2024 Board of Game Meeting In Kotzebue For Western Arctic And Western Region
Western Arctic Caribou Herd In The Spotlight
Alaska Board of Game Meeting in Kotzebue, January 26, 2024
The Western Arctic Caribou Herd (WACH) – once Alaska’s largest caribou herd – has been in a steady decline for the past several years for reasons unknown. Overwinter cow mortality has increased, which is a concern for future recruitment. The most recent ADF&G photocensus in 2022 has the herd at 164,000 animals, which according to the WACH Working Group (WACH WG) Plan, calls for “preservative” management of the herd that could include restrictions on resident hunting opportunities.
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We were pleased to see proposals from the WACH WG, the Kotzebue Fish & Game Advisory Committee, and the Northwest Arctic Regional Advisory Council, requesting a change in the bag limit for WACH from five caribou per day to four caribou total, only one of which may be a cow. Their willingness to sacrifice to help the herd recover does not go unnoticed. RHAK has consistently recommended limiting or eliminating cow harvests as the herd has declined and strongly supported these new limits for all residents due to conservation concerns for the WACH.
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The WACH WG and others also proposed to eliminate all nonresident hunting of the WACH, which RHAK opposed because nonresident caribou hunters were already restricted to just one bull caribou per year on state lands and accounted for less than 3% of the total harvest. Instead, RHAK recommended putting nonresident caribou hunters on draw-only permits with a limited allocation as the best solution to limit nonresident bull harvests while still allowing some nonresident hunting opportunity.
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During board deliberations on these proposals, something interesting happened. Local northwest arctic and arctic residents lobbied board members after hours and reached tentative agreements on how best to proceed. The board the next day amended the proposals to limit resident caribou hunters to four per year, only one of which may be a cow, to increase the bag limit to 15 caribou per regulatory year, only one of which may be a cow, in Units 22, 23, and the southwestern portion of 26A. Those amended proposals passed unanimously, so for the 2024 fall season the resident bag limit in those units is 15 caribou, only one of which may be a cow.
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The board also amended the proposals to eliminate all nonresident caribou hunting in Unit 23 to make all nonresident caribou hunts in the unit draw-only with a limited allocation of up to 300 permits. Those also passed unanimously. That regulation will go into effect in the fall of 2025.
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A summary of all the actions the board took at the Kotzebue meeting can be found here: https://www.adfg.alaska.gov/static/regulations/regprocess/gameboard/pdfs/2023-2024/waw/prelim_actions_1-31-24.pdf
ADF&G graph showing peak of WACH and current declines
2024 Board of Game Meeting in Fairbanks For Interior And Eastern Arctic Region
RHAK proposal 176 to prioritize the Unit 20B any-bull moose hunts for residents only passed, and it was good to get the Board of Game on the record stating that these any-bull moose hunts are primarily designed to allow Alaskans more opportunity to put food in the freezer. The any-bull moose hunts on the middle fork of the Chena and the upper Salcha are now for residents only beginning this fall.
RHAK proposal 180 to get a higher allocation for residents for the DC 827 Delta caribou draw permit hunt also passed as amended. We had asked to change the 75/25 percent resident/nonresident allocation to 90/10. The board amended our proposal to change the allocation to 85/15 percent resident/nonresident. That change will go into effect on next year’s draw application.
RHAK Proposal 112 asked the board to limit nonresident Fortymile caribou hunters who are now taking 25% of the overall harvest to Zone 2 only, based on conservation concerns for the declining herd and displacement of caribou hunters now that the Nelchina caribou herd is closed to hunting. That proposal was voted down.
One bright spot with caribou is the comeback of the Central Arctic Caribou Herd up north along the haul road. With the herd now above the population objective, RHAK asked to increase the resident bag limit to what it was (5 caribou) before the herd declined and allow for the taking of some cows. The board increased the resident bag limit to 5 caribou in Unit 26B Remainder with the allowance to take cows.
The board deferred all Unit 19C sheep proposals to next year’s Statewide meeting, so Unit 19C sheep hunting remains open for residents only in 2024. The board voted down our proposals to put all nonresident sheep hunters on draw-only permits in Unit 20A in the Alaska Range and Units 24A/26B in the Brooks Range. We don’t understand why the board believes it’s okay to allow unlimited nonresident sheep hunting opportunity anywhere in the state, especially with our sheep declines. Even if there are no sheep conservation concerns - which is the board’s position - seeing that a guided sheep hunt now goes for upwards of $30K and nonresidents are required to hire a guide and there are no limits on guides...it’s a recipe for exactly what we are now seeing in the field: crowding and conflicts and nonresident sheep hunters taking the majority of the harvest.
