford did not resign but stated that he was "deeply disturbed" that the SRC had "limited administrative support" to carry out its charter provisions. Lee to "To Whom it May Concern," May 8, 1991; Rexford to Raymond Paneak, April 15, 1993; both in GAAR SRC files.

¹⁰ Congressional Record, May 2, 1979, E 2014.

¹¹ Public Law 96-487, December 2, 1980, Sec. 801(4), Sec. 802(1), and Sec. 811. Congress made it clear that subsistence users, within proper limits, should be able to utilize new technologies; it thus agreed with Shismaref resident George Olanna who told Congress, "We cannot be limited and restricted into one small world of the past, where hunting was done with spears and total demand of obtaining food and shelter was from the land. We are in a modern world where modern equipment is needed to survive. We cannot be pushed into a living museum where the western culture have created in order to satisfy his ego. It would be like, living in an imaginary western movie." Congressional Record, July 23, 1980, S 9598.

¹² Sen. Ted Stevens press release, October 16, 1990, in "Press Releases thru FY 93" folder, AKSO-RS.

¹³ Lou Waller (December 20, 2000 interview) notes that parks augmented the funds from Stevens' allotment with additional funds that had been authorized for SRC use but not expended. The various SRC charters authorized a $10,000 annual expenditure, but as Appendix 5 notes, several SRCs spent less than their annual allotment.

¹⁴ GAAR SRC minutes, November 14-15, 1990, 10; CAKR SRC minutes, March 12, 1991, 1.

¹⁵ Clarence Summers interview, December 19, 2000; Lou Waller interview, December 20, 2000; Joe Fowler email, January 7, 2001; Jim Hannah interview, January 9, 2001. Individuals who assumed responsibility for park subsistence activities included Susan Savage, ANIA/KATM; Ken Adkisson, BELA; Hollis Twitchell, DENA; Steve Ulvi, GAAR; Lee Fink, LACL; Lois Dalle-Malle, NWAK; Jay Wells, WRST; and Cary Brown, YUCH. Savage, Twitchell, Ulvi, and Dalle-Molle were hired to be subsistence coordinators, Adkisson became a subsistence coordinator after a previous stint as chief ranger, and Fink was hired as a resource management specialist and subsistence coordinator after serving as a local-hire pilot. At WRST, district ranger Jim Hannah incorporated subsistence protection duties into his job. Finally, Mike Sharp was hired as a subsistence ranger pilot under a two-park cooperative agreement; he was located in Yakutat and dealt with subsistence issues both at WRST (Malaspina Forelands) and GLBA (Dry Bay). Superintendents at WRST and YUCH opted to spend their subsistence funds on equipment for the subsistence program; subsistence concerns at these units were handled by existing staff.

¹⁶ Hollis Twitchell was hired as DENA's subsistence specialist in July 1991 (Twitchell to Waller, July 24, 1991, in "Federal Subsistence Permits" folder, AKSO-RS Collection), but Lee Fink (Ralph Tingey interview, December 20, 2000) did not assume LACL's subsistence duties until late 1992. See Chief, Subsistence Division to Subsistence Coordinators, July 24, 1991, in ANIA and DENA SRC folders.

¹⁷ Steve Ulvi and Hollis Twitchell, who began working as park subsistence coordinators in 1991, noted that regional subsistence specialists during this period were dead set against any expansion of subsistence eligibility that was not specified in the regulations. When either suggested a relaxation of eligibility requirements, the regional officials' stock response was, "We think you're giving away the farm." Ulvi interview, April 6, 1999; Twitchell interview, March 22, 1999.

¹⁸ Jennifer A. Salisbury to Bill Ellis, July 14, 1992, in WRST SRC files.

¹⁹ Recommendation #1 reaffirmed the legitimacy of the existing, community-based resident zone system. Recommendation #2 was in two parts; one advocated the legality of subsistence hunters to fly between resident zone communities, while the other supported the recent, four-party agreement regarding ATV use in the Anaktuvuk Pass area. Recommendation #3 asked that "the entire park be generally classified as a traditional use area." GAAR SRC, "Subsistence Hunting Plan," February 25, 1992, in SRC files.

²⁰ Superintendent, GAAR to Chief, Subsistence Division, Alaska Region, May 13, 1992, in GAAR SRC files. The letter, to a large extent, was written by the park's Subsistence Coordinator, Steve Ulvi. The specifics regarding the three issues with which the SRC was concerned are discussed in greater detail later in this chapter.

²¹ Superintendent, GAAR to Regional Director, July 13, 1992, in GAAR SRC files.

²² Jennifer A. Salisbury to Raymond Paneak, December 3, 1992, "SRC Hunting Plan Responses" file, AKSO-RS. As noted later in this chapter, this "proposed regulation" was never implemented.

²³ Superintendent GAAR to Chief, Subsistence Division, December 11, 1992, in GAAR SRC files; Steve Ulvi, email to the author, November 17, 2000. "Subsistence superintendents," as used here, include the superintendents of all park units in which subsistence is a legally-authorized activity.

²⁴ Superintendent GAAR to Chief, Subsistence Division, December 11, 1992, in GAAR SRC files.

²⁵ John Morehead (in an April 23, 2001 interview) indicated that one of the most restive superintendents was Russ Berry (DENA), and several sources have noted that Karen Wade (WRST) was also active in expressing her frustrations with the existing NPS subsistence management system.

²⁶ Hollis Twitchell interview, March 22, 1999; Steve Ulvi interview, April 6, 1999.

²⁷ Alaska Superintendents to Jack Morehead, January 21, 1993, in Paul Anderson files; NPS, Gates of the Arctic SRC Newsletter, February 9, 1993, in GAAR SRC files; John Morehead interview, April 23, 2001.

²⁸ The conference was held at the Holy Spirit Retreat House, in the Upper Hillside section of Anchorage.

²⁹ Steve Ulvi interview, April 17, 2001; Bill Brown interview, April 18, 2001; Paul Anderson interview, April 30, 2001.

³⁰ "Notes — Subsistence Workshop, 3/22-26/93," Ray Bane personal files; Waller to the author, December 20, 2001.

³¹ This statement remained in draft form until April 1997, when it was slightly modified at an NPS subsistence workshop. It emerged as the NPS Subsistence Mission Statement, which was published as part of the August 1997 Subsistence Management Program.

³² See John M. Morehead to Jack Hession letter, June 1, 1993, in WRST SRC files.

³³ GAAR SRC minutes, April 13-15, 1993, 2.

