U.S. Fish & Wildlife Service 

Revised Comprehensive Conservation Plan 

Innoko National Wildlife Refuge
U.S. Fish and Wildlife Service Mission Statement 

The mission of the U.S. Fish and Wildlife Service is 

working with others to conserve, protect, and enhance 

fish, wildlife, plants, and their habitats for the continuing 

benefit of the American people. 

National Wildlife Refuge System Mission Statement 

The mission of the National Wildlife Refuge System is to 

administer a national network of lands and waters for the 

conservation, management, and, where appropriate, 

restoration of the fish, wildlife, and plant resources and 

their habitats within the United States for the benefit of 

present and future generations of Americans. 

—National Wildlife Refuge System Improvement Act of 1997 

The comprehensive conservation plan details program planning levels that are 

substantially greater than current budget allocations and, as such, is for 

strategic planning and program prioritization purposes only. This plan does not 

constitute a commitment for staffing increases or funding for future Refugespecific land acquisitions, construction projects, or operational and 

maintenance increases. 
Table of Contents 

Table of Contents 

Title Page ..........................................................................................................................................................................i 

Dear Reader Letter.......................................................................................................................................................iii 

Table of Contents...........................................................................................................................................................ix 

Appendices....................................................................................................................................................................xiv 

Figures ..........................................................................................................................................................................xiv 

Tables ............................................................................................................................................................................xvi 

Inserts ...........................................................................................................................................................................xvi 

Acronyms and Abbreviations ...................................................................................................................................xviii 

1. Introduction .................................................................................................................................................. 1-1

1.1 Purpose and Need for Action ................................................................................................................ 1-1

1.2 Planning Context..................................................................................................................................... 1-3

1.2.1 The U.S. Fish and Wildlife Service .................................................................................................. 1-3

1.2.2 The National Wildlife Refuge System ............................................................................................. 1-3

1.2.3 Principles of Refuge Management................................................................................................... 1-4

1.3 Legal and Policy Guidance and State Coordination........................................................................... 1-5

1.3.1 Legal Guidance ................................................................................................................................... 1-5

1.3.2 Policy Guidance................................................................................................................................... 1-6

1.3.3 State of Alaska Coordination ............................................................................................................ 1-6

1.4 Refuge Purposes and Vision Statement............................................................................................... 1-7

1.4.1 Refuge Purposes................................................................................................................................. 1-7

1.4.2 Refuge Vision Statement................................................................................................................... 1-8

1.5 Refuge Overview ..................................................................................................................................... 1-8

1.5.1 Historical Perspective and Refuge Establishment........................................................................ 1-8

1.5.2 Physical Environment...................................................................................................................... 1-10

1.5.3 Biological Resources ........................................................................................................................ 1-10

1.5.4 Human Uses...................................................................................................................................... 1-12

1.6 Special Values ........................................................................................................................................ 1-12

1.6.1 Waterfowl Habitat............................................................................................................................ 1-12

1.6.2 Moose Habitat................................................................................................................................... 1-13

1.6.3 Gold Rush History............................................................................................................................ 1-13

1.6.4 Iditarod National Historic Trail ..................................................................................................... 1-13

1.6.5 Natural Processes............................................................................................................................. 1-14

1.6.6 Wilderness Values ............................................................................................................................ 1-14

1.7 Planning Requirements........................................................................................................................ 1-15

1.8 The Planning Process ........................................................................................................................... 1-15

1.8.1 Design the Process ........................................................................................................................... 1-16

1.8.2 Initiate Public Involvement and Scoping ...................................................................................... 1-17

1.8.3 Determine Significant Issues.......................................................................................................... 1-18

1.8.4 Develop and Analyze Alternatives ................................................................................................. 1-18

1.8.5 Prepare Draft Plan and Environmental Assessment.................................................................. 1-18

1.8.6 Prepare and Adopt a Final Plan..................................................................................................... 1-18

1.8.7 Implement Plan, Monitor, and Evaluate....................................................................................... 1-19

1.8.8 Review and Revise the Plan............................................................................................................ 1-19

1.9 Issues ...................................................................................................................................................... 1-19

1.9.1 How will the refuge address intensifying competition to harvest moose? ............................... 1-19

1.9.2 How will the refuge manage air taxis to balance demand for visitor access with user 

experience and resource protection? ............................................................................................. 1-20

1.9.3 How will the refuge address threats to water quality from off-refuge mining?...................... 1-20

1.9.4 How will the refuge enhance its relationship with communities?.............................................. 1-21

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan ix 
U.S. Fish and Wildlife Service Mission Statement 

The mission of the U.S. Fish and Wildlife Service is 

working with others to conserve, protect, and enhance 

fish, wildlife, plants, and their habitats for the continuing 

benefit of the American people. 

National Wildlife Refuge System Mission Statement 

The mission of the National Wildlife Refuge System is to 

administer a national network of lands and waters for the 

conservation, management, and, where appropriate, 

restoration of the fish, wildlife, and plant resources and 

their habitats within the United States for the benefit of 

present and future generations of Americans. 

—National Wildlife Refuge System Improvement Act of 1997 

The comprehensive conservation plan details program planning levels that are 

substantially greater than current budget allocations and, as such, is for 

strategic planning and program prioritization purposes only. This plan does not 

constitute a commitment for staffing increases or funding for future Refugespecific land acquisitions, construction projects, or operational and 

maintenance increases. 
Revised 

Comprehensive Conservation Plan 

for the 

Innoko National Wildlife Refuge 

November 2008 

Prepared by: 

Alaska Region 

U.S. Fish and Wildlife Service 

U.S. Fish and Wildlife Service U.S. Fish and Wildlife Service 

Innoko National Wildlife Refuge Division of Conservation Planning & Policy 

P.O. Box 69 1011 East Tudor Road, MS 231 

McGrath, AK 99627 Anchorage, AK 99503 



United States Department of the Interior

FISH AND WILDLIFE SERVICE 

National Wildlife Refuge System-Alaska 

Division of Conservation Planning & Policy 

1011 East Tudor Road – MS 231 

Anchorage, Alaska 99503 

(907) 786-3357

Dear Reader: 

This Revised Comprehensive Conservation Plan (Plan) for Innoko National Wildlife Refuge will 

guide management of the Refuge for the next 15 years. The Plan provides a vision, goals, and 

objectives for future management of the Refuge. It addresses the issues raised during public 

scoping and comments received during public review of the draft plan. Based upon comments 

received, we adopted Alternative B (Preferred Alternative) from the draft plan. 

Comments received during the public review of the draft plan and our responses to them are 

included in this document in Appendix J. The environmental assessment and draft plan are on 

file with our offices in McGrath and Anchorage. 

Draft compatibility determinations for Innoko National Wildlife Refuge were included in the 

draft revised comprehensive conservation plan and comments were accepted as part of the 

review of this plan. Our responses to comments on those draft compatibility determinations can 

also be found in Appendix J. The final signed compatibility determinations are in Appendix F. 

A discussion of compatibility determinations can be found in Chapter 2, section 2.4.6. More 

information on the compatibility process can be found at the refuge office or at 

http://alaska.fws.gov/nwr/planning/completed.htm. 

You may obtain a copy of the Plan, a summary, or a compact disk containing both at the offices 

listed below. You may view the Draft Plan online at 

http://www.r7.fws.gov/nwr/planning/plans.htm. 

Requests for copies, CD-ROMs or Request for further information 

further information should be directed to: about the Refuge should be directed to: 

Planning Team Leader Refuge Manager 

U.S. Fish and Wildlife Service Innoko National Wildlife Refuge 

1011 E. Tudor Road, MS-231 P.O. Box 69 

Anchorage, AK 99503 McGrath, AK 99627 

907-786-3357 907-524-3251 

fw7_innoko_planning@fws.gov Innoko@fws.gov

 http://innoko.fws.gov/ 

We thank everyone who participated in the planning and public involvement process. 

Your comments helped us prepare a better plan for the future of Innoko Refuge. 

Table of Contents 

1.9.5 How will the refuge monitor and address the effects of climate change? ................................ 1-21

1.9.6 How will the refuge respond to the Alaska Department of Fish and Game’s proposed 

wood bison project? .......................................................................................................................... 1-22

1.9.7 How will the refuge integrate regional policies and guidelines into its management?........... 1-22

1.10 References.............................................................................................................................................. 1-22

2. Goals, Objectives, and Management Direction ........................................................................................ 2-1

2.1 Goals and Objectives............................................................................................................................... 2-1

2.2 Regional Management Direction Introduction................................................................................. 2-26

2.3 Management Categories ...................................................................................................................... 2-27

2.3.1 Intensive Management .................................................................................................................... 2-27

2.3.2 Moderate Management.................................................................................................................... 2-28

2.3.3 Minimal Management ...................................................................................................................... 2-28

2.3.4 Wild and Scenic Rivers .................................................................................................................... 2-31

2.3.5 Wilderness ......................................................................................................................................... 2-31

2.3.6 Special Management ........................................................................................................................ 2-32

2.3.6.1 Management of Selected Lands .......................................................................................... 2-32

2.4 Management Policies and Guidelines................................................................................................. 2-32

2.4.1 Introduction....................................................................................................................................... 2-32

2.4.2 Management Emergencies ............................................................................................................. 2-33

2.4.3 Land Exchanges and Acquisitions ................................................................................................. 2-33

2.4.4 Land Protection Plans ..................................................................................................................... 2-33

2.4.5 Appropriate Refuge Uses................................................................................................................ 2-34

2.4.6 Compatibility Determinations ........................................................................................................ 2-35

2.4.7 Mitigation........................................................................................................................................... 2-36

2.4.8 Cooperation and Coordination with Others.................................................................................. 2-37

2.4.8.1 Federal, State, and Local Governments............................................................................. 2-37

2.4.8.2 Tribes and Native American Organizations....................................................................... 2-38

2.4.8.3 Owners of Refuge Inholdings and Adjacent Lands.......................................................... 2-38

2.4.8.4 Fish and Wildlife Service Jurisdiction over Waters within Innoko Refuge.................. 2-38

2.4.8.5 Other Constituencies............................................................................................................. 2-38

2.4.9 Ecosystem and Landscape Management...................................................................................... 2-38

2.4.9.1 Air Quality .............................................................................................................................. 2-39

2.4.9.2 Water Resources (Hydrology) Management..................................................................... 2-39

2.4.9.3 Visual Resource Management ............................................................................................. 2-40

2.4.9.4 Cultural, Historical, and Paleontological Resources ........................................................ 2-40

2.4.10 Fish and Wildlife Habitat Management........................................................................................ 2-41

2.4.10.1 Habitat Management ............................................................................................................ 2-41

2.4.10.2 Fire Management .................................................................................................................. 2-42

2.4.11 Fish and Wildlife Population Management .................................................................................. 2-43

2.4.11.1 Wildlife Inventory and Monitoring Plan (I&M Plan)....................................................... 2-43

2.4.11.2 Scientific Peer Review .......................................................................................................... 2-43

2.4.11.3 Compliance with the Animal Welfare Act .......................................................................... 2-44

2.4.11.4 Marking and Banding ........................................................................................................... 2-44

2.4.11.5 Threatened or Endangered Species ................................................................................... 2-44

2.4.11.6 Reintroductions...................................................................................................................... 2-44

2.4.11.7 Fish and Wildlife Control ..................................................................................................... 2-45

2.4.11.8 Management of Non-native, Invasive, and Pest Species ................................................. 2-45

2.4.11.9 Disease Prevention and Control.......................................................................................... 2-46

2.4.11.10 Fishery Restoration .............................................................................................................. 2-46

2.4.11.11 Fishery Enhancement........................................................................................................... 2-47

2.4.12 Subsistence Use Management........................................................................................................ 2-47

2.4.12.1 Access for Subsistence Purposes......................................................................................... 2-48

x Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Table of Contents 

2.4.12.2 Section 810 Evaluations ........................................................................................................ 2-48

2.4.13 Public Access and Transportation Management ......................................................................... 2-48

2.4.13.1 Snowmachines, Motorboats, Airplanes, and Nonmotorized Surface 

Transportation ....................................................................................................................... 2-48

2.4.13.2 Off-Road Vehicles .................................................................................................................. 2-48

2.4.13.3 Helicopters.............................................................................................................................. 2-48

2.4.13.4 Access to Inholdings.............................................................................................................. 2-49

2.4.13.5 Temporary Access ................................................................................................................. 2-49

2.4.13.6 Subsistence Access ................................................................................................................ 2-49

2.4.13.7 Transportation and Utility Systems ................................................................................... 2-49

2.4.13.8 State Transportation Planning ............................................................................................ 2-50

2.4.13.9 RS 2477 Rights-of-Way......................................................................................................... 2-50

2.4.13.10 17(b) Easements..................................................................................................................... 2-50

2.4.13.11 Navigation Aids and other Facilities .................................................................................. 2-51

2.4.14 Recreation and Other Public Use................................................................................................... 2-51

2.4.15 Public Use Facilities......................................................................................................................... 2-52

2.4.15.1 Cabins...................................................................................................................................... 2-52

2.4.15.2 Temporary Facilities for the Taking of Fish and Wildlife ............................................... 2-52

2.4.16 Outreach............................................................................................................................................. 2-53

2.4.17 Commercial Use Management ....................................................................................................... 2-53

2.4.17.1 Commercial Recreation Services......................................................................................... 2-54

2.4.17.2 Mineral Exploration and Development .............................................................................. 2-54

2.4.17.3 Commercial Fishing and Related Facilities....................................................................... 2-55

2.4.17.4 Commercial Harvest of Timber and Firewood.................................................................. 2-55

2.4.17.5 Commercial Gathering of Other Resources....................................................................... 2-55

2.4.17.6 Commercial Filming and Recording Activities ................................................................. 2-55

2.4.17.7 Other Commercial Uses........................................................................................................ 2-56

2.4.18 Environmental Contaminants Identification and Cleanup......................................................... 2-56

2.4.19 Management of Designated Wilderness ....................................................................................... 2-56

2.4.20 Administration of Innoko National Wildlife Refuge.................................................................... 2-57

2.4.20.1 Administrative Sites and Visitor Facilities ........................................................................ 2-57

2.4.20.2 Refuge Management Plans .................................................................................................. 2-58

2.4.21 Alaska Mineral Resource Assessment Program.......................................................................... 2-59

2.5 Management Categories Table ........................................................................................................... 2-59

2.5.1 Introduction....................................................................................................................................... 2-59

2.5.1.1 Definitions for Management Categories Table ................................................................. 2-60

2.6 References.............................................................................................................................................. 2-74

3. Refuge Resources......................................................................................................................................... 3-1

3.1 Geographic Setting.................................................................................................................................. 3-1

3.1.1 Land Status ......................................................................................................................................... 3-1

3.1.1.1 Village Native Corporation Land .......................................................................................... 3-1

3.1.1.2 Regional Native Corporation Lands..................................................................................... 3-2

3.1.1.3 Native Allotments.................................................................................................................... 3-2

3.1.1.4 Other Private Lands................................................................................................................ 3-5

3.1.1.5 State of Alaska ......................................................................................................................... 3-5

3.1.1.6 Submerged Lands.................................................................................................................... 3-5

3.1.1.7 17(b) Easements....................................................................................................................... 3-5

3.1.1.8 RS 2477 Rights-of-Way........................................................................................................... 3-6

3.1.1.9 Environmental Contaminants (Including Water Contaminants) ..................................... 3-6

3.1.2 Ecosystems.......................................................................................................................................... 3-7

3.2 Physical Environment .......................................................................................................................... 3-11

3.2.1 Climate ............................................................................................................................................... 3-11

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan xi 
Table of Contents 

3.2.2 Landforms ......................................................................................................................................... 3-11

3.2.3 Geology............................................................................................................................................... 3-13

3.2.4 Soils and Permafrost........................................................................................................................ 3-14

3.2.5 Oil and Gas Occurrences and Potential ......................................................................................... 3-15

3.2.6 Minerals ............................................................................................................................................. 3-15

3.2.7 Water Resources .............................................................................................................................. 3-16

3.2.7.1 Water Quality ......................................................................................................................... 3-29

3.2.8 Effects of Fire ................................................................................................................................... 3-29

3.2.9 Fire Regime of the Innoko Refuge ................................................................................................ 3-37

3.2.9.1 Fire Occurrence and Frequency ......................................................................................... 3-37

3.2.9.2 Fire Size .................................................................................................................................. 3-38

3.2.9.3 Fire Season............................................................................................................................. 3-38

3.2.9.4 Fire Return Interval for Alaska .......................................................................................... 3-39

3.2.9.5 Approximate Fire Return Interval and Fire Rotation for the Innoko Refuge............. 3-39

3.2.9.6 Appropriate Management Response .................................................................................. 3-39

3.2.9.7 Fire Effects Monitoring and Evaluation ............................................................................ 3-40

3.2.9.8 Affected Villages Around the Innoko Refuge.................................................................... 3-40

3.3 Biological Environment........................................................................................................................ 3-40

3.3.1 Vegetation.......................................................................................................................................... 3-40

3.3.1.1 Habitats................................................................................................................................... 3-41

3.3.1.2 Non-Native Invasive Plants ................................................................................................. 3-49

3.3.2 Fish and Wildlife............................................................................................................................... 3-51

3.3.2.1 Fish .......................................................................................................................................... 3-51

3.3.2.2 Amphibians ............................................................................................................................. 3-54

3.3.2.3 Birds ........................................................................................................................................ 3-54

3.3.2.4 Mammals................................................................................................................................. 3-59

3.3.2.5 Non-Native Invasive Insects................................................................................................ 3-73

3.3.2.6 Threatened, Endangered, and Sensitive Wildlife ............................................................. 3-73

3.3.3 Concerns Regarding Fish, Wildlife, and their Habitats ............................................................. 3-75

3.3.3.1 Climate Change...................................................................................................................... 3-75

3.3.3.2 Invasive Species..................................................................................................................... 3-77

3.3.3.3 Forest Defoliators.................................................................................................................. 3-78

3.3.3.4 Mineral Extraction ................................................................................................................ 3-78

3.3.3.5 Wildlife Disease...................................................................................................................... 3-79

3.3.3.6 Moose....................................................................................................................................... 3-79

3.3.3.7 Predator Control.................................................................................................................... 3-80

3.3.3.8 Wood Bison............................................................................................................................. 3-80

3.3.3.9 Wood Frog .............................................................................................................................. 3-80

3.3.3.10 Fish .......................................................................................................................................... 3-80

3.4 Human Environment............................................................................................................................ 3-82

3.4.1 Area History...................................................................................................................................... 3-82

3.4.1.1 Prehistory ............................................................................................................................... 3-82

3.4.1.2 Ethnography .......................................................................................................................... 3-83

3.4.1.3 History..................................................................................................................................... 3-84

3.4.1.4 Archaeological and Historic Sites........................................................................................ 3-85

3.4.2 Population and Settlement Patterns.............................................................................................. 3-86

3.4.2.1 Overview.................................................................................................................................. 3-86

3.4.2.2 Principle Refuge-Affected Communities............................................................................ 3-86

3.4.2.3 Social Infrastructure ............................................................................................................. 3-90

3.4.3 Regional Access ................................................................................................................................ 3-91

3.4.4 Economy ............................................................................................................................................ 3-92

3.4.5 Subsistence ........................................................................................................................................ 3-92

3.4.6 Recreation.......................................................................................................................................... 3-94

xii Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Table of Contents 

3.4.6.1 Overview.................................................................................................................................. 3-94

3.4.6.2 Moose Hunting....................................................................................................................... 3-94

3.4.6.3 Fishing................................................................................................................................... 3-103

3.4.6.4 Environmental Education and Interpretation Programs.............................................. 3-103

3.5 Wilderness Values............................................................................................................................... 3-104

3.5.1 Characteristics Common to All Units.......................................................................................... 3-106

3.5.2 Designated Wilderness Unit......................................................................................................... 3-106

3.5.3 Wapoo Hills Unit ............................................................................................................................ 3-106

3.5.4 Kaiyuh Mountains Unit ................................................................................................................. 3-109

3.6 River Values......................................................................................................................................... 3-109

3.6.1 Introduction..................................................................................................................................... 3-109

3.6.2 Outstandingly Remarkable Values .............................................................................................. 3-109

3.6.2.1 Scenic Values........................................................................................................................ 3-110

3.6.2.2 Recreation Values................................................................................................................ 3-110

3.6.2.3 Wildness Values ................................................................................................................... 3-110

3.6.2.4 Geologic Values .................................................................................................................... 3-110

3.6.2.5 Fish Values ........................................................................................................................... 3-110

3.6.2.6 Wildlife Values ..................................................................................................................... 3-113

3.6.2.7 Cultural Values .................................................................................................................... 3-113

3.6.2.8 Historic Values..................................................................................................................... 3-113

3.6.2.9 Prehistoric Values................................................................................................................ 3-113

3.6.2.10 Other Values......................................................................................................................... 3-113

3.6.3 Rivers and River Segments .......................................................................................................... 3-114

3.6.3.1 Yukon River.......................................................................................................................... 3-114

3.6.3.2 Innoko River......................................................................................................................... 3-114

3.6.3.3 Dishna River......................................................................................................................... 3-115

3.6.3.4 Hather and Magitchlie Creeks........................................................................................... 3-115

3.6.3.5 Iditarod River....................................................................................................................... 3-116

3.6.3.6 Shageluk/Holikachuk Slough System............................................................................... 3-117

3.7 Refuge Infrastructure and Administration ..................................................................................... 3-117

3.7.1 Administrative Facilities ............................................................................................................... 3-117

3.7.2 Staffing............................................................................................................................................. 3-117

3.8 References Cited ................................................................................................................................. 3-118

4. Implementation and Monitoring ................................................................................................................ 4-1

4.1 Step-Down Plans ..................................................................................................................................... 4-1

4.1.1 Inventory and Monitoring (I&M Plan)............................................................................................ 4-1

4.1.2 Fisheries Management Plan ............................................................................................................. 4-2

4.1.3 Cultural Resource Guide ................................................................................................................... 4-2

4.1.4 Fire Management Plan...................................................................................................................... 4-2

4.1.5 Land Protection Plan ......................................................................................................................... 4-3

4.1.6 Station Safety Plan and Occupant Emergency Plan ..................................................................... 4-3

4.1.7 Water Resources Inventory and Assessment: Plan of Study ...................................................... 4-3

4.1.8 Spill Prevention, Control, and Countermeasure Plan................................................................... 4-3

4.1.9 Visitor Services Plan .......................................................................................................................... 4-3

4.1.10 Wilderness Stewardship Plan........................................................................................................... 4-3

4.2 Partnership Opportunities..................................................................................................................... 4-4

4.3 Monitoring and Evaluation .................................................................................................................... 4-5

4.4 Plan Amendment and Revision ............................................................................................................. 4-5

4.5 Funding and Personnel Requirements ................................................................................................ 4-6

4.6 References Cited ..................................................................................................................................... 4-6

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan xiii 
Table of Contents 

5. Consultation and Coordination with Others............................................................................................. 5-1

5.1 Interagency agreements ........................................................................................................................ 5-1

5.1.1 Wildland fire suppression services................................................................................................... 5-1

5.1.2 Radio repeater sites ........................................................................................................................... 5-1

5.1.3 Others................................................................................................................................................... 5-1

5.2 Section 7 compliance ............................................................................................................................... 5-1

Appendices 

A Legal Guidance and Planning Coordination 

B Coordination with the State of Alaska 

C Predator Management 

D Glossary 

E Yukon-Innoko Moose Management Plan 

F Compatibility Determinations 

G Species Lists 

H Landcover 

I Preparers 

J Response to Comments 

K Finding of No Significant Impact 

Figures 

Figure 1-1. Refuge location within Alaska .........................................................................................................1-1

Figure 1-2. Innoko Refuge location within region.............................................................................................1-2

Figure 1-3. The 16 National Wildlife Refuges in Alaska ..................................................................................1-4

Figure 1-4. Alaska game management subunits in relation to the Innoko Refuge ......................................1-9

Figure 1-5. Hather Creek on Innoko National Wildlife Refuge (Photo: Robin Corcoran, 

USFWS)............................................................................................................................................1-10

Figure 1-6. Alaska bull moose (Photo: Donna Dewhurst, USFWS).............................................................1-11

Figure 1-7. Refuge employee holding northern pike (Photo: Robin Corcoran, USFWS).........................1-12

Figure 1-8. Waterfowl and moose habitat (USFWS photo)...........................................................................1-13

Figure 1-9. Natural processes and wilderness—fire in the Innoko landscape (USFWS photo)..............1-14

Figure 1-10. The Planning Process .....................................................................................................................1-16

Figure 2-1. Innoko Refuge management categories.......................................................................................2-29

Figure 3-1. Land status, easements, and rights-of-way ...................................................................................3-3

Figure 3-2. Ecoregions..........................................................................................................................................3-9

Figure 3-3. Locations of snow poles on Innoko Refuge..................................................................................3-12

Figure 3-4. Average snow depth recorded on Innoko Refuge, 1996–2006 (see Figure 3-3 for 

locations of snow poles)...................................................................................................................3-13

Figure 3-5. Generalized surface geology ..........................................................................................................3-17

Figure 3-6. Soil associations on Innoko Refuge...............................................................................................3-19

Figure 3-7. Distribution of permafrost on Innoko Refuge.............................................................................3-21

Figure 3-8. Mineral occurrences........................................................................................................................3-23

Figure 3-9. Placer & mining districts................................................................................................................3-25

Figure 3-10. Successional trajectories in interior Alaska along soil temperature and moisture 

gradients (Chapin 2004)..................................................................................................................3-30

xiv Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Table of Contents 

Figure 3-11. Hypothetical patterns of bird species response dependent on 3 distinct structural 

habitat types to a substantial habitat disturbance (Oliver et al. 1998).....................................3-32

Figure 3-12. Wildfire occurrence (1957–2006) ...................................................................................................3-35

Figure 3-13. Innoko area natural fire starts, 1957–2007 ..................................................................................3-37

Figure 3-14. Acres burned on the Innoko Refuge, 1957–2007.........................................................................3-38

Figure 3-15. 1981 Land cover...............................................................................................................................3-43

Figure 3-16. 1991 Land cover...............................................................................................................................3-45

Figure 3-17. Proportion of vegetation cover classes derived from 1981 Landsat 3 imagery (Talbot 

and Markon 1988) and 1991 Landsat 7 imagery (Bureau of Land Management et al. 

2002) for Innoko National Wildlife Refuge, Alaska. The 1991 shrub class includes 

shrub and dwarf shrub classes of Talbot and Markon (1988)....................................................3-48

Figure 3-18. Lichen is an important forage item for caribou; the extent of pure lichen habitat on 

Innoko is very limited and usually occurs as an understory plant in several forest 

and shrub plant communities. (Photo W. Raften, USFWS)......................................................3-49

Figure 3-19. Chickweed (left) and pineappleweed (right) are two of the five non-native invasive 

plant species found at the Innoko Refuge administrative site. (Photos S. Kovach, 

USFWS.)...........................................................................................................................................3-50

Figure 3-20. Bluegrass (left) and common plantain (right) are non-native invasive plant species 

found at the Innoko Refuge administrative site. (Photos: bluegrass, University of 

Kentucky; plantain, S. Kovach, USFWS) ....................................................................................3-50

Figure 3-21. Lambsquarter found growing along the Innoko River. (Photo S. Kovach, USFWS)...........3-51

Figure 3-22. The wood frog is the only amphibian found on Innoko Refuge and has the ability to 

freeze as much as 35 to 45 percent of its body during the cold winter months. (Photo 

USFWS)............................................................................................................................................3-54

Figure 3-23. Locations where moose were observed during February/March census efforts on 

Innoko Refuge in 1994, 1996, 1998, and 2004...............................................................................3-59

Figure 3-24. Moose count areas ...........................................................................................................................3-63

Figure 3-25. 1986 Moose capture locations.........................................................................................................3-65

Figure 3-26. Approximate Distribution of the Beaver Mountain Caribou Herd ..........................................3-68

Figure 3-27. Adult beaver carrying a willow back to a cache. (Photo S. Hillebrand, USFWS)..................3-71

Figure 3-28. Typical beaver dam on a smaller stream. (Photo USFWS)......................................................3-71

Figure 3-29. The blackpoll warbler is on the list of “Species of Special Concern” by the State of 

Alaska and is a priority species for conservation by the Boreal Partners In Flight 

(2006). (Photo USFWS) ..................................................................................................................3-75

Figure 3-30. Iditarod National Historic Trail ....................................................................................................3-87

Figure 3-31. Game management subunits and the Paradise Controlled Use Area......................................3-95

Figure 3-32. Big Game Guide Areas....................................................................................................................3-97

Figure 3-33. Uniform coding units used for non-local moose harvest analysis.............................................3-99

Figure 3-34. Residency of non-local moose hunters using Innoko Refuge, 1983–2006..............................3-101

Figure 3-35. Proportion of non-local moose hunters using boat or aircraft to access hunting areas 

on Innoko Refuge, 1983–2006 ......................................................................................................3-102

Figure 3-36. Number of moose harvested on Innoko Refuge by non-local hunters, 1983–2006...............3-102

Figure 3-37. Three-year running mean moose harvest success rate by non-local hunters on 

Innoko Refuge, 1983–2006. Total indicates the total harvest success rate by nonlocal hunters combined. ................................................................................................................3-103

Figure 3-38. Round Mountain science camp lecture, 2007 session (Photo Jerry McDonnell) ..................3-104

Figure 3-39. Innoko Wilderness Area and Wilderness study area units .....................................................3-107

Figure 3-40. Rivers with special values.............................................................................................................3-111

Figure 3-41. Yukon River in winter (Photo Robin Corcoran, USFWS).......................................................3-114

Figure 3-42. Innoko River (Photo Leon Kolankiewicz) ..................................................................................3-115

Figure 3-43. Hather Creek (Photo Robin Corcoran, USFWS) .....................................................................3-116

Figure 3-44. Iditarod River (Photo Leon Kolankiewicz)................................................................................3-116

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan xv 
Table of Contents 

Tables 

Table 2-1. Required step-down management plans for Innoko National Wildlife Refuge......................2-59

Table 2-2. Activities, public uses, commercial uses, and facilities by management category .................2-62

Table 3-1. Surface land statusa of the Innoko Refuge, as of March 2007 ....................................................3-2

Table 3-2. Approximate mileage of State of Alaska claimed RS 2477 rights-of way within the 

Innoko Refuge*..................................................................................................................................3-6

Table 3-3. Climate data from the Anvik Airport automated weather observation station for 

November 1993 through November 2007* .................................................................................3-11

Table 3-4. Historical and present mineral production 1898–2004. Map numbers refer to 

number found in Figure 3-8. Source: U.S. Geological Survey Alaska Resource Data 

Files (Dashevsky 2002a, Dashevsky 2002b, Dashevsky 2002c, Bundtzen 2004) ....................3-24

Table 3-5. Size (in acres) of lakes found on the Innoko Refuge...................................................................3-27

Table 3-6. Major water bodies within Innoko Refuge ..................................................................................3-28

Table 3-7. Landcover classes and subclasses derived from 1981 Landsat 3 imagery (Talbot and 

Markon 1988)....................................................................................................................................3-42

Table 3-8. Landcover classes and subclasses derived from 1991 Landsat 7 imagery (Bureau of 

Land Management et al. 2002) ......................................................................................................3-47

Table 3-9. Bird projects conducted on Innoko Refuge .................................................................................3-55

Table 3-10. Results of the molting goose aerial surveys on Innoko Refuge................................................3-56

Table 3-11. Numbers of white-fronted geese leg-banded on Innoko Refuge..............................................3-57

Table 3-12. Number of ducks banded on Innoko Refuge ...............................................................................3-57

Table 3-13. Moose population and density (moose/mi2) estimates for Innoko Refuge..............................3-60

Table 3-14. Moose winter browse species used on Innoko Refuge ...............................................................3-62

Table 3-15. Threat ranking of invasive plant species known on Innoko Refuge. Threat ranking 

from the Alaska Natural Heritage Program (2006). See appendix G for scientific 

names.................................................................................................................................................3-78

Table 3-16. Population trends in the Innoko Refuge area communities ......................................................3-86

Table 3-17. ANSCA Village Corporations in the vicinity of the Innoko Refuge.........................................3-91

Table 3-18. Reported guided fishing use on the Innoko Refuge, 1995–2005 .............................................3-104

Table 4-1. Budget needs......................................................................................................................................4-6

Table 4-2. Staffing needs beyond current levels..............................................................................................4-6

Table 4-3. Examples of inventory or monitoring questions and possible management actions ...............4-7

Table G-1. Vascular plant currently known to exist on Innoko Refuge based on collections and 

field studies........................................................................................................................................G-1 

Table G-2. Lichens currently known to exist on the Innoko Refuge based on collections and field 

studies ..............................................................................................................................................G-11 

Table G-3. Bryoflora currently known to exist on the Innoko Refuge based on collections and 

field studies......................................................................................................................................G-12 

Table G-4. Mammals currently known to exist on the Innoko Refuge based on collections and 

field studies......................................................................................................................................G-14 

Table G-5. Fish of the Innoko Refuge, listed in taxonomic order...............................................................G-16 

Table G-6. Amphibians of the Innoko Refuge................................................................................................G-16 

Table G-7. Birds known to exist on the Innoko Refuge based on field studies.........................................G-17 

Table H-1 Comparison of Landcover classes and subclasses used in innoko NWR................................. H-1 

Inserts 

Figure 2-1. Innoko Refuge management categories.......................................................................................2-29

Figure 3-1. Land status, easements, and rights-of-way ...................................................................................3-3

Figure 3-2. Ecoregions..........................................................................................................................................3-9

Figure 3-5. Generalized surface geology ..........................................................................................................3-17

Figure 3-6. Soil associations on Innoko Refuge...............................................................................................3-19

Figure 3-7. Distribution of permafrost on Innoko Refuge.............................................................................3-21

xvi Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Table of Contents 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan xvii 

Figure 3-9. Placer & mining districts................................................................................................................3-25

Figure 3-12. Wildfire occurrence (1957–2006) ...................................................................................................3-35

Figure 3-15. 1981 Land cover...............................................................................................................................3-43

Figure 3-16. 1991 Land cover...............................................................................................................................3-45

Figure 3-24. Moose count areas ...........................................................................................................................3-63

Figure 3-30. Iditarod National Historic Trail ....................................................................................................3-87

Figure 3-32. Big Game Guide Areas....................................................................................................................3-97

Figure 3-39. Innoko Wilderness Area and Wilderness study area units .....................................................3-107

Figure 3-40. Rivers with special values.............................................................................................................3-111

Figure 3-41. Yukon River in winter (Photo Robin Corcoran, USFWS).......................................................3-114

Figure 3-44. Iditarod River (Photo Leon Kolankiewicz)................................................................................3-116
Acronyms and Abbreviations 

Acronyms and Abbreviations 

AC Advisory Committee 

ADF&G Alaska Department of Fish and Game 

AFS Alaska Fire Service 

ALMS Alaska Landbird Monitoring System 

ANILCA Alaska National Interest Lands Conservation Act 

ANCSA Alaska Native Claims Settlement Act 

AMR Appropriate Management Response 

ARG American Reclamation Group, LLC 

BBS Breeding Bird Survey 

BLM Bureau of Land Management 

Boreal PRISM Program for Regional and International Shorebird Monitoring 

BMP Best Management Practice 

BRD Biological Resources Division 

BLM/AFS Bureau of Land Management/Alaska Fire Service 

CE Categorical Exclusion 

DOI Department of the Interior 

EA Environmental Assessment 

EIS Environmental Impact Statement 

FLPMA Federal Land Policy and Management Act 

FMP Fire Management Plan or Fisheries Management Plan 

FONSI Finding of No Significant Impact 

FRCC Fire Regime/Condition Class 

FY Fiscal Year 

GASH Grayling, Anvik, Shageluk, Holy Cross 

GIS Geographic Information System 

GMU Game Management Unit 

IACUC Institutional Animal Care and Use Committee 

IASD Iditarod Area School District 

IC Interim Conveyance 

IM Intensive Management (State) 

I&M Inventory and Monitoring 

LANDFIRE Landscape Fire and Resource Management and Planning Tools 

LOD Level of Detection 

MIST Minimum Impact Suppression Tactics 

MRLC Multi-Resolution Land Characteristics 

NAWBPS North American Waterfowl Breeding Pair Survey 

NCBP National Contaminants Biomonitoring Program 

NEPA National Environmental Policy Act 

NFDRS National Fire Danger Rating System 

NFFL National Fire Fuel Laboratory 

NMFS National Marine Fisheries Service 

NRCS Natural Resource Conservation Service 

ORV Off-road Vehicle 

RAC Regional Advisory Council 

RAWS Remote Automated Weather Station 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan xviii 
Acronyms and Abbreviations 

xix Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

RDI Recordable Disclaimer of Interest 

RIT Refuge Information Technician 

RONS Refuge Operating Needs System 

SAMMS Service Asset Maintenance Management System 

STEP Student Career Experience Program 

USDOI United States Department of the Interior 

USFWS U.S. Fish and Wildlife Service 

USGS U.S. Geological Survey 

USGS-BRD U.S. Geological Survey, Biological Resources Division 

WFIP Wildland Fire Implementation Plan 

WFSA Wildland Fire Situation Analysis 

YIWG Yukon-Innoko Moose Management Working Group 
Chapter 1: Introduction 

1. Introduction 

This document is the Final Revised Comprehensive Conservation Plan (Revised Conservation 

Plan; Revised Plan, Plan) for management of Innoko National Wildlife Refuge (Innoko Refuge; 

refuge). It replaces the management direction for Innoko Refuge described in the original Innoko 

National Wildlife Refuge Final Comprehensive Conservation Plan/Environmental Impact 

Statement/Wilderness Review (1987 Innoko Conservation Plan or 1987 Conservation Plan; 

USFWS 1987a) and associated Record of Decision (USFWS 1987b) adopted in 1987. 

The U.S. Fish and Wildlife Service (Service) administers approximately 3,816,000 acres as the 

Innoko Refuge. This chapter provides background information that establishes the framework 

used to develop this document, including the purpose of and need for the Plan; an overview of the 

refuge, including historical perspective and refuge establishment; purposes and vision of the 

refuge; the environmental setting; the legal context of refuge management; and the planning 

process, including the identification of significant planning issues addressed in the Plan. 

Figure 1-1. Refuge location within Alaska 

1.1 Purpose and Need for Action 

This is a revision of the 1987 Innoko Refuge Comprehensive Conservation Plan. Comprehensive 

conservation plans provide broad policy guidance and establish management directions for a 

refuge. They define long-term goals and objectives toward which refuge management activities 

are directed and identify which uses are appropriate and may be compatible with the purposes of 

the refuge and mission of the National Wildlife Refuge System (System). Comprehensive 

conservation plans are dynamic documents, requiring periodic review and updating. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 1-1 
Chapter 1: Introduction 

Figure 1-2. Innoko Refuge location within region 

Federal statute, specifically section 304(g) of the Alaska National Interest Lands Conservation 

Act of 1980 as amended, 16 U.S.C. 140hh-3233, 43 U.S.C. 1602-1784 (ANILCA), directs the 

Secretary of the Interior to prepare, and “from time to time,” revise, a comprehensive 

conservation plan for each refuge in Alaska. 

The Service revised the Innoko Refuge Comprehensive Conservation Plan to provide direction for 

management of the refuge for the next 15 years. The revised plan follows guidance found in 

ANILCA and other Federal laws, primarily the National Wildlife Refuge System Administration 

Act of 1966, as amended by the National Wildlife Refuge System Improvement Act of 1997, 16 

U.S.C. 668dd-668ee (Refuge Administration Act); and the National Environmental Policy Act of 

1969, as amended, 42 U.S.C. 4321-4347 (NEPA), as implemented by the Council on Environmental 

Quality’s (CEQ) Regulations for Implementing the Procedural Provisions of NEPA, 40 CFR 1500-

1508. Revising the Conservation Plan allows the Service to: 

 Update management direction related to national and regional policies and guidelines 

implementing Federal laws governing refuge management; 

 Incorporate new scientific information on refuge resources; and 

1-2 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

 Re-evaluate current refuge management direction based on changing public demands for use 

of the refuge and its resources, and changing environmental conditions. 

In addition to the preceding requirements, a comprehensive conservation plan also serves to: 

 Ensure that the purposes of the refuge and the mission of the Refuge System are being 

fulfilled; 

 Ensure that national policy is incorporated into the management of the refuge; 

 Ensure that opportunities are available for interested parties to participate in the 

development of management direction; 

 Provide a systematic process for making and documenting decisions about refuge resources; 

 Establish broad management direction for refuge programs and activities; 

 Provide continuity in refuge management; 

 Provide a basis for budget and personnel requests; and 

 Provide a basis for evaluating accomplishments. 

1.2 Planning Context 

The Innoko National Wildlife Refuge is part of a national system of more than 545 refuges. The 

Service places an emphasis on managing individual refuges in a manner that reflects national 

priorities of the National Wildlife Refuge System and the purposes for which the refuge was 

established. As a result, the Revised Conservation Plan must contribute to meeting the mission 

and goals of the entire System while adhering to the purposes of the individual refuge. 

1.2.1 The U.S. Fish and Wildlife Service 

The U.S. Fish and Wildlife Service is the principal Federal agency responsible for conserving, 

protecting, and enhancing fish, wildlife, plants, and their habitats. In addition to the National 

Wildlife Refuge System, the Service also operates national fish hatcheries, fishery resource 

offices, and ecological services field stations. The Service enforces Federal wildlife laws, 

administers the Endangered Species Act, manages migratory bird populations, restores nationally 

significant fisheries, conserves and restores wildlife habitat such as wetlands, and helps foreign 

governments with their conservation efforts. It oversees the Federal Aid in Wildlife Restoration 

program, which distributes to State fish and wildlife agencies hundreds of millions of dollars 

derived from excise taxes on fishing and hunting equipment. 

The mission of the U.S. Fish and Wildlife Service is: 

Working with others to conserve, protect, and enhance fish, wildlife, plants, and 

their habitats for the continuing benefit of the American people. 

1.2.2 The National Wildlife Refuge System 

The National Wildlife Refuge System comprises more than 96 million acres of Federal lands, 

encompassing more than 545 national wildlife refuges, thousands of small wetlands, and other 

special management areas. System lands are located in all 50 states and the territories of the 

United States. The System was created to conserve fish, wildlife, plants, and their habitats. This 

conservation mission includes providing Americans with opportunities to participate in compatible 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 1-3 
Chapter 1: Introduction 

wildlife-dependent recreation on System lands, including fishing and hunting, and to better 

appreciate the value of and need for fish and wildlife conservation. 

Alaska contains 16 national wildlife refuges (Figure 1-3). These refuge lands contain a wide range 

of habitats with varied terrain, including mountains, glaciers, tundra, grasslands, wetlands, lakes, 

woodlands, and rivers. Together, the 16 refuges comprise 76.8 million acres and constitute about 

80 percent of the entire National Wildlife Refuge System. 

The mission of the National Wildlife Refuge System is: 

...to administer a national network of lands and waters for the conservation, 

management, and, where appropriate, restoration of the fish, wildlife, and plant 

resources and their habitats within the United States for the benefit of present and 

future generations of Americans (National Wildlife Refuge System 

Administration Act, as amended). 

Figure 1-3. The 16 National Wildlife Refuges in Alaska 

1.2.3 Principles of Refuge Management 

The National Wildlife Refuge System Administration Act, as amended, states that each refuge 

shall be managed to fulfill both the mission of the National Wildlife Refuge System and the 

purposes for which the individual refuge was established. It requires that any use of a refuge be 

compatible with refuge purposes. Therefore, any use of a refuge will not materially interfere with 

nor detract from fulfillment of the mission of the System or the purposes of the refuge. 

1-4 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

The 1997 amendments to the National Wildlife Refuge System Administration Act identified a 

number of principles to guide management of the Refuge System, including: 

 Conserve fish, wildlife, and plants, and their habitats within the System 

 Maintain the biological integrity, diversity, and environmental health of the System 

 Coordinate, interact, and cooperate with adjacent landowners and State fish and wildlife 

agencies 

 Maintain adequate water quantity and water quality to meet refuge and System purposes 

and acquire necessary water rights 

 Maintain hunting, fishing, wildlife observation, wildlife photography, interpretation, and 

environmental education as the priority general public uses of the System 

 Provide opportunities for compatible priority wildlife-dependent public uses 

within the System 

 Provide enhanced consideration for priority wildlife-dependent public uses over other 

general public uses in planning and management 

 Provide increased opportunities for families to experience priority general public uses, 

especially traditional outdoor activities such as fishing and hunting 

 Monitor the status and trends of fish, wildlife, and plants in each refuge 

To maintain the health of individual refuges and the National Wildlife Refuge System as a whole, 

managers must anticipate future conditions. Managers must endeavor to avoid adverse impacts 

and take positive actions to conserve and protect refuge resources. Effective management also 

depends on acknowledging resource relationships and acknowledging that refuges are parts of 

larger ecosystems. Refuge managers work together with partners—including other refuges, 

Federal and State agencies, tribal and other governments, Native organizations and entities, and 

nongovernmental organizations and groups—to protect, conserve, enhance, and/or restore all 

native fish, wildlife (including invertebrates), plants, and their habitats. 

1.3 Legal and Policy Guidance and State 

Coordination 

Refuge management is dictated, in large part, by the legislation that created the unit and by the 

purposes and goals described later in this chapter. However, refuge management is also guided 

by other laws, regulations, and policies, as well as by agreements with the State of Alaska. This 

section identifies the laws and the policy guidance that are integral to developing this Plan. 

1.3.1 Legal Guidance 

Operation and management of refuges throughout the System are influenced by a wide array of 

laws, treaties, and executive orders. Among the most important are the National Wildlife Refuge 

System Administration Act, as amended by the National Wildlife Refuge System Improvement Act; 

the Refuge Recreation Act; the Endangered Species Act; and the Wilderness Act. These acts are 

described briefly in appendix A, along with other laws that influence management of the refuge. 

For national wildlife refuges in Alaska, ANILCA, as amended, provides key management direction. 

ANILCA sets forth the purposes of the refuge, defines provisions for planning and management, 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 1-5 
Chapter 1: Introduction 

and authorizes studies and programs related to wildlife and wildland resources, subsistence 

opportunities, and recreation and economic uses. ANILCA also provides specific direction for the 

management of designated Wilderness areas and Wilderness study areas in the State of Alaska. 

ANILCA’s influence on management of the refuge is described throughout this document. 

The designated Innoko Wilderness includes about 1,322,000 acres southeast of the Innoko River, 

comprising 35 percent, or just over one-third, of the refuge. After considering the requirements 

for Wilderness reviews, we determined that the planning requirements of section 304(g) of 

ANILCA were best satisfied by honoring the Wilderness recommendations of the previous Plan 

and focusing our efforts on describing the wilderness values of the refuge. In our assessment, this 

would provide better direction for how the refuge could be managed to protect those values. 

A similar approach was taken with Wild and Scenic River reviews. We determined that we would 

meet the intent of the Wild and Scenic Rivers Act of 1968 by focusing our efforts on describing river 

values and providing better direction for how the refuge could be managed to protect those values. 

Wilderness values and river-related values are discussed in chapter 3, sections 3.5 and 3.6 of this 

Plan. Programs and actions to protect all refuge-related values are discussed in the Management 

Direction section of chapter 2. 

1.3.2 Policy Guidance 

Policy documents provide additional direction for the management of national wildlife refuges. 

These documents include: 

 Fish and Wildlife Service Manual chapters 

 Director’s orders 

 National policy issuances 

 Handbooks 

 Director’s memoranda 

 Regional directives 

Although it is not practical to provide information about all these documents in this Plan, they are 

critical to management of the refuge. Much of the management direction described in chapter 2 

and throughout this Plan is influenced by guidance from these policy documents. 

Several of these documents direct that an ecosystem approach be used in refuge management. 

We must consider the health of the entire ecosystem when managing the refuge, and this concept 

requires close coordination with others. Appendix A provides a brief description of this concept 

and of several of the national and regional management plans and programs that were considered 

during the development of this Plan. Other key policies, such as the compatibility policy and the 

biological integrity policy, are described in later chapters, as they provide guidance in this Plan. 

1.3.3 State of Alaska Coordination 

The Alaska Department of Fish and Game (ADF&G) has the primary responsibility for managing 

resident fish and wildlife populations within the State. On refuge lands, the Service and ADF&G 

share a concern for all fish and wildlife resources and their habitats, and both agencies engage in 

extensive fish and wildlife conservation, management, and protection programs. In 1982, the 

Service and ADF&G signed a Master Memorandum of Understanding (appendix B) that defines 

1-6 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

the cooperative management roles of each agency and sets the framework for cooperation 

between the two agencies. 

The State of Alaska establishes fishing, hunting, and trapping regulations at the direction of the 

Alaska Boards of Fisheries and Game; these regulations apply to Federal public lands. If Service 

regulation of hunting or fishing was needed, it would be done through a rulemaking or through 

closures or restrictions under 50 CFR 36.42 (2003). The State is divided into 26 game 

management units (GMUs); most of these are further divided into subunits. Management 

objectives are developed for populations within the GMUs. All of Innoko Refuge lies within GMU 

21—the Middle Yukon. Most of the refuge is situated within subunit A of GMU 21, with smaller 

portions on the west side of the refuge in the subunits 21D and 21E (Figure 1-4). 

The Alaska Department of Natural Resources (DNR) and its divisions are key management 

partners with all refuges in Alaska. DNR manages all State-owned land, water, and surface and 

subsurface resources except for fish and game. DNR’s Division of Mining, Land, and Water 

manages the State’s water and land interests within the refuge. Issues related to State interests 

will most likely expand in the next 10 to 15 years, especially with regard to water rights, navigable 

waters, ownership of submerged lands, and rights of way over refuge lands. 

1.4 Refuge Purposes and Vision Statement 

1.4.1 Refuge Purposes 

Section 101(b) of ANILCA identifies purposes for all conservation system units in Alaska and states, 

“It is the intent of Congress in this Act to preserve unrivaled scenic and geological 

values associated with natural landscapes; to provide for the maintenance of sound 

populations of, and habitat for, wildlife species of inestimable value to the citizens of 

Alaska and the Nation, including those species dependent on vast relatively 

undeveloped areas; to preserve in their natural state extensive unaltered arctic 

tundra, boreal forest, and coastal rainforest ecosystems; to protect the resources 

related to subsistence needs; to protect and preserve historic and archeological sites, 

rivers, and lands, and to preserve wilderness resource values and related 

recreational opportunities including but not limited to hiking, canoeing, fishing, and 

sport hunting, within large arctic and subarctic wildlands and on freeflowing rivers; 

and to maintain opportunities for scientific research and undisturbed ecosystems.” 

Section 302(3)(B) of ANILCA states that the purposes of Innoko Refuge include: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including but not limited to waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence by local residents; and 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 1-7 
Chapter 1: Introduction 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

A purpose of the Innoko Wilderness is to secure an enduring resource of wilderness, protect 

and preserve the wilderness character of the area as part of the National Wilderness 

Preservation System, and administer the area for the use and enjoyment of the American 

people in a way that will leave it unimpaired for future use and enjoyment as wilderness. 

1.4.2 Refuge Vision Statement 

The Innoko National Wildlife Refuge encompasses a largely unaltered ecosystem dominated by 

numerous rivers flowing among diverse habitats, including muskeg, tundra, and dense boreal 

forest. Remote even by Alaskan standards, the natural forces of fire and water, now apparently 

affected by climate change, dominate the landscape. The refuge is not accessible by road, and 

only the occasional visitor discovers the many opportunities to hunt, fish, and view wildlife. The 

refuge hosts hundreds of thousands of breeding and molting waterfowl and is important rearing 

habitat for salmon and other species of fish. In addition, moose, black and grizzly bears, and 

furbearers are abundant. Refuge lands have been important to subsistence hunters for 

generations, and the area has a rich Gold Rush history. A main portion of the historic Iditarod 

Trail, the overland winter route from Seward to the gold fields of Nome, crosses refuge land. The 

Innoko Refuge is a place to discover the vastness and diversity of interior Alaska, to reflect upon 

Native Alaskan and mining history, and to experience nature in solitude for generations to come. 

1.5 Refuge Overview 

1.5.1 Historical Perspective and Refuge Establishment 

On December 2, 1980, President Jimmy Carter signed into law the Alaska National Interest 

Lands Conservation Act (ANILCA). Section 302 of this act established the Innoko National 

Wildlife Refuge as part of the National Wildlife Refuge System. Section 702 (5) established the 

Innoko Wilderness Area as part of the National Wilderness Preservation System. 

Innoko Refuge consists of two units—the 3.8-million-acre southern unit and the 750,000-acre 

northern unit. This Plan covers only the southern unit. The northern unit is situated adjacent to 

the Yukon River on the Kaiyuh Flats. Its primary users are the residents of Galena, Koyukuk, 

Nulato, and Kaltag. To facilitate this use, the Service manages the northern unit from the 

headquarters of Koyukuk Refuge in Galena rather than Innoko Refuge in McGrath, some 140 air 

miles to the southeast. The northern unit of Innoko Refuge has been included in the Koyukuk 

Refuge Comprehensive Conservation Plan to simplify management of the area by providing the 

Koyukuk staff with one management plan. 

1-8 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

Figure 1-4. Alaska game management subunits in relation to the Innoko Refuge 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 1-9 
Chapter 1: Introduction 

1.5.2 Physical Environment 

Innoko National Wildlife Refuge is situated on a relatively flat plain with the highest point 

reaching just over 1,460 feet in elevation. Water dominates the Innoko Refuge landscape. The 

Yukon River defines the north and west boundaries of the refuge, while the Innoko, Iditarod, 

Dishna, and Yetna rivers flow through it. The Innoko River forms the north and west boundaries 

of the Congressionally-designated Innoko Wilderness. These rivers tend to be sluggish and silty 

with constantly meandering courses. Extensive wetlands with countless small lakes, streams, and 

bogs are particularly abundant in the southeast portion of the refuge. Many of the bogs support 

thick floating mats of vegetation that give the appearance of solid ground. Much of this rich 

wetland area depends on the yearly flooding and drawdown regime for nutrient input. The rest of 

the terrain is marked by hills, most of which are less than 1,000 feet in elevation. 

The area has a continental climate: summers are short with moderate temperatures; winters are 

long and cold. Temperatures span some of the widest extremes on earth, ranging from over 90 

degrees Fahrenheit in summer to minus 70 degrees Fahrenheit in winter. Spring and fall are 

brief seasons that begin and end abruptly. 

Figure 1-5. Hather Creek on Innoko National Wildlife Refuge (Photo: Robin Corcoran, USFWS) 

1.5.3 Biological Resources 

The refuge can be roughly divided into two distinct habitat types. Approximately half consists of 

black spruce muskeg, wet meadows, and sedge or horsetail marshes, sprinkled with innumerable 

lakes and ponds of varying size. The other half consists of upland habitat dominated by mixed 

hardwood-conifer forest. 

The vegetation of the refuge is typical of the boreal forest of interior Alaska. White spruce is 

found in large pure stands along rivers where soils are better drained. Numerous fires have set 

vast areas back to earlier successional stages (seres) consisting of aspen, birch, and willow. Black 

1-10 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

spruce muskegs or bogs develop on the poorly drained soils. Dense willow and alder stands are 

common along the rivers and sloughs. The most conspicuous characteristic of Innoko Refuge’s 

vegetation is the complex interspersion of types. 

Frequent flooding of the many rivers and streams within the refuge helps fertilize surrounding 

soils and maintain the rich willow sandbar habitat that provides winter food for the moose 

population found on the refuge, which is a subsistence mainstay for neighboring communities. 

This same habitat is a home for the ubiquitous beaver. 

The refuge is also home to many other mammals. Barren ground caribou from the Beaver 

Mountain herd use Innoko Refuge year-round. Both black and brown bears and wolves are also 

present year round. Other furbearers include marten, lynx, red fox, river otter, and wolverine. 

Among the smaller mammals are the porcupine, several species of shrews, voles, and one species 

of jumping mouse. 

Figure 1-6. Alaska bull moose (Photo: Donna Dewhurst, USFWS) 

During at least one season of the year, 128 species of birds use the refuge, including 25 nesting 

waterfowl species such as trumpeter swans, white-fronted geese, and greater scaup. Innoko 

Refuge is also an important nesting area for red necked grebes, lesser yellow legs and Hudsonian 

godwits, as well as such neotropical songbirds as the alder flycatcher, gray-cheeked thrush, 

Swainson's thrush, yellow warbler, yellow-rumped warbler, blackpoll warbler, northern 

waterthrush, Lincoln’s sparrow, and savannah sparrow. These neotropical migrants embark on 

long annual journeys between their breeding grounds in Alaska’s arctic and subarctic and their 

wintering grounds in the tropical habitats of Central and South America and the Caribbean Sea. 

The refuge only has one known amphibian, the wood frog, and not a single reptile. In contrast, 

Innoko Refuge supports many species of fish. Large northern pike; Chinook, coho, and chum 

salmon; burbot; and several species of whitefish, including sheefish, abound in refuge streams and 

lakes. Dolly Varden char and arctic grayling also exist on the refuge. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 1-11 
Chapter 1: Introduction 

1.5.4 Human Uses 

The majority of public use occurring within the refuge is by local people from the seven 

communities near the refuge. Many of these people depend on the natural resources in the area 

for their livelihood. The refuge lies within the traditional hunting and fishing areas of the 

Holikachuk Athapaskan Indians, who still depend on its wildlife and fishery resources for 

subsistence. Visitors from outside the local area include people from other parts of Alaska, other 

states, and other countries. 

Figure 1-7. Refuge employee holding northern pike (Photo: Robin Corcoran, USFWS) 

1.6 Special Values 

Section 304(g) of ANILCA directs us to identify and describe “special values of the refuge, as well 

as any other archeological, cultural, ecological, geological, historical, paleontological, scenic, or 

wilderness values of the refuge.” The Innoko Refuge staff has determined that the following 

characteristics are of special value. 

1.6.1 Waterfowl Habitat 

Innoko Refuge is one of the more important waterfowl areas in interior Alaska. A primary reason 

for establishment of the refuge was protection of the vast wetland complex surrounding the 

confluence of the Innoko and Iditarod rivers important to waterfowl during many life stages. The 

unique water regime in this area, characterized by frequent spring flooding and slow drawdown of 

lakes, creates excellent habitat for breeding, molting, and migrating birds. It is estimated that the 

refuge supports, on average, over 75 percent of the molting greater white-fronted geese surveyed 

in interior Alaska. Annual breeding pair surveys indicate that approximately 185,000 ducks are 

found on refuge wetlands in early spring. 