The board liberalized many brown/grizzly bear seasons across the interior with longer spring baiting seasons and earlier fall hunting seasons that start on August 10th. Keep in mind that the regulatory year is from July 1 to June 30, so the new spring baiting seasons won’t start until 2025. More in the summary of actions here: https://www.adfg.alaska.gov/static/regulations/regprocess/gameboard/pdfs/2023-2024/iea/soa_3-22-24_2.pdf
Alaska Board of Game Meeting in Fairbanks, March 15, 2024
Federal Subsistence Board Meeting April 2024 In Anchorage
RHAK Executive Director Mark Richards represented us at the 2024 Federal Subsistence Board (FSB) meeting in Anchorage and testified in opposition to Wildlife Special Action closure requests WSA 24-04, 24-05, and 24-06 to close portions of Admiralty and Chichagof Islands to deer hunting by non-federally qualified users (NFQU) during the peak of rut (Nov. 1 – 15) based on competition from non-local hunters and local subsistence needs not being met. These 3 proposals were essentially do-overs of those that were not passed by the board in 2023.
As to evidence of subsistence needs not being met, we again did not see any such evidence in Wildlife Proposals 24-04, 24-05, or 24-06. If we did, we would have a different position. NFQU are not “obstructing access,” nor are they altering deer behavior, as stated in WP 24-04. The one factual statement in WP 24-04 is that NFQU compete with locals for the deer resource. But that does not mean that such competition prevents subsistence needs from being met during the peak of the rut, which is when proponents of these proposals want non-local deer hunters restricted.
As we had previously stated, “competition” alone is not a valid reason under ANILCA guidelines to restrict NFQU. Of course, every hunter would like it if he or she was the only one in the field, but that isn’t realistic, and the opportunity to hunt is never a guarantee that one will be successful. One individual hunter who may not have been as successful as he or she was in the past is not at all an example that subsistence needs are not being met.
The board ended up passing all three proposals but decreased the duration of the deer hunting closure to NFQU to Nov 1 – 10 and decreased the size of the areas where they would take effect.
Our presence and testimony at FSB meetings is a quandary that Mark Richards wanted to address, as our opposition to so many of these closure requests implies that we do not support subsistence hunting opportunities for rural residents. One different aspect of FSB meetings is that every morning before they begin, they allow public testimony on non-agenda items. Mark took advantage of that and after his introduction gave this oral testimony, below:
I wanted to speak to you today about what our organization is about and why we often have to oppose some of the special action requests that come before this board. Our organization, Resident Hunters of Alaska, wants to ensure that all Alaskans, no matter where they live, have the same hunting opportunities we have today. Our focus is on sustainable wildlife management policies with a clear emphasis on prioritizing resident hunting opportunities.
We formed in 2016 to educate the public about the influence of the commercial hunting industry on our wildlife management decisions and advocate for changes. We are the only western state that does not limit nonresident out-of-state hunters across the board for many species of animals that so many of us depend upon to feed our families.
For us, this is primarily a Board of Game issue, as that board determines all wildlife management and allocation decisions across the state. Those decisions too often then negatively impact resident hunters in rural areas as well. The seven-member Board of Game is currently made up of a majority of big game guides, which is an unprecedented imbalance in favor of commercial hunting interests. I recently gave a presentation in the legislature to the Senate Resources Committee on Board of Game issues and the influence of the commercial hunting industry, and new legislation and guardrails that are needed to ensure we manage our wildlife to benefit Alaskans. We can’t continue to manage our wildlife (or fisheries for that matter) based on who brings in the most money. I encourage you all to view and read the presentation, it is posted on our website on our Board of Game page. Even though we may disagree at times, I hope those on this board and those listening will support our advocacy for changes to the Board of Game process and stronger statutory guardrails to protect our resident hunting opportunities and the hunting traditions of all Alaskans.
Our organization has a policy that whenever we have any wildlife conservation concerns, or crowding and conflicts issues, if there is a nonresident component, that component always needs to be addressed first and limited or restricted first.
