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A Below-the-Radar Public Lands Decision With Big Implications for Alaska Native Communities
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A Below-the-Radar Public Lands Decision With Big Implications for Alaska Native Communities

A pending decision by Interior Secretary Deb Haaland for 28 million acres of public lands could be one of the Biden administration’s biggest conservation and Indigenous rights wins.

Tackling Climate Change and Environmental Injustice, Conservation, Public Lands, +1 More

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In this article
Child swings from a fish drying rack
Child swings from a fish drying rack in the Upper Kobuk region of the Northwest Arctic, Alaska. (Jayme Dittmar/SalmonState)

Introduction and summary

Days before leaving office in 2021, the Trump administration attempted to quietly revoke protections for 28 million acres of public lands in Alaska,1 an area roughly 37 times the size of Yosemite National Park.2 These lands—mostly closed to industrial development since the early 1970s and overseen by the U.S. Bureau of Land Management (BLM)—include uniquely intact habitat and miles of waterways that support abundant wildlife populations and provide a stronghold for at-risk species.

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Critically, these productive lands support numerous Alaska Native communities reliant on subsistence harvesting—the use of wild resources—as an important cultural cornerstone and a key source of nutrition. In fact, approximately 80 percent of Alaska Native villages are within 50 miles of these 28 million acres of threatened BLM lands, and, additionally, 74 percent of the lands are federally designated as areas where rural communities have priority to hunt and fish for subsistence.3

With so much at stake for communities and wildlife across the state, this decision represents an unmatched opportunity for Secretary Haaland to fulfill President Joe Biden’s conservation commitments and respond to the calls of Alaska Native Tribes, who have overwhelmingly called for fully maintaining protections.

The incoming Biden administration immediately hit the brakes on the effort to strip protections from these lands, and Interior Secretary Deb Haaland will soon decide whether to fully maintain protections and finish the job of unwinding the damage wrought by the previous administration. With so much at stake for communities and wildlife across the state, this decision represents an unmatched opportunity for Secretary Haaland to fulfill President Joe Biden’s conservation commitments and respond to the calls of Alaska Native Tribes, who have overwhelmingly called for fully maintaining protections. A strong decision today would also lay the groundwork for future progress toward co-management or co-stewardship of key lands between the BLM and Alaska Native Tribes, restoring a historic connection for the long-term benefit of communities and natural resources.

In this report, the Center for American Progress assesses what’s at risk, highlighting three regions and communities and further opportunities that could be unlocked by a strong decision.

Background

Today, the BLM manages close to 55 million acres of lands in Alaska that were “withdrawn” by the secretary of the interior in the early 1970s, placing them mostly off-limits to industrial extractive development or transfer to state ownership.4 Because the withdrawals were authorized under Section 17(d)(1) of the Alaska Native Claims Settlement Act (ANCSA), these lands are often referred to as “D-1 lands” and the protections as “D-1 protections.” For half a century, these relatively intact and undeveloped lands, as well as the subsistence resources they support, have remained legally protected from extractive industrial development.

In January 2021, the Trump administration attempted to lift D-1 protections on 28 million acres of BLM lands across five of the agency’s planning areas: Bay, Bering Sea-Western Interior, East Alaska, Kobuk-Seward Peninsula, and the Ring of Fire. These areas are distributed throughout the state, stretching from just above Glacier Bay National Park in the southeast to Bristol Bay in the Southwest and north to the Chukchi Sea.5

Shortly after taking office, the Biden administration took a hard look at the rushed public land orders, determined they were legally flawed, and put them on pause. Among other legal deficiencies, the Department of the Interior cited the “failure to adequately analyze potential impacts on subsistence hunting and fishing.”6 The BLM initiated a full environmental review in 2022 to inform a final decision by the secretary of the interior on whether to retain some—or all—of the protections for these 28 million acres of public lands,7 and a decision is expected by this summer.8

By the numbers

80%

Of Alaska Native villages are within 50 miles of the BLM lands under evaluation.

Wild Salmon Center, “Key Stats on Alaska D1 Lands."

Source

74%

Of BLM lands under review are federally designated as priority subsistence lands.

Wild Salmon Center, “Key Stats on Alaska D1 Lands."

Source

What’s at risk

A decision to lift protection for these lands—opening them to industrial minerals development or transfer—would have major impacts on Alaska Native communities and culture, world-class fisheries, at-risk wildlife, and overall ecosystem health. One letter to Secretary Haaland from dozens of Tribal governments called BLM lands the “breadbasket” for thousands of Alaska Native peoples.9 Overall, more than half of the federally recognized Tribes in Alaska have formally called on Secretary Haaland to retain protections for the full 28 million acres of land.10

Overall, more than half of the federally recognized Tribes in Alaska have formally called on Secretary Haaland to retain protections for the full 28 million acres of land. CAP, "A Below-the-Radar Public Lands Decision With Big Implications for Alaska Native Communities" (2024).

Wildlife habitat and climate change

These public lands encompass about 6,700 miles of rivers and streams accessible to fish migrating from the ocean—including five varieties of Pacific salmon, among other species supported by these waters.11 Nearly 15 million acres of the lands under review also fall within the range of the Western Arctic caribou herd,12 one of the largest caribou herds on the planet.13 Abundant moose populations and a vast number of migratory birds and other species also utilize these diverse habitats.14

Particularly as Alaska is warming two to three times faster than the global average,15 these intact and well-connected BLM public lands represent a vital buffer against the impacts of climate change. Several Alaskan wildlife populations have seen major declines in recent years, and remaining populations rely heavily on intact, protected lands.16 Resilient populations of chinook and sockeye salmon in the Bristol Bay watershed depend on the interconnected “habitat mosaics” that characterize their spawning and rearing grounds, utilizing different parts of the watershed at different times and allowing them to adapt to shifting conditions.17 Likewise, three of North America’s largest caribou herds depend on the BLM lands under review, which support intact migration corridors necessary to support robust populations.18 Revoking protections for these lands and waters and allowing industrial development would fragment habitat needed to protect vulnerable fish and wildlife populations from the effects of climate change.