1-12 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

1.6.2 Moose Habitat 

The combination of Innoko Refuge’s natural water and fire regimes create a wide variety of habitat 

for moose. Fire sets back succession of the vegetation and promotes growth of willows and other 

plants that are important winter food sources for moose. Regular flooding of the refuge’s lowland 

areas inhibits growth of spruce and other vegetation typical of later succession boreal forests. This 

tends to maintain high quality winter habitat along rivers and floodplains. Habitat available on 

Innoko Refuge is of a quality and quantity to consistently produce good moose densities. 

Figure 1-8. Waterfowl and moose habitat (USFWS photo) 

1.6.3 Gold Rush History 

In 1906, a major gold discovery was made on Ganes Creek in the upper Innoko River area. A 

second major strike on Otter Creek, a tributary of the Iditarod River, occurred on Christmas Day 

in 1908. The “Inland Empire,” as this area was soon called, experienced a brief but significant 

boom of activity as thousands of prospectors, miners, and business people settled in the Innoko 

River basin. The existing Native community of Dishkaket and the new sites of Dementi, Innoko 

City, Shermeyers Halfway Roadhouse, Simels, Rennies Landing, and Dikeman became important 

support sites. All are now abandoned, but the gold history of the area and historic sites on the 

refuge are valuable resources. 

1.6.4 Iditarod National Historic Trail 

The influx of people wishing to get to the gold fields of Nome prompted the United States Army 

(Alaska Road Commission) to survey an overland winter route stretching from Seward to Nome. 

This trail passed through the interior mining district and the town by the same name: “Iditarod.” 

From the town of Iditarod, the trail followed the Iditarod River north, passing through what is 

now the Innoko National Wildlife Refuge, including the Innoko Wilderness, to the towns of 

Dishkakat and Dikeman—also within the refuge boundary—then on to Kaltag and Nome. The 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 1-13 
Chapter 1: Introduction 

Service is a party to the Iditarod National Historic Trail Management Plan led by the Bureau of 

Land Management. 

1.6.5 Natural Processes 

On Innoko Refuge, the natural forces of water and fire dominate the landscape. During spring 

break up, large ice sheets scour islands in the Yukon and Innoko rivers; the resulting willow 

regeneration creates abundant winter moose forage. Low-lying areas adjacent to the Yukon and 

Innoko rivers, as well as low-lying basins and numerous smaller rivers, are subject to frequent 

flooding. This flooding brings vital nutrients to the soil, allows water exchanges with lakes and 

sloughs not otherwise connected to rivers, allows resident fish species to move between rivers and 

unconnected lakes and sloughs, and enhances waterfowl nesting, brood rearing, and molting 

habitats. Summer drawdown of water levels in lakes and rivers produces moist soil vegetation 

critical to foraging waterfowl. Due to size and remoteness, wildfires on the refuge are generally 

allowed to burn unimpeded. This natural fire regime creates a mosaic of upland habitat types and 

is essential in forming and maintaining habitats important for a diversity of wildlife. 

1.6.6 Wilderness Values 

The Innoko Wilderness area—in fact, the entire Innoko National Wildlife Refuge—is extremely 

remote and displays the wilderness attributes of a large area that is undeveloped, natural, and 

untrammeled, offering the occasional visitor outstanding opportunities for solitude or a primitive 

and unconfined type of recreation. During the summer, it is not unusual to travel for a week on 

the Innoko River without seeing another person. 

Figure 1-9. Natural processes and wilderness—fire in the Innoko landscape (USFWS photo) 

1-14 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

1.7 Planning Requirements 

Section 304(g) of ANILCA directs that comprehensive conservation plans be developed for each 

refuge. It also specifies procedures to follow while developing these plans. 

The following must be identified and described prior to developing a plan for any refuge: 

 The populations and habitats of the fish and wildlife resources of the refuge 

 The special values of the refuge and any other archeological, cultural, ecological, 

geological, historical, paleontological, scenic, or wilderness values of the refuge 

 Areas within the refuge suitable for use as administrative sites or visitor facilities, or for 

visitor services, as provided for in ANILCA sections 1305 and 1306 

 Present and potential requirements for access with respect to the refuge, as provided for 

in ANILCA title XI 

 Significant problems that may adversely affect the populations and habitats of fish and 

wildlife identified 

Each comprehensive conservation plan shall: 

 Be based upon the identifications and the descriptions developed in the planning 

requirements described previously. 

(i) Designate areas within the refuge according to their respective 

resources and values. 

(ii) Specify the programs for conserving fish and wildlife and the programs 

related to maintaining the special values of the refuge that are proposed to 

be implemented within each area. 

(iii) Specify the uses within each area that may be compatible with the 

major purposes of the refuge. 

 Set forth those opportunities provided within the refuge for fish and wildlife-oriented 

recreation, ecological research, environmental education, and interpretation of refuge 

resources and values, if such recreation, research, education, and interpretation is 

compatible with the purposes of the refuge. 

While preparing the plans, the Service is required to ensure that adequate opportunities exist for 

interagency coordination and public participation. Any interested and affected parties, such as 

State agencies, Native corporations, local residents, and residents of political subdivisions that 

would be affected by decisions in the plan must be provided meaningful opportunities to present 

their views. Prior to adopting a plan, the Service will issue notice of its availability in the Federal 

Register, make copies available in regional offices of the U.S. Fish and Wildlife Service throughout 

the United States, and provide an opportunity for public review and comment. 

1.8 The Planning Process 

This section describes the process used to develop this Revised Comprehensive Conservation Plan 

(Revised Conservation Plan; Revised Plan, Plan) and the Environmental Assessment (EA). The 

process is consistent with the planning requirements specified in section 304(g) of ANILCA; the 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 1-15 
Chapter 1: Introduction 

Refuge System Administration Act, as amended; the Service’s planning policy (602 FW 1 and 3); 

the National Environmental Policy Act (42 U.S.C. 4321-4347); and the Council on Environmental 

Quality’s Regulations for Implementing the Procedural Provisions of the National Environmental 

Policy Act (40 CFR 1500–1508). The Service is using an eight-step planning process to revise the 

Innoko Refuge Comprehensive Conservation Plan: 

1) Design the planning process (preplanning) 

2) Initiate public involvement and scoping 

3) Determine significant issues 

4) Develop and analyze alternatives 

5) Prepare draft comprehensive conservation plan and environmental assessment 

6) Prepare and adopt a final plan 

7) Implement the plan and monitor and evaluate it 

8) Review and revise the plan 

Figure 1-10. The Planning Process 

1.8.1 Design the Process 

In the spring of 2006, the Service began reviewing the Innoko Refuge Comprehensive 

Conservation Plan to determine if it should be revised or a new plan should be prepared. The 

Service found that on-the-ground management actions were usually meeting refuge objectives. 

However, some management direction needed to be updated. New laws (such as the National 

Wildlife Refuge System Improvement Act), new regulations and policies, and other changes (such 

as Service management of the Federal subsistence program within Alaska refuges) needed to be 

1-16 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

included in the Innoko Refuge Comprehensive Conservation Plan. For these reasons, the Service 

decided that a revision of the Innoko Refuge Comprehensive Conservation Plan was necessary. 

The Service then identified relevant laws, regulations, policies, and other direction that would 

have to be considered during revision of the Innoko Refuge Comprehensive Conservation Plan. 

These are discussed in the legal and planning context sections earlier in this chapter. Additional 

detail can be found in appendix A. The Service also reviewed data available on refuge resources 

and uses and identified some areas in which additional work was required. 

1.8.2 Initiate Public Involvement and Scoping 

This step informed the public that the refuge was beginning to revise the Innoko Refuge 

Comprehensive Conservation Plan and solicited ideas on what should be addressed. Formal 

public scoping began with publication of a Notice of Intent to revise the Innoko Refuge 

Comprehensive Conservation Plan and preparation of an Environmental Assessment (EA) in the 

Federal Register on February 23, 2007 (Vol. 72, No. 36, pg. 8197). 

In December 2006, a planning update announcing the revision and seeking comments was mailed 

to approximately 1,350 individuals and organizations. The planning update contained information 

about the refuge, described issues identified by the refuge staff, and provided an opportunity for 

the public to identify other issues that should be addressed during revision of the Innoko Refuge 

Comprehensive Conservation Plan. Public meetings to gather input were held in McGrath, 

Grayling, Anvik, Shageluk, Holy Cross, Takotna, and Kaltag. 

During scoping, the refuge solicited comments on what people valued about Innoko Refuge, what 

they perceived as threats to the refuge, and opportunities for future management of the refuge. 

Comments about what people valued on the refuge can be categorized into three topics: 

wilderness/wildland protection; wildlife and habitat protection; and hunting and fishing and other 

activities. Each topic is briefly described in the following text. 

Wilderness/Wildland Protection: Many people described values associated with the wild, 

undeveloped setting of the refuge landscape. Although some linked landscape features to specific 

purposes (such as wildlife protection) or activities (such as hunting), other respondents explained 

that they simply value the inherent qualities of undeveloped nature that are protected on the 

refuge. Examples of comments include: 

“[I value] its remoteness and pristine qualities.” 

“[I value] its naturalness and wildness.” 

“[I value] that it’s protected.” 

Wildlife and Wildlife Habitat Protection: This theme is closely related to the wildland protection 

theme. The difference is that people specifically referred to the undeveloped, protected refuge 

setting as an ideal place for wildlife. Examples of comments include: 

 “[I value] knowing that it will be there to provide for the perpetuation of wildlife populations 

for Alaska and all the areas to the south where the nesting birds migrate from.” 

“[I value] having that land dedicated to wildlife resources for the inherent value it has as 

public land and a wildlife refuge.” 

“[I value] pristine flora and natural habitat for fauna; ecological processes managing 

themselves.” 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 1-17 
Chapter 1: Introduction 

Hunting, Fishing and Other Activities: If values were inferred from all the comments received, 

then hunting and fishing—particularly moose hunting—would likely be the dominant refuge 

value. Quite a few people chose to use one- or two-word phrases to describe their hunting and 

fishing values: Hunting; Moose Hunting; Big Pike; Sporting Opportunities. One person further 

explained that the undeveloped and relatively uncrowded refuge setting is also an important part 

of the hunting opportunity provided there. A few people referred to specific activities other than 

hunting and fishing, including boating and berry picking. Examples of comments include: 

“It is some of the most remote country in AK, and there is an abundance of fish and 

game. I value being able to hunt and fish there without seeing other people.” 

“[The refuge is] great for float trips, wildlife viewing, fishing, hunting, and peaceful use.” 

1.8.3 Determine Significant Issues 

The planning team reviewed the issues raised by the public, refuge staff, and other Service 

divisions to determine the significant planning issues to be addressed in the revised Plan. 

Significant planning issues are those that are within the purview of the refuge and may be handled 

differently in the alternatives. Section 1.9 in this chapter provides more detail on the process used 

to identify the significant planning issues and what those issues involve. 

1.8.4 Develop and Analyze Alternatives 

In April 2007, the planning team developed a set of two draft alternatives (including current 

management) for management of the refuge. These alternatives were presented to the regional 

director of the U.S. Fish and Wildlife Service, other members of the Service leadership, and to the 

public for review and comment in a June 2007 planning update that was distributed to 

approximately 1,350 interested individuals and organizations. 

The alternatives were then presented in chapter 2 of the Draft Revised Comprehensive 

Conservation Plan and Environmental Assessment; chapter 4 of that document analyzed 

environmental effects of the alternatives. 

1.8.5 Prepare Draft Plan and Environmental Assessment 

This step produced a draft plan for public review. It described two alternatives (including current 

management) for managing Innoko Refuge over the next 15 years. It included an analysis of the 

potential impacts of implementing each alternative and described how the Service determined its 

preferred alternative (Alternative B). It also included a description of management common to all 

the alternatives—management that would remain the same no matter which alternative was 

implemented. The Service’s Notice of Availability of the Draft Revised Plan and Environmental 

Assessment was published in the Federal Register on May 14, 2008 (Vol. 73, No. 94, pp. 27842-

27844). During the public review and comment period, the Service held one public meeting in 

McGrath. The public review period ended on July 22, 2008. 

1.8.6 Prepare and Adopt a Final Plan 

The planning team reviewed and analyzed all comments received on the Draft Revised 

Conservation Plan (see appendix J), modified the draft as needed, and developed the Final 

Revised Conservation Plan. A Finding of No Significant Impact (FONSI) was signed by the 

regional director on September 22, 2008 (see appendix K). A Notice of Availability has been 

1-18 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

published in the Federal Register, and the Final Revised Plan and FONSI have now been 

distributed to the public.

1.8.7 Implement Plan, Monitor, and Evaluate 

Upon approval of the FONSI and Revised Conservation Plan, refuge staff began implementing 

the management changes and actions called for in the Revised Plan. A critical component of 

management is monitoring—measuring resource and social conditions to make sure that 

progress is being made toward meeting refuge purposes, goals, and objectives. Monitoring 

includes determining if the refuge is implementing the Plan and if actions being taken are 

effective in meeting the objectives. The refuge will use an adaptive management approach, 

which means that information gained from monitoring will be used to evaluate and, as needed, 

modify refuge objectives. 

1.8.8 Review and Revise the Plan 

Service policy directs that the refuge review the Plan annually to assess the need for change. The 

Service will revise the Plan when important new information becomes available, when ecological 

conditions change, or when the need to do so is identified during a review. If major changes are 

proposed, public meetings may be held and a new environmental assessment or an environmental 

impact statement may be necessary. Consultation with appropriate State agencies and others 

would occur during any future revisions. Full review and revision of the Plan will occur 

approximately every 15 years. The Service will continue to inform and involve the public through 

appropriate means (such as reporting on activities at community meetings and via planning 

updates or other mailings) throughout the implementation and monitoring process. 

1.9 Issues 

The Service defines an issue as any unsettled matter that requires a management decision such as 

an initiative, opportunity, resource management problem, threat to refuge resources, conflict in 

uses, public concern, or presence of an undesirable resource condition. Several means were used 

to identify issues: input was obtained from the public at “open house” meetings, through issue 

worksheets that were distributed with the planning update, and through visits with village elders 

and community leaders. Issues were also identified by Service staff. 

Scoping initially identified a broad range of topics that became more focused into specific issues as 

more information was gathered. Issues identified during public involvement were refined and 

clarified during a planning team meeting. Issues identified by the public and Service staff and 

how they are addressed are identified in the following section. 

1.9.1 How will the refuge address intensifying competition to harvest moose? 

The number and range of comments about moose and moose hunting indicates this is a multidimensional concern shared by a large proportion of refuge users. Many people expressed the 

belief that moose numbers in and around the refuge are in decline. They believe this is most likely 

due to pressure from a large and growing hunter population. Local area residents regard 

“outside” (both out-of-State and out-of-region) hunters as a primary threat; “outsiders” 

emphasized that they, too, have a legitimate stake in refuge management. This local versus nonlocal tension is a second dimension of the issue. Air taxis are also regarded as contributing to 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 1-19 
Chapter 1: Introduction 

moose hunting increases—those comments are addressed in a subsequent section. Finally, a few 

suggested that predator management is needed in response to declining moose numbers. 

Representative comments include: 

“Increased hunting is disrupting the area and changing wildlife patterns.” 

“Do you know, there are more hunters who come in to hunt than there are moose 

 in the area.” 

 “I don't mind the fluctuation in moose numbers; that is a natural cycle. But the number 

of out-of-state hunters needs to be closely monitored. There are too many.” 

“Many hunters from outside [the area] are coming into the area to hunt, and the locals 

don't have a chance to harvest moose...” 

“This refuge is a national interest land, not a local use game production area.” 

“Most important issue is control of wolves. Current over-population of wolves is and will 

continue to adversely impact moose populations.” 

The refuge proposes to address this issue through implementation of the Yukon-Innoko Moose 

Management Plan in cooperation with the State of Alaska Department of Fish and Game. 

Completed December 2006, this plan was designed to address many aspects of this issue. Refuge 

goals and objectives will also address the issue (see chapter 2). For further information on how the 

refuge will address predator management, see appendix C. 

1.9.2 How will the refuge manage air taxis to balance demand for visitor access with user 

experience and resource protection? 

Comments about air taxis were closely linked to concerns about moose. Several people suggested that 

air taxis are directly responsible for increased hunting activity. One person suggested that air taxis 

are already “over-regulated,” making refuge access difficult. Others expressed concerns about 

difficult access, and at least one implied that air taxis provide access for activities other than hunting. 

Representative comments include: 

“Without a doubt, the commercial air taxis and their moose hunting clients [are an 

important issue]. They should be limited just like the big game guides.” 

“Most people interested in the refuge have no way to access it. This disconnection needs to 

be bridged somehow. Are there refuge tours or the ability for groups to affordably charter 

flights to the refuge?” 

“You need to increase and improve the public's ability to actually get to the refuge for 

wildlife observation and photography.” 

The refuge proposes to address this issue through continued monitoring of air taxi operators and 

potential future visitor service planning, as well as through the Yukon-Innoko Moose Management 

Plan. See objectives under Goal 4 in chapter 2 for additional information. 

1.9.3 How will the refuge address threats to water quality from off-refuge mining? 

There are at least two dimensions to this concern. The perceived threat of future mining 

development and the threats from existing mines were both mentioned. 

1-20 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 1: Introduction 

Representative comments include: 

“I do think that mining and other extractive development could be extremely damaging to 

the refuge. I don't know if there are any parties looking at large-scale mining in the 

Iditarod-Flat area, but that shouldn't be allowed.” 

 “Subsurface extraction of minerals is a big concern for the refuge.” 

“The most important issues are the water quality that will affect all fish and game on the 

refuge if it is contaminated from any source—i.e., Illinois Creek mine.” 

The refuge proposes to address this issue through continued cooperation with the State of Alaska 

Departments of Environmental Conservation and Natural Resources and through monitoring 

identified in Objective 41 in chapter 2 of this Plan. 

1.9.4 How will the refuge enhance its relationship with communities? 

Comments suggest that some people feel that they are not sufficiently engaged in, or informed 

about, refuge management issues. One person suggested that the refuge consider a comanagement arrangement with Native organizations, and another suggested that the refuge 

might better engage the regional public by enhancing volunteer opportunities. 

Representative comments include: 

“Even though I live in the bush, the refuge is far enough away that news or personal 

impact of use of the refuge does not concern me. Maybe some communication from the 

refuge to the ‘neighbors’ would help me be concerned with use of the refuge.” 

“Offering opportunities to engage students and area communities in refuge activities 

 [is important].” 

“The refuge needs to look for ways to enhance local volunteer opportunities.”

Several objectives in Goals 3 and 6 in chapter 2 of this Plan address refuge plans for enhanced 

communication with the public and local communities. 

1.9.5 How will the refuge monitor and address the effects of climate change? 

Three public comments referenced global warming specifically. One of the comments was from 

outside Alaska, one was from McGrath, and one was from a Holy Cross village resident. 

Representative comments include: 

“Global warming, permafrost thawing, habitats diminished. Be sure that every facet of 

the plan is considered with global warming climate change in mind.” 

“[The Refuge should be...] monitoring environmental components to contribute to studies 

concerning global warming.” 

The effects of climate change are also of concern for refuge staff. The Service is addressing 

climate change effects at national, regional, and local levels. Objectives under Goal 2 in chapter 2 

propose monitoring of climate change effects on the refuge. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 1-21 
Chapter 1: Introduction 

1-22 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

1.9.6 How will the refuge respond to the Alaska Department of Fish and Game’s proposed wood 

bison project? 

Two comments referred to wood bison specifically. The first, from Safari Club International, 

supports the project, while the second opposes the project (although it is not clear why). 

The comments include: 

 “The wood bison project is such a stinky deal.” 

“We believe that [the Refuge] should facilitate the conservation not only of species that 

currently exist on the Refuge, but also those that historically inhabited Alaska. For that 

reason, we recommend that the Revised Comprehensive Plan be amended to specify that 

natural diversity include wildlife populations that are historically indigenous but not 

locally extinct.” 

The Service has indicated it has no objection to the State of Alaska placing wood bison near the 

refuge. However, the Service has also indicated the need to carefully monitor any wood bison that 

occur on refuges as a result of the State’s project to assure there are no unanticipated or 

unacceptable adverse effects on refuge resources. Goals and objectives displayed in chapter 2 call 

for studies in advance of the wood bison project and monitoring to detect effects, if any, on refuge 

resources after project implementation. If adverse effects are detected, appropriate actions would 

be taken in consultation with the Alaska Department of Fish and Game. 

1.9.7 How will the refuge integrate regional policies and guidelines into its management? 

As mentioned in section 1.3.1, management of refuges in Alaska is governed by Federal law (i.e., 

the National Wildlife Refuge System Administration Act of 1966 [Refuge Administration Act], as 

amended by the National Wildlife Refuge System Improvement Act of 1997 [Refuge 

Improvement Act; 16 U.S.C. 668dd] and the Alaska National Interest Lands Conservation Act of 

1980), by regulations implementing these laws, by intergovernmental treaties, by Service policy, 

and by principles of sound resource management, all of which establish standards for resource 

management or limit the range of potential activities that may be allowed on refuges. The 

management policies and guidelines described in chapter 2 were developed as common 

management direction for national wildlife refuges in the Alaska Region of the U.S. Fish and 

Wildlife Service. These policies and guidelines are essentially the same for all of the refuges in 

Alaska. These regional policies and guidelines were adopted for Innoko Refuge as part of this 

comprehensive conservation plan (see chapter 2, sections 2.2 through 2.5). 

1.10 References 

USFWS. 1987a. Innoko National Wildlife Refuge Final Comprehensive Conservation Plan, 

Environmental Impact Statement, and Wilderness Review. Anchorage, Alaska: 

U.S. Fish and Wildlife Service. 

USFWS. 1987b. “Record of Decision: Innoko National Wildlife Refuge Comprehensive 

Conservation Plan, Environmental Impact Statement, and Wilderness Review.” 

December 29, 1987. Anchorage, Alaska: U.S. Fish and Wildlife Service. 
Chapter 2: Goals, Objectives, and Management Direction 

2. Goals, Objectives, and Management 

Direction 

This chapter includes sections addressing two major topics: 1) Goals and Objectives, and 2) 

Management Direction. Section 2.1 identifies refuge goals and objectives to be implemented 

under this Revised Comprehensive Conservation Plan (Revised Plan, Plan). Section 2.2 provides 

an introduction to regional management direction, and section 2.3 describes the management 

categories on Alaska’s national wildlife refuges. Section 2.4 details management policies and 

guidelines adopted for Innoko National Wildlife Refuge (Innoko Refuge, refuge) as a result of this 

comprehensive conservation planning effort, and section 2.5 is a table comparing permitted 

activities, uses, and facilities by management category. 

2.1 Goals and Objectives 

The refuge purposes and vision (chapter 1, sections 1.4.1 and 1.4.2) provide a framework for 

developing goals and objectives for managing the refuge. 

The objectives are often applicable to more than one goal. To avoid unnecessary duplication, each 

objective is listed only under the goal that represents the clearest connection. In addition, the 

ordering of the objectives is not intended to imply prioritization. When necessary (e.g., in the 

wildlife goal), the objectives have been clustered into rough categories (in this example: 

inventories and monitoring, cooperative efforts, and research). Following each objective, the 

rationale for developing that objective is presented. 

The refuge’s Inventory and Monitoring (I&M) step-down management plan will further address 

priorities and provide details on inventory and monitoring activities. The full range of objectives 

is presented here to provide the reader with an overview of the topics that are currently being 

addressed or might be addressed during the life this Revised Plan. Some of these objectives may 

not be addressed during the life of the Revised Plan. Funding and staffing will play a large role in 

determining how many and which objectives are undertaken. 

Many of the objectives important for managing subsistence activities and public use of the refuge 

require monitoring or improving knowledge of the natural resources linked to these activities. 

For this reason, most of the objectives for subsistence or public use are listed beneath Goal 3 or 

Goal 4, which are focused on improving knowledge of the refuge’s biological resources and on 

conserving habitat for those resources. 

Cooperation with State and Federal agencies and other organizations is a critical component 

to successfully meeting most of the objectives listed in this chapter. This cooperation can 

range from reviewing and revising study plans and reports to cooperating on data collection 

and report completion. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-1 
Chapter 2: Goals, Objectives, and Management Direction 

GOAL 1 – WILDLIFE 

Improve knowledge of fish and wildlife species on the refuge to maintain healthy populations in 

their natural diversity 

Inventory and Monitoring: 

1. Objective: Within five years of adoption of the Plan and within the capabilities of the regional 

refuge biologist, host a biological program review. 

Rationale: Biological program reviews are required by Service Manual 701 FW 2. These peer 

reviews of the refuge’s biological program identify where it has been and where it should consider 

going in the future. Findings from the review play an important role in the development of the 

required Inventory and Monitoring Plan (see Objective 2). 

2. Objective: Within two years of the biological program review report and within staffing 

capabilities, prepare an Inventory and Monitoring Plan (I&M Plan) to integrate and direct 

inventory and monitoring activities of plants, fish, wildlife, and habitats that includes statistical 

benchmarks and management action thresholds for trust, harvested, and selected indicator 

species. Integral to the I&M Plan will be a habitat management plan. The I&M Plan will be 

formally reviewed at least annually and approved by the Alaska refuge chief every 5–8 years. 

Rationale: An I&M Plan is required by Service Manual 701 FW 2; however, the I&M Plan cannot 

be started until completion of the biological program review report (see Objective 1), as it is an 

integral part of the I&M Plan. The I&M Plan will document the rationale, techniques, and 

schedule for routinely conducted inventories and monitoring efforts, and ensure information is 

collected in a biologically and statistically sound manner. Each national wildlife refuge is required 

to develop a habitat management plan under Service policy 620 FW 1.5. 

Innoko National Wildlife Refuge has a variety of challenging issues such as the proposed wood 

bison project, proposed mineral extraction activities, and pronounced natural processes (e.g., 

flooding, wildfire). Although refuge lands are the focus of the biological program, an ecosystem 

approach requires that a larger scale be used for long-term monitoring efforts. This effort will 

also assist the refuge in documenting landscape scale effects of global climate change such as 

changes in wetland drying, carbon budgets, permafrost depth, and species distribution. As 

outlined in Service Manual 602 FW 4, the I&M Plan will translate the goals and objectives from 

this Revised Comprehensive Conservation Plan into specific, achievable strategies (including 

those developed under various objectives under Goals 1 and 2) to be carried out on the refuge as 

part of its biological program. It will also facilitate incorporation of refuge information into 

regional and national databases. 

3. Objective: Continue to monitor avian biodiversity in support of continent, statewide, and 

bioregional efforts by conducting two national Breeding Bird Surveys (BBS) annually. 

Rationale: Policy (601 FW 3) dictates that each refuge should consider their contribution to the 

biological integrity, diversity, and environmental health at multiple landscape scales. 

Additionally, each refuge is encouraged to contribute to nationwide efforts where possible. 

Innoko Refuge established two boat-based BBS routes in 1992; these routes have been surveyed 

annually since their establishment. 

4. Objective: Within two years of funding, increase the number of breeding landbird surveys to 

include all major habitat types found on the refuge (i.e., conifer forest, deciduous forest, low 

shrub/tundra). 

2-2 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

Rationale: Innoko Refuge should increase the number of landbird surveys to include all major 

habitat classes representative of the refuge landscape. Partners in Flight high priority needs for 

range-wide monitoring of landbirds have called for new and expanded breeding season surveys in 

the boreal forest. To facilitate expanded surveys, the Partners in Flight and Biological Resources 

Division (BRD) of the U.S. Geological Survey (USGS) worked together to create the Alaska 

Landbird Monitoring System (ALMS). Four ALMS plots have been identified for Innoko Refuge. 

By adding these plots to the annual breeding bird surveys, Innoko Refuge could contribute to the 

long-term understanding of landbirds both on the refuge and across the boreal forest. 

5. Objective: In cooperation with Boreal Partners in Flight, and within two years of funding, 

develop and implement population monitoring surveys for diurnal and nocturnal raptors on the 

refuge, and incorporate them into the revised Inventory and Monitoring Plan. 

Rationale: The Innoko Refuge has a range of habitats from forest to open tundra, supporting a 

diverse raptor assemblage that includes 17 breeding species. Raptors are an apex predator and 

an indicator of ecosystem health. Methods of inventorying and monitoring their status should be 

developed and incorporated into the Innoko Refuge I&M Plan. 

6. Objective: In cooperation with neighboring State and Federal land managers, obtain a moose 

population estimate for at least one-half of the refuge at 1–3 year intervals by conducting aerial 

surveys to determine population trends. 

Rationale: Recognizing the ecological significance of moose and its importance to subsistence, 

Congress specifically stated that Innoko Refuge was created to conserve, among other things, 

moose and moose habitat. The refuge is also to allow for continued subsistence harvest 

opportunities where possible. Moose is the most sought-after terrestrial species by subsistence 

hunters who use Innoko Refuge. Additionally, moose hunting by other hunters results in 

approximately 75 percent of the non-subsistence visitor use days estimated to occur on the refuge. 

Refuge managers need current information on the status and trend of the moose population to 

assist with decisions affecting management of this resource and to continue participating in the 

Yukon-Innoko Moose Management Plan. 

Obtaining a refuge population estimate with a 90 percent confidence interval below approximately 

25 percent is expensive. The survey effort must be substantially expanded. Given current 

budgets, the refuge staff can only expect to conduct such surveys at about 2–3 year intervals. The 

refuge staff will conduct surveys annually if needed to address specific resource issues. 

7. Objective: Within five years of funding, conduct initial surveys to estimate abundance and 

winter distribution of wolves, wolverine, lynx, and marten on the refuge; use the initial surveys to 

begin assessment of population trends; and incorporate monitoring protocols into the Inventory 

and Monitoring Plan. 

Rationale: Furbearers are one of the reasons cited by Congress for the creation of Innoko 

Refuge. Little is known about terrestrial based furbearer populations and their distribution on 

the refuge. Furbearers are a significant component of the refuge’s natural diversity; and they 

have subsistence, cultural, and economic value to local residents. While population estimates for 

furbearers are expensive and likely not necessary given current trapping activity, given concerns 

expressed by local residents and nearby predator control programs, it is important to gather data 

on abundance and general distribution. These same data will also be needed to evaluate the 

effects of fire management and harvest on furbearer populations. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-3
Chapter 2: Goals, Objectives, and Management Direction 

8. Objective: Within staffing and funding constraints, monitor the beaver population on the 

refuge by conducting fall aerial surveys of beaver food caches at no more than five-year intervals. 

Rationale: The beaver is an important species on the refuge. Historically, people relied on them 

for both food and fur; their foraging and water manipulation activities influence aquatic and 

terrestrial habitats of fish and wildlife; and they are a prey species for larger predators. Refuge 

files indicate a moderate to high density of beaver may exist on the refuge. Statistically sound 

techniques for estimating the number of caches are now available to provide refuge-wide 

estimates with a reasonably high degree of accuracy and a minimum amount of effort 

(approximately 12–15 aircraft days). Repeated surveys will allow the refuge to assess the status 

and trends of beaver on the refuge in a quantitative fashion. 

9. Objective: Quantify snowshoe hare population cycles in cooperation with other interior Alaska 

refuges by standardizing survey protocols. This is to be accomplished by incorporating 

monitoring protocols into the I&M Plan during its preparation (see Objective 2). 

Rationale: Little is known about snowshoe hares on the refuge. Snowshoe hares are of particular 

interest due to their cyclical nature. The snowshoe hare is a keystone herbivore in the boreal 

forest with the potential to affect other species both as prey and as a competitor, and by changing 

plant characteristics through its browsing. Lynx and several raptors, in particular, respond 

favorably to increasing populations of snowshoe hares. These data are critical for interpretation 

of wildlife population trends. By standardizing survey protocols with other interior refuges, 

managers will be able to evaluate cycles and trends over broader areas and incorporate wildfire 

effects into management activities. 

10. Objective: As time permits during other field activities, investigate structures on the refuge 

for the presence of little brown bats over the life of this plan. 

Rationale: Innoko Refuge lies at the approximate northern distribution of little brown bats within 

Alaska. Their presence is known from villages south of the refuge but not from the refuge itself. 

Little brown bats, like other bat species in Alaska, have slow-growing populations. Bats could be 

affected during management activities around Gold Rush era structures and during maintenance 

of refuge administrative cabins. By determining the presence and distribution of little brown bats, 

the refuge could add to regional knowledge of the species, time cabin maintenance and historic 

structure management to avoid the bat pupping and nursing periods of late spring and early 

summer, and provide alternative bat-roosting structures. 

11. Objective: Immediately following approval of this Plan and prior to implementation of any 

wood bison project in the vicinity of Innoko Refuge, initiate field studies on Innoko Refuge to 

document existing conditions of selected wildlife populations and plant communities in areas 

adjacent to the proposed wood bison release site. Should the wood bison project proceed adjacent 

to the refuge, field studies will continue in order to determine changes in wildlife and plant 

communities (if any). 

Rationale: ADF&G is proposing a wood bison project adjacent to Innoko Refuge in the very near 

future. The extensive literature review provided by Gardner and DeGange (2003) and Alaska 

Department of Fish and Game (2007) clearly showed that no data exist regarding how resident 

wildlife populations (such as small mammals, ground-nesting birds, medium to large carnivores, 

and existing ungulates) and plant communities changed once wood bison were in the area. Figure 

1 (Gardner and DeGange 2003) clearly indicates that Innoko Refuge and the proposed Lower 

Innoko-Yukon River release sites are west of the western-most boundary of both the estimated 

distribution during the last 5,000 years and the region represented in existing oral and written 

2-4 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

accounts. Innoko Refuge not only has policy obligations to ensure continued biological integrity, 

diversity, and environmental health, but has preservation of moose, furbearer, and waterfowl and 

their habitats as primary purposes. Baseline data, coupled with continued monitoring following 

implementation of the State’s project, will enable the refuge to determine what (if any) impacts 

are likely due to the presence of wood bison. 

Cooperative Efforts 

12. Objective: Continue to collaborate with staffs of other refuges, agencies, and research 

institutes to obtain data needed for accomplishing refuge goals and to gain a better understanding 

of boreal forest ecosystem processes. 

Rationale: Cooperating on projects is a cost-effective strategy to address research needs during 

times of shrinking budgets. Many ecological questions are best studied on a regional scale and 

cannot be adequately addressed by working within a single land management unit (e.g., effects of 

climate change). Cooperative research enables the refuge staff to obtain information they would 

not normally be able to collect and provides an opportunity for the refuge to contribute to regional 

investigations. Results of such studies can facilitate management of resources on refuge lands, 

and it behooves the refuge to be included in these efforts by serving as a study site. Such 

cooperative endeavors also allow participants to learn more about their partners’ organizations. 

By working together, the refuge and its partners would be able to pool resources, share 

information, and make the best management decisions possible. 

13. Objective: Continue to implement and update existing cooperative management plans for 

refuge resources (e.g., Yukon-Innoko Moose Management Plan). Develop new plans with 

appropriate partners as needed. 

Rationale: Innoko National Wildlife Refuge will continue to develop good working relationships 

with adjacent landowners and agencies. Such relationships allow for better management across 

boundaries of locally important wildlife species. 

14. Objective: In cooperation with the U.S. Geological Survey Biological Resources Division 

(USGS-BRD), within two years of funding, determine factors potentially limiting greater whitefronted geese on molting areas and possible relationships between habitat conditions and survival. 

Rationale: One of the reasons for the establishment of Innoko Refuge was to protect interior 

Alaska greater white-fronted geese during the summer flightless period. However, despite the 

importance of this region, very little is known about the molting ecology of geese in interior 

Alaska. It is not known whether foraging habitat on Innoko Refuge is adequate to support the 

current population of 20,000–50,000 greater white-fronted geese molting there. Geese from 

interior Alaska are unique with respect to nesting ecology, migration behavior, and winter 

distribution compared to other mid-continent white-fronts (Ely and Schmutz 1999). There is 

concern for these geese within the central flyway, as the population has undergone a long-term 

decline in size and productivity (Spindler 1999) and has low survival rates compared to other midcontinent white-front populations. 

15. Objective: Continue participating in cooperative efforts with the Division of Migratory Bird 

Management in annual monitoring of Alaska mid-continent greater white-fronted geese by 

banding, radio tracking, and molt survey efforts as requested annually. 

Rationale: Innoko Refuge is a high density molting area in interior Alaska for greater whitefronted geese, including Tule white-fronted geese, a subspecies that numbers less than 8,000. Due 

to a scarcity of harvest distribution and survival data, a banding program was initiated in 1975 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-5
Chapter 2: Goals, Objectives, and Management Direction 

with a goal of marking 1,000 adult geese every season. Band recoveries have helped determine 

survival rates, flyway routes, and wintering areas used by geese. 

16. Objective: Continue to collaborate with the Boreal Program for Regional and International 

Shorebird Monitoring (Boreal PRISM) to help design and implement appropriate inventory and 

monitoring techniques for breeding and migrant shorebirds through the life of this Plan, and 

incorporate these techniques into the I&M Plan. 

Rationale: While shorebird usage of coastal habitats for migration is well documented in Alaska 

(e.g., Copper River Delta, Kachemak Bay), the value of ephemeral migratory habitats (e.g., spring 

flooding of meadows, late summer drying of wetlands) for inland migrants and/or breeders has been 

essentially overlooked in the State. Investigations of these habitats in the non-breeding seasons will 

contribute to a more complete inventory of shorebirds and their habitats within the refuge. 

Boreal forest-breeding shorebird species that occur on the refuge, such as lesser yellowlegs and 

solitary sandpiper, are showing steep continental population declines. Techniques to effectively 

monitor them are being developed and will require testing in areas such as interior Alaska refuges. 

17. Objective: Within two years of the Inventory and Monitoring Plan’s approval, work with the 

Fairbanks Fish and Wildlife Field Office to revise the Innoko Refuge Fisheries Management Plan. 

Rationale: The 1993 Innoko Refuge Fisheries Management Plan is a five-year step-down plan that 

provides numerous strategies for achieving refuge goals and objectives and addresses various issues 

and concerns regarding fisheries resources on the refuge. A revision of the Fisheries Management 

Plan is needed to accurately reflect current Service policy and refuge management direction. 

18. Objective: Continue to collaborate with Ecological Services in conducting studies of 

malformed wood frogs within the refuge. 

Rationale: The wood frog is the only amphibian species known to occur on Innoko Refuge. 

Increased sightings of malformed frogs throughout North America raised concerns about possible 

exposure to environmental contaminants. Baseline data collections began in 2002 near the field 

camp area of the refuge. Malformed frogs have been consistently located near the Field Camp 

but not in other ponds searched thus far. Continued collections will allow the refuge to compare 

trends over time and bolster current statewide efforts. 

19. Objective: Within three years of funding, work with partners to develop and implement 

strategies for the inventory of terrestrial invertebrates on Innoko Refuge, including but not 

limited to leaf miners and forest defoliators, and incorporate them into the Inventory and 

Monitoring Plan. 

Rationale: The importance of insects and other invertebrates in the function of forest ecosystems 

has been long recognized. However, additional information is needed to more fully understand 

and quantify their role in the boreal forest and establish a baseline for measuring changes in 

species diversity and population density over time. 

Research 

20. Objective: In cooperation with other agencies, monitor for fish and wildlife diseases and 

parasites that may affect the Innoko ecosystem. 

Rationale: Diseases (such as whirling disease, rabies, chronic wasting disease, and West Nile 

virus) and parasites (such as lice, tularemia, and trichinosis) are threatening populations of fish 

and wildlife throughout North America. Natural migration of fish, mammals, and birds may bring 

diseases or parasites to the Innoko Refuge ecosystem. As seen in 2002 and 2003, outbreaks of 

2-6 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

diseases such as chronic wasting disease and West Nile virus in areas outside Alaska can be 

devastating to wild animal populations. With active monitoring, timely management actions can 

reduce the impact of these diseases. 

21. Objective: Strive to publish results from refuge-sponsored research in peer-reviewed 

journals. Report routine fish and wildlife survey results regularly in publicly accessible reports to 

keep local residents and other interested groups informed. 

Rationale: Peer review ensures that the research meets current scientific standards. Before a 

technical manuscript can be published, it is reviewed for sufficiency by a committee of scientists 

with specialized expertise in the study topic. This committee recommends publication if the 

manuscript is sufficient but rejection if it is not. Publication promotes understanding by 

disseminating results to the scientific community and the public. 

By routinely providing information to all of the refuge’s constituents, more public input is 

garnered, and better decisions can be made by resource managers. It is in the best interest of the 

refuge to keep interested parties involved in the process because they are the ones for whom these 

lands are managed. 

22. Objective: Within four years of funding, determine annual abundance and productivity of 

waterfowl across a range of habitat types on Innoko Refuge, with a focus on northern pintails. 

Rationale: Innoko Refuge was set aside, in part, for its unique waterfowl values, and it has one of 

the highest densities of waterfowl found in interior Alaska. Annual breeding pair surveys indicate 

that approximately 185,000 ducks are found on refuge wetlands in early spring. Northern pintails 

are abundant on the refuge, and continental populations remain below North American Waterfowl 

Management Plan goals. Extensive, long-term field studies are critical to assess pintail 

distribution and recruitment in important Alaska nesting regions. The data collected during this 

effort can identify habitats important for nesting, molting, and brood rearing. This information 

will also provide baseline data that can be use to assess localized impacts of both wetland drying 

and wood bison grazing on nesting waterfowl abundance and productivity. 

23. Objective: Within two years of funding, replicate a study of wetland habitat conducted during 

the 1980s on Innoko Refuge. 

Rationale: From 1985 through 1993, waterfowl production surveys were conducted on 

approximately 30 randomly selected one-square-mile plots. In addition to waterfowl data, 

vegetation was described, including percent vegetated and cover values for all aquatic plant 

species from 143 waterbodies on 21 of the production plots. The waterfowl data were not found to 

be useful. Returning to these plots two decades later would allow us to document wetland drying 

and changes to aquatic vegetation related to lower water levels. There is a unique opportunity to 

document habitat changes over time. 

24. Objective: Replicate (and where necessary, modify) the 1994–1995 expanded aerial waterfowl 

breeding pair survey in cooperation with the Division of Migratory Bird Management throughout 

the life of this Plan. The survey should be conducted regularly (e.g., every five years) thereafter. 

Rationale: Waterfowl are a trust species and are specifically mentioned in the refuge’s purposes 

(section 1.4.1). Aerial line transect surveys of breeding waterfowl have been conducted annually 

on the refuge since 1957 as part of the North American Waterfowl Breeding Pair Survey 

(NAWBPS). Waterfowl and waterbird distribution and abundance data based on only the five 

NAWBPS transects that fall within the refuge are likely not representative of the refuge, given 

the available wetland habitat not covered by the survey lines. The best data on distribution and 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-7
Chapter 2: Goals, Objectives, and Management Direction 

abundance of breeding waterfowl and waterbirds on or near the refuge are derived from a 1994–

1995 aerial survey (Platte 1996). Regular replication of this survey (e.g., every five years) would 

provide a continuing picture of distribution and serve as a basis for monitoring. Because a single 

survey targeting dabbling and diving ducks and sea ducks would likely be better timed for one 

group than the other (or perhaps be mistimed for both groups), two within-year surveys—

targeting first dabbling ducks, then the later-nesting diving ducks and sea ducks—would increase 

accuracy of estimates. 

25. Objective: Within three years of funding, determine current species composition, distribution, 

productivity, and habitat preferences of swans on the refuge, and develop a monitoring strategy 

for inclusion into the Inventory and Monitoring Plan. 

Rationale: Because the refuge contains habitat for both trumpeter and tundra swans, which 

cannot be separated into species in aerial surveys, it is not included in statewide aerial surveys for 

trumpeter swans conducted every five years by the Service. Although both species of swans are 

known to breed on the refuge, it is uncertain which species predominates and what habitat 

associations might separate the two species. While both species of swans are increasing in 

numbers in Alaska (Conant et al. 2007, Mallek and Groves 2007), populations are still at risk from 

continued loss of wintering habitat, concentration of wintering flocks at relatively few sites, and 

lead poisoning. It is important to identify and monitor the abundance of each species in areas 

where ranges overlap. 

26. Objective: For those species of migratory birds that regularly breed on the refuge and that 

are demonstrating long-term population declines, continue collaboration throughout the life of this 

Plan with other agencies and organizations on monitoring activities, research projects, and public 

outreach efforts that contribute to the conservation of these species. 

Rationale: Boreal forest breeders that regularly occur on the refuge and that are experiencing 

continental declines include northern pintail, lesser yellowlegs, solitary sandpiper, olive-sided 

flycatcher, blackpoll warbler, and rusty blackbird. Refuge support could include providing study 

sites for projects, testing methods, and participating in working groups (e.g., Rusty Blackbird 

Working Group). 

27. Objective: Within five years of funding, complete efforts to determine the seasonal 

distribution and critical habitats of the moose population that occupies Innoko Refuge and 

surrounding lands. 

Rationale: Moose are a prominent feature in the boreal landscape and are culturally and 

economically important to humans in interior Alaska. Longstanding concerns about moose 

availability and subsistence opportunities have been voiced by local users. Delineating the 

seasonal distribution and habitat use of the local moose population will allow us to identify and 

address potential management issues (e.g., hunting, wildfire, development). 

28. Objective: Within three years of funding, document seasonal abundance and distribution 

of caribou. 

Rationale: Caribou were the most abundant large mammal species in the Innoko Refuge region 

in the 1800s. Caribou were traditionally an important subsistence species and were heavily used 

by early prospectors in the region. The Beaver Mountain Caribou Herd appears to have declined 

in recent years; however, other than incidental observations, quantitative information on their 

abundance and seasonal distribution is absent. Local subsistence users and local resource 

managers desire additional information on the status of the Beaver Mountain Caribou Herd. 

Additionally, seasonal distribution information is critical to understanding if and how wildfire 

2-8 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

management should be altered on Innoko Refuge to ensure that caribou continue to use important 

areas both on and adjacent to the refuge. 

29. Objective: Within six years of funding, determine the life history parameters, distribution, 

and seasonal use patterns of black bears on the refuge. 

Rationale: When Congress created Innoko Refuge, the conservation of black bears and their 

habitat was specifically identified as one of the reasons. Little is known about the number of black 

and brown bears on the refuge. Local subsistence users report observing more bears in 

traditional moose hunting areas than in the previous 30 years. Additionally, recent changes that 

liberalize bear hunting regulations have generated increased concern about bear populations and 

their status. Previous research on basic life history parameters for black bears in interior Alaska 

is very limited, is dated, and is all from study areas in the eastern portions of the State. 

Conducting basic life history research using current and emerging technologies would begin to 

answer many questions about the refuge’s current black bear population and allow managers to 

evaluate black bear–moose relationships. 

30. Objective: Within two years following the completion of a study of seasonal use patterns (see 

Objective 29), work with partners to develop protocols for estimating abundance and density of 

black bears on the refuge. Then within two years of funding, initiate the first effort to estimate 

abundance and density of black bears on the refuge. 

Rationale: New methods have emerged that allow for unbiased population estimation of forest 

dwelling bears provided seasonal use patterns are known for males and females. Using 

information collected on seasonal distributions and movement patterns, and collaborating with 

bear researchers experienced in design and implementation of these specific surveys, a protocol 

will be developed. This protocol, when implemented, would obtain data for the first estimate of 

black bear numbers and density for the refuge. 

31. Objective: Within five years of funding, evaluate distributions of furbearer populations, 

including but not limited to wolf, wolverine, lynx, marten, mink, and weasel, in relation to fire 

severity. This objective is dependent on Objective 7. 

Rationale: Furbearers are one of the reasons cited by Congress for the creation of Innoko 

Refuge. Furbearers are a significant component of the refuge’s natural diversity; and they have 

subsistence, cultural, and economic value to local residents. In the boreal forest, a range of postfire seral stages provides different habitat requisites for different furbearers. Wildfire timing and 

severity affect the rate of vegetative succession and post-fire recolonization of many species. 

Utilizing a variety of remote sensing technologies, managers can estimate the severity of wildfires 

at the landscape scale. This effort would combine these remote sensing technologies with previous 

and newer land cover mapping efforts and recent knowledge of furbearer distributions to improve 

our understanding of the short- and long-term response of furbearers to fire. 

32. Objective: Integrate existing moose distribution and census information with bear and 

furbearer distribution and census information to outline predator-prey relationships on the refuge. 

Using this outline, apply for funding to evaluate predator-prey relationships on the refuge. 

Rationale: Moose, furbearers, and black bears were all cited by Congress as reasons for creation 

of Innoko Refuge. Local subsistence users have been asking if there are fewer moose due to 

excessive predation. Predator control efforts by the State in nearby areas are increasing the 

public’s awareness of predator-prey issues. By integrating data collected from ongoing moose 

census efforts with new efforts to collect information on numbers and seasonal distribution of 

black bears and large furbearers (e.g., wolf and lynx), insights can be gained on possible predatorInnoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-9
Chapter 2: Goals, Objectives, and Management Direction 

prey relationships on the refuge. These insights would then be used to generate managementrelated questions upon which to base specific funding requests. This objective is dependent upon 

completion of several other objectives. 

33. Objective: On approval of funding, initiate long-term studies of how small mammals (including 

species diversity, distribution, and relative abundance) and vegetation are affected by fire. 

Document changes to forest succession from differing fire intensities during the life of this Plan or 

until results indicate small mammal populations have stabilized. 

Rationale: Periodic fire is one of the primary natural forces that form the mosaic of habitats 

present on Innoko Refuge. Vegetation regrowth after fire often affects forage availability and the 

distribution of animals. The amount, species, and quality of vegetative regrowth after fire depend 

on several factors. Fire severity can affect the rate of vegetative succession and post-fire regrowth. 

Small mammals are an important prey item for many mammalian and avian predators. Although 

fire has been shown to be beneficial for some species of small mammals, little is known about how 

small mammals respond over time to a range of fire severity within various vegetation types. 

34. Objective: Within five years of funding, determine the seasonal distribution (spawning, 

rearing, wintering) and migratory patterns of northern pike and select species of whitefish. 

Rationale: Both northern pike and whitefish are important to local subsistence users. There has 

been a long-standing need to determine resident fish abundance and distribution in the Innoko 

River and its larger tributaries (e.g., Iditarod, Mud, and Dishna rivers). Additionally, other 

studies point to the refuge area rivers as being important rearing grounds for Yukon River 

resident fisheries. Determination of the seasonal distribution and critical habitat areas on the 

refuge would assist local managers and contribute to management efforts throughout the Yukon 

River system. 

35. Objective: Within two years of completing baseline data collection of selected contaminants, 

initiate research to evaluate uptake of identified contaminants by selected indicator species (e.g., 

brown bears, black bears, sculpins). The refuge will work with the State of Alaska as appropriate. 

Rationale: The immediate monitoring of point and nonpoint sources of contaminants and water 

quality does not fully address the potential effects of anthropogenic pollutants on refuge fish and 

wildlife. Environmental contaminants from local and distant sources are subject to short- and 

long-range transport. Arctic and subarctic environments are especially vulnerable to the longrange air and water transport of environmental contaminants because once chemicals reach colder 

climates, less volatilization occurs. Contaminants of particular concern within the Arctic include 

persistent organic pollutants, polycyclic aromatic hydrocarbons, heavy metals, and radionuclides. 

Anadromous fish and migratory birds are also possible biotic sources of contaminants. Because 

these taxa are highly mobile, they may be exposed to contaminants outside of the refuge 

boundaries. Brown bears, for example, may be exposed to PCBs by ingesting salmon that 

accumulate PCBs from their years at sea. Similarly, migratory birds may be exposed to 

potentially toxic chemicals on their wintering grounds in the contiguous 48 States and in other 

countries, including organochlorines that are banned in the United States. This migratory 

transport of contaminants provides a potential exposure pathway to other organisms that would 

otherwise likely not be exposed to these chemicals. 

2-10 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

GOAL 2 – HABITAT 

Perpetuate ecosystem processes that shape habitats within the natural range of variability 

Planning 

36. Objective: Within five years of the I&M Plan’s approval and within staffing capabilities, and 

in cooperation with appropriate partners, develop the refuge’s Habitat Management Plan as part 

of a larger regional effort. 

Rationale: Each national wildlife refuge is required to develop a habitat management plan under 

Service policy 620 FW 1.5. However, the need for this plan extends beyond Service policy and the 

refuge itself. Innoko Refuge has a variety of challenging issues, such as proposed mineral 

extraction activities and pronounced natural processes (e.g., flooding, wildfire). The refuge is 

bordered by the Yukon River, which servers as a corridor for factors such as invasive species and 

contaminants. Although refuge lands are the focus of the biological program, an ecosystem 

approach requires that a larger scale be used for long-term monitoring efforts. This effort will 

also assist the refuge in documenting landscape-scale effects of global climate change such as 

changes in wetland drying, carbon budgets, permafrost depth, and species distribution. 

37. Objective: Within five years of approval of the I&M Plan, and within funding, staffing, and 

time constraints, formulate a strategy for inventorying wetland, lake, stream, and river resources 

within the refuge, including aquatic plants, fish, wetland-dependent wildlife, aquatic invertebrates, 

and physical and chemical properties of lakes and wetlands. Implement this objective as funding 

is provided. 

Rationale: Additional data are required to describe the waterbodies and wetlands within refuge 

boundaries, including the plants and wildlife dependent on them, and to establish a baseline for 

comparison of future conditions. Changes in water quality and quantity can affect the diversity 

and abundance of fish, wildlife, and plants within the refuge, but very little is currently known 

about existing conditions. Refuge staff would work with specialists from other Service branches 

and outside the Service to develop feasible and productive studies. 

38. Objective: Within 10 years of the Plan’s approval, work with USGS Water Resources Division 

to evaluate installation and operation of official water gaging stations on the refuge. 

Rationale: In 1996, the USGS concluded an “Evaluation of the Streamflow-Gaging Network of 

Alaska in Providing Regional Streamflow Information” (Brabets 1996). The primary purpose of the 

gaging network is to provide peak flow, average flow, and low flow characteristics through a series 

of regional equations. The objective is part of a large-scale effort to provide regional streamflow 

characteristics to users for all regions of the State. Sampling error would decrease by 3 percent for 

the peak discharge equation, 10 percent for the average discharge equation, and 20 percent for the 

low flow equation (Brabets 1996). With multiple mineral development projects proposed for the 

western interior region, the information provided from the network would assist land managers and 

resource developers in the planning and the decision making process. Installation of water gaging 

stations would provide the refuge with site specific information that could support the development 

of a water budget and support instream flow water right reservations. 

39. Objective: Within the life of this plan, assess the feasibility of developing a hydrologic model 

for the refuge’s principal watersheds. 

Rationale: A hydrologic model tracks the input, storage, movement, and output of water within a 

basin. Such a model would allow the refuge to track and predict changes in water resources and 

evaluate the effect of these changes on fish, wildlife, plants, and people. For example, climate 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-11
Chapter 2: Goals, Objectives, and Management Direction 

change could lead to changes in precipitation patterns that could affect flooding regimes and 

water quantity, melting of permafrost with alteration of drainage patterns, and changes in water 

temperature that could affect the survival of fish, aquatic plants, and invertebrates. Model results 

are highly dependent on the availability and quality of input data, and the refuge currently does 

not have the information necessary to develop even a basic model. Data collected during projects 

listed in other objectives (e.g., snow depth monitoring, water resources inventory, water gaging 

stations) will be incorporated into the model and will enable the refuge to assess additional data 

required to improve the model. 

40. Objective: Continue to support the Service Water Resources Division in their efforts to 

secure refuge instream water rights. 

Rationale: The Water Resources Division monitored nine streams as they entered the refuge for 

five years, including periodic water quality sampling. Once these data have been fully analyzed, 

the Water Resources Division will file for water rights with the State of Alaska on behalf of 

Innoko Refuge. The refuge will continue to work with the Water Resources Division to analyze 

these data and support the filing of water rights. 

41. Objective: Within two years of funding, seek collaboration to initiate a water quantity and 

quality monitoring program for waters within the refuge that includes investigating 

anthropogenic influences. 

Rationale: One purpose for Innoko Refuge is to ensure water quality and quantity necessary for 

the conservation of fish, wildlife, and their habitats. Little is known about pollution affecting 

waters within the refuge. Human activities on the refuge and other activities on adjacent lands 

have the potential to affect water quality. Improper waste disposal, motor boats, and snowmobiles 

are some of the known sources of pollution within the refuge. Gathering data will help the refuge 

compare changes over time and assess the impacts from pollution sources on and near the refuge. 

42. Objective: Throughout the life of this Plan, endeavor to move the mobile Remote Automated 

Weather Station (RAWS) facility to other portions of the refuge. Evaluate the weather data and 

determine how representative the permanent RAWS facility is to other regions of the refuge and 

whether additional permanent stations would significantly improve the system’s predictive capability. 

Rationale: There is concern that the existing weather station may not represent actual conditions 

in the southern or eastern portions of the refuge. By moving the refuge’s one portable RAWS 

facility to other parts of the refuge for an entire summer season, managers would have the ability 

to evaluate how representative data from the Innoko Flats RAWS facility is to the entire refuge 

for dealing with potential wildfires. This would also provide managers with critical local weather 

information that could be included in habitat, wildlife, and climate studies on the refuge. 

43. Objective: Continue implementing the refuge’s Fire Management Plan. 

Rationale: According to the Department of the Interior Manual 620 and National Fire Plan policy 

(2001), agency and refuge approved fire management plans are required to continue managing all 

fire operations on refuge lands. It is required by policy (minimum) that every five years, the refuge 

Fire Management Plan be revised to reflect any changes on an agency and interagency perspective. 

44. Objective: At five-year intervals following the Plan’s approval, assess and report fire 

occurrence, fire causes, fire behavior, fire intensity, and fire effects trends and interagency issues 

(using the best available technology and data) to provide fire managers the information necessary 

to revise the refuge’s Fire Management Plan. 

2-12 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

Rationale: As stated in Objective 43, the policy standard for revision is a five-year interval 

according to the National Fire Plan (2001). Additionally, fire effects monitoring will be necessary 

to evaluate refuge and fire management decision criteria for a five-year evaluation of the existing 

refuge Fire Management Plan. The fire effects monitoring will include short- and long-term 

monitoring criteria for caribou lichen through the fire-impacted areas to guide future 

management decisions. 

Mapping 

45. Objective: Within two years of completion of an updated land cover dataset (see Objective 49), 

incorporate expanded aerial waterfowl breeding pair survey data to identify and classify 

important waterfowl habitat. 

Rationale: A current land cover map would provide a foundation for numerous data products—one of 

which is identification of important waterfowl habitat. Geographic Information Systems (GIS) can be 

a powerful tool for assembling, storing, manipulating, analyzing, and displaying geographically 

referenced information. Deriving and classifying important waterfowl habitats on the refuge will 

assist managers in directing future waterfowl related investigations and decision making. 

46. Objective: Provided that fish, wildlife, habitat, and disturbance inventories have been 

conducted as described elsewhere in this Plan, develop models that begin to explain how biotic and 

abiotic factors affect the distribution of species and communities of management concern at the 

landscape scale. 