And therein lies our issues with this Board. You don’t have the authority, when you impose limits or restrictions on non-federally qualified users, to differentiate between Alaska resident non-federally qualified users or someone from another state or country who is a non-federally qualified user. To this board, someone from Fairbanks or Juneau, and someone from Los Angeles or Timbuktu, are the same. This was and continues to be a huge mistake in how this board functions, that you don’t have the authority to differentiate between your fellow Alaskans and those who don’t live here.
So, with some of these closure requests to non-federally qualified users, it is hard for us to support them when the nonresident component is not addressed first. The goals of our organization have much in common with the concerns that Native and rural communities have over wildlife management decisions and allocations. We believe the main focus should be on the big picture and what our future looks like, and that emphasis should be on first getting a clear resident hunting priority for all Alaskans. We must stop making wildlife management decisions based on who brings in the most money. Certainly, economic considerations are important, but in the end we have to have limits on commercial exploitation of our wildlife resources.
Renew Your Membership Today!
Membership renewal is quick and easy when you click the "renewing member" tab on our Join/Renew page. Or contact Mark Richards at 371-7436 or info@residenthuntersofalaska.org.
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Email pictures to share on our website and newsletter to info@residenthuntersofalaska.org.
RHAK’s Juneau Efforts This Session
RHAK board members Bob Cassell, Travis Drake, and Pete Dickinson, along with executive director Mark Richards, flew to Juneau for a couple days this past session to visit with legislators and talk about RHAK’s mission and garner support for some much-needed changes to how the Board of Game operates and legislative solutions to some of the problems we face. A well-attended reception after hours for legislators and staff was also held so we could informally mingle and have further discussions.
This was followed up a couple of weeks later when Executive Director Mark Richards gave a presentation to the Senate Resources Committee that highlighted issues with the Board of Game and how the commercial hunting industry is influencing decisions that negatively affect our wildlife and resident hunting opportunities. He also expounded on legislative fixes to these issues.
Click here to view all the slides and speaker notes. See the video of the presentation, along with the questions from committee members and answers at this link: https://www.akleg.gov/basis/Meeting/Detail?Meeting=SRES%202024-03-06%2015:30:00 (presentation starts at the 10:00 minute mark)
RHAK's presentation to Senate Resources Committee
Update On The Cassell Lawsuit Against The State And Board Of Game
RHAK VP Bob Cassell sued the Board of Game over whether allocating up to 40 percent of all available Kodiak brown bear “draw” permits to nonresident hunters was constitutional under Article 8 of our state constitution:
§ 2. General Authority: The legislature shall provide for the utilization, development, and conservation of all natural resources belonging to the State, including land and waters, for the maximum benefit of its people.
§ 3. Common Use: Wherever occurring in their natural state, fish, wildlife, and waters are reserved to the people for common use.
The case has taken several years to make its way through the courts and on February 13, 2024, the Alaska Supreme Court heard oral arguments on the case. You can watch the proceedings at this link: https://www.ktoo.org/video/gavel/alaska-supreme-court-robert-cassell-v-state-of-alaska-department-of-fish-game-board-of-game-2024021004/?eventID=2024021004
It will likely take a year or longer before the court releases its final opinion. Regardless of the outcome, this lawsuit was imperative to proceed with to find out just what the courts believed the intent of our state constitution was. Does the “common use” clause in Article 8 allow the Board of Game to exclusively grant to nonresident hunters up to 40 percent of all Kodiak brown bear “draw” permits? Where is the line? What about 50 percent or more?
The reason we have put quotes around “draw” permits is because these nonresident guided-only Kodiak brown bear permits are not really draw permits for nonresidents. Nonresidents don’t have to submit a draw permit application or pay an application fee; they have 100% opportunity to hunt if they have enough money and make a deal with a guide with an exclusive concession within the Kodiak National Wildlife Refuge, whereas resident hunters must submit an application, pay the application fee, and go through an actual random draw lottery process with a 1-3% chance of drawing. Clearly that is not what our state constitution intended.
We will notify you when the Alaska Supreme Court reaches a decision.
Cassell’s attorney Matthew Findley arguing the case before the Alaska Supreme Court
Alaska Department Of Fish & Game Denies RHAK Governor’s Tags Because Of Our Involvement In The Cassell Case!
For the past five years RHAK has participated in the Governor’s hunt permit program and auctioned off Governor’s tags at our banquet to help raise money for the Department. During this same period, we have been involved in the Cassell lawsuit against the Board of Game and the state.