In addition to their climate resilience values, these lands also hold important reservoirs of natural carbon important for managing the climate crisis. The public lands under review have been estimated to store 164 million tons of “irrecoverable carbon,” which is carbon that would not recover by midcentury if released now by human activity.19 That equates to more than 600 million tons of carbon dioxide, or the emissions from burning roughly 8 million tanker trucks’ worth of gasoline.20

Alaska Native subsistence resources

Approximately 80 percent of Alaska Native villages (183 total) and more than half a million people live within 50 miles of the BLM lands under evaluation.21 Of the lands under review, 74 percent are designated by the federal government as areas where rural community residents have priority to hunt and fish for subsistence.22

Subsistence harvesting is a foundational element of Alaska Native traditions, as well as an important source of food, economic stability, and other needs.23 The overwhelming majority of rural Alaskans rely on food harvested from the surrounding lands and waters, with 86 percent of rural households consuming wild game and 95 percent consuming wild fish.24 More than a method of obtaining nutrition, subsistence is a pillar of Alaska Native culture and a process of communal sharing and generational bonding.25

Under the Alaska National Interest Lands Conservation Act, federal agencies are required to consider and minimize adverse impacts to subsistence uses in public land use decisions.26 In passing the law in 1980, Congress found that “the continuation of the opportunity for subsistence uses … is essential to Native physical, economic, traditional, and cultural existence.”27

Revoking D-1 protections would open those public lands to industrial minerals development, resulting in likely impacts to fish and wildlife populations and displacement of subsistence activities.28 Additionally, lifting D-1 protections and subsequent conveyance of some of those lands to the state of Alaska would result in Alaska Native communities and other rural residents losing priority for subsistence use of fish and wildlife resources offered by the federal government on federal lands.29 This subsistence priority enables subsistence activities locally, with beneficial harvest limits and hunting seasons and according to traditional customs.30

Regional examples

The three different areas explored below illustrate, at regional and community levels, the value of existing conservation protections and what’s at stake in the upcoming decision.

FIGURE 1

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Bristol Bay

In southwestern Alaska, the Bristol Bay watershed is home to the world’s largest sockeye salmon run. With approximately 46 percent of the global population of wild sockeye, this fishery contributes significantly to the Alaskan economy and sustains a subsistence way of life dating back thousands of years.31 Bristol Bay’s healthy fisheries stand in stark contrast to the situation outside Alaska, where sockeye have experienced precipitous declines in population.32 Bristol Bay also made headlines in recent years for another environmental battle, as the proposed Pebble Mine met with massive opposition because of the dangers it posed to the iconic watershed.33

The productivity of Bristol Bay’s sockeye salmon fishery, and of other wild populations, is due in large part to the watershed’s diverse, well-connected, and relatively pristine aquatic habitat.34 The region’s salmon also serve as a backbone for the food web, providing food and nutrients for bears and other mammals, birds, and many other members of this ecosystem.35 The withdrawn BLM lands—which would have been opened to industrial minerals development by the Trump administration’s orders—include large portions of this watershed along the Nushagak, Kvichak, and Alagnak rivers at the very heart of this world-class ecosystem.

In addition to fueling a $2.2 billion commercial fishery,36 the Bristol Bay watershed supports essential subsistence harvests and cultural connection for Alaska Native residents.37 On average, 80 percent of the protein in the diet of Bristol Bay residents comes from subsistence harvests, with salmon accounting for more than half of those harvests.38

Commercial fishing dock

Commercial fishing dock in Naknek, Alaska, a central hub for the sockeye salmon industry in Bristol Bay. (Getty/Luis Sinco/Los Angeles Times)

Among the Alaska Native Tribes that rely on abundant salmon and other species is Igiugig Village. Igiugig is located along Lake Iliamna and the Kvichak River, home to one of the largest sockeye salmon runs in Bristol Bay.39 The BLM public lands under consideration overlap substantially with lands traditionally used for subsistence by Igiugig Village.40

Beyond salmon, a decision to lift protections for these BLM lands could affect other species of importance for Igiugig: caribou and moose. At-risk lands include critical calving areas and seasonal ranges for moose and the Mulchatna caribou herd,41 whose population has already shrunk dramatically. The herd’s 2021 population was estimated at 12,850 caribou, fewer than half of the minimum population goal set by wildlife managers to sustain population levels.42 As a result of these declines, Igiugig subsistence users have not been able to hunt this herd for the past three years.43 Removing protections for vital habitat could further jeopardize recovery of the herd, as well as other wildlife populations important for subsistence.