³⁴ Bob Gerhard to Regional Director, ARO memo, June 29, 1993, in Gerhard files; GAAR SRC minutes, June 18, 1993, 2.

³⁵ John M. Morehead interview, April 23, 2001.

³⁶ Glen Alsworth to Manuel Lujan, August 17, 1992; John H. Davis to Alsworth, October 1, 1992; both in LACL SRC files; John Morehead interview, April 23, 2001.

³⁷ Lois Dalle-Molle to Betty Barlond, October 5, 1993; Bob Gerhard to Jack (Morehead) and Paul (Anderson), December 22, 1993; both in CAKR SRC files.

³⁸ Pete Schaeffer to Bruce Babbitt, June 13, 1994, in Cape Krusenstern SRC file; Walter Sampson to Babbitt, June 13, 1994, in Kobuk Valley SRC file.

³⁹ GAAR SRC minutes, May 10-11, 1994, 2-4; Paul Hunter to Lou Waller email, May 31, 1995, in DENA SRC file; Hollis Twitchell interview, April 6, 1999; Paul Anderson interview, April 30, 2001.

⁴⁰ Ralph Tingey interview, January 11, 2001; Paul Anderson interview, April 30, 2001.

⁴¹ NPS, AKSO, Natural Resources Program Review, "Reinventing Natural Resources Management," February 1996, 2-4, 15. The team consisted of two Alaskan NPS managers (Jon Jarvis of WRST and Judy Gottlieb of AFO), a non-Alaska NPS employee (John Varley from the Yellowstone Center for Resources), and an Outside biologist unaffiliated with the NPS (Gerry Wright from the National Biological Service).

⁴² NPS, Natural Resources Program Review, 2, 4, 14-15.

⁴³ AKSO telephone lists, March 7, 1996 and June 21, 1996.

⁴⁴ Jon Jarvis to Lou Waller, February 26, 1996 email, WRST SRC files; GAAR SRC Minutes, November 13-14, 1996, 10.

⁴⁵ Ralph Tingey interview, January 11, 2001; Bob Gerhard to author, email, January 11, 2001; Gerhard to author note, October 1, 2001.

⁴⁶ DENA SRC, April 29, 1996 and August 9, 1996; GAAR SRC, May 14-16, 1996, 2; November 13-14, 1996, 15, 21; WRST SRC, February 25-27, 1997, 8; John Vale to Bob Barbee, March 8, 1997, in WRST SRC files.

⁴⁷ NPS, Subsistence Management Program, editions of July 3, 1997 and August 18, 1997. The April 1997 workshop was held at Grace Hall on the Alaska Pacific University campus; see "Background Materials for Use at the Subsistence Workshop, April 14-15, 1997," Janis Meldrum collection, NPS.

⁴⁸ WRST SRC minutes, February 25-26, 1997, 2, 8; November 3-4, 1997, 3; November 17-18, 1998, 5. Since 1998, the SMP has been augmented as needed in response to various agency and SRC actions.

⁴⁹ Hollis Twitchell to author, email, January 16, 2001; Janis Meldrum interview, January 12, 2001.

⁵⁰ Steve Ulvi email, January 11, 2001; Mary McBurney interview, January 12, 2001; McBurney to author, email, April 8, 2002.

⁵¹ Janis Meldrum to author, email, January 12, 2001 and August 23, 2001.

⁵² Since June 1996, meetings of the SRC chairs have taken place on the following dates: August 25, 1997; October 13, 1998; October 19, 1999; October 17, 2000, and October 23, 2001. All of these meetings have been held in Anchorage.

⁵³ NPS, "Update from the Subsistence Committee of the Alaska Cluster of Superintendents," January 6, 1997, in "Management Plan, Summer 97" file, author's collection.

⁵⁴ Bob Gerhard to the author, email, June 3, 1997.

⁵⁵ "Park Subsistence Coordinators Meeting, February 17-19, 1999" (agenda), author's files.

⁵⁶ Catton, Land Reborn, 303-05; Alaska Legislative Resolve 89 (1990); Paul F. Haertel to Director NPS, June 21, 1990, in "R Correspondence, 1989-90" file, AKSO-RS collection.

⁵⁷ Catton, Land Reborn, 305; Stan Leaphart to James M. Ridenour, April 10, 1990; Haertel to Director NPS, June 21, 1990; both in "R Correspondence, 1989-90" file.

⁵⁸ Catton, Land Reborn, 287-88. The proposed rule, however, brought such a storm of protest that the original October 4 comment deadline was later extended to November 3. Because of circumstances described in a endnote below, no final rule was ever issued. See the Federal Register 56 (August 5, 1991), 37262-65, and Federal Register 56 (September 13, 1991), 46589.

⁵⁹ Catton, Land Reborn, 312-13; "Park May Be Opened to Commercial Fishing," National Parks 66 (September/October 1992), p. 9; Mary Grisco, "Regional Report/Alaska," National Parks 66 (November/December 1992), p. 22. Rep. Young submitted two bills—H.R. 3156 and H.R. 3158—on July 31, 1991, while Sen. Murkowski submitted S. 1624 on August 2.

⁶⁰ Chip Dennerlein, "Regional Report/Alaska," National Parks 67 (September/October 1993), p. 24; Anchorage Daily News, April 29, 1993, E1; May 13, 1993, B1. In a March 1993 briefing statement for newly-appointed Interior Secretary Bruce Babbitt, the NPS noted that while it "does not agree with the subsistence portion of the bills [which were H.R. 704 and S. 291], we could assist in drafting a more narrow and appropriate alternative for Native fishing and gathering."

⁶¹ Catton, Land Reborn, 313.

⁶² NPS Press Release, December 9, 1993; Federal Register 59 (March 29, 1994), 14565; Federal Register 61 (July 5, 1996), 35134.

⁶³ Federal Register 59 (March 29, 1994, 14564-66; Federal Register 60 (December 5, 1995), 62233-36.

⁶⁴ Federal Register 61 (July 5, 1996), 35133-37. The ticklish ownership issue, which (as Catton notes on p. 278 and elsewhere) had been considered off and on by both state and federal lawyers since the early 1980s, lay dormant until March 1999, when Alaska Attorney General Bruce Botelho announced the state's intention to sue the federal government in the matter. The state filed such a suit that November; it included many other southeastern Alaska submerged lands in addition to those in Glacier Bay. The case is still unresolved; a final decision in the case is not expected for several years.

