Mr. Cliff Judkins, Chairman Alaska Board of Game
Mr. Vince Webster, Chairman Alaska Board of Fisheries
%Boards Support Section Alaska Department of Fish and Game PO Box 115526 Juneau, AK 99811-5526
Dear Chairman Judkins and Chairman Webster
I am writing you to request that you plan for and hold a joint board meeting, and accept written Proposals and public comment when you meet to appoint a new Commissioner of the Department of Fish and game.
The Joint boards do not meet frequently enough to accommodate many of the issues that Alaska is still growing into. Recently a Very popular issue was before the Board of Game and due to the legality of the joint boardís responsibilities; the Board of game was unable to act upon the Proposal. This is in reference to Proposal #30 requesting a NON - Subsistence area be formed within a portion of the unit 13 home range of the Nelchina caribou herd. Unit 13 has been a hot bed of angst, resentment, and confusion among all of Alaskaís resident hunters for many years.
The continuing court battles and subsequent court decisions have only helped compound upon the issues before the public and the board. Many of these Decisions have led us to the ad-hoc path we are now on, with again a poorly planned and adopted harvest regulation, that once again leaves all Alaskan hunters questioning, not only the legality but the sustainability of the regulation. Removal of this confusion is necessary to all hunters so that they may in the future plan accordingly and wisely.
If I may out line some of the issues that will again be before the board of game this March regarding nelchina Moose and Caribou harvest.
1. The folks from the Copper basin and Ahtna regions all testified that Caribou has become more of a Necessity since the ability to locate a moose has been more difficult. Many wished and asked for more moose rather than caribou hunting opportunity
2. Many hunters from around the state have requested equal access to a population of caribou that are nearby and have a harvestable surplus that exceeds most herds in neighboring units.
3. The subsistence regulations have prevented both Board of game and the board of fish; from making decisions that would benefit not only the rural residents that reside in these units, but the residents that reside in non-subsistence areas and are denied access to the herdís population.
4. The board of game adopted and passed another regulation for a Community harvest plan that is likely to be challenged in court at a considerable expense to the state and its Residents. As well allocated 300 animals of the ANS established at 600-1000 animals even though most area residents and local ACís testified that a lower ANS would be acceptable for that region.
5. The board of game adopted and passed a regulation that equates to an un-regulated registration hunt of the nelchina caribou herd. This is a Tier I subsistence registration hunt, and that after establishing an ANS of 600-1000 animals,(of which 300 are set aside for CHP) the board did not put a cap on permits that would be available. On top of it all the Board is forcing all registrants and their family members, to hunt moose within the boundary of unit 13. This method of exclusionary language has been thought to deter resident hunters from applying for or excepting tags for the nelchina caribou. When in fact it has also increased the hunting pressure on a recovering moose population, and equated to additional competition for a resource the local copper basin residents seem to actually prefer.
6. And finally the board adopted and passed regulation for a draw style hunt that was initially requested by a large portion of eligible state residents, as the determination of a fair and equitable method of allocation of a state resource. The language of UP/TO 3000 Permits may be issued, was adopted and passed into regulation. In November, the Permit application supplement was printed and published on the state Fish and game web site. The issuable permit numbers are listed as,Ē TBD ďat a later date by the department; as the Department has no idea how many drawing tags may be issued, until the unlimited available number of registration Tier I and Community harvest permits are counted and issued afore hand.
To further compound the situation the board of game left the Department hanging in the wind, to be brutalized if it all falls apart yet again in the spring. Hunters are applying for an Unknown, 0-3000 tags may be issued, refunds may have to occur, and in fact if tags are issued, a hunt may not happen should the unlimited number of Tier I permit holders and CHP meet the harvest quota prior to Draw permits season opener. Again the Department will receive the black eye for the boards not taking responsible action regarding many of these issues.
I feel as a resident of the State of Alaska, the time has come to correct may of the issues before us. Alaskaís Subsistence regulations are out dated and over lapped with Federal subsistence regulation that was not in place, during the inception of legislation of Alaskaís laws. Yet the federal opportunities may not be considered when adopting regulation by the boards. I also feel that the establishment of non subsistence areas/zones would solve many of the user conflicts regarding user groups.
The Joint Boards should meet on a much more frequent basis, so that issues of these nature can be brought up and discussed, and the Joint boards should request the Alaska Legislator to review and amend Alaska Statuteís to work with the current dynamics of Alaskaís population centers. Alaska has seen much growth and expansion of resource availability since the 60ís and 70ís when the acts we are currently operating under took effect.
On this subject I would also share that as a member of the public that attends many Advisory committee meetings around the state, it is also clear to me the dissatisfaction within the ACís of the joint boards accessibility to the ACís, as well that the responsibilities of the joint board, to the ACís and members of the public are in fact NOT being met. Many feel the boards are avoiding issues, and are resistant to the joint meeting process so that these issues may be ignored.
As a member of the public, I feel that the joint boards should meet at least once per cycle, and given that at least every two years both boards are meeting at the same time, in the same city two days at least should be set aside for public comment and review. In the least a short period of time should be allocated for AC action and member review.
The Issue of subsistence, regulation and allocation has come before both boards with great expense and difficulty over the last few cycles. Yet a resolution to the problem has yet to appear. I respectfully request that as a meeting must occur in the near future, the Boards agree to meet, Accept Proposals, Public comment, and take a good hard look at what is needed to repair a faltering and expensive system of management and allocation.
Alaskaís hunters and Fishers are commonly the most underrepresented group within this process, yet deal with all of the decisions forced upon them. I am but one person speaking for many when I ask, to be awarded an equal opportunity as a state resident to share our bounties provided to us.
I am personally willing, at my own expense to travel and work with any group to assist in developing an acceptable resolution to some of the unit 13 problems. I have several current ideas for Non-subsistence area that are located well within the boundaries of unit 13, and allow for much of the traditional subsistence and federal subsistence hunts to continue. As the areas I would propose, are not only the harder to access but also predominantly hunted by residents that reside in non-subsistence areas. I would be grateful would the boards meet me along the way.
Thank You for your consideration
C/C Governor Sean Parnell