Rationale: The collection of floral and faunal sampling across the refuge will enable managers to 

model species distribution over the landscape. In particular, the refuge will be able to model how 

wildlife distribution and abundance are affected by habitat, topography, elevation, and changes to 

the landscape. The development of species-habitat models will allow the refuge to better assess 

the impacts of development on the refuge and global climate change and to better use habitat 

management tools such as prescribed fire. 

47. Objective: Develop fire progression maps for future refuge fires as opportunities allow 

throughout the life of this plan. 

Rationale: Progression maps can be used to validate and refine fire spread models, improve 

future predictions of spread, and assist in the interpretation of fire severity remote sensing. 

Linking fire progression data with weather and fuel data will allow managers to refine fire 

behavior predictions for the refuge. 

48. Objective: Within one year of a fire’s occurrence on the refuge, develop a fire severity map if 

sufficient data are available. 

Rationale: Recent work on Innoko Refuge and other interior Alaska refuges has shown promise 

in using remote sensing technologies to estimate severity of wildfires across the landscape. 

Accurate severity estimates, combined with updated land cover data, provide a solid baseline for 

numerous future habitat and wildlife research within burned areas, and allow managers to make 

better estimates of potential habitat changes to species of concern. 

49. Objective: Within three years of funding, create an updated land cover map of vegetation and 

wetland communities using satellite imagery and Multi-Resolution Land Characteristics (MRLC) 

or other advanced methods. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-13
Chapter 2: Goals, Objectives, and Management Direction 

Rationale: Fire and flooding are the primary sources of changes to the landscape within Innoko 

Refuge. There have been two previous land cover mapping efforts for the refuge—each using 

different classification schemes, thereby complicating our ability to monitor changes across the 

landscape. The last land cover map was derived using satellite imagery collected in 1991; this map 

did not cover the entire refuge and is now vastly outdated due to the numerous wildfires that have 

occurred since then. Medium resolution satellite imagery (i.e., 30 x 30 meter pixels) is adequate 

for monitoring habitat changes at the landscape scale; updated land cover data are basic for 

wildlife monitoring, wildfire modeling, recreation planning, and biological research. The refuge 

needs both the current distribution of habitats and a cost-effective way to monitor changes in 

those habitats. 

50. Objective: Within one year of completion of the updated land cover map, develop data 

crosswalks to fire fuels classification systems, including but not limited to the National Fire 

Danger Rating System (NFDRS), Landscape Fire and Resource Management Tools 

(LANDFIRE), Fire Regime/Condition Class (FRCC), and the National Fire Fuel Laboratory 

(NFFL) system. 

Rationale: A current land cover map would provide a foundation for numerous data products—

one of which is fire fuels. Fire fuel datasets will provide base inputs for short- and long-term fire 

behavior modeling using existing predictive software. These fire behavior models are used to 

develop prescribed fire plans, Wildland Fire Situation Analyses (WFSAs) and Wildland Fire 

Implementation Plans (WFIPs). Completion of fuels mapping will allow refuge fire managers and 

incident management teams to use proven fire behavior and fire effects predictive modeling tools 

to better manage wildland and prescribed fires and make better decisions. 

51. Objective: Acquire funding to purchase the 1950s panchromatic aerial photographs (1:40,000) 

from the U.S. Geological Survey for all lands within the refuge boundaries, and complete 

conversion of all historic aerial photography into geo-referenced, orthorectified digital images for 

use in wetland and habitat change detection analysis. 

Rationale: Historic photography is a valuable tool to assist managers and researchers monitoring 

changes in refuge resources caused by natural or anthropogenic disturbances. Historic 

photography provides valuable information when complete baseline information is lacking. 

However, due to the location of Innoko Refuge, aerial photography is limited; consequently, what 

exists is of exceptional value for management. The photography is also valuable from a strictly 

historic perspective. Digital reproduction will help preserve the original photography. The refuge 

has a complete set of high-resolution, color, infrared (1:60,000) photographs taken from 1978 

through 1980 and in 2006 (1:30,000). Adding the 1950s photos to this existing dataset would allow 

refuge staff to have a greater understanding of changes through time. 

Inventory and Monitoring 

52. Objective: Throughout the life of this Plan (as allowed by winter precipitation), obtain baseline 

information about late winter availability of moose forage under differing snow depth regimes. 

Rationale: As noted earlier in this chapter, moose are an important resource on the refuge, and 

considerable effort is expended to monitor their population. It is difficult to predict how many 

moose an area can support because of complex and changing interactions among habitat, weather, 

predation, and hunting pressure. The refuge currently monitors a number of these factors (i.e., 

moose numbers, human harvest, snow depth, fire history), but relatively little information on the 

availability and use of forage species, primarily willows, is available. Collecting data on moose 

forage in late winter (late March–early April) allows for analysis when snow depth is at its peak, 

2-14 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

forage availability is limited due to earlier browsing or being buried under the snow, and moose 

are physiologically stressed. Information on late winter availability of browse under differing 

snow depths will enable a better understanding of the potential for the habitat to support moose 

and will assist in understanding moose distribution under differing snow depth regimes. 

53. Objective: Using a landscape based approach, quantify winter moose forage species condition 

during the same calendar year that population estimates are made. 

Rationale: Building on Objective 52, which will allow the refuge to determine the distribution of 

available winter moose forage, the refuge needs to use new techniques for measuring the condition 

and status of moose forage over the broad areas covered in winter moose population estimation 

efforts (see Objective 6). By correlating late winter forage availability, snow depth, forage 

condition, and late winter moose distribution and number, managers will be better able to 

understand the dynamics of the moose population and determine what limitations, if any, forage 

has on the refuge. 

54. Objective: Within two years of funding, develop inventory and monitoring strategies to assess 

the effects of fire on caribou and moose habitat quality, and incorporate these strategies into the 

I&M Plan. 

Rationale: Both moose and caribou are locally important to subsistence users, and it is important to 

quantify and monitor the availability of quality habitat for both species. It is also generally agreed 

that both moose and caribou habitat and population dynamics are affected to some extent by fire. 

The character of these relationships, however, remains unclear, for caribou in particular. The 

amount, species, and quality of forage regrowth after fire depend on several factors. The 

composition of the pre-fire community, time of year of the fire, fire intensity, size of the fire, and 

burn patterns are all important to monitor. This information will assist the refuge, agencies, and 

boards responsible for management of moose and caribou populations, and for management of fire. 

55. Objective: Within three years of the Plan’s approval and within the constraints of staffing and 

funding, develop a geodatabase model and supporting relational database system that is 

compatible with the refuge’s GIS. The model and supporting database will be capable of storing 

and managing the refuge’s current data collections. The model and database will also include 

provisions for streamlining the entry of future data collected by electronic and paper means. 

Rationale: GIS can be a powerful tool for assembling, storing, manipulating, and displaying 

geographically referenced information. Over the course of the refuge’s history, a wide variety of 

biological and management activities have occurred. Using these historic efforts as a base, it is 

possible to develop a geodatabase model that can accommodate the existing legacy data and much 

of the foreseeable future data as well. Geodatabases designed in this fashion will allow refuge 

staff to more efficiently store, retrieve, and analyze data that it collects. These same geodatabases 

will simplify data collection in the future. 

56. Objective: Within five years of the development of the geodatabase model and supporting 

relational database system, and within staffing capabilities, complete entry and validation of all 

legacy biological and abiotic data. 

Rationale: Conversion of existing legacy data into an electronic format and linking these data 

geographically (where possible) enables the data to be accessed by the refuge’s GIS. Assembling 

biological and abiotic information into a database that is compatible with the refuge’s GIS will 

make this information readily accessible to more users, minimize duplication of effort, and 

maximize GIS implementation as an analysis and management tool. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-15
Chapter 2: Goals, Objectives, and Management Direction 

57. Objective: Implement the refuge’s Land Protection Plan and monitor development of 

inholdings and uses of lands adjacent to the refuge for activities that could adversely affect refuge 

users or resources. 

Rationale: Innoko Refuge has over 75 inholdings of private land accounting for almost 240,000 

acres; regional and village corporations account for the majority of the area. Of these inholdings, 

61 are small parcels (ranging in size from 3 to 160 acres) that are completely surrounded by refuge 

owned lands. The recently completed Land Protection Plan calls for consolidation of land 

ownership where possible. In addition, the refuge has placed a high interest in those parcels 

located within the Innoko Wilderness because they are located within this designated wilderness. 

The refuge will remain committed to work with land owners to ensure minimal impacts to 

natural resources. 

58. Objective: Continue to document fire history patterns on the refuge and participate in 

research on Alaskan fire regimes during the life of this Plan. 

Rationale: Fire and flooding are the primary causes of habitat disturbance and subsequent 

vegetation regrowth on the refuge and is therefore a key determinant of how the ecosystem 

changes. Our current knowledge of fire history patterns is insufficient to manage for natural fire 

regimes or adapt to potential habitat or population changes caused by climate change. Refuge 

staff will continue to document fire history patterns on the refuge using historic records and 

appropriate field studies and will continue to participate in localized or regional fire ecology 

research during the life of this Plan. 

59. Objective: Within two years of funding, begin annual measurements of the production of 

berries that are important as forage for wildlife species on the upland habitats and for subsistence 

activities, and assess trends in production in relation to fire severity and climate data. 

Rationale: Wild berries are an important component of annual subsistence activities and Native 

culture. Berries have also been shown to be seasonally important to many migratory birds, some 

furbearers, small mammals, and bears. Fire severity can affect the rate of vegetative succession 

and post-fire establishment of berry producing plants. This study will provide a better 

understanding of the relationships among fire severity, weather, and the distribution, abundance, 

and annual fruit production following fire. 

60. Objective: In cooperation with the Natural Resources Conservation Service (NRCS), continue 

to monitor snow depth at nine snow markers on a monthly basis (December–May) and monitor 

snow density at the refuge field camp on a monthly basis (December–May). 

Rationale: In 1996, refuge staff worked with NRCS to establish nine snow depth measuring poles 

throughout the refuge. Refuge staff have since recorded snow depth at these nine points every 

December through May and forwarded that data to NRCS for inclusion in their statewide 

database. Additionally, snow density (i.e., water content of the snow) has been measured at the 

field camp or at McGrath when landing conditions were unsafe at the field camp. The amount, 

density, and duration of snow cover on the refuge can affect a variety of factors and functions, 

including distribution and overwinter survival of wildlife; spring flooding and nutrient input to 

lakes; timing of spring bird migration; and the timing and probability of fire each spring. 

Continuation of this project is important to the refuge. 

61. Objective: Depending on availability of funding, continue to assess levels of selected 

contaminants in water, sediments, and fish tissue at five-year intervals. 

2-16 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

Rationale: Historically, decline and recovery of bird populations have been linked to incidence 

of many factors, including environmental contaminants. Arctic and subarctic environments are 

especially vulnerable to the long-range air and water transport of environmental contaminants 

because once chemicals reach colder climates, less volatilization occurs. Working with 

appropriate partners, the Service will continue to collect samples to monitor baseline 

contaminants, compare changes over time, and assess the impacts, if any, from potential 

contamination sources on and near the refuge. 

62. Objective: Throughout the life of this Plan (if adequate funding is available), monitor 

landscape changes of both vegetation and physical features at five-year intervals or after a 

significant disturbance. 

Rationale: The refuge will monitor landscape-level changes in vegetation (e.g., fire, insect outbreak) 

and physical features (e.g., rivers, wetlands) using tools such as medium- and high-resolution 

satellite imagery. This technology provides an extremely cost-effective and reasonably accurate 

method for assessing vegetation and wildlife habitat change over time, updating refuge land cover 

maps, and assessing the long-term effects and effectiveness of various fire management decisions. 

63. Objective: Within five years of funding, complete an inventory of vascular plants across all 

refuge habitat types. 

Rationale: Innoko Refuge has an obligation to protect natural plant diversity. Previous 

inventories have begun to document the variety of plants on the refuge, including surveys of 

lichens and bryophytes. Voucher specimens from these inventories are housed in the refuge 

herbarium. Expanding this inventory and developing an appropriate database for inclusion in the 

refuge GIS will provide important baseline information against which to compare changes over 

time, including documenting the presence of rare plant species. The database and voucher 

specimen collection also serve as a valuable resource for teaching and as a reference collection. 

64. Objective: Complete reconnaissance and conduct monitoring of terrestrial and aquatic 

invasive plant and animal species near historical communities and other high public use areas. 

Rationale: Refuge staff has been working to search both historic sites and high use public sites 

for the presence of invasive plant species. Invasive plant species have been recorded near the 

field camp and on higher sand bars along the Innoko River. The last of these historic sites and 

public use sites need to be inventoried for the presence of invasive plant species. Additionally, 

surveys for invasive aquatic plants and animals and for non-native and/or invasive animals need to 

be conducted. Where invasive species are located, monitoring needs to be conducted to ensure 

that spreading to other parts of the refuge does not occur. 

65. Objective: Within two years of funding, use remotely sensed imagery to determine wetland 

area loss for closed- and open-basin wetlands on Innoko Refuge. 

Rationale: Climate change is more pronounced at northern latitudes, and warming temperatures 

have been implicated in wetland drying in boreal Alaska and Siberia. Recent studies in the 

reduction of surface water using aerial photography of closed-basin wetlands taken over a 50-year 

period indicated that drying has been most severe in westcentral Alaska (Kaiyuh Flats). Given 

unprecedented warming and drying conditions and the importance of water to the ecology of 

Innoko Refuge, determining wetland area loss should be a high priority. 

66. Objective: Continue cooperative efforts to document and monitor invasive non-native insect 

impacts to larch, aspen, and willow. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-17
Chapter 2: Goals, Objectives, and Management Direction 

Rationale: Invasive non-native insects were observed causing mortality to larch in the 1990s. The 

refuge and U.S. Forest Service began cooperative studies in 2000 to measure impacts to marked 

trees. Of the live trees marked in 2000, 87 percent were defoliated and dead by 2007 due to insect 

infestation. This high mortality rate is being observed throughout the refuge. Should this 

continue, these insects threaten to eliminate larch from the needleleaf and mixed forest 

communities found on Innoko Refuge. Recently, invasive non-native insects have been observed 

affecting aspen and willows as well. The U.S. Forest Service conducts aerial surveys over portions 

of Alaska each fall; these surveys have infrequently included small portions the refuge. Innoko 

Refuge has the means to provide field logistical support to ensure that a greater proportion of the 

refuge is consistently included in these annual surveys. 

GOAL 3 – SUBSISTENCE 

Provide the opportunity for continued subsistence uses of the refuge, consistent with the 

subsistence priority and with other refuge purposes 

Note: Many of the objectives under Wildlife and Habitat (Goals 1 and 2) also contribute to the 

Subsistence goal. 

67. Objective: Continue the Refuge Information Technician (RIT) program to enhance 

information exchange with local communities on refuge issues, particularly those dealing with 

subsistence issues. 

Rationale: Due to their isolated locations, residents of the GASH villages (Grayling, Anvik, 

Shageluk, and Holy Cross) have less contact with the refuge staff than residents of McGrath or 

Takotna. The RIT position at Innoko Refuge has been one way to change that. With this staff 

position, more time can be devoted to contacting tribes, corporations, and individuals who do not 

have ready access to the refuge office. This person prepares information specifically for the 

villages and visits the villages regularly. While in the village, the RIT can personally deliver 

information, answer questions, and return with feedback for refuge staff. 

68. Objective: As a continuing commitment, conduct annual informational meetings in each 

village associated with the refuge and regularly attend other subsistence-related meetings, 

providing information regarding the status of subsistence resources and their use, and 

commenting on proposals related to subsistence management within the refuge to maintain a 

respectful dialogue with refuge resource stakeholders and subsistence users. 

Rationale: The refuge is mandated by Alaska National Interest Lands Conservation Act 

(ANILCA) to provide the opportunity for continued subsistence uses by local residents when 

consistent with other refuge purposes. However, it is essential that affected parties work 

cooperatively towards common subsistence goals. Face-to-face meetings in local villages are the 

most effective forum for reviewing and explaining Federal subsistence harvest regulations 

promulgated to conserve fish and wildlife populations and to discuss issues of local concern to 

subsistence users. 

69. Objective: Continue to work closely with tribal councils, the GASH Advisory Committee, the 

Federal Subsistence Western Interior Regional Advisory Council, other local and/or regional 

working groups, Alaska Department of Fish and Game, and the Office of Subsistence 

Management to address issues and concerns through the State and Federal regulatory processes 

as provided in ANILCA to conserve fish and wildlife. 

2-18 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

Rationale: The refuge is mandated by ANILCA to provide the opportunity for continued 

subsistence uses by local residents when consistent with other refuge purposes. It is essential 

that affected parties work cooperatively towards achieving common subsistence goals. 

70. Objective: Continue to work with tribal councils, Alaska Department of Fish and Game 

(ADF&G) Subsistence Division, and Alaska Migratory Bird Co-management Council to develop 

and implement a subsistence harvest monitoring plan to conserve migratory bird populations for 

future subsistence use. 

Rationale: ANILCA and recent amendments to the Migratory Bird Treaty Act direct us to 

conserve migratory birds for continued subsistence use and document traditional migratory bird 

harvest levels. The amendment established a spring–summer migratory bird subsistence hunt 

that has the potential to affect the conservation of many species. A cornerstone of the amendment 

was that the current level of harvest would remain the same. A harvest monitoring plan and 

implementation protocol based on an accurate estimate of harvest are needed to ensure long-term 

conservation of trust species and continued opportunity for subsistence use. Continued 

communication and collaboration between the refuge and local governments is critical in 

conducting successful and accurate subsistence harvest monitoring programs. 

71. Objective: Continue to coordinate with and assist the Division of Migratory Bird Management 

in completing the annual Migratory Bird Harvest Survey. 

Rationale: The Migratory Bird Treaty Act Protocol Amendment provides for harvest of 

migratory birds during spring and summer; however, the amendment states that there will not be 

a significant increase in the number of birds harvested relative to their continental population 

sizes. The need for harvest surveys was officially specified at the time the amendment was 

approved. Harvest survey data document the harvest level each year and will help ensure that 

harvest does not significantly increase over the coming years. The refuge is committed to 

continue working with the Migratory Bird Management office and assist in conducting harvest 

surveys and obtaining this critical information. 

72. Objective: Continue to coordinate with and assist the Yukon Drainage Fisheries Association 

in completing the annual In-Season Fish Harvest Assessment. 

Rationale: The primary purpose of the Yukon River Drainage Fisheries Association is to 

coordinate in-season subsistence fishing by hosting teleconferences that include people 

participating in personal use and commercial fishing and State and Federal managers along the 

Yukon River. Teleconferencing gives the fishermen a voice on how salmon are managed and the 

anticipated management based on preseason projections. 

73. Objective: Within three years of the Plan’s approval, expand subsistence harvest surveys to 

include large mammals (i.e., moose, black bear, and brown bear) and furbearers. 

Rationale: Refuge staff currently collects, or assist in collecting, subsistence harvest data on 

salmon and migratory birds. The Subsistence Division of ADF&G recently completed a two-year 

project on moose harvest in the GASH villages. This project would expand the ongoing 

subsistence harvest surveys to consistently include moose and other important large mammals 

and furbearers harvested from Innoko Refuge and surrounding areas. 

74. Objective: Within 10 years of the Plan’s approval, map the seasonal distribution and intensity 

of subsistence activities on the refuge. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-19
Chapter 2: Goals, Objectives, and Management Direction 

Rationale: To effectively provide continued subsistence opportunities and manage for healthy 

populations of fish, wildlife, and plants, it is necessary to identify the intensity and distribution of 

subsistence activities across the refuge. Because the majority of information relating to the location 

and intensity of subsistence activities was gathered in the late 1980s and early 1990s and does not 

reflect more recent changes in subsistence lifestyles, demographics, bag limits, or hunting seasons, 

it is becoming less useful for making management decisions. Updated information will assist with 

management of natural resources and identify potential areas of user conflict. 

GOAL 4 – RECREATION AND PUBLIC USE 

Provide opportunities for quality wildlife-dependent recreation, emphasizing short-term, lowdensity uses that require minimal facility development or habitat disturbance 

75. Objective: Continue to provide opportunities for multi-day recreational trips within the refuge 

that allow the public to experience and explore the dynamic landscape and wildlife of the refuge. 

Rationale: The National Wildlife Refuge Improvement Act of 1997 mandated refuges to manage 

for quality wildlife-dependent recreation. Multi-day recreational trips are one of the only means 

of achieving this objective on a remote refuge such as Innoko. 

76. Objective: Expand the public-use monitoring program for all uses of the refuge. Emphasis 

will be placed on annually monitoring all commercial use activities and uses that may conflict with 

refuge purposes or other uses. Monitoring will be scheduled as required. 

Rationale: To provide opportunities for quality wildlife-dependent recreation, public use must be 

monitored to assure that levels are sustainable and that different users are not in competition or 

negatively affecting other users. A full-time permanent pilot–resource manager position with law 

enforcement authority, in addition to several seasonal positions, will be required to implement this 

objective. This additional law enforcement position is within the recommended staffing under the 

Department of the Interior’s Law Enforcement Deployment Plan. 

77. Objective: Continue to implement and strengthen Innoko Refuge’s special use permit 

program, improve permittee documentation of use requirements, and increase enforcement of and 

compliance with permit stipulations. 

Rationale: The issuance of special use permits and collection of data from permit holders is an 

important aspect of monitoring refuge visitation and consumptive take from the Innoko Refuge. 

The special use permit program provides for this information to be collected per regulations. 

78. Objective: Work with the State of Alaska and Bureau of Land Management to increase law 

enforcement patrols on surrounding lands. On refuge lands, law enforcement activities will shift 

from seasonal patrols by dual function officers to year-round patrols by full-time refuge law 

enforcement officers. These patrols will target compliance with and investigate violations of fish 

and wildlife, cultural resources, and other State and Federal regulations. 

Rationale: This objective reflects the need for additional law enforcement on the Innoko Refuge 

and surrounding lands per the Service and Department of the Interior (DOI) Law Enforcement 

Deployment Plan. 

79. Objective: Within two years of the Plan’s approval, have a visitor services review conducted 

for the refuge and the administrative site at McGrath. 

2-20 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

Rationale: This review would bring the refuge into compliance with the wildlife-dependent 

recreation policy, which focuses on wildlife-dependent recreational opportunities. 

80. Objective: If necessitated by increased public use, develop a visitor services plan. 

Rationale: This step-down management plan would contain specific strategies to meet the visitor 

services goals and objectives of this Plan. The visitor services plan also would address issues not 

addressed in the Yukon-Innoko Moose Management Plan, including conflicting uses of the refuge 

and special use permits for outfitters and guides, and air taxis. 

GOAL 5 – WILDERNESS 

Preserve and enhance in perpetuity wilderness values of designated wilderness 

81. Objective: Continue to provide opportunities for solitude, self-reliance, and other 

characteristics that depend on a wilderness environment while not impairing other uses and 

values associated with wilderness. 

Rationale: The Wilderness Act and the Alaska National Interest Lands Conservation Act 

(ANILCA) acknowledge the need within humans for a wilderness experience, whether this 

experience is felt firsthand or by just knowing that areas exist where the wilderness experience is 

possible. The Innoko Refuge wilderness provides exceptional opportunities for solitude and 

primitive, unconfined recreation. 

82. Objective: Prepare a Wilderness Stewardship and Management Plan within two years of 

release of national wilderness guidelines. 

Rationale: The Wilderness Stewardship and Management Plan will allow the refuge staff to move 

forward in a unified direction per rules and regulations provided under these pending guidelines. 

83. Objective: Allow naturally occurring fires to burn within the wilderness whenever possible. 

If suppression steps must be taken, use “Light Hands On the Land” (Minimum Impact 

Suppression Tactics or MIST) firefighting techniques. 

Rationale: Fire is one of the two naturally occurring forces that greatly affect the Innoko Refuge 

landscape. Fire has occurred in these environments for eons and should be allowed to continue to 

shape the landscape. Fire suppression tends to leave scars on the landscape that would affect the 

natural appearance of the designated wilderness, and precautions should be taken to avoid or 

minimize any evidence of human actions. 

84. Objective: Ensure appropriate uses, including administrative uses, of the Innoko Refuge 

wilderness on an annual basis by conducting a minimum requirements analysis for new activities 

and reviewing existing minimum requirements analyses for accuracy. 

Rationale: The aim of the Wilderness Act and of this objective is to assure that designated 

wilderness areas remain materially unaffected by “the hand of man.” 

GOAL 6 – OUTREACH AND ENVIRONMENTAL EDUCATION 

Provide outreach, environmental education programs to develop and/or increase a sense of 

stewardship for wildlife, cultural resources, and the environment 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-21
Chapter 2: Goals, Objectives, and Management Direction 

85. Objective: Produce and distribute Leave No Trace and other information about the Innoko 

Refuge wilderness, and work with guides, transporters, and the visiting public to assure 

adherence to these principles while in the designated wilderness. 

Rationale: The Wilderness Act provides for the protection of wilderness values. In an area as 

remote as Innoko Refuge, the production and distribution of information is a major method of 

providing information to users. 

86. Objective: Continue to provide the public with timely and accurate information about the 

refuge through a wide variety of communication tools, re-evaluate the tools used, and update and 

correct information at least twice annually. One method will be to utilize the existing Web-based 

information, which hosts current and comprehensive information about the refuge, its regulations, 

safety tips, and recreation opportunities. 

Rationale: Information about the refuge and programs offered are critical to the public’s 

knowledge and support of the Service and refuge. 

87. Objective: In McGrath, Takotna, Nikolai, Holy Cross, Anvik, Grayling, and Shageluk, 

participate when possible in community events, festivals, and programs that will facilitate education 

and interpretation of Service and refuge goals and build awareness of the refuge and its resources. 

Rationale: These communities are closest to the refuge and provide the greatest amount of local 

visitation, both subsistence and non-consumptive. It is important that users in these communities 

feel comfortable working with and obtaining information from refuge staff. 

88. Objective: As opportunities arise, and as staff and funding allow, conduct workshops and 

provide classroom visits and educational materials as requested by educators in the Iditarod Area 

School District (IASD) to enhance curriculum and outreach dealing with refuge resources, issues, 

and opportunities. 

Rationale: The educational goal at Innoko Refuge is not to provide refuge staff for classroom 

teaching, which is logistically impossible, but to extend our reach by providing information for 

educators. Nonetheless, staff will occasionally work to provide Service and refuge information in 

person if possible. 

89. Objective: For each refuge environmental education program, develop reliable methods to 

assess the degree to which the program enhances understanding and appreciation of refuge 

purposes, special values, and management goals. Program target goals and evaluation tools will 

be developed and implemented within five years of the Plan’s approval. 

Rationale: This objective will allow the staff to evaluate a variety of ongoing programs to assure 

that those that reach the most individuals are a higher priority. 

90. Objective: Within five years of the Plan’s approval, at least 80 percent of IASD kindergarten 

through 12th grade students will have an opportunity to participate in at least one environmental 

education program focusing on key refuge resource conservation issues. 

Rationale: By having students involved, they are likely to develop a more responsible 

environmental ethic. 

91. Objective: Continue with and maximize long-term partnerships with IASD and other community 

organizations and volunteers to help meet the educational goals and objectives of the refuge. 

Rationale: The purpose of working with local students is to get them involved at a young age so 

they understand and appreciate the environment around them. 

2-22 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

92. Objective: Within two years of funding, establish a permanent refuge program to annually 

provide one high school–level field research course related to priority refuge resource issues. 

Rationale: This objective attempts to develop an early interest in students to become aware of 

their environment and possibly look at wildlife management and/or biology as a career or field 

of endeavor. 

93. Objective: Working with adjoining land managers, develop appropriate land status maps of a 

detail useful for recreationists to determine when they are on Federal, State, or private land. 

Rationale: The ownership of land along these remote rivers is a checkerboard and under different 

ownership where different laws and regulations apply. Maps of some type are required to indicate 

what is permissible and prohibited on any given parcel of land. 

94. Objective: Acquire base funds for the Earth Week activities, summer science camp, and 

advanced summer science camp through Refuge System funding processes to avoid depending on 

annual fund-raising. 

Rationale: Earth Week activities and science summer camp programs have been very successful 

in developing interest in students. They have been funded by challenge cost share in the past and 

dedicated funding would allow a more consistent operation. 

95. Objective: Continue to maintain and develop the partnership with the Alaska Geographic 

(formerly Alaska Natural History Association) and/or other cooperating associations to provide 

interpretive and environmental sales items on the natural and cultural history of the refuge and 

surrounding public lands. 

Rationale: The Alaska Geographic outlet within the Innoko Refuge office encourages people to 

enter the office and inquire about other events and projects occurring on the refuge. 

GOAL 7 – CULTURAL RESOURCES 

Conserve cultural and archeological resources of the refuge 

96. Objective: By 2010, revise the refuge’s Cultural Resource Guide to include the other 

objectives listed in this section and provide additional details about cultural resources 

management of the refuge. 

Rationale: A Cultural Resource Guide was prepared for the refuge in 1995. It contains an 

overview of Service cultural resource management authorities and responsibilities, and identifies 

compliance requirements. It also identifies inventory, archival research, ethnographic research, 

field survey, evaluation, protection, and information dissemination projects that the refuge could 

undertake. Refuge staff and the regional historic preservation officer should review this plan and 

determine which projects have been completed and identify new projects to undertake. 

97. Objective: Cooperate with the Iditarod National Historic Trail, Inc., and the local Trailblazers 

group to commemorate the Centennial of the Iditarod National Historic trail. 

Rationale: The year 2008 marks the 100th anniversary of the beginning of work by the Federal 

government to open the Iditarod Trail. The trail was marked and signed in 1910, and mail service 

from Seward to Nome began in 1914. The partners in management of the Iditarod Historic Trail 

have proposed an extended centennial period from 2008 through 2012. They have proposed a 

centennial initiative that will involve all the partners and local communities in a variety of projects 

and products. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-23
Chapter 2: Goals, Objectives, and Management Direction 

98. Objective: Seek funding to manage the Iditarod National Historic Trail within the refuge, 

focusing on documentation, conservation, research, and interpretation. 

Rationale: Iditarod National Historic Trail, Inc., adopted a resolution asking that the Service 

seek adequate funding to: (1) document sites, structures, buildings, and objects related to the 

trail; (2) conserve collections of artifacts and documents relating to the trail and sites on refuge 

lands; and (3) conduct historic research for management and interpretation of the trail and related 

sites. Securing funding will enable the refuge to complete this request. 

99. Objective: In cooperation with the communities of Holy Cross, Anvik, Grayling, and 

Shageluk, collect and incorporate existing place names information for the refuge into 

management and documents. 

Rationale: Place names contain an enormous amount of information on traditional uses, culturally 

significant places, historic camps and settlements, and other culturally important information. This 

information is an untapped archive that could mutually benefit local communities and the refuge, 

recognizing the significant role of local people in the natural and cultural heritage of the refuge. 

100. Objective: Within five years of Plan’s approval, inventory and map structures and other cultural 

resources in and around the refuge at risk from wildland fire and/or fire management activities. 

Rationale: This inventory will be used to update the refuge’s Fire Management Plan annually to 

ensure that important historic structures and private inholdings are protected, if possible, and 

that sensitive cultural resources are considered in fire planning. This is especially important for 

on-the-ground suppression so that adverse effects to cultural resources are avoided whenever 

possible. Interagency communication will be a priority after any revisions to the refuge Fire 

Management Plan to ensure that on-the-ground suppression actions are adhered to on Service 

lands. The communication of the Innoko Refuge Fire Management Plan revisions will be directed 

to the Bureau of Land Management (BLM) Alaska Fire Service on an annual basis. 

101. Objective: Within five years of plan approval, and within staffing and funding capabilities, 

update, compile, and organize a refuge cultural resource atlas and geodatabase to include all 

known historical and archaeological sites, place names, and paleontological locality information. 

Rationale: Having this information available within the refuge’s geodatabase would facilitate 

future cultural resource and paleontological work on the refuge and help ensure that these 

resources are considered in refuge planning and management. 

102. Objective: Within five years of Plan’s approval and within staffing and funding capabilities, 

organize and complete records of the refuge’s human history, including oral history collections. 

Rationale: Over time, the refuge has amassed a wealth of information, but much of this 

information is not well-organized or easily retrievable. It is especially important that oral 

histories contain accurate documentation, including required releases for use of the information. 

103. Objective: Identify priority areas to inventory for archaeological and other cultural sites in 

the updated Cultural Resource Guide. 

Rationale: Section 110 of the National Historic Preservation Act requires that historic properties 

be identified, evaluated, and nominated to the National Register of Historic Places. Prior to 

conducting field inventory, background research and planning should be used to identify areas to 

inventory. Archival research, contacts with local residents with knowledge of the areas, and 

review of detailed topographic information about the refuge can all be helpful in identifying areas 

to be inventoried on-the-ground. 

2-24 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

104. Objective: Conduct cultural resource surveys as time and personnel allow. Perform surveys at a 

level sufficient to evaluate the eligibility of identified sites to the National Register of Historic Places. 

Rationale: While it will take several planning cycles to identify all potentially eligible properties 

on the refuge, surveys should be designed and conducted to gather sufficient information to 

evaluate eligibility without repeated field visits being necessary. (See subsequent objectives.) 

105. Objective: Seek out and develop partnerships with Native corporations, Iditarod National 

Historic Trail, Inc., the Tochak Historical Society, universities, other government agencies, etc., to 

cooperatively develop projects to inventory, manage, and protect cultural and historical resources. 

Rationale: Cooperative projects allow parties to pool scarce resources and increase the amount of 

work completed. They allow the Service the advantage of working with recognized experts in the 

region, which greatly increases the value of completed work. 

106. Objective: As necessary, consult with Native groups and other local entities regarding 

research projects and proposals related to cultural resource management. 

Rationale: Routine cooperation with others maximizes use of scarce resources and assures 

frequent information exchange so that all are aware of each other’s work. Working with local 

entities also ensures that those with direct ties to the lands and resources are involved in the 

management of those lands and resources. 

107. Objective: Curate artifacts collected from historic sites on the refuge, and make collection 

information accessible through exhibits and publications. 

Rationale: When artifacts are collected, the refuge will ensure that proper records are prepared 

and maintained, that artifacts are curated in an appropriate manner, and that Service and DOI 

standards are met. Published records ensure that others have access to information about the 

resources in Service possession. 

108. Objective: Provide training to refuge staff as needed in the National Historic Preservation 

Act and Archaeological Resources Protection Act. 

Rationale: These laws are the primary legal means to protect and manage cultural resources on 

the refuge. It is important for all staff members to understand the cultural significance of these 

resources and legal mandates and responsibilities. 

109. Objective: Identify sites or areas at risk for vandalism, and monitor those areas with 

periodic law enforcement patrols. 

Rationale: Cultural resource protection on the refuge will be more effective if those conducting 

law enforcement patrols are aware of the locations of important resources and which resources 

are at greatest risk for vandalism. 

GOAL 8 – ADMINISTRATIVE 

Provide and maintain the facilities and equipment necessary to ensure and administer a safe and 

secure environment for the visiting public and Service personnel 

110. Objective: Continue implementation of the administrative facility plan. 

Rationale: The Innoko Refuge office and administrative site is currently located in a leased 

facility with very limited shop space. The administrative facility plan recommends Service-owned 

office space, including a small interpretive station, within the office facility. It also includes a 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-25
Chapter 2: Goals, Objectives, and Management Direction 

heated shop facility with space for maintenance of government equipment during winter, and 

secure storage facilities for government equipment. This step-down plan also includes three 

additional housing units. 

111. Objective: Continue an aggressive safety program. 

Rationale: Work on Innoko Refuge occurs in a remote and natural environment, and safety for 

employees is foremost. Potential safety issues are eliminated when possible and mitigated by 

other means when elimination is not possible. 

112. Objective: Continue to meet legal requirements for the administrative facilities of the refuge 

(e.g., equipment operation, hazardous materials handling). 

Rationale: There are multiple laws and regulations, both Service-promulgated and those of other 

Federal and State agencies, to which Service employees and contractors adhere. 

113. Objective: Coordinate with State and local agencies to assist in providing support 

during emergencies. 

Rationale: Refuge staff generally are not long-term local residents. By working with other 

community members and organizations in times of need (i.e., fires, search and rescues), refuge 

staff become active members of the community. This community involvement helps generate 

positive feelings about the refuge and the Service. 

114. Objective: Establish up to three new administrative sites on the refuge (one on the Yukon 

River, one on the upper Innoko River, and one on the lower Innoko River) as funding allows. 

Investigate the possibility of allowing public use of these new administrative sites. 

Rationale: Several small fixed sites on the refuge would allow for more effective operations and 

provide for employee safety in the event of bad weather or other unforeseen events. 

115. Objective: Maintain buildings, vehicles, and equipment. Using the Service Asset 

Maintenance Management System (SAMMS) or other reporting system, document building and 

equipment needs, and provide a safe environment for employees and the public. 

Rationale: Service directives mandate proper accounting of funds spent on maintenance 

equipment. The use of the SAMMS reporting system allows for completion of this requirement. 

2.2 Regional Management Direction Introduction 

Sections 2.3, 2.4 and 2.5 present an overview of the management direction for national wildlife 

refuges in Alaska. The primary sources of this management direction are the laws governing the 

National Wildlife Refuge System (Refuge System) and the regulations, policies, and other 

guidance, both national and regional, developed to implement these laws. Although each refuge is 

unique, it is only one piece of this system. The management direction presented here represents 

the common base for management of the Alaska refuges and identifies appropriate sideboards for 

management of individual refuges. 

Some deviations from these region-wide management policies and guidelines are likely to appear 

in each comprehensive conservation plan, given differing establishing orders or refuge purposes. 

Any refuge-specific departures will be clearly described, along with supporting rationale, in each 

revised comprehensive conservation plan. 

2-26 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

These sections contain the following: 

 Descriptions of the management categories and their associated general 

management intent 

 Policies and guidelines specific to each category 

 A table that displays activities, public uses, commercial uses, and facilities by 

management category 

The management category descriptions are not the same as those from the previous (1980s) round 

of comprehensive conservation plans, which evolved over the course of the planning process. 

These management category descriptions will remain constant for all the plans unless a welljustified exception is warranted as described previously. 

2.3 Management Categories 

Five management categories, ranging from Intensive management to designated Wilderness, are 

used to describe management levels throughout the refuges in Alaska. A management category is 

used to define the level of human activity appropriate to a specific area of the refuge. It is a set of 

refuge management directions applied to an area, in light of its resources and existing and 

potential uses, to facilitate management and the accomplishment of refuge purposes and goals. 

The Management Activities Table (Table 2-2) shows those management activities, public uses, 

commercial uses, and facilities that may be allowed in each management category and under what 

conditions. Wilderness management and Minimal management are the only management 

categories used on Innoko Refuge (see Figure 2-1). 

2.3.1 Intensive Management 

This category is designed to allow compatible management actions, public facilities, and economic 

activities that may result in alterations to the natural environment. In Intensive management 

areas, the presence of human intervention may be very apparent. Roads, buildings, and other 

structures are likely to be seen. Intensive management is applied to the smallest area reasonable 

to accommodate the intended uses. When Intensive management is proposed for an area, the 

specific purposes for its establishment will be described. 

Natural processes or habitats may be modified through human intervention. Habitats may be 

highly modified to enhance conditions for one or more animal species. For example, water 

regimes may be artificially controlled to improve habitat for waterfowl. 

High levels of public use may be accommodated and encouraged through modifications to the 

natural environment such as paving, buildings, developed campgrounds, and other facilities that 

could alter the natural environment in specific areas. Public facilities are designed to provide a 

safe and enjoyable experience of the natural environment and an increased understanding of 

refuge resources for a wide range of visitors. Facilities may accommodate a large number of 

visitors while protecting refuge resources from damage through overuse. 

Compatible economic uses of refuge resources that result in alterations to the natural 

environment may be authorized in Intensive management areas. All economic uses are subject to 

the compatibility standard, must contribute to the purposes of the refuge, and require official 

authorizations such as special use permits. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-27
Chapter 2: Goals, Objectives, and Management Direction 

2.3.2 Moderate Management 

Moderate management is meant to allow compatible management actions, public uses, commercial 

uses, and facilities that may result in changes to the natural environment that are temporary or 

permanent but small in scale and that do not disrupt natural processes. The natural landscape is the 

dominant feature of Moderate management areas, although signs of human actions may be visible. 

Management actions in the category of Moderate management will focus on maintaining, 

restoring, or enhancing habitats to maintain healthy populations of plants and animals where 

natural processes predominate. For example, logging and prescribed burning may be used to 

convert mature forests to earlier native seral stages to enhance browse for moose. In general, 

management facilities, both temporary and permanent, will be allowed for the purposes of 

gathering data needed to understand and manage resources and natural systems of the refuge. 

Structures will be designed to minimize overall visual impact. 

Public facilities provided in Moderate management will, while protecting habitats and resources, 

allow the public to enjoy and use refuge resources in low numbers over a large area, or they will 

encourage the short-term enjoyment of the refuge in focused areas. The emphasis is on small 

facilities that encourage outdoor experiences. Facilities such as public use cabins, rustic 

campgrounds, kiosks, viewing platforms, trails, and toilets may be provided. Facilities will be 

designed to blend with the surrounding environment. 

Compatible economic activities may be allowed where impacts to natural processes and habitats 

are temporary (e.g., small-scale logging where an earlier seral stage meets management goals; 

facilities in support of guiding and outfitting services such as tent platforms or cabins that 

encourage enhanced public use). All economic activities and facilities require authorizations such 

as special use permits. 

2.3.3 Minimal Management 

Minimal management is designed to maintain the natural environment with very little evidence of 

human-caused change. Habitats should be allowed to change and function through natural 

processes. Administration will ensure that the resource values and environmental characteristics 

identified in the Plan are conserved. Public uses, economic activities, and facilities should 

minimize disturbance to habitats and resources. Ground-disturbing activities are to be avoided 

whenever possible. 

Management actions in this category focus on understanding natural systems and monitoring the 

health of refuge resources. Generally, no roads or permanent structures are allowed (except 

cabins). Temporary structures may be allowed in situations in which removal is planned after the 

period of authorized use and the site can be rehabilitated using plants native to the immediate 

area. Existing cabins may be allowed for administrative, public use, subsistence, or commercial or 

economic (e.g., guiding) purposes. New subsistence or commercial cabins may be authorized if no 

reasonable alternatives exist. Public use or administrative cabins may be constructed if necessary 

for health and safety. 

Public use of the refuge for wildlife-dependent recreation and subsistence activities is encouraged. 

Public use facilities are not generally provided. Mechanized and motorized equipment may be 

allowed when the overall affects are temporary or where its use furthers management goals. 

2-28 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Figure 2-1. Innoko Refuge management categories 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

2-30 
Chapter 2: Goals, Objectives, and Management Direction 

Compatible economic activities may be allowed where the evidence of those activities does not last 

past the season of use, except as noted in the preceding discussion of cabins. The primary 

economic activities are likely to be guiding and outfitting of recreation activities such as hunting, 

fishing, hiking, river floating, and sightseeing. All economic activities and facilities require 

authorizations such as special use permits. 

2.3.4 Wild and Scenic Rivers 

The Wild and Scenic Rivers category applies to those rivers and corridors of the adjacent lands that 

have been designated by Congress as part of the Wild and Scenic Rivers System. This is a national 

system of designated rivers that possess outstandingly remarkable scenic, recreational, geologic, 

fish and wildlife, historic, cultural, or other similar values. All designated rivers on refuges in Alaska 

are classified as Wild Rivers. Wild Rivers are those rivers or sections of rivers that are free of 

impoundments, with shorelines or watersheds still largely primitive and waters unpolluted. 

Within this management category, water bodies are maintained in natural, free-flowing, and 

undisturbed conditions. Emphasis is placed on maintaining the natural function of the river 

system, and the appearance and sense of wildness are preserved. Evidence of human activities is 

minimal. Each river within the Wild and Scenic Rivers System has particular values for which it 

was designated; the management of a Wild River must protect those specific values. Management 

actions focus on understanding, monitoring, and maintaining the resources, natural ecosystem 

function, and aesthetics of the river corridor. 

Permanent structures generally are not allowed, with the exception of historic and cultural 

resources and, in certain limited circumstances, subsistence or administrative cabins and 

associated structures. Cabins, temporary structures, and hardened sites will be visually shielded 

from the river wherever possible. Where shielding is not practical, facilities and structures are as 

rustic or unobtrusive in appearance as possible. Public use facilities would provide opportunities 

for primitive recreation experiences. 

Compatible uses of a Wild River corridor will be allowed where those activities do not detract 

from the values for which the corridor was designated. Primary commercial uses are likely to be 

recreation services such as guided float, sightseeing, fishing, and hunting trips. A variety of 

management actions may be taken to maintain the values and classification of the corridor. All 

commercial activities and facilities require authorizations such as special use permits. 

2.3.5 Wilderness 

This category applies only to areas designated by Congress as units of the National Wilderness 

Preservation System, including the Innoko Refuge wilderness; areas proposed for wilderness 

designation will be managed under Minimal management, consistent with section 1317(c) of 

ANILCA and U.S Fish and Wildlife Service (Service) policy. Designated wilderness will be 

managed under the Wilderness Act of 1964 and the exceptions provided by ANILCA. Because 

wilderness units are part of a nationwide, multi-agency system, the Service recognizes that 

responsibilities for managing refuge wilderness go beyond the mission of the Service and that the 

purposes of the Wilderness Act are within and supplemental to the other purposes for which 

individual refuges were established. (Also, see section 2.4.19.) 

The history and intent behind the Wilderness Act make wilderness more than just another 

category of land management. Wilderness encourages a broadened perspective of the refuge 

landscape, one that extends beyond managing it solely as wildlife habitat. Wilderness is managed 

as an area “retaining its primeval character and influence.” In addition, wilderness provides 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-31
Chapter 2: Goals, Objectives, and Management Direction 

human visitors with opportunities for solitude or a primitive and unconfined type of recreation, 

which may be characterized in terms of experiential dimensions such as discovery, self-reliance, 

and challenge. 

Wilderness areas are managed to preserve their experiential values as well as aesthetic, scientific, 

and other related values. Research has shown that some values of wilderness extend beyond their 

boundaries to people who may never visit but who benefit from the protection of natural ecological 

processes—benefits such as clean air and water and the simple knowledge that such places exist. 

In managing wilderness, managers are encouraged to consider these off-site and symbolic values, 

as well as tangible resource values, in decision making. 

Permanent structures are generally prohibited; examples of exceptions are historic and cultural 

resources and, in certain circumstances, administrative structures or cabins that predate ANILCA, 

cabins that are necessary for trapping, and public use cabins necessary for the protection of human 

health and safety. Facilities and structures are rustic and unobtrusive in appearance. 

Compatible commercial uses of wilderness areas are generally limited to those activities that 

facilitate wilderness recreation (e.g., guided fishing, hunting, and wilderness trips). All commercial 

activities and facilities require authorizations such as special use permits. 

Actions such as prescribed fires or invasive species control may be conducted when it is necessary 

to protect life or property or when it is necessary to restore, maintain, or protect wilderness 

values. Management activities in wilderness must be found to be the minimum requirements for 

the administration of the area as wilderness. 

2.3.6 Special Management 

Special management lands are managed within one of the categories described previously but 

have additional requirements because of their status. 

2.3.6.1 Management of Selected Lands 

The Service retains management responsibility for lands selected but not yet conveyed to Native 

village and regional corporations or to the State of Alaska. The appropriate Native corporation or 

agency of the State of Alaska will be contacted and its views considered prior to issuing a permit 

involving these lands. Fees collected for special use or right-of-way permits will be held in escrow 

until the selected lands are conveyed or relinquished. Management of these lands will be the same 

as for adjacent refuge lands. 

2.4 Management Policies and Guidelines 

2.4.1 Introduction 

Refuge management is governed by Federal laws such as the National Wildlife Refuge System 

Administration Act of 1966 (16 U.S.C. 668dd), as amended, (Refuge Administration Act); the 

National Wildlife Refuge System Improvement Act of 1997, an amendment to the Refuge 

Administration Act (P.L. 105-57) (Refuge Improvement Act); and ANILCA; by regulations 

implementing these laws; by treaties; by Service policy; and by principles of sound resource 

management—all of which establish standards for resource management or limit the range of 

potential activities that may be allowed on the refuge. 

2-32 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

ANILCA authorizes traditional activities such as subsistence; the exercise of valid commercial 

fishing rights; and hunting, fishing, and trapping in accordance with State and Federal laws. 

Under Service regulations implementing this direction, “[p]ublic recreation activities within the 

Alaska National Wildlife Refuges are authorized as long as such activities are conducted in a 

manner compatible with the purposes for which the areas were established” (50 CFR 36.31(a)). 

Such recreation activities include but are not limited to sightseeing, nature observations and 

photography, hunting, fishing, boating, camping, hiking, picnicking, and other related activities. 

The Refuge Administration Act, as amended by the Refuge Improvement Act, defines “wildlifedependent recreation” and “wildlife-dependent recreational use” as “hunting, fishing, wildlife 

observation and photography, or environmental education and interpretation” (16 U.S.C. § 668ee). 

These uses are encouraged and will receive emphasis in management of public use on refuges. 

2.4.2 Management Emergencies 

It may be necessary, when emergencies occur on the refuge, to deviate from policies and 

guidelines discussed in the Plan. Activities not allowed on the refuge or under a specific 

management category, as shown in Table 2-2, may occur during or as a result of emergencies. For 

example, if naturally occurring or human-caused actions (e.g., landslides, floods, fires, droughts) 

adversely affect refuge resources, it may be necessary to undertake rehabilitation, restoration, 

habitat improvement, water management, fisheries enhancement, or other actions that would not 

otherwise be allowed to the same extent on the refuge. Threats to human health and safety may 

also result during emergencies. In emergencies, the refuge manager is authorized to take prudent 

and reasonable actions to protect human life and to address immediate health, safety, or critical 

resource protection needs. 

2.4.3 Land Exchanges and Acquisitions 

Under section 1302 of ANILCA and subject to certain restrictions, the Service may acquire by 

purchase, donation, or exchange any lands within the boundaries of Alaska refuges. Proposed 

land exchanges or acquisitions must benefit fish and wildlife resources, satisfy other purposes for 

which the refuge was established, or be necessary to satisfy other national interests. The Service 

can also purchase conservation easements or enter into cooperative management agreements to 

meet these objectives. 

Innoko National Wildlife Refuge is divided into two units. The southern unit is the Innoko Unit 

about which this Plan is written. The northern unit, which is also known as the Kaiyah Flats, is 

administratively managed from the Galena Fish and Wildlife Office as part of the 

Koyukuk/Nowitna Refuge. 

2.4.4 Land Protection Plans 

Department of Interior and Service policies require development of a step-down plan, called a 

Land Protection Plan, addressing priorities for habitat conservation within refuge boundaries. 

Land protection plans inform private landowners what land within refuge boundaries the Service 

would like to see conserved for fish and wildlife habitat. The plans do the following: 

 Identify the private lands within the refuge boundary that the Service believes 

should be conserved 

 Display the relative protection priority for each parcel 

 Discuss alternative means of land and resource conservation 

 Analyze the impacts on local residents of acquisition 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-33
Chapter 2: Goals, Objectives, and Management Direction 

The Service only acquires land from willing landowners. It is Service policy to acquire land only 

when other methods of achieving goals are not appropriate, available, or effective. Sometimes 

resource conservation goals can be met through cooperative management agreements with 

landowners or by similar means. The refuge will work with all landowners to ensure that overall 

fish and wildlife and habitat values within the refuge are conserved. 

A Land Protection Plan for the refuge was completed in July 2007. A pre-acquisition 

environmental site assessment is required for all real property proposed for acquisition by the 

Service or for public domain lands returning to Service jurisdiction (Service Manual 341 FW 3). 

2.4.5 Appropriate Refuge Uses 

Comprehensive conservation plans include a review of the appropriateness and compatibility of 

existing refuge uses and of any planned future public uses. All uses of a national wildlife refuge 

over which the Service has jurisdiction must be determined to be appropriate uses under the 

Appropriate Refuge Uses Policy (Service Manual 630 FW 1). An appropriate use of a national 

wildlife refuge is a proposed or existing use on a refuge that meets at least one of the following 

four conditions. 

1.) The use is a wildlife-dependent recreational use as identified in the Refuge Improvement 

Act (hunting, fishing, wildlife observation, wildlife photography, environmental education, 

and interpretation). 

2.) The use contributes to fulfilling the refuge purpose(s), the Refuge System mission, or 

goals or objectives described in a refuge management plan approved after October 9, 1997, 

the date the Refuge Improvement Act was signed into law. 

3.) The use involves the take of fish and wildlife under State regulations. 

4.) The refuge manager has evaluated the use, following guidelines in the Service Manual 603 

FW 1.11 (shown in the following text), and found it appropriate. 

a.) Do we have jurisdiction over the use? 

b.) Does the use comply with applicable laws and regulations (Federal, State, tribal, 

and local)? 

c.) Is the use consistent with applicable executive orders, Department and 

Service policies? 

d.) Is the use consistent with public safety? 

e.) Is the use consistent with goals and objectives in an approved management plan or 

other document? 

f.) Has an earlier documented analysis not denied the use or is this the first time the 

use has been proposed? 

g.) Is the use manageable within available budget and staff? 

h.) Will this be manageable in the future within existing resources? 

i.) Does the use contribute to the public’s understanding and appreciation of the 

refuge’s natural or cultural resources, or is the use beneficial to the refuge’s 

natural or cultural resources? 

2-34 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

j.) Can the use be accommodated without impairing existing wildlife-dependent 

recreational uses or reducing the potential to provide quality, compatible, wildlifedependent recreation into the future? 

This Plan identifies, in the following text, those existing and proposed uses that are found 

appropriate and compatible. If additional uses not addressed in this Plan are proposed for the 

refuge, the refuge manager will determine if they are appropriate uses following guidance in the 

Service Manual (603 FW 1). 

 Commercial Big Game Hunting Guide Services 

 Commercial Recreational Fishing Guide Services 

 Commercial Recreation Guide Services 

 Commercial Transporter Services 

 Helicopter Landings 

 Non-Wildlife Dependent Recreational Activities 

 Reburial of Archaeological Human Remains 

 Recreational Fishing 

 Recreational Hunting 

 Scientific Research 

 Snowmobiling 

 State of Alaska Management Activities 

 Subsistence Activities 

 Subsistence and Trapping Cabins 

 Subsistence Harvest of House Logs 

 Trapping 

 Wildlife Observation, Wildlife Photography, Environmental Education and Interpretation 

2.4.6 Compatibility Determinations 

The Refuge Administration Act states that “the Secretary [of the Interior] is authorized, under 

such regulations as he [or she] may prescribe, to... permit the use of any area within the [Refuge] 

System for any purpose, including but not limited to hunting, fishing, public recreation and 

accommodations, and access whenever he [or she] determines that such uses are compatible . . . .” 

A compatible use is a proposed or existing wildlife-dependent recreation use or any other use of a 

national wildlife refuge that, based on sound professional judgment, will not materially interfere 

with nor detract from the fulfillment of the Refuge System mission or the purposes for which the 

national wildlife refuge was established. Economic uses must contribute to achieving refuge 

purposes and the National Wildlife Refuge System mission. 

Compatibility determinations are not required for refuge management activities, except economic 

activities. They are also not required where statute directs mandatory approval of the activity, as 

in the case of facilities for national defense. 

If a use is found to be incompatible, the refuge would follow normal administrative procedures 

for stopping the action. If the use was a new use requiring a special use permit, the refuge 

manager would not issue a permit. If the use was an existing use already under permit, the 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-35
Chapter 2: Goals, Objectives, and Management Direction 

refuge manager would work with the permittee to modify the use to make it compatible or would 

terminate the permit. 

Ending incompatible uses that do not require a special use permit or other formal authorization, 

or that cannot be addressed by other Federal or State agencies, would require the refuge to go 

through the normal rulemaking process. This would include publishing the proposed regulations 

in the Federal Register and providing opportunity for public comment. 

Compatibility determinations for refuge uses are included in this Draft Comprehensive 

Conservation Plan. Public comments on the draft determinations are addressed in the final 

determinations released with the Final Comprehensive Conservation Plan. Draft compatibility 

determinations are found in appendix F. 

Compatibility determinations for existing hunting, fishing, wildlife observation and photography, 

and environmental education and interpretation must be re-evaluated with the preparation or 

revision of a comprehensive conservation plan or at least every 15 years, whichever is earlier. 

Refuge compatibility determinations for all other uses must be re-evaluated every 10 years or 

earlier if conditions change or significant new information relative to the use and its effects 

becomes available. 

To review completed compatibility determinations for all refuges in Alaska, go to 

http://alaska.fws.gov/nwr/planning/completed.htm. 

Additional details on applying compatibility standards and completing refuge compatibility 

determinations are found in the compatibility regulations at 50 CFR (Parts 25, 26, and 29) and in 

the Service Manual (603 FW 2). 

2.4.7 Mitigation 

In the interest of serving the public, it is the policy of the Service, throughout the nation, to seek 

to prevent, reduce, or compensate for losses of fish, wildlife, and their habitats, and uses thereof, 

from land and water development. To that end, the Service developed a Mitigation Policy in 1981 

that includes measures ranging from avoiding an activity that results in loss of such resources to 

seeking compensation by replacement of or substitution for resource loss. 

The Service will promulgate regulations, develop stipulations, and issue permits to reduce or 

eliminate potential adverse impacts resulting from compatible activities that may be authorized 

under this Plan. These regulations, stipulations, and permits would mitigate impacts in a variety 

of means, as stipulated in the Mitigation Policy guidelines (Service Manual 501 FW 2.1). The 

means, in order of application, are as follows: 

1. Avoiding the impact altogether by not taking a certain action or parts of an action 

2. Minimizing impacts by limiting the degree or magnitude of the action and its implementation 

3. Rectifying the impact by repairing, rehabilitating, or restoring the affected environment 

4. Reducing or eliminating the impact over time by preservation and maintenance operations 

during the life of the action 

5. Compensating for the impact by replacing or providing substitute resources or environments 

6. When determining if activities or uses are compatible, projects should be designed first to 

avoid adverse impacts. The Service generally does not allow compensatory mitigation on 

Refuge System lands. Only in limited and exceptional circumstances related to existing 

rights-of-way could compensatory mitigation be used to find a use compatible. The Service 

Manual (501 FW 2 and 603 FW 2) provides more information. 

2-36 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

Mitigation may consist of standard stipulations such as those attached to right-of-way permits; 

special stipulations that may be attached to leases or permits on a site-specific basis; and sitespecific, project-specific mitigation identified through detailed step-down management plans or 

the environmental assessment process. In all instances, mitigation must support the mission of the 

Refuge System and must be compatible with the purposes of the refuge. The degree, type, and 

extent of mitigation undertaken would depend on the site-specific conditions present and the 

management goals and objectives of the action being implemented. 