⁶⁵ Wayne Howell to author, December 11, 2001; Anchorage Daily News, December 18, 1997, F4; John Quinley interview, October 13, 2000.

⁶⁶ Anchorage Daily News, April 10, 1997, E4; October 3, 1997, B1; April 14, 1998, F1. Murkowski inserted Section 12 into S. 967 on June 26, 1997, but by the time the bill emerged from markup, on October 29, the provision had been removed.

⁶⁷ NPS, Glacier Bay Update 1 (August/September 1999), 1-2, 5; Anchorage Daily News, October 22, 1998, A-1.

⁶⁸ NPS, Glacier Bay Update, 1-2; Anchorage Daily News, February 27, 1999, E1; March 24, 1999, D1; June 14, 1999, B1; May 13, 1999, A1; June 18, 1999, B1. Young's bill, H.R. 947, went nowhere, but Murkowski's bill, S. 501, was the subject of a July 29 report and was amended on November 19.

⁶⁹ Federal Register 64 (August 2, 1999), 41854; Federal Register 64 (October 20, 1999), 56455-64.

⁷⁰ NPS, Glacier Bay Update, 2; Anchorage Daily News, October 15, 1998, B7; September 20, 1999, B1; October 4, 1999, B1.

⁷¹ The agreement, at this stage of negotiations, would also have abolished Anaktuvuk Pass as a resident zone community and replaced it with a roster system; that is, a list of eligible subsistence users. The community had asked for this change "to protect [residents] from new people moving in." GAAR SRC minutes, January 27-29, 1990, 8-9. But in the fall of 1991, the roster-system idea was dropped after the NPS held a series of meetings in Anaktuvuk Pass on the matter, and it was not included in any of the various Congressional land-exchange bills. GAAR SRC meeting, September 11, 1991; Roger Siglin to John T. Shively, September 27, 1991, in SRC file.

⁷² GAAR SRC minutes, November 16-17, 1989, 4; January 27-29, 1990, 6-7; November 14-15, 1990, 6; Raymond Paneak to Secretary of the Interior, January 31, 1990; Paul Haertel to Paneak, February 22, 1990; all in SRC file.

⁷³ GAAR SRC minutes, November 14-15, 1990, 4.

⁷⁴ NPS, Draft Legislative Environmental Impact Statement, All-Terrain Vehicles for Subsistence Use, Gates of the Arctic National Park and Preserve, Alaska (Anchorage, the author, January 1991), 3, 41.

⁷⁵ Meetings were held on March 19 in Anaktuvuk Pass, on March 20 in Fairbanks, and on March 21 in Anchorage. NPS Press Release, February 25, 1991.

⁷⁶ NPS, Final Legislative Environmental Impact Statement, All-Terrain Vehicles for Subsistence Use, Gates of the Arctic National Park and Preserve, Alaska (Anchorage, the author, February 1992), cover letter, 62; NPS Press Release, April 28, 1992.

⁷⁷ NPS, Record of Decision, Final Legislative Environmental Impact Statement, All-Terrain Vehicles for Subsistence Use, Gates of the Arctic National Park and Preserve, Alaska (Anchorage, the author, October 20, 1992), 1-2, 4; NPS Press Release, October 30, 1992; Anchorage Daily News, December 11, 1992, A-11.

⁷⁸ The three non-federal signatories were ASRC President Dick Adams, Mark Morry of the Nunamiut Corporation, and Anaktuvuk Pass mayor Reed Nay. GAAR SRC minutes, April 13-15, 1993, 6.

⁷⁹ Anchorage Daily News, June 22, 1994, A1; July 14, 1994, B1.

⁸⁰ Congressional Record 140 (February 1, 1994), pp. 26033-34 and the Congressional Record website (www.access.gpo.su_docs/aces/aaces002.html); Anchorage Daily News, September 22, 1994, B1; October 11, 1994, B1. Also see House Report 103-769 (October 3, 1994) and Senate Report 103-424 (November 30, 1994).

⁸¹ Anchorage Daily News, January 19, 1995, B3; Congressional Record 141 (February 1, 1995), 3262-65; also see House Report 104-8 (January 27, 1995), p. H 839.

⁸² Congressional Record 141 (June 30, 1995), pp. S 9561, S 9592-95. Also see Senate Report 104-44 (April 7, 1995), p. S 5546.

⁸³ Anchorage Daily News, May 3, 1996, B5; November 13, 1996, A1.

⁸⁴ GAAR SRC minutes, November 13, 1996, 2.

⁸⁵ As noted in Table 5-1, the regulations listed a total of 53 communities, of which four—Ambler, Kobuk, Kotzebue, and Shungnak—served as resident communities for two different park units.

⁸⁶ ANIA SRC minutes, January 11, 1990, 2; Susan Savage to ANIA SRC Chairman, etc., April 28, 1992, 4; GSA, Form T-820-H (1997) for DENA SRC; DENA Subsistence Management Plan, August 18, 2000, 2:5.

⁸⁷ Bill Ellis to Secretary of the Interior, December 2, 1991; Jennifer A. Salisbury to Ellis, July 14, 1992; both in WRST SRC files.

⁸⁸ WRST SRC minutes for November 3-4, 1997, 3-4; November 17-18, 1998, 4-5; GSA, Form T-820-H (1996) for WRST SRC; Tom Carpenter to Jon Jarvis, March 23, 1998; WRST Press Release, August 30, 1999; all in WRST SRC files.

⁸⁹ Federal Register 66 (June 14, 2001), 32282-84; Federal Register 67 (February 25, 2002), 8481-84. The implementation of this regulation marked the first time, in the 18-year history of the NPS's subsistence resource commissions, that an SRC recommendation—with the exception of so-called "subpart D" regulations—has resulted in a new or modified regulation.

⁹⁰ Florence Collins to Russell Berry, June 9, 1994, in NPS, Denali National Park and Preserve Subsistence Management Plan, August 18, 2000, 2:42-45. These boundaries were established even though, according to the SRC chair, "people from ... Nikolai and Telida do not use park lands for subsistence." Collins to Harold Huntington, December 1, 1993, in DENA SRC files.

⁹¹ Annette Burroughs to GAAR SRC, August 11, 1991; GAAR SRC minutes, September 11, 1991, 3; February 25-26, 1992, 3-4. As noted in the minutes, the NPS approved the newly-established boundaries "as long as the community understands that the Service retains the option of reducing the limits of the resident zone or eliminating the resident zone and going to a permit system in the future if a lot of changes take place within the community. The commission agreed with the Park Service's plan."