Fifteen Tribes from the Bristol Bay region, including Igiugig Village, have called on Secretary Haaland to maintain full protections across the BLM D-1 lands.44 In their formal comments, the Igiugig Village Council and Igiugig Native Corporation explained that retaining D-1 protections is critical to the “ecological, cultural, and economic well-being” of the region and its communities, while also noting the importance of conservation that honors Indigenous rights, knowledge, and stewardship of the lands.45

Watch

Yukon River

Stretching from western Alaska into Canada, the Yukon River is one of the longest in North America, running more than 2,000 miles from the mountains in British Columbia to the Bering Sea.46 The river and its tributaries host multiple Indigenous and non-Indigenous communities and have been used by Alaska Native and First Nations people, settlers, visitors, and industry for transportation, drinking water, and hunting and fishing access and resources for thousands of years.47

Like Bristol Bay, the intact Yukon River watershed provides quality habitat for multiple species, including important salmon runs.48 In fact, a treaty between the United States and Canada, finalized in 2002, recognizes the international importance and uniqueness of the Yukon River and its salmon fishery;49 however, the river’s salmon populations have recently experienced severe population crashes, connected in part to the effects of climate change.50 This region’s boreal forests, shrubs, and open meadows also provide important habitat for moose, caribou, black and brown bears, wolves, lynx, breeding waterfowl, and other wildlife.51

Overhead shot of Yukon River

Yukon River in interior Alaska. (Getty/Patrick J. Endres)

Living along a section of the Yukon River surrounded by BLM lands, the Holy Cross Tribe is calling on Secretary Haaland to retain full protections “to preserve … ancestral lands and the resources that support Indigenous ways of life.”52 Holy Cross has joined with 37 other Tribes—through the Bering Sea-Interior Tribal Commission—to advocate collectively on this and other BLM lands issues.53

In addition to being a cultural tradition, subsistence harvesting is a necessity for residents in Holy Cross. BLM considers Holy Cross a “low-income population of concern” and has identified 49 percent of its population as low income.54 Many residents rely on the land for most of their food—ranging from moose, bird hunting, and fishing. As Eugene John Paul, chief of the Village of Holy Cross, explained, “We don’t have access to what they call it—Safeway or Costco or Fred Meyers—in our village. So most of our stuff just comes off our land, and that’s what we choose to do.”55

Loss of protections would threaten these species and the ability of Holy Cross and other communities to practice subsistence harvesting. In a final management plan for this area published in 2021, which considered the impacts of lifting the D-1 protections, the BLM acknowledged that “locatable mineral decisions may cause a large reduction in the abundance of fish, moose, and caribou harvesting and a major redistribution of fish, caribou, and moose” for Holy Cross and other communities.56

Northwest Arctic

Above the Arctic Circle, along the Chukchi Sea, the Northwest Arctic supports one of the world’s largest caribou herds.57 Making one of the longest migrations of any land mammal on the planet, this massive herd’s range extends from Alaska’s North Slope down to the southern edge of the Seward Peninsula, a largely intact, undisturbed landscape covering massive amounts of federal lands.58 More than 14 million acres, or more than half, of the BLM D-1 lands under review are within the Western Arctic caribou herd range.59 The BLM estimates that approximately 40 villages utilize this one caribou herd for subsistence.60

Numbering almost half a million animals two decades ago, the herd’s population was estimated at only 152,000 in 2023, down more than 100,000 animals in six years and more than 300,000 in 20 years.61 As the herd numbers drop, Northwest community leaders and a Western Arctic Caribou Herd Working Group have come together to make recommendations to state Board of Game decision-makers about how many animals hunters can harvest to protect the herd for future generations.62 As individual hunters sacrifice how much food they can bring home to their communities, they also rely on the lands staying intact and undeveloped to support the survival rates of the caribou. Buckland—a community surrounded by D-1 lands and located at the core of the Western Arctic herd winter range63—formally joined Tribes across the state to call for the continued protection of D-1 lands.64 Caribou contribute more than any other resource to the subsistence diet of Buckland residents.65 Experienced hunters, such as those in Buckland, travel freely across a large search area to hunt caribou, making the availability of these public lands for subsistence activities particularly important.66

Traditional Iñupiaq values are passed on to new generations in Buckland because of subsistence traditions and the diversity of resources to which the village has access. Intact landscapes that support diverse species are vital to maintaining those traditions and resources. From Eschscholtz Bay, up the Buckland River, to the village site, smelt charge upriver in incredible abundance, with trout, salmon, pike, and burbot also harvested seasonally.67 Eschscholtz Bay is also where traditional societies had their marine mammal hunting camps and where seal hunting continues today.68

Person leaning over side of fishing boat to unhook fish

Subsistence fishing on the Kobuk River in Alaska’s Northwest Arctic region. (Jayme Dittmar/SalmonState)

The Native Village of Buckland may take up only a few miles of dirt roads,69 but the people of the Northwest Arctic region’s relationship to the land extends to where the seal, the caribou, the fish, and the moose are in any given season, to where traditional camps sustained ancestors before the introductions of permanent villages. For Buckland and the 10 other Northwest Arctic villages, that relationship extends across the roughly 10 million acres of BLM D-1 land in the region.70

Tribal co-stewardship and co-management opportunities

In addition to protecting ongoing subsistence activities, retaining full protections for the 28 million acres of BLM lands would allow the Department of the Interior to engage with federally recognized Alaska Native Tribes on potential co-stewardship or co-management of the lands and resources vital to the cultural, traditional, and customary use of these communities. While specific definitions vary, the broad term “co-stewardship” generally refers to sovereign-to-sovereign cooperative or collaborative arrangements between Tribes and the federal government for the conservation or management of lands, waters, or related resources.71 The term “co-management” is typically used to describe a version of co-stewardship that more clearly involves shared, or delegated, decision-making.72

BLM lands under review for this pending decision include Tribal ancestral homelands that, as discussed above, continue to provide access and resources necessary for sustaining Alaska Native communities and subsistence practices. Alaska Native people have fished, hunted, and harvested wildlife, fish, birds, and flora since time immemorial.73 Incorporating this traditional and local knowledge into co-stewardship with Alaska Native Tribes would result in more effective, equitable, and informed management of BLM lands and the fish, wildlife, and habitat those lands encompass.