For reasons unknown, a new “policy” was enacted by the Department that states that if any organization, or one of that organizations board members, is involved in a lawsuit against the state, the Board of Game, the Department, or the Commissioner of the Department, then that organization is not eligible to participate in the Governor’s hunt permit program.
We have asked the Department for an explanation of when and why this new “policy” came about but have not yet received an answer. RHAK is the only organization that participates in the Governor’s tag program we know of that is also involved in a lawsuit against the Board of Game, so this seems purposely directed at RHAK.
It’s a strange policy, because the Board of Game has passed regulations that were later deemed unconstitutional by the courts, and the Department is saying regardless of what the court decides, our involvement in the Cassell case should preclude us from participating in the Governor’s tag program.
On top of that, the organizations on the other side of the Cassell case (Safari Club International, Safari Club Alaska Chapter, and the Alaska Outdoor Council) arguing that it’s perfectly fine to allocate up to 40 percent of all Kodiak brown bear “draw” permits to nonresident guided hunters are allowed to continue to participate in the Governor’s tag program. What makes no sense at all is that organizations who participate in the Governor’s tag program must demonstrate that they support a “state-based model of wildlife management,” yet these other organizations arguing against Cassell are part of a coalition arguing that federal Refuge status on Kodiak Island preempts our state constitution and thus out-of-staters should have equal rights to our wildlife on federal lands.
How A Bill Becomes Law, Alaska Edition
Guide Concession Program Update
RHAK testified on Senate and House bills (SB 253 & HB 396) this past session that sought to create a pilot Guide Concession Program (GCP) on state lands that would limit the number of guides. Read the bill language here: https://www.akleg.gov/basis/Bill/Text/33?Hsid=SB0253A
Both bills are identical and have a half-million-dollar fiscal note. A quarter-million would go to the Department of Natural Resources (DNR) so they could hire new staff to administer the program. The other quarter-million would go to ADF&G so they could hire more staff to help with the program. This money would not be paid back by the guides via increased licensing fees.
RHAK opposed this legislation as written as it was essentially a plan without any specifics, with everything to be hashed out after passage. The state didn’t have the money to fund it without it being paid back, and we especially opposed putting DNR – a land management agency – in control of regulating guides. We also didn’t believe the Board of Game should be involved in determining which areas of the state should have guide concessions via proposals from the public.
The Senate version was heard in the Senate Resources committee but went nowhere. The House version passed out of the House Resources committee and then went to the House Finance committee at the tail end of the session but was never heard in Finance.
On the last day of the session, during the 11pm hour, Representative Cronk inserted the GCP legislation into another bill, SB 189, as an amendment, which then went to the Senate for concurrence. SB 189 was a bill to “extend the termination date of the Alaska Commission on Aging,” and inserting the GCP bill as an amendment into SB 189 did not meet the “single-subject” rule of the Alaska Constitution. The framers of our Alaska constitution specifically prohibited inserting other bills that have nothing to do with another bill into that legislation, for obvious reasons.
A whole slew of bills were inserted into SB 189 at the last minute that clearly did not comply with the single-subject rule. What actually passed our legislature in the last hour of the session as SB 189 is written below and also at this link https://www.akleg.gov/basis/Bill/Detail/33?Root=sb%20189.
“An Act extending the termination date of the Big Game Commercial Services Board; extending the termination date of the Board of Massage Therapists; establishing a big game guide concession area permit program on land in the state; relating to the duties of the Big Game Commercial Services Board, the Board of Game, the Department of Fish and Game, and the Department of Natural Resources; relating to education tax credits for certain payments and contributions for child care and child care facilities; relating to the insurance tax education credit, the income tax education credit, the oil or gas producer education credit, the property tax education credit, the mining business education credit, the fisheries business education credit, and the fisheries resource landing tax education credit; extending the termination date of the Alaska Commission on Aging; extending the termination date of the Marijuana Control Board; renaming the day care assistance program the child care assistance program; relating to the child care assistance program and the child care grant program; requiring the Board of Game to establish an initial big game guide concession area; providing for an effective date by amending the effective date of secs. 1, 2, and 21, ch. 61, SLA 2014; and providing for an effective date.”
The single-subject rule states: “Every bill shall be confined to one subject unless it is an appropriation bill or one codifying, revising, or rearranging existing laws.”