2.4.8 Cooperation and Coordination with Others 

2.4.8.1 Federal, State, and Local Governments 

The refuge will continue to work closely with those Federal, State, and local governments and 

agencies whose programs affect or are affected by the refuge. State and local government input 

will be sought during the development of regulatory policies addressing management of the 

Refuge System (Executive Order 13083, “Federalism”). When possible, the Service will 

participate in interagency activities (such as joint fish and wildlife surveys and co-funded 

research), cooperative agreements, sharing data, and sharing equipment and/or aircraft costs to 

meet mutual management goals and objectives. 

The refuge and the State of Alaska will cooperatively manage fish and wildlife resources within 

the refuge. The Master Memorandum of Understanding between the Service and the Alaska 

Department of Fish and Game, dated March 13, 1982, defines the cooperative management roles 

of each agency (see appendix B). In this agreement, the Alaska Department of Fish and Game 

agreed to “recognize the Service as the agency with the responsibility to manage migratory birds, 

endangered species, and other species mandated by Federal law, and on Service lands in Alaska to 

conserve fish and wildlife and their habitats and regulate human use.” Correspondingly, the 

Service agreed to “recognize the right of the Alaska Department of Fish and Game as the agency 

with the primary responsibility to manage fish and resident wildlife within the State of Alaska.” 

Further discussion of intergovernmental cooperation regarding the preservation, use, and 

management of fish and wildlife resources is found in 43 CFR 24, Department of the Interior Fish 

and Wildlife Policy: State and Federal Relationships. 

The Service does not require refuge compatibility determinations for State wildlife management 

activities on a national wildlife refuge pursuant to a cooperative agreement between the State and 

the Service where the refuge manager has made a written determination that such activities 

support fulfilling the refuge purposes or the Refuge System mission. When the activity proposed 

by the State is not part of a cooperative agreement or the State is not acting as the Service’s 

agent, a special use permit may be required, and a refuge compatibility determination will need to 

be completed before the activity may be allowed. Separate refuge compatibility determinations 

addressing specific proposals will be required for State management activities that propose 

predator management, fish and wildlife control (with the exception of emergency removal of 

individual rogue animals), reintroduction of species, non-native species management, pest 

management, disease prevention and control, fishery restoration, fishery enhancement, native fish 

introductions, non-native species introductions, construction of facilities, helicopter and off-road 

vehicle access, or any other unpermitted activity that could alter ecosystems on the refuge. 

The Service will cooperate with other State agencies (e.g., the Department of Natural Resources 

and the Department of Transportation and Public Facilities) on matters of mutual interest and 

may enter into informal and/or formal management agreements. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-37
Chapter 2: Goals, Objectives, and Management Direction 

2.4.8.2 Tribes and Native American Organizations 

The Service’s Native American Policy (USFWS 1994) identifies general principles that guide the 

Service’s government-to-government relationships with tribal governments in the conservation of 

fish and wildlife resources. Additional guidance has been provided by Executive Order 13084, 

“Consultation and Coordination with Indian Tribal Governments,” issued May 14, 1998; and the 

Department of the Interior–Alaska Policy on Government-to-Government Relations with Alaska 

Native Tribes, issued January 18, 2001 (USDOI 2001). The refuge will maintain government-togovernment relationships with tribal governments. The refuge will also work directly with 

regional and village corporations and respect Native American cultural values when planning and 

implementing refuge programs. 

2.4.8.3 Owners of Refuge Inholdings and Adjacent Lands 

The refuge will work cooperatively with inholders and adjacent landowners, providing information on 

refuge management activities and policies. The refuge will consult periodically with them regarding 

topics of mutual interest; will respond promptly to concerns over refuge programs; and will participate 

in cooperative projects (e.g., water quality monitoring and fish and wildlife management). 

2.4.8.4 Fish and Wildlife Service Jurisdiction over Waters within Innoko Refuge 

Where the United States holds title to submerged lands beneath waters within the refuge, the 

Service has jurisdiction over certain activities on the water. In 1980, under ANILCA, the United 

States Congress established or expanded 16 national wildlife refuges. These areas of land and 

water may contain both navigable and non-navigable waters. Where waterbodies are nonnavigable within the refuge, the Service has management authority over most activities on water 

where adjacent uplands are Federally owned. Where State of Alaska lands exist beneath 

navigable waterbodies or where the State, a Native corporation, or a Native allotee owns the 

adjacent uplands within areas of the refuge where the withdrawal process started after statehood, 

the Service’s management authority is more limited. 

The Service’s statutory authority to manage these lands and waters comes from ANILCA; the 

Service manages these lands pursuant to the Refuge Administration Act. Under provisions of 

ANILCA, the Service manages the Federal Subsistence Program on all inland waters within and 

adjacent to the external boundaries of the refuge (50 CFR 100.3(b)). 

2.4.8.5 Other Constituencies 

The refuge will inform local communities, special interest groups, and others who have expressed 

an interest in or are affected by refuge programs about refuge management policies and activities. 

The refuge will seek input from these constituents when issues arise that may affect how the 

refuge is managed. When appropriate, local residents and other stakeholders will be asked to 

participate in refuge activities so their expertise and local knowledge can be incorporated into 

refuge management. 

2.4.9 Ecosystem and Landscape Management 

Species do not function alone; they function together in the environment as part of an ecosystem. 

Refuge resources will be managed by employing ecosystem-management concepts. Individual 

species are viewed as integral to the diversity of those ecosystems; as such, they are indicators of the 

healthy functioning of the entire ecosystem. When the Service identifies species to use as indicators 

of the health of an ecosystem, it will do so through a rigorous peer-reviewed scientific process 

involving experts from other Federal agencies and the Alaska Department of Fish and Game. 

2-38 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

Inventorying, monitoring, and maintaining a comprehensive database of selected ecosystem 

components is critical for making refuge management decisions and for ensuring proper longterm ecosystem stewardship. This includes regular and recurring monitoring of status and trends 

of ecosystem components such as fish, wildlife, plants, climatic conditions, soils, and waterbodies. 

All monitoring will employ appropriate disciplines, new technologies, and scientific capabilities 

whenever practical. 

2.4.9.1 Air Quality 

The Service’s authorities for air quality management are included in several laws. The most direct 

mandates to manage air resources are found in the Wilderness Act and the Clean Air Act. 

The Service is required by the Clean Air Act to preserve, protect, and enhance air quality and air 

quality–related values on Service lands. Air quality–related values include visibility, plants, animals, 

soil, water quality, cultural and historical resources, and virtually all resources that are dependent 

upon and affected by air quality. In addition, the Wilderness Act requires the Service to protect and 

preserve the wilderness character, including the pristine air quality, of designated areas. 

Class I air quality sites receive the highest level of protection. Very little deterioration is allowed 

in these areas, and the Federal land manager has an “affirmative responsibility” to protect air 

quality–related values on those lands. With the exception of three Class I air quality sites in 

designated wilderness on the Alaska Maritime National Wildlife Refuge, all other lands managed 

by the Service in Alaska are designated as Class II and receive protection through the Clean Air 

Act. Moderate deterioration, associated with well-managed growth, is allowed in Class II areas. 

If air quality or related resources are at risk, the refuge manager will work with the Service’s Air 

Quality Branch; the regional air quality coordinator; the Alaska Department of Environmental 

Conservation and other State, local, and Federal agencies; and the public, as appropriate, in 

developing an air quality management plan as outlined in the Service Manual (563 FW 2.8). 

2.4.9.2 Water Resources (Hydrology) Management 

Every national wildlife refuge in Alaska shares the common purpose of ensuring that water 

resources are maintained and protected. ANILCA mandates that the Service safeguard water 

quality and necessary water quantity within refuges and to conserve fish and wildlife populations 

and habitats in their natural diversity. 

Although the Service has reserved water rights sufficient to accomplish the purposes of the 

refuges, the Refuge Administration Act and the Service Manual (403 FW 1 through 3) direct the 

Service to obtain, to the extent practicable, water supplies of adequate quantity and quality for 

Service facilities, for refuge purposes, and as trust resources; and to obtain the legal right to use 

that water through State laws, regulations, and procedures. 

The Alaska Region of the Service conducted a water resources threats analysis (Harle 1994) for 

the purpose of guiding water resource investigations and protecting water resources by acquiring 

instream water rights. Based on the results of the threats analysis, the Service’s regional office 

developed a strategic plan for systematically quantifying the surface water on refuges within 

Alaska (Bayha et al. 1997). 

Using existing data, or through the collection of hydrologic and biologic data, the Service applies 

to the State of Alaska for appropriative water rights, for instream water reservations, and for 

water withdrawals to meet the Service’s needs. Establishing State water rights is only a part of a 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-39
Chapter 2: Goals, Objectives, and Management Direction 

management strategy to protect refuge resources and to understand ecosystem processes. 

Collection of hydrologic data allows the Service to accomplish the following: 

 Plan floodplain and riparian zone management 

 Estimate flow for ungaged streams within the refuge 

 Supplement historical or current fisheries and wildlife studies 

 Detect and evaluate future natural or human-induced changes in the hydrologic system 

 Provide stream profile and velocity data for the design of fish weirs or other structures 

 Estimate the potential for future flooding and erosion 

 Analyze the impacts of proposed projects on stream flow and water supply 

 Provide a basis for decision making about commercial operations on some important streams 

 Provide baseline water quality information 

All facilities and activities on refuges must comply with pollution control standards set by Federal 

laws (e.g., the Clean Water Act 33 U.S.C. 1251 and the Safe Drinking Water Act 42 U.S.C. 300f); 

State laws where Federal law so provides; and the regulations, policies, and standards 

implementing these laws. 

2.4.9.3 Visual Resource Management 

Visual resource management has two primary purposes: (1) to manage the quality of the visual 

environment and (2) to reduce the visual impact of development activities. To accomplish these 

purposes, the refuge will identify and maintain scenic values and will, within the constraints 

imposed by the Plan, minimize the visual impacts of refuge development and uses. All activities 

and facilities on the refuge will be designed to blend into the landscape to the extent practical. 

The Service will cooperate with other Federal, State, local, tribal, and private agencies and 

organizations to prevent significant deterioration of visual resources. 

2.4.9.4 Cultural, Historical, and Paleontological Resources 

The Service has long-term responsibilities for cultural resources on refuge lands. Cultural 

resources on refuge lands are managed under a number of laws, executive orders, and regulations, 

including the Antiquities Act; the National Historic Preservation Act, as amended; the 

Archaeological Resources Protection Act; the American Indian Religious Freedom Act; the Native 

American Graves Protection and Repatriation Act; Executive Order 11593, “Protection and 

Enhancement of the Cultural Environment”; Executive Order 13007, “Indian Sacred Sites”; and 

36 CFR 800. 

The 1980 amendments to the National Historic Preservation Act direct the Service to inventory 

and evaluate cultural resources for their eligibility for inclusion on the National Register of 

Historic Places. Pending a complete evaluation, all cultural resources will be considered 

potentially eligible for the National Register of Historic Places. All significant historic, 

archaeological, cultural, and paleontological resources on the refuge will be protected and 

managed in accordance with Federal and State law. 

A Cultural Resource Guide for the refuge was completed in 1995 to provide guidance for cultural 

resource management on the refuge. It outlines legal mandates and considerations, reviews 

current information about resources, and establishes goals and objectives for the program. The 

Cultural Resource Guide should be updated within five years of completion of this plan. 

2-40 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

It is illegal to collect archaeological materials and/or paleontological remains on the refuge without 

a permit. Historic aircraft and other World War II material will be managed in accordance with 

the policy published December 20, 1985, in the Federal Register (FR 50:51952-51953). These 

materials may be collected on refuge lands only as authorized by a permit issued to a qualified 

organization or individual. Cultural resource research permits will only be issued to qualified 

individuals operating under appropriate research designs. The refuge will encourage 

archaeologists, historians, ethnologists, and paleontologists from educational institutions and 

other government agencies to pursue their research interests on refuge lands as long as these 

research interests are compatible with refuge purposes. Research that collects data from 

threatened sites and minimizes disturbance to intact sites will be encouraged. 

When any Federal undertaking—including any action funded or authorized by the Federal 

government and having the potential to directly or indirectly affect any archaeological or historic 

site—is planned, a consultation must be initiated with the State Historic Preservation Officer, 

under section 106 of the National Historic Preservation Act. If sites that may be affected are 

found in the project area, their significance will be evaluated to determine their eligibility for 

inclusion in the National Register of Historic Places. For eligible sites, consultation will result in a 

course of action causing the least possible impact. Impacts may be minimized in a variety of ways, 

including relocation or redesign of a project, site hardening, mitigation through information 

collection, or cancellation of the project if no alternatives are feasible. To protect archaeological 

and historic sites, other uses may be precluded. Private interests proposing to conduct commercial 

uses on the refuge will normally be required to fund studies necessary for consultation and for 

mitigation of impacts. 

The refuge will implement Executive Order 13007, “Indian Sacred Sites,” allowing access to 

identified sacred sites and avoiding adversely affecting the physical integrity of these sites. 

Where appropriate, the Service will maintain the confidentiality of sacred sites. 

Further information on cultural resources management can be found in the Service Manual (614 

FW 1 through 5) and the Cultural Resources Management Handbook (USFWS 1992). 

2.4.10 Fish and Wildlife Habitat Management 

2.4.10.1 Habitat Management 

Habitats are managed in keeping with the purposes, goals, and objectives of a refuge. In Alaska, 

this means habitats are largely managed to maintain natural diversity and natural processes. 

However, in some cases, habitats are manipulated to maintain or improve conditions for selected 

fish and wildlife populations, to control invasive plant species, or to manage fire fuels on refuge 

lands. These habitat management and manipulation activities will be carried out in support of the 

purposes, goals, and objectives of the refuge. Generally, refuges use the least intrusive 

management measures needed. Where practical and economically feasible, habitat management 

practices should maintain a natural appearance on the landscape. Habitat management 

practices—even those carried out for the benefit of a single species or small group of species—

will, to the extent possible, maintain the natural diversity of native (indigenous) wildlife species 

and habitat types. 

Habitat management and manipulation may be achieved by mechanical, chemical, and manual 

methods, including the use of fire, or by a combination of methods. Mechanical treatment could 

include mechanical removal, crushing, cutting, or mowing. When applicable, State and Federal 

guidelines for timber management will be followed. Riparian or aquatic habitat management 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-41
Chapter 2: Goals, Objectives, and Management Direction 

and manipulation may be achieved by acquiring instream flow reservations or making beneficial 

water diversions. 

Chemical treatment involves the use of chemicals to restore nutrient levels in a lake system 

(fertilization) for fisheries restoration, to reduce hazardous fuels, or to eliminate invasive plant and 

animal species, normally by killing them or destroying their ability to spread or prosper. Before 

chemical treatment is approved for use, the refuge will analyze the need for action, the options for 

treatment, and the potential impacts of those options through the National Environmental Policy 

Act (NEPA) process. Pest control, including integrated pest management, is discussed in section 

2.4.11.8 under the heading “Management of Non-native, Invasive, and Pest Species”. 

Manual treatment could include the use of hand tools to remove, reduce, or modify plants, or to 

modify habitats (e.g., removal of invasive plants). 

Aquatic habitat modification may include activities and structures such as streambank restoration, 

passage structures, fish barriers, or obstacle removal that results in physical modification of 

aquatic or riparian habitats to benefit fish species. These activities would be undertaken to 

maintain or restore native fish populations and may require appropriate NEPA compliance and 

refuge compatibility determinations. 

2.4.10.2 Fire Management 

Fire management is the full range of activities necessary to conserve, protect, and enhance 

habitat, and to maintain desired ecological conditions for the benefit of fish and wildlife. Fire 

management activities include preparedness, emergency suppression operations, wildland fire 

use, fire prevention, education, monitoring, research, prescribed fire, hazardous fuel reduction, 

and mechanical treatments. All activities will be conducted in accordance with refuge, Service, and 

Department of Interior policies and approved interagency and refuge-specific fire management 

plans. Additional guidance on fire management can be found in the Service Manual (621 FW 1 

through 3). 

Fire management plans provide the basis for integrating fire as a critical natural process into 

other refuge plans and activities at a landscape scale. The refuge Fire Management Plan provides 

specific information on the application and management of fire on the refuge. The Alaska 

Interagency Wildland Fire Management Plan provides a cooperative framework and operational 

guidelines for the suppression of wildland fires. The suppression of human-caused and unwanted 

wildland fires and the use of nature-caused wildland fires and prescribed fires as management 

tools are important management prerogatives. 

Wildland Fire Suppression. Fire suppression activity is the work of confining, constraining, 

controlling, or monitoring a fire or portion of a fire to protect, prevent, or reduce the loss of 

identified values. Suppression takes place, with the highest priority being the safety of 

firefighters and the public, using the appropriate management response based on values to be 

protected. The Alaska Interagency Wildland Fire Management Plan, amended in October 1998, is 

the guiding document for suppression actions. The plan establishes four management options—

critical, full, modified, and limited—that direct a range of wildlife fire management responses. 

Refuge lands have been classified using these fire management options with all facilities mapped. 

The Bureau of Land Management Alaska Fire Service (BLM/AFS) provides emergency 

suppression services on refuge lands in Alaska (Department Manual 620 DM 2), as directed by the 

refuge manager. Through a cooperative agreement with BLM/AFS, the State of Alaska Division 

2-42 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

of Forestry provides emergency suppression services on refuge lands in State protection zones, as 

directed by the refuge manager. 

Wildland Fire Use. Wildland fire use is the application of the appropriate management response 

to naturally ignited wildland fires to accomplish resource management objectives outlined in fire 

management plans. Wildland fires may be used to protect, maintain, and enhance natural and 

cultural resources; as nearly as possible, wildland fires will be allowed to function in their natural 

ecological role. Optional management is described in each refuge fire management plan. 

Prescribed Fire. Prescribed fires are ignited by management action to meet specific wildland 

fuel, vegetation, and habitat management objectives. Prior to each ignition, a written, approved 

plan outlining prescription conditions is required. Use of prescribed fires must also comply with 

the Alaska Enhanced Smoke Management Plan for Prescribed Fire. The plan provides guidance 

and direction concerning smoke issues related to prescribed fire. 

2.4.11 Fish and Wildlife Population Management 

Conservation of habitat is a key element in maintaining the natural diversity of populations on the 

refuge, and management of native fish and wildlife populations is an important component of 

maintaining healthy ecosystems. The refuge will be managed in accordance with the purposes of 

the refuge and consistent with the Policy on Maintaining Biological Integrity, Diversity, and 

Environmental Health of the National Wildlife Refuge System (Service Manual 601 FW 3) to 

ensure native species are managed in their natural diversity and abundance. 

The refuge will work with the State of Alaska to conserve fish and wildlife populations, 

recognizing that populations may experience fluctuations in abundance because of environmental 

factors and may require management actions for conservation purposes. The refuge will be 

managed to maintain the genetic variability of wild, native fish stocks. 

2.4.11.1 Wildlife Inventory and Monitoring Plan (I&M Plan) 

To assess presence, relative abundance, distribution, and trends in populations of fish, wildlife, 

and plants, the refuge will prepare an I&M Plan. The I&M Plan describes objectives, 

justification, methods, management implications, geographic scale, report schedules, and database 

management for studies on species targeted for inventory and monitoring. The I&M Plan will 

include studies that address environmental parameters (e.g., weather) and hydrology, soils, and 

fire history to explain potential changes in the distribution, relative abundance, and populations of 

fish, wildlife, and plants. The refuge will review the I&M Plan every two years. Regional office 

review is required every five to eight years. Updates to the I&M Plan will be made as indicated 

from these reviews. 

2.4.11.2 Scientific Peer Review 

Biologists, ecologists, botanists, and other refuge personnel conducting scientific investigations 

will adhere to refuge, regional, Service, and Department of Interior policies on scientific conduct, 

including the Management of Fish and Wildlife Service Scientific Publications Recommended 

Outlets, Procedures, and Policies. The overall goal of scientific peer review is to ensure that 

information collected, analyzed, interpreted, and reported to the public (and upon which policy and 

management decisions are based) meets established standards of the scientific community. To 

achieve this goal, all study plans and reports to be disseminated outside the originating office must 

be peer-reviewed. The region’s peer review procedure is available upon request. The type and 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-43
Chapter 2: Goals, Objectives, and Management Direction 

level of review shall be commensurate with the potential significance of the scientific information 

and its likely influence on policy and management actions. 

2.4.11.3 Compliance with the Animal Welfare Act 

The Animal Welfare Act of 1996, as amended, established legal standards for animal care and use. 

To prescribe methods and set standards for the design, performance, and conduct of animal care 

and use, research facilities and Federal agencies must establish an Institutional Animal Care and 

Use Committee (IACUC). Field studies conducted or authorized by refuge employees within the 

purview of the Animal Welfare Act will require review and approval of an IACUC. Any refuge 

study that involves an invasive procedure or that harms or materially alters the behavior of an 

animal under study will be reviewed and approved by an IACUC prior to implementing field work. 

A scientific collection permit is also required for game species from the Alaska Department of 

Fish and Game under 5 Alaska Administrative Code 92.033. 

2.4.11.4 Marking and Banding 

These activities include fish and wildlife capture, marking, banding, radio-collaring, release, 

tracking, and other information-gathering techniques. Cooperation with appropriate partners, 

including the Alaska Department of Fish and Game, will be stressed, and specific protocols will be 

followed, taking advantage of all appropriate disciplines and new technologies wherever possible. 

2.4.11.5 Threatened or Endangered Species 

The refuge will consult with the U.S. Fish and Wildlife Service Ecological Services field office on 

actions that may affect listed, proposed, or candidate species or designated or proposed critical 

habitat. These actions include refuge operations, public use programs, private lands, and Federal 

assistance activities, promulgating regulations, and issuing permits (USFWS & NMFS 1998). 

2.4.11.6 Reintroductions 

A species may be introduced on a refuge only if that species is native to the refuge (i.e., a 

reintroduction). Non-native species may not be introduced. Definitions of native and non-native 

species are found in Appendix D: Glossary. 

Reintroductions can be useful tools for restoring species to natural ranges and re-establishing a 

refuge’s natural fish, wildlife, and habitat diversity. Reintroductions would require appropriate 

NEPA compliance, a review to ensure consistency with the Policy on Maintaining Biological 

Integrity, Diversity, and Environmental Health of the National Wildlife Refuge System, an 

ANILCA section 810 determination, and a refuge compatibility determination. Reintroductions 

also require extensive coordination with adjacent landowners and with the State of Alaska. In 

evaluating the project, the cause(s) of the extirpation should be evaluated and management 

actions taken to alleviate the cause(s) prior to reintroduction. 

The environmental requirements of the species and the ecological dynamics of the area proposed 

for the reintroduction need to be thoroughly reviewed prior to a reintroduction. Some factors to 

consider include behavior, diseases, general ecology of the species, habitat requirements, interand intra-species competition, life history, genetics, management practices, population dynamics, 

and predators. Consideration should be given to whether there have been significant habitat 

changes since the species’ extirpation (e.g., is the area still within the species’ natural range?). 

2-44 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

2.4.11.7 Fish and Wildlife Control 

These activities involve the control, relocation, and/or removal of native species, including 

predators, to maintain natural diversity of fish, wildlife, and habitats. These management actions 

may be employed with species of fish and wildlife within their original range to restore other 

depleted native populations. These activities are subject to appropriate NEPA compliance, an 

ANILCA section 810 determination, and a refuge compatibility determination. 

Predator management includes the relocation, removal, sterilization, and other management of 

native predators to accomplish management objectives. The Service considers predator 

management to be a legitimate conservation tool when applied in a prudent and ecologically sound 

manner and when other alternatives are not practical. The key requirements are that a predatormanagement program be ecologically sound and biologically justified. In keeping with the 

Service’s mandate to first and foremost maintain the biological integrity, diversity, and 

environmental health of fish and wildlife populations at the refuge scale, a predator population will 

not intentionally be reduced below a level consistent with the low end of natural population cycles 

(see Service Manual 601 FW 3). 

A predator-management program requires appropriate NEPA compliance, an ANILCA section 

810 determination and, if conducted by other than the Service or an agent of the Service, a refuge 

compatibility determination. Alternative management actions must be evaluated prior to 

pursuing direct predator-control activities. Any proposal to allow or implement a predatormanagement program on national wildlife refuges in Alaska will be subject to public review and 

closely coordinated with the Alaska Department of Fish and Game, local communities, tribal 

governments, and adjacent landowners and/or managers. Predator-management activities must 

be monitored and evaluated for effectiveness and resource impacts. 

For additional information about predator management on Alaska National Wildlife Refuges, see 

appendix C. 

Normal environmental education and population-management activities—such as trapper 

education programs and regulation changes that allow for increased harvests of predatory animals 

by licensed trappers and hunters—are not considered to be “predator management.” The control 

or extirpation of non-native predators is not considered to be “predator management” (see next 

section on “Management of Non-native, Invasive, and Pest Species”). 

2.4.11.8 Management of Non-native, Invasive, and Pest Species 

In general, non-native species (including feral domestic animals) are not compatible with refuge 

purposes or with Refuge System policies. When a non-native species (fish, wildlife, or plant) occurs 

on a refuge, the Service may control or eliminate that species. Where a population of a non-native 

species has already been established on a refuge and this population does not materially interfere 

with or detract from the fulfillment of the mission of the Refuge System or the purposes of the 

refuge, the species may be managed as part of the refuge’s diverse ecosystems. 

Pests are defined as those organisms (vertebrates, invertebrates, plants, and microorganisms and 

their vectors) that are detrimental to fish, wildlife, human health, fish and wildlife habitat, or 

established management goals. Pests also include noxious weeds and other organisms, which are 

classified as pests by law (Administrative Manual 30 AM 12). 

Invasive species are non-native species whose introduction causes or is likely to cause economic or 

environmental harm, or harm to human health. The Federal government is prohibited by 

executive order, law, and policy from authorizing, funding, or carrying out actions that are likely 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-45
Chapter 2: Goals, Objectives, and Management Direction 

to cause or promote the introduction or spread of invasive species in the United States or 

elsewhere (Service Manual 620 FW 1). Refuge managers conduct habitat management activities to 

prevent, control, or eradicate invasive species using techniques described through an integrated 

pest management plan or other similar management plan. Refuge integrated pest management 

planning will address the advantages and limitations of potential techniques, including chemical, 

biological, mechanical, and cultural techniques. Management of invasive species on refuges is 

guided by the National Strategy for Invasive Species Management and conducted within the 

context of applicable policy (Service Manual 620 FW 1). 

By definition, invasive species significantly affect the land and water resources or the species of 

plants and animals that use these habitats. To manage invasive plants, the refuge will include 

weed inventories as part of all habitat inventories. The refuge will review the proposed action’s 

potential to introduce or spread invasive plants and will take measures to reduce the hazards (e.g., 

require weed-free feed for pack animals). 

Introduced vertebrates (e.g., foxes and rats) may also adversely affect wildlife populations, 

particularly in island ecosystems where species historically occurred without vertebrate 

predators. Presence of these invasive species may interfere with attainment of refuge purposes 

and management goals. 

Pests on refuges may also be controlled to prevent damage to private property; and routine 

protection of refuge buildings, structures, and facilities is addressed in refuge policy (Refuge 

Manual 7 RM 14). 

The refuge will coordinate with other landowners and agencies and use integrated pest management 

practices to enhance the detection, prevention, and management of invasive species and other pests. 

Use of chemical control measures on refuge lands requires regional office review and approval of a 

pesticide use proposal (Administrative Manual 30 AM 12 and Refuge Manual 7 RM 14). 

2.4.11.9 Disease Prevention and Control 

Certain disease organisms, viruses, or vectors of disease (e.g., rabies or parasites) may threaten 

human health or the health and survival of native wildlife or plant species. These threats may be 

managed or eliminated after consideration of all reasonable options and consultation with the 

State of Alaska and other concerned parties. This will normally only occur when severe resource 

damage is likely or when public health or safety is jeopardized. Wherever possible, an integrated 

approach to pest management will be used in accordance with the Service’s Administrative 

Manual (30 AM 12) and Refuge Manual (7 RM 14). If chemical controls are used, a pesticide-use 

proposal must be approved. 

2.4.11.10 Fishery Restoration 

Fishery restoration is any management action that increases fishery resources to allow full use of 

available habitat or to reach a population level based on historical biologic data. Although the goal 

of restoration is self-sustaining populations, situations may exist in which some form of fishery 

management or facilities could continue indefinitely. 

Where fishery resources have been severely adversely affected, the refuge will work with the 

State of Alaska, local tribes, and other partners to restore habitats and populations to appropriate, 

sustainable conditions. Restoration emphasis will focus on strategies that are the least intrusive 

to ecosystems and do not compromise the viability or genetic characteristics of the depleted 

population. This may include regulatory adjustments and/or evaluations of escapement goals. If 

the stocks have been reduced or are threatened, temporary restoration facilities may be allowed in 

2-46 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

designated wilderness or Wild River areas, as long as the facilities will not significantly detract 

from the values for which those areas were established. 

2.4.11.11 Fishery Enhancement 

Fishery enhancement is any management action or set of actions that is applied to a fishery stock 

to supplement numbers of harvestable fish to a level beyond that which could be naturally 

produced based on a determination or reasonable estimate of historic levels. This could be 

accomplished by stocking barren lakes, providing access to barren spawning areas (fish passages), 

constructing hatcheries, outstocking in productive systems, or fertilizing rearing habitat. 

Refuge management priorities will focus on conserving naturally diverse ecosystems. Fishery 

enhancement facilities for the purpose of artificially increasing fish populations normally will not 

occur within any management category. 

Proposals for fishery enhancement projects will be subject to the provisions of NEPA regulations, 

an ANILCA section 810 determination, and a refuge compatibility determination. Only 

temporary fishery enhancement facilities may be authorized in Minimal, Wild River, and 

Wilderness management areas. Proposals for facilities within designated wilderness require a 

minimum-requirements analysis to determine if the facilities are necessary within the wilderness 

area and would not significantly detract from the values for which those areas were established. 

2.4.12 Subsistence Use Management 

Providing the opportunity for continued subsistence use by local residents is one of the purposes 

of the refuge, as stated in title III of ANILCA. Title VIII of ANILCA further provides that rural 

Alaska residents engaged in a subsistence way of life be allowed to continue using resources 

within refuges for traditional purposes. These resources include fish and wildlife, house logs and 

firewood, and other plant materials (berries, bark, etc.). 

Many aspects of subsistence management are addressed outside of refuge comprehensive 

conservation plans. The Federal Subsistence Board, through its rulemaking process, addresses 

seasons, harvest limits, and customary and traditional use determinations. The Federal board has 

established Regional Subsistence Advisory Councils to provide for meaningful public input to the 

rulemaking process. 

The refuge will work with others to monitor subsistence harvest. The refuge will supplement the 

State’s ongoing harvest and resource monitoring programs to provide additional information on the 

status of fish and wildlife populations harvested for subsistence uses. This monitoring is intended to 

identify potential problems before populations of fish and wildlife become depleted and to ensure 

preference is given to subsistence users as required by law. All information the refuge gathers 

through subsistence monitoring will be shared with local State fish and game advisory committees, 

tribes, and other entities. Refuge staff will attend various subsistence-related meetings, including 

those of local fish and game advisory committees and regional subsistence advisory councils, and 

provide information on the status of subsistence resources and management. 

The non-commercial gathering by local rural residents of fruits, berries, mushrooms, and other 

plant materials for subsistence uses and of dead standing or down timber for firewood is allowed 

without a special use permit. Harvest of live standing timber for house logs, firewood, or other 

uses is allowed, although specific requirements vary by size and location. See 50 CFR 36.15 for 

specific details. Timber stocks subject to subsistence use will also be monitored to ensure they 

remain available over the long term. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-47
Chapter 2: Goals, Objectives, and Management Direction 

Under section 816 of ANILCA, refuge lands may be closed to the taking of fish and wildlife if 

closure is deemed necessary for reasons of public safety or administration, or to ensure the 

continued viability of particular populations of fish or wildlife. Emergency closure to subsistence 

taking generally would occur only after other consumptive uses competing for the resources were 

restricted or eliminated. 

2.4.12.1 Access for Subsistence Purposes 

Access to refuge lands by traditional means will be allowed for subsistence purposes in accordance 

with section 811 of ANILCA, subject to reasonable regulation (50 CFR 36.12). Traditional means 

include snowmachines, motorboats, dog teams, and other means of surface transportation 

traditionally used by local rural residents engaged in subsistence activities. Use of these 

traditional means of travel will be in compliance with State and Federal law in such a manner to 

prevent waste of harvested resources or damage to the refuge and to prevent herding, 

harassment, hazing, or driving of wildlife. 

2.4.12.2 Section 810 Evaluations 

The refuge will evaluate the effects of proposed activities on subsistence use to ensure compliance 

with section 810 of ANILCA. The refuge will work with the Federal Subsistence Board, regional 

subsistence advisory councils, local fish and game advisory committees, tribes, Native 

corporations, the Alaska Department of Fish and Game, and other appropriate local sources to 

determine whether a proposed activity would “significantly restrict” subsistence uses. If the 

refuge determines that a proposal would probably result in adverse effects to subsistence use, the 

refuge would follow the requirements identified in section 810 before making a final decision on 

the proposal. 

2.4.13 Public Access and Transportation Management 

2.4.13.1 Snowmachines, Motorboats, Airplanes, and Nonmotorized Surface Transportation 

Section 1110(a) of ANILCA allows the use of snowmachines (during periods of adequate snow 

cover and frozen river conditions), motorboats, airplanes, and nonmotorized surface 

transportation methods for traditional activities and for travel to and from villages and homesites. 

Such access shall be subject to reasonable regulations to protect the natural and other values of 

the refuge (43 CFR 36.11). Specific areas may be closed, in accordance with these regulations, to 

such uses. The refuge manager is responsible for determining when snow cover is adequate to 

protect the underlying vegetation and soil from damage by snowmachine use. 

2.4.13.2 Off-Road Vehicles 

The regulations at 43 CFR 36.11(g) restrict the use of off-road vehicles within refuges. The definition 

of off-road vehicles in 50 CFR 36.2 excludes snowmachines but includes air boats and air-cushion 

vehicles along with motorized wheeled vehicles. Off-road vehicles may be allowed only on designated 

routes or areas within Intensive and Moderate management areas or by special use permit. 

2.4.13.3 Helicopters 

The use of a helicopter in any area other than at designated landing areas pursuant to the terms 

and conditions of a permit issued by the Service, or pursuant to a memorandum of understanding 

between the Service and another party, or involved in emergency or search and rescue operations 

is prohibited (43 CFR 36.11(f)(4)). 

2-48 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

Helicopter landings for volcano monitoring, geologic hazards evaluations, and fisheries and 

wildlife management activities may be authorized under special use permit or other authorization, 

subject to site-specific stipulations. Helicopter landings for initial-attack fire suppression must 

comply with operational guidance in the Alaska Interagency Wildland Fire Management Plan. 

Helicopter landings by commercial operators and for general public access are generally not 

allowed in designated wilderness. Where such use was established prior to wilderness 

designation, it may be allowed to continue. 

2.4.13.4 Access to Inholdings 

Section 1110(b) of ANILCA ensures adequate and feasible access, for economic or other purposes, 

across a refuge for any person or entity that has a valid inholding. An inholding is defined as 

State-owned or privately-owned land, including subsurface rights underlying public lands, valid 

mining claims, or other valid occupancy that is within or effectively surrounded by one or more 

conservation system units. When a right-of-way permit is necessary under this provision (e.g., 

construction of permanent or long-term facilities), the Service will review and process the 

application in accordance with regulations at 43 CFR 36 and 50 CFR 29. Such permits are subject 

to terms and conditions as specified in the regulations. 

2.4.13.5 Temporary Access 

Temporary access, as defined by 43 CFR 36.12(a)(2), is “limited, short-term (i.e., up to one year 

from issuance of the permit) access which does not require permanent facilities for access to State 

or private lands.” Temporary access is limited to survey, geophysical, exploratory, or other 

temporary uses of non-Federal lands and where access is not otherwise provided for in 43 CFR 

36.10 or 43 CFR 36.11. 

The refuge will evaluate applications for temporary access across the refuge and shall issue a 

permit with the necessary stipulations and conditions to ensure that the access granted is 

compatible with the purposes for which the refuge was established, that it complies with the 

provisions of section 810 of ANILCA, and that it ensures that no permanent harm will result to 

refuge resources. 

2.4.13.6 Subsistence Access 

See Access for Subsistence Purposes under Subsistence Use Management (section 2.4.12.1. 

2.4.13.7 Transportation and Utility Systems 

Transportation and utility systems include roads, highways, railroads, airports, pipelines, 

electrical transmission lines, communication systems, and related structures and facilities 

reasonably and minimally necessary for the construction, operation, and maintenance of such 

systems (section 1102 of ANILCA). Anyone seeking to acquire a right-of-way across refuge lands 

for a transportation or utility system must, consistent with 43 CFR 36, file an application with the 

regional office. Regulations at 43 CFR 36 and 50 CFR 29 establish specific procedures and time 

constraints for application review, compliance with NEPA, decision making, and appeals. 

The Service will decide whether to approve or disapprove that portion of a transportation or utility 

system that would cross refuge lands, except for those on designated wilderness. When the 

proposed transportation or utility system would cross a designated wilderness area, the Service 

tentatively approves or disapproves the application subject to the President’s subsequent decision. 

If the President approves, a recommendation is submitted to Congress for final approval. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-49
Chapter 2: Goals, Objectives, and Management Direction 

A right-of-way for a transportation or utility system across refuge lands can be granted only if the 

system meets the compatibility standard, the criteria outlined in section 1104(g)(2) of ANILCA, and 

the regulations at 43 CFR 36.7(a)(2), and if there is no economically feasible and prudent alternative 

route for the system. If approved, permits issued for a transportation or utility system will contain 

terms and conditions as required under regulations at 43 CFR 36.9(b) and 50 CFR 29.21 through 

29.24. Rights-of-way that cross any area within the boundaries of a Wild and Scenic River unit will 

assure that the stream flow of, and transportation on, such river are not interfered with or impeded 

and that the facility is located and constructed in an environmentally sound manner according to 

section 1107(b) of ANILCA and the regulations at 43 CFR 36.9(c) and (d). Additional special 

requirements apply to rights-of-way for pipelines issued under the Mineral Leasing Act of 1920 (30 

U.S.C. 185), section 1107(c) of ANILCA, and regulations at 43 CFR 36.9(d). 

When considering an application for a transportation or utility system, the authorization process 

would incorporate a corresponding Plan amendment to update the desired management 

category(s) of the affected area if the system were to be approved. 

2.4.13.8 State Transportation Planning 

Federal transportation planning regulations require each state to develop a long-range statewide 

transportation plan in consultation and coordination with other government agencies and the 

public. In Alaska, transportation projects nominated for funding are evaluated and ranked by the 

Alaska Department of Transportation and Public Facilities. When appropriate, the refuge will 

participate in the State transportation planning process and provide input regarding 

environmental considerations of proposed projects affecting refuge lands and resources. See 

section 3.1.1 of this Plan for a discussion of State-identified potential transportation and utility 

systems that cross refuge lands. 

2.4.13.9 RS 2477 Rights-of-Way 

The State of Alaska identifies numerous claims to roads, trails, and paths across Federal lands 

under Revised Statute 2477 (RS 2477), a section in the Mining Act of 1866 that states, “The rightof-way for the construction of highways over public lands, not reserved for public uses, is hereby 

granted.” RS 2477 was repealed by the Federal Land Policy and Management Act of 1976, subject 

to valid existing claims. Assertion and identification of potential rights-of-way does not establish 

the validity of these claims nor the public’s right to use them. The validity of all RS 2477 rights-ofway will be determined on a case-by-case basis, either through the courts or by other legally 

binding document. The State of Alaska has identified in Alaska Statute 19.30.400 routes on the 

refuge it claims may be asserted as rights-of-way under RS 2477 (see figure 3-1 in chapter 3). 

2.4.13.10 17(b) Easements 

Section 17(b) of the Alaska Native Claims Settlement Act of December 18, 1971, authorizes the 

Secretary of the Interior to reserve easements on lands conveyed to Native corporations to 

guarantee access to public lands and waters. Easements across Native lands include linear 

easements (e.g., roads and trails) and site easements. Site easements are reserved for use as 

temporary campsites and to change modes of transportation. 

The Service is responsible for administering those public easements inside and outside refuge 

boundaries that provide access to refuge lands. Service authority for administering 17(b) 

easements is restricted to the lands within the easement. The size, route, and general location of 

17(b) easements are identified on maps filed with conveyance documents. Conveyance documents 

2-50 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

also specify the terms and conditions of use, including the acceptable periods and methods of 

public access. 

2.4.13.11 Navigation Aids and other Facilities 

Section 1310 of ANILCA authorizes reasonable access to and operation and maintenance of 

existing air and water navigation aids, communications sites, and related facilities. It authorizes 

existing facilities for weather, climate, and fisheries research and monitoring, subject to applicable 

laws and regulations. Reasonable access to and operation and maintenance of facilities for 

national defense and related air and water navigation are also provided for, including within 

designated wilderness areas. 

New facilities shall be authorized only after consultation with the head of the Federal department 

or agency undertaking the establishment, operation, or maintenance, and in accordance with 

mutually agreed to terms and conditions. 

2.4.14 Recreation and Other Public Use 

Public recreation activities compatible with refuge purposes are authorized unless specifically 

prohibited (50 CFR 36.31). Compatible recreation uses of the refuge will continue. The Refuge 

Administration Act identifies compatible hunting, fishing, wildlife observation and photography, 

and environmental education and interpretation as priority public uses. These uses are 

encouraged and will receive emphasis in public use management. 

Both consumptive (e.g., hunting, fishing, and trapping) and non-consumptive (e.g., wildlife 

observation and photography) recreation uses are appropriate. Some recreational uses are 

incidental to others. For example, camping and hiking may be related to hunting, fishing, wildlife 

photography, or other recreational uses. 

There is often a fine line between subsistence and recreation use (e.g., berry picking). Subsistence 

uses are addressed under Subsistence Use Management (section 2.4.12). When it is necessary to 

restrict the taking of fish and wildlife on a refuge to protect the continued viability of such 

populations, the taking of fish and wildlife for non-wasteful subsistence uses on refuges shall be 

accorded priority over the taking of fish and wildlife for other purposes, in accordance with title 

VIII of ANILCA. 

The refuge will be managed to provide recreation experiences in generally natural wildland 

settings. Recreation use would be managed consistent with the designated management area 

category. Intensive and Moderate management areas will be managed for greater concentrations 

of visitors than will be Minimal management and designated wilderness areas. The refuge will 

manage all recreation use to avoid crowded conditions and to minimize adverse effects to cultural 

resources, fish and wildlife, wilderness, and other special values of the refuge. Leave No Trace 

will be the standard. 

The least intrusive means of managing use will be employed. Education will be the primary 

management tool for recreation management, using brochures, maps, signs, and personal 

contacts. However, if voluntary methods fail, other actions may be taken. Actions that may be 

taken to manage recreation include limiting commercial guiding and outfitting; regulating use and 

access subject to the provisions of section 1110(a) of ANILCA; and recommending changes in 

State and/or Federal fishing, hunting, and/or trapping regulations. When necessary, recreation 

opportunities may be seasonally or otherwise restricted to minimize user conflicts and to protect 

the natural or other values of a refuge. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-51
Chapter 2: Goals, Objectives, and Management Direction 

Any restrictions on public use will follow the public participation and closure procedures at 50 

CFR 36, 43 CFR 36 or other applicable regulations. State management actions available through 

the Master Memorandum of Understanding (see appendix B) and other State management tools 

will also be used where mutually desirable. 

A visitor services plan may be prepared for the entire refuge, or more specific management plans 

may be prepared for areas of relatively concentrated use. 

2.4.15 Public Use Facilities 

Facilities may be provided to support certain recreation and other public uses. Recreation 

facilities may be located on refuge lands and at administrative sites. Visitor centers and highly 

developed environmental education and interpretive sites may be located off refuge lands at 

administrative sites or other appropriate locations. Public use facilities may include roads, trails, 

boat launch sites, airstrips, campgrounds, interpretive sites, environmental education sites, visitor 

centers, public use cabins, visitor contact facilities, and signs. 

All new buildings (e.g., visitor centers, restrooms, public use cabins, and visitor contact buildings), 

some recreation facilities (e.g., fishing platforms) and additions and alterations to existing 

buildings will comply with current accessibility standards. Other non-building recreation facilities 

(e.g., campgrounds, trails) are not currently covered under these standards, although access for 

the disabled will be considered in the design of new or upgraded facilities. As funds are available, 

existing buildings will be updated to meet these standards. 

The level of development and appearance of facilities will be appropriate for the management 

category of the area in which they are located. More intensive and sophisticated facilities will be 

constructed in the Intensive management category; more rustic and rudimentary facilities will 

occur in the other management categories. 

2.4.15.1 Cabins 

Special use permits are required for subsistence and commercial cabins. Management of existing 

cabins and review of proposals for construction of new cabins for traditional uses will be in 

accordance with the Service’s cabin regulations (50 CFR 36.33) and regional cabin policy. Private 

recreational-use cabins will not be authorized. 

Public use cabins are intended to provide the public with unique opportunities to enjoy and use the 

refuge. They also help ensure public health and safety in bad weather and emergencies. 

2.4.15.2 Temporary Facilities for the Taking of Fish and Wildlife 

Per section 1316 of ANILCA, the refuge will allow the use of temporary campsites, tent platforms, 

shelters, and other temporary facilities and equipment directly and necessarily related to the 

taking of fish and wildlife, provided these facilities are not detrimental to refuge purposes. Special 

use permits may be issued for tent frames, caches, smokehouses, and other facilities. Appropriate 

stipulations will be included in the special use permits to ensure protection of refuge resources. 

The following criteria will be considered in evaluating applications for temporary facilities: 

 Where feasible, they will be located in a manner to not displace or compete with existing 

public uses. 

 They will be located away from the vicinity of existing cabins. 

 They will be located on sites that are not currently popular campsites. 

2-52 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

 They will be located to minimize displacement of wildlife. 

The following conditions may be imposed on temporary facility special use permits: 

 The time of occupancy will coincide with the State and/or Federal hunting, fishing, and/or 

trapping season for the species for which the temporary facility is being used. 

 At the end of the specified occupancy, tents and other readily portable materials will 

be removed. 

 To the extent feasible, temporary structures will be built with materials that blend into and 

are compatible with the surrounding landscape. 

 To the extent feasible, temporary facilities will be screened from water and located so 

that they are as unobtrusive as possible when viewed from trails and areas of significant 

public use. 

2.4.16 Outreach 

Outreach is two-way communication between the refuge and the public to establish mutual 

understanding, promote public involvement, and influence public attitudes and actions. The 

refuge will continue to take advantage of partnership opportunities in providing these services, 

including working with the Alaska Geographic; Alaska Public Lands Information Centers; 

Friends of Alaska National Wildlife Refuges; local, State, and other Federal agencies; local 

schools; tribal governments; Alaska Native organizations; and others. 

Use of outreach as a management tool is key to the success of many of the management activities 

outlined in this plan. Two outreach activities—environmental education and interpretation—are 

included in the six priority public uses identified in the Refuge Improvement Act. Many other 

activities are also available for use by the refuge staff in its outreach program, which may be 

developed in more detail as a step-down management plan. All outreach activities must be 

continually evaluated to determine whether they fulfill refuge management goals and objectives. 

The refuge will ensure that these services are available to all segments of the public, including 

those with disabilities and those who speak languages other than English. 

Refuge staff will work with the news media, attend public meetings and workshops, develop Internet 

home pages, invite the public to the refuge (open houses), and foster one-on-one communication. 

2.4.17 Commercial Use Management 

Commercial uses are activities involving use of a refuge or its resources for a profit. Subsistence 

uses are not included in commercial uses. Refer to section 2.4.12 for policies related to subsistence. 

Except for mining on valid claims under the 1872 Mining Law, other activities where specific 

property rights are held by entities other than the Federal government, or where specifically 

exempted by law, all commercial uses must comply with both NEPA and the compatibility 

requirements of the Refuge Administration Act. A written authorization (such as a special use 

permit) is required to conduct commercial activities on any refuge. Compliance with NEPA and 

a refuge compatibility determination will be required prior to deciding whether to authorize a 

commercial use. Prior to authorizing any economic use of a natural resource, the refuge 

manager must determine that each use, except for proposed activities authorized by ANILCA, 

contributes to the achievement of refuge purposes or the Refuge System mission (50 CFR 29.1). 

Except for commercial services described previously, commercial enterprises are prohibited in 

designated wilderness. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-53
Chapter 2: Goals, Objectives, and Management Direction 

2.4.17.1 Commercial Recreation Services 

Air taxi and water taxi operators, wildlife-viewing guides, tour operators, wilderness guides, 

recreational fishing guides, big game hunting guides, and others providing recreation services are 

required, under 50 CFR 27.97, to obtain special use permits to operate on refuge lands. Where 

the number of special use permits is limited, refuge managers will award permits competitively 

(50 CFR 36.41). Special use permits require compliance with all applicable laws and regulations 

(e.g., United States Coast Guard licensing regulations). Permit stipulations ensure that camps; 

travel methods; storage of food, fish, and game meat; and activities are compatible with refuge 

purposes and reduce the potential for impacts to resources and to other refuge users. If problems 

arise relating to commercial recreation activities—such as disturbance of active nests, conflicts 

with subsistence use, chronic incidence of bears getting into food, or violations of State or Federal 

regulations—the refuge may modify or terminate use under the special use permit stipulations. 

The refuge will monitor the number and type of guides and outfitters operating in the refuge and 

the number of clients and will, if necessary, further regulate use. 

Under section 1307 of ANILCA, local preference is provided for all new commercial visitor 

services except guiding for recreational hunting and fishing. Regulations defining local 

preference are at 50 CFR 36.37. 

2.4.17.2 Mineral Exploration and Development 

Oil and Gas Assessment. Geological and geophysical studies, including subsurface core sampling 

and seismic activities, require special use permits with site-specific stipulations that ensure 

compatibility with refuge purposes and consistency with the management objectives of this Plan. 

Decisions to allow exploration will be made on a case-by-case basis. These activities will not be 

allowed in designated wilderness. 

Oil and Gas Leasing. Oil and gas leasing may be allowed only in Intensive management areas. Oil 

and gas leasing will not be authorized until completion of the following: 

 An assessment of potential 

 A national interest determination 

 A refuge compatibility determination, where applicable 

 A comprehensive conservation plan amendment 

During this process, the Service will seek the views of State and local governments and other 

interested parties, in accordance with section 1008(b)(2) of ANILCA. 

If leasing is authorized, lease holders will be subject to Federal leasing regulations (43 CFR 3100) 

and appropriate State regulations. Leases will be subject to stipulations on access, seasonal use, 

and site restoration; operators would be required to use technology that minimizes impacts on 

fish, wildlife, and habitat. The refuge will work closely with leaseholders to minimize adverse 

effects of mineral exploration and extraction on refuge resources and recreation opportunities. 

Sand, Gravel, and Other Common Variety (Saleable) Minerals. Common variety minerals—such 

as sand, gravel, stone, limestone, pumice, pumicite, cinders, and clay—may be sold pursuant to the 

Materials Act of July 31, 1947 (30 U.S.C. 601 and 602), as amended. Regulations are found at 43 

CFR 3600. Disposal is also authorized under the Refuge Revenue Sharing Act (16 U.S.C. 715s). 

Also see 612 FW 1 of the Service Manual. Extraction may be authorized, where compatible, in 

Intensive and Moderate management areas to support construction and maintenance projects on 

or near refuge lands if no reasonable material sites exist off refuge lands. 

2-54 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

Other Mineral Leasing. In general, mineral leasing is not allowed on refuge land. Geothermal 

leasing is not allowed on refuges under section 1014(c) of the Geothermal Steam Act (30 U.S.C. 

1014). Coal mining is also prohibited, subject to valid existing rights, under section 16 of the 

Federal Coal Leasing Amendment Act of 1975 (30 U.S.C. 201 Notes) and the Surface Mining 

Control and Reclamation Act of 1977 (30 U.S.C. 1272; 43 CFR 3400.2). In specific cases of national 

need, however, mineral exploration, development, or extraction may be permitted under section 

1502 of ANILCA. The President must determine that the national need for the mineral activity 

outweighs the other public values of the land. Any recommendation by the President would take 

effect only after enactment of a joint resolution by Congress. 

2.4.17.3 Commercial Fishing and Related Facilities 

Under section 304(d) of ANILCA, the Service will continue to allow individuals with valid 

commercial fishing rights or privileges to operate on the refuge. The use of campsites, cabins, 

motor vehicles, and aircraft on the refuge in support of commercial fishing is subject to reasonable 

regulation. Section 304(d) provides for restricting commercial fishing rights if the use is 

determined to be inconsistent with refuge purposes and to be a “significant expansion of 

commercial fishing activities . . . beyond the level of such activities during 1979.” The Service 

recognizes that fishery levels are cyclic and will take that into consideration when applying the 

1979-level criteria. Any new fishery and related facilities and equipment will have to meet the 

compatibility standard. 

Aquaculture and mariculture support facilities may be allowed in Intensive management, subject 

to provisions of State and Federal laws. Seafood processing plants will not be allowed. 

2.4.17.4 Commercial Harvest of Timber and Firewood 

Commercial harvest of timber and firewood will only be authorized under a special use permit and 

when necessary to fulfill overall refuge management objectives. Within Moderate, Minimal, and 

Wild River management categories, commercial harvest of timber and firewood to accomplish 

management objectives will only occur when an approved refuge fire management plan identifies 

the need to reduce fuel loads in an area. Applicable Federal and State of Alaska guidelines for 

timber management will be followed. Commercial harvest of timber and firewood is not allowed in 

designated wilderness. 

2.4.17.5 Commercial Gathering of Other Resources 

Commercial gathering of other resources (e.g., antlers or mushrooms) requires a special use 

permit under 50 CFR 27.51 and may be authorized in Intensive and Moderate management. 

2.4.17.6 Commercial Filming and Recording Activities 

It is Service policy to provide refuge access and/or assistance to firms and individuals in the 

pursuit of commercial visual and audio recordings when they are compatible with refuge purposes 

or the mission of the Refuge System. Commercial films, television production, or sound tracks 

made within refuges for other than news purposes require a special use permit or authorization 

(43 CFR 5.1). 

Commercial filming or recording activities such as videotaping, audio taping, and photography for 

the purpose of advertising products and services are subject to an A/V Production Permit (Refuge 

Manual 8 RM 16). 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-55
Chapter 2: Goals, Objectives, and Management Direction 

Permits are not required for still photography on refuge lands open to the general public, 

including commercial still photography, so long as no models or props that are not a part of the 

site’s natural or cultural resources or administrative facilities are used (16 U.S.C. 460l-6d(c)). 

2.4.17.7 Other Commercial Uses 

Generally, other commercial uses such as grazing, agriculture, and hydroelectric power 

development will not be allowed. An exception may be made for low-head or small run-of-the-river 

hydropower facilities. These may be authorized in Intensive and Moderate management areas on 

a case-by-case basis. See section 2.4.13.7 for transmission lines, pipelines, and other rights-of-way 

mentioned in title XI of ANILCA. 

2.4.18 Environmental Contaminants Identification and Cleanup 

One goal of the Refuge Administration Act is to maintain the biological integrity, diversity, and 

environmental health of the Refuge System. In support of this goal, the Service studies 

environmental contaminants that may threaten trust species (i.e., those species for which the 

Service has primary jurisdiction) and other resources of the refuge. This work will continue as 

new concerns are identified and as funding allows. 

An assessment of known or suspected contaminants threats is normally completed for each refuge 

as part of the national Contaminants Assessment Process. During comprehensive conservation plan 

revisions, existing information will be reviewed, and an assessment of potential contaminants threats 

will be entered into an electronic database. A contaminant assessment report will also be prepared. 

When contaminants are identified on refuge lands, the Service will initiate discussions with the 

responsible party or parties to remedy the situation. If the Service caused the contamination, funds 

will be sought to define the extent and type of the contamination and to remedy it. Appropriate 

environmental regulations—including the Resource Conservation Recovery Act, Comprehensive 

Environmental Response and Compensation Liability Act, Oil Pollution Act of 1990, and State of 

Alaska regulations (e.g., 18 AAC 75)—would be followed during remediation work. 

All spills of petroleum products and hazardous materials must be reported to the Alaska 

Department of Environmental Conservation and to the National Response Center. Incidents also 

need to be reported to the U.S. Fish and Wildlife Service Regional Spill Response Coordinator. 

The refuge will refer to the U.S. Fish and Wildlife Service Region 7 Spill Response Contingency 

Plan and other relevant plans when responding to spills. 

2.4.19 Management of Designated Wilderness 

Designated wilderness will be managed in accordance with the Wilderness Act of 1964, as 

modified by provisions of ANILCA; Service guidelines as found in the Refuge Manual (6 RM 8) 

and Part 610 of the Service Manual, when approved; and regional policy. Preserving the 

wilderness character of the area is the management focus for designated wilderness. A minimum 

requirements analysis will be conducted for administrative activities proposed in wilderness areas. 

This two-step decision process involves determining if an activity should be conducted in the 

wilderness area and, if so, determining the minimum tool, which is the least intrusive tool, 

equipment, device, force, regulation, or practice deemed necessary to achieve a management 

objective in wilderness. 

Certain activities are legislatively prohibited in designated wilderness, including oil, gas, and 

other mineral leasing, and most surface-disturbing activities. Section 4(c) of the Wilderness Act 

generally prohibits roads, commercial enterprises, motor vehicles, motorboats, other forms of 

2-56 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

mechanical transport, motorized equipment, the landing of aircraft, and structures and 

installations in wilderness areas. Provisions of ANILCA, however, provide exceptions to some of 

these prohibitions for specific purposes, such as allowing motorized public access for traditional 

activities, and for the continuation of pre-existing commercial and private use cabins. Following 

are some of the ANILCA provisions and their applicable sections affecting public use of 

wilderness areas: 

 Access for subsistence purposes (section 811) 

 Access for traditional activities and to and from villages and homesites (section 1110(a)) 

 Access to State- or privately-owned lands (including subsurface rights), valid mining claims, 

or other valid occupancy (section 1110 (b)) 

 Construction and use of cabins for traditional and customary uses (section 1303) 

 Use of facilities associated with the exercise of valid commercial fishing rights 

(section 304(d)) 

Other provisions of ANILCA affect the administrative uses of wilderness areas, including the 

following: 

 Access for mineral assessment purposes, as part of the Alaska Mineral Resources 

Assessment Program (section 1010) 

 Construction and maintenance of navigation aids and other facilities (section 1310) 

 Continuation of existing, and construction of new, public use cabins (sections 1315(c) and (d)) 

Under 50 CFR 35.5(b), regional policy (RW-16) allows local residents engaged in subsistence 

activities to use chainsaws. Other motorized equipment not related to transportation (such as 

generators and water pumps) is not allowed. 