A number of Tribes have made formal proposals for co-stewardship or co-management of specific BLM lands under evaluation, including some proposals made during the ongoing environmental review process for the D-1 protections. Many of the potential and pending agreements between the federal government, Tribal governments, and Alaska Native organizations are centered around subsistence resources and access.74

Among the Tribes seeking co-management is the Village of Holy Cross, which has proposed a new concept of creating a Tribal Conservation District that would include co-management of millions of acres of BLM-managed lands currently protected under the D-1 withdrawals.75 In fact, Holy Cross was recently awarded an America the Beautiful Challenge grant of $1.2 million over three years to fund the Bering Sea-Interior Tribal Commission’s exploration of this innovative concept.76

Lifting the D-1 protections would compromise lands and resources currently under active consideration for co-stewardship or co-management, as well as jeopardize future opportunities and innovation. On the flip side, a strong decision would enable the Department of the Interior to fully pursue these opportunities to honor Tribal traditions and knowledge, while improving land management and conservation outcomes.

Conclusion

With her impending decision, Secretary Haaland has a chance to secure protections for 28 million acres of public lands that are essential for traditional subsistence; rural economic viability; and the long-term health of lands, waters, and wildlife already facing the brunt of a changing climate. She would be responding to the calls of Tribes across Alaska, particularly villages whose subsistence traditions were put in the crosshairs by the Trump administration’s decisions for these lands, as well as the many allies who have echoed those calls.77

Beyond repairing harm left by the previous administration, retaining long-standing protections for these lands could also be a proactive step forward. A soon-to-be-finalized environmental review would be a strong starting point for the Interior Department to consider the growing number of Alaska Native Tribes that have requested co-stewardship and co-management agreements. With a strong decision, Secretary Haaland could not only protect traditional practices today but could also open the door to restoring traditional care of lands and resources to their original stewards on behalf of those communities and the lands themselves.

Acknowledgments

The authors would like to thank Rachel James and Loretta Brown from SalmonState; Emily Anderson, Morgan Urquia, Jon Hart, and Luke Brockman from Wild Salmon Center; Megan Condon from Native American Rights Fund; Angelo Villagomez, Mariel Lutz, Sharon Ferguson, Nicole Gentile, Will Beaudouin, Bill Rapp, Chester Hawkins, Meghan Miller, Beatrice Aronson, and Audrey Juarez from the Center for American Progress; and other reviewers for their assistance with this report.