⁹² John M. Morehead to Jack Hession, June 1, 1993, in WRST SRC files.

⁹³ Lou Waller and John Hiscock to Jay Wells and Clarence Summers, facsimile, June 17, 1992; Karen Wade to Jack Morehead, email, December 2, 1992; Wade to Bill Ellis, January 4, 1993; all in WRST SRC files.

⁹⁴ NPS, "Summary of Actions Taken at the April 7-8 SRC Meeting," n.d.; GSA, Form T-820-H (1995) for WRST SRC; both in WRST SRC files.

⁹⁵ WRST SRC minutes, November 17-18, 1998, 3-4.

⁹⁶ WRST SRC minutes, November 3-4, 1997, 3-4.

⁹⁷ NPS, Draft Review of Subsistence Law and NPS Regulations, September 26, 1995, as revised by the NWAK Working Group, April 18, 1996, 5:23-31.

⁹⁸ Bob Gerhard to Ron McCoy, July 23, 1996; George T. Frampton, Jr. to Pete Schaeffer, September 25, 1996; both in CAKR SRC files; Bob Gerhard interview, October 23, 2000.

⁹⁹ Ken Adkisson to author, email, January 16, 2001; Clarence Summers interview, April 4, 2002.

¹⁰⁰ Jennifer A. Salisbury to Bill Ellis, July 14, 1992, in WRST SRC files; NPS, Gates of the Arctic SRC Newsletter, July 7, 1993.

¹⁰¹ NPS, GAAR SRC minutes, November 13-14, 1996, 19; John Vale to Robert Barbee, March 8, 1997, in WRST SRC files; NPS, Subsistence Management Program, August 1997, 9.

¹⁰² John M. Morehead to Director, NPS, July 5, 1991; DENA SRC minutes, May 28, 1992, 1; Glen Alsworth to Sec. Manuel Lujan, August 17, 1992; John H. Davis to Alsworth, October 1, 1992; all in DENA SRC files.

¹⁰³ John M. Morehead to Director, NPS, July 9, 1993, in DENA SRC files.

¹⁰⁴ Collins to Babbitt, February 17, 1995, in DENA SRC files. The bold type is as in Ms. Collins's letter.

¹⁰⁵ Robert D. Barbee to Wallace A. Cole, April 11, 1995; Barbee to Collins, June 6, 1995; both in DENA SRC files.

¹⁰⁶ Paul Hunter to Lou Waller, email, May 31, 1995, in DENA SRC files; Barbee to Lisa Natwick, July 13, 1995, in LACL SRC files.

¹⁰⁷ DENA SRC minutes, August 9, 1996, 8.

¹⁰⁸ NPS, Lake Clark National Park and Preserve Subsistence Plan (October 5, 2000), 2:4-5.

¹⁰⁹ ANIA SRC minutes, March 24-25, 1992, 35; Harry Kalmakoff, Jr. to Sec. Bruce Babbitt, October 14, 1998; Robert D. Barbee to Kalmakoff, November 23, 1998; all in ANIA SRC files; NPS, Lake Clark National Park and Preserve Subsistence Plan (October 5, 2000), 2:5. As noted in Appendix 5, no Aniakchak SRC meetings between November 1992 and February 1997 were able to attract a quorum of their membership.

¹¹⁰ GAAR SRC, "Subsistence Management Program," May 8, 1991, in GAAR SRC files.

¹¹¹ GAAR SRC, "Subsistence Management Program," February 25, 1992; Annette Burroughs to the SRC, August 11, 1991; both in GAAR SRC files.

¹¹² Federal Register, June 17, 1981, 31849.

¹¹³ GAAR SRC minutes, November 16-17, 1989, 6, 11-12; November 14-15, 1990, 5.

¹¹⁴ John Vale to Robert Barbee, March 8, 1997, in WRST SRC files.

¹¹⁵ John Vale to Gov. Tony Knowles, November 4, 1997, in WRST SRC files.

¹¹⁶ NPS, Lake Clark National Park and Preserve Subsistence Plan (October 5, 2000), 2:28-29. The Aniakchak, Lake Clark, and Wrangell-St. Elias SRCs have gone on record as being in favor of a residency requirement, while the Denali and Gates of the Arctic SRCs have professed little interest in implementing it.

¹¹⁷ Jim Pepper to Richard Stenmark, October 17, 1986; Roger Siglin to Ray Smith, August 16, 1988; GAAR SRC minutes, May 25, 1990, 2; Siglin to Rick Reakoff, July 13, 1990; all in GAAR SRC files.

¹¹⁸ Lee R. Adler to Jon Jarvis, February 7, 1998; John Vale to Robert Barbee, March 8, 1997; both in WRST SRC files; Susan Savage to ANIA SRC chair, April 28, 1992, 3, in ANIA SRC files.

¹¹⁹ Benjamin P. Nageak to Donald Hodel, May 6, 1987; Susan Reece to Nageak, May 18, 1988; both in GAAR SRC files.

¹²⁰ GAAR SRC minutes for November 16-17, 1989, 11; January 27-29, 1990, 6; November 14-15, 1990, 5-6; GAAR SRC, "Subsistence Management Program," May 8, 1991, 3; February 25, 1992, 2; Jennifer A. Salisbury to Raymond Paneak, December 3, 1992; all in GAAR SRC files.

¹²¹ GAAR SRC minutes, May 5-6, 1992, 5.

¹²² Roger Siglin to Jeff Poor, August 3, 1992; Steve Ulvi to Jeff and Cheryl Poor, June 7, 1993, both in GAAR SRC files; Steve Ulvi to the author, email, November 17, 2000.

¹²³ Susan Savage to ANIA SRC, April 28, 1992, 3, in ANIA SRC files.

¹²⁴ Pete Schaeffer to Bruce Babbitt, August 24, 1993; George T. Frampton, Jr. to Schaeffer, September 25, 1996; both in CAKR SRC files.

¹²⁵ DENA SRC minutes, March 6, 1992, 3; May 28, 1992, 5.

¹²⁶ DENA SRC minutes, June 28, 1993, 3; Clarence Summers, telephone conversation record, November 5, 1993; both in DENA SRC files; NPS, Denali National Park and Preserve Subsistence Management Plan, August 18, 2000, 5:5-6. Other sources have indicated that the earliest ORV use along Windy Creek was in 1950.

¹²⁷ NPS, DENA Subsistence Management Plan, August 2000, 5:6; Hollis Twitchell interview, January 18, 2001.

