#TheYearofBelief | #TYBSubsistence | #TYBLocalExpertise

When the People Who Know the Land Must Remain in the Room

Note to Readers:

This post is longer than usual and is written in direct response to a recent Federal Register notice announcing a scoping review of the Federal Subsistence Management Program. That review includes reconsideration of governance structures that directly affect subsistence protections across Alaska.

We are using The Year of Belief platform intentionally here—to help Tribes, Alaska Native organizations, rural residents, researchers, and partners understand what is being reviewed, what is at stake, and why participation in this process matters. This is not a call to alarm. It is a call to attention and action: We strongly encourage you to submit written comments in support of rural subsistence rights. (HINT: use AFN’s template. More about what comments do below.)

🌿 From the Land: Subsistence is Crucial to Rural Alaska Native Livelihoods

On December 15, 2025, the Departments of the Interior and Agriculture issued a Federal Register notice announcing a scoping review of the Federal Subsistence Management Program. The review identifies governance structures—especially the membership and authority of the Federal Subsistence Board and the criteria for Regional Advisory Councils—as areas for possible reconsideration.

The next day, the Alaska Federation of Natives (AFN) responded, naming the review for what it could become: a potential threat to rural subsistence. AFN’s concern is not abstract. The review is tied to a petition seeking to narrow who holds decision-making authority in subsistence governance. And because scoping happens before any rule is written, this is the moment when the boundaries of change—and power—are set, quietly, through process.

We agree with AFN’s reading of this moment.

From the land, the stakes are clear. Subsistence is not a symbolic practice or a management category. It is a living system of food, knowledge, and responsibility, sustained by people who depend on it daily and who carry the consequences of regulatory decisions first. That is why questions about who sits on the Federal Subsistence Board, and who qualifies to serve on Regional Advisory Councils, are not procedural details. They are questions about who has authority, whose knowledge is treated as credible, and who bears the risk when decisions are wrong.

Subsistence governance exists because subsistence and sport hunting operate under fundamentally different logics. Sport hunting is recreational and opportunity-based. Subsistence is essential, continuous, and tied to survival, food security, and cultural responsibility. ANILCA recognizes this difference explicitly by establishing a rural subsistence priority, ensuring that subsistence needs are protected first—not balanced against, diluted by, or treated as equivalent to sport hunting interests. This priority is not a compromise; it is a legal and ethical commitment to rural and Indigenous communities whose lives depend on access to these resources.

On December 18, we gathered our Equitable Arctic Research community online to think through this moment together. Lance Qaluraq Kramer, a subsistence expert, a member of the Kotzebue Sound Subsistence Advisory Committee, and a former member of a federal Regional Advisory Council (also Corina’s husband whose subsistence activities have been featured in this blog many times), joined us to share how subsistence functions as a complete system of living—what Iñupiat refer to as iñuunialiqput.

Qaluraq described subsistence through the framework of SPEECHES:

Spiritual
Physical
Economical
Emotional
Cultural
Health
Educational
Social

This framework makes visible what is often flattened in institutional processes. Subsistence is not just about hunting or fishing or harvest limits or access points. It is how people feed their families, teach their children, maintain health, uphold cultural responsibility, and sustain community life over time. We are embedding a video of Qaluraq explaining this framework here, because it offers a clear way to understand what is at stake when subsistence governance is reshaped through administrative review.

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In the online meeting we had, Cana and Qaluraq also spoke directly about the importance of public and Tribal representation on the Federal Subsistence Board. (The video is below and offers a ton of information and context not in this blog post.) As of October 2024, three seats on the Board were nominated by Alaska Native Tribes—an important step toward ensuring that subsistence expertise is present where federal decisions are made.

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The current scoping notice, and the “subsequent processes” it anticipates, place that progress at risk. Sport hunting interests—whose priorities are fundamentally at odds with the rural subsistence priority established under Title VIII of ANILCA—have pushed to eliminate these public and tribally nominated seats in favor of a fully federally appointed board.

This matters on the ground. The ongoing decline of the Western Arctic caribou herd heightens concern about whose priorities shape management decisions. For subsistence communities, caribou are central to food security, cultural continuity, and survival. For the State, caribou are also tied to hunting revenues and management frameworks that do not—and legally cannot—prioritize rural subsistence in the same way.

When the people who rely on subsistence are not present on Boards and Councils, decision-making power consolidates elsewhere—in ways that privilege dominant, urban, and institutionally familiar experiences. Sport hunting perspectives, often better resourced and more closely aligned with state frameworks, tend to fill that space. Subsistence is reframed as one interest among many, rather than as the governing priority it is meant to be. Abstraction, consistency, and administrative efficiency begin to outweigh accuracy, accountability, and the lived realities of rural and Indigenous life.