Endnotes

  1. Public Land Orders (PLOs) 7900, 7901, 7902, and 7903, which would revoke withdrawals on lands in the Ring of Fire, Bay, Bering Sea-Western Interior, and East Alaska planning areas, respectively, were signed on January 15 and 16, 2021; however, they were never published in the Federal Register. PLO 7899, which would revoke withdrawals on lands in the Kobuk-Seward Peninsula planning area, was signed on January 11, 2021, and published in the Federal Register on January 19, 2021 (86 FR 5236). U.S. Bureau of Land Management, “Public Land Order No. 7899; Partial Revocation of Public Land Orders No. 5169, 5170, 5171, 5173, 5179, 5180, 5184, 5186, 5187, 5188, 5353, Alaska,” Federal Register 86 (11) (2021), available at https://www.federalregister.gov/documents/2021/01/19/2021-01111/public-land-order-no-7899-partial-revocation-of-public-land-orders-no-5169-5170-5171-5173-5179-5180. For additional context, see U.S. Bureau of Land Management, “Notice of Intent To Prepare an Environmental Impact Statement To Consider the Impacts of Opening Lands Subject to ANCSA 17(d)(1) Withdrawals, Including Lands Within the Bay, Bering Sea-Western Interior, East Alaska, Kobuk-Seward Peninsula, and Ring of Fire Planning Areas; Alaska,” Federal Register 87 (159) (2022), available at https://www.federalregister.gov/documents/2022/08/18/2022-17806/notice-of-intent-to-prepare-an-environmental-impact-statement-to-consider-the-impacts-of-opening.
  2. National Park Service, “Yosemite National Park, California: Nature & Science,” available at https://www.nps.gov/yose/learn/nature/index.htm (last accessed June 2024).
  3. Wild Salmon Center, “Key Stats on Alaska D1 Lands,” available at https://wildsalmoncenter.org/resources/key-stats-on-alaska-d1-lands/ (last accessed June 2024).
  4. Three public land orders issued in 2018 and 2019 removed about 1.6 million acres of withdrawals from 56.9 million acres of remaining D-1 withdrawals. Additionally, some of the public land orders have been modified to allow for some types of extractive development, such as locatable mineral entry. See U.S. Bureau of Land Management, “Alaska D-1 Withdrawals,” available at https://www.blm.gov/programs/lands-and-realty/regional-information/alaska/d-1_withdrawals (last accessed June 2024); U.S. Bureau of Land Management, “Public Land Order No. 7874: Partial Revocation of Public Land Orders No. 5179, 5180, 5181, 5184, and 5188, Alaska,” Federal Register 83 (193) (2018), available at https://www.federalregister.gov/documents/2018/10/04/2018-21641/public-land-order-no-7874-partial-revocation-of-public-land-orders-no-5179-5180-5181-5184-and-5188; U.S. Bureau of Land Management, “Public Land Order No. 7880: Partial Revocation of Public Land Orders No. 5176 and 5179, Alaska,” Federal Register 84 (132) (2019), available at https://www.federalregister.gov/documents/2019/07/10/2019-14708/public-land-order-no-7880-partial-revocation-of-public-land-orders-no-5176-and-5179-alaska; U.S. Bureau of Land Management, “Public Land Order No. 7879: Partial Revocation of Public Land Orders No. 5173, 5178, 5179, 5180, 5184, 5186 and 5187, Alaska,” Federal Register 84 (132) (2019), available at https://www.federalregister.gov/documents/2019/07/10/2019-14709/public-land-order-no-7879-partial-revocation-of-public-land-orders-no-5173-5178-5179-5180-5184-5186; U.S. Bureau of Land Management, “Sec. 207 Alaska Land Transfer Acceleration Act: A Review of D-1 Withdrawals” (Washington: U.S. Department of the Interior, 2006), p. 4, available at https://www.blm.gov/sites/blm.gov/files/uploads/BLM_AK_sec207report_final_2019Reprint.pdf.
  5. U.S. Bureau of Land Management, “Land Use Planning Boundaries: Alaska,” available at https://www.blm.gov/sites/blm.gov/files/documents/files/Planning_Alaska_Land_Use_Planning_Boundaries_Map.pdf (last accessed June 2024).
  6. U.S. Bureau of Land Management, “Notice of Intent To Prepare an Environmental Impact Statement To Consider the Impacts of Opening Lands Subject to ANCSA 17(d)(1) Withdrawals, Including Lands Within the Bay, Bering Sea-Western Interior, East Alaska, Kobuk-Seward Peninsula, and Ring of Fire Planning Areas; Alaska.”
  7. Ibid.
  8. The effect of the public land order for the Kobuk-Seward Peninsula—which was previously published in the Federal Register, unlike the other four—was formally delayed until August 31, 2024. U.S. Bureau of Land Management, “Interior delays opening of lands in Public Land Order No. 7899,” Press release, April 7, 2023, available at https://www.blm.gov/press-release/interior-delays-opening-lands-public-land-order-no-7899.
  9. Native Village of Aleknagik and others, Letters from 78 federally recognized Tribes to U.S. Bureau of Land Management, “RE: Alaska Native Tribal Support for Maintaining ANCSA D-1 Protections,” October 19, 2023, available at https://landvoicefuture.org/wp-content/uploads/2023/11/Alaska-D-1-Tribe-Sign-On-Letter_October-19-2023.pdf.
  10. At least 131 unique Tribes of nearly 230 federally recognized Tribes in Alaska joined the following joint letters calling for retaining the full D-1 withdrawals under review. Associated Council of Village Presidents, Tanana Chiefs Conference, and Kawarek, Letter to Secretary Deb Haaland, “RE: Three Tribal Consortia Support for Retention of ANCSA Sect. 17(D)(1) Protections,” December 19, 2023, available at https://landvoicefuture.org/wp-content/uploads/2024/01/AVCP-Kawerak-TCC-Tribal-Consortia-D-1-Letter-Signed.pdf; Bering Sea-Interior Tribal Commission, Letter to Secretary Deb Haaland and BLM State Director Steve Cohn, “Bering Sea-Interior Tribal Commission’s Comments on the Bureau of Land Management’s Draft ANCSA 17(d)(1) Withdrawals Environmental Impact Statement,” February 2, 2024, on file with authors; Ahtna Intertribal Resource Commission, Letter to U.S. Bureau of Land Management, “Opposition to the Removal of 17(d)(1) BLM Land Designation,” December 14, 2023, on file with authors; United Tribes of Bristol Bay, Letter to Secretary Deb Haaland and BLM State Director Steve Cohn, “United Tribes of Bristol Bay’s Comments on the Bureau of Land Management’s Draft ANCSA 17(d)(1) Withdrawals Environmental Impact Statement,” February 14, 2024, on file with authors; Native Village of Aleknagik and others, Letters from 78 federally recognized Tribes to U.S. Bureau of Land Management, “RE: Alaska Native Tribal Support for Maintaining ANCSA D-1 Protections.”