¹²⁸ DENA SRC minutes, August 9, 1996; GSA, Form T-820-H (1997) for DENA.

¹²⁹ ANIA SRC Recommendation 92-7 (November 6, 1992); Robert D. Barbee to Harry Kalmakoff, Jr., November 23, 1998, both in ANIA SRC files; GSA, Form T-820-H (1991) for CAKR; CAKR SRC Hunting Plan Recommendation 2A, August 24, 1993; George T. Frampton, Jr. to Pete Schaeffer, September 23, 1996, both in CAKR SRC files; Lois Dalle-Malle to author, email, January 18, 2001; Mary McBurney to author, email, January 19, 2001.

¹³⁰ Bill Ellis to Secretary Lujan, December 2, 1991; Jennifer A. Salisbury to Ellis, July 14, 1992; both in WRST SRC files.

¹³¹ NPS, Wrangell-St. Elias National Park and Preserve Resource Management Plan, August 1993, Study #S100.01 (14:1-3); Terry L. Haynes to Paul Anderson, January 12, 1994; both in WRST SRC files.

¹³² G. Ray Bane to Lou Waller, January 25, 1994; Roy Ewan to Bruce Babbitt, April 18, 1994; George T. Frampton to Roy Ewan, September 12, 1994; Frank Rue to "Dear Reader," November 29, 1995; WRST SRC minutes, November 3-4, 1997, 4. The state's June 1994 report, written by ADF&G's ANILCA Program Office, was called Documentation of Traditional and Subsistence Access in Wrangell-St. Elias National Park and Preserve: A Review of Existing Source Materials, while the November 1995 study, by Terry Haynes and Stan Walker, was entitled Pilot Project; Documenting Traditional and Subsistence Access in Wrangell-St. Elias National Park and Preserve.

¹³³ Orville Lind to Randy Briggs, November 10, 1992; DENA SRC minutes, August 9, 1996; CAKR SRC, Recommendation 3, August 24, 1993. ANIA SRC Recommendation 92-1, passed in November 1992, stated that "Trapping was customary and traditional in all drainages of the Monument." This was a marked departure from the SRC's April 1987 recommendation, which identified particular drainages where historical trapping had taken place.

¹³⁴ Susan Reece to Benjamin Nageak, May 18, 1988, in GAAR SRC files.

¹³⁵ GAAR SRC minutes, November 14-15, 1990, 6; GAAR SRC, "Subsistence Hunting Plan" for May 8, 1991 and February 25, 1992; Jennifer A. Salisbury to Paneak, December 3, 1992; all in GAAR SRC files.

¹³⁶ GAAR SRC, "Draft Recommendation #9—Gates of the Arctic National Park Traditional Use Area," November 9, 1993. Tracks in the Wildland; A Portrayal of Koyukon and Nunamiut Subsistence (Cooperative Park Studies Unit, University of Alaska, 1982) was written by Richard K. Nelson, Kathleen H. Mautner, and G. Ray Bane; it was an excellent compendium of subsistence lifeways in and around Gates of the Arctic National Park and Preserve.

¹³⁷ GAAR SRC minutes, May 10-11, 1994, 9.

¹³⁸ Martin to Waller, email, May 18, 1994; Martin, "Briefing Statement (Draft)," July 21, 1994; both in GAAR SRC files. The quote is excerpted from the Congressional Record 126 (November 12, 1980), p. 29280 (H 10547). Martin's subsistence coordinator, Steve Ulvi, helped draft both the May email and the July briefing statement.

¹³⁹ Ray Bane to Mike Finley, July 22, 1994; Jack Hession, "Five Latent Traditional National Parks in Alaska," June 23, 1994; both in GAAR SRC files.

¹⁴⁰ George T. Frampton to Raymond Paneak (draft), September 28 and October 13, 1994; GAAR SRC minutes, May 14-16, 1996, 34-35; Paneak to Bruce Babbitt, June 3, 1996; Robert D. Barbee to Paneak, June 24, 1996; all in GAAR SRC files.

¹⁴¹ DENA SRC, August 9, 1996; GAAR SRC, November 13-14, 1996, 17; NPS, Subsistence Management Program, August 1997, 6-7.

¹⁴² WRST SRC minutes, November 17-18, 1998, 3-4; Robert D. Barbee to Harry Kalmakoff, Jr., November 23, 1998, in ANIA SRC files.

¹⁴³ GAAR SRC minutes, January 14-15, 1998, 24-26; NPS, GAAR Subsistence Management Plan (draft), January 25, 2000, 12:6-7; Don Callaway interview, January 19, 2001; NPS, Traditional Subsistence Use Areas; Information Necessary for Making a Determination for Gates of the Arctic National Park (draft), April 18, 1999, in GAAR SRC files. The report was written by Don Callaway, Paul Hunter, and Steve Ulvi.

¹⁴⁴ Jack Hession to Robert D. Barbee, May 6, 1999; Hession to Barbee, June 6, 1999; Barbee to Hession, July 8, 1999; NPS, DENA Subsistence Management Plan (August 18, 2000), 12:1.

¹⁴⁵ GAAR SRC minutes, January 27-29, 1990, 2.

¹⁴⁶ GAAR SRC minutes, May 7-8, 1991, 3, 20, 26.

¹⁴⁷ GAAR SRC minutes, September 11, 1991, 2; February 25-26, 1992, 5.

¹⁴⁸ WRST SRC minutes, November 13-14, 1991, 1; Bill Ellis to Curtis McVee, November 14, 1991; Lujan to Ellis, February 21, 1992; all in WRST SRC files; John Morehead interview, April 23, 2001.

¹⁴⁹ ANIA SRC minutes, March 24-25, 1992, 36; DENA SRC minutes, May 28, 1992, 4-5; GSA, Form T-820-H (1992) for LACL.

¹⁵⁰ ANIA SRC minutes, November 5-6, 1992, 3.

¹⁵¹ Denali staff reacted to the Interior Secretary's directive with an April 7 letter that fully supported the SRC, and on August 17, the Federal Subsistence Board adopted the SRC's recommendation. At Aniakchak, the Interior Secretary made no equivalent ruling because that SRC—plagued as it was by poor meeting attendance—did not forward its moose-season recommendation to the Interior Secretary until 1998. Denali SRC minutes, June 28, 1993, 4; Florence Collins to Bruce Babbitt, October 18, 1993; George T. Frampton, Jr. to Collins, January 10, 1994; Russell W. Berry, Jr. to Chief, Subsistence Division, April 7, 1994; William L. Hensley to Collins, September 29, 1994, all in DENA SRC files.

