The federal subsistence board is taking another look at the criteria for deciding whether or not an Alaskan community is rural.

Rural designation is a key step in granting subsistence priority to a community. Subsistence users, for instance, can harvest halibut on longlines, or dipnet sockeye, or hunt for deer after the closure of the sport season, if they live in a federally-designated rural community. Without it, residents have to follow sport rules and bag limits, which are typically much lower.

Historically, the board has used a population threshold to help it make a determination about a community’s rural status.

Sitka is the largest rural community in Southeast, for subsistence purposes. Members of the federal subsistence board held a hearing late last month to sample public opinion about Sitka’s rural designation.


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The official name for the process is “rural determination,” and it typically happens every ten years, after the US Census is released. But that’s not what is happening at the moment. Rather, the federal subsistence board has been directed by the secretaries of Interior and Agriculture to review and reconsider how it decides which Alaskan communities are rural, and to make recommendations for changes.

The 1980 Alaska National Interest Lands Conservation Act specifies that subsistence should be a priority in rural areas. The problem is that Congress didn’t actually define “rural” in the law. It simply excluded Alaska’s major cities at the time — Anchorage, Fairbanks, Juneau, and Ketchikan.

So the federal subsistence board has been using population guidelines ever since to determine a community’s status. Below 7,000 residents, a community is presumed to be rural. If a community has over 7,000 residents, it’s presumed to be urban, unless it has “rural characteristics.”

Make a public comment regarding your community’s rural/non-rural designation.

Sitka falls well above the threshold, but residents who turned out for the hearing were unanimous that Sitka retained significant rural characteristics.

Mayor Mim McConnell paraphrased an assembly resolution:

“Sitka is an isolated, rural community unconnected to any road system. And the vast majority of Sitka residents — over 90 percent — harvest large quantities of personal, traditional, and subsistence-use fish and game year round for both themselves and others, and consider this a basic part of their cultural, social, and economic identities. This use has been well-documented, and has nothing to do with how many people call Sitka home.”

McConnell called the threshold of 7,000 “arbitrary,” and urged the board to raise it to 11,000 — as has been suggested by the Secretary of Agriculture. That idea was seconded by other testimony.

Tribal elder Harvey Kitka observed that Sitka’s growth over the years has not fundamentally altered the lifestyle described by the mayor.

“Seems like we’ve always always had this type of style where we harvested and shared as a community. The non-Natives that have come to this community have learned to do the same thing over the years.”

The ANB’s Nels Lawson stressed that the correct use and respect of resources was integral to cultural education in Sitka. Tracy Gagnon, with the Sitka Conservation Society, testified that education crossed cultural boundaries.

“Generation after generation, skills are being passed on and shared with young people to continue and perpetuate living with the land. As SCS we are teaching youth how to identify wild foods, how to harvest, prepare, and preserve them. These skills create connection to place, community, responsibility, and keep us fed. Subsistence is our way of life. It is what defines our home.”

Representative Jonathan Kreiss-Tomkins argued that some aspects of rural were measurable. He thought roadlessness was a good start.

“The amount of roads a community has is also highly significant. I represent Prince of Wales Island — I drive around Prince of Wales Island when I’m down there. Sitka has 7 miles of road in each direction. Beyond that is unpeopled wilderness. Sitka is hemmed in by ocean, mountain, and forest. Beyond that is wildness, and I think that is what this community loves about Sitka — it feels wild, it is remote, and it’s rural.”

But no one made a stronger case for Sitka’s connection to food than resident Bob Sam. He told a story about being sick and hospitalized, and discovering that the remedy was not in a pill bottle.

“This food is medicine. It keeps me healthy. My weight (pounds table) is strong. I am TLINGIT. My food is what makes me what I am today.”

The review of the rural determination criteria stems, in part, from objections leveled by the state Department of Fish & Game following the last time Sitka received a rural designation in 2005. In a letter, Commissioner McKie Campbell wrote “I am deeply concerned that recent decisions affecting the status of subsistence users as rural or non-rural residents, and findings regarding customary and traditional subsistence uses, have been made without strict adherence to established processes and policies.” Sitka not only exceeded the 7,000 population threshold, Campbell argued, but the rural characteristics Sitka claimed, and the harvest patterns of the community, also had not been thoroughly evaluated.

To read McKie Campell’s letter to the Federal Subsistence Board, see page 45 of the 2007 Final Rule on Rural Determination.

The federal subsistence board is taking public comment on the review of the rural determination process through November 1. It plans to propose changes by April of next year.