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              From :     Denby Lloyd [denby_Iloyd@fishgame.state.ak.us]
              Sent:      Sunday, April 22, 2007 11:07 AM
              To:        gov.sarah@yahoo.com
              Cc:      Michael A Nizich; Tibbles; Michael A (GOV); John W Bitney; Kenton P Taylor
             Subject: FW: Gov's Visit to Glenallen

             Cliff Judkins sent me some brief information on the Board of Game's actions with regard to the Tier II
             subsistence hunts and Advisory Committee input that you heard about in Glenallen . They are outlined
             below FYI.


             Denby S. Lloyd
             Alaska Department of Fish and Game
             P. O. Box 115526
             Juneau, AK 99811-5526

             From: Cliff Judkins (mailto:cjudkins@mtaonline.net)
             Sent: Thursday, April 19, 2007 6:23 PM
             To: Denby Lloyd; 'Matt Robus'
             Cc: 'Kenton Taylor'
             Subject : Re: Gov's Visit to Glenallen

             Denby- Thanks for the opportunity to comment. History on the Boards T-II actions:. Two years ago the
             Board of Game appointed a committee to review the Nelchina T-!! hunt. We had received many
             complaints from all users that the system was broke and they wanted change. The committee consisted
             of three Board members, and Reps. of various groups including Ahtna, AOC, Tanana Chiefs, Subsistence
             Div. , The Mat. Valley Advisory Committee and Department staff. Three members of the committe,
             myself, Ron Somerville and Rod Arno traveled to the area and met with the Glenallen AC, Slana AC,
             Paxon Ac, Cantwell Ac. and members of the Delta AC. At that time we were trying to get comments
             concerning a concept that the Committee had put together which included separating subsistence hunting
            areas from "recreational" hunting areas, establishing methods and means for subsistence that more
            closely related to subsistence hunting. We held a special meeting in Anchorage. The proposal was not
            at all well received by Ahtna. We went back up to Copper Center and met with Ahtna. No agreement
            was reached. There final comment was -Yes the system is broken but nothing else works better- so
            leave it as it is. Last year the Board adopted some salvage requirements and vehicle limitations that we
            felt more closely reflected what subsistence hunters described as their way of hunting. We had a lot of
            testimony from Ahtna folks that subsistence users salvaged internal organs, head and skin and that they
            did not use big vehicles to hunt. This spring we added the income criteria. Our goal has been to
            establish a subsistence hunt that more closely replicates what the users and the statutes define as
            subsistence use. 5AAC. 99.010. concerning subsistence uses establishes what we refer to as the "eight
            criteria": 1. a long term consistence use, 2. a pattern of taking or use recurring in specific seasons each
            year, 3. methods and means of harvest characterized by efficiency and economy of effort and cost, 4.
            long term and consistent pattern of taking, use and reliance, 5. traditional means of handling and
            preparing 6 handing down knowledge of hunting skills, 7. sharing of harvest, 8. reliance for subsistence
            purposes upon a wide diversity of resources that provide substantial economic, cultural, social and
            nutritional elements of the subsistence way of life. When there is not sufficient resources (in this case
            caribou) to satisfy demand the board must first eliminate nonsubsitence, consumption uses. If further
            reduction is necessary the Board must distinguish among subsistence users based upon: 1. Customary
            and direct dependence, 2. proximity of users domicile to the game population and 3. the ability of the


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              user to obtain food if use of the population is eliminated,

             As you can plainly see nothing here is simple . In trying to better define "subsistence use" The income criteria
             goes to the economy of effort provisions and the ability to obtain other food . Discussion at the Board hearing
             when the income criteria was adopted included "Taking a 100,000 . 00 dollar motor home and three or four four
             wheelers up to the Denali Hwy . to kill one caribou does not fit the economy of effort criteria- nor does flying in with
             a 185" . " Folks with this income level can drive to one of the big grocery stores to shop ." I think the Board is
             making difficult, hard decisions ; especially in light of the laws we are guided by. What might happen here is this
             criteria may reduce the number of qualified subsistence users to below the number of harvestable caribou. This
             would allow the state to reduce the amount necessary for subsistence and we would be able to have a drawing
             hunt for the balance of the caribou where all Alaskans could participate equally.

             Concerning AC input and advice , I think if you look at the record you will see that the Board listens very carefully
             to AC input and follow it when we can . Some times the AC recommendations are contrary to the Departments
             biologically based recommendations or just not appropriate to the situation . Where we can adopt their
             recommendations we do . An example is the Unit 16B predator control program . This was an AC proposal
             which the Board adopted . At the last Southcentral meeting an AC recommended that we reduce the length Unit
             16A moose season . We adopted the proposed reduction . I am sure there are many more . I know the ACs
             become upset when we do not follow their recommendation ; but some times the recommendation is just not in the
             best interest of the wildlife when you are looking at the population from a more global view point.

             Again thank you for the opportunity to comment. Cliff