Granting rights-of-way for transportation or utility systems through designated wilderness requires 

Presidential and Congressional approval (section 1106(b) of ANILCA; see also section 2.4.13.7). 

A step-down wilderness stewardship plan may be prepared for specific designated wilderness 

areas to address in greater detail their resources, uses, and management. Specific details would 

be included on how the broad management direction provided in the Comprehensive Conservation 

Plan would be applied in a given designated wilderness area to preserve the wilderness character. 

The step-down plan would be prepared in cooperation with the State of Alaska and others and 

would include appropriate public involvement. 

2.4.20 Administration of Innoko National Wildlife Refuge 

2.4.20.1 Administrative Sites and Visitor Facilities 

Administrative sites include temporary and permanent field camps, residences, offices, and 

associated storage, communication, and transportation facilities. The type of administrative site 

and level of development will be consistent with the management intent of the management 

category in which they are constructed. Administrative field camps or other administrative 

facilities within Minimal, Wild River and Wilderness management categories will only be allowed 

when required to meet management objectives, when no reasonable alternative sites exist, and 

when the facilities are essential to protect the health and safety of employees. New facilities 

would only be the minimum required to meet long-term needs. 

Fuel storage or other hazardous material storage in conjunction with administrative sites will 

meet all Federal and State requirements for spill containment and storage. Hazardous materials 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-57
Chapter 2: Goals, Objectives, and Management Direction 

stored within the Wild River and Wilderness management categories will be in small (55-gallon or 

less) containers. 

Under section 1306 of ANILCA, the Secretary of the Interior may establish administrative sites 

and visitor facilities, either within or outside the boundaries of a conservation system unit, in 

accordance with the unit’s management plan and for the purposes of ensuring the preservation, 

protection, and proper management of the unit. Section 1306 further states that “to the extent 

practicable and desirable, the Secretary shall attempt to locate such sites and facilities on Native 

lands in the vicinity of the unit.” 

Department of Interior guidelines, developed in 1995 and implementing section 1306, require that 

prior to initiating a search for an administrative site or visitor facility, site-selection criteria be 

developed, with public input, and that all proposals be evaluated according to the site-selection 

criteria. If it is determined that Native lands satisfy the site-selection criteria and are desirable 

and practicable for the intended use, the highest-ranked Native lands shall be selected as the 

preferred site, subject to a specific site evaluation. If no Native lands satisfy the site-selection 

criteria, the highest ranked parcel will become the preferred site. Public comments will be 

considered prior to making a final decision. 

Applicability of Refuge Regulations to Off-Refuge Administrative and Visitor Facility Sites.

Under 50 CFR 36.1(c) the Service is authorized to enforce regulations concerning public safety 

and protection of government property, and State of Alaska fish and wildlife regulations, on 

administrative and visitor facility sites that may be held in fee or less-than-fee title and are inside 

or outside the approved boundaries of any Alaska national wildlife refuge. 

2.4.20.2 Refuge Management Plans 

Some management programs are addressed in sufficient detail in the Comprehensive 

Conservation Plan to be integrated directly into the budgetary process. For other programs, it 

may be necessary to prepare step-down management plans to implement general strategies 

identified in this Plan. More information on the step-down planning process can be found in 602 

FW 3 of the Service Manual. 

2-58 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

The following step-down management plans for Innoko Refuge are required. 

Table 2-1. Required step-down management plans for Innoko National Wildlife Refuge 

Plan Completion / Update 

Inventory and Monitoring Plan To be completed within 2 years of refuge 

biological review 

Fisheries Management Plan Completed in 1993; to be revised within 2 

years of completion of Inventory and 

Monitoring Plan 

Cultural Resource Guide Completed 1995; to be updated by 2010 

Fire Management Plan Completed 2005; to be updated every 5 years 

Land Protection Plan Completed 2007 

Station Safety Plan 

Occupant Emergency Evacuation Plan 

Completed 2006; reviewed annually, 

revised as needed 

Water Resources Inventory and Assessment: 

Plan of Study 

Completed 1996 

Spill Prevention Control and Countermeasure Plan Completed 2000; updated periodically 

Visitor Services Plan To be completed when necessary 

Wilderness Stewardship Plan To be completed within one year of release of 

national wilderness guidelines 

2.4.21 Alaska Mineral Resource Assessment Program 

Section 1010 of ANILCA requires that all Federal lands be assessed for their oil, gas, and other 

mineral potential, although section 304(c) prohibits new hardrock mining on refuges. Mineral 

assessment techniques that do not have lasting impacts—such as side-scanning radar, trenching, 

and core drilling—may be allowed throughout the refuge. Special use permits issued to other 

government agencies or their contractors for assessment work would include stipulations to 

ensure that the assessment program is compatible with refuge purposes. For example, 

stipulations may limit access during nesting, calving, spawning, or other times when fish and 

wildlife may be especially vulnerable to disturbance. 

2.5 Management Categories Table 

2.5.1 Introduction 

Table 2-2 lists activities, public uses, commercial uses, and facilities by management category. In 

some cases, it provides very specific guidance (such as for highway vehicles). In other cases (such 

as for research and management facilities), the direction is general. While facilities may be 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-59
Chapter 2: Goals, Objectives, and Management Direction 

allowed in all management categories, the types of facilities and how they would be constructed 

and operated vary by management category. The descriptions of the management categories 

reflect a clear distinction in the level of action, type of action, and constraints that may be placed 

on activities or development within the management categories. The descriptions of the 

management categories should be used to reflect the desired future condition of the area when 

site-specific proposals are being evaluated. Activities allowed or authorized within the different 

categories will be managed differently depending on the management category in which they 

occur. Because no rivers within Innoko Refuge are designated or proposed for designation as Wild 

and Scenic Rivers, this category is not included in the table. Those management categories and 

activities, public uses, commercial uses, and facilities that generally do not apply to Innoko Refuge 

are shaded grey. 

2.5.1.1 Definitions for Management Categories Table 

The following are definitions for terms used in the table. 

Allowed – Activity, use, or facility is allowed under existing NEPA analysis, appropriate use 

findings, refuge compatibility determinations, and applicable laws and regulations of the Service, 

other Federal agencies, and the State of Alaska. 

May be allowed – Activity, use, or facility may be allowed subject to site-specific NEPA analysis, 

an appropriate use finding (when required), a specific refuge compatibility determination (when 

required), and compliance with all applicable laws and regulations of the Service, other Federal 

agencies, and the State of Alaska. 

May be authorized – Activity, use, or facility may be allowed; a special use permit or other 

authorization is required. 

Not allowed – Activity, use, or facility is not allowed. 

The following terms are used: 

NEPA analysis – All activities, uses, and facilities proposed for a refuge that have the potential to 

result in significant effects on the environment require an analysis of potential environmental 

impacts under the National Environmental Policy Act. This analysis may be documented as a 

categorical exclusion (CE), an environmental assessment (EA), or an environmental impact 

statement (EIS), depending on the nature of the proposed project. 

Appropriate Use – All uses over which the Service has jurisdiction must be determined to be 

appropriate following direction in Service Manual 630 FW 1. Hunting, fishing, wildlife 

observation and photography, and environmental education and interpretation are considered 

appropriate by national policy with no further analysis required. See section 2.4.5 for a 

description of the criteria used to determine if other uses are appropriate. 

Compatibility – All activities, uses, and facilities allowed on the refuge, except management 

actions undertaken by or for the Service, must be compatible with the purposes of the refuge and 

the mission of the Refuge System. The analysis that occurs results in a refuge compatibility 

determination. Management activities undertaken by the Service or by volunteers, cooperators, or 

contractors working for the Service, with limited exception, are exempt from compatibility review 

(part 603 of the Service Manual). 

Regulations – All activities, uses, and facilities allowed on a refuge must comply with any 

applicable regulations, as published in the Code of Federal Regulations. Regulations are 

developed by the Service through a public process to implement the legal authorities under which 

2-60 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-61

the Service manages the Refuge System. For more information on these regulations, see the 

appropriate topic in the Management Policies and Guidelines section (section 2.4) of this chapter. 

For some activities, other Federal agency and/or State regulations may also apply. 

Temporary – A continuous period of time not to exceed 12 months, except as specifically provided 

otherwise. Special use permits or other authorizations may prescribe a longer period of time, but 

the structures or other human-made improvements need to be readily and completely dismantled 

and removed from the site when the period of authorized use terminates. 

The following guidelines apply to all activities, uses, and facilities allowed on a refuge. 

Area or time restrictions – All activities and uses allowed on a refuge may be restricted in 

certain areas or at certain times, at the discretion of the refuge manager and with the appropriate 

level of public involvement, by emergency (short-term) or permanent regulation, if necessary to 

protect refuge resources or human health and safety. 

Management emergencies – Activities, uses, and facilities not allowed on a refuge or in specific 

management categories may be allowed if naturally occurring or human-caused actions adversely 

affect refuge resources or threaten human health and safety. 
Chapter 2: Goals, Objectives and Management Direction 

2-62 Innoko National Wildlife Refuge Revised CompreTable 2-2. Activities, public uses, commercial uses, and facilities by management category 

Activity Wilderness Management Minimal Management Moderate Management 

ECOSYSTEM, HABITAT, AND FISH AND WILDLIFE MANAGEMENT Ecosystem and Landscape Management Collecting Information on and Monitoring Ecosystem Components Data gathering, monitoring, and maintaining a comprehensive data base of selected ecosystem components (plants, animals, fish, water, air) (see sections 2.4.10 & 2.4.11) 

Allowed; see section 2.4.19∗

Allowed Allowed 

Research and Management Access and collection of data necessary for management decisions or to further science by the Service (see sections 2.4.10 & 2.4.11) 

Allowed; see section 2.4.19∗

Allowed Allowed 

Access and collection of data necessary for management decisions or to further science by ADF&G 

Allowed; see section 2.4.19∗

Allowed Allowed 

Access and collection of data necessary for management decisions or to further science by other researchers 

May be authorized; see section 2.4.19∗

May be authorized May be authorized 

Research and Management Facilities May be permanent or temporary structures or camps, including weirs, counting towers and sonar counters (see section 2.4.20) 

May be allowed; consistent with section 2.3.5∗

May be allowed May be allowed 

Fish and Wildlife Habitat Management Describing, Locating, and Mapping Habitats Development of quantitative, written, and graphic descriptions of fish and wildlife habitat, including water, food, and shelter components (see section 2.4.10) 

Allowed; see section 2.4.19∗

Allowed Allowed 

Habitat Management (see section 2.4.10.1) Mechanical Treatment Activities such as cutting, crushing or mowing of vegetation; water control structures; fencing; artificial nest structures 

Not allowed; with exceptions consistent with section 2.3.5; see also section 2.4.19∗

Not allowed; with exceptions consistent with section 2.3.4 

May be allowed 

Chemical Treatment Use of chemicals to remove or control non-native species (see section 2.4.10.1) 

May be allowed; see section 2.4.19∗

May be allowed May be allowed 

∗ Subject to minimum requirements analysis. 
Chapter 2: Goals, Objectives, an

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Activity Wilderness Management Minimal Management Moderate Management 

Manual Treatment Use of hand tools to remove, reduce, or modify hazardous plant fuels, exotic plant species, or to modify habitats (e.g., remove beaver dams) 

May be allowed; see section 2.4.19∗

May be allowed May be allowed 

Aquatic Habitat Modifications Activities such as stream bank restoration, passage structures, fish barriers, or removal of obstacles that result in physical modification of aquatic habitats to maintain or restore native fish species (see section 2.4.10.1) 

May be allowed; consistent with section 2.3.5; see also section 2.4.19∗

May be allowed May be allowed 

Fire Management—Prescribed Fires Fire ignited by management actions to meet specific management objectives (see section 2.4.10.2) 

May be allowed; see section 2.3.5∗

May be allowed May be allowed 

Fire Management—Wildland Fire Use The planned use of naturally occurring fires to meet management objectives (see section 2.4.10.2) 

May be allowed∗ May be allowed May be allowed 

Fire Management—Fire Suppression Management actions intended to protect identified resources from a fire, extinguish a fire, or alter a fire’s direction of spread (see section 2.4.10.2) 

Allowed Allowed Allowed 

Non-native and Pest Plant Control Monitoring, extirpation, control, removal and/or relocation, and other management practices for pest and non-native plant species (see section 2.4.11.8) 

May be allowed; see section 2.4.19∗

May be allowed May be allowed 

Water Quality and Quantity Management Monitoring of water quality and quantity to identify baseline data and for management purposes; includes installation of gaging stations (see section 2.4.9.2) 

Allowed; see section 2.4.19∗

Allowed Allowed 

∗ Subject to minimum requirements analysis. 
Chapter 2: Goals, Objectives and Management Direction 

2-64 Innoko National Wildlife Refuge Revised Compre

Activity Wilderness Management Minimal Management Moderate Management 

Fish and Wildlife Population Management Reintroduction of Species The reintroduction of native species to restore natural diversity of fish, wildlife, and habitats (see section 2.4.11.6) 

May be allowed; see section 2.4.19∗

May be allowed May be allowed 

Fish and Wildlife Control The control, relocation, sterilization, removal, or other management of native species (including predators) to maintain natural diversity of fish, wildlife, and habitats; favor other fish or wildlife populations; protect reintroduced, threatened, or endangered species, or to restore depleted native populations (see section 2.4.11.7) 

May be allowed; see section 2.4.19∗

May be allowed May be allowed 

Non-native Species Management The removal or control of non-native species (including predators) (see section 2.4.11.8) 

May be allowed; see section 2.4.19∗

May be allowed May be allowed 

Pest Management and Disease Prevention and Control Relocation or removal of organisms that threaten human health or survival of native fish, wildlife or plant species; management practices directed at controlling pathogens that threaten fish, wildlife, and people, such as rabies and parasite control (see section 2.4.11.8) 

May be allowed; see section 2.4.19∗

May be allowed May be allowed 

Fishery Restoration Actions taken to restore fish access to spawning and rearing habitat, or actions taken to restore populations to historic levels; includes harvest management, escapement goals, habitat restoration, stocking, egg incubation boxes, and lake fertilization (see section 2.4.11.10) 

May be allowed∗ May be allowed May be allowed 

∗ Subject to minimum requirements analysis. 
Chapter 2: Goals, Objectives, an

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Activity Wilderness Management Minimal Management Moderate Management 

Fishery Restoration Facilities Permanent or temporary fisheries facilities, including hatcheries, fish ladders, fish passages, fish barriers and associated structures (see sections 2.4.11.10 and 2.4.20) 

May be authorized∗ May be authorized May be authorized 

Fishery Enhancement Activities applied to a fish stock to supplement numbers of harvestable fish to a level beyond what could be naturally produced based upon a determination or reasonable estimate of historic levels (see section 2.4.11.11) 

May be allowed; consistent with section 2.4.19∗

May be allowed May be allowed 

Fishery Enhancement Facilities May be permanent or temporary and may include hatcheries, egg incubation boxes, fish ladders, fish passages, fish barriers and associated structures (see sections 2.4.11.11 and 2.4.20) 

May be authorized* May be authorized May be authorized 

Native Fish Introductions Movement of native fish species within a drainage on the refuge to areas where they have not historically existed (see section 2.4.11.6) 

May be allowed∗ May be allowed May be allowed 

Non-native Species Introductions Introduction of species not naturally occurring within the refuge (see section 2.4.11.6) 

Not allowed Not allowed Not allowed 

SUBSISTENCE 

(see section 2.4.12) 

Subsistence Activities Fishing, Hunting, Trapping, and Berry Picking The taking of fish and wildlife and other natural resources for personal consumption, as provided by law 

Allowed Allowed Allowed 

Collection of House Logs and Firewood Harvesting live standing timber greater than 6 inches diameter at breast height for personal or extended family use 

May be authorized May be authorized May be authorized 

∗ Subject to minimum requirements analysis. 
Chapter 2: Goals, Objectives and Management Direction 

2-66 Innoko National Wildlife Refuge Revised Compre

Activity Wilderness Management Minimal Management Moderate Management 

Collection of House Logs and Firewood Harvesting live trees between 3 and 6 inches diameter at breast height for personal or extended family use 

20 trees or less per year allowed; more than 20 trees per year may be authorized 

20 trees or less per year allowed; more than 20 trees per year may be authorized 

20 trees or less per year allowed; more than 20 trees per year may be authorized 

Collection of Plant Materials Harvesting trees less than 3 inches diameter at breast height, dead standing or downed timber, grass, bark, and other plant materials used for subsistence purposes 

Allowed Allowed Allowed 

Temporary Facilities Establishment and use of tent platforms, shelters, and other temporary facilities and equipment directly related to the taking of fish and wildlife (see section 2.4.15.2) 

May be allowed May be allowed May be allowed 

Subsistence Cabins – see Cabins (see also section 2.4.15.1) Subsistence Access – subject to reasonable regulations under provisions of section 810 of ANILCA (see section 2.4.12) Use of snowmobiles, motorboats, and other means of surface transportation traditionally employed for subsistence purposes 

Allowed Allowed Allowed 

ACCESS 

(see sections 2.4.13 and 2.4.14) 

Restrictions subject to provisions of section 1110 of ANILCA as applicable; see also Subsistence Access sect

Foot Allowed Allowed Allowed Dogs and Dog Teams(weed-free bedding materials may be required) 

Allowed Allowed Allowed 

Other Domestic Animals Includes horses, mules, llamas, etc. (weed-free feed may be required) 

Allowed Allowed Allowed 

Nonmotorized Boats Includes canoes, kayaks, rafts, etc. 

Allowed Allowed Allowed 

Use of snowmachine, motorboats, airplanes, and nonmotorized surface transportation methods for traditional activities and for travel to and from villages and homesites 

Allowed Allowed Allowed 

Highway Vehicles Not allowed Not allowed May be allowed on 

designated roads 
Chapter 2: Goals, Objectives, an

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Activity Wilderness Management Minimal Management Moderate Management 

Off-Road Vehicles (All-Terrain Vehicles) Includes air boats and air cushion vehicles (see sections 2.4.12.1 and 2.4.13.2) 

Not allowed; with exceptions consistent with section 2.14.13. 

Not allowed; with exceptions consistent with section 2.14.13. 

May be allowed 

Helicopters Includes all rotary-wing aircraft (see section 2.4.13.3) 

May be authorized; consistent with sections 2.4.19 and 2.3.5 

May be authorized May be authorized 

PUBLIC USE, RECREATION, and OUTREACH ACTIVITIES 

Also see ACCESS and Commercial Recreation sections. 

Hunting, Fishing, Wildlife Observation, Wildlife Photography, Interpretation and Environmental Education Note: All activities listed are priority public uses (see section 2.4.14) 

Allowed Allowed Allowed 

Trapping, Walking, Hiking, Camping at Undeveloped Sites, and Dog Sledding (see section 2.4.14) 

Allowed Allowed Allowed 

General Photography See also COMMERCIAL USES (see sections 2.4.14) 

Allowed Allowed Allowed 

Outreach Activities (see sections 2.4.16) 

Allowed Allowed Allowed 

Public Use and Recreation Facilities – level of development is consistent with management intent of the category (see section All Weather Roads All weather roads and associated developments, including bridges 

Not allowed Not allowed May be allowed 

Unimproved Roads Note: while unimproved roads are not allowed in Minimal management, Wilderness and Wild Rivers, roads may exist. In these management categories, the roads would not be designated for use or maintained. 

Not allowed Not allowed May be allowed 

Designated Off-Road Vehicle (All-Terrain Vehicle) Trails and Routes 

Not allowed Not allowed May be allowed 

Roadside Exhibits and Waysides Not applicable Not applicable May be allowed 
Chapter 2: Goals, Objectives and Management Direction 

2-68 Innoko National Wildlife Refuge Revised Compre

Activity Wilderness Management Minimal Management Moderate Management 

Constructed and Maintained Airstrips Not allowed Not allowed May be allowed Cleared Landing Strips and Areas Includes unimproved areas where airplanes land; minor brush cutting or rock removal by hand is allowed for maintenance 

Existing strips allowed to remain; new strips not allowed; see section 2.4.19∗

May be allowed May be allowed 

Constructed Hiking Trails Includes bridges, boardwalks, trailheads, and related facilities 

May be allowed∗ May be allowed May be allowed 

Designated Hiking Routes Unimproved and unmaintained trails; may be designated by signs, cairns, and/or on maps 

Allowed Allowed Allowed 

Boat Launches and Docks Designated sites for launching and storing watercraft or tying up a float plane 

May be allowed∗ May be allowed May be allowed 

Visitor Contact Facilities A variety of staffed and unstaffed facilities providing information on the refuge and its resources to the public, ranging from visitor centers to kiosks and signs (see section 2.4.15) 

Generally not allowed; see sections 2.3.5 and 2.4.19∗

May be allowed May be allowed 

Campgrounds Developed sites accessible by highway vehicles 

Not applicable Not applicable May be allowed 

Hardened Campsites Areas where people can camp that are accessible by vehicle or on foot but where the only facilities provided are for public health and safety and/or resource protection; may include gravel pads for tents, hardened trails, and/or primitive toilets (see section 2.4.15) 

Allowed; consistent with section 2.4.19∗

Allowed Allowed 

Temporary Facilities Includes tent frames, caches, and other similar or related facilities; does not include cabins; see also SUBSISTENCE, COMMERCIAL USES, and Administrative Facilities (see section 2.4.15.2) 

May be authorized May be authorized May be authorized 

∗ Subject to minimum requirements analysis. 
Chapter 2: Goals, Objectives, an

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Activity Wilderness Management Minimal Management Moderate Management 

Cabins – also other related structures such as outdoor toilets, food caches, storage sheds, and fish drying racks (see section 2Public Use Cabin A cabin administered by the Service and available for use by the public; intended only for short-term public recreational use and occupancy 

Existing cabins allowed to remain; new cabins may be allowed; consistent with section 2.4.19∗

Existing cabins allowed to remain; new cabins may be allowed 

Existing cabins allowed to remain; new cabins may be allowed 

Administrative Cabin Any cabin primarily used by refuge staff or other authorized personnel for the administration of the refuge (see section 2.4.20.1) 

May be allowed; consistent with section 2.4.19∗

May be allowed May be allowed 

Subsistence Cabin Any cabin necessary for health and safety and to provide for the continuation of ongoing subsistence activities; not for recreational use 

Existing cabins allowed to remain; new cabins may be authorized; consistent with section 2.4.19 

Existing cabins allowed to remain; new cabins may be authorized 

Existing cabins allowed to remain; new cabins may be authorized 

Commercial Cabin Any cabin used in association with a commercial operation, including but not limited to commercial fishing activities and recreational guiding services 

Existing cabins allowed to remain; new cabins not allowed consistent with section 2.4.19 

Existing cabins allowed to remain; new cabins may be authorized 

Existing cabins allowed to remain; new cabins may be authorized 

Other Cabins Cabins associated with authorized uses by other government agencies 

May be authorized; consistent with section 2.4.19 

May be authorized May be authorized 

Administrative Facilities (see section 2.4.20.1) Administrative Field Camps Temporary facilities used by refuge staff and other authorized personnel to support individual (generally) field projects; may include but not limited to tent frames and temporary/portable outhouses, shower facilities, storage/maintenance facilities, and caches 

May be allowed∗ May be allowed May be allowed 

∗ Subject to minimum requirements analysis. 
Chapter 2: Goals, Objectives and Management Direction 

2-70 Innoko National Wildlife Refuge Revised Compre

Activity Wilderness Management Minimal Management Moderate Management 

Administrative Field Sites Permanent facilities used by refuge staff or other authorized personnel for the administration of the refuge; includes administrative cabins and related structures (see Cabins) and larger multi-facility administrative sites necessary to support ongoing field projects, research, and other management activities; or temporary facilities to meet short-term needs 

Use of existing sites allowed, including replacement of existing facilities as necessary; new sites may be allowed; consistent with sections 2.4.19∗ and 2.3.5 

Use of existing sites allowed, including replacement of existing facilities as necessary; new sites may be allowed 

Use of existing siteallowed, including replacement of existing facilities anecessary; new sitemay be allowed 

Refuge Administrative Office Complex Facilities necessary to house refuge operations, outreach, and maintenance activities, and associated infrastructure; includes staff offices, storage, maintenance, parking lots, and other similar facilities 

Not allowed Not allowed Not allowed 

Hazardous Materials Storage Sites, including appropriate structures and equipment, necessary for the storage and transfer of fuels and other hazardous materials used for administrative purposes; must be in compliance with all Federal and State requirements 

May be allowed May be allowed May be allowed 

Residences Residential housing for refuge staff and their families; includes single and multi-family dwellings 

Not allowed Not allowed Not allowed 

Bunkhouses Quarters to house temporary and similar employees, volunteers, visitors, and other agency personnel 

Not allowed Not allowed May be allowed 

Aircraft Hangars and Facilities for Storage of Aircraft 

Not allowed∗ Not allowed Not allowed 

Boat Launches and Docks Designated sites for launching and storing watercraft or tying up a float plane 

May be allowed∗ May be allowed May be allowed 

Radio Repeater Sites Sites used to maintain radio communications equipment; may include helispots for access 

May be allowed∗ May be allowed May be allowed 

* Subject to minimum requirements analysis 
Chapter 2: Goals, Objectives, an

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Activity Wilderness Management Minimal Management Moderate Management 

COMMERCIAL USES 

Except as noted, a special use permit or other authorization is required for economic use of a refuge

Commercial Recreation – includes all forms of guiding, including those operated by nonprofit, educational, and other noncomm2.4.17.1) Guiding and Outfitting May be authorized May be authorized May be authorized Transporting May be authorized May be authorized May be authorized Fixed-Wing Air Taxis May be authorized May be authorized May be authorized Helicopter Air Taxis Not allowed; with 

exceptions consistent with section 2.4.13.3 

May be authorized May be authorized 

Bus and Auto Tours Not applicable Not applicable May be authorized Mineral Exploration (see section 2.4.17.2) See section 2.4.21 for information on the Alaska Mineral Resource Assessment Program Surface Geological Studies Includes surface rock collecting and geological mapping activities (includes helicopter or fixed-wing access)

Not allowed May be authorized May be authorized 

Geophysical Exploration and Seismic Studies Examination of subsurface rock formations through devices that set off and record vibrations in the earth; usually involves mechanized surface transportation, but may be helicopter supported; includes studies conducted for the Department of the Interior 

Not allowed May be authorized May be authorized 

Core Sampling Using helicopter transported motorized drill rig to extract subsurface rock samples; does not include exploratory wells; includes sampling conducted for Department of the Interior 

Not allowed May be authorized May be authorized 

Other Geophysical Studies Helicopter-supported gravity and magnetic surveys and other minimal impact activities that do not require mechanized surface transportation 

Not allowed May be authorized May be authorized 
Chapter 2: Goals, Objectives and Management Direction 

2-72 Innoko National Wildlife Refuge Revised Compre

Activity Wilderness Management Minimal Management Moderate Management 

Mineral Development (see section 2.4.17.2) Oil and Gas Leasing Leasing, drilling, and extraction of oil and gas for commercial purposes; includes all associated above and below ground facilities 

Not allowed Not allowed Not allowed 

Sale of Sand, Gravel, and Other Common Variety Minerals Extraction of sand, gravel, and other saleable minerals for commercial purposes; includes commercial use by Federal, State, and local agencies 

Not allowed Not allowed May be authorized 

Other Mineral Leasing Includes the extraction of coal, geothermal resources, potassium, sodium, phosphate, sulfur, or other leaseable minerals for commercial purposes; for cases of national need, see section 2.4.17.2 

Not allowed Not allowed Not allowed 

Mining of Hardrock Minerals Development of valid (pre-ANILCA) mining claims (lode, placer, and mill sites) on refuge lands for the purpose of extracting hardrock minerals 

Allowed only on valid claims 

Allowed only on valid claims 

Allowed only on vaclaims 

Other Commercial Activities Commercial Filming, Videotaping, and Audiotaping (see section 2.4.17.6) 

May be authorized May be authorized May be authorized 

Grazing (see section 2.4.17.7) 

Not allowed Not allowed Not allowed 

Agriculture (Commercial) (see section 2.4.17.7) 

Not allowed Not allowed Not allowed 

Commercial Fishery Support Facilities At or below 1979 levels (see section 2.4.17.3) 

Allowed Allowed Allowed 

Commercial Fishery Support Facilities Above 1979 levels (see section 2.4.17.3) 

Not allowed May be authorized May be authorized 

Seafood Processing (see section 2.4.17.3) 

Not allowed Not allowed Not allowed 

Aquaculture and Mariculture Support Facilities (see section 2.4.17.3) 

Not allowed Not allowed Not allowed 

Commercial Timber and Firewood Harvest (see section 2.4.17.4) 

Not allowed May be authorized May be authorized 
Chapter 2: Goals, Objectives, an

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Activity Wilderness Management Minimal Management Moderate Management 

Commercial Gathering of Other Refuge Resources (see section 2.4.17.5) 

Not allowed Not allowed May be authorized 

Transportation and Utility Systems Includes transmission lines, pipelines, telephone and electrical power lines, oil and gas pipelines, communication systems, roads, airstrips, and other necessary related facilities; does not include facilities associated with on-refuge oil and gas development (see section 2.4.13.7) 

Must be authorized by Congress 

May be authorized; would require a plan amendment 

May be authorized 

Navigation Aids and Other Facilities Includes air and water navigation aids and related facilities, communication sites and related facilities, facilities for national defense purposes and related air/water navigation aids, and facilities for weather, climate, and fisheries research and monitoring; includes both private and government facilities (see section 2.4.13.11) 

May be authorized∗ May be authorized May be authorized 

Major Hydroelectric Power Development Hydroelectric dams creating a change in streamflow with an elevation change and reservoir behind the dam (see section 2.4.17.7) 

Not allowed Not allowed Not allowed 

Small Hydroelectric Power Development Hydroelectric generation by low-head or instream structures that do not change the flow of the river (see section 2.4.17.7) 

Not allowed Not Allowed May be authorized 

∗ Subject to minimum requirements analysis. 
Chapter 2: Goals, Objectives and Management Direction 

2.6 References 

Alaska Department of Fish and Game. 2007. Wood bison restoration in Alaska: a review of 

environmental and regulatory issues and proposed decisions for project 

implementation. Alaska Department of Fish and Game. Juneau, Alaska. 

Bayha, K., S. Lyons, and M.L. Harle. 1997. “Strategic Plan for Water Resources Branch.” 

WRB-97-1. Anchorage, Alaska: U.S. Department of the Interior, Fish and Wildlife 

Service, Division of Realty. 25 pp. 

Brabets, Timothy, P. 1996. Evaluation of the Streamflow-Gaging Network of Alaska in 

Providing Regional Streamflow Information 

Conant, B., J.I. Hodges, D.J. Groves, and J.G. King. 2007. Alaska trumpeter swan status 

report - 2005. Unpubl. Report. U.S. Fish and Wildl. Serv., Juneau, AK. 

DOI. “Departmental Manual.” Accessed November 13, 2003. At 

http://elips.doi.gov/app_dm/index.cfm?fuseaction=home on the World Wide Web, 

produced by U.S. Department of the Interior. Source last updated December 1, 

2001. 

Ely, C.R. and J.A. Schmutz. 1999. Characteristics of mid-continent Greater White-Fronted 

Geese from interior Alaska: Distribution, migration ecology, and survival. USGS 

report submitted to the Central Flyway Technical Committee. Anchorage, AK, 35 pp. 

Gardner, C.L., and A.R. DeGange. 2003. A review of information on wood bison in Alaska 

and adjacent Canada, with particular reference to the Yukon Flats. Alaska 

Department of Fish and Game. US Fish and Wildlife Service. Unpublished report. 

Harle, M.L. 1994. “Water resources threats analysis.” Unpublished report. Anchorage, 

Alaska: U.S. Department of the Interior, Fish and Wildlife Service, Water 

Resources Branch. 30 pp. plus appendices. 

Mallek, E.J. and D.J. Groves. 2007. Alaska-Yukon waterfowl breeding population survey - 

May 14 to June 25, 2007. Unpubl. Report. U.S. Fish and Wildl. Serv., Juneau, AK. 

Platte, Robert M. 1996. Water bird abundance and distribution on Innoko National 

Wildlife Refuge, Alaska. USFWS Migratory Bird Management. Anchorage, 

Alaska. 

Spindler, M.A. 1999. Trends in abundance and productivity of white-fronted Geese in the 

taiga of northwest and interior Alaska. Report submitted to the Central Flyway 

Technical Committee, March 5, 1999, Lawton, Oklahoma. 

USDOI. 2001. “Department of the Interior—Alaska Policy on Government-to-Government 

Relations with Alaska Native Tribes.” Washington, D.C: U.S. Department of the 

Interior. 3 pp. (Policy signed on January 18, 2001) 

U.S. Government. 2007-2008. “Code of Federal Regulations.” Accessed August 24, 2007, at 

http://www.gpoaccess.gov/cfr/index.html on the World Wide Web. 

USFWS. 1992. “Cultural Resources Management Handbook.” U.S. Fish and Wildlife 

Service. Washington, DC. November 1992. 

2-74 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 2: Goals, Objectives, and Management Direction 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 2-75 

USFWS. 1994. “Native American Policy.” National Policy Issuance #94-10. Washington, 

D.C: U.S. Fish and Wildlife Service. 11 pp. (Policy signed on June 28, 1994; issued 

as national policy on August 24, 1994). 

USFWS and NMFS. 1998. Endangered Species Consultation Handbook. March. 

USFWS. “Service Manual.” Accessed October 4, 2004. At 

http://policy.fws.gov/manual.html on the World Wide Web, produced by U.S. Fish 

and Wildlife Service. 

USFWS. “Administrative Manual.” U.S. Fish and Wildlife Service. Washington, DC. 

USFWS. “Refuge Manual.” U.S. Fish and Wildlife Service. Washington, DC. 
Chapter 3: Refuge Resources 

3. Refuge Resources 

Established in 1980 by the Alaska National Interest Lands Conservation Act (ANILCA), the 

refuge was created primarily to protect the natural diversity of fish and wildlife populations and 

their habitats. This chapter describes the physical, biological, social, and economic components of 

the ecosystem that could be affected by actions associated with management of Innoko National 

Wildlife Refuge (Innoko Refuge, refuge). This chapter is divided into seven major headings: 

Geographic Setting, Physical Environment, Biological Environment, Human Environment, 

Wilderness Values, River Values, and Refuge Infrastructure and Administration. Scientific 

names of all plants and animals are provided in appendix G. All place name spellings were taken 

from the Dictionary of Alaska Place Names (Orth 1971). 

3.1 Geographic Setting 

3.1.1 Land Status 

Two acts of Congress, the Alaska Native Claims Settlement Act of 1971 (ANCSA) and the Alaska 

National Interest Lands Conservation Act (ANILCA) in 1980 determined the current land 

ownership patterns of the Innoko Refuge. ANCSA authorized the formation of village and 

regional Native corporations and enabled them to select and gain title to large blocks of Federal 

land. ANILCA established the refuge. 

Refuge boundaries were drawn roughly along or near major ecological features, such as rivers or 

watershed boundaries, regardless of existing land ownership patterns. Consequently, the refuge 

boundaries incorporated lands that are owned or selected by individuals, Native corporations, or 

the State of Alaska. 

The exterior boundary of the southern unit encompasses approximately 3,816,217 acres. Regional 

and village Native corporations currently own or claim about 235,020 acres. In addition, privatelyowned or selected small parcels, including 69 Native allotments, are scattered across the refuge. 

The remaining 3,568,837 acres of land are administered by the refuge (Figure 3-1). 

3.1.1.1 Village Native Corporation Land 

Two village Native corporations, the Zho-Tse Corporation (Shageluk) and Heeyea Lingde 

Corporation (Grayling) have land holdings within the refuge boundary. Each corporation has a 

total land entitlement of 92,160 acres and each has taken some of this entitlement outside the 

refuge boundary as well as within. As of March 2007, about 17,571 acres inside the refuge had 

been conveyed to the Zho-Tse Corporation and an additional 5,237 acres had been selected. These 

land selections, however, include 4,145 acres that are also selected by Doyon, Limited (Doyon, 

Doyon Ltd.), the regional corporation (Table 3-1). Heeyea Lingde Corporation owns a total of 

41,926 acres within the refuge and has selected another 12,501 acres. Land status within the 

refuge will change as selected lands are conveyed, relinquished, or rejected. However, land status 

should be resolved by 2009 under the provisions of the Alaska Land Transfer Acceleration Act of 

2004 (P.L. 108-452). 

The Zho-Tse Corporation lands are mostly located in the southern portion of Innoko Refuge, 

along and near the Innoko River. Heeyea Lingde Corporation lands are located along and near 

the Yukon River in the southwest portion of Innoko Refuge (Figure 3-1). 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-1 
Chapter 3: Refuge Resources 

Table 3-1. Surface land statusa of the Innoko Refuge, as of March 2007 

Area in Acresb 

Category Landowner 

Conveyedc Selected Total Conflicting 

Claimsd 

Federal – 

Refuge 

United States 3,568,837 3,568,837 0 

State 

Government 

State of Alaska 0 129 129 0 

Native 

Allotments 

Many (69 landowners) 7,647 761 8,408 0 

Regional 

Native 

Corporation 

Doyon Ltd. 100,255 57,540 157,795 4,145 

Other Private 12 0 12 0 

Village Native 

Corporation 

Heeyea Lingde 

Corporation (Grayling) 

41,926 12,501 54,427 0 

Zho-Tse Corp. (Shageluk) 17,571 5,237 22,808 4,145 a

 Acreage figures do not include submerged beds of meanderable water bodies (rivers of 198 feet or more in width and 

lakes of 50 acres or more). There are approximately 44,790 acres of these water bodies on refuge lands and about 

7,950 acres on conveyed and selected lands. Ownership of the submerged lands beneath these water bodies depends 

on the navigability status and is yet to be determined for many of the water bodies. No ownership of the land beneath 

these water bodies is implied in this table. 

b

 All acreages are GIS-calculated approximations and may differ from official acreage figures reported elsewhere. All 

data are from Master Title Plats maintained by the Bureau of Land Management. c

 Includes patented and Interim Conveyed (IC) lands. Only land claims within the refuge boundary are reported. d

 Acres of land selected by more than one entity. 

3.1.1.2 Regional Native Corporation Lands 

Doyon holds title to 100,256 acres of land and has selected an additional 56,540 acres within the 

Innoko Refuge. However, 4,145 acres of these claims conflict with those of the Zho-Tse 

Corporation. Doyon lands are mostly located along and near the Yukon River in the western 

portion of Innoko Refuge (Figure 3-1). 

According to the conveyance rules of ANCSA [section 14(f)], Doyon is granted the subsurface rights 

to the lands conveyed to both Zho-Tse and Heeyea Lingde village corporations. This provision gives 

the regional corporation the rights to potentially valuable mineral interests but gives the village 

control of the surface lands necessary to supply their subsistence and economic needs. 

3.1.1.3 Native Allotments 

Until its repeal in 1971, the Native Allotment Act of 1906 authorized Alaskan Natives to claim up 

to 160 acres of land. In addition, a 1998 amendment to ANCSA (section 432 of P.L. 105-276 [43 

U.S.C. 1629g]) authorized qualified Alaskan Native Vietnam veterans to apply for an allotment if 

they had not previously done so. The 1998 law addressed the concern that military service may 

have prevented some Native veterans from applying for an allotment under the 1906 Act. The 

application period for these new allotments closed on January 31, 2002. To date, a total of 64 

allottees have been deeded a total of 7,798 acres within Innoko Refuge. Another 762 acres (seven 

parcels) are selected, including a total of five Vietnam veteran allotment claims (about 541 acres). 

3-2 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Figure 3-1. Land status, easements, and rights-of-way 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources

3-4 
Chapter 3: Refuge Resources 

3.1.1.4 Other Private Lands 

Congress extended the nation’s principal land laws to Alaska in 1884. Many of these laws were 

designed to encourage private settlement and improvement of public lands. There is only one 

private patent within the boundaries of the refuge. This patent was issued for a trade and 

manufacturing site, totaling about 12 acres. The Trade and Manufacturing Act of 1898 allowed a 

cash entry for up to 80 acres of land to be used as a place of business. 

3.1.1.5 State of Alaska 

The State of Alaska has selected a single 129-acre parcel of land on Bullfrog Island in the Yukon 

River (Figure 3-1). The Alaska Statehood Act (PL 85-508) entitled the State to select 102,550,000 

acres of vacant, unappropriated and unreserved land under the general grant, and to select an 

additional 400,000 acres to promote development and expansion of communities. The State was 

also granted title to most of the existing roads, airfields, and associated facilities under the Alaska 

Omnibus Act (Public Law 86-70). 

3.1.1.6 Submerged Lands 

In general, the lands beneath tidelands and inland navigable waters were granted to the State of 

Alaska by the Equal Footing Doctrine, the Submerged Lands Act of 1953, and the Statehood Act 

of 1958. However, lands beneath water bodies that were reserved or withdrawn by the Federal 

government prior to statehood on January 3, 1959, may have been retained by the United States. 

If the U.S. did not reserve or withdraw submerged lands, then the ownership of submerged lands 

is determined on the basis of navigability. If a water body is navigable, the underlying bed of the 

river or lake belongs to the State; if non-navigable, the bed belongs to the adjacent landowner(s). 

The Innoko Refuge contains both navigable and non-navigable waters. However, the status of 

many water bodies has not yet been determined. Any disagreements between the State and 

Federal governments over what waters are navigable or non-navigable are generally resolved 

through the Federal courts. 

Although judicial action through the Quiet Title Act has been the primary means of clearing title 

to submerged lands, recent Bureau of Land Management (BLM) regulation changes regarding 

Recordable Disclaimers of Interest in Lands (RDI) provide an administrative means to clear title 

to submerged lands. The RDI process allows the Secretary of Interior, acting through the BLM, 

to disclaim land interests that have terminated or are invalid. In February 2003, the State filed its 

first disclaimer application for submerged lands beneath the Black River in northeast Alaska. An 

RDI for the Black River was issued later that year. The State has filed numerous subsequent 

applications and cleared title to large areas of lands, but none have been for submerged lands 

within the Innoko Refuge. 

Adjudicating the extent and boundaries of navigable waterways may take many years to resolve. 

In the meantime, the Service is cooperating with the State on a case-by-case basis regarding 

management of major waterways that may be determined navigable. 

3.1.1.7 17(b) Easements 

Section 17(b) of ANCSA requires the Federal government to reserve easements for access to 

public lands or waters whenever land is conveyed to Native corporations. Easements are reserved 

to ensure access to public lands and waters that would otherwise be completely blocked by 

conveyed Native corporation lands. Easements can be linear (i.e., roads and trails), or one-acre 

sites for use as temporary campsites and/or to change modes of transportation. Each 17(b) 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-5 
Chapter 3: Refuge Resources 

easement reserves a right to use land owned by another for a specified purpose. Public activities, 

such as recreation and hunting, are not authorized on the easement or on the private lands 

surrounding the easement or through which the easement passes. The conveyance document 

describes in detail each 17(b) easement and the specific use(s) reserved by that easement. 

Currently, there are two one-acre site easements and one trail easement in the Innoko Refuge 

(Figure 3-1). However, additional 17(b) easements may be created as the Bureau of Land 

Management conveys the remaining land entitlements to Native corporations. Currently, a one-acre 

site easement and two trail easements have been proposed for selected lands in the Innoko Refuge. 

If these lands are conveyed, easements and their allowable uses will be described in the conveyance 

document. Public easements are created at the time they are reserved in the conveyance document. 

3.1.1.8 RS 2477 Rights-of-Way 

The state of Alaska identifies numerous claims to roads, trails, and paths across Federal lands 

under Revised Statute 2477 (RS 2477), a section in the Mining Act of 1866 that states, “The rightof-way for the construction of highways over public lands, not reserved for public uses, is hereby 

granted.” RS 2477 was repealed by the Federal Land Policy and Management Act of 1976, 

subject to valid existing claims. 

Assertion and identification of potential rights-of-way does not establish the validity of these 

claims nor the public’s right to use them. The validity of all RS 2477 rights-of-way will be 

determined on a case-by-case basis, either through the courts or by other legally binding 

document. The state of Alaska has identified in Alaska Statute 19.30.400 twelve routes on the 

Refuge it claims may be asserted as rights-of-way under RS 2477 (Figure 3-1; Table 3-2). 

Table 3-2. Approximate mileage of State of Alaska claimed RS 2477 rights-of way within the Innoko Refuge* 

Reference Number Route Name Mileage 

731 Cripple-North Fork Innoko River 6 

730 Cripple Landing-Rennies Landing 23 

557 Dikeman-First Chance Creek Trail 15 

 63 Dishkaket-Kaltag Trail 41 

556 First Chance Creek Across Glacier-Horsefly Trail 5 

 97 Iditarod-Dishkaket Trail 70 

129 Lewis Landing-Dishkaket Trail 29 

161 Nulato-Dishkaket Trail 41 

164 Ophir-Dishkaket Trail 23 

732 Rennies Landing-Cripple Landing (South) 27 

506 Shageluk-Holikachuk Winter Trail 7 

165 Ophir-Iditarod 5 

*From State of Alaska RS 2477 database (March 23, 2006) 

3.1.1.9 Environmental Contaminants (Including Water Contaminants) 

Innoko Refuge has potential contaminant issues, primarily as a result of the area’s rich and 

diverse mineral deposits and placer mining for gold, which has occurred in many of the major and 

minor drainages that enter the refuge. In a study to document baseline conditions associated with 

proposed development of the Illinois Creek heap-leach gold mine, most measures of water quality 

were found to be within the range typical of surface waters in interior Alaska (Mueller and Matz 

2002). Surface waters on the refuge were relatively uncontaminated by metals. Concentrations of 

metals in sediment were also within the range observed at other interior refuges except for 

3-6 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

elevated levels of arsenic, cadmium, iron, and manganese. The sites with the highest arsenic, zinc, 

and lead levels were the mineralized drainages of the upper Little Mud River and Illinois Creek. 

Concentrations of arsenic in one of 19 Chinook salmon fry samples and all 5 coho salmon fry 

samples in the 1990s baseline study were greater than the 85th percentile range of the National 

Contaminants Biomonitoring Program (NCBP). Boron was detected in 17 of 19 Chinook salmon 

fry in concentrations up to 10.0 milligrams per kilograms (mg/kg) but not in coho salmon fry or 

Arctic grayling, and in only 5 northern pike muscle samples at the level of detection (LOD) of 1.0 

mg/kg. Salmonids are very sensitive to selenium contamination and Chinook salmon fry from 

California Creek had up to 1.5 mg/kg and silver salmon from Illinois Creek had up to 1.3 mg/kg 

selenium (Mueller and Matz 2002). 

All northern pike muscle samples but one from 1996 exceeded the greatest geometric mean of 

NCBP for mercury, and all but three exceeded the 85th percentile maximum value. Mercury 

concentrations in northern pike kidney were similar to those at Kanuti and Selawik refuges but 

less than those at the Nowitna Refuge (Mueller and Matz 2002). 

Mine production on Illinois Creek, a tributary of the Little Mud River, began in early 1997. The 

mine is located approximately five miles north of the refuge boundary. Production was limited in 

1997 and 1998, and the operating company filed for bankruptcy in the second year of operation. 

The bond to reclaim the mine was insufficient, so the State of Alaska initiated a plan of mining the 

deposit to produce additional revenue to fully fund reclamation and closure. American 

Reclamation Group, LLC (ARG), conducted small scale mining during reclamation through 2002, 

while gold recovery from the heap continued into 2003. The State declared the site fully closed and 

reclaimed in November 2005. Illinois Creek was permitted as a “zero discharge” facility; however, 

interruption of mining and processing activities during bankruptcy proceedings, incorrect water 

balance modeling, and mechanical failures led to oversaturation of the mine’s heap, creating a risk 

of overflowing. In 2000, to deal with the situation, ARG received permission to treat the overflow 

(cyanide destruct by mixing with hydrogen peroxide) and apply the overflow in a spraying 

program onto the land adjacent to the central pit. Tests of Illinois Creek water indicated that the 

treatment prior to land application removed over 98 percent of cyanide indicators; however, 

contaminants such as copper, arsenic, and ammonia remained in solution. ARG and the 

Department of Revenue have committed money that will be used for 30 years of environmental 

monitoring at the site. Monitoring of refuge water resources in this region should continue, and 

the results should be compared to baselines established by Mueller and Matz (2002). 

Refuge staff is involved in a clean-up project at Rennies Landing on the upper Innoko River. 

Rennies Landing was constructed in the mid-1930s for the transportation of mining equipment and 

supplies to Cripple Landing and then on to other mining camps in the Innoko region. It was active 

until the 1950s, and approximately 100 55-gallon fuel drums now litter the site. Most are empty and 

the refuge began to remove and properly dispose of all waste material during the 2007 field season. 

The site is not currently believed to be a point source for environmental contaminants. 

3.1.2 Ecosystems 

The 1997 National Wildlife Refuge System Improvement Act mandated an ecosystem approach to 

land management and required refuge lands be managed in the context of, and in concert with, 

surrounding public and private lands. The ecosystem approach to conservation and management 

acknowledges that the living organisms, physical surroundings, and natural cycles that sustain 

them are all interconnected. Refuges in Alaska encompass mostly intact ecosystems, and the 

challenge is to maintain these natural systems through protection and monitoring. From this 

prospective, the ecosystem level is an appropriate level for refuge planning. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-7 
Chapter 3: Refuge Resources 

There have been numerous attempts to classify ecosystems and ecoregions in Alaska (e.g., Joint 

Federal-State Land Use Planning Commission for Alaska 1973, Bailey 1980, Omernick 1987, Gallant 

et al. 1996, Nowacki and Brock 1995). The existing U.S. Fish and Wildlife Service ecosystem map 

defines 10 ecosystems in Alaska (USFWS 1996). The source for this map was the U. S. Geological 

Survey's Hydrologic Unit Map based upon the delineation of watersheds. The Service then grouped 

these watersheds based on vegetation cover types, physiography, and optimum size. Innoko Refuge 

is located on the western edge of the Service’s Interior Alaska Ecosystem. 

The Interior Alaska Ecosystem is defined as the intermontane plateau bounded by the Alaska 

Range on the south and east and the Brooks Range on the north, and encompasses approximately 

528,000 square miles (Van Cleve et al. 1983). This vast region is characterized by small, isolated 

mountain ranges; large areas of gently sloping uplands; meandering rivers with broad flood 

plains; and extensive, flat lowland plains dotted with numerous thaw lakes. Discontinuous 

permafrost underlies as much as 75–90 percent of the terrain. Black spruce forest is the dominant 

vegetation type below treeline and covers 44 percent of the area. Above treeline, subalpine shrubs, 

tundra sedge meadows, and heaths predominate. The major river systems draining interior 

Alaska are the Yukon River and its largest tributary, the Tanana River. 

Other refuges and Federal lands included in this ecosystem are: Tetlin, Yukon Flats, Kanuti, Koyukuk, and 

Nowitna National Wildlife Refuges; Denali National Park and Preserve; Yukon-Charley Rivers National 

Preserve; the Steese National Conservation Area; and the White Mountains National Recreation Area. 

Reviewing the various depictions of ecoregion boundaries for Innoko Refuge and the surrounding area 

shows all maps to be similar. The biggest differences are the naming systems used and the dividing lines 

between the lower areas associated with the Yukon and Innoko rivers and the more mountainous areas. 

Given the numerous attempts to classify ecosystems and ecoregions in Alaska, Nowacki et al. 

(2001) attempted to unify ecoregion boundaries to aid Alaskan users and facilitate interagency 

work. The final product, “Ecoregions of Alaska and Neighboring Territories Map,” delineates 32 

ecoregions in Alaska. Under this classification system, Innoko Refuge falls within two ecoregions: 

the Yukon River Lowlands and the Kuskokwim Mountains (Figure 3-2). 

The majority of the refuge is within the Yukon River Lowlands ecoregion, an expansive wetland 

system associated with the lower stretches of the Yukon River in west central Alaska. This region 

is characterized by floodplains lined by deep deposits of undifferentiated sediments; a seasonally 

moist continental climate with cool, moist summers and cold, dry winters; and discontinuous 

permafrost, which leads to poor drainage and a prevalence of wet, organic rich soils and a dense 

concentration of lakes and ponds. The vegetation along the major rivers is dominated by white 

spruce and balsam poplar, while floodplains and river bars support tall stands of alders and 

willows. Wet sedge meadows are common around sloughs and oxbow ponds, and the adjacent 

permafrost dominated lowlands are characterized by black spruce woodlands, and birchericaceous shrub and sedge tussock bogs. 

A small portion of the southern edge and northeast corner of Innoko Refuge falls into the 

Kuskokwim Mountain ecoregion. These low rolling mountains are underlain with thin to 

moderately thick permafrost. Boreal forests dominate grading from white spruce, white birch, and 

trembling aspen on uplands to black spruce and larch in lowlands. 

3-8 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Figure 3-2. Ecoregions 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources

3-10 
Chapter 3: Refuge Resources 

3.2 Physical Environment 

3.2.1 Climate 

Innoko Refuge has a continental subarctic climate characterized by low annual precipitation, low 

humidity, low cloudiness, and large diurnal and annual temperature ranges. The summer sun 

provides almost continuous radiation and heats valleys that are protected from coastal winds and 

clouds by surrounding hills. On June 21, the area gets more than 20 hours of daylight. On 

December 21, the sun stays above the horizon for less than four hours. The valleys become cold 

sinks, and temperatures are among the coldest on the continent. Incomplete but recent climate 

data are available from the automated weather observation station located at the Anvik airport 

(Table 3-3). Based on these data, December and January are the coldest months, while June, July, 

and August are the warmest months. Average annual precipitation data were not available.

Table 3-3. Climate data from the Anvik Airport automated weather observation station for November 1993 through 

November 2007* 

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec 

Average Max. 

Temperature (F) 

7 17 21 37 53 64 65 60 51 34 19 9 

Average Daily 

Temperature (F) 

2 11 13 30 44 55 57 52 44 29 14 4 

Average Min. 

Temperature (F) 

-3 6 7 23 37 47 50 46 39 25 10 -1 

*NOAA web site http://cdo.ncdc.noaa.gov 

 

Freeze-up on the Yukon River at Holy Cross usually occurs in late October to early November with 

breakup in early to mid-May. Ice is present in the lakes and many sloughs from early October to 

late May. The frost-free period for this area is approximately 105 days (Selkregg 1976). 

Working in conjunction with the U.S. Department of Agriculture Natural Resources Conservation 

Service (NRCS), nine snow depth measuring stations were installed on Innoko Refuge in 1996 

(Figure 3-3). These nine stations provide both an east-west and north-south gradient of snow 

depth across the refuge. 

Snow depths are recorded from aerial overflights in the first week of December, February, 

March, April, and May. Each winter, average snow depths across the refuge vary little for the 

months of February–April (February average depth is 28.0 inches, March average depth is 31.9 

inches, April average depth is 30.6 inches). (See Figure 3-4.) On average, the central and northern 

sections of the refuge receive more snow in the February–April period than the southern section, 

32.6 inches, 31.8 inches, and 27.4 inches, respectively. Conversely, the western portion of the 

refuge along the Yukon River has deeper snow during February–April than the central or eastern 

sections, 34.4 inches, 28.8 inches, and 29.9 inches, respectively. 

3.2.2 Landforms 

Innoko Refuge is primarily a large lowland area between the Yukon River to the west and the 

Kuskokwim Mountains to the south and east. The Kuskokwim Mountains rise to 4,000 feet above 

sea level with broad gentle slopes. The Kaiyuh Mountains are located on the refuge just east of 

the Yukon River and run parallel to it. Most of the highest peaks on the refuge are between 1,000 

and 1,330 feet. These peaks are generally located 10 to 15 miles east of Blackburn Island, with 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-11 
Chapter 3: Refuge Resources 

Figure 3-3. Locations of snow poles on Innoko Refuge 

3-12 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-13 

0

5

10

15

20

25

30

35

40

Dec Feb Mar Apr May

1 2 3 4 5 6 7 8 9

Snow Depth (inches)

another small group approximately 5 miles north of Holikachuk. The highest peak on the refuge 

is 1,461 feet and is an extension of the Kuskokwim Mountains, which project a few miles into the 

refuge northeast of Shageluk. 

Between the two mountain ranges lie the Innoko River and the Innoko lowlands. The river 

meanders diagonally across the refuge from northeast to southwest. The Innoko lowlands extend 

the entire length of the main trunk of the river. Tributaries of the Innoko River drain the east side 

of the Kaiyuh Mountains and the west side of the Kuskokwim Mountains. The Innoko lowland 

area is over 30 miles wide along the central reaches of the Innoko River and narrows somewhat in 

the upper and lower reaches. The lowland is broadly developed on the lower Iditarod River and 

extends far up the other Innoko River tributaries. Lakes in the area are upland basins, ice formed 

lowland, river flooded lowland, and oxbow types. 

Figure 3-4. Average snow depth recorded on Innoko Refuge, 1996–2006 (see Figure 3-3 for locations of snow poles) 

3.2.3 Geology 

Innoko Refuge is located within the Yukon-Koyukuk province, a “basin” of volcanic origin. Being a 

depression, the province is called a basin. It does not contain sediments normally associated with 

basins, as the lows were apparently filled with materials of igneous origins. Within the basin, uplands 

are included with lowlands due to differential uplift associated with rise of the Alaska Range. 

Perimeters of the basin are metamorphosed continental rock. The Brooks Range to the north, the 

Ruby Uplift (including the Kaiyuh Mountains, the Kokrines Hills, and the Hodzana Highlands) on the 

east, and the base of the Seward Peninsula to the west delineate the basin. Farther south, the 

perimeter of the basin is unknown, probably buried under the Yukon-Kuskokwim Delta. 

The Yukon-Koyukuk Basin is generally a mass of andesitic volcanics which overlies mafic (basalt and 

gabbro) and ultramafic (gabbro and olivine) rock. Locally thick volcanoclastic sediments overlay the 

volcanics. Outcroppings in the basin are mafic and ultramafic rocks, mixed with metamorphic rocks 

because of thrusting, and intruded in places by granite along the north and east basin perimeters. 
Chapter 3: Refuge Resources 

In terms of plate tectonics, the Yukon-Koyukuk Basin is believed to be a drifted piece of oceanic 

crust that collided with the continental crust of the southern Brooks Range and the Ruby Uplift. 

