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[revised, 2013-09-20]

State Joint Board comments on proposals due before next Wednesday, 25 Sept 2013. They may be submitted online at

http://www.adfg.alaska.gov/index.cfm?adfg=process.comments

. Please use your own words but see this example text.

State Joint Boards Proposal 40

Kodiak is currently a subsistence area.

The Joint Board established the current nonsubsistence areas in 1992. There have been no changes to the Kodiak community which warrant a change in its current subsistence area status from subsistence area to nonsubsistence area, under any of the criteria used by the Joint Board.

Kodiak remains an area where dependence upon subsistence items is a principle characteristic of the economy, culture, and way of life of the area.

Therefore, Proposal 40 should be opposed.


The proposals to create or change a nonsubsistence area are not required to specify which of the 12 criteria have changed, so even brief incomplete proposals must still go through the entire review process. Perhaps proposals to the Joint Board should be required to submit details to avoid insincere proposals?
1) the social and economic structure;
(2) the stability of the economy;
(3) the extent and the kinds of employment for wages, including full-time, part-time, temporary, and seasonal employment;
(4) the amount and distribution of cash income among those domiciled in the area or community;
(5) the cost and availability of goods and services to those domiciled in the area or community;
(6) the variety of fish and game species used by those domiciled in the area or community;
(7) the seasonal cycle of economic activity;
(8) the percentage of those domiciled in the area or community participating in hunting and fishing activities or using wild fish and game;
(9) the harvest levels of fish and game by those domiciled in the area or community;
(10) the cultural, social, and economic values associated with the taking and use of fish and game;
(11) the geographic locations where those domiciled in the area or community hunt and fish;
(12) the extent of sharing and exchange of fish and game by those domiciled in the area or community;
(13) additional similar factors the boards establish by regulation to be relevant to their determinations under this subsection.


See also http://www.adfg.alaska.gov/static-f/regulations/regprocess/pdfs/jbmeetings/jb-meet-2013/nonsubsistence_areas_report_2013.pdf [PDF] Technical Paper No. 386
… Therefore, this report updates information on the 12 characteristics modeled
after the 1992 staff report, and features the findings from the 1992 and …

Kodiak sections are here, Kodiak nonsubsistence_areas_report_2013



http://www.adfg.alaska.gov/index.cfm?adfg=process.commentinstruct (comments can be submitted from here.)
…List the Proposal Number

Written comments should indicate the proposal number to which the comments apply and should clearly indicate whether you “support” or “oppose” the proposal. This will help ensure written comments are correctly noted for the board members. If the comments support a modification in the proposal, please indicate “support as amended” and provide your preferred amendment in writing. You do not need to list the Alaska Administrative Code (AAC) number.

Please Explain Why You Support or Oppose the Proposal

This helps the board understand the rationale for your recommendation and identify factors that should be taken into account when acting on the proposal. A brief description consisting of a couple of sentences on why you support or oppose the proposal is sufficient.

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