¹⁵² Florence Collins to Federal Subsistence Board, February 17, 1995, in DENA SRC files; Raymond Paneak to Fenton Rexford, January 20, 1995, in GAAR SRC files; John Vale to Lee Titus, February 29, 1996, in WRST SRC files; GSA, Form T-820-H (1996) for LACL.

¹⁵³ John Vale to Bruce Babbitt, February 29, 1996; Jay Wells to Judy Gottlieb, email, July 17, 1996; Chick Fagan to Clarence Summers, August 2, 1996; George T. Frampton, Jr. to Vale, August 30, 1996; NPS, Wrangell-St. Elias National Park and Preserve Subsistence Plan (September 30, 1999), 1:11; Bob Gerhard interview, August 22, 2001.

¹⁵⁴ Federal Register 55 (October 30, 1990), 45663; Federal Register 59 (November 15, 1994), 58804.

¹⁵⁵ Federal Register 59 (November 15, 1994), 58804.

¹⁵⁶ Federal Register 60 (April 14, 1995), 19011-12.

¹⁵⁷ Raymond Paneak to Robert D. Barbee, February 9, 1995, in GAAR SRC files; Florence Collins to Barbee, June 16, 1995, in DENA SRC files. The GAAR letter was written largely at the behest of SRC member Jack Reakoff.

¹⁵⁸ Federal Register 60 (April 14, 1995), 19011; Office of the Federal Register, Code of Federal Regulations, Title 36, Chapter 1, §13.21 (1998), 180; Paul Hunter interview, January 24, 2001. The regulations terminology was modified by the elimination, between the proposed and final rules, of the phrase "under State or Federal hunting laws and regulations" in paragraph (a)(4) of §13.21.

¹⁵⁹ WRST SRC minutes, February 25-26, 1997, 8; John Vale to Robert Barbee, March 8, 1997, in WRST SRC files; GSA, Form T-820-H (1997) for DENA; NPS, Subsistence Management Program, August 1997, 25-26.

¹⁶⁰ Judy Gottlieb to Florence Collins, May 17, 1999, in Denali SMP (August 18, 2000), 1:11-12; Gottlieb to Collins, February 4, 2000, in Denali SMP (August 18, 2000), B:3; Gottlieb to Harry Kalmakoff, Jr., February 8, 2001, in ANIA SRC files.

¹⁶¹ GAAR SRC minutes, April 20-21, 1999, 4; Florence Collins to Judy Gottlieb, February 14, 2000, in DENA SRC files.

¹⁶² Lou Waller to author, December 20, 2001.

¹⁶³ Bill Ellis to Manuel Lujan, November 14, 1991; Lujan to Ellis, February 21, 1992; both in WRST SRC files. In 1990, a Gates of the Arctic SRC member, Charlie Brower, voiced his "concerns that the ... Park Service and not the Secretary of the Interior" commented on the various park hunting plan recommendations. NPS officials, however, quickly reassured him that the park's recommendations "did go to the Secretary of the Interior's office for approval" and that "the person rejecting the previous hunting plan was the Secretary of the Interior's assistant and was not the 'Park Service.'" GAAR SRC minutes, November 14-15, 1990.

¹⁶⁴ NPS, Subsistence Management Program (August 1997), 5; Judy Gottlieb to John Vale, May 17, 1999.

¹⁶⁵ Robert Barbee to Assistant Secretary for Fish and Wildlife and Parks, July 28, 1999; Bill Pierce to NPS-Alaska Region, fax, September 20, 1999; Judith C. Gottlieb to Glen Alsworth, February 4, 2000, in NPS, Lake Clark National Park and Preserve Subsistence Plan (October 5, 2000), 1:13.

¹⁶⁶ GAAR SRC, "Subsistence Hunting Plan," February 25, 1992; Roger Siglin to Chief, Subsistence Division, May 13, 1992; Jennifer A. Salisbury to Raymond Paneak, December 3, 1992; all in GAAR SRC files.

¹⁶⁷ GAAR SRC minutes, June 18, 1993, 2; NPS, GAAR SRC Newsletter, July 7, 1993, 3. The NPS's Mentasta Caribou Herd Cooperative Management Plan, June 1995, p. 3, stated that "For the purpose of managing this herd, the agencies agree to interpret 'natural' to mean, in part, free from human manipulation for the express purpose of maximizing yield for humans. Rather, humans will be considered an integral component of the predator/prey system and will share with predators the naturally occurring production of caribou."

¹⁶⁸ GAAR SRC minutes, May 10-11, 1994, 2; Supts. WRST, DENA, and GAAR to Deputy Field Director, Alaska, September 8, 1995; David Spirtes to Subsistence Workgroup, February 6, 1996; both in Jon Jarvis, comp., "Natural and Healthy" folder, WRST.

¹⁶⁹ NPS, Subsistence Management Plan, August 1997, 2.

¹⁷⁰ Natural Resources Advisory Council [NPS], "A Definition of Natural and Healthy as Used in the Alaska National Interest Lands Conservation Act," February 26, 1998; Dave Spirtes to Jon Jarvis, email, April 23, 1998; [Dave Spirtes,] "Natural and Healthy" (draft), July 1, 1998; [Spirtes,] "An NPS Interpretation of Natural and Healthy," July 22, 1998; Steve Martin to Spirtes, August 31, 1998; all in Jon Jarvis, comp., "Natural and Healthy" folder, WRST.

¹⁷¹ [Jon Jarvis] to Steve Ulvi, etc., email, c. December 15, 1998; Kyran Kunkel, Harry Bader, and Steve Ulvi, "A Suggested Legal and Biological Framework for Managing Natural and Healthy Fish and Wildlife Populations in National Park System Units in Alaska," February 3, 1999; Dave Mills to Gary Candelaria, email, January 11, 2000; [Dave Spirtes,] "Legal and Biological Framework for Managing Natural and Healthy Populations of Fish and Wildlife Under ANILCA," c. January 2001.

¹⁷² WRST SRC minutes, November 3-4, 1997, 2; GAAR SRC minutes, January 14-15, 1998, 15; NPS, GAAR SMP (January 25, 2000), 7:4. Also see NPS, DENA SMP (August 18, 2000), Introduction:7 and NPS, ANIA SMP (January 3, 2001), 9:8.

¹⁷³ Florence Collins to Robert Barbee, August 29, 1996, in NPS, DENA SMP (August 18, 2000), B:2; John Vale to Robert Barbee, March 8, 1997, in WRST SRC files; NPS, Subsistence Management Program, August 1997, 27.