For researchers, this matters.

The Federal Subsistence Board and the Regional Advisory Councils are not only management bodies. They are institutional pathways through which subsistence expertise enters federal systems—the same systems that authorize research access, data collection, monitoring programs, and environmental decision-making. These bodies are not neutral channels; they are sites where power determines how knowledge moves, and whose knowledge counts.

When membership criteria for those bodies are treated as adjustable or technical, what is really being reconsidered is whether lived subsistence knowledge remains decision-critical evidence, or is relegated to background context—consulted, but not authoritative.

Iñuunialiqput expertise is not anecdotal.
It is cumulative, place-based, and accountable to consequence, communities, and cultures. It is also accountable to future generations.

When subsistence experts are present, research-informed management can respond to real conditions. When they are not, research risks producing conclusions that are internally consistent but misaligned with the land itself.

This is not only a subsistence issue.
It is an integrity issue.

The land does not distinguish between “Indigenous Knowledge,”  “management knowledge” and “research knowledge.” It responds to what is done, not how expertise is labeled. Power, however, determines whose actions are authorized.

🏛️ From the Institutions: How Process Becomes Policy

The Federal Register notice published on December 15, 2025 announces a scoping review of the Federal Subsistence Management Program. At first glance, the review is framed as preliminary—no rule has been drafted yet. But the notice is explicit about what is under consideration: governance structures, including the membership and authority of the Federal Subsistence Board and the criteria for Regional Advisory Councils.

The notice also refers to “subsequent processes.” This phrase, used to indicate what’s next, is left intentionally undefined. It does not specify what those processes will be, when they will occur, or how decisions made during scoping will constrain later options. In federal regulatory practice, this kind of vagueness matters. It signals that the scoping period is not merely informational, but foundational—setting the boundaries for what future actions are possible, defensible, and administratively justified.

In other words, scoping is where agencies quietly decide what counts.

Public comments play a concrete role in this stage. They are not simply read and set aside. Comments are counted, categorized, summarized, and cited in internal analyses and in any later rulemaking documents. The notice itself makes clear that comment volume and content are used to justify agency decisions—whether to proceed, how far to go, and which concerns must be addressed. Metrics drawn from comments become part of the administrative record agencies rely on to explain and defend their actions. Oftentimes, reported comments only number in the double digits—so every comment counts! (And, the frequency and cohesion of specific comments also matter.)

This is why participation matters now, before any proposed rule is written.

The Alaska Federation of Natives has prepared a template letter (link within) to help people submit informed comments explaining how subsistence governance works in practice and why local and Tribal expertise must remain central to federal decision-making. While the template was developed in response to concerns raised by Alaska Native communities, anyone may submit comments. You do not need to be Alaska Native or live in Alaska to participate in this process. ((PLEASE submit a written comment using the template before 2/13/2026))

Using the AFN template does not require full agreement with every point, you can edit the letter as you feel necessary. Their letter template offers a clear structure for documenting impacts, naming risks, and reinforcing the importance of rural subsistence priority, effective community engagement, and decision-making grounded in lived experience.

Comments are due February 13, 2026.

From an institutional perspective, submitting a comment is one of the few ways the public can shape how a review is framed before outcomes begin to harden through “subsequent processes.”

From a community-engaged research perspective, it is also a way of practicing responsibility—recognizing that silence during procedural moments can carry long-term consequences for communities whose knowledge is too often treated as optional.

🧭 TYB Framework: This Week’s Practice

Know Who You Are
This week asks us to be honest about where we stand in relation to subsistence systems.
What knowledge do you carry—and what knowledge do you rely on but do not live?
How does your work intersect with governance structures that affect people’s ability to make a living?

Invest in a Community of Support
Subsistence does not persist through individual effort. It persists through shared responsibility, representation, and care.
Who are the people and organizations—like AFN, Regional Advisory Councils, and Tribal leaders—already doing this work?
How can you support them without taking up space that is not yours?

Do the Next Right Thing, Even Imperfectly
You do not need perfect language or total certainty to participate.
Submitting a comment, sharing accurate information, or helping others understand what is happening are all forms of action that matter—especially during early, procedural moments.

Reinforce Hope with Grit
Hope here is not optimism. It is staying engaged when the process is slow, technical, and uneven.
Grit looks like learning how institutions move—and choosing to move with intention rather than disengage.

Remembering Forward

Subsistence has never been protected by accident. It endures because people pay attention early—
before decisions harden,
before authority shifts quietly,
before lived knowledge is treated as optional.

Belief, in moments like this, is not passive trust in systems. It is the steady work of showing up, naming what matters, and insisting that those who know the land remain part of deciding its future.

We remember forward by refusing to forget that making a living—iñuunialiqput—requires voice, presence, and care.