A comment period is open until Feb. 13 as part of a program review that could change the way subsistence hunting and fishing is managed on federal lands in Alaska.
On May 5, 2025, Safari Club International filed a petition with the U.S. Department of the Interior (DOI) asking for significant changes to the Federal Subsistence Management Program — including the removal of all six public members from the Federal Subsistence Board, changes to how members of the Regional Advisory Councils are selected, and elimination of the board’s authority to take “temporary special actions … to temporarily open or close public lands for subsistence uses … [or] to close public lands for the taking of fish and wildlife for nonsubsistence uses, or restrict take for nonsubsistence uses.”
December 15, the Department of Interior initiated a review of the Subsistence Management Program. The DOI review’s focus areas closely mirror the Safari Club’s petition requests.
A public scoping period is now open until Feb. 13 for comments that will inform what changes the secretaries of Interior and Agriculture consider.
At the Southeast Alaska Subsistence Regional Advisory Council (RAC) meeting that took place in Wrangell on Dec. 17 and 18, a few days after the program review was announced, many rural Alaskans expressed alarm at the changes being considered.
The most alarming request in the Safari Club’s petition, says Ted Sandhofer, a Petersburg resident who serves on the Southeast RAC, is the proposed elimination of the six public seats on the Federal Subsistence Board, leaving only five members on the board, all government agency heads. “Those five positions are basically politically appointed. So [instead of the board being a way for rural Alaskan subsistence users to have a voice in the subsistence management process, the board would become] more of a political tool, which is not in the best interest of anybody,” Sandhofer told the Pilot.
How federal subsistence management differs from state management
In 1980, Congress passed the Alaska National Interest Lands Conservation Act, known as ANILCA, which established a subsistence priority for rural residents on federal public lands. The law recognized that for Alaskans in remote communities — many without road access or grocery stores — hunting and fishing are not recreation, but are a way of feeding one’s family and community.
For nearly a decade, Alaska managed subsistence on both state and federal lands under a rural priority system. But in 1989, the Alaska Supreme Court ruled in McDowell v. State that the state constitution’s prohibited giving priority to rural residents over urban ones.
“Before ‘89 the state talked about the same rural preference as the feds,” Sandhofer said. “But then in ‘89 the McDowell case — they went to court and it was decided the state constitution doesn’t allow a rural preference. So everybody in the state has the same rights to fish and game regardless of where you live.”
That created a problem: federal law required a rural priority on federal lands, but the state could no longer provide one. In 1990, the federal government stepped in to manage subsistence on federal public lands.
Today, roughly 60 percent of Alaska is federal land. On that land, rural residents get priority subsistence access to fish and wildlife — particularly when populations decline and harvests must be restricted.
The Regional Advisory Councils
A key feature of the federal program is the 10 Regional Advisory Councils, or RACs, that provide recommendations to the Federal Subsistence Board. Unlike state advisory committees, whose recommendations the Board of Game and Board of Fisheries can freely accept or reject, the federal subsistence board must defer to RAC recommendations under most circumstances.
ANILCA Section 805 requires the board to follow RAC recommendations unless it can show the recommendation isn’t supported by substantial evidence, violates recognized principles of fish and wildlife conservation, or would be detrimental to the satisfaction of subsistence needs.
On Southeast Alaska’s RAC there are 13 members, representing communities from Prince of Wales Island to Yakutat. Members are appointed by the secretaries of Interior and Agriculture after a lengthy application and interview process.
“Basically all of them — are people that use the subsistence program,” Sandhofer said of the RAC council members. “They have a really good knowledge and use the subsistence program.”
The Federal Subsistence Board itself currently has 11 voting members: five federal agency heads, plus six public members — three general public representatives and three members nominated by federally recognized tribal governments. The public members give subsistence users a slim 6-5 voting majority over the agency representatives.
What the petition asks for
The Safari Club petition makes five primary requests:
1. Remove all public members from the Federal Subsistence Board. The petition asks that the six public seats be eliminated, leaving only the five federal agency heads as voting members.
2. Modify how RAC members are selected. To better ensure that 30 percent of the RAC members represent sport and commercial interests, as was described in ANILCA.
3. Require deference to Alaska Department of Fish and Game. The petition seeks to require the Federal Subsistence Board to defer to ADF&G on matters of wildlife conservation.
4. Eliminate duplicate regulations. The petition asks for removal of federal regulations that duplicate state regulations.
5. Restrict special actions. The petition argues the board has exceeded its authority by using emergency and temporary special actions to close federal lands to non-rural hunters or to open additional hunting opportunities during food emergencies.
The petition cites specifically criticizes a 2020 special action that allowed a few additional moose to be hunted by the village of Kake during the Covid-19 pandemic, arguing ANILCA contains “no language to allow a federal agency to open a hunt.”
