Alaska Inter-Tribal Council : Advocating for Alaska Tribal Governments

The Honorable Ken Salazar,
Secretary of the Interior
1849 C Street, NW
Washington, DC 20240

RE: Subsistence Management Review.

Dear Mr. Secretary,

The Alaska Inter-Tribal Council, formally requests that the Sovereign Federally Recognized Tribes of Alaska be granted an extended period to provide written comments regarding the upcoming changes to federal regulations articulating subsistence management. Changes to federal regulations regarding subsistence have a direct impact on the living cultures and life ways of all Indigenous Peoples inhabiting our great sacred land. Tribal governments require additional time to prepare and deliver comments. An extension for comments from Federally Recognized Tribes needs to be acted upon to allow additional time for government-to-government consultation to occur with each Tribe ensuring the requirement of fully informed consent is adequately met. The potential impacts created through the implementation of changes to subsistence policies will forever impact the life ways of all Alaska's Indigenous Peoples.

Mr. Secretary, we thank you for recognizing that the changes to subsistence policies should be created from the bottom up. It is clear from your statements to Tribes, that you understand the importance of responsible resource management in communities that depend on customary and traditional life ways such as hunting, fishing, gathering, harvesting, and trading. Thank you for recognizing the value and significance of Tribal inclusion in the creation of policy that will shape the future for all of the unborn generations. This opportunity that you have created helps to build upon the foundation of government-to-government consultation between federal and Tribal governments.

Since time immemorial, each Tribe has provided protection of customary and traditional resources, while balancing the needs of the community to utilize these resources to create safe harmonious communities. The Department of Interior must work together with AI-TC and individual Tribal Governments to ensure that Tribes are never challenged regarding the control and regulation of Traditional Tribal resources.

Creating legislation that further recognizes and articulates Tribes as the Sovereign Trust Protectors and Stewards of the Earth will ensure that all peoples' grandchildren will have the opportunities to experience the wonder that is provided by existing with all the sacred animals inhabiting Traditional Tribal Lands. It is clear from the living histories provided by our Elders, that under Tribal management customary and traditional resources were more plentiful and available to provide for healthy Traditional Tribal Communities.

The federal government has an obligation to honor the sacred natural resource trust between the Sovereign Tribal Governments and itself. Federal legislation articulating the responsibility of Tribes to protect trust lands, waters, rivers, air, and environment will provide direct benefits to all peoples of all nations. Increased active participation by Tribal Governments in the management of natural resources will provide real opportunities for Tribes to improve the humanitarian conditions within their communities. Many of the food based health related problems that exist in communities are caused as a result of the unresolved management of subsistence resources. In many cases Tribal members are denied access to traditional foods as a result of poor management of traditional and customary resources. This has forced communities to rely on foods that are expensive to import and may not provide a balanced diet. This opportunity is a matter of great significance to the food security of the Indigenous Peoples of the North. Tribes should not be hindered by state and federal agencies in the management of the resources on traditional Tribal lands. Attempts by state entities to regulate and manage wildlife and subsistence resources have created real impacts that have caused families to migrate, and families to go without. In short, the current legal systems structuring subsistence management have created an unresolved matter of great significance that violates the jurisdiction of Tribes, and threatens the food security of all Indigenous Peoples.

Unequal application of law by state and federal agencies has caused great hardship to some of the most underfunded and under-served communities in the entire world. Please extend the comment period to allow additional participation by communities that are un-prepared and unable to provide meaningful comments in the allocated time.

Respectfully,

Brad Garness
Executive Director