A letter to the Federal Subsistence Board

File Photo

by the Akiak Native Community

To: Anthony Christianson, Chairman of the Federal Subsistence Board and the U.S. Fish & Wildlife Service

March 14, 2017

Re: Akiak Native Community Special Action Request to the Federal Subsistence Board to assume management of Kuskokwim Salmon Stocks, Limit 2017 Kuskokwim Chinook Salmon Fisheries to Federally Qualified Subsistence Users, and Implement an Allocation Strategy Consistent with Section 804 of ANILCA Among the Native Villages, Communities and Federally Qualified Subsistence Users in the Kuskokwim Drainage.

The Akiak Native Community, a federally recognized Tribe, submits this Special Action Request asking the Federal Subsistence Board to limit the 2017 Kuskokwim River drainage Chinook subsistence salmon fisheries to federally qualified subsistence users.

The Tribe also requests that the Board implement a strategy for Chinook salmon subsistence management and allocation among the Native Villages, communities and federally qualified subsistence users throughout the Kuskokwim River drainage that ensures the ability, consistent with necessary conservation, to engage in social, customary, and traditional uses of Chinook.

Without federal management of Kuskokwim River Chinook fisheries, our local tribal members and tribal communities will not be ensured the priority and opportunity for important customary and traditional uses of the Kuskokwim Chinook salmon that is required by Title VIII of ANILCA.

Without federal management, our social and cultural reliance on this resource will also be implicated.

Finally, the Tribe requests the Board take over management of the Kuskokwim salmon fisheries other than Chinook in order to ensure that the management of these fisheries is consistent with the management of the Kuskokwim drainage Chinook stocks for conservation and opportunity for subsistence uses.

In 2016, the Board accepted the 804 analysis completed by the Office of Subsistence Management regarding the customary and traditional subsistence use determinations under ANILCA Section 804 for the following villages: Chefornak, Kipnuk, Kwigillingok, Kongiganak, Tuntutuliak, Eek, Napakiak, Napaskiak, Kasigluk, Nunapitchuk, Atmautluak, Oscarville, Bethel, Kwethluk, Akiachak, Akiak, Tuluksak, Lower Kalskag, Kalskag, Aniak, Chuathbaluk, Napaimute, Crooked Creek, Georgetown, Red Devil, Sleetmute, Stony River, Lime Village, Takotna, Nikolai, Telida, and McGrath*.

It them limited the 2014 Kuskokwim Chinook salmon fisheries to these federally qualified subsistence users, and delegated all management and allocation authority to the federal in-season manager.

As in 2016, federal management of Chinook salmon, restricting this fishery to federally qualified subsistence users during the 2017 Kuskokwim River fishing season, is necessary to provide for the priority and opportunity for customary and traditional subsistence uses of chinook salmon, to ensure ability to engage in social and cultural uses of Chinook salmon, and to ensure the healthy conservation of Chinook salmon stocks in light of anticipated low Chinook salmon run forecasts in 2017.

Chinook salmon play a crucial role in our Tribe’s social and cultural practices. Without federal management, the Tribe’s ability to harvest Chinook for customary and traditional subsistence uses, and our social and cultural reliance on and use of this resource, will be compromised by other regulatory requirements that do not prioritize subsistence uses or our cultural and social needs.

The Tribe requests that the Board implement an allocation strategy, consistent with section 804 of ANILCA, which provides for equitable opportunity for customary and traditional subsistence users of Chinook for the Native Villages, communities and federally qualified subsistence users within the Kuskokwim River drainage.

Chinook harvest management for the Kuskokwim is usually approached by limiting the area, time and gear for fishery openings. These blunt strategies have proved insufficient as methods for precise management of Chinook and fail to equitably allocate the Chinook resource between communities and subsistence users when harvestable surpluses are low.

This management strategy also falls short of what is required for the conservation and rebuilding of the Kuskokwim Chinook stocks. It is also essential that there is a management strategy for Kuskokwim chum, red and silver salmon stocks that is consistent with ensuring conservation, rebuilding and the opportunity for subsistence uses of Kuskokwim Chinook salmon.

The Tribe requests federal management of all Kuskokwim salmon stocks as necessary to ensure conservation, important cultural practices, and subsistence uses of the Chinook stocks.

It is essential that the Board work closely with our Tribe and the other tribal governments on the Kuskokwim River drainage in managing salmon and subsistence uses for the River. The tribe fully supports the demonstration project announced by the Secretary for establishment of a co-management structure for the Kuskokwim that incorporates the Kuskokwim River Inter-Tribal Fish Commission into the federal management system.

This co-management structure should be fully implemented for the 2017 season. For the 2017 season, the Board should implement an interim co-management system through temporary rules and the tribal consultation requirement that meaningfully incorporates tribal governments and the inter-tribal commission into all pre-season and in-season management actions and in the development and implementation of a Chinook allocation plan for the members and residents of tribal communities.

*As the Board identified (Native Village) as a Federally qualified subsistence user in 2014, another ANILCA 804 analysis is unnecessary at this time.

Respectfully submitted,

Ivan M. Ivan, Chief

Akiak IRA Council