On collision, the oceanic crust overrode the continental material. Thus, the continental Brooks 

Range and Ruby Uplift borderlands were the leading edge of a subduction zone, while oceanic 

crust was thrust up, over, and through the borderlands. Further thrusting occurred inside the 

drifted terrane, bringing volcanic rocks over ocean crust. The result is a basin rim of overlapping 

stacks: andesite volcanic over mafic/ultramafic over metamorphic rocks. 

During upthrusting of the mafic rocks into the metamorphic borderlands, new greywacke occurred. 

With this greywacke, andesites of the drifted plate floor were raised in a broad arch, leaving two 

successor basins at about sea level. The easternmost basin parallels the present Yukon and lower 

Kuskokwim rivers. Sediments from the borderlands were deposited in both shallow marine and 

continental environments, forming primarily micaceous shale and silt, sandstone, and coal. 

Northeast folds in the basin sediments resulted from late Cretaceous deformation. Troughs, 

developed along the north and northeast fringes of the Yukon-Koyukuk Basin, were quickly filled 

with conglomerate. The Yukon-Koyukuk province, like all interior Alaska, has remained emergent 

since the Cretaceous period. Tertiary sediments formed only locally. 

According to Beikman (1974) (Figure 3-5), the oldest geologic materials on the refuge are lower 

Paleozoic rocks, including limestone, dolomite, argillite, greywacke, quartzite, and slate, which 

occur in a wide band from north to south, covering most of the eastern part of the refuge. Basalts 

occur in the north central part of the refuge, while volcanic greywacke, mudstone, and sandstone 

are located in the western part of the refuge from the northern border to south of Blackburn 

Island. South of this formation, along the Yukon River, is a band of Pleistocene deposits, the 

youngest rocks on the refuge. These are primarily alluvial, glacial, dune sand, loess, and reworked 

sand and silt deposits. To the east of these are a group of felsic volcanic rocks. Smaller groups of 

basalt and volcanic greywacke, mudstone, and sandstone are found in the central southern portion 

of the refuge. 

3.2.4 Soils and Permafrost 

In an extensive reconnaissance survey, Reiger et al. (1979) mapped the soils of Alaska, including 

the Innoko Refuge, at a scale of 1:1,000,000 ( Figure 3-6). 

The soils of the Innoko Refuge are relatively uniform with poorly drained, peaty silt to silt loams 

dominating. The soil surface tends to be hummocky with a thick accumulation of peaty material (8 

to 16 inches). These soils occur on low terraces in broad valleys, long foot slopes, flood plains, and 

rolling uplands. Recent field studies by Innoko Refuge staff found organic soils ranging from 2 to 

33 inches in depth. 

Permafrost is ground that is continuously frozen through at least two successive cold seasons and the 

intervening summer. Permafrost is found throughout the area, except along major drainages, and is 

usually shallow (from 10 to 25 inches). Brown and Fleener (2001) found that the area of Innoko 

Refuge is primarily in a region of discontinuous permafrost (50–90 percent) containing medium 

amounts of ground ice (10–20 percent of the upper 66 feet of soil) with a thick overburden layer (more 

than 15 feet). A small portion of Innoko Refuge is underlain by continuous permafrost with medium 

amounts of ground ice and thick overburden (Figure 3-7). In interior Alaska, temperatures of the 

upper layers of the permafrost are in the range of 28–31 degrees Fahrenheit. 

3-14 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

3.2.5 Oil and Gas Occurrences and Potential 

As described in section 3.2.3, Innoko Refuge lies within the Yukon-Koyukuk geologic province. This 

province was classed as a possible petroleum province by Miller et al. (1959). However, subsequent 

studies indicate that the sedimentary rock types present in the province are generally unfavorable for 

deposits of oil and gas, having been involved in severe compression and dislocation (Patton 1973). The 

earliest sedimentary rocks, probably marine shelf deposited, now form metamorphic borderland 

buttresses. Subsequent marine sediments, possibly 15,000 to 25,000 feet deep in places, appear to be 

poured-in volcanics and contain easily alterable tuffs. Little chance for sand development exists with 

these sediments. Some submarine fans, which can be favorable for oil and gas accumulation, may exist 

in these sediments. However, much of these sediments are metamorphosed and highly deformed, 

making the potential for petroleum very low. Other sediments, though only gently deformed, are 

limited in extent and are in near-surface positions, which also indicate low potential. 

3.2.6 Minerals 

Innoko Refuge lacks large scale geologic mapping, and its mineral resources potential remains 

largely unknown. However, rocks within the refuge are permissive for the presence of several 

deposit types, including vein and disseminated gold, base metal, and chromite. Sites of known or 

indicated mineralization, locations of favorable terranes, and produced placers in the vicinity of 

Innoko Refuge are identified in Figure 3-8. Most sites are outside refuge boundaries. Many are 

on State-owned lands that are open to mineral leasing. The State has identified some lands east of 

the refuge as having high to very high mineral potential (Alaska Department of Natural 

Resources 1986). These areas are reflected by concentrations of mining claims and activities near 

Tolstoi and Cripple Landing, and along the Innoko, Dishna, and Iditarod rivers (Figure 3-8). No 

valid claims exist on the refuge, and refuge land is not open to new mining activities. Mining 

operations are legally required to adhere to State and Federal water quality standards. 

The Innoko mining district (Figure 3-9) is the oldest in the Ruby-Kuskokwim region. Beginning in 

the late 1880s, prospectors worked the Innoko River in search of gold. However, it was not until 

September of 1906, when the Tom Ganes’ party found rich color while panning on the Innoko 

River bars just below the mouth of Ganes Creek, that prospecting efforts were successful. The 

party later found a rich placer gold deposit a few miles up Ganes Creek. 

During the summer of 1907, a Gold Rush brought hundreds of prospectors and merchants to the 

upper Innoko area. In February 1908, rich placer deposits were located on nearby Ophir Creek. 

More discoveries followed on adjacent streams such as Spruce, Little, Yankee, Anvil, and Ester 

creeks, and at Victor Gulch. 

A second mining area, the Iditarod district (Figure 3-9), dates to the December 25, 1908, discovery of 

gold on Otter Creek by William Dikeman and John Beaton. The resulting rush to this area in the 

summers of 1909 and 1910 brought hundreds more prospectors who made discoveries on surrounding 

streams. By 1912, claims were established on Otter, Flat, Happy, Willow, Black, Moore, and Chicken 

creeks and at Glen Gulch. At that time, 29 claims were being worked by 36 plants, including 1 dredge, 

22 steam machinery plants, and 13 plants using hand methods. In 1933, three dredges, one scraper 

plant, seven hydraulic plants, and seven hand method operations were at work in the area. 

A typical hydraulic plant consisted of a single giant water cannon with a two-inch nozzle, and 

water was delivered to the pumping unit in a mile-long ditch with a 30–35 foot head. The 

overburden removed by the water jet was from 30–35 feet deep. The top 20–30 feet was muck 

with large masses and wedges of ice, with the lower 5–6 feet being gravel. The gold was mostly 

found in “pay dirt” located at the bedrock alluvial interface. The dredges, operated in a pond 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-15 
Chapter 3: Refuge Resources 

within the streambed area, were bucket type with 34 buckets, each capable of removing 2.5 cubic 

feet of material, and operated at the rate of 15 buckets per minute. The gold was recovered with 

sluicing equipment supplied with water from a 12-inch pump. 

Chromite deposits near Innoko Refuge are located in the Kaiyuh Hills 36 miles south of Galena—

between the Yuki River and East Fork of the Yuki River—and at Mt. Hurst south of Tolstoi. Refuge 

drainages that may be affected by mining operations include the Innoko, Iditarod, Dishna, Tolstoi and 

Little Mud rivers. The amount of impact would depend on the extent of mining and transportation in 

and out of the mining area. The Kaiyuh deposits are under the jurisdiction of the State of Alaska and 

open to mineral entry. The area has an estimated 17,000 to 37,000 tons of chromite in four podiform 

type deposits. One of the deposits is a three-foot band of nearly massive chromite (2,000 to 5,000 tons) 

(Foley et al. 1984). The other deposits contain 3–5 percent chromite and would require on-site 

benefication to concentrate the chromite. Chromium is a silvery white metal with a bluish tinge. It has 

a very high melting point and is used as a plating for iron and brass and as an alloy in steel production. 

Chromite deposits in the area are considered to have low economic potential (Roberts 1984). 

The DeCourcy Mountain Mine (Figure 3-8, Table 3-4), located on a tributary of the Iditarod River 

some 30 miles south and west of Flat, produced over 1,200 flasks of mercury, and it is the only 

significant Alaskan mercury mine outside the Kuskokwim River Basin. Mercury was recovered 

from lenses, veins, and stockworks of cinnabar with minor stibnite in a zone up to 2,000 feet long, 

250 feet wide and 360 feet deep, consisting of altered basalt that intrudes graywacke and shale. 

Mining districts incorporating the refuge include the Iditarod, Innoko, and Kaiyuh (Alaska 

Department of Natural Resources 2006; Figure 3-9). It is estimated that close to 2,000,000 troy 

ounces of gold and 250,000 troy ounces of silver were produced from 1914 through 1972 in the 

Innoko and Iditarod districts (Bundtzen et al. 1987). Although mining continues, more recent 

production data are incomplete since no mint data are available after 1972, when gold was 

decontrolled by Federal legislation. Table 3-4 provides dates of past production from these 

districts and additional lands north and south of Innoko Refuge. 

Rocks of the Kaltag formation bearing thin irregular seams of lignite (generally less than two feet 

thick) are found along the Yukon River bluffs bordering the refuge. The coal is bituminous to 

subbituminous, friable, and slacks rapidly when exposed to air and drying (Chapman 1963). Two 

coal mines located on the west bank of the Yukon River have been active in the past. Coal mine 

No. 1 (Figure 3-8, Table 3-5) was located about 16 miles upriver from the abandoned settlement of 

Blackburn. The mine was opened in 1898 and closed later that year because of flooding problems. 

Approximately 900 tons of coal was produced in that time. The bed is 2–3 feet thick. The Williams 

Mine was on the west bank of the Yukon River about six miles north of Bullfrog Island. The 39-

inch bed of bituminous coal reportedly produced 1,700 tons of coal before closing in 1902. 

Evidence of the mine has been obscured by slides. Neither of these mines was located on the 

refuge, and the coal resources of the refuge have not been thoroughly examined, but some coal 

beds are likely to occur on the refuge along the Yukon River. Chapman (1963) noted that the thin, 

highly fractured, and steeply dipping coal beds are not likely to be of value for other than smallscale local use. 

3.2.7 Water Resources 

The waters within Innoko Refuge form a complex of streams, oxbow and thaw lakes, sloughs, 

bogs, wet meadows, and wetlands that create the habitat for which the refuge was established. 

Though the Yukon River forms the western boundary of the refuge, it is the Innoko River and its 

tributaries whose continual flooding and deposition of nutrients has created the landscape of 

wetlands, lakes, ponds, and bogs. The Innoko River and its tributaries tend to be slow-moving and 

3-16 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Figure 3-5. Generalized surface geology 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources

3-18 
Figure 3-6. Soil associations on Innoko Refuge 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources

3-20 
Figure 3-7. Distribution of permafrost on Innoko Refuge 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources

3-22 
Chapter 3: Refuge Resources 

Figure 3-8. Mineral occurrences 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-23 
Chapter 3: Refuge Resources 

Table 3-4. Historical and present mineral production 1898–2004. Map numbers refer to number found in Figure 3-8. Source: U.S. 

Geological Survey Alaska Resource Data Files (Dashevsky 2002a, Dashevsky 2002b, Dashevsky 2002c, Bundtzen 2004) 

Map 

Number Location Commoditya

 Years of Reported 

Activity 

Number of 

Claims 

Currently Active 

Claims 

1 Colorado Creek Au, Ag, Sb 1913–present 9 2 

2 Folger Creek Au 1914–1950 2 0 

3 Tolstoi Creek Au, Cr, Pt 1915–present 10 4 

4 Granite Mt. Ag, Cu, As, Sb, Sn, 

Pb, Bi, Zn 

1984–1986 7 0 

5 Ophir Au, Ag 1907–present 14 4 

6 Ganes Creek Au, Ag, Sb 1906–present 12 2 

7 Yankee Creek Ag, Au, Cr, Sb 1909–present 8 4 

8 Dishna River Au, Hg, Sb, As, 

Mo, Mn, Pb 

Pre-WWII–1986 15 0 

9 Beaver Mountains Au, Hg, Sb, Ag, 

Cu, As, Pb, Zn, Fe

1979–1992 15 0 

10 Upper Yetna River Au, Ag, Pb, Nb, 

Sn 

1984–1985 6 0 

11 Upper Iditarod River Au, Ag, Cr, Ni, Bi, 

Sn, Sb, As, Cu 

1984–1986 10 0 

12 Bonanza Creek Hg, Ag, Cu, Au, 

As, Sb, Zn, 

1983–1986 13 0 

13 Willow Ag, Au 1910–present 9 4 

14 Flat Au, Hg, Ag, Sb, 

W, Pb 

1908–present 13 4 

15 DeCourcy Mountain Ag, Cu, Zn, As, 

Au, Hg, Sb, 

1910–1985 9 0 

16 Kaiyuh Mountains Cu, Mo, W, Pb, 

Zn, 

1980–1984 5 0 

17 West Fork Little Mud 

River 

Pb, Zn, Ag 1980–present 3 1 

18 Little Mud River Au, Ag, Pb, Zn 1909–1980 4 0 

19 Illinois Creek Ag, Au, Zn 1980–2005 2 0 

20 Yukon River Ag, Au 1999–present 1 1 

21 Donlin Creek Hg, Au, Cu 1910–present 9 3 

22 Halls Rapids coal 1900 prospect 0 

23 Blackburn Mine coal prospect 0 

24 Coal Mine No. 1 coal 1898 1 0 

25 Williams Mine coal 1900,1902 2 0 

26 Innoko River coal 1900 prospect 0 

27 Innoko River coal prospect 0 a

Ag – silver; As – arsenic; Au – gold; Bi – bismuth; Cr – chromium; Cu – copper; Fe – iron; Hg – mercury; Mn – 

manganese; Mo – molybdenum; Nb – niobium; Ni – nickel; Pb – lead; Pt – platinum; Sb – antimony; Sn – tin; W – 

tungsten; Zn – zinc. 

3-24 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Figure 3-9. Placer & mining districts 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources

3-26 
Chapter 3: Refuge Resources 

moderately silty with constantly meandering courses. Many of the bogs (known as muskeg) 

support thick floating mats of vegetation that give the appearance of solid ground (USFWS 1987). 

There are 22,881 lakes on the refuge, 95 percent of which are less than 10 acres in size (Table 3-5). 

The Yukon River, where it forms the western boundary of the refuge, is characterized by many 

relatively large islands and numerous sloughs. Not including the shoreline of the Yukon River, 

there are 7,101 miles of rivers, creeks, and sloughs on the refuge. 

Table 3-5. Size (in acres) of lakes found on the Innoko Refuge 

Size Range Number 

<1.0 13,495 

 1.0–4.9 7,178 

 5.0–9.9 1,105 

10.0–24.9 626 

25.0–49.9 224 

50.0–99.9 122 

≥100 131 

The Innoko River originates in the southern portion of the Cloudy Mountains and flows northeast 

and southwest some 463 miles to the Yukon River just east of Holy Cross, draining over 14,000 

square miles en route. Table 3-6 identifies the major water bodies within the refuge, including the 

tributaries of the Innoko River. 

The description of the river system that follows has been synthesized from a report of studies 

conducted in the area and prepared by Alt (1983). The portion of the Innoko River from the 

confluence with the Yukon River to Holikachuk is characterized by many meandering loops, 

several oxbow lakes, drawdown lakes, and thaw lakes, many of which are river-connected. Water 

from the Yukon River flows into the Innoko River above Shageluk and at Holikachuk via the 

Shageluk/Holikachuk Slough system located some 90 miles above the confluence with the Yukon 

River. Both sloughs carry silty water of the Yukon River through the lower portion of the Innoko 

River. The Innoko River in this lower portion is 650–1000 feet wide and 20–50 feet deep. The 

river’s cut side has high mud banks. The riparian vegetation consists of willow, birch, alder, 

cottonwood, and spruce. Water current is between one and two miles per hour. 

The section of the Innoko River from the Holikachuk to the Iditarod River is clearer due to the 

absence of Yukon River water. The channel is less defined and often spreads out across the willow 

areas. Drainage in this section is generally poor with willows being the dominant vegetation. The 

river substrate and banks are mud and silt. This section of the river provides important rearing 

habitat for whitefish, pike, and sheefish. Northern pike also spawn in this section. 

Dishkakat is some 160 miles upstream from the mouth of the Iditarod River. The Innoko River 

along this section is more confined to a shallower and narrower channel. Meanders and a few 

oxbow lakes characterize this section. Drainage is poor, and the landscape is generally flat. 

Willows dominate the vegetation. Tributaries in this section include Hammer, Grouch, and 

Hather creeks and the Mud River. 

From Dishkakat to the North Fork Innoko River (approximately 120 miles), the current increases 

from 1–2 miles per hour to 2–3 mile per hour. The streamside vegetation is riparian forest 

dominated by spruce, alder, willow, and birch. The channel is 200–400 feet wide with mud bars 

and a substrate that gradually transitions to sand, silt, and small gravel. Smaller tributaries in this 

section of the river include Finland, Horseshoe, Taft, and Scandinavian creeks. The Dishna River, 

also found in this section, is a major tributary of the Innoko River. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-27 
Chapter 3: Refuge Resources 

Table 3-6. Major water bodies within Innoko Refuge 

Water body Tributary of: 

Yukon River Bering Sea 

 Innoko River Yukon River 

Shageluk Slough Innoko River 

Holikachuk Slough Innoko River 

Netlenta River Innoko River 

Iditarod River Innoko River 

Yetna River Iditarod River 

Grouch Creek Innoko River 

Hammer Creek Innoko River 

Hather Creek Innoko River 

Magitchile Creek Hather Creek 

Mud River Innoko River 

Little Mud River Mud River 

Galatea Creek Mud River 

Wapoo Creek Innoko River 

Dishna River Innoko River 

Tolstoi Creek Dishna River 

Mastadon Creek Tolstoi Creek 

Taft Creek Innoko River 

Horseshoe Creek Innoko River 

Finland Creek Innoko River 

Scandinavian Creek Innoko River 

Khotol Creek Yukon River 

Papa Willie Creek Yukon River 

Shovel Creek Yukon River 

Sucker Creek Yukon River 

Sixmile Lake n/a 

The U.S. Fish and Wildlife Service operated stream gauges between spring 1997 and fall 2001 on 

the Innoko River, Iditarod River, Dishna River, North Fork Innoko River, Mud River, Yetna 

River, Little Yetna River, Moose Creek, and Tolistoi Creek. Gage data from these locations have 

not been published at this time. Discharge records generated from the stream gaging project will 

be used to characterize the flow regime of the Innoko River and its tributaries. This information 

will be used to support the legal protection of these waters to meet refuge purposes. 

The “water year” begins in October. For the waters of the Innoko Refuge, this is a period of 

decreasing flows and the start of freeze-up. By late October or early November, rivers and lakes 

are ice-covered. As winter progresses, flows decrease and input from surface sources is 

diminished; the remaining flow is primarily from groundwater or springs. By late winter, ice may 

reach six feet in thickness, and many tributaries of the Innoko will freeze all the way to the 

bottom. Overflow is common. The Innoko River and it largest tributaries will be at their lowest 

flow for the year, and water quality conditions are poor (particularly from low concentrations of 

dissolved oxygen) for aquatic organisms under these conditions. 

Breakup generally occurs in May. A combination of snowmelt, ice damming, and large rivers 

backing up smaller rivers creates the natural and often extensive flooding that shapes the 

landscape; recharges the lakes, wetlands, bogs, and ponds; disperses nutrients and seeds; and 

maintains the healthy riparian and flood plain areas. 

3-28 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

During spring flooding, the river systems of interior Alaska are typically high, with additional 

periods of high flow during spring and summer rains. Summer flows are maintained through a 

steady return of water from the spring flooded areas, summer rain, and thawing ground ice above 

permafrost. Intense summer storms and fall rains bring higher flows and local flooding at times. 

Habitat complexity on the landscape is a function of the physical forces that act upon it over time. 

In combination, the fire and water regime—the timing, duration, magnitude, and frequency of 

hydrologic or fire events—are drivers of the Innoko Refuge landscape. The earth appears to be 

experiencing a rapid change in climatic conditions; changes are expected to be more pronounced in 

arctic and subarctic regions. Changes to the physical environment, including changes to air 

temperature, length of growing season, precipitation (snow and rain), permafrost, river ice 

conditions, snow depth, etc., will alter the water regime—that is, the timing, frequency, duration, 

and magnitude of hydrologic events. This, in turn, will alter the landscape and the habitat, and 

thus, the flora and fauna of the refuge. 

3.2.7.1 Water Quality 

The waters of the Innoko River and its tributaries, though silty, are generally thought to be 

natural in condition. Exceptions to the generally natural conditions are associated with past and 

present mining activities on or adjacent to the refuge. These activities often increase turbidity, 

sedimentation, and metals concentrations. Silt particles suspended in water may remain 

suspended for several miles downstream, depending on the size and weight of the particle. Silt 

restricts penetration of sunlight and thus, photosynthesis, which reduces food sources for fish. 

Fish also tend to avoid (if possible) silt laden water, although they tolerate many miles of silty 

water to reach spawning grounds. 

Preliminary samples collected during 1985 and 1986 from the Innoko River and its tributaries 

indicated that turbidity, copper, zinc, and mercury were possibly elevated (Jackson 1990). Based 

on these findings, a monitoring effort was conducted at 14 sites during 1987 and 1988 to determine 

baseline concentrations of metals in water, sediment, and fish muscle from selected drainages on 

the refuge. Jackson (1990) reported relatively high concentrations of chromium (water, sediment, 

tissue), nickel (sediment), zinc (water), and possibly aluminum (water). Sediment and water data 

from mined streams showed no significant differences when compared to controls; however, the 

sample sizes were too small for adequate comparisons. Mercury concentrations in fish muscle 

were elevated at both mine and control sites. Additional monitoring was recommended at two- to 

three-year intervals, particularly if new mining activities occurred. From 1995–1997, Mueller and 

Matz (2002) conducted a study to examine water quality, and metal and metalloid concentrations 

in water, sediment, and fish tissue on and adjacent to the refuge. Water quality characteristics 

(pH, calcium- and magnesium-bicarbonate base) were found to be typical of uncontaminated rivers 

in the region. Surface waters on the refuge were also relatively uncontaminated by metals; most 

metal concentrations were within the ranges of metals measured at Kanuti, Koyukuk, Nowitna, 

and Selawik National Wildlife Refuges. 

Because metals concentrations in water depend on many factors, there is high spatial and 

temporal variability in samples from Innoko Refuge. Periodic assessments of metals 

concentrations are necessary to monitor the effects of mining activities occurring near the refuge. 

3.2.8 Effects of Fire 

Fire is a natural feature of the ecology of the boreal forest throughout its holarctic distribution 

(Viereck 1973, Johnson and Rowe 1975, Andreev 1977, Kelsall et al. 1977, Zackrisson 1977, Van 

Cleve et al. 1991, Payette 1992). Effects of wildfires to plant and animal communities can be 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-29 
Chapter 3: Refuge Resources 

viewed at the local (i.e., site-specific) level or at the landscape level (i.e., refuge-wide or Innoko 

River watershed). The types of effects vary depending on the level examined for plants and 

animals. Measured effects at the local level, be it to a plant or animal community, can be difficult 

to apply at the landscape level (Schmoldt et al. 1999). 

Forman and Godron (1986) described landscapes as spatially heterogeneous, characterized by 

structure (biotic and abiotic components arranged in space, size, shape, number, and kind); 

function (interactions between biotic and abiotic components); and temporal variation (changes in 

structure and function over time). At the landscape level, the most obvious impact by fire is the 

creation and maintenance of a mosaic of different types, sizes, and ages of plant communities—

sometimes referred to as habitat patches. Different habitat patches are created within a single 

wildfire, both large and small, due to variation in the severity, which usually ranges from 

unburned to exposed mineral soil. It is this variation in severity that creates different habitat 

patches. Increased heterogeneity of habitat patches provides animals increased opportunities to 

select from a variety of habitat conditions and successional stages (Lyon et al. 2000). 

As shown in Figure 3-10 (Chapin 2004), the relationship of soil moisture and soil temperature 

greatly influences forest succession and is a significant factor influencing climax boreal forest 

communities. On the wettest and coolest soils, climax forests are characterized by black spruce 

with an herb seral stage in secondary succession. At the opposite end of the spectrum, in the 

driest and warmest soils, climax forests are characterized by aspen, also with an herb seral stage. 

Between these extremes are more complex secondary succession processes with climax 

overstories of white or black spruce, and seral stages of herb communities followed by aspen or 

birch, depending upon soil moisture and temperature. These succession cycles tend to remain 

relatively constant. However, changes in environment, disturbance regime, or post-disturbance 

seed availability can shift a stand to a new successional trajectory (Chapin et al. 2005). 

Figure 3-10. Successional trajectories in interior Alaska along soil temperature and moisture gradients (Chapin 2004) 

Foote (1983) identifies six seral stages of secondary succession in white and black spruce forests 

following fire disturbance: newly burned, moss-herb, tall shrub-sapling, dense tree, hardwood or 

mixed hardwood-spruce, and spruce. Essentially, if forest succession on both white and black 

spruce sites is broken into these six seral stages, there is a potential for 12 different forest 

communities to occur across the landscape at any given time. When combined with other 

landcover types, such as tundra, wetlands and lakes, the potential for a diverse mosaic becomes 

readily apparent. 

3-30 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Fires in the boreal black spruce and white spruce ecosystems are large and frequent due to the dry 

continental climate, the flammable nature of the forest, and the continuity of fuels extending from 

ground level to the forest crown (Heinselman 1981, Viereck 1983). Feathermoss understories 

typical of these ecosystems also form large, horizontally continuous, and well-aerated fuelbeds. 

Most fires in black spruce forests are either severe ground fires or crown fires of sufficient intensity 

to damage or kill both the overstory of spruce and the entire understory vegetation (Duchesne and 

Hawkes 2000). However, these fires do not burn with consistent intensity or severity over these 

large areas; and often a patchwork of unburned, lightly burned, and moderately burned areas is 

created with a very irregular line of burned and unburned vegetation along the fire perimeter 

(Innoko Refuge unpublished data). Spruce fires can smolder deep in the duff and hold over through 

long periods of high relative humidities and moderate rainfall. 

While not as significant in terms of acreage, hardwood and mixed spruce/hardwood forests play an 

important role in terms of wildlife habitat and wildfire behavior. Shading and deciduous leaf litter 

of hardwood and mixed forests combine to create moist, cool conditions and compact litter layers 

with less available fuel than is found in spruce forests. Fire fuels in these hardwood and mixed 

hardwood forests typically do not form a continuous ladder from the ground to the tree crowns, 

usually resulting in surface fires. Because of these characteristics, hardwood stands often serve 

as natural fuel breaks where fires typically smolder in the understory and spread slowly. 

Shrub habitats and sedge tussock-mixed shrub tundra are characterized by light flashy fuels 

whose moisture content responds quickly to modest changes in relative humidity. These fires 

tend to burn quickly and intensely, skipping over and around standing water between the tussocks 

and pockets of sphagnum mosses. Wind contributes to high rates of spread and short- to mediumrange spotting. With a little moisture, these fires go out quickly; they do not hold over for long. 

Moderately intense fires may kill the above-ground plant parts, but seldom burn the belowground parts or kill the plant (Bliss and Wein 1972, Van Wagner 1983, Viereck and Schandelmeier 

1980). In drier conditions, fires in these shrub habitats and tussocks may have high rates of 

spread and intensity, which can easily carry the fire into adjacent spruce forests. 

Many studies of animal community responses to wildfire depict a reorganization of the 

communities as a result of the wildfire (Huff and Smith 2000). Each species within a community is 

likely to respond in differing manners and levels depending on the community prior to the 

wildfire, the extent and severity of the wildfire, and many other factors. Huff and Smith (2000) 

identified five possible animal community response patterns: 

 Increasers predominate – a high proportion of invader and/or exploiter responses, 

representing an upward shift in abundance 

 Decreasers predominate – a high proportion of avoider and/or endurer responses, 

representing a downward shift in abundance 

 Most populations change – an equally high proportion of invader and/or exploiter responses 

with avoider and/or endurer responses, resulting in little overall change in total abundance 

but large shifts in abundance of many individual species 

 Few populations change – a high proportion of resister responses and a low proportion of 

other responses, representing little change in species composition 

 Intermediate change – a high proportion of resister, endurer, and exploiter responses with a 

low proportion of invader and avoider responses 

Wildfire effects on bird communities are largely related to the amount of structural change in the 

habitat patches. Oliver et al. (1998) depicted how three groups of bird species would likely 

respond to a large scale habitat disturbance: those residing in structurally complex habitats, with 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-31 
Chapter 3: Refuge Resources 

understory shrubs and a well developed forest structure; those that preferred edge areas between 

dense and open vegetation; and those residing in more open habitats. As depicted in Figure 3-11, 

as habitat patches age after being burned, the different successional stages of development favor 

some types of birds over others. 

Figure 3-11. Hypothetical patterns of bird species response dependent on 3 distinct structural habitat types to a substantial 

habitat disturbance (Oliver et al. 1998) 

For birds, the season of the wildfire is important. Nest site selection, territory establishment, 

nesting success, molting, and foraging can all be influenced by the timing of wildfires. Quality of 

the habitat patch prior to the wildfire is also important. Most raptors tend to respond favorably to 

burned areas, as reduced cover enhances hunting efficiency. Wildfires that create habitat patches 

with numerous standing dead trunks and limbs tend to provide favorable sites for insects, thereby 

favoring insect consuming birds and primary cavity nesting birds. All ground nesting birds tend 

to be more affected by wildfires. Canopy nesting birds tend not to be as affected by understory 

consuming wildfires as they are by stand-replacing wildfires. Smucker et al. (2005) found that 

almost twice as many bird species increased as decreased in response to a wildfire in Montana. 

They found different species responding differently to differing levels of severity and changes in 

abundance between the first and second year following the wildfire. 

Moose in North America tend to respond favorably to wildfire effects. Wildfires in the boreal 

forest set back habitat succession to earlier seral stages, which tend to be preferred by moose 

(Peek 1997). Early succession areas with preferred forage species tend to produce the highest 

amounts of forage compared to later successional habitats (Collins and Helm 1997). These early 

succession areas enable moose populations to grow. Many studies have shown that moose use 

burned areas of different ages at different times throughout the year. Maier et al. (2005) found 

that in early winter, moose in the central portion of interior Alaska preferred areas that had been 

burned 11–30 years prior to different census efforts. 

While there is little dispute that wildfires are beneficial to moose and their habitat, the literature 

contains many papers arguing the effects of wildfire on barren ground caribou and their habitat 

(see reviews by Klein 1982 and Rupp et al. 2006). The primary source of concern is wildfire’s 

effects on lichen, a preferred and important component of the winter diet of caribou. Wildfire is a 

natural part of the boreal forest ecosystem, and caribou have been present in the boreal forest 

since recorded time. While moose can be considered as adapted to surviving in a fire ecosystem 

3-32 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

due to their preference for early serial habitat types, caribou are more correctly considered to be 

fire influenced due to their use of foliose and fruticose lichens (Klein 1982). 

Both foliose and fruticose lichens are associated with tundra and open spruce habitats that are 

established well after disturbance by wildfire. Various studies have listed the development of 

these lichens at 30 to 100 years following loss from wildfires (Palmer 1942, Skuncke 1969, Scotter 

1971, Viereck 1973, Pegau 1975). Miller (2000) found caribou feeding on lichen stands aged 35–166 

years in northwestern Manitoba and 46–148 years in north central Saskatchewan. In south 

central Alaska, Joly et al. (2002) found that caribou used lichen stands less than 80 years old 

compared to older lichen stands. Both Skoog (1968) and Joly et al. (2003) found that burns less 

than 10 years old were not used by wintering caribou. In northern Canada, Scotter (1967) found 

that wintering caribou made greatest use of forests more than 50 years following a wildfire. 

Klein (1982) made the argument that wildfire had both short-term effects (less than 70 years) and 

long-term effects (greater than 70 years) on caribou habitat. Several researchers have made the 

argument that over the long term, wildfires are actually necessary to maintain caribou habitat and 

that the long-term benefits actually outweigh the short-term negative effects. Klein (1982) 

believed that the short-term effects from wildfires were likely manifested by the yearly variations 

of seasonal use areas by caribou. 

While there does not appear to be a clear cause-and-effect relationship between the occurrence of 

wildfire and caribou population declines, the apparent correlation between the occurrence of wildfire 

and changes in caribou numbers or distribution suggests that wildfire may have other direct or 

indirect effects (other than destruction of lichen communities). Additionally, most previous work on 

caribou-fire relationships has been carried out on large herds that travel over large areas. The 

effect of large fires affecting large proportions of available winter habitat for small caribou herds 

with a limited use area has not been examined. Additionally, changes in the frequency and intensity 

of wildfires are expected to increase, which will likely further affect caribou habitat, most notably in 

the form of fewer but larger patches of lichen habitat (Rupp et al. 2006). 

Local residents have expressed concern over wildfires pushing moose and caribou away from 

traditional use areas. During the 1996 Millers Reach Fire in the Susitna Valley, several radio 

collared moose were observed to only have a temporary displacement by the fire (H. Griese, 

ADF&G Area Biologist, personal communication, 1997). Refuge staff has collected a large 

number of opportunistic observations while wildfires were active; these observations strongly 

suggest that fires do not have anything more than a temporary (i.e., 1–2 days) effect on where 

moose or caribou are located. In many cases, both moose and caribou have been observed actively 

foraging on the vegetation that re-sprouts immediately following a fire. 

Large carnivores typically have large home ranges and are little affected by even large wildfires 

(Lyon et al. 2000). Ballard et al. (2000) found that wolf use of a large burned area changed little 

over the three years following the fire compared to before the fire in northwest Alaska. Johnson 

et al. (1995) found lynx to be most abundant in a burned area 25–28 years old compared to a 

burned area 6–8 years old and an unburned area. Johnson et al. (1995) found marten to be more 

abundant in the unburned area and least abundant in the burned area 25–28 years old. They 

found the marten population had a higher average age in the unburned area compared to the 

burned area 6–8 years old, however. 

Little work has been done looking at the direct or indirect effects of wildfire on beaver. Beaver 

have been found to invade areas where wildfire has resulted in enhanced growth of willow, paper 

birch, and aspen (Kellyhouse 1979, Ream 1981). Prachar et al. (1988) found more beaver colonies 

in burned areas than in unburned areas in New York. Hood and Bayley (2003), working in a 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-33 
Chapter 3: Refuge Resources 

transition area between forests and prairie in Alberta, Canada, found that frequent fires designed 

to re-establish a prairie ecosystem negatively affected lodge occupancy rates. 

Small mammals (shrews, lemmings, voles, squirrels, and snowshoe hares) tend to be killed or 

displaced by large intense wildfires (Ream 1981) but return very quickly. Johnson et al. (1995) 

found numerous red-backed voles in both unburned and burned areas 25–28 years old, whereas 

yellow-cheeked voles were most numerous in a burned area 6–8 years old. On Kanuti Refuge, redbacked voles and shrews were captured in the summer following a wildfire; yellow-cheeked voles 

were not captured until the sixth year following the fire. By the following year, yellow-cheeked 

voles were more numerous than the smaller red-backed voles (L. Saperstein, Kanuti Refuge, 

personal communication, May 2007). Johnson et al. (1995) found snowshoe hares to be most 

abundant in a burned area 26–28 years old compared to an unburned area and a burned area 6-8 

years old due to its greater abundance of cover and preferred forage. Fox (1978) presented an 

argument that succession resulting from wildfires had a larger influence on snowshoe hare 

population cycles in Canada than predation from lynx. 

Effects of wildfires, particularly larger fires, to fish can be both direct and indirect. Rieman and 

Clayton (1997) provide a very good overview of wildfire effects to fish. They point out that direct 

effects to fish can include mortality, displacement, increased water temperature, and altered 

water chemistry. Indirect effects can include increased suspended sediments, increased organic 

litter inflow, altered nutrient cycles, increased woody debris, and increased algal growth. Smaller 

streams tend to be more affected than larger streams and rivers; effects are also more 

pronounced in headwater streams (Minshall et al. 1989). While the effects from wildfires may be 

evident for extended time periods, these effects may not be catastrophic in nature. 

Effects to aquatic invertebrates vary with the degree of sedimentation and changes in streamflow 

rates. Increases in fine sediments, as well as increases in stream flow rates that affect the stream 

bed, can cause reductions in numbers of invertebrates (Minshall et al. 1989). Minshall et al. (2001) 

found that the extent of the watershed actually burned had a large influence on the amount of 

changes to the invertebrate community. Charette and Prepas (2003) found similar relationships 

between water depth and changes in phytoplankton. The larger the burned area and the 

shallower the water body, the greater the effects. 

While a wide variety of changes in stream temperatures—in some cases, extreme increases—have 

been reported in the literature, stream temperatures typically increase 4–18 degrees Fahrenheit 

due to decreased shading from loss of stream-side vegetation (Amaranthus et al. 1989, Minshall et 

al. 1989). Loss of vegetation from wildfires directly relates to increased sediment concentrations, 

which are most pronounced during the first few months following a wildfire. 

Studies have reported changes in nitrogen and phosphorus in water following wildfire. Spencer 

and Hauer (1991) reported that that both nitrogen and phosphorus increased dramatically 

during and for two days following a wildfire burning through a watershed. They found that 

nitrogen and phosphorus declined to pre-fire levels a few days to a few weeks following the 

wildfire. On Kanuti Refuge, a post-fire study compared the nutrient chemistry (total nitrogen 

and total phosphorus) of lakes with burned versus unburned shorelines (Heglund et al. 2002). 

They found no significant differences in mean chemical and nutrient concentrations in burned 

and unburned lakes, but high levels of variability may have masked differences. Minshall et al. 

(1989) pointed out that moderately burned watersheds may, in fact, show little or no changes in 

stream chemistry. 

3-34 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Figure 3-12. Wildfire occurrence (1957-2006) 
Chapter 3: Refuge Resources

3-36 
Chapter 3: Refuge Resources 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-37 

0

2

4

6

8

10

12

14

Number of Fires

1957 1961 1965 1969 1973 1977 1981 1985 1989 1993 1997 2001 2005

Year

In the boreal forest, wildfires can also affect areas underlain with permafrost. Lipovsky et al. 

(2006) reported on the occurrence of numerous shallow (up 24 inches deep) landslides during and 

the year following extensive wildfires in Yukon Territory. These landslides occurred on slopes as 

shallow as 10 degrees and exposed the permafrost layer to additional seasonal melting that 

otherwise would not have occurred. 

3.2.9 Fire Regime of the Innoko Refuge 

On a regional scale, the occurrence, frequency, size, season of occurrence, distribution, intensity, 

and severity of fire in the Innoko Refuge remain much as they have since recorded time. The 

most significant changes to this fire regime are confined to areas surrounding local villages and 

communities. 

3.2.9.1 Fire Occurrence and Frequency 

There is evidence of wildland fire through most of the Innoko Refuge below 1,000 feet in elevation 

(Figure 3-12). Although reliable records have only been kept since the 1950s, fire has played a 

major role in influencing both the distribution and diversity of habitats in the Innoko Refuge. 

Until the 1950s, nearly all fire occurrence was the result of lightning. Of the 119 wildfires in the 

Innoko Refuge area from 1981 through 2007, five percent were human-caused. U.S. Fish and 

Wildlife Service fire records go back to the inception of the Innoko Refuge in December 1980. 

Additional fire records from 1957 through 1981 are not depicted in Figure 3-13, as only fires 

greater than 1,000 acres were reported. 

Figure 3-13. Innoko area natural fire starts, 1957–2007 
Chapter 3: Refuge Resources 

3.2.9.2 Fire Size 

Most wildland fires in the Innoko Refuge are started naturally by lightning; these wildfires 

account for 95 percent of the total number of acres burned. Most fire suppression efforts are 

focused on human-caused fires in and around developed and village areas. In the absence of 

suppression, the final sizes of Innoko Refuge wildfires are determined by a variety of factors. For 

example, the later in the season a wildland fire starts, the less time it has to spread. Weather is 

important not only on ignition day but over the duration of the fire. Fires can hold over during 

long periods of moist weather and become active again after a drying period. High winds can 

cause a fire to quickly grow. Fuel continuity also determines whether a wildland fire can continue 

to grow. Wetlands and rocky areas are firm barriers that can only be breached by spotting. 

Hardwood stands, wet areas, and old burn scars may also serve as barriers; reduced fuels within 

these areas will usually limit fire behavior and slow fire spread. Consequently, some wildland 

fires may burn only a few square feet, while others that continue throughout a summer can burn 

thousands—or hundreds of thousands—of acres. From 1957 through 2007, 149 wildland fires 

burned a total of 3,268,001 acres. 

Record temperatures and drought conditions in 2005 allowed eight lighting-caused fires in the 

Innoko Refuge area to burn over 321,522 acres, accounting for the third largest amount of burned 

area in the Innoko Refuge’s 26-year history (1981–2007). 

0

200,000

400,000

600,000

800,000

1,000,000

1,200,000

1,400,000

1,600,000

Burned Acres

1957 1961 1965 1969 1973 1977 1981 1985 1989 1993 1997 2001 2005

Year

Figure 3-14. Acres burned on the Innoko Refuge, 1957–2007 

3.2.9.3 Fire Season 

The fire season in the Innoko Refuge area is highly variable. It begins some years as soon as the 

snow has melted in early to mid-May. Because of the low moisture content in local snow, the 

severity of this early season is more dependent on spring breakup conditions than it is on the 

3-38 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

amount of overwinter precipitation. Rapid thawing allows moisture to percolate downward, 

leaving surface fuels dry, while a slow breakup impedes drying by holding moisture close to the 

surface above frozen layers. Early season fires tend not to burn deeply but may burn intensely 

and spread quickly across the surface. 

As green-up progresses and live fuel moistures rise during late May and early June, fires become 

less frequent. As days lengthen further, increased differential heating becomes more conducive to 

convective activity and, in the absence of significant rain, causes surface fuels to dry. This effect 

peaks from mid-June to mid-July and is the basis for the Innoko Refuge lightning fire season. 

The most active fire years are often characterized by large, stable high-pressure systems over the 

interior, which result in prolonged periods of hot, dry weather and more frequent lowprecipitation thunderstorms. Other years are characterized by a series of low pressure systems 

that sweep across the valley and bring widespread rain. 

By mid-July, thunderstorm activity begins to lessen due to shorter days and less intense sunlight. 

Fuels can remain dry, allowing ongoing fires to continue burning; however, new ignitions occur 

less often. Typically, large high-pressure systems give way to systemic moisture sometime in 

August. Without moisture, a late season can extend into September. Late season ignitions are 

often the result of escaped campfires. Although fires can burn into October if snowfall is delayed, 

rarely do they spread significantly. 

3.2.9.4 Fire Return Interval for Alaska 

In spite of the difficulties in determining fire return intervals in Alaska, several researchers have 

estimated the length of the fire cycle in interior Alaska. In forests dominated by black spruce, 

fires typically occur every 50 to 100 years (Heinselman 1981, Rowe et al. 1974, Viereck 1983). In 

wetter lowland bog areas and muskeg, conditions must be drier and more extreme for large 

sustained fires. Typically, these areas burn every 100–150 years (Heinselman 1981). The 

frequency of wildfire in white spruce or mixed white spruce/hardwood forest varies considerably 

(50–300 years), depending upon local climate and topography, but wildfire generally occurs less 

frequently than in black spruce forests (Duchesne and Hawkes 2000, Rowe et al. 1974). 

3.2.9.5 Approximate Fire Return Interval and Fire Rotation for the Innoko Refuge 

The annual averages for size of fires and number of occurrences for wildland fires in the Innoko 

Refuge for the last 50 years is 21,932 acres burned per fire and three fires per year, respectively. 

Based on 50 years of fire records and an average of 65,796 acres burned per year, the approximate 

fire rotation for the Innoko Refuge is 58 years, meaning that the refuge land base of 3,816,220 

acres will burn every 58 years. However these figures do not depict what actually burns in 

specific areas (typically upland areas). There are areas in the central basin of the refuge that have 

no fire record at all due to wetlands and the amount of water barriers in those areas. The uplands 

have repeatedly burned in areas on the western, southern, and northeastern portions of the refuge 

(see Figure 3-12) over the past 50 years. 

3.2.9.6 Appropriate Management Response 

Appropriate Management Response (AMR) encompasses all of the response actions necessary to 

manage a wildfire or wildland fire for the duration of the event. In implementing the AMR, the 

full spectrum of tactical options, from monitoring a fire at a distance to intensive suppression 

actions, are available to the fire manager. Beginning with the initial response to any wildland fire, 

decisions will reflect the goal of using available firefighting resources to manage the fire for the 

most effective, most efficient, and safest means available. The AMR strategies and tactics used to 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-39 
Chapter 3: Refuge Resources 

manage a wildland fire will be based on objectives identified in the land or resource management 

plan and/or fire management plan. 

AMR strategies and tactics will consider firefighter and public health and safety, fire cause, 

current and predicted weather, current and potential fire behavior and fire effects, values to be 

protected from fire, management priorities, resource availability, cumulative effects of the fire, 

and cost effectiveness. Direct assessment of resource benefits from fire is currently allowed only 

where wildland fire use has been identified in the land or resource management plan and/or fire 

management plan as an acceptable strategy. 

Bureaus must write and approve all Wildland Fire Implementation Plans before beginning an 

appropriate management response action that limits suppression actions. The Service’s Alaska 

Region requires a stage one Wildland Fire Implementation Plan to be completed for all wildland 

fires. Plan development and implementation will follow guidance as described in the Wildland 

Fire Use Implementation Procedures Reference Guide (USDA and USDOI 2005). 

3.2.9.7 Fire Effects Monitoring and Evaluation 

Land resource managers need data derived from remote sensing techniques to be ecologically 

meaningful (i.e., reasonably predict habitat successional paths from pre- and post-fire conditions) 

if they are to be of any use. Innoko Refuge staff started working with the regional fire ecologist 

and others to assess burn severity using different remote sensing tools in 2006. So far, there have 

been two years of short-term monitoring of wildland fires on the Innoko Refuge. The refuge 

proposes a longer term fire effects monitoring plan that would span a minimum of five years per 

project area. This would enable refuge staff the opportunity to evaluate management criteria and 

adjust to meet natural resource goals. 

For further information regarding specific fire management issues and operating procedures for 

the Innoko Refuge, see the Innoko Fire Management Plan. 

3.2.9.8 Affected Villages Around the Innoko Refuge 

Seven village communities could be potentially affected by wildland fires on or adjacent to the 

Innoko Refuge. The village of Shageluk is located six miles south of the southwestern corner of 

the refuge. This village could be severely affected by a wildland fire coming off the refuge and 

into the immediate area. The villages of Grayling, Anvik, Holy Cross, Kaltag, McGrath, and 

Takotna are located further away or have significant natural barriers (i.e., the Yukon River) from 

the refuge boundaries. Wildland fires in those areas could potentially affect the natural resource 

values on the refuge (i.e., subsistence resources) that these village residents use. 

3.3 Biological Environment 

3.3.1 Vegetation 

Except where other references are cited, the following overview of the boreal forest is from Chapin 

(2004). The boreal forest is the second most extensive terrestrial biome on earth (Whittaker 1975) 

and has many characteristics that set it apart from other ecosystems. It has a cold, dry climate, 

making it potentially sensitive to climate change. It has few dominant tree species, so changes in 

these tree species have large ecosystem impacts. It is relatively undisturbed by current human 

activities. Productivity and diversity are low relative to other forests (Grower et al. 1997, Waide et 

al. 1999), but boreal forests provide habitat suitable for many fish and wildlife species. 

3-40 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

A defining characteristic of the boreal forest ecosystem is the cycle of wildfire and its influence on 

the distribution, abundance, and connectivity of various plant community types and habitats. 

Because of this significant relationship, the boreal forest is often referred to as a “fire dependent” 

ecosystem—meaning if fire were entirely removed, there would be a dramatic and permanent 

change in the vegetation, fish, wildlife, and habitats that now exist. 

3.3.1.1 Habitats 

The refuge lies within the boreal forest or “taiga” that spans the boreal (or northern portions) of 

North America, Europe, and Asia. The Russian term “taiga,” meaning “little sticks,” is 

descriptive of the small coniferous trees which grow in this region. Muskeg is another term 

frequently used in conjunction with the boreal forest; it refers to wet, boggy areas that are usually 

dominated by Sphagnum mosses and stunted spruce trees. “Boreal forest” is often used as a 

comprehensive term that includes the forest, muskeg, forest openings, and wetlands that 

characterize the boreal region. This mosaic, or patchwork, of different vegetation types within the 

boreal forest is the visible culmination of complex interactions between climate, geology, 

topography, soils, hydrology, permafrost, and fire. Vegetation plays a role in determining the 

distribution of wildlife species, but the activities of herbivores such as moose, hares, insects, and 

beaver can also have profound influences on vegetative patterns; additionally, abiotic factors such 

as fire, flooding, and mechanical alteration from ice also play an important role in determining 

vegetative patterns. A list of plant species found on the refuge is located in appendix G. 

Any attempt to classify and quantify habitat on the refuge becomes quickly outdated as new 

wildland fires occur or as plant communities develop through different post-fire stages of 

succession. Landcover mapping using satellite imagery is a way to get a “snapshot in time” across 

large areas. The term “landcover map” is used rather than “vegetation map” because nonvegetative components such as rock, water, and developed areas can also be identified on the 

imagery. The image provided by the satellite only distinguishes ground features by the way they 

reflect light; fieldwork, aerial photos, and knowledge of the area are required to identify what 

those features are. Two landcover maps have been developed for the refuge (figures 3.15 and 

3.16). The first effort was completed in 1986 from a cooperative effort by the Service and US 

Geological Survey (Talbot and Markon 1988) using 1981 Landsat 3 imagery. The second effort 

was completed in 2002 as a cooperative effort by the Service, the Bureau of Land Management 

(BLM), and Ducks Unlimited (Bureau of Land Management et al. 2002) using 1991 Landsat 7 

imagery. Ducks Unlimited and BLM have used standardized procedures for landcover mapping 

in Alaska since 1988; however, the landcover classification system used does not follow Service 

standards. While the first landcover mapping effort included all of the refuge, the second effort 

included only 3,422,217 acres, or 89.7 percent of the refuge. 

The first landcover mapping effort defined 6 classes with a total of 21 subclasses (Table 3-7). The 

second landcover mapping effort defined 31 subclasses for 6 classes (Table 3-8). Definitions of the 

classes and subclasses from both mapping efforts are found in appendix H. The complex fire 

history of the refuge sometimes made it difficult to classify recent burns, partly because the 

vegetation within them changes rapidly during the first ten years or so. Some of these were 

simply labeled as “Upland Burn Regeneration” and “Fire Scar–Regeneration” for burned areas 

with readily identifiable regenerating vegetation for the two different mapping efforts. Since the 

1991 satellite imagery was obtained, 27 significant fires have occurred on the refuge, burning over 

1,500,000 acres; these changes are not included in the landcover classes. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-41 
Chapter 3: Refuge Resources 

Table 3-7. Landcover classes and subclasses derived from 1981 Landsat 3 imagery (Talbot and Markon 1988) 

Class Subclass Area (acres) Percent of Total 

Forest Closed Needleleaf 318,659 8.3 

Open Needleleaf 516,026 13.6 

Needleleaf Woodland 89,257 2.3 

Mixed Forest 167,834 4.4 

Broadleaf Forest/Tall Shrub 375,199 9.9 

Shrub Lowland Shrub 244,613 6.5 

Subalpine Shrub 4,361 0.1 

Upland Burn Regeneration 291,846 7.6 

Dwarf Shrub Prostrate Dwarf Shrub Tundra 70 <0.1 

Erect Dwarf Shrub Heath 410 <0.1 

Dwarf Shrub – Graminoid Peatland 350,322 9.2 

Dwarf Shrub – Graminoid Tussock Peatland 356,651 9.3 

Dwarf Shrub Raised Bog 319,072 8.4 

Dwarf Shrub – Graminoid Marsh 450,700 11.8 

Herbaceous Graminoid Bog 20,293 0.5 

Graminoid Marsh 63,587 1.7 

Graminoid Tussock – Dwarf Shrub Peatland 124,212 3.2 

Scarcely 

Vegetated 

Scree 367 <0.1 

Floodplain 932 <0.1 

Water Clear 119,916 3.1 

Sedimented 5,026 0.1 

Examination of landcover class definitions between Talbot and Markon (1988) and Bureau of Land 

Management et al. (2002) in appendix H not only shows where the differences between the 

classification systems used occurred, but where there was reasonable overlap. The biggest 

differences are the splitting of shrub classes by Talbot and Markon (1988) versus the lumping by 

Bureau of Land Management et al. (2002) and the splitting out of aquatic vegetation by Bureau of 

Land Management et al. (2002). However, cross-referencing the subclasses between the two is 

much more problematic and is the primary source for differences in the proportion contributed to 

each cover class (Figure 3-17). A minor source for differences in the proportion contributed by 

each cover class arises from the incomplete coverage of the refuge (Figure 3-16) by Bureau of 

Land Management et al. (2002). 

Forests account for 38–68 percent of the vegetation on the refuge. These forested areas are 

characterized by trees 15 feet or taller or in the intermediate successional stage less than 15 feet 

tall but growing. Depending upon soils and topography, climax forest communities are dominated 

by an overstory of either black or white spruce. 

The majority of forest on Innoko Refuge is dominated by black spruce, which is found in cooler 

wet lowland sites and north-facing slopes. A carpet of feather mosses, Sphagnum mosses, and 

lichens are very common as a primary component of the understory. Graminoid tussocks, various 

shrub willow species, and ericaceous shrubs such as blueberry, crowberry leatherleaf, and 

labrador tea may also be present. Sphagnum mosses may be present on moister sites. 

3-42 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Figure 3-15. 1981 Land cover 
Chapter 3: Refuge Resources

3-44 
Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Figure 3-16. 1991 Land cover 
Chapter 3: Refuge Resources

3-46 
Chapter 3: Refuge Resources 

Table 3-8. Landcover classes and subclasses derived from 1991 Landsat 7 imagery (Bureau of Land Management et al. 2002) 

Class Subclass Area (acres) Percent of Total 

Forest Open Needleleaf 345,205 10.1 

Open Needleleaf – Lichen 794,157 23.2 

Woodland Needleleaf 305,712 8.9 

Woodland Needleleaf - Lichen 124,056 3.6 

Closed Deciduous 191,849 5.6 

Open Deciduous 94,071 2.7 

Closed Mixed Needleleaf/Deciduous 180,826 5.3 

Open Mixed Needleleaf/Deciduous 180,213 5.3 

Tall Shrub 116,383 3.4 

Shrub Low Shrub 270,974 7.9 

Low Shrub – Lichen 2,569 0.1 

Low Shrub – Tussock Tundra 57,030 1.7 

Low Shrub – Willow/Alder 348 <0.1 

Fire Scare Regeneration 45,666 1.3 

Dwarf Shrub 153,127 4.5 

Dwarf Shrub – Lichen 12,743 0.4 

Herbaceous Wet Graminoid 91,101 2.7 

Wet Forb 3,619 0.1 

Tussock Tundra 3,890 0.1 

Tussock Tundra – Lichen 11,234 0.3 

Lichen 13,164 0.4 

Moss 307,488 9.0 

Mesic/Dry Graminoid 7,796 0.2 

Mesic/Dry Forb 64 <0.1 

Aquatic Vegetation Aquatic Bed 10,428 0.3 

Emergent 5,505 0.2 

Barren Sparse Vegetation 188 <0.1 

Rock/Gravel 1,534 <0.1 

Non-vegetated Soil (Mud/Silt/Sand) 228 <0.1 

Water Clear 83,717 2.4 

Turbid 8,065 0.2 

White spruce forests are more commonly found on warmer well-drained sites such as alluvial 

deposits. On lowland sites, paper birch and balsam poplar may be components of the overstory, 

with quaking aspen as a component on upland sites. The understory may include tall shrub 

willow, alder, prickly rose, and a shallow carpet of feather mosses. 

Mid-successional stage forest communities are dominated by broadleaf hardwood species (quaking 

aspen, balsam poplar, and paper birch) or mixed stands of spruce and hardwood species. Aspen is 

well adapted to regeneration following fires and will quickly recolonize an area from suckers on 

their extensive root system, which is well insulated from the heat of most fires by the surface layer 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-47 
Chapter 3: Refuge Resources 

of organic matter and soil. Both aspen and paper birch can also regenerate from their root collars 

where the roots spread out from the base of the stem (Duchesne and Hawkes 2000). The ability of 

the tree to regenerate depends upon fire intensity and moisture present in the soil or moss/lichen 

layer. Deciduous forests are found in riparian areas, lake margins, burns, and on well-drained 

slopes and wooded ridges. The mixed cover type usually is found as either mature stands on welldrained productive sites, post-fire stands with openly-spaced smaller trees, or stands on poorer sites 

that are dominated by spruce with stunted birch and aspen interspersed throughout the stand. 

0

10

20

30

40

50

60

70

Forest Shrub Herbaceous Aquatic

Vegetation

Barren Water

Vegetation Class

1981

1991

Proportion

Figure 3-17. Proportion of vegetation cover classes derived from 1981 Landsat 3 imagery (Talbot and Markon 1988) and 1991 

Landsat 7 imagery (Bureau of Land Management et al. 2002) for Innoko National Wildlife Refuge, Alaska. The 1991 shrub class 

includes shrub and dwarf shrub classes of Talbot and Markon (1988) 

Willows and alder sometimes grow to tree height and can form large stands (i.e., tall shrub subclass) 

but are usually mixed with other deciduous species. 

Shrub communities include low and dwarf shrub subclasses and made up 16–53 percent of the 

refuge. Low shrub communities are composed predominantly of deciduous shrubs ranging from 

1.5–15 feet in height. On Innoko Refuge, shrub occurs primarily along water courses, in poorly 

drained sites, in graminoid zones, and as early successional stage plant communities in disturbed 

or burned areas. Shrub stands on well-drained sites are typically dominated by willow and alder, 

which are important forage species for animals such as moose and snowshoe hare. Shrubs quickly 

revegetate burned areas and provide important forage and habitat for wildlife and nutrients such 

as nitrogen, which all plants need to grow. Browsing by moose and snowshoe hares, combined 

with nitrogen added by symbiotic bacteria, help the forest progress to the next stage of succession 

(Chapin 2000). Dwarf shrub communities are composed predominantly of ericaceous shrubs and 

members of the heath and crowberry families less than 1.5 feet in height. Mosses and lichens are 

commonly found within these communities. Areas that were affected by moderate to high severity 

wildfires within the 10 years preceding the Landsat imagery are included in this landcover class. 

