Alaska Department of Fish & Game Commissioner Sam Cotten published “…Out of Bounds on Refuges” Sept. 4, and is short of memory portraying ADFG’s protection for rural subsistence. An Oct. 25, 1983, NewsMiner advertisement urged repeal of the state’s rural subsistence priority statute by voting for Prop 7, signed by 54 ADFG College Road biologists. ADFG fiercely opposed, and Prop. 7 passed. With the McDowell challenge to rural subsistence priority, Alaska ended up minus subsistence responsibilities on federal lands.
Also Mr. Cotten seems oblivious to results of numerous court challenges to federal wildlife management preemption. Court results clearly affirm and reaffirm federal authority to manage on federal lands (see Alaska Law Review Vol.27.1 “National Wildlife Refuges and Intensive Management in Alaska; Another Case for Preemption”- Julie Lurman Joly). Such challenges to federal authority failed, most on failure to manage fish and wildlife populations in a manner consistent with “the conservation of healthy populations of fish and wildlife.” Instead we have a Board of Game (a.k.a. board of hunters and trappers) dishing out an ongoing wolf and bear holocaust earning a reputation of abuse and savagery that is growing to national recognition.
And what of the 1982 ADFG/USFWS Memorandum of Understanding, renewed in 2006? It recognizes the Service’s responsibility “to manage fish and resident wildlife in their natural species diversity on Service lands” Mr. Cotten, you are far “out of bounds.”
Jim Kowalsky
Fairbanks