Sandhofer remembers that special action. At that time, he was the Petersburg District Ranger and was involved in the discussions that led to the Federal Subsistence Board’s decision to allow the hunt during spring of 2020. “I was a ranger at that time ... Kake residents had trouble … food supply to the community was disrupted. Their grocery stores weren’t stocked. They got a couple moose, and they fed a lot of people, so it was a good decision.” The emergency hunt resulted in the harvest of two moose and five deer, which were distributed to 135 Kake households. The Dunleavy administration then sued the subsistence board for overreach and lost the suit. The state appealed and last summer, a panel of 9th Circuit Court of Appeals judges, citing ANILCA, ruled that the decision to open the hunt was legal.
What the DOI program review is considering
The Interior Department’s review will examine:
• Membership of the Federal Subsistence Board
• Criteria for Regional Advisory Council membership
• The role of the State of Alaska and ADF&G in the federal program
• Federal and state regulations for duplication and inconsistency
• Regulations applicable to special actions
• Board policies and procedures for rural determinations
• The 2024 move of the Office of Subsistence Management from the U.S. Fish and Wildlife Service to the Office of the Assistant Secretary for Policy, Management and Budget
Initial response at Southeast Alaska RAC
The Southeast Alaska Subsistence Regional Advisory Council met Dec. 17-18 in Wrangell, where there was a presentation introducing the Department of Interior’s review of the subsistence management program.
Sandhofer described the response from council members and the public as pretty unanimous.
“There were no comments from anybody there, including the council members, that were in favor of changing the program,” he said.
The Central Council of the Tlingit and Haida Indian Tribes of Alaska submitted written testimony urging rejection of efforts that “would erode subsistence protections under the guise of administrative efficiency or user balance.”
“For our people, subsistence is not optional, recreational, or symbolic — it is necessary to our ways of life and essential to our survival,” Tlingit & Haida President Richard J. Peterson wrote. “Our people do not harvest for sport. We harvest to survive, to feed our families, to care for our Elders, to teach our children.”
The Alaska Native Brotherhood Grand Camp also submitted comments opposing the review.
“To rural residents, this feels less like a neutral review and more like a pathway to weakening the very mechanisms that ensure our voices are heard,” wrote Matthew Anderstrom, the organization’s second vice president. “ANILCA is not broken. It is functioning as intended.”
At the national level, the National Congress of American Indians passed a resolution in November calling on the secretaries to “reject the Safari Club’s Petition” and “maintain the present composition of the FSB including the six public seats...”
Safari Club
John Sturgeon, who leads the government affairs committee for Safari Club International’s Alaska chapter, told the Anchorage Daily News in December that the petition’s requests are “very modest.”
“Our biggest concern is that we want to see the resource protected,” Sturgeon said. “We’re trying to get more science put into the process, and we have no objections to rural preference.”
Sandhofer said he doesn’t view Safari Club as adversaries, and he acknowledges the scientists working as State of Alaska’s fish and wildlife managers are doing good work.
“I don’t have anything against Safari Club International. It is a good organization,” Sandhofer said. “But they have a different agenda — to get more people hunting. Non-rural people, just people in general. Not only just state, non-rural individuals, but also from out of state and international.”
“I’m a born and raised Alaskan. I have a lot of loyalty to this state,” said Sandhofer, who is retired and an active subsistence user. He spent a 34-year career with the Forest Service that culminated with him serving as Petersburg District Ranger until 2021.
“I think there’s some balance here ... we all know people that make their living, or some of their living, guiding and hunting … I know a lot of them, and they’re good people … the state benefits from that [and so does Petersburg] … income from non-resident hunters and, you know, outfitters, guides and so forth.”
“It’s a good thing. We just have got to balance that … especially when it comes to be a conservation issue,” said Sandhofer. “The rural preference is very important when stocks are in decline … that’s when they start putting restrictions on non-rural hunters. You know, when there’s a higher competition because there’s not enough animals out there.”
The question ultimately comes down to priorities, says Sandhofer.
“Who needs to be first — the people that need to fill their freezers to feed their families, or trophy hunters?” he said. “That’s kind of what it comes down to.”
“If you’re concerned, you need to comment,” Sandhofer said.
How to comment
The Interior Department is accepting written comments through Feb. 13, 2026. Comments can be submitted by:
• Email: subsistence@ios.doi.gov
• Online: regulations.gov (search docket number DOI-2025-0170)
• Mail: Office of the Secretary, U.S. Department of the Interior, 4230 University Drive, Suite 300, Anchorage, AK 99508
The Interior Department plans to hold a public meeting in Anchorage in early February during the comment period. Details will be posted at doi.gov/subsistence.
Once the scoping period closes, the secretaries will develop recommendations. There will be another opportunity for public comment if regulatory changes are proposed.
The Southeast Alaska RAC will meet again in March in Juneau.
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