Alaska's Subsistence Program Under Threat
What is the Federal Subsistence Program in Alaska?
In most states, the state fish and game department manages fishing and hunting on all lands, even on federal lands where there is no conflict with federal law. But in Alaska, the Federal Subsistence Program manages fish and wildlife on federal lands and prioritizes fishing and hunting harvest for rural subsistence users. This program comes from the Alaska National Interest Lands Act (ANILCA), a federal law from 1980, which required this priority for rural subsistence users. Subsistence is a way of life for most rural communities, many of which are indigenous Alaskan Tribal communities.
Why is the rural subsistence priority important?
Without the rural priority, people who rely on subsistence to put food on their tables and freezers would not be prioritized and would be at risk of not having enough to eat. Subsistence foods like salmon and moose are healthy and culturally significant. Replacing these foods with items from the grocery story is prohibitively expensive, less healthy, and severs a cultural connection to the land and animals. The priority for rural subsistence users becomes even more important as temperatures increase, the land changes, and fish and wildlife shift their patterns and timing. As these changes occur, it is even more important to ensure rural subsistence users gain priority access to the fish and game populations that do remain healthy.
The rural priority afforded under ANILCA is not found in the Alaska Constitution, which requires that all Alaskans should have equal access to subsistence resources. This gives rise to a conflict that means that on state lands, managers do not prioritize rural users, while on federal lands, managers must prioritize rural subsistence users over sport users and commercial users.
Open comment period on the Federal Subsistence Program
In May 2025, the recreational sport hunting and fishing group Safari Club International submitted a petition to the federal government asking for changes to the Federal Subsistence Program, including changes that would limit local and Tribal perspectives, and put the rural priority at risk. In response, the federal government has opened a comment period to review the Program and consider making changes. Following this current comment period, the agencies would next publish a draft proposed rule, which would open another comment period in the future. After the agencies receive comments on the draft proposed rule, the agencies would publish a final rule. It is important to tell the agencies why the rural priority is important and what could happen if rural, local, and Tribal perspectives are sidelined.
Petition > Scoping period (comments open) > Draft Rule (future comment period) > Final Rule
If you have a rural subsistence perspective on these issues, we encourage you to comment! You can write your own comment, or use a template to get you started. AIJ has created two templates to help highlight the rural subsistence perspective:
Additionally, the Alaska Federation of Natives has created a more technical template comment letter that is available for anyone to use here.
Comments are due by March 30, 2026 at 7:59 PM Alaska Time. You can submit comments by email to subsistence@ios.doilgov, or through www.regulations.gov (docket number DOI-2025-0170).