3-48 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Common shrubs include willow, alder, dwarf and shrub birch, blueberry, lingonberry, and 

labrador tea. Dense willow thickets are often found adjacent to rivers and lakes; willows are also 

common in the forest understory. 

The herbaceous landcover class made up 5–13 percent of the refuge. This class includes 

graminoid (grasses and sedges) marshes, which are wetlands periodically inundated with standing 

or slowly moving water, found along lake shores and in alluvial sites. Graminoids can dominate 

communities such as tussock tundra, which is comprised largely of tussock cottongrass. 

Relatively pure stands of bluejoint grass can occupy riverbanks or move in after fire. Herbaceous 

plants are typically mixed with other plants or are in the understory of forests, but fireweed can 

form extensive stands following fire, turning the landscape pink in July. Talbot and Markon 

(1988) combined aquatic communities split out by Bureau of Land Management et al. (2002). 

Aquatic plants are readily visible when flying over the refuge. Water lilies can cover a pond’s 

surface, and other aquatic and emergent plants such as horsetails, buckbean, mare’s tale, 

pondweeds, and bladderwort are found in lakes and at their edges. Floating bog mats sometimes 

fringe water bodies and support sundews, bog rosemary, Sphagnum mosses, and lowbush 

cranberry. Pure lichen communities are very rare on the refuge, and lichens are more commonly 

found as ground cover in forest stands. When they occur, they are usually rich in the branched 

“reindeer” lichens used by caribou as a winter food source (Figure 3-18). 

Lake vegetation on the refuge is dominated by pondweed, water lily, bladderwort , burreed , and 

water milfoil. Horsetail frequently occurs in the shallow water areas with various grasses, sedges, 

and shrubs growing on the shoreline. Areas of floating bog often extend far out from the shoreline. 

The barren or scarcely vegetated landcover class is characterized by sites dominated by exposed soil 

or rocks. This landcover class comprised less than 0.1 percent in both landcover mapping efforts. 

Figure 3-18. Lichen is an important forage item for caribou; the extent of pure lichen habitat on Innoko is very limited and usually 

occurs as an understory plant in several forest and shrub plant communities. (Photo W. Raften, USFWS) 

3.3.1.2 Non-Native Invasive Plants 

Invasive non-native species pose a significant risk to ecological stability and integrity. Despite 

searches conducted in recent years at several Gold Rush era sites, former cabin sites, sites used 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-49 
Chapter 3: Refuge Resources 

extensively by hunters, and the refuge’s administrative site, only five species of invasive plants 

have been found—all at the administrative site. Invasive plant species recorded at the 

administrative site include annual bluegrass, common chickweed, pineappleweed, and common 

plantain (figures 3-19 and 3-20). Recently, fishery biologists noticed lambsquarter growing on the 

upper reaches of two gravel bars along the Innoko River (Figure 3-21). 

 

Figure 3-19. Chickweed (left) and pineappleweed (right) are two of the five non-native invasive plant species found at the Innoko 

Refuge administrative site. (Photos S. Kovach, USFWS.) 

 Figure 3-20. Bluegrass (left) and common plantain (right) are non-native invasive plant species found at the Innoko Refuge 

administrative site. (Photos: bluegrass, University of Kentucky; plantain, S. Kovach, USFWS) 

3-50 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Figure 3-21. Lambsquarter found growing along the Innoko River. (Photo S. Kovach, USFWS) 

3.3.2 Fish and Wildlife 

3.3.2.1 Fish 

The Innoko Refuge has an expansive complex of fish communities and their habitats. These 

waters provide critical spawning, rearing, feeding, and/or migratory habitats for 22 reported 

species of fish (appendix G, table G-5) (USFWS 1993). Most species are classified in the salmon 

family with individual species representing eight other families. The two life history strategies 

used by these species are represented by the anadromous behaviors of salmon and whitefish and 

the purely freshwater dependence of Arctic grayling and northern pike. 

Little is understood about the life history, distribution, behaviors, and harvest of fish found in the 

refuge. Most of the available information is related to salmon, and their basic life history is 

understood in the larger context of the Yukon River system. However, comprehensive 

information about adult salmon stock abundance, population structure, timing, distribution, and 

critical habitats within Innoko Refuge is lacking. Additionally, information about the 

characteristics of juvenile salmon populations on the refuge and factors affecting them is absent. 

Whitefish are an important refuge resource. These species provide subsistence users with 

sustenance during seasons when salmon are not available, and emerging commercial fisheries 

have the potential to harvest large numbers. These fish act as an important prey base for wildlife 

and other fish species, and sheefish are also targeted in sport fisheries. Similar to salmon, the 

migratory habits of several of these species make Innoko Refuge stocks susceptible to harvest 

impacts outside of the refuge. However, unlike salmon, few fundamental population 

characteristics or critical habitats have been identified. 

While some information exists for other harvested species in the region, such as northern pike and 

Arctic grayling, little is known about these species within the refuge. Also, information about 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-51 
Chapter 3: Refuge Resources 

species that are not used directly by humans but may be important for predator-prey relationships 

and other ecological aspects, such as trout perch and pond smelt, is nonexistent. Additionally, 

although salmon harvests in some villages are documented annually by the Service (Gerken 2006, 

Gerken and Holder 2005) and Alaska Department of Fish and Game (Busher and Hamazaki 2005), 

with non-salmon harvests occasionally described (Brown et al. 2005), detailed harvest information 

for all species is lacking. Descriptions of the more commonly known species follow. 

Northern Pike 

Northern pike are an abundant species in the refuge and inhabit the lower portions of larger 

rivers and most lakes of suitable depth (USFWS 1993). The abundance of river connected lakes 

and sloughs provide ideal habitat for all aspects of their life history. Fish begin spawning during 

the spring of their third year (Cheney 1971), and fry emerge one to three weeks after spawning. 

Soon after emergence, they become active feeders. Based on a radio telemetry study from 2002 

through 2004, northern pike tagged outside the refuge in the lower Innoko River overwintered in 

areas outside of the refuge in the lower Innoko River and the mainstem Yukon River downstream 

of Holy Cross (Scanlon In press). These fish did not leave the lower Innoko River area for 

spawning or during summer feeding. The only two fish that approached the refuge boundary 

were relocated in March 2003 and May 2004 downstream of the refuge near the village of 

Shageluk. Based on this information, northern pike in the refuge may comprise a separate 

population that does not mix with fish from the lower Innoko River system. 

Broad Whitefish 

Broad whitefish are highly migratory and thought to be anadromous (Brown et al. 2007). They 

enter waters within the refuge from the main stem Yukon River to feed in the lower river systems 

and river connected lakes soon after breakup (Alt 1983). Summer distributions include the 

Dishna, Yetna, and Iditarod rivers, and near Hather Creek. Similar to other whitefish, broad 

whitefish are fall spawners, but no spawning areas have been identified. This species is a primary 

forage fish for aquatic and terrestrial predators. 

Humpback Whitefish 

As with broad whitefish, humpback whitefish are highly migratory and thought to be anadromous 

(Brown et al. 2007). The timing of arrival in waters within the refuge is similar to broad whitefish, 

with both species using overlapping habitats for feeding. During fall, they ascend the large rivers 

to spawning areas in the mainstem Innoko River upstream of Cripple Landing, and in the Iditarod 

River near Iditarod (Alt 1983). Humpback whitefish are also an important forage species. 

Least Cisco 

Like the previous whitefish species, least cisco are highly migratory and thought to be 

anadromous (Brown et al. 2007). Their timing and habitat use appear to be similar to broad and 

humpback whitefish (Alt 1983). During mid-September, they move to spawning areas in the upper 

main stem Innoko River in the Cripple Landing–Beaver Creek area. Eggs overwinter and fry 

emerge the following spring. Young-of-the-year fish were reported emigrating from the Innoko 

River system in June. Least cisco are a primary forage fish for aquatic and terrestrial predators. 

Sheefish (inconnu) 

Sheefish are also highly migratory and thought to be anadromous (Brown et al. 2007). Their 

distribution in the refuge is limited to the main stem Innoko and Iditarod rivers. Sheefish 

overwinter in the lower Yukon River and migrate into the lower Innoko and Iditarod rivers after 

breakup to forage in tributaries (Alt 1983). No sheefish have been reported above the mouth of 

3-52 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

the Dishna River. Sheefish are generally inconsecutive (that is, not consecutive) spawners, with 

females spawning every other year beginning at approximately age eight or nine. Males begin 

spawning at age six to eight (Alt 1981). Spawners leave the refuge in July and August bound for 

spawning areas in the upper Yukon and Koyukuk rivers. Spawning occurs in late September to 

mid-October, with fry appearing in early spring. Important food items of sheefish include 

whitefish, northern pike, longnose suckers, lamprey, and salmon parr and smolts (Alt 1983). 

Arctic Grayling 

The documented distribution of Arctic grayling includes the upper Innoko and Iditarod river 

systems, specifically Beaver and Folger creeks (Alt 1983). Fish congregate at the mouth of clear 

water tributaries in the large river systems in early April and move into spawning areas as soon as 

the ice leaves these streams (USFWS 1993). Arctic grayling begin spawning at age three, with fry 

emerging within a month of spawning. Soon after emergence, fry seek slower velocity areas to 

rear. Insects of the orders Diptera and Hemiptera constitute the major food items (Alt 1983). 

Chum (dog) Salmon 

Chum salmon in the refuge are part of the Yukon River population—one of the largest natural runs 

in North America (USFWS 1993). Two distinct chum salmon runs use the refuge. Summer chum 

salmon arrive in early June and spawn on the refuge through August, while fall chum salmon pass 

the refuge during August on their way to spawning areas in the middle and upper Yukon River 

basin. Spawning areas for summer chum salmon are known to exist above Ophir in the main stem 

Innoko River in Beaver Creek, Dishna River, and likely in the upper Iditarod (Rost 1988, Alt 1983). 

Also, waters of the refuge are corridors for chum salmon that have been captured in California and 

Tolstoi Creeks (Olsen et al. 2004) and the upper Little Mud River (Mueller and Matz 2002). Eggs 

develop through the fall and winter, with fry emerging in early spring. Soon after emergence, the 

fry begin migration to salt water and return in three to six years (Salo 1991), although four-year-old 

chum salmon account for most of the annual return (Buklis and Barton 1984). 

Coho (silver) Salmon 

Coho salmon in the refuge are also part of the Yukon River population (USFWS 1993). These fish 

arrive in early September and spawn throughout late fall. Adult coho salmon have been captured 

in the North Fork Innoko River, and spawning areas are thought to be located in this tributary 

(Alt 1983). Waters of the refuge also act as corridors for coho salmon parr and smolts that have 

been captured in the middle Innoko River in California and Illinois creeks (Olsen et al. 2004) and 

in the upper Little Mud River (Mueller and Matz 2002). Eggs develop throughout the fall and 

winter, with fry appearing the following spring. Coho salmon parr typically remain in fresh water 

1–3 summers and smolt the following spring (Sandercock 1991). These fish generally rear for one 

year in the ocean before returning to freshwater to spawn. Four-year-old fish comprise most of 

the annual return. 

Chinook (king) Salmon 

Chinook salmon using the refuge are part of the Yukon River population, which is one of the 

largest natural runs of Chinook in the world (USFWS 1993). Returning adults arrive in early 

June and typically complete spawning by early August. Documented spawning areas include 

Gaines Creek in the upper mainstem Innoko River, above Ophir (Alt 1983), the Dishna River, 

Iditarod River, and Tolstoi Creek (Eiler et al. 2006a, Eiler et al. 2006b, Eiler et al. 2004). Waters 

within the refuge also act as corridors for Chinook salmon parr and smolts that have been 

captured in California Creek (Mueller et al. 2000). Eggs develop throughout the fall and winter, 

with fry appearing early the next spring. Chinook salmon parr typically rear for one year in fresh 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-53 
Chapter 3: Refuge Resources 

water and smolt during the spring of their second year of life (Healey 1991). Once the smolt enter 

the ocean, they generally rear and mature for three to six years before returning to fresh water to 

spawn. Five-year-old fish account for most of the annual return. 

3.3.2.2 Amphibians 

Of the eight species of amphibians known to occur in Alaska (MacDonald 2003), only the wood frog 

(Figure 3-22) occurs on Innoko Refuge. Increased sightings of malformed frogs throughout North 

America raised concerns about amphibian health. The U.S. Fish and Wildlife Service began 

investigating the prevalence of abnormal amphibians in 2000 on refuges across the United States 

(Trust and Tangermann 2002); a total of 13 sites were sampled in Innoko Refuge from 2003 through 

2006. Most of the selected sites were close to the Innoko River and during these surveys, it was 

noted that not every pond with suitable habitat had frogs. Stevens et al. (2006) suggest that small 

beaver ponds, older ponds in particular, provide suitable and stable wood frog habitat and need to be 

included in searches for wood frogs. 

Of the sites surveyed thus far, all but one had either no abnormalities or a very low percentage (i.e., 

less than two percent) of abnormalities. One site that had a consistently high rate of abnormalities 

(12–21 percent in three of four years sampled) was a small pond located approximately 450 feet 

northeast of the administrative site. The cause for this localized high abnormality rate is unknown. 

Figure 3-22. The wood frog is the only amphibian found on Innoko Refuge and has the ability to freeze as much as 35 to 45 percent 

of its body during the cold winter months. (Photo USFWS) 

3.3.2.3 Birds 

The numerous rivers and creeks of Innoko Refuge provide riparian and wetland habitats that 

support abundant bird life: 128 bird species have been recorded on the refuge, of which 118 are 

thought to breed there (appendix G); of these, 22 species are hardy enough to overwinter. Grouse, 

owls, woodpeckers, chickadees, gray jays, ravens, and redpolls are year-round residents of the 

refuge. One of the reasons for establishment of the refuge was protection of the vast wetland 

complex surrounding the confluence of the Innoko and Iditarod rivers—important to waterfowl 

during many life stages. The unique water regime in this area, characterized by frequent spring 

flooding and slow drawdown of lakes, creates excellent habitat for breeding, molting, and 

migrating birds. Wetland habitats also support a diversity of breeding land and water birds, 

including several species of conservation concern. Table 3-9 is a summary of bird projects 

conducted by refuge staff and cooperators on Innoko Refuge. 

3-54 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Table 3-9. Bird projects conducted on Innoko Refuge 

Project Years Periodicity Comments 

Greater white-fronted goose 

banding 

1945–1974 

1975–present 

Sporadic 

Annual 

Currently conducted by Division of 

Migratory Birds 

Greater white-fronted goose 

aerial molt survey 

2000–present Annual Conducted by Division of Migratory 

Birds; approximately 735 mi2 

surveyed 

Greater white-fronted goose 

molting ecology study 

2006–2007 Annual Energetics and survival, foraging 

ecology, and population 

discrimination and distribution; - 

conducted by USGS-BRD in 

cooperation with refuge staff 

Alaska-Yukon waterfowl 

breeding population surveys 

1957–present Annual Conducted by Division of Migratory 

Birds; 7 transects totaling 177 mi 

Ground-based waterfowl 

production surveys 

1983–1993 Annual Standardized survey plots 

established 1985; regional standard 

operating procedures established 

1990; all surveys across Alaska 

ended in 1994 

Highly pathogenic Asian 

H5N1 avian influenza 

sampling in northern pintails 

2006–present Annual August migration banding at sites 

located on the Netletna River to 

sample 200 pintails for H5N1 

Water bird abundance and 

distribution 

1994–1995 Single Survey Systematic aerial survey sampling 

190 mi2

 (5%) of the 3,545 mi2 survey 

area 

Breeding Bird Surveys 

(BBS), river-based 

1993–present Annual Two 50-point routes: Hather Creek 

and the Mud River 

Off-road landbird point 

counts 

1993–2005 Annual Three 12-point walking routes: Bog, 

Half-way Hill, and Lowland routes 

Alaska Landbird Monitoring 

Survey (ALMS) 

2006 Annual Innoko Refuge assigned four plots 

from statewide grid; survey will 

resume when sufficient staff and 

funding are available 

Resource selection within the 

Innoko River floodplain 

1998–2002 Annual In-depth study of resource selection 

by riparian nesting song birds 

Riparian parasitic bird 

occurrences 

2002 Single Survey Part of a larger study of parasitic 

bird ecology conducted by University 

of California, Santa Barbara 

Nesting dynamics of rusty 

blackbirds 

2005–2006 Pilot Study Project to determine feasibility of 

conducting in-depth nesting ecology 

study 

During the 15 years that the breeding bird surveys have been completed on Innoko Refuge, 85 

species from 10 families have been detected. While the two routes (Hather Creek and Mud River) 

are located in very similar habitat, they share only 65 of the 85 species detected. Not surprisingly, 

the 13 species with the most detections are identical between the two routes. Of the 20 species 

detected every year, only 9 are common to both routes. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-55 
Chapter 3: Refuge Resources 

Geese 

Estimates indicate that the refuge supports, on average, over 75 percent of the molting greater 

white-fronted geese surveyed in interior Alaska. Results of the molting goose survey conducted 

annually since 2000 are presented in Table 3-10. Recovery distributions and survival estimates 

indicate that geese leg-banded on Innoko Refuge (Table 3-11) represent white-fronts from at least 

three different breeding populations: 1) mid-continent birds from interior Alaska; 2) Pacific 

Flyway birds from the Yukon Kuskokwim Delta, Alaska; and 3) tule white-fronted geese from 

Cook Inlet, Alaska, a subspecies that numbers less than 8,000 (Ely and Terenzi 2004). Tule whitefronted geese radio-tagged during the winter are regularly relocated molting on the Iditarod 

lowlands in mid-summer (Ely et al. 2006). Recent analyses revealed that interior Alaska whitefronts are unique among the mid-continent white-front population with respect to their early 

nesting and migration schedule, winter distribution into Mexico, and low annual survival relative 

to other mid-continent white-fronts (Ely and Schmutz 1999). Declines in nesting populations 

(Spindler 1999) and low survival rates of interior Alaska white-fronts have led to increased 

interest in research and monitoring in this region. 

Canada geese are less abundant than white-fronted geese but also breed and molt on Innoko 

Refuge. Based on morphological measurements, most Canada geese on the refuge are believed to 

be the Tavenor Canada goose subspecies that nests on the Yukon Delta, and lesser Canada geese 

thought to predominate in interior valleys. 

Table 3-10. Results of the molting goose aerial surveys on Innoko Refuge 

Species Year Adult Young Total 

White-fronted Geese 2000 20,684 121 20,805 

2001 18,246 137 18,383 

2002 11,273 19 11,292 

2003 27,243 17 27,260 

2004 11,420 42 11,462 

2005 9,761 76 9,837 

2006 16,146 66 16,212 

2007 11,252 177 11,429 

Mean 15,753 82 14,835 

Canada Geese 2000 653 28 681 

2001 4,777 40 4,817 

2002 3,903 114 4,017 

2003 8,216 132 8,348 

2004 4,625 35 4,660 

2005 3,153 162 3,315 

2006 6,027 144 6,171 

2007 5,414 974 6,888 

Mean 4,596 204 4,852 

3-56 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Table 3-11. Numbers of white-fronted geese leg-banded on Innoko Refuge 

Yeara 1969 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994

Number 500 9 545 604 944 22 1,158 138 577 686 567

Yeara 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 

Number 515 168 1,082 918 628 1,311 976 1,150 1,140 1,043 aNo banding 1970 through 1984

Swans 

Innoko Refuge contains habitat for both trumpeter and tundra swans. Since these swans cannot 

be specifically differentiated during aerial surveys, the refuge is not included in statewide aerial 

surveys for trumpeter swans conducted every five years (Conant et al. 2007). Although swans are 

known to breed on the refuge, it is uncertain which species predominates and what habitat 

associations might separate the two species. Tundra swans may prefer open meadow habitats, 

while trumpeter swans favor forested wetlands (Wilk 1993). Bryant et al. (2005) examined nesting 

tundra and trumpeter swans on the Koyukuk Refuge and found nesting lake shape was the only 

peramenter that assisted in separating the two during aerial surveys. 

Ducks 

Annual aerial surveys indicate that approximately 187,000 ducks are found on wetlands on and 

adjacent to the refuge each spring. Northern pintails are most numerous, comprising about 30 

percent of all ducks counted during these surveys. Other common species include American 

wigeon, American green-winged teal, northern shoveler, mallard, and scaup (predominantly 

greater scaup). Brood survey data from Innoko Refuge in the 1980s indicated that drawdown 

wetlands directly connected to a lake, stream or river were preferred to wetlands not directly 

connected to a lake, stream or river. Innoko Refuge staff initiated a duck banding program on the 

Iditarod and Netletna rivers in 2006 in conjunction with sampling northern pintails for H5N1, a 

highly pathogenic avian influenza (Table 3-12). 

Table 3-12. Number of ducks banded on Innoko Refuge 

 Number leg-banded 

 2006 2007 

Northern pintail 288 121 

Mallard 31 

Green-winged teal 4 

American wigeon 2 

Greater scaup 7 

Totals 332 121 

In 2006, the Alaska Interagency Avian Influenza Working Group identified northern pintails as a 

high-ranking species for sampling because of regular contact with Asian migratory birds, making 

them a likely vector for disease transmission. Pintails captured in late July and August likely 

represent some portion of North American wintering birds returning from breeding grounds in 

Asia. In developed areas, pintails prefer ephemeral wetlands and regularly use farm fields and 

wetlands. Thus the habitats used by pintails increases their likelihood of exposure to poultry 

wastes, a major route of disease transmission. Innoko Refuge was selected for sampling due to 

known concentrations of molting and staging northern pintails. In August 2006 and 2007, refuge 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-57 
Chapter 3: Refuge Resources 

staff collected cloacal swabs from 288 and 119 pintails, respectively, for avian influenza testing at 

sites along the lower Netletna River near its confluence with the Innoko River. There are several 

types, subtypes, and strains of avian influenza: in 2006, 9 of 288 pintail cloacal samples tested 

positive for avian influenza, but none of the samples was H5 or N1 positive. This represents a 

three percent prevalence of non-H5N1 avian influenza in Innoko Refuge northern pintails. 

Water Birds 

In addition to waterfowl, other wetland-associated birds use the refuge, particularly common and 

red-throated loons and red-necked grebes. Sandhill cranes are also frequently noted in small to 

medium-sized flocks feeding on refuge wetlands. Mew gulls, Arctic terns, and long-tailed jaegers 

breed on the refuge; Bonaparte’s, glaucous, glaucous-winged, and herring gulls are also regularly 

seen along rivers. 

Shorebirds 

A variety of shorebirds use the refuge during the migration and breeding seasons. Spotted 

sandpipers are abundant, foraging and nesting along river and creek edges. Other species 

commonly seen in these habitats include red-necked phalaropes, least sandpipers, solitary 

sandpipers, and lesser yellowlegs. In muskeg habitats, nesting shorebirds include Wilson’s snipe, 

Hudsonian godwits, and whimbrel. During the migration season, small flocks of pectoral 

sandpipers and large flocks of red-necked phalaropes are regularly encountered foraging on 

shallow wetlands. 

Gallinaceous Birds 

Ruffed grouse and spruce grouse are common in wooded habitats, while tundra and shrub habitats 

support willow ptarmigan. Sharp-tailed grouse have been infrequently observed. 

Raptors 

The wide range of habitats supports a diverse raptor assemblage. The interspersion of islands of 

trees in large expanses of open habitats increases raptor use by providing nest sites. Harlan’s 

hawks and osprey are the most common raptors on the refuge, and nests are frequently 

encountered in tall trees along the river and creek edges. Bald eagles are also fairly common and 

are found nesting along rivers in the refuge and near oxbow lakes. Other nesting raptors include 

northern harrier and rough-legged hawk. Peregrine falcons can be seen nesting on the few 

available rock faces along the Innoko and Yukon rivers and can be readily observed hunting ducks 

during fall migration. Several owl species are also found on Innoko, including great horned owl, 

great gray owl, northern hawk-owl, short-eared owl, and boreal owl. 

Kingfishers, Woodpeckers, and Songbirds 

Breeding bird surveys conducted on the refuge have been used to develop the species list (appendix 

G) and to contribute to regional and national monitoring programs for landbirds. The rattling calls 

of belted kingfishers can be heard along many creeks and rivers on the refuge. Less common (but 

still occasionally seen and heard) are the year-round woodpecker species: black-backed, three-toed, 

downy, and hairy woodpeckers, and the migratory northern flicker. Diverse wetland and terrestrial 

habitats on the refuge support close to 50 species of passerines. The most common riparian 

songbirds are northern waterthrush, alder flycatcher, Swainson’s thrush, yellow warbler, blackpoll 

warbler, and fox sparrow. Several species that breed on the refuge are considered priority species 

for conservation in the northwest interior forest region, including olive-sided flycatcher, graycheeked thrush, blackpoll warbler, and rusty blackbird (Boreal Partners in Flight Working Group 

3-58 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

2006). Year-round resident songbirds include black-capped and boreal chickadee, gray jay, common 

raven, common and hoary redpoll, pine grosbeak, and white-winged crossbill. 

3.3.2.4 Mammals 

Innoko Refuge has 38 species of mammals known or suspected to occur (appendix G). This 

includes the muskox, normally a species found along the Bering Sea and Arctic Ocean coasts, 

which has been observed upstream of the refuge along the Innoko River—clearly, the muskox is 

an accidentally occurring species. Beaver are common, moose occur in moderate numbers, and 

both black and brown bears are found on the refuge. Tracks of wolves, lynx, wolverine, marten, 

fox, and river otter are commonly seen in winter, but these species are difficult to observe during 

the summer months. Low numbers of caribou are commonly observed throughout the year. 

Moose 

Moose were specifically identified by Congress when citing purposes for creating Innoko Refuge. 

Moose are critically important to subsistence users of the refuge and are specifically sought after 

by many visitors. Innoko Refuge provides a variety of important habitats for moose. Moose are 

distributed throughout the refuge from late spring through mid to late fall (depending on freezeup); in the winter, moose tend to be concentrated along river systems where riparian vegetation is 

abundant (Figure 3-23). 

Figure 3-23. Locations where moose were observed during February/March census efforts on Innoko Refuge in 1994, 1996, 1998, 

and 2004 

Sources say moose are a recent immigrant to western interior Alaska. Local residents’ oral 

histories have reported moose were first observed in the vicinity of McGrath around 1900 (R. 

Collins, University of Alaska, Fairbanks, retired, personal communication, 2006) and along the 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-59 
Chapter 3: Refuge Resources 

Yukon River in the vicinity of Holy Cross, Anvik, and Grayling in the 1930s. However, earlier 

accounts place moose along the Yukon River, and presumably Innoko Refuge, much earlier. Lutz 

(1960) summarized the travels of Lavrentii Zagoskin along the Yukon and Kuskokwim rivers in 

1843 and 1844. Zagoskin recorded “large herds of caribou and moose on the Innoko River” (Lutz 

1960: 15). Zagoskin also recorded several Native words that Schott (1849; cited by Lutz 1960) 

reported as being related to moose. Raymond (1871; cited by Lutz 1960) reported that while 

moose were abundant on the upper Yukon River in 1869, they were rarely found down river of 

Nulato. Raymond (1873; cited by Lutz 1960) did note the occurrence of moose along the Anvik 

River, however. Nelson and True (1887; cited by Lutz 1960) reported claims of moose being 

observed in the vicinity of Anvik and Russian Mission in the 10 previous years (i.e., 1877 to 1887). 

It is unknown where the perception of recent immigration by moose into western interior Alaska 

originated. However, it is clear from these early writings that moose have been present in 

western interior Alaska and Innoko Refuge for more than 150 years. Kelsall and Telfer (1974) 

concluded that moose populations throughout their range in North America fluctuate dynamically 

in response to environmental changes. Therefore, it is not unreasonable that local fluctuations in 

abundance, and possibly localized extinctions, may have contributed to the perception of “recent” 

(i.e., within the last 80 years) colonization of moose in the Innoko Refuge region. 

Innoko Refuge staff have attempted to survey moose and estimate moose abundance for over 25 

years. This history of moose surveys on Innoko Refuge was reconstructed from files, unpublished 

data, and annual narratives on file at the refuge, and from Skinner et al. (1997). The first survey 

to examine winter moose numbers was in 1982. Surveys to estimate moose density on the refuge 

started in fall 1987. To facilitate surveys, the refuge was divided into north and south halves in 

1989. In the early 1990s, refuge staff worked to modify the way they estimated moose density on 

the refuge. Rather than attempt to count moose in a polygon delineated by creeks and ridges, the 

refuge counted moose along transect lines and developed a means to determine the number of 

moose not observed. 

Using the line transect method, the northern half of the refuge has been counted three times, 

while the southern half of the refuge has been counted twice. Figure 3-24 shows how the refuge 

was split in half for moose census efforts and the current count areas within each half. 

The count areas within each half have evolved with the development of the line transect method. 

These shifts in the boundaries of the count areas make it virtually impossible to examine changes 

through time for individual count areas; however, comparing census and density estimates within 

and between the north half and the south half of the refuge is very easy, as that boundary has not 

changed since 1989. Table 3-13 summarizes the estimated moose population for Innoko Refuge. 

The 2004 effort to census moose over the southern half of the refuge was cut short after only 

completing two of five count areas due to bad weather. The 2006 effort to census moose over the 

northern half of the refuge was not carried out due to inadequate snow cover during the time 

period of the census (i.e., late February–early March). 

Table 3-13. Moose population and density (moose/mi2) estimates for Innoko Refuge 

Half Year Population Estimate Density Estimate 

North 1994 1,235 0.37 

1998 2,085 0.63 

2002 1,725 0.52 

South 1996 2,086 0.74 

2000 1,960 0.69 

3-60 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Table 3-13 shows that there is a higher density of moose in the southern half of the refuge than 

the northern half. Survey data also suggest that for the floodplain along the Yukon River and 

along the Innoko River, there appears to be an increasing moose density as one travels from east 

to west. The densities found for Innoko Refuge (Table 3-13) are higher than the average density 

of 0.38 moose per square mile from 20 moose populations in Alaska and the Yukon territories 

(Gasaway et al. 1992) but within the range of 0.13–3.2 moose per square mile reported by Ballard 

et al. (1991) for 29 moose populations in Alaska. 

Since 1992, Innoko Refuge has conducted moose census and density estimation efforts in late 

winter (late February–early March). Conducting census efforts in late winter only allows for basic 

demographic information (i.e., calves and adults) to be collected in addition to the total number. 

Census estimation efforts in the 1980s were attempted at different times of the year, but fall was 

preferred. Conducting census estimation efforts in the fall also allowed refuge staff to obtain 

population composition (i.e., calves; cows; and small, medium, and large bulls) information. 

However, changing weather patterns in November have resulted in insufficient snow cover for 

counting moose and in unsafe ice conditions for landing ski planes. While the full demographic 

information available from fall census efforts is the most desirable for moose management, safety 

of survey crews is more important. Therefore, late winter surveys will continue to be conducted 

into the foreseeable future on Innoko Refuge. 

Fire history is one factor influencing the number of moose in an area. There are numerous 

scientific papers examining the benefits of wildfire to moose (e.g., Krefting 1974, Davis and 

Franzmann 1979). The manner in which fires benefit moose was summarized by Davis and 

Franzmann (1979) as: increased edge between habitats; increased forage quantity; and increased 

forage quality. A recent study of early winter moose distribution relative to landscape 

characteristics in interior Alaska indicated that the densest populations of moose occurred closer 

to towns, at moderate elevations, near rivers, and in areas where fire occurred 11–30 years prior 

(Maier et al. 2005). Moose distribution within the refuge generally aligns with these findings. 

Innoko Refuge teamed with ADF&G and BLM in the mid 1980s to radio collar moose along the 

Yukon River to study moose movements. In March 1986, 15 females and 20 males were captured 

between Holikichuk Slough and Holy Cross (Figure 3-25) and fitted with radio telemetry collars. 

The study found that one group of 6 females and 5 males spent all their time in the low elevation 

areas along the Yukon River, while another group of 5 females and 12 males spent the winters in the 

low elevation areas along the Yukon River but spent their summers in upper elevation areas of the 

Kaiyuh Mountains. Moose in this second group tended to move over much larger areas than moose 

in the first group. Moose that spent summers in higher elevation areas tended to occupy areas that 

had been affected by wildfires 30 or more years prior to the study, even though more recently 

burned over areas were available to them. Results from this study showed that about half of the 

cows that wintered in the low areas spent their summers there, while half moved into the mountains 

and spent time in old burned areas. It also appeared that most bulls left the low wintering areas for 

the mountains, selecting old burned areas as well. A few moose moved long distances between their 

winter and summer areas, but this appeared to be the rare exception and not the rule. During one 

summer, a large fire burned through an area occupied by some radio-collared moose. Relocations of 

those moose during and after the fire showed that the fire did not displace the moose; they avoided 

the main fire but returned to familiar sites once the fire had cooled down. 

No investigations of moose habitat have occurred within the refuge to date. There has been some 

work dealing with winter moose forage, however. The first was a series of investigations done in 

collaboration with ADF&G. This work involved systematically spaced transects running 

perpendicular to the river used to access the site. This intensive project was aimed towards 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-61 
Chapter 3: Refuge Resources 

identifying moose browse species on the refuge, twig size selection, and nutrition of selected browse 

species and twig sizes to develop a nutritional carrying capacity estimate for the refuge. This 

project identified 11 species used by moose (Table 3-14) and indicated that twig diameters of 0.1–

0.35 inches were the most preferred (Innoko Refuge files). Notes attached to data summaries 

commented on shifting consumption rates of browse species that appeared to be directly related to 

differing winter distribution of moose caused by different snow depths from one winter to the next. 

While numerous collections were made for nutrient analysis, this project was never completed. 

The other investigation on winter moose forage was a master’s level thesis completed by a refuge 

employee. Mallek (1999) examined how moose selected winter forage along the Innoko River, 

focusing on feltleaf willow and diamondleaf willow. While Mallek (1999) acknowledged that plant 

architecture is known to affect forage availability, none of the parameters he measured were found 

to be important. He did find that moose appeared to be more selective of the diamondleaf willow 

that were selected than those of the feltleaf willow. Mallek (1999) found that simple measures of 

stem presence and frequency of harvest by moose were inadequate to evaluate the availability of 

forage—much less estimate carrying capacity of an area for moose. 

As part of a larger effort, ADF&G conducted a browse survey in spring 2005 to determine the use of 

browse species in Game Management Unit (GMU) 21E, including a part of Innoko Refuge (T. 

Paragi, Alaska Department of Fish and Game, Fairbanks, personal communication, March 2007). 

This survey found that about 25 percent of the available browse had been removed by moose. More 

importantly, the survey found extensive stands of feltleaf willow in the Yukon River floodplain area 

that were created by extensive flooding (presumably by the Yukon River) in the 1960s. The stands 

of willow probably provided a very high amount of available forage to moose through the 1970s and 

likely into the 1980s. Much of these willow stands are now of a mature height that causes much of 

the forage to be out of reach of moose. The evolution of these large willow stands likely contributed 

to increased numbers of moose along the Yukon River in GMU 21E into the 1980s and to declining 

moose numbers from the 1990s to present. This finding also has implications for habitat 

management relative to moose. While the telemetry study found that older burned areas were 

important for summer use, wintering areas within the floodplain of the Yukon River (and 

presumably its larger tributaries) may be more important sites for habitat management. More work 

on moose habitat in general—and winter forage specifically—needs to be undertaken by the refuge. 

Table 3-14. Moose winter browse species used on Innoko Refuge 

Growth Form Common Name 

Tree Balsam poplar or cottonwood 

Quacking aspen 

Paper birch 

Tall Shrub Feltleaf willow 

Diamondleaf willow 

Bebb’s willow 

Littletree willow 

Sandbar willow 

Low Shrub Red-Osier Dogwood 

Highbush Cranberry1

Prickly Rose1

1

These plants are used but many are covered by snow in later winter and 

are therefore not available to moose for winter browsing. 

3-62 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Figure 3-24. Moose count areas 
Chapter 3: Refuge Resources

3-64 
Chapter 3: Refuge Resources 

Figure 3-25. 1986 Moose capture locations 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-65 
Chapter 3: Refuge Resources 

Caribou 

Historical information and numerous studies since 1965 in Alaska and Canada document wide 

fluctuations in caribou population size and distribution (Hinkes et al. 2005). Studies in Alaska and 

Canada have also shown caribou herds change their range and migration patterns on an annual or 

long-term basis; make extensive lateral shifts away from traditional migration routes; and 

sometimes join with other herds or split apart with unpredictable frequency (Hinkes et al. 2005). 

There are also indications that Alaskan and Canadian caribou herds peak every 60–90 years, or 

even longer, with each herd remaining at a relatively stable size during the intervening time 

periods (Haber and Walters 1980, Couturier et al. 1990, Hinkes et al. 2005). 

Dramatic fluctuations of caribou populations are not unique, as animal populations in northern 

latitudes undergo drastic fluctuations. Currently, one barren-ground caribou herd, the Beaver 

Mountain herd, utilizes Innoko Refuge. Some evidence indicates that portions of the western 

Arctic caribou herd have crossed the Yukon River onto the Innoko Refuge in the past. 

VanStone (1959; cited by Skoog 1968) noted that the Russian explorer Glazunov observed caribou 

crossing the Yukon River into and out of the highlands between the Norton Sound and the Yukon 

River in the fall of 1833; this is presumably the region between Kaltag and Holy Cross, which 

would include the Innoko Refuge area. Lutz (1960) summarized the travels of Lavrentii Zagoskin 

along the Yukon and Kuskokwim Rivers in 1843 and 1844 where Zagoskin recorded “large herds 

of caribou and moose on the Innoko River” (Lutz 1960:15). A study by Skoog (1968) contains 

comments from various explorers in the mid-1860s reporting large numbers of caribou crossing 

the Yukon River downstream of Nulato and the presence of over 4,000 calf caribou skins drying in 

a village near Anvik. Skoog’s study (1968) indicates that local residents reported caribou had 

reduced numbers since the introduction of firearms. Skoog (1968) speculated that caribou in the 

mountains separating the Yukon and Kuskokwim Rivers began to decline by the early 1870s 

according to records of caribou skin trading reported by Elliott (1875). Based on numerous 

records of the time, Skoog (1968) postulated that caribou numbers in western Alaska declined 

dramatically from 1875 through 1895. Dice (1921) reported observing numerous caribou trails in 

the Beaver Mountains in 1912 but noted that caribou were rare at that time. Various Alaska 

Game Commission reports cited by Skoog (1968) indicated that small scattered herds of caribou 

were present throughout the McGrath area in the 1920s. In 1931, a segment of the McKinley 

caribou herd was reported to have moved westward to the head of the Innoko River (Alaska Game 

Commission 1931; cited by Skoog 1968). 

Skoog (1963) is the first reference located that mentions the Beaver Mountain caribou herd by 

name; however, there was a note stipulating that the relationship between the various small 

caribou herds scattered throughout the Kuskokwim Mountains was unknown. The Beaver 

Mountain caribou herd was one of 11 herds specifically identified by Skoog (1968) as being present 

in Alaska—yet relegated to the status of a remnant herd, along with 2 others he classified as 

remnant herds. Pegau (1986) conducted a radio telemetry study in the early 1980s and did not 

find any range overlap with the nearby Sunshine Mountains caribou herd. Numerous ADF&G 

survey-inventory reports identified the Beaver Mountain caribou herd as a distinct herd from the 

1980s to the present. By fall 2000, ADF&G was recognizing 32 caribou herds in Alaska (Alaska 

Department of Fish and Game 2001). 

The range of the Beaver Mountain caribou herd has been described in various reports. The best 

consolidated description of the overall range of the herd is the Iditarod River and Iditarod lakes to 

the west and northwest, the Innoko River to the north, the Dishna River to the northeast, the 

Beaver Mountains in the east, and Horn Mountain near Red Devil to the southwest (Pegau 1986, 

Boudreau 2001) (Figure 3-26). Calving areas have consistently been described as the foothills on 

3-66 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

the northwest end of the Beaver Mountains and within the Beaver Mountains. Summering areas 

have been described as “throughout the herd’s range” (Boudreau 2001:117). Wintering areas have 

been described as the north side of the Kuskokwim Mountains, the Iditarod lakes, the Iditarod 

River, and Dishna River. Incidental observations from refuge staff have reported caribou 

consistently in the vicinity of the Innoko–Iditarod River confluence in July and on the ridge that 

separates the Iditarod and Dishna rivers in fall and winter. It is not uncommon for hunters on the 

refuge to harvest caribou during September. 

The Beaver Mountain caribou herd was estimated to contain 3,000 individuals in 1963 (Skoog 1963); 

this estimate was revised down to 2,000 in 1970 (Davis 1978). Shepherd (1981) later revised the size 

of the Beaver Mountain caribou herd to less than 1,000 individuals based on aerial surveys in 1980. 

This is in contrast to the report by Pegau (1986), who believed that the Beaver Mountain caribou 

herd declined considerably during 1983 and 1984 because he only observed 879 caribou during 

surveys in 1985. He commented that previous estimates for the herd were listed at 1,000–2,000 but 

did not provide any references for those values. Whitman (1995) estimated the Beaver Mountain 

caribou herd at only 536 in 1994, again based on an aerial survey that counted 429 caribou. In 1995, 

Whitman (1997) only observed 400 caribou. In July 1999, Boudreau (2001) observed a single group 

of 129 caribou. Based on an aerial survey in June 2001 that located over 140 caribou in two groups, 

Boudreau (2005) estimated the current size of the Beaver Mountain caribou herd at 150–200. The 

latest aerial survey (June 2007) in the Beaver Mountains counted only 23 caribou (R. Seavoy, 

ADF&G Area Biologist, McGrath, personal communication, August 2007). 

Population estimates for the Beaver Mountain caribou herd in the 1960s and 1970s appear to be 

rough estimates based on information obtained from a number of sources rather than directed 

efforts to estimate the herd size. Pegau’s work in the 1980s was the most directed effort ever 

expended on this herd. Efforts to assess the size of the herd in the 1990s and later were 

concentrated on the areas described by Pegau as being typically occupied during June. These 

efforts were hampered by the lack of radio telemetry collars in the herd. Therefore, if the Beaver 

Mountain caribou herd had shifted its seasonal use areas, as has been described for a number of 

caribou herds in Alaska (Hinkes et al. 2005), an unknown proportion of the herd may have been 

missed. In a similar fashion, typical use areas were surveyed to obtain basic calf production and 

survival estimates, which have been described in various annual reports as very good to poor, 

depending on the year. 

Since 1998, the management objective for the Beaver Mountain caribou herd has been to increase 

the herd size to 1,200–1,500 individuals (Alaska Department of Fish and Game 1998). Numerous 

comments are made in annual reports that while no forage studies have been conducted, adequate 

forage exists for increased numbers of caribou. Additionally, no landcover map exists for most of 

the area used by the Beaver Mountain caribou herd. 

Little work has been expended on the Beaver Mountain caribou herd over the years that would 

enable managers to have a good understanding of its movements, seasonal use areas, or 

population dynamics. 

Bears 

Innoko Refuge provides a mix of important habitats for both brown (grizzly) and black bear. 

Despite the black bear being specifically identified by Congress as a purpose for creating the 

refuge, little is known about the size of populations within the refuge; both species are considered 

common, however. Based on incidental observations, black bears appear to be somewhat limited 

in their distribution on the refuge, being generally absent from the more open wetland and tundra 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-67 
Chapter 3: Refuge Resources 

Figure 3-26. Approximate Distribution of the Beaver Mountain Caribou Herd 

3-68 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

dominated areas, and more abundant in forest dominated areas. In contrast, brown bears appear 

to be distributed throughout the entire refuge. 

Estimates of bear numbers on the refuge are not available. Information from village residents 

and incidental observations by refuge staff comprise the extent of our knowledge about bears. 

Wolf 

Besides black and brown bears, Innoko Refuge supports a wide variety of other carnivores (see 

appendix G). Unlike many refuges and parks outside of Alaska, natural predator-prey 

relationships are intact within the refuge. Bears and wolves generally receive the most public 

attention; this is likely due to their rarity in many areas of the United States, their role as symbols 

of wilderness, and their effect on ungulate populations. Little inventory work has been done on 

carnivores due to the difficulty and expense of surveying these species. Techniques used for 

surveying wolves and other larger carnivores include radio telemetry and aerial surveys of winter 

tracks, each of which is expensive and difficult. Results are highly dependent on snow (cover and 

age) and light conditions, expertise of surveyors, and the number of animals within the survey 

area boundaries during the survey.

The wolf density for GMUs 21A and 21E were estimated to be 22.3 and 30.1 wolves per 1,000 

square miles, respectively, in fall 2002 (Szepanski 2003). ADF&G management objectives for 

wolves in GMU 21A and 21E are to provide a sustained annual harvest rate of up to 30 percent 

from the combined area, except where greater harvest rates are mandated by approved wolf 

predation control plans (Szepanski 2003). Studies on other interior refuges of winter and summer 

wolf predation found moose were a major component of the year-round diet. Moose calves were 

taken more often during summer, whereas more adults than calves were consumed during winter 

months (Tetlin National Wildlife Refuge 1987, Doyle et al. 1988). However, the effect and 

proportion of moose mortality attributable to wolf predation on the Innoko Refuge is unknown. 

Harvest of wolves from the area, including the refuge, has been quite variable through time, 

ranging from 14 to 78 from 1985 through 2002 (Szepanski 2003). Wolf harvests were reported to 

have declined beginning in 1967 after the loss of bounties on wolves. The Federal Airborne 

Hunting Act of 1972 then eliminated the common practice of shooting wolves from airplanes. 

However, ADF&G issued aerial shooting permits to members of the public until 1983 (Szepanski 

2003). Several residents of McGrath have commented on their previous aerial shooting activities 

of wolves in the area where the refuge currently exists. Today, the price received for marten fur 

is believed to be the single largest influence in wolf trapper activities both on and adjacent to the 

refuge—the higher the price, the more people participate in trapping activities and the more 

wolves are caught due to active trappers (R. Seavoy, ADF&G Area Biologist, McGrath, personal 

communication, April 2007). 

Lynx 

The abundance and distribution of lynx populations are affected primarily by natural cycles of 

their primary food source—snowshoe hares (see the snowshoe hare discussion later in this 

chapter). Based on harvest data and comments from area trappers, Stout (2004) identified peaks 

in the lynx population cycle in 1990–1991 and 2000–2001. If trapping records accurately portray 

the population cycles, the population was at its lowest point during the winter of 1995–1996 (Stout 

2004). The time between population highs in GMU 21 appeared to be in time with the typical 10-

year cycle of snowshoe hares and lynx. This is in contrast to eastern interior Alaska, where 

snowshoe hare and lynx numbers appear to have increased during the winters of 1990–1991 and 

1991–1992, then again during the winters of 1997–1998 and 1998–1999, earlier than expected 

(Gardner 2001b). 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-69 
Chapter 3: Refuge Resources 

While no studies of lynx have been carried out on Innoko Refuge, observations of lynx and their 

tracks are made each winter. On Tetlin Refuge, a radio telemetry study found that lynx preferred 

broadleaf and mixed forests and avoided dwarf shrub/tundra habitats (Perham 1995). A study on 

Nowitna Refuge found that lynx were more abundant in an area that had burned 25–27 years 

previous to the study than in a mature (i.e., more than 100-year-old) needleleaf forest or an area that 

had burned 6–8 years previously. The study also found that ridges were favored travel locations by 

lynx. The moderate-aged, burned-over area and ridges also corresponded to areas with the greatest 

amount of brush cover, preferred habitat for snowshoe hares (Johnson et al. 1995). 

Other Carnivores 

Wolverine are distributed throughout all of GMU 21, but no effort has been made to assess 

relative abundance. Incidental winter observations indicate that wolverine may be more locally 

abundant in the hilly regions of the refuge than in other areas of GMU 21E. Stout (2001, 2004) 

reported stable wolverine populations throughout GMU 21 from 1997 through 2003. 

Marten are found throughout the refuge where suitable habitat exists. Incidental winter 

observations indicate that tracks are abundant in both open and closed needleleaf forest areas. A 

radio telemetry study conducted on Nowitna Refuge looked at marten use of areas affected by 

wildfire. While the study could not account for severity of the fires, it revealed that marten were 

much more abundant in a burned area 6–8 years old than a burned area 25–27 years old, but less 

abundant than in mature (i.e., more than 100 years old) needleleaf forests (Johnson et al. 1995). 

Marten are an important trapping species in the region; however, depressed fur prices have kept 

trapping interest down until recently. Throughout GMU 21, the estimated marten harvest 

between the winters of 1992–1993 and 2002–2003 was reasonably steady except for a peak in the 

winter of 1996–1997, a year of higher than average fur prices. 

River otter are found throughout the refuge but appear to be more numerous along smaller 

streams than along the larger rivers. Very little is known about river otter on the refuge. 

Incidental winter observations of access holes, tracks, and slides include a wide variety of habitat 

types. Even less is known about mink on the refuge other than they are observed along smaller 

streams throughout much of the refuge. 

Red fox appear to be abundant and widely distributed throughout most of the refuge. Coyotes 

have been reported in very low numbers in GMU 21. While their presence on the refuge is 

suspected, no observations have been made to date. Refuge staff is interested in attempting to 

monitor when coyotes appear on the refuge and—should they establish themselves—how their 

establishment affects the red fox population. However, given the apparent abundance of wolves 

on the refuge, it is unlikely that a large coyote population will become established in the 

immediate future. 

The smallest carnivore on the refuge, and the smallest member of the carnivore order, is the least 

weasel. The least weasel preys primarily on lemmings and voles, but has been known to take 

small hares as well (Fagerstone 1987); therefore, cover and abundant prey are the driving factors 

behind the abundance and distribution of least weasels on the refuge. 

Rodents 

The beaver is the largest rodent on the refuge and is an important furbearer as well. Beaver, and 

evidence of their presence, are frequently observed on and around lakes, streams, and sloughs 

within the refuge. They are trapped by local residents for food, and fur and can be a significant 

component in the diet of wolves, particularly during snow-free periods (Peterson 1977). Beaver 

(Figure 3-27) play a large role in shaping the hydrologic features and habitats of the refuge. Their 

3-70 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

activities increase habitat diversity by changing flow patterns and creating impoundments where 

lake habitats develop. Beaver also influence the structure and composition of terrestrial vegetation 

by foraging on shrubs and felling trees. Beaver dams can restrict fish movement during periods of 

low flow (Figure 3-28). This has generated concern about the disruption of normal fish movements 

(Andersen and Fleener 2001). Though dams may restrict fish movement at times, beaver ponds 

provide stable rearing habitat for juvenile fish (Snodgrass and Meffe 1999, Brown and Fleener 

2001). In the Black River drainage of interior Alaska, Brown and Fleener (2001) found that juvenile 

northern pike, humpback whitefish, least cisco, and broad whitefish were found only in habitats 

created by beaver dams, while adults were found in both these and flowing water habitats. They 

also found that relative fish abundance was greater in lake habitats, and seasonal high flows 

provided opportunities for fish to move over beaver dams. Older, more stable beaver ponds were 

found to provide high quality breeding habitat for wood frogs (Stevens et al. 2006). 

Figure 3-27. Adult beaver carrying a willow back to a cache. (Photo S. Hillebrand, USFWS) 

Figure 3-28. Typical beaver dam on a smaller stream. (Photo USFWS) 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-71 
Chapter 3: Refuge Resources 

While other refuges have attempted to monitor beaver populations by counting or estimating the 

total number of active lodges, Innoko Refuge has not done so to date. The logic for counting or 

estimating the total number of active lodges is very sound because if beaver use habitat as a unit, 

density of active lodges should be an accurate indicator of habitat quality (Slough and Sadleir 

1977). However, population size can vary dramatically while the overall number of active lodges 

remains stable (Bergerud and Miller 1977, Swenson et al. 1983). Innoko Refuge hopes to begin 

estimating the number of beaver in the near future through a combination of estimating the total 

number of active beaver lodges with caches of various sizes once pilot studies have assessed how 

to correlate cache size to number of beaver occupying an active lodge. 

Muskrat is another furbearer that is important to some trappers but does not appear to be an 

important furbearer to subsistence users of the Innoko Refuge. Muskrat, and evidence of their 

presence, are not widely observed on Innoko Refuge. Stout (2001) reported muskrat numbers 

declining in the late 1990s throughout GMU 21 and remaining low during the 2000–2003 period 

(Stout 2004). Reasons for the low numbers of muskrat on the refuge are unknown and have not 

been investigated. 

While 15 species of voles, lemmings, and mice are known or suspected to occur (appendix G), little is 

known about the distribution and abundance of small mammal species that occur on Innoko Refuge. 

Only one limited project on small mammals has been conducted on the refuge, which confirmed the 

presence of two vole species and one lemming species (appendix G). Small and medium-sized 

mammals such as voles and snowshoe hares are the prey base for a wide variety of avian and 

mammalian predators. Krebs (2001) found that, in terms of biomass, snowshoe hares, squirrels, 

mice, and voles comprised a much greater percentage of herbivore biomass than moose in the 

Kluane ecosystem of the Yukon Territory. A similar relationship likely exists on this refuge. 

Foraging, seed caching, and fertilization through fecal deposition by these herbivores also shapes 

their habitat, but the effects of their dietary habits on the ecosystem are poorly understood. 

Yellow-cheek voles form colonies in burned areas in the boreal forest but are not commonly seen 

in high densities in undisturbed habitat. In terms of biomass, black spruce habitat supported 

more yellow-cheeked voles (approximately 4.5 pounds per acre) than upland spruce/birch forest 

(Rexstad 2003). This estimate of biomass per unit area is roughly equivalent to biomass estimates 

of moose in the Tanana River floodplain (Flora 2002), again emphasizing the importance of small 

mammals as a prey base and the role of fire in creating habitat and species diversity. 

Lagomorphs 

The refuge has only one lagomorph—the snowshoe hare. Snowshoe hares are an integral part of 

the boreal ecosystem. Hare population densities are cyclical across boreal North America over an 

8–11 year period (Keith 1963, Krebs et al 1986, Keith 1990), with amplitudes of 5–25 fold (Hodges 

2000). Hares are an important food item for a variety of terrestrial and avian predators (Keith 

1990, Hodges 2000) and hare densities can greatly influence production and recruitment of a 

variety of species—the best known of these being lynx (Keith 1963, Brand and Keith 1979). Hare 

densities are also positively correlated with other species such as spruce grouse, willow 

ptarmigan, and arctic ground squirrel (Boutin et al. 1995). Great-horned owl and northern 

goshawk production and densities are also strongly influenced by hare density (McInnaville and 

Keith 1974, Keith et al. 1977, Boutin et al. 1995, McIntyre 1995). Other species such as wolves, red 

fox, marten, and red-tailed hawks may be less dependent on hares, but use likely increases during 

cyclic highs (Wolff 1980, Todd et al. 1981, Carbyn 1987). 

From 1960 through 2000, the snowshoe hare cycle has been largely synchronous across Canada 

and into Alaska (Hodges 2000). Cyclic peaks occurred roughly at the turn of each decade 1960–

3-72 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

1961, 1970–1971, 1980–1981, 1990–1991, with lowest densities typically occurring three years later 

(1963–1964, 1973–1974, 1983-1984, 1993–1994) (Hodges 2000). However, speculation exists about 

differences within interior Alaska (Paragi 1999, Gardner 2001b, Stout 2004). 

The close correlation between population densities of hares and other boreal forest fauna, and the 

predictable hare cycle, suggests monitoring hare populations can provide predictive information 

for other species. Tetlin Refuge has conducted hare pellet counts annually since in 1990. Kanuti 

Refuge infers their hare numbers from track counts and browse survey work conducted by the 

National Park Service in Wiseman. 

Insectivores 

In North America, the order of insectivores is represented by two families, only one of which is 

found in Alaska. Shrews are the smallest mammals in the world. They are characterized by 

having long pointed snouts, short velvet-like fur, minute black bead-like eyes, and short legs 

(Banfield 1974). As mentioned, small mammal studies on Innoko Refuge have been limited to a 

single project, which confirmed the presence of four species of shrews on the refuge—common 

shrew, dusky shrew, tundra shrew, and pigmy shrew. Innoko Refuge is within the known 

distribution of two other shrews (appendix G). 

3.3.2.5 Non-Native Invasive Insects 

The potential for invasive insects to have a major adverse affect on the forest health on Innoko 

Refuge is very real. Refuge staff has been working with the U.S. Forest Service, Forest Health 

Division, in monitoring several study plots on the refuge. Problem insects range from non-native 

insects to those that are native to North America but are increasing their range, possibly due to 

climate changes.

Several insect species have been negatively affecting the larch population on the refuge and in 

some localized areas, removing the larch component from the forest. These insects are the larch 

sawfly (Pristiphora erichsonii) and the eastern larch beetle (Dendroctomus simplex). Other 

species of insects that are either currently on the refuge or could have a devastating effect on the 

refuge’s ability to meet our goals are the spruce budworm (Choristomeura fumiferana, C. orae, 

and C. biennis), willow leaf miner (Micrurapteryx salicifoliella), and aspen leaf miner 

(Phyllocnistis populiella). Willow leaf minder is found on other refuges in interior Alaska with 

negative effects on the willow population, which, in turn affects beaver and moose populations. 

In August 2000, the refuge and the U.S. Forest Service established two permanent study plots near 

the refuge administrative site to document larch mortality rates. When the plots were established, 

trees were noted as currently being attacked by larch sawfly. From August 2000 through August 

2007, 87 percent of the marked trees died due to larch sawfly and/or eastern larch beetle attacks. 

Beginning in 1989, the U.S. Forest Service and the Alaska Department of Forestry conducted 

aerial surveys across Alaska to map the distribution and extent of various forest insects and 

disease. The exact area surveyed has varied from year to year, particularly in the area of the 

refuge. However, these surveys have detected alder defoliation, cottonwood defoliation, ips 

engraver beetle, larch sawfly, spruce bark beetle, willow leafblotch miner, and willow defoliation 

(USDA Forest Service 2002, USDA Forest Service 2005) on and in the vicinity of the refuge. 

3.3.2.6 Threatened, Endangered, and Sensitive Wildlife 

At this time, there are no Federally listed threatened or endangered plants or animals on Innoko 

Refuge. The American race of the peregrine falcon was delisted (removed from the endangered 

species list) in 1999 but remains a species of concern (U.S. Fish and Wildlife Service 2002). 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-73 
Chapter 3: Refuge Resources 

Peregrine falcon nests have been found on cliffs above the Innoko River and Yukon River; 

however, the nests along the Yukon River are outside the Innoko Refuge boundary. Arctic 

peregrine falcons, which migrate through the refuge, were delisted from threatened status in 

1994. Though gray wolves and grizzly bears are listed as Endangered or Threatened in the 

contiguous U.S., they are not listed as such in Alaska (50 CFR 17.11 and 17.12). 