  11. Wild Salmon Center, “Key Stats on Alaska D1 Lands”; Wild Salmon Center, “In 5 Maps: Why Alaska Needs Your Help,” January 18, 2024, available at
    https://wildsalmoncenter.org/2024/01/18/in-5-maps-why-alaska-needs-your-help/.
  12. Ibid.
  13. Christian Thorsberg, “In Qikiqtaġruk and the Northwest Arctic, Local Knowledge and Collaboration Carry Climate-Impacted Caribou Forward,” U.S. Fish and Wildlife Service, November 29, 2023, available at https://www.fws.gov/story/2023-11/local-knowledge-carries-caribou-forward.
  14. Bureau of Land Management, “ANCSA 17(d)(1) Withdrawals: Draft Environmental Impact Statement” (Washington: U.S. Department of the Interior, 2023), available at https://eplanning.blm.gov/public_projects/2018002/200530736/20101297/251001297/ANCSA17d1_DEIS_508.pdf.
  15. U.S. Global Change Research Program, “Fifth National Climate Assessment, Chapter 29: Alaska,” (Washington: 2023), available at
    https://nca2023.globalchange.gov/chapter/29/.
  16. U.S. Department of Agriculture, “Climate Change and Wild Foods in Alaska,” available at https://www.climatehubs.usda.gov/hubs/northwest/topic/climate-change-and-wild-foods-alaska (last accessed June 2024); Conor Mallory and Mark Boyce, “Observed and predicted effects of climate change on Arctic caribou and reindeer,” Environmental Reviews 26 (1) (2017): 13–25, available at https://doi.org/10.1139/er-2017-003; Carly Vynne and others, “The Importance of Alaska for Climate Stabilization, Resilience, and Biodiversity Conservation,” Frontiers in Forests and Global Change 4 (2021), available at https://doi.org/10.3389/ffgc.2021.701277.
  17. Sean Brennan and others, “Shifting habitat mosaics and fish production across river basins,” Science, 364 (6442) (2019): 783–786, available at https://www.science.org/doi/full/10.1126/science.aav4313.
  18. Wild Salmon Center, “In 5 Maps: Why Alaska Needs Your Help”; Heather Johnson and others, “Caribou Use of Habitat Near Energy Development in Arctic Alaska,” The Journal of Wildlife Management 84 (3) (2019): 401–412, available at https://doi.org/10.1002/jwmg.21809; Simon Dyer and others, “Quantifying barrier effects of roads and seismic lines on movements of female woodland caribou in northeastern Alberta,” Canadian Journal of Zoology 80 (5) (2002), available at https://cdnsciencepub.com/doi/abs/10.1139/z02-060.
  19. Wild Salmon Center, “Key Stats on Alaska D1 Lands.”
  20. U.S. Environmental Protection Agency, “Greenhouse Gas Equivalencies Calculator,” available at https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator (last accessed June 2024).
  21. Wild Salmon Center, “Key Stats on Alaska D1 Lands.”
  22. Ibid.
  23. U.S. Department of the Interior Indian Affairs, “Alaska Subsistence Program,” available at https://www.bia.gov/service/alaska-subsistence-program (last accessed June 2024).
  24. Caroline Brown and Brooke McDavid, “The Harvest and Use of Wild Resources by Communities Within or Near Northern Alaska Parklands,” National Park Service, available at https://www.nps.gov/articles/000/aps-21-1-9.htm (last accessed June 2024).
  25. Thomas Thornton, “Subsistence in Northern Communities: Lessons from Alaska,” The Northern Review (23) (2001): 82–102, available at https://web.pdx.edu/~tthornto/text_files/Northern%20Review%20Article.pdf.
  26. Alaska National Interest Lands Conservation Act, 16 U.S.C. § 3120(a), available at https://www.law.cornell.edu/uscode/text/16/3120 (last accessed June 2024).
  27. Alaska National Interest Lands Conservation Act, 16 U.S.C. § 3111(a), available at https://www.law.cornell.edu/uscode/text/16/3111 (last accessed June 2024).
  28. Bureau of Land Management, “ANCSA 17(d)(1) Withdrawals: Draft Environmental Impact Statement”; Robert Wolfe and Robert Walker, “Subsistence Economies in Alaska: Productivity, Geography, and Development Impacts,” Arctic Anthropology 24 (2) (1987): 56–81, available at https://www.adfg.alaska.gov/download/download/subecon.pdf; Yereth Rosen, “Oil field road traffic disrupts North Slope caribou more than previously recognized,” Alaska Public Media, January 16, 2024, available at https://alaskapublic.org/2024/01/16/oil-field-road-traffic-disrupts-north-slope-caribou-more-than-previously-recognized/.
  29. Bureau of Land Management, “ANCSA 17(d)(1) Withdrawals: Draft Environmental Impact Statement,” p. 3-169.
  30. Bureau of Land Management, “ANCSA 17d)(1) Withdrawals: Draft Environmental Impact Statement,” p. 3-166.
  31. U.S. Environmental Protection Agency, “About Bristol Bay,” available at https://www.epa.gov/bristolbay/about-bristol-bay (last accessed June 2024).
  32. Bethany Lindsay, “Genetic study of sockeye salmon in B.C. river suggests 75% decline since 1913,” CBC News, August 20, 2019, available at https://www.cbc.ca/news/canada/british-columbia/skeena-river-sockeye-genetic-study-1.5252649; National Marine Fisheries Service West Coast Region, “Status of the Species: Snake River Sockeye Salmon” (Portland, OR: 2023), available at https://www.fisheries.noaa.gov/s3/2023-02/feb-2023-status-snake-r-sockeye.pdf.