¹⁷⁴ Carl Morgan to Robert Barbee, January 21, 1998; Paul R. Anderson to Morgan, August 24, 1998; in NPS, DENA SMP (August 18, 2000), 9:5-7; Anderson to Harry Kalmakoff, Jr., December 2, 1998, in WRST SRC files; Anderson to Florence Collins, December 2, 1998, in NPS, DENA SMP (August 18, 2000), 9:7. The January 1998 WIRAC letter also mentioned that "trade in the sense of cash exchange" has long "included handicrafts made from ... various plant materials." But because plant materials were not included in the Council's policy recommendation, the NPS did not address the issue at that time.

¹⁷⁵ Judith C. Gottlieb to Glen Alsworth, February 4, 2000, in NPS, LACL SMP (October 5, 2000), 1:12.

¹⁷⁶ Florence Collins to Judy Gottlieb, February 14, 2000, in NPS, DENA SMP (August 18, 2000), 9:4, B:5; NPS, ANIA SMP (January 3, 2001), 11:5; Judith C. Gottlieb to Harry Kalmakoff, Jr., February 8, 2001, in ANIA SRC file.

¹⁷⁷ Taylor Brelsford to author, January 18, 2002; Janis Meldrum to author, March 5, 2002.

¹⁷⁸ During the 1993-94 round of proposal analysis, agencies that were most affected by specific subsistence proposals were given broad latitude to make analyses and recommendations as they saw fit; thus F&WS staff, for example, were allowed predominant consideration on proposals that primarily affected Alaska's national wildlife refuges. This agency deference still exists today, though to a lesser extent than before.

¹⁷⁹ Taylor Brelsford to author, January 18, 2002.

¹⁸⁰ GAAR SRC minutes, May 10-11, 1994, 8; Taylor Brelsford to author, January 18, 2002. Part of the reason for these reversals was traceable to a lack of funding; the OSM, that first year, was unable to provide travel funds for regional council representatives to attend the April 1994 Federal Subsistence Board meeting in Anchorage. Janis Meldrum to author, March 5, 2002.

¹⁸¹ Janis Meldrum interview, January 30, 2001; Sandy Rabinowitch interview, February 8, 2001.

¹⁸² Members of this committee included Bob Gerhard and Janis Meldrum (NPS), Helen Armstrong (OSM), John Borbridge (BIA), Rod Kuhn and Steve Zemke (USFS), and others.

¹⁸³ Taylor Brelsford, in a January 18, 2002 note to the author, noted that the OSM management at the time—Dick Pospahala, Jim Kurth, Dick Marshall, and Peggy Fox—imposed this new, cooperative model over the objections of many staff members.

¹⁸⁴ Sandy Rabinowitch interview, January 31, 2001.

¹⁸⁵ This trend, however, is by no means universal. Members of some regional advisory councils, particularly those situated away from the road system, appear to strongly prefer the federal program, while members of other regional councils have long supported an active state management regime. Terry Haynes interview, May 15, 2002.

¹⁸⁶ Terry Haynes interview, April 7, 1999.

¹⁸⁷ Terry Haynes to author, email, February 6, 2001; Don Callaway interview, February 13, 2001.

¹⁸⁸ Bob Gerhard interview, January 31, 2001.

¹⁸⁹ Paul Anderson interview, April 30, 2001; Sandy Rabinowitch to author, email, May 2, 2001.

¹⁹⁰ Bob Gerhard interview, January 31, 2001; Mitch Demientieff to Roy Ewan, May 28, 1996, in NPS, DENA SMP (August 18, 2000), 12:19; Paul Anderson interview, April 30, 2001.

¹⁹¹ Sandy Rabinowitch interview, January 31, 2001.

¹⁹² The regional advisory councils have continued to have two meetings per year. The Federal Subsistence Board, which had met four to six times per year during the mid-1990s, has gradually increased its workload over the years, and since the federal fisheries assumption in October 1999, Board meetings have been held about once per month. Perhaps half to three-quarters of those meetings have been open to the public; the remainder have been work sessions with OSM and agency staff. Regional council meetings, which are organized by the various regional council coordinators, are typically advertised in rural newspapers, on local radio stations, and in public buildings where the meetings will take place. Federal Subsistence Board meetings, which are publicized by OSM's Statewide Support Division, typically involve advertisements in Alaska's urban and rural newspapers as well as the official government channels. Sandy Rabinowitch interview, January 31, 2001 and February 5, 2001; Karen Laubenstein to author, email, February 5, 2001.

¹⁹³ Sandy Rabinowitch interview, February 5, 2001. Federal agencies other than the NPS have typically assigned either one or two people to their federal subsistence program support efforts; at the BIA, for example, staff involvement has usually been limited to the agency's staff committee representative, while at several other agencies, a staff assistant or other support person has augmented the staff committee representative's efforts.

¹⁹⁴ Sandy Rabinowitch to subsistence staff, email, April 13, 2001; Bob Gerhard interview, April 27, 2001.

¹⁹⁵ Taylor Brelsford to author, January 18, 2002.

¹⁹⁶ FSB, Final Environmental Impact Statement, Subsistence Management for Federal Public Lands in Alaska (February 1992), II-15 plus maps 7, 9, and 10; FSB, Record of Decision, Subsistence Management for Federal Public Lands in Alaska (April 1992), 9-11.

¹⁹⁷ GAAR SRC minutes, May 10-11, 1994, 5-6; Raymond Paneak to "To whom it may concern," January 11, 1995; Don Callaway interview, February 2, 2001; Steve Ulvi interview, February 2, 2001.

¹⁹⁸ DENA SRC minutes, May 28, 1992, 4; Russell Berry, Jr. to Regional Director, Alaska, May 29, 1992, in DENA SRC files; NPS, DENA SMP (August 18, 2000), 1:17-19 and Appendix G.

¹⁹⁹ GAAR SRC, Resolution 93-03 (October 18, 1993), in GAAR SRC files; Raymond Paneak to Bruce Babbitt, January 26, 1995; NPS, GAAR SMP (January 25, 2000), 1:7.

²⁰⁰ Public Law 96-487 (December 2, 1980), Sec. 102(3); Federal Register 55 (June 29, 1990), 27115, 27122; Federal Register 57 (May 29, 1992), 22942, 22951-52.