We don’t see how this complies with the single-subject rule but apparently if the Governor signs this legislation, it becomes law. The only recourse then is if someone has the money to sue the legislature for not complying with the single-subject rule.
We are extremely disappointed in the legislators who introduced all these amendments into another bill and voted for it and let this go through. This last-minute rush to pass bills that did not make it through committees by inserting them into other bills should not be allowed to happen, and the Governor should not sign into law legislation that was passed in this manner.
If the Governor does sign this legislation and it becomes law, the Board of Game will choose an area on state lands to start the pilot Guide Concession Program. Likely that would be Unit 19C, one of the known problem areas. That pilot guide concession program would then run for two years at which time an assessment would be made on whether it worked and was beneficial to reduce guide numbers, client harvests, crowding and conflicts.
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Unit 19C Sheep Working Group
The new Unit 19C Sheep Working Group (SWG) was funded by ADF&G, with Dr. Alistair Bath hired as the facilitator. Dr. Bath facilitated the previous SWG during the winter of 2015-2016. See https://www.adfg.alaska.gov/index.cfm?adfg=sheepcomm.main.
RHAK opposed this new SWG based on results of the previous and even more expensive SWG, which reached a consensus that nonresident sheep hunters should be limited. We believe the Department can use the money spent on this SWG for more important things, like sheep research and population surveys. Certainly, Tom Lohuis and Brad Wendling, two of the Department’s sheep research biologists who are currently working on sheep projects, could use that money!
There is nothing new under the sun to find out about why we have problems in sheep areas like 19C and 20A in the Alaska Range. Guided sheep hunts are going for upwards of $30K and in high demand. Alaska is the only state where a nonresident is required to hire a guide to hunt sheep and the only state where a nonresident can hunt sheep over the counter. There are also no limits on the number of guides that can operate on state lands. So, we have a free-for-all for nonresidents and the guides they are required to hire.
And we still don’t know for sure whether the full-curl (FC) harvest regulations are sustainable under all conditions. Some biologists believe it is, some don’t. That’s what Brad Wendling’s study in the Brooks Range is hoping to collect more information on.
But even if FC management was sustainable under all conditions, the State of Alaska and the Board of Game should never allow unlimited nonresident sheep hunting opportunity. This is the known cause of the problems and conflicts in the field.
We’re where we are because the guide lobby and the Board of Game want to “provide stability to the guide industry.”
Aside from the fact that it isn’t the board’s job or anywhere in their duties to provide stability to the guide industry, we understand that if we have unlimited guides in a subunit and their clients go to draw-only permits with a limited allocation, this doesn’t give assurances to every single guide that they will all get clients, be able to fund staff and camps and flights, and thus doesn’t “provide stability” to their businesses.
But isn’t that the same with any business? What other businesses demand that the state assures they have clientele? Guides already are guaranteed business with Alaska’s must-be-guided law, unique among the states. And what about the guides in operation currently in areas with draw-only hunts; how do they continue to be able to stay in business?
It’s ironic because the Guide Concession Program the guide lobby and Board of Game have pushed for to solve the known problems is a guide-business killer; only the guides who are able to win a concession stay in business in that area.
The 19C SWG met for the first time in person June 25-26, 2024 in Anchorage. The meeting summary and video will be posted on the Board of Game page. The working group does not have regulatory authority and can only make recommendations to the Board of Game.
Moose Tongue Sandwiches - Mark Richards
In speaking to other hunters over the years, it seems not many eat moose and caribou tongue, but it’s always been one of my family’s favorite parts and makes for a great sandwich!
The first thing we do after a moose or caribou is down is pull the tongue, wash it off, and hang it over a branch in the shade. I typically cut it out from underneath the jawbone as pictured here. Cut it off as far back as you can. We bring it back to camp with the meat and typically have it for sandwiches the next day.
To prepare, put the tongue in a pot of water, add a little salt and some pickling spices, bring to a rigorous boil and then simmer for a hour and a half. That will cook the tongue and make the outside skin bubble up for easy removal. Remove from the water and let it cool, peel off the outer skin, then slice the tongue in thin pieces for sandwiches. If you’ve never eaten tongue you’ll likely find it to be very tasty and wonder why you haven’t been harvesting it along with the rest of the animal.
Pulling the moose tongue
Slicing the boiled moose tongue for sandwiches