  33. Earthjustice, “Alaska’s Bristol Bay & The Pebble Mine,” available at https://earthjustice.org/feature/alaska-bristol-bay-pebble-mine (last accessed June 2024).
  34. U.S. Environmental Protection Agency, “Final Determination of the U.S. Environmental Protection Agency Pursuant to Section 404(c) of the Clean Water Act: Pebble Deposit Area, Southwest Alaska,” (Washington: 2023), available at https://www.epa.gov/system/files/documents/2023-01/Pebble-Deposit-Area-404c-FD-Jan2023.pdf; U.S. Environmental Protection Agency, “An Assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay, Alaska” (Washington: 2014), appendices A–D, available at https://cfpub.epa.gov/ncea/bristolbay/recordisplay.cfm?deid=253500.
  35. Daniel Schindler, “Pacific salmon and the ecology of coastal ecosystems,” Frontiers in Ecology and the Environment 1 (1) (2003): 31–37, available at https://doi.org/10.1890/1540-9295(2003)001[0031:PSATEO]2.0.CO;2.
  36. McKinley Research Group, “The Economic Benefits of Bristol Bay Salmon” (Anchorage, AK: 2021), available at https://stoppebbleminenow.org/wp-content/uploads/2021/03/Final-Economic-Benefit-of-Bristol-Bay-Salmon-3_17_21.pdf.
  37. Igiugig Village Council, Letter to BLM State Director Steve Cohn and Secretary Deb Haaland, “Re: ANCSA 17(d)(1) Withdrawals EIS,” February 13, 2024, on file with authors.
  38. U.S. Environmental Protection Agency, “About Bristol Bay.”
  39. Daniel Rinella and others, “Fishery Resources of the Bristol Bay Region, Volume 2, Appendix A,” in U.S. Environmental Protection Agency, “An Assessment of Potential Mining Impacts on Salmon Ecosystems of Bristol Bay, Alaska” (Washington: 2013), available at https://ordspub.epa.gov/ords/eims/eimscomm.getfile?p_download_id=516964.
  40. Igiugig Village Council, Letter to BLM State Director Cohn and Secretary Haaland.
  41. Neil Barten and Lauren Watine, “Caribou Management Report and Plan, Game Management Units 9B, 9C, 17A, 17B, 17C, 18, 19A, 19B: Mulchatna Caribou Herd, Report Period 1 July 2012–30 June 2017, and Plan Period 1 July 2017–30 June 2022” (Junea, AK: Alaska Department of Fish and Game Division of Wildlife Conservation, 2020), available at https://www.adfg.alaska.gov/static/research/wildlife/speciesmanagementreports/pdfs/caribou_2012_2022_mulchatna_units_9b_17_18_19a_19b.pdf.
  42. Mulchatna Caribou Herd Interagency Management Group, “Mulchatna Caribou Trails: Conservation for a Comeback,” Summer 2021, available at https://www.adfg.alaska.gov/static/hunting/caribouhunting/pdfs/mulchatna_newsletter_summer_2021.pdf.
  43. Igiugig Village Council, Letter to BLM State Director Cohn and Secretary Haaland.
  44. United Tribes of Bristol Bay, Letter to Secretary Deb Haaland and BLM State Director Steve Cohn, “United Tribes of Bristol Bay’s Comments on the Bureau of Land Management’s Draft ANCSA 17(d)(1) Withdrawals Environmental Impact Statement,” February 14, 2024, on file with authors.
  45. Igiugig Village Council, Letter to BLM State Director Cohn and Secretary Haaland.
  46. Timothy Brabets and others, “Environmental and Hydrologic Overview of the Yukon River Basin, Alaska and Canada” (Anchorage, AK: U.S. Geological Survey, 2000), available at https://pubs.usgs.gov/wri/wri994204/pdf/wri994204.pdf; NOAA Fisheries, “Changing Environmental Conditions on the Yukon River May Pose Challenge For Juvenile Salmon,” March 20, 2023, available at https://www.fisheries.noaa.gov/feature-story/changing-environmental-conditions-yukon-river-may-pose-challenge-juvenile-salmon.
  47. Brabets and others, “Environmental and Hydrologic Overview of the Yukon River Basin, Alaska and Canada”; Jody Beaumont and Michael Edwards, “An Introduction to First Nations Heritage Along the Yukon River” (Whitehorse, Yukon Territory: Yukon Education Resource Services), available at http://lss.yukonschools.ca/uploads/4/5/5/0/45508033/an_introduction_to_first_nations_heritage_along_the_yukon_river.pdf (last accessed June 2024).
  48. NOAA Fisheries, “Changing Environmental Conditions on the Yukon River May Pose Challenge For Juvenile Salmon.”
  49. Yukon River Drainage Fisheries Association and Yukon River Panel, “Yukon River Salmon Agreement Handbook” (Anchorage, AK, and Whitehorse, Yukon Territory: 2005), available at https://yukonsalmon.org/wp-content/uploads/Yukon-River-Salmon-Agreement-Handbook.pdf.
  50. Marlena Sloss and Dino Grandoni, “There’s a crisis in the Yukon River,” The Washington Post, December 3, 2023, available at https://www.washingtonpost.com/climate-environment/2023/12/03/yukon-river-salmon-climate-change/.
  51. Bureau of Land Management, “Areas of Critical Environmental Concern: Report on the Application of the Relevance and Importance Criteria and Special Management” (Washington: U.S. Department of the Interior, 2018), available at https://eplanning.blm.gov/public_projects/lup/36665/168768/205411/BSWI_2018_ACEC_Report_508.pdf.
  52. Holy Cross Tribe, Letter to State Director Steve Cohn and Secretary Haaland, “Re: Comments on Draft Environmental Impact Statement regarding ANCSA Section 17(d)(1) withdrawals,” January 10, 2024, on file with authors.
  53. Joaqlin Estus, “Alaska tribes urge protection for federal lands,” Alaska Beacon, December 7, 2023, available at https://alaskabeacon.com/2023/12/07/alaska-tribes-urge-protection-for-federal-lands/.
  54. In the analysis, the BLM defines “low income” as at or below 200 percent of the federal poverty line. Bureau of Land Management, “ANCSA 17(d)(1) Withdrawals: Draft Environmental Impact Statement,” Appendix F, p. 10.
  55. Estus, “Alaska tribes urge protection for federal lands.”
  56. Bureau of Land Management, “Bering Sea – Western Interior: Record of Decision and Approved Resource Management Plan” (Washington: U.S. Department of the Interior, 2021), available at https://eplanning.blm.gov/public_projects/36665/200045911/20033500/250039699/BSWI_ROD_ARMP_BLM-(508).pdf.