²⁰¹ Federal Register 60 (February 2, 1995), 6466-67; Federal Register 61 (April 4, 1996), 15014; Alaska Senate Bill History, 1995-1996, Senate Joint Resolution 19; Florence Collins to Federal Subsistence Board, February 17, 1995, in DENA SRC files. The petitioners also included the Stevens Village Council, Kawerak, Inc., Copper River Native Association, Alaska Federation of Natives, Alaska Inter-Tribal Council, RuralCAP, and the Dinyee Corporation.

²⁰² Federal Register 61 (April 4, 1996), pp. 15016.

²⁰³ DENA SRC minutes, August 9, 1996, 7; GAAR SRC minutes, November 13-14, 1996, 11, 16-17.

²⁰⁴ NPS, Subsistence Management Program, August 1997, 6-7.

²⁰⁵ Federal Register 62 (December 17, 1997), 66217, 66223; Federal Register 64 (January 8, 1999), 1280, 1287-88; ANILCA, Sec. 102(4); NPS, DENA SMP, August 18, 2000, 1:20.

²⁰⁶ http://www4.law.cornell.edu/uscode/16/703.text.html ; http://www.fws.gov/~r9mbmo/intrnltr/intreat.html. According to the Fish and Wildlife Service, "the framers of the [1916] Convention were [apparently] aware of subsistence activity but unaware of the extent to which it was needed and practiced by far northern rural peoples. Thus, the Convention provides inadequately for subsistence uses." Federal Register 58 (August 13, 1993), 43119.

²⁰⁷ Claus-M. Naske and Herman E. Slotnick, Alaska; A History of the 49th State (Grand Rapids, Eerdmans, 1979), 207.

²⁰⁸ Federal Register 52 (December 31, 1987), 49450.

²⁰⁹ http://laws.fws.gov/lawsdigest/treaty.html; ANILCA, Sec. 815(4).

²¹⁰ Federal Register for the following dates: May 19, 1986, 19349-50; July 18, 1986, 26029; and December 31, 1987, 49449-50; Taylor Brelsford to author, January 18, 2002.

²¹¹ Federal Register for the following dates: December 31, 1987, 49449-50; August 13, 1993, 43119-20; August 31, 1993, 45915; March 7, 1994, 10654-55; July 7, 1994, 34859-60.

²¹² http://laws.fws.gov/lawsdigest/treaty.html; http://www.fws.gov/~r9mbmo/intrnltr/intreat.html; http://www.gaiabooks.co.uk/environment/ migratorytreaty.html ; Bob Stevens interview, May 22, 2001.

²¹³ ANIA SRC minutes, November 5-6, 1992, 3; Roy Ewan to Bruce Babbitt, April 18, 1994; George T. Frampton, Jr. to Roy Ewan, September 12, 1994; both in WRST SRC files.

²¹⁴ John Vale to Lee Titus, February 29, 1996; Vale to Bruce Babbitt, December 6, 1996; both in WRST SRC files.

²¹⁵ Chris Bockmon (IOS) to Clarence Summers, email, June 10, 1998, in Summers email file; WRST SRC minutes, November 17-18, 1998, 6. Also see GAAR SRC minutes, April 20-21, 1999, 3.

²¹⁶ Judith C. Gottlieb to Florence Collins, May 17, 1999, in NPS, DENA SMP (August 18, 2000), 1:11.

²¹⁷ Pollock Simon, Sr. to WRST SRC, May 12, 1999, in GAAR SRC files.

²¹⁸ Bockmon to Summers, June 10, 1998; Mimi Hogan (Migratory Birds Division, F&WS) to Clarence Summers, proposed email, February 24, 1997, in Summers email file; Judith C. Gottlieb to Glen Alsworth, February 4, 2000, in NPS, LACL SMP (October 5, 2000), 1:14.

²¹⁹ Robert D. Barbee to Ray Sensmeier, May 16, 2000, in NPS, WRST SMP (November 3, 2000), 6:17; Judith C. Gottlieb to Harry Kalmakoff, Jr., February 8, 2001, in ANIA SRC file.

²²⁰ Florence Collins to ADF&G, June 18, 1988; Beth Stewart to Collins, July 12, 1988; Collins to ADF&G, December 14, 1989; all in NPS, DENA SMP (August 18, 2000), 4:4-5.

²²¹ Dennis R. Kogl, etc. to "Subsistence Board," December 3, 1990; John M. Morehead to Lee Basner, September 30, 1991; both in DENA SRC files.

²²² DENA SRC minutes, May 28, 1992, 3; June 28, 1993, 4; Lee Titus to Ron McCoy, November 23, 1993, in NPS, DENA SMP (August 18, 2000), 4:7. EIRAC's 1993 letter mentioned the prominent role that McKinley Village resident Pat O'Connor was already playing; specifically, it noted that "this problem has been 'in resolution' for an unreasonably long time despite all the time and effort that Mr. O'Connor in particular has devoted to it."

²²³ NPS, DENA SMP (August 18, 2000), 4:2-3.

²²⁴ Florence Collins to Steve Martin, February 17, 1995; Collins to FSB, June 16, 1995; both in DENA SRC files; Federal Register 57 (May 29, 1992), 22948.

²²⁵ NPS, DENA SMP (August 18, 2000), 4:3, 9, 10.

²²⁶ Florence Collins to Chair, Federal Subsistence Board, March 29, 1997, in DENA SRC files; Sandy Rabinowitch interview, February 13, 2001.

²²⁷ NPS, WRST SMP (November 3, 2000), 9:8.

²²⁸ Florence Collins to FSB, February 13, 1998, in DENA SRC files; [Janis Meldrum], "Staff Analysis" (P99-9/11), in FSB proposal files; WRST SRC minutes, November 17-18, 1998, 7. The NPS's August 1997 issues paper (p. 8) noted that "federal regulations provide for C&T determinations to be made on an individual basis for NPS areas, but to date no individual determinations have been made."

²²⁹ NPS, WRST SMP (November 3, 2000), 9:8-9. All parties sought to avoid listing the names of individual C&T holders in the subsistence regulations. The wildlife regulations that were issued on July 1, 1999, therefore, showed no change in the affected GMUs from those that had been issued a year earlier. What was added, however, was a new clause in the final corrected federal fish and wildlife regulations. That clause noted the Board's broad acceptance of the individual C&T concept. It also noted that "the Fish and Wildlife Service and the local National Park Service superintendent will maintain the list of individuals having customary and traditional use on National Parks and Monuments;" the names would not be listed in the regulations themselves. Federal Register 64 (July 1, 1999), 35781-85, 35823.