  57. Thorsberg, “In Qikiqtaġruk and the Northwest Arctic, Local Knowledge and Collaboration Carry Climate-Impacted Caribou Forward.”
  58. National Park Service, “Predicting Seasonal Distributions and Migratory Routes of Western Arctic Herd Caribou,” available at https://www.nps.gov/articles/seasonalmigration.htm (last accessed June 2024); Wild Salmon Center, “In 5 Maps: Why Alaska Needs Your Help.”
  59. Wild Salmon Center, “Key Stats on Alaska D1 Lands.”
  60. Bureau of Land Management, “ANCSA 17(d)(1) Withdrawals: Draft Environmental Impact Statement,” p. 3-131.
  61. Thorsberg, “In Qikiqtaġruk and the Northwest Arctic, Local Knowledge and Collaboration Carry Climate-Impacted Caribou Forward”; Western Arctic Caribou Herd Working Group, “Caribou Trails: News from the Western Arctic Caribou Herd Working Group” (23) (2023), available at https://westernarcticcaribou.net/wp-content/uploads/2023/07/Caribou-Trails-2023-FINAL-PRINT.pdf.
  62. Western Arctic Caribou Herd Working Group, “Caribou Trails: News from the Western Arctic Caribou Herd Working Group.”
  63. Randi Jandt and others, “Slow Recovery of Lichen on Burned Caribou Winter Range in Alaska Tundra: Potential Influences of Climate Warming and Other Disturbance Factors,” Arctic, Antarctic, and Alpine Research 40 (1) (2018): 89–95, available at https://doi.org/10.1657/1523-0430(06-122)[JANDT]2.0.CO;2.
  64. Native Village of Aleknagik and others, Letters from 78 federally recognized Tribes to U.S. Bureau of Land Management, “RE: Alaska Native Tribal Support for Maintaining ANCSA D-1 Protections.”
  65. Damian Satterthwaite-Phillips and others, “Iñuuniaḷiqput Iḷiḷugu Nunaŋŋuanun: Documenting Our Way of Life through Maps” (Kotzebue, AK: Northwest Arctic Borough, 2016), available at https://www.nwabor.org/wp-content/uploads/1-Cover-and-Front-Matter.pdf; Satterthwaite-Phillips and others, “Iñuuniaḷiqput Iḷiḷugu Nunaŋŋuanun: Documenting Our Way of Life through Maps, Chapter 2,” available at https://www.nwabor.org/wp-content/uploads/3-Chapter-2a-Villages.pdf.
  66. Satterthwaite-Phillips and others, “Iñuuniaḷiqput Iḷiḷugu Nunaŋŋuanun: Documenting Our Way of Life through Maps.”
  67. Ibid.
  68. Ernest S. Burch Jr., “Traditional Eskimo Societies of North America,” Senri Ethnological Studies 4 (1980): 253–303; Henry Huntington, Mark Nelson, and Lori T. Quakenbush, “Traditional Knowledge Regarding Ringed Seals, Bearded Seals, and Walrus near Kotzebue, AK” (Eagle River, AK: Huntington Consulting and Fairbanks, AK: Alaska Department of Fish and Game, 2016), available at https://www.adfg.alaska.gov/static/research/programs/marinemammals/pdfs/2016_traditional_knowledge_kotzebue.pdf.
  69. Morgan Urquia, Wild Salmon Center, personal communication with authors via email, June 3, 2024, on file with authors.
  70. Bureau of Land Management, “ANCSA 17d)(1) Withdrawals: Draft Environmental Impact Statement.”
  71. Monte Mills and Martin Nie, “FAQs: Sovereign-to-Sovereign Cooperative Agreements,” University of Washington School of Law, available at https://lib.law.uw.edu/c.php?g=1329421&p=10063577 (last accessed June 2024).
  72. Ibid.
  73. Monte Mills and Martin Nie, “Bridges to a New Era: A Report on the Past, Present, and Potential Future of Tribal Co-Management on Federal Public Lands,” Public Land & Resources Law Review 44 (2) (2021), available at https://scholarworks.umt.edu/plrlr/vol44/iss1/2/.
  74. Tanana Chiefs Conference, Letter to Rachel Jones and Bettie Shelby (Bureau of Land Management), “Comments on the Notice of Intent to prepare an environmental impact statement to consider the impact of opening lands subject to ANCSA 17(d)(1) withdrawals over 28 million acres of land, water and wildlife across Alaska,” October 17, 2022; Chilkat Indian Village, “Scoping comments on proposed action to prepare an environmental impact statement to consider the effects of opening lands currently subject to withdrawals established pursuant to Section 17(d)(1) of the Alaska Native Claims Settlement Act (ANCSA) on lands within the Bay, Bering Sea-Western Interior, East Alaska, Kobuk-Seward Peninsula, and Ring of Fire planning areas,” October 2022, on file with authors.
  75. Liz Ruskin, “Tribes organize ‘First Indigenous Sovereign Habitat Tribal Conservation District’ from Bering Sea to Interior Alaska,” Alaska Public Media, December 28, 2023, available at https://alaskapublic.org/2023/12/28/tribes-organize-first-indigenous-sovereign-habitat-tribal-conservation-district-from-bering-sea-to-interior-alaska/.
  76. National Fish and Wildlife Foundation, “America the Beautiful Challenge: 2023 Grant Slate,” available at https://www.nfwf.org/sites/default/files/2023-11/NFWF-ATBC-20231113-GS_0.pdf (last accessed June 2024).
  77. SalmonState and Wild Salmon Center, “As Biden Administration Weighs Future of Alaska BLM Lands, Massive Wave of Support for Protections,” Press release, available at https://salmonstate.org/press-releases/as-biden-administration-weighs-future-of-alaska-blm-lands-massive-wave-of-support-for-protections (last accessed June 2024); Alaska Community Action on Toxics and others, Letter from 43 national, regional, and local organizations to BLM Director Tracy Stone-Manning and State Director Steve Cohn, “Re: Comments on Draft Environmental Impact Statement regarding ANCSA § 17(d)(1) withdrawals, Docket No. DOI-BLM-AK-0000-2022-0003-EIS,” February 14, 2024, on file with authors.

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Authors

Drew McConville

Senior Fellow

Alia Hidayat

Senior Policy Analyst, Conservation Policy

Team

Conservation Policy

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