The U.S. Fish and Wildlife Service (2002) identified species, subspecies, and populations of 

migratory birds that are of conservation concern (formerly Category 2 Species under the 

Endangered Species Act). This designation indicates that there is significant concern about the 

species but insufficient data for listing as Threatened or Endangered; without additional 

conservation actions, these species are likely to become candidates for listing under the 

Endangered Species Act. While eight species of conservation concern were identified for the 

northwestern interior forest region, only the peregrine falcon is known to breed on the refuge. 

The State of Alaska has also identified species and subspecies of fish and wildlife native to Alaska 

that have entered a long-term decline in abundance or are vulnerable to a significant decline (Alaska 

Department of Fish and Game 2006a). Vulnerability to decline includes low numbers, restricted 

distribution, dependence on limited habitat resources, and/or sensitivity to environmental 

disturbance. On Innoko Refuge, identified Species of Special Concern include peregrine falcon, 

olive-sided flycatcher, gray-checked thrush, Townsend’s warbler, and blackpoll warbler. 

Boreal Partners in Flight developed a list of priority landbird species breeding in each 

biogeographic region in Alaska (Boreal Partners in Flight Working Group 1999). The rankings 

are based on species abundance in North America, the degree to which breeding and wintering 

distributions are restricted and threatened, the proportion of the species’ range occupied by the 

bioregion, and population trends. Of the 19 priority species that occur in the central Alaska region, 

11 breed on Innoko Refuge: great gray owl, boreal owl, black-backed woodpecker, olive-sided 

flycatcher, Hammond’s flycatcher, gray-cheeked thrush, varied thrush, Townsend’s warbler, 

blackpoll warbler, rusty blackbird, and white-winged crossbill. 

Great grey owls occur in low densities in needleleaf and mixed needleleaf-deciduous forests with 

open areas for foraging. Boreal owls appear to prefer closed canopy needleleaf forests but are also 

common in mixed needleleaf-deciduous forests. The black-backed woodpecker occurs in needleleaf 

forests with many dead or dying trees. It can be found in high densities in burns. The olive-sided 

flycatcher occurs in mature spruce forests associated with habitat edges, in burns, and in riparian 

areas. Hammond’s flycatchers are most commonly associated with mature stands of deciduous 

forests, especially pure stands of aspen, with open areas of four acres or more. The gray-cheeked 

thrush is found in a variety of habitats: willow and alder thickets in lowland, upland, and subalpine 

areas; upland and riparian deciduous forests; needleleaf forests; and needleleaf-deciduous 

woodlands. The varied thrush is found both in thick riparian habitats and closed mixed needleleafdeciduous forests. Townsend’s warblers select mature needleleaf forests for nesting; white spruce 

appears to be an important component to site selection. Blackpoll warblers (Figure 3-29) select a 

variety of habitats but are commonly associated with tall shrubs in riparian areas, needleleaf forests, 

deciduous forests, and woodlands. Rusty blackbirds are frequently found in a wide variety of waterassociated habitats, including fens, alder-willow thickets and bogs, muskeg, beaver ponds, tall 

riparian shrub, swampy shores of lakes and streams, and other forest openings such as those 

created by fire, windthrow, and beaver activity. White-winged crossbills prefer closed needleleaf 

forests of white spruce but are also found in needleleaf forests dominated by black spruce and larch. 

While the Alaska Natural Heritage Program identifies 363 rare or sensitive plant species and 

subspecies (Limpkin 2007), the likelihood that any exist on Innoko Refuge is low (S. Talbot, 

Regional Botanist, USFWS, Anchorage, AK, personal communication, March 2007). 

3-74 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Figure 3-29. The blackpoll warbler is on the list of “Species of Special Concern” by the State of Alaska and is a priority species for 

conservation by the Boreal Partners In Flight (2006). (Photo USFWS) 

3.3.3 Concerns Regarding Fish, Wildlife, and their Habitats 

3.3.3.1 Climate Change 

Global climate change models are in agreement that boreal zones may experience temperature 

increases up to 40 percent greater than the global mean (IPCC 2007). A contributor to more 

pronounced warming at northern latitudes is ice-albedo feedback, when areas previously covered 

by highly reflective ice and snow are replaced by a darker surface (ocean or land) that absorbs 

more of the sun’s energy, and leads to more warming and more melting—a positive feedback 

(Winton 2006). Minimum temperatures are increasing at about twice the rate of maximum 

temperatures, leading to longer freeze-free periods and a 10 percent decrease in snow cover and 

ice extent at northern latitudes (Walther et al. 2002). The climate in Alaska has warmed by about 

four degrees Fahrenheit since the mid-1950s, including a seven-degree Fahrenheit increase 

during winter in interior Alaska (Parson et al. 2001). Climate models project that the greatest 

warming will continue to occur in the arctic region (Parson et al. 2001). Data indicate that arctic 

summers are now warmer than at any other time in the last 400 years (Overpeck et al. 1997) and 

that the snow-free period is lengthening (Chapin et al. 2005). A warming climate will have 

numerous effects on habitat, hydrology, and species occurrence that could fundamentally change 

the boreal forest as we know it (Chapin et al. 2005, Hinzman et al. 2005). 

Effects of climate change are likely to include declines in snow cover. Documented changes in 

boreal regions include increases in permafrost degradation, growing season length, and 

productivity, and changes in precipitation patterns. Global climate change models predict the 

boreal region will experience a decline in wetlands, increased fire frequency and intensity, shifts in 

the distribution and composition of plant communities, changes in phenology, changes in the 

ranges and breeding behavior of wildlife species, increased likelihood for invasive plant 

establishment, and increased possibility of wildlife disease and insect outbreaks. These changes in 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-75 
Chapter 3: Refuge Resources 

habitat and wildlife due to climate warming will, in turn, affect the arctic and subarctic people who 

rely on natural resources for food, fur, and cultural identity. 

Changes in wetlands are of particular concern due to their predominance within the refuge, their 

contribution to biodiversity, and their importance to numerous fish and wildlife species. Research 

and monitoring efforts can help determine the extent of climate-related changes on the refuge. 

Since changes occur on a much broader scale on the refuge, the most appropriate role for the 

refuge in these investigations is likely to participate in larger, landscape-level efforts to monitor 

climate change and its effects on wildlife and habitats. Though there may be little that refuge 

staff can do to mitigate these changes, awareness of their long-term effects may result in 

reprioritization of issues and changes in management strategies. Communication with resource 

users regarding evolving information about environmental changes and discussion of potential 

management approaches will be increasingly important as conditions change. 

Wetland Drying

The northwest boreal zone of North America receives relatively little precipitation, and the 

abundant wetlands result largely from cool, short summers with low evapotranspiration and an 

impermeable permafrost layer that prevents infiltration and impedes drainage of the upper 

unfrozen layer (Ford and Bedford 1987). Climate warming of the magnitude already observed in 

the boreal region has increased growing season length by eight days since 1988 (McDonald et al. 

2004). Widespread melting of permafrost, which has already been documented (Osterkamp and 

Romanovsky 1999, Jorgenson et al. 2001), and increased evapotranspiration result in fewer, more 

nutrient-rich wetlands (Rouse et al. 1997, Klein et al. 2005, Smith et al. 2005). Nutrients are 

concentrated as wetlands dry (lose water volume); and as permafrost underlying wetlands and 

adjacent uplands melts, rates of nutrient mineralization and leaching into surface waters increase. 

Resulting changes in trophy may cause major shifts in wetland community structure (Bayley and 

Prather 2003). 

Climate also affects the timing of important life history events. In a review of phenological shifts, 

62 percent of 677 species showed trends toward spring advancement (Parmesan and Yohe 2003). 

If different species show unique responses to changing temperature, their interactions with other 

species may be altered (Winder and Schindler 2004). In a study of loss of surface area from closed 

basin wetlands from 1950 through 2002, Riordan et al. (2006) analyzed over 10,000 wetlands across 

nine study sites throughout Alaska. The highest percent surface area loss (31 percent) 

documented was on the Kaiyuh Flats 25 miles north of Innoko Refuge. These changes occurred 

despite the absence of a significant trend in the amount of total annual precipitation recorded at 

nearby weather stations. The authors believed that the following factors contributed to the 

observed changes in wetlands: increased loss of water due to evaporation and transpiration by 

plants caused by warmer, longer growing seasons; melting permafrost under lakes that allows 

lakes to drain; and increased incidence of wildfire that accelerates warming of permafrost. Sites 

on Innoko Refuge will be included in a follow-up study to the Riordan et al. (2006) analysis of 

closed basin wetlands. The objectives of this follow-up project conducted by researchers from the 

University of Alaska at Fairbanks will be to fully characterize the heterogeneity in the magnitude 

and rate of lake drying in Alaskan refuge wetlands; identify differential characteristics of lakes 

that are drying and those that are not; estimate whether change in total surface water area in 

wetlands (open and closed-basin lakes) occurs at the same rate of decline as for closed-basin lakes; 

and assess the influence of fire on lake drying in refuge wetlands. 

3-76 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Fire Frequency and Intensity 

Forest fire frequency and intensity have increased markedly, and the average area of Alaskan 

boreal forest burned annually has more than doubled since 1970. After severe fire, organic soil 

may be completely consumed, exposing the underlying mineral soil and resulting in rapid 

degradation of permafrost (Yoshikawa et al 2003). As the unfrozen “active layer” becomes 

thicker, subsurface drainage increases leading to soil drying and a change in post-recovery 

vegetation compared to the pre-fire vegetation. In boreal ecosystems, future increases in air 

temperature may lengthen the fire season and cause an increase in the frequency, extent, and 

severity of fires; a reduction in mean fire return intervals; and a shifting of age class distributions 

towards younger forests (Stocks et al. 2000, Gillett et al. 2004, Soja et al. 2007). 

Insect Disturbance 

Increased insect disturbance is also associated with warming trends in interior Alaska, with 

warmer temperatures leading to both accelerated insect development times and increased tree 

vulnerability through moisture stress. Climate-warming trends recorded throughout Alaska 

during the last two decades correlate with spruce bark beetle infestation increases during the 

same period (Parson et al. 2001). Significant increases in conifer defoliator activity (spruce 

budworm, coneworm, and larch sawfly) in the interior boreal forest have occurred during this 

period as well (Werner et al. 2006). 

3.3.3.2 Invasive Species 

Although only five invasive plant species have been identified within the refuge, there is concern 

that the number of invasive species and number of infested sites may expand. Lambsquarter was 

only recently discovered on the refuge. It readily invades open, disturbed sites such as sandbars 

and gravel bars along rivers. There is concern that burns may provide similar habitat. 

Lambsquarter can form dense colonies that can out-compete shade intolerant native species. 

Lambsquarter can be removed by mechanical means (pulling, cutting), but several attempts may 

be needed for eradication, as seeds remain viable in the soil for up to 40 years (Royer and 

Dickinson 1999), so post-treatment monitoring is necessary long after the plant is removed. 

Pineappleweed also readily invades disturbed sites but will invade sites with as little disturbance 

as trampling of existing vegetation. It is often found on compacted soils. The seeds are gelatinous 

when wet, allowing them to be easily transported by humans and animals. Pineappleweed can 

easily be removed through pulling; however, repeated treatments over following years will likely 

be required. 

Common plantain is common in highly disturbed sites. It is an alternate host for a number of 

viruses that infect cultivated crops, as well as serving as larval food for leaf miners (Sagar and 

Harper 1964). As common plantain is an early pioneer species, there are concerns that it may 

alter successional regimes where it establishes itself. The seeds remain viable in the soil for up to 

60 years (Royer and Dickinson 1999), and it readily re-emerges on sites that are redisturbed. 

Because of this characteristic, there is concern this species might spread into areas prone to 

repeated burning by wildfires. Common plantain is easily controlled through pulling; however, 

several attempts may be necessary to eliminate germinating plants from seed or root fragments. 

It is also easily controlled with chemical treatment (Rutledge and McLendon 1996). 

Common chickweed is able to create dense mats that shade young seedlings of other plants 

(Turkington et al. 1980). Common chickweed occurs and persists on disturbed lands with both 

continued or periodic soil disturbances. Fortunately, chickweed is relatively quickly replaced by 

perennial plants if the disturbance ceases (Sobey 1981). Like common plantain, common 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-77 
Chapter 3: Refuge Resources 

chickweed is easily controlled by mechanical means, but removal of all plant fragments is critical. 

Common chickweed can be controlled by some chemicals, as well as allowing native perennials to 

become re-established (Sobey 1981). 

While annual bluegrass often forms dense mats that can reduce nutrient availability, it generally 

does not compete well with established plants. Annual bluegrass is considered a pioneer species 

and may limit colonization by native species. Results from field experiments suggested that native 

seed germination and survival is reduced by the presence of annual bluegrass litter (Bergelson 

1990). Annual bluegrass appears to persist on sites that are kept open by trampling activities. 

Mechanical treatment appears to be largely ineffective due to the repeated applications required; 

chemical treatment is generally done, but no chemicals are currently specific to annual bluegrass. 

The Alaska Natural Heritage Program (2006) ranks invasive species on a scale of 0–100, with 100 

having the highest risk in terms of threat to natural communities, biological characteristics, 

dispersal ability, distribution and abundance, and feasibility of control. Table 3-15 lists the five 

invasive species known on Innoko Refuge and their threat scores. 

Invasive, non-native insects (i.e., larch sawfly and eastern larch beetle) are already negatively 

affecting larch on the refuge. The spruce budworm and leaf miners are of great concern for their 

ability to alter plant community composition. Any changes in plant communities affected by 

insects, and potentially exacerbated by climatic changes, could cause significant changes in animal 

communities on the refuge. 

Table 3-15. Threat ranking of invasive plant species known on Innoko Refuge. Threat ranking from the Alaska Natural Heritage 

Program (2006). See appendix G for scientific names. 

Common Name Threat Rank 

Pineappleweed 32 

Lambsquarter 35 

Common chickweed 42 

Common plantain 44 

Annual bluegrass 46 

3.3.3.3 Forest Defoliators 

In addition to the invasive non-native insects affecting needleleaf trees, deciduous trees, and tall 

shrubs, leaf blotch miners (Phyllocnistis populiella and P. ontario) and willow leaf miners 

(Micrurapteryx salicifoliella) are also a concern. Leaf blotch miners can attack aspen, 

cottonwood, paper birch, and green alder, while willow leaf miners attack all the willow species 

found on Innoko Refuge except feltleaf willow. Repeated heavy attacks on the same tree will 

cause reduced overall growth of the tree and branch dieback (Holsten et al. 2001). In response to 

the larch sawfly evaluation and re-evaluation on the Innoko Refuge (Kruse and Patterson 2007), 

refuge management plans to continue collaborative monitoring of various forest insects and 

disease by aerial and ground techniques. 

3.3.3.4 Mineral Extraction 

Ricketts et al. (1999) identified mining as a major ecoregional threat. Commodity prices in world 

markets have been very strong for base and precious metals, spurring a boom in mineral 

exploration in interior Alaska that is expected to continue as very strong economic growth in Asia 

spurs demand. There are approximately 30 active mining claims within the Innoko Refuge 

watershed. Specific concerns related to mining for fish and wildlife conservation include the 

3-78 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

disposal of millions of tons of mine waste (tailings) laced with heavy metals and chemicals such as 

cyanide; transportation and redistribution of metals and increased turbidity in rivers; loss of 

upland habitat from road building and staging areas in support of mining; and the effects of 

emissions from processing plants (see Environmental Contaminants, Minerals, and Water Quality 

sections in this chapter). 

3.3.3.5 Wildlife Disease 

Epizootic episodes are always a concern for fish and wildlife managers. Current concerns for 

avian diseases centers on the Asian strain of avian influenza and West Nile virus. As highly 

pathogenic Asian H5N1 avian influenza has spread across Asia and into Africa, interest has arisen 

in the role of wild migratory birds as carriers of the virus. Because several bird species that breed 

at northern latitudes migrate between Alaska and Asia, Alaska has been identified as the most 

likely site for the first appearance of Asian H5N1 in North America in wild birds. 

West Nile virus is a potentially fatal human disease transmitted by mosquito (and other bloodsucking arthropods) bites. Birds serve as an intermediate reservoir for the virus and have been 

affected by large scale die-offs. At least 317 different bird species in North America have been 

found to harbor the virus, many of which migrate to Alaska. To date, West Nile virus has not been 

detected in Alaska, but it remains a disease of considerable concern to wildlife managers in Alaska. 

Brucellosis is an important zoonotic disease, widely distributed in a variety of terrestrial wildlife 

species. Infection localizes in the joints and reproductive tract and usually leads to abortion in the 

host. Brucellosis has been reported in bison, caribou, muskox, and moose. Predators such as 

bears and wolves are exposed when they feed on infected caribou. In the Innoko region from 1975 

through 1998, estimated prevalence of Brucella spp. in caribou was 2.9 percent, 6.3 percent in 

wolves, and 12.5 percent in grizzly bears, based on observed prevalence, modeling effects, and 

effects of neighboring areas (Zarnke et al. 2006). Evidence from literature and unpublished 

experimental data suggest that such infections may interfere with reproduction in wild species, 

but additional study is needed to resolve this question. 

Rabies is always a concern in mammals, particularly foxes and wolves. While caribou are more 

prone, moose are also susceptible to the bacterium Spherophorous necrophorous, which causes 

hoofrot. Snowshoe hare, beaver, and muskrat are susceptible to tularemia infection, while bears 

are known to have problems with the roundworm Trichinella spiralis that causes trichinosis. 

Lice (Trichodectes canis) have been identified from wolves east of the refuge in GMU 19D (R. 

Seavoy, ADF&G Area Biologist, McGrath, Alaska, personal communication, December 2006). 

Louse infections significantly affect pelt quality, and there is concern that the parasite will cross 

over onto the refuge. Chronic wasting disease has not been identified in Alaska as yet, but 

ungulate managers are concerned should this disease spread north. 

Since its identification in Alaska, the metazoan parasite Myxobolus cerebralis, which causes 

whirling disease, has also become a concern wherever salmon and trout are located. 

3.3.3.6 Moose 

Congress specifically identified the conservation of moose and their habitat as one of the reasons 

for creating Innoko Refuge in 1980. Moose are a critically important subsistence species to the 

local residents and are widely sought after by non-local hunters. Concern for the apparent decline 

in population size prompted local subsistence hunters, ADF&G, BLM, and the refuge to develop 

the Yukon-Innoko Moose Management Plan (Alaska Department of Fish and Game 2006b). While 

estimates can not state with certainty that the moose population is declining, other information 

appears to point in that direction. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-79 
Chapter 3: Refuge Resources 

Causes for the possible decline in the moose population are unknown, and much additional work and 

data collection are needed. Most important are up-to-date population estimation and density data. 

Information about the composition and age structure of the harvest and the overall population are 

needed. Quantitative data on the status and trend of the habitat (both summer and winter) are 

needed. More information is needed to understand how wildfires are affecting moose habitat 

(summer and winter) and how habitat regeneration from various fire intensities affects habitat 

quality through time. Quantitative data on the number and seasonal distribution of black bears, 

brown bears, and wolves are needed to understand how predation affects the moose population. 

3.3.3.7 Predator Control 

The State of Alaska currently conducts predator control in GMUs 19A and 19D south and east of 

the refuge. Low to moderate densities of moose on the refuge, coupled with local requests to 

bolster the moose population through predator control, will contribute to increased pressure on 

the refuge to consider predator control as a management tool in the future. For additional 

information about predator management on Alaska National Wildlife Refuges, see appendix C. 

3.3.3.8 Wood Bison 

Alaska Department of Fish and Game is currently proposing to release wood bison south and west 

of the Innoko Refuge in the area between the Innoko and Yukon rivers (Alaska Department of 

Fish and Game 2007a). While comprehensive in its overview of the existing scientific literature on 

existing wood bison herds in Canada, the Alaska Department of Fish and Game (2007a) shows 

that little is really known about how a bison herd would affect (positively or negatively) groundnesting birds, including waterfowl; vegetation communities, especially in high use areas; small and 

medium-sized mammal communities; large carnivores; and moose. Should wood bison be 

introduced into the Innoko ecosystem between 2010 and 2013, little time exists to document 

existing conditions from which to measure future changes, if any. 

3.3.3.9 Wood Frog 

Metamorph stage wood frogs have been evaluated for abnormalities for five years (Reeves et al. 

2008). High numbers of abnormalities have been documented only at one pond located 150 yards 

northeast of the field camp, and this number has not been consistent across years. Work needs to 

be accomplished to understand the causes behind the high abnormality rate at this specific site. 

Depending on those findings, Innoko Refuge may need to conduct additional investigations on 

abnormality rates in the vicinity of Gold Rush era sites such as Rennies Landing, Dishkaket, 

Dikeman, and Holikachuk. 

3.3.3.10 Fish 

Increased Fishing Pressure 

The potential for increased fishing pressure from sport and commercial fisheries may affect 

population size and structure of several species in the refuge. In recent years, the Innoko River 

has become a popular destination for guided anglers targeting northern pike in the lower Innoko 

River outside of the refuge (Brown et al. 2005, Scanlon In press). Most effort is catch and release, 

but the combined potential for subsistence harvest, sport harvest, and post-capture mortality may 

affect the status of the population. Likewise, a combination of subsistence harvest and the 

increasing interest in commercial fishing may also affect whitefish populations. Objectives 2, 17, 

34, 69, and 74 all address this concern. 

3-80 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Increase in User Conflicts (Northern Pike) 

Subsistence users in the area have expressed concerns about competition with sport fishers for 

northern pike (Brown et al. 2005). Their concerns focus on potential waste by sport users, 

declining size of fish, mortality from catch and release, and targeting large fish during spawning 

season. This conflict may have caused locals to change harvest and use patterns near villages. 

Alteration of Wild Salmon Stocks Caused by Salmon Enhancement 

During recent times, several stocks of salmon in the Yukon River have become depressed to 

where management actions have reduced fishing opportunities or closed fishing periods. With 

insufficient numbers of fish for harvest and escapement, enhancement becomes a consideration 

for rebuilding the stocks. Enhancement could develop large populations of particular stocks that 

would be heavily exploited. Such high exploitation of enhanced stocks could lead to pressure on 

smaller stocks. However, ADF&G has rigorous policies and guidelines for preventing or 

mitigating the potential for inadequate escapement, loss of genetic diversity, or an unsustainable 

harvest. If carefully planned and implemented, under both State and Service protocols, 

enhancement could supplement wild salmon production and increase salmon harvests. 

Off-Refuge Harvest of Refuge Whitefish and Salmon Stocks 

Mainstem mixed stock commercial and subsistence fishing may have an effect on the population 

size and structure of salmon and whitefish that spawn in the refuge. Because genetic fish 

sampling that can rapidly identify particular fish stocks is expensive and rarely used, individual 

fish stocks could be disproportionately harvested. Disproportionate harvest could be especially 

detrimental to small stocks that pass through fisheries during a short time frame of intense 

fishing activity. The bycatch of salmon in Bering Sea and Gulf of Alaska groundfish fisheries may 

also affect refuge salmon stocks. Alaska Department of Fish and Game considers all these factors 

in fishery management to avoid long-term detrimental impacts. 

Off-Refuge Mining Activities 

Mining activities may have introduced excessive amounts of sediment and other contaminants to 

streams, causing degraded fish habitat. Historic placer mining activities caused increased levels 

of turbidity and sediment transport in area streams. Alt (1983) noted an unexplained absence of 

Arctic grayling in the upper Innoko River and suggested that water turbidity associated with 

mining activity may have caused the absence. Currently, there are insufficient data available to 

determine the extent that mining practices may have had on refuge fish populations and their 

habitats. However, current mining technology and State and Federal regulations have 

substantially reduced sediment pollution. Water quality monitoring of refuge streams will identify 

upstream disturbances that may affect refuge fishery resources. 

Development of Inholdings and Lands Adjacent to the Refuge 

Private lands within and outside the refuge have the potential to be developed for residential, 

agricultural, mineral, sportfishing, and remote tourism access. These developments may lead to 

fragmented habitats, degraded water quality, reduced instream flows, altered water tables, increased 

pressure on fishery resources, and increased conflicts with local users. Coordinated planning efforts 

among agencies and private land owners may help decrease inconsistencies and conflicts. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-81 
Chapter 3: Refuge Resources 

3.4 Human Environment 

3.4.1 Area History 

3.4.1.1 Prehistory 

The archaeology of interior Alaska is not well known, but the broad outline can be sketched here. 

Most research has focused on the earliest inhabitants. By about 9000 B.C., the unglaciated areas 

of central Alaska, including the area of Innoko Refuge, were occupied by people belonging to 

several archaeological traditions, including the Northwest microblade complex, Nenana complex, 

Denali complex, Chindadn, and Sluiceway—closely related to the East Siberian groups of the 

same period. Many authorities consider most of these traditions to be variations of a single 

PaleoArctic tradition (Clark 1991, Clark 2001, Dumond 2001, Holmes 2001). Recent discoveries at 

the Nogahabara Sand Dune site on the Koyukuk Refuge strongly support the contention that 

these various traditions are functional differences between sites rather than different cultural 

groupings and that, in fact, only one PaleoArctic tradition occupied interior Alaska from 12,500 

years ago to about 6,000 years ago (Daniel Odess, personal communication, 2005). 

These people used a blade and microblade technology, presumably in conjunction with an 

extensive kit of bone, antler, and wooden tools. Subsistence was probably based primarily on the 

large herd animals of the time. 

As the glaciers retreated, routes of travel were opened to the south and east, and the previously 

easy routes to the west were blocked by the encroaching Arctic Ocean and Bering Sea. In this 

period, there are indications of contact and perhaps an amalgamation of the Siberian-related 

cultures and the Paleo-Indian cultures that had been developing south of the continental ice 

sheets. The Mesa site on the North Slope and Spein Mountain in southwest Alaska have been 

interpreted as a manifestation of the big game hunting PaleoIndian tradition, with roots in the 

Great Plains. 

The Northern Archaic tradition began about 6,000 years ago with clear antecedents in the 

PaleoArctic tradition. The tradition is defined by the presence of side-notched points in tool 

assemblages. Northern Archaic people used leaf-shaped spear points, large bifaces, endscrapers, 

choppers and hidescrapers, and notched stone net sinkers. Net sinkers signal a significant shift in 

subsistence from land based hunting to a mixed hunting and fishing economy that incorporated 

the rich fish resources available in lakes and rivers. The presence or absence of microblades in 

Northern Archaic sites remains a hotly debated point in northern archaeology. Microblades are 

rare from most sites dating after this time, but they never totally disappear from the record. 

The Northern Archaic tradition lasted until about 2,000 years ago. It is generally assumed to be 

ancestral to the more recent cultures of the area. This later prehistoric period, up until European 

contact, is characterized by small, tapered-stem projectile points, groundstone hide and wood 

working tools, bone implements, and limited use of copper. Sites are larger than those of the 

earlier Northern Archaic and PaleoArctic peoples and contain semi-subterranean houses and 

cache pits. There is, however, substantial diversity in the sites of the later period, and the advent 

of sites that can be described as clearly being in the “Athapaskan tradition” is highly variable in 

time. Much work remains to be done to clarify and explain what have been described as somewhat 

“refractory” data (Clark 1991). 

3-82 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-83 

3.4.1.2 Ethnography1 

For all practical purposes, Innoko Refuge may have been the territory of the Holikachuk 

Athabaskan Indians. Although the early Russian explorers of this area recognized that the people 

of the upper Innoko River were a separate group from their Ingalik or Koyukon neighbors, this 

little-known group has most often been discussed with one or the other. The distinction was 

“rediscovered” on linguistic grounds by Michael Krauss in 1962 (Snow 1981). The language of the 

Holikachuk is intermediate between the Koyukon and Ingalik languages (and this position is 

recognized by its speakers), although it is slightly closer to Koyukon. Socially and geographically, 

however, the Holikachuk are closer to the Ingalik, although with fewer Eskimo borrowings 

(Krauss and Golla 1981). Dishkaket was originally a central village in the upper Innoko and was 

connected by winter trails to both the Yukon and Kuskokwim rivers, which is probably why it was 

chosen by early miners as a location for stores and a post office. The last Native residents moved 

out sometime around 1920 after the village was decimated by sickness (possibly by one of the 

influenza epidemics). Holikachuk was nearly abandoned by 1963 when the bulk of the residents 

moved to Grayling where there was better fishing and more reliable summer barge service. 

At contact, the Holikachuk occupied five winter villages along the Upper Innoko River: Tlegon 

(Davenport), whose name also referred to the river above the confluence with the North Fork; 

Tlegokokhkakat; Tleket; Kkholikakat (Hammer Creek); and Ttality (Dementy) (Snow 1981). The 

population of the Upper Innoko at that time was probably not more than a few hundred; population 

densities for interior Alaska in general were probably in the range of 1–1.4 people per square mile 

(Hosley 1981), and there is no reason to believe that the upper Innoko was an exception. 

Over time, the people of the upper Innoko tended to congregate lower on the river. In 1844, the 

village of Khuligichagat, near the mouth of Holikachuk Slough, was occupied by Ingalik 

Athabaskans; but by 1866, Holiaktzagmiut—at the site of the recent village of Holikachuk—was the 

most southern settlement of the Holikachuk people. By the 1890 census, the population of the village 

was 114, and the villages upstream were—while perhaps still occupied—of diminishing importance. 

The last upstream Holikachuk settlements were Dementy and (probably) Dishkakat. Holikachuk 

was nearly abandoned in 1963, with the bulk of the residents moving to Grayling (Snow 1981). 

In common with other Athabaskans of the Alaska plateau, the Ho1ikachuk were primarily hunters 

and secondarily fishermen. This distinction was particularly notable for the Holikachuk, since 

there were only limited runs of salmon on the upper Innoko. Consequently, fish camps in the 

summer were located on the Yukon River, as much as 70 or 80 miles from the locations of the 

winter villages (in contrast with the Ingalik, whose fish camps and winter villages were generally 

within 6–8 miles of each other). Historically, the single most important game animal was the 

caribou, with bear, moose, and smaller animals being seasonally or occasionally utilized. 

The basic unit of Holikachuk Athabaskan society was composed of one or two multi-generational 

families who stayed together throughout the yearly subsistence cycle. They moved seasonally, and 

their winter village would consist of two to five such households. This constituted a local band, which 

used the same lands for subsistence throughout the year. Groups of local bands in an area, such as a 

river drainage, could constitute a regional band, and it is convenient to consider the Holikachuk 

people to be a regional band—with five local bands corresponding with the five identified villages. 

The Holikachuk people were united by kinship ties, language, and culture (Hosley 1981). Ties with 

surrounding Athabaskan groups were maintained through marriage and trade, which was facilitated 

by a system of well-established trails throughout the interior of Alaska. 

 

1

Place name spellings are from Orth (1971). Other spellings are commonly used in the local area and literature. 
Chapter 3: Refuge Resources 

3.4.1.3 History 

The first direct contact between Europeans and the people of the upper Innoko occurred in 1839, 

when Petr Kolmakov (the son of Fedor Kolmakov, the principal Russian trader on the 

Kuskokwim) crossed over from the Takotna River to the Innoko drainage “where he obtained 800 

beaver pelts by trading with the inhabitants” (Zagoskin 1967). In 1844, Zagoskin visited 

Holikachuk and the next village up the Innoko River, which he called “Ttality” (possibly Dementi, 

at the mouth of the Iditarod River). It is likely, however, that the Holikachuk people had already 

obtained trade goods of European manufacture before this date through Eskimo or other 

Athabaskan middlemen. The Holikachuk were visited by the Hieromonk Illarion (a Russian 

Orthodox priest from Ikogmiut on the lower Yukon) in 1860 and by E.W. Nelson (better known for 

his work with the Eskimo) in 1880. There was little other contact with the Holikachuk in their own 

territory until the beginning of the Gold Rush (VanStone and Goddard 1981). 

Gold prospecting in the interior of Alaska became an important economic activity beginning in the 

middle of the 1880s. A visit by John Folger in 1888 is the earliest documented visit to the Innoko 

Refuge by a prospector. Efforts at first were concentrated around Hughes on the Koyukuk but 

soon spread widely. In September of 1906, a prospecting party consisting of Thomas Ganes, 

F.C.H. Spencer, Mike Roke, and John Maki made a significant discovery of placer gold on Ganes 

Creek, a tributary of the Innoko River. Prospectors, miners, and business people rushed to the 

area during the next two years. A second discovery—on Christmas Day 1908—by William 

Dikeman and John Beaton on Otter Creek, a tributary of the Iditarod River, sparked an even 

greater rush to the Innoko basin. Numerous communities, including Innoko City, Dementi, and 

Dikeman, sprang up along the rivers to provide services to the thousands of travelers. The native 

village of Dishkaket was an existing community that provided stores and a post office during part 

of the rush. (Maddren 1910). 

In 1908, the Alaska Road Commission sent W.L. Goodwin to locate and map a mail route from 

Seward to Nome through the Kuskokwim and Innoko river basins. On his return to the coast in 

1910, Goodwin and his party surveyed, constructed, and marked the winter trail route from Nome 

to Seward, most of which followed existing native trails. Upon reaching Dishkaket, the party made 

a side trail through Dikeman to Iditarod to include the newest mining area (Alaska-Yukon 

Magazine 1911). In further support of the pre-existence of Native trails throughout the Territory, 

the following is quoted from Lt. Herron’s report of exploring “an All-American overland route 

from Cook Inlet, Pacific Ocean to the Yukon.” 

“In exploring my route I found that there already existed throughout its length 

winter sled trails cut out, blased, and in regular use by the Indians and 

coinciding with or paralleling my trail throughout ... These trails represent the 

result of a knowledge of the country accumulated during many generations, as 

well as the labor of many Indians. They follow direct lines and traverse 

advantageous ground. These can be economically followed, connected, plainly 

marked, and made ready for general use....” (Herron 1909). 

Undoubtedly, the Native Alaskan people who lived in the Innoko valley had established part of the 

trail routes which Mr. Goodwin chose for the Seward to Nome mail route, now known as the 

Iditarod Trail. 

The first major strike in the “Inland Empire,” as the Innoko area became known, came in 

September 1906 when the Thomas Ganes party found placer gold deposits on Ganes Creek. This 

discovery spawned a Gold Rush into the upper Innoko country in the spring of 1907. On Christmas 

Day, 1908, a second major gold strike was made, this one on Otter Creek, a tributary of the 

Iditarod River. Thousands of prospectors, miners, and businessmen stampeded to the upper 

3-84 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Iditarod district in 1909 and 1910. Established in 1906, the Alaska Road Commission surveyed a 

number of winter overland route from Seward to Nome, now famous as the historic Iditarod Trail 

(Peterson 1980). The historic trail followed multiple routes rather than one specific trail. The 

remains of mining camps and other structures from this period exist on the refuge. (See 

Archaeological and Historic Sites in this chapter.) 

The period of boom activity in the Innoko and Iditarod districts was relatively short. Many small 

prospects were purchased by large corporations. Prospectors covered the area and then moved 

on; big equipment, such as dredges, replaced men working the deposits. World War I drew off 

manpower and equipment, and the continuing fixed price of gold contributed to a decline in mining 

activity. The regional post office at Dishkakat was transferred upriver to Cripple Landing in 1915, 

and Dishkakat was abandoned by the early 1920s. Iditarod, too, saw its business base collapse, and 

by the early 1920s, only a few people remained. A few family operations remained active in the 

Innoko and Iditarod districts—except when closed by government mandate during World War II. 

The removal of the government’s fixed price on gold in 1971 encouraged miners to renew activity 

in several locations bordering the refuge, but the level of activity has never returned to that of 

early years. 

3.4.1.4 Archaeological and Historic Sites 

Little or no archaeological work has been done to date on Innoko Refuge. There are 41 known 

sites on the Innoko Refuge. These include the locations of the five Holikachuk villages first 

reported by the Russians in the 1840s and the site of the Ingalik village near the mouth of 

Holikachuk Slough. Presuming that the Innoko area is similar to other portions of the interior, it 

can be expected that many more sites remain to be identified. The greatest number of these will 

be at the confluences of streams; at the inlets and outlets of lakes; on prominences providing views 

of the surrounding countryside; and on stable, well-drained river banks. 

In the realm of historic sites, we are dealing with the remains of mining activity from the early 

part of the twentieth century. Thirty of the known sites relate to the Iditarod National Historic 

Trail—mostly communities, roadhouses, and camps served by the trail. Six trail segments 

associated with the historic trail pass through the refuge (Figure 3-30). The modern dogsled race 

route bypasses the refuge on even-numbered years when the route follows the “northern route” 

(Ophir to Ruby); in odd-numbered years the route follows the “southern route” (Ophir to Iditarod 

to Shageluk), which—for about six miles—crosses the refuge and the designated wilderness area 

in its southeastern corner. The BLM serves as the Federal coordinator for the trail and published 

the Iditarod National Historic Trail Comprehensive Management Plan (Trail Plan) (1986). 

Although the Trail Plan is currently only advisory, it has been proposed that the Service enter a 

Memorandum of Understanding with BLM for the management of the trail. 

The Trail Plan identifies 19 sites within Innoko Refuge for management activity. Of those, two 

sites fall under priority management (Dishkakat and Dikeman); three for secondary management 

(Innoko City [also known as Dishna], Simels, and Shermeier’s Halfway Roadhouse) for minimum 

management. Efforts are underway to document these sites and identify others. 

Innoko Refuge has known archaeological and historic resources of considerable extent and of 

national significance, and the potential for substantial resources not yet discovered. Considerable 

work remains to be done in this fertile area. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-85 
Chapter 3: Refuge Resources 

3-86 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

3.4.2 Population and Settlement Patterns2 

3.4.2.1 Overview 

Innoko Refuge lies within the Yukon-Koyukuk census area, which is home to less than 7,000 

people and covers over one-quarter of Alaska’s landmass. Four other national wildlife refuges are 

also located wholly or partially within the census Area. Most of Innoko Refuge and most of the 

communities affected by refuge management lie within the McGrath–Holy Cross census subarea. 

McGrath is the largest community in the subarea with 325 residents. 

Rivers are the most important transportation routes for area residents, and most communities are 

located along the Yukon River or its major tributaries. None of the refuge-area communities are 

connected to Alaska’s road system. Supplies, services, and travel out of the region generally route 

through Anchorage. 

About 65 percent of the McGrath–Holy Cross subarea population is Alaska Native, but most of the 

non-Native residents live in McGrath. Outside of that community, the population is about 85 

percent Alaska Native. Forty-five percent of area residents are female, and the median age is 33. 

Roughly 70 percent of the adult population has at least a high school education, but just 14 percent 

have completed a bachelor’s or higher degree. 

The Institute of Social and Economic Research (ISER) at the University of Alaska prepared a set 

of population projections for Alaska in the mid-1980s (Goldsmith 1986). ISER prepared four sets 

of projections based on different economic scenarios. Using those projections as a base, the 

population in the vicinity of the refuge was projected to grow between 8 and 39 percent during the 

period 1987–2010. After a short period of growth, however, the populations of most communities in 

the region stabilized or began to decline. In 2006, there were just over 1,150 residents in the 

region—about 200 fewer than in 1980 (Table 3-16). Most of the reduced population is attributable 

to declines in McGrath, which now has nearly 200 fewer residents than in 1990. 

Table 3-16. Population trends in the Innoko Refuge area communities 

Community 1970 1980 1990 2000 2006 

Grayling 139 209 208 194 174 

Anvik 83 114 82 104 88 

Shageluk 167 131 139 129 124 

Holy Cross 199 241 277 227 204 

Kaltag 206 247 240 230 199 

Takotna* 48 38 50 53 

McGrath 279 355 528 401 321 

 TOTAL 1,073 1,345 1,512 1,335 1,163 

*Data for Takotna in 1970 not available. 

3.4.2.2 Principle Refuge-Affected Communities 

Except where otherwise noted, this section is adapted from the Alaska Community Database 

(2007). Four communities in the vicinity of Innoko Refuge rely most heavily on the refuge for 

subsistence resources. These communities, sometimes referred to as the “GASH villages,” are: 

Grayling, Anvik, Shageluk, and Holy Cross (Figure 3-31). Two other communities to the north of 

the refuge, Kaltag and Nulato, also rely on Innoko Refuge resources (and resources in nearby 

 

2

 Except where otherwise noted, this section is adapted from Windisch-Cole (2001). 
Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Figure 3-30. Iditarod National Historic Trail 
Chapter 3: Refuge Resources

3-88 
Chapter 3: Refuge Resources 

Nowitna Refuge). Residents of Takotna and McGrath rely less on refuge resources. McGrath is 

important as a regional service hub and population center, and also as the site of Innoko Refuge 

headquarters. Within the broader region, these eight communities are most likely to affect, and 

be affected by, refuge management. 

Grayling 

Grayling is located on the west bank of the Yukon River, near the southwest corner of Innoko 

Refuge. The community was established between 1962 and 1966 when about 25 families moved from 

nearby Holikachuk, which was prone to spring flooding. The city government was incorporated in 

1969. All but three homes have access to city water and sewer facilities. Grayling has a State-owned, 

lighted 2,315-foot gravel airstrip, and skiffs are used for transportation up and down river in the 

summer. Every other year, Grayling is a checkpoint in the annual Iditarod sled dog race. 

Anvik 

Anvik is located on the Anvik River, south of Grayling and north of Holy Cross. Anvik has been 

known as American Station, among other names, and has likely been inhabited since the 1830s. An 

Episcopal mission and school was established there in 1887, followed by a post office in 1897. Most 

homes are fully plumbed with individual wells and piped sewage disposal and complete plumbing. 

Anvik has barge and boat service in the summer and a State-owned 2,910-foot gravel airstrip.

Shageluk 

Shageluk is located on the east bank of the Innoko River, about 20 miles east of Anvik. The area 

was first reported as a Native settlement by Russian explorers in 1850. A post office was 

established in 1924. Residents of Shageluk moved in 1966 from a flood-prone location to a higher 

site located two miles to the southeast. Today, most households haul treated water from a central 

source and use honey buckets or outhouses. Residents rely on the washeteria for bathing and 

laundry. A State-owned 2,910-foot airstrip provides access. Every other year, Shageluk serves as 

an Iditarod checkpoint. 

Holy Cross 

Holy Cross is located on Ghost Creek Slough, just off the Yukon River at the southwest corner of 

the Yukon-Koyukuk census area. Russian explorers reported 170 people in what is now Holy 

Cross in the early 1840s. After being called by a series of Alaska Native and Russian names, the 

community was named Holy Cross in 1912, after the local Catholic mission and a school 

established in 1899. A boarding school operated by the church ceased operations in 1956 and was 

later torn down. Most homes in the community are connected to a central water system. Holy 

Cross has a small local road system, summer barge service, and a 4,000-foot State-owned airstrip. 

Kaltag 

Kaltag is located on the west bank of the Yukon River, about 20 miles from Innoko Refuge. The 

community has undergone numerous changes during its 150-year plus history. It served primarily 

as a cemetery for surrounding villages until about 1900, when disease and starvation dramatically 

affected the regional Native population. Survivors from nearby areas moved to Kaltag to regroup. 

During the next 30 years, mining and steamship activity caused a mini-boom in the area. A series 

of schools and post offices opened, closed, and re-opened again during this period. Modern 

facilities, including an airport and clinic, were constructed in the 1960s, and the city government 

was incorporated in 1969. Today, there is a central water and sewage system, and most homes are 

fully plumbed. A lighted 3,900-foot airstrip, regular barge service, and the 90-mile Old Man Trail 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-89 
Chapter 3: Refuge Resources 

to Unalakleet provide relatively good access into and out of the community. Kaltag serves as an 

Iditarod checkpoint each year. 

Takotna 

Takotna is located on the north bank of the Takotna River, 17 air miles west of McGrath. The 

community was first named Berry Landing after a sternwheeler captain who was hired to bring 

goods up the Takotna River in 1908. The town served gold miners and grew to include several 

businesses, a post office, and about 50 houses by 1919. During the 1930s, McGrath became the 

dominant regional supply center, and services in Takotna dwindled. The town grew again in the 

1950s following construction of the nearby Tatalina Air Force Station and a White Alice 

communications site, but operations were phased out in the 1980s. Today, Takotna has a school, 

a post office, and a washeteria that supplies water to residents. Most homes are not fully 

plumbed. Access to Takotna is by air or water. There is a State-owned 1,717-foot long by 65-foot 

wide gravel airstrip and a 3,800-foot gravel runway at Tatalina Air Force Station 10 miles 

southeast of town. Cargo is offloaded at Sterling Landing, 24 miles southeast of Takotna. The 

community has 80 miles of local roads that connect with Tatalina Air Force Station, Sterling 

Landing, and existing mines. A winter trail is marked to McGrath (20 miles). It is a checkpoint 

for the Iditarod sled dog race. 

McGrath 

McGrath is located along the Kuskokwim River, 221 miles northwest of Anchorage. The area 

traditionally served as a seasonal village and meeting site. It became a regional supply center 

when gold was discovered in the region in 1906. The town was named after Peter McGrath, a U.S. 

marshal who worked there in 1907. Changes in the Kuskokwim River during the 1930s made the 

original town site less functional, and community members eventually moved to a new site across 

the river. The Federal Aviation Administration (FAA) established a complex there in 1940, and a 

high school was constructed in 1964. Today, McGrath serves as a transportation, communications, 

and supply center in interior Alaska. It has more of a cash economy than surrounding villages, 

although subsistence activities are still important for many families. There is a limited city sewage 

system, and virtually all homes are fully plumbed. Access is provided by a lighted 5,435-foot 

asphalt runway, a 1,720-foot crosswind runway, float planes, summer barges, and numerous 

winter trails. 

3.4.2.3 Social Infrastructure 

Social infrastructure includes local government, housing, education, health services, local 

transportation, water and sewage systems, solid waste disposal, police and fire protection, and 

communication systems. 

All of the villages in the area are incorporated second-class cities with mayor-council 

governments. Traditional tribal governments are also active. 

All of the communities are eligible for land entitlements under the Alaska Native Claims 

Settlement Act. The Native residents of the area are shareholders in Doyon, Limited (the regional 

native corporation), and members of the non-profit Tanana Chiefs Conference. Both organizations 

have offices located in Fairbanks. The Native residents of these communities are also 

shareholders in local village corporations (Table 3-17) organized under ANCSA. These 

corporations have land holdings and are often involved in local business concerns. 

The communities in the area are similar in their infrastructure. Law enforcement is provided by 

village public safety officers and the Alaska State Troopers. 

3-90 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Table 3-17. ANSCA Village Corporations in the vicinity of the Innoko Refuge 

Community ANCSA Village Corporation 

Holy Cross Deloycheet, Inc 

Anvik Ingalik, Inc 

Grayling Hee-Yea-Lingde Corporation 

Shageluk Zho-Tse, Inc. 

Kaltag Gana-a’ Yoo, Inc. 

McGrath MTNT, Ltd. 

Elementary and secondary schools are available in all of the villages. The Tanana Chiefs 

Conference offers Headstart programs for preschoolers in Grayling, Holy Cross, and McGrath. 

Health facilities are provided in the GASH villages by the Yukon-Kuskokwim Health Corporation. 

Other communities are served by other health care providers. Clinics are staffed by health aides 

trained by the U.S. Public Health Service (PHS). In addition, PHS physicians and other health 

care givers visit the villages regularly. 

Communications facilities are relatively good in the area. Post offices, satellite communications 

(telephone and television), and electricity are available in all of the communities. 

The housing stock consists of both wood frame and log homes, most of which date from the 1960s, 

although more recent construction is common. Public lodging is available in Grayling, Holy Cross, 

and McGrath. Community water and sewage systems are available and serve most of the 

residents of Holy Cross, Grayling, Kaltag, and McGrath. Anvik and Shageluk do not have water 

distribution or sewage collection systems. Most residents haul their water from public buildings 

that are served by wells. 

3.4.3 Regional Access 

Historically, boats and dog sleds were the only means of access to the refuge proper; snow 

machine use has replaced dog sleds. There are no established landing strips currently on the 

refuge, so aircraft must be prepared for snow or water landings. Off-road vehicles have not been 

recorded on the refuge. 

Residents use trucks, vans, off-road vehicles (ORVs), and snow machines for transportation within 

the villages. Boats and airplanes are used in addition to ORVs and snow machines for travel 

between villages and in surrounding areas. No roads connect these villages with any other 

community. The mining area of Ophir, east of the refuge, is connected by gravel road to Takotna, 

30 miles to the southeast. Miners haul much of their equipment and supplies along winter cat 

trails from McGrath and Takotna. All of the villages have gravel airstrips and are served by 

regularly scheduled commercial airlines and local air charter operators. Regularly scheduled 

flights are generally available twice a day, six days a week, connecting with Aniak; and once a day, 

three times a week connecting with McGrath for the communities of Anvik, Grayling, Shageluk, 

and Holy Cross.Kaltag has scheduled flights to Galena six days a week. Air strips are also located 

near most mining operations. Seasonal barge service is available in Kaltag, Shageluk, Anvik, 

Grayling, Holy Cross, Takotna, and McGrath. Access in the vicinity of the refuge is relatively good 

by interior Alaska standards. No proposals for additional means of overland access have been 

made. The available access appears to adequately meet the needs of the area at present and in the 

foreseeable future. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-91 
Chapter 3: Refuge Resources 

3.4.4 Economy 

Except where otherwise noted, this section is adapted from Windisch-Cole (2001). The region 

surrounding Innoko Refuge is sparsely populated and relatively undeveloped, so opportunities for 

year-round wage and salary employment are limited. The traditional cash-generating activities of 

the region—gold mining, commercial fishing, and trapping—all suffered significant declines 

during the 1990s. The economy of the Yukon-Koyukuk census area now supports about 2,400 yearround jobs, and 60 percent of those are local, State, or Federal government positions (Alaska 

Department of Commerce, 2008. Local governments, including school districts, are by far the 

dominant employer. Within the private sector, many jobs are associated with Alaska Native 

organizations, many of which provide services under contract with non-profit or government 

entities. In essence, public funds support their efforts. Construction activity, another important 

private sector employer, also largely depends on public funding. 

Overall wage and salary income within the Yukon-Koyukuk census area is well below the State 

average. The median family income, about $35,000, is more than 30 percent below the statewide 

median. Nearly 25 percent of the area population falls below Federal poverty levels, compared to 

the statewide rate of about 11 percent; and nearly 40 percent of adults in the area are not in the 

work force, compared to 20 percent for a typical developed community elsewhere in the United 

States (Alaska Department of Commerce 2008). The expense of travel and daily life in the area—

grocery prices are among the highest in the State—compounds the effect of low employment and 

low family incomes. 

Employment and income statistics do not provide a complete picture of regional economic 

conditions, however, because subsistence hunting and fishing remains important culturally and as 

a means of livelihood in the region. Subsistence work is not done for pay, so personal income 

statistics can give a misleading picture of the well-being of places where subsistence makes a 

significant contribution to meeting the food and other needs of a community. Such communities 

often have more resources available than is reflected by personal income. Nevertheless, even in 

the most subsistence-oriented communities, cash is still needed for the purchase of fuel, firearms, 

ammunition, fishing gear, snowmachines, boats, and associated materials and maintenance costs. 

3.4.5 Subsistence 

Both Alaska Natives and non-Natives living in rural Alaska participate in subsistence activities on 

a regular basis. Their dependence on wild resources is both cultural and economic. Alaska’s 

indigenous inhabitants have relied upon the traditional harvest of wild foods for thousands of 

years and have passed this way of life, its culture, and their values down through generations. 

Subsistence has also become important to many non-Native Alaskans, particularly in rural Alaska. 

Subsistence consists of the harvest of fish, game, plants, and other products of the land for direct 

personal or family use. The subsistence lifestyle also includes the processing of these products for 

food, clothing, and other uses, and the activities associated with the harvest, such as care of dog 

teams and maintenance of snow machines. Subsistence is sometimes viewed as a job because time 

spent in subsistence activities produces food, shelter, clothing, and other items for sustaining life. 

People working for wages trade their labor for money that they subsequently spend on food, 

shelter, and clothing. People engaged in subsistence activities trade their labor directly for these 

products. One very important feature of subsistence is inter-family and inter-community sharing. 

Generally, not all households participate directly in subsistence hunting or fishing, but resources 

are shared by those that do. In fact, it is not uncommon for a few “super-households” in a given 

village to harvest the majority of the resources utilized by the community (Wolfe 1987). 

3-92 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Fish, wildlife, and plant materials are harvested on Innoko Refuge by residents of all communities in 

the area, but the GASH communities (Grayling, Anvik, Shageluk, and Holy Cross) rely most heavily 

on refuge resources. In these communities, subsistence centers mostly around fish and big game. 

Fish are the most relied upon subsistence resource in the Innoko region. Subsistence fishing 

occurs year round, although summer and fall salmon runs have historically been the most 

important in terms of catch volume. Salmon and other fish are typically harvested with nets and 

preserved for later use. The Yukon River and its tributaries provide the bulk of salmon harvested, 

but these stocks can show substantial variability in seasonal abundance, as normally expected in 

wild salmon stocks. Very low salmon returns were recorded in the Yukon River drainage in 2000 

and 2001. Some stocks rebounded with record or near record returns for portions of the chum 

salmon run in 2005 and 2006 (ADF&G 2006c). 

Specific subsistence harvest figures for salmon are not available for the individual area villages 

over time, but in 2005, 159 households in Grayling, Anvik, Shageluk, and Holy Cross reported 

harvesting a combined total of 6,321 Chinook and 8,296 chum salmon (ADF&G 2005). In 1990–

1991, these residents harvested approximately 61,000 pounds of non-salmon fish species. During 

periods of low salmon returns, such as those experienced in 2000–2001, subsistence users’ reliance 

on species of fish other than salmon increased. These include whitefish, northern pike, sheefish, 

burbot, Arctic grayling, longnose sucker, Alaska blackfish, and lampreys (Brown 2007). 

Brown et al. (2005) reported that overall, the GASH communities harvested almost 88,000 pounds of 

non-salmon fish during 2002 (the last year for which a thorough household survey was completed). 

Whitefish constituted the greatest proportion of the total (about 39 percent), followed by Arctic 

lamprey (35 percent), sheefish (14 percent), and pike (10 percent). Burbot, longnose sucker, Alaska 

blackfish, and Arctic grayling each accounted for less than one percent of the total harvest. The 

large lamprey catch may be related to salmon declines. Lamprey now fulfill part of the role that 

salmon used to for feeding dog teams, and the bulk of the lamprey catch (more than 70 percent) took 

place in Grayling, where there are more dog teams than in the other GASH villages. 

Among big game species, moose, caribou, wolves, and bear have long been the most important for 

subsistence in the Innoko Region (Brown and Koster 2005). Moose is by far the most widely used 

animal. According to a 2003–2004 harvest survey by Brown and Koster (2005), 66 percent of 

households in all four GASH villages attempted to harvest moose in the preceding year, and 94 

percent actually used moose. About one-third of the GASH population spent a total of 1,041 

hunter-days pursuing moose during the 12-month period from April 2003 through March 2004. A 

total of 118 moose were reported harvested in that time, and an estimated 40 percent of the 

harvest occurred on Innoko Refuge (the rest was on surrounding State lands). 

Harvest and use of caribou in the GASH villages varies tremendously depending on the movement 

of the western Arctic caribou herd. During the 2003–2004 survey year, just two caribou were 

reported harvested, both by residents of Grayling. Black bears are a somewhat more consistent 

food resource, although they are typically harvested opportunistically rather than actively hunted. 

A total of five black bear were reported harvested by residents from Grayling and Shageluk 

during the 2003–2004 survey year. Next to moose, wolves appear to be the most widely used big 

game animal. Wolves are trapped or shot for their fur and, according to villagers, as part of an 

informal predator control program. A total of 52 wolves were reported taken during the survey 

year, all from GMU 21E; about 10 percent of households reported using wolf. 

In general, subsistence harvest of all big game species, measured in both absolute and per capita 

terms, has declined since 1990. The moose harvest has undergone the most significant decline. The 

absolute number of moose harvested by GASH community residents in 1990 was nearly twice the 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-93 
Chapter 3: Refuge Resources 

number harvested in 2003–2004 survey year. The substantial drop may be partially due to declines 

in the human population, but per capita rates have also dropped by nearly half in most 

communities. Area residents have reported that moose populations have declined over the last 

decade, while competition with other hunters has increased. Implementation of the Yukon-Innoko 

Moose Management Plan will address these local perceptions. 

In addition to fish and big game animals, numerous other subsistence resources are collected from 

the refuge and surrounding areas. Furbearers are trapped for cash and trade; beaver are 

harvested for both meat and pelts; and hares, ducks, geese, grouse, and ptarmigan are hunted as 

well. Berries are harvested and may be eaten fresh or frozen for later use. Many buildings are of 

log construction, and local forests provide much of the needed construction materials. Poles are 

cut for fish-drying racks, tent frames, and other uses. In addition, wood heat is used in many 

households, and firewood cutting is a major activity for some. 

3.4.6 Recreation 

3.4.6.1 Overview 

Recreational visitors access Innoko Refuge by boat on one of several major rivers or by small 

airplane. The refuge issues special use permits for commercial air and boat taxis each year, and 

some visitors arrive in private boats or airplanes as well. There are no recreational facilities 

located on the Innoko Refuge. During the 1980s, two or three commercial air taxi permits were 

issued each year. The number of permits grew to six during the 1990s and has remained at six or 

seven into the present. One or two boat taxi permits are also issued each year. 

Although wildlife observation and photography, camping, berry picking, and other incidental 

activities do occur on the refuge, the primary purpose of most recreational visits is moose hunting 

or fishing. Moose hunting, in particular, is the activity most often associated with Innoko Refuge. 

In a typical year, 120–150 recreational hunters harvest approximately 80 moose on the refuge (this 

is in addition to the subsistence harvest by local area residents). Over the last 20 years, there has 

been an increase in the total number of hunters, an increase in the proportion of non-local hunters 

(i.e., hunters from residences other than Anvik, Grayling, Holy Cross, Kaltag, and Shageluk), and 

a decrease in harvest success rates. 

Compared to moose hunting, which consistently attracts the greatest proportion of refuge visitors, 

recreational fishing participation is highly variable from year to year. Commercial guiding 

interest, weather, water levels, and other factors influence the number of fishing visits each year. 

Special use permit records indicate that in a high-use year, more refuge visitors may participate in 

fishing than in hunting. 

Based on hunting harvest ticket reports, special use permit records, and refuge staff observations, 

the total number of annual refuge visitors (not including local residents who use the refuge) is 

estimated to be 250–400, accounting for an estimated 750 to 1,200 visitor-use days. 

3.4.6.2 Moose Hunting 

Innoko Refuge lies within portions of Alaska Game Management Units (GMUs) 21A, 21D, and 

21E (Figure 3-31). A portion of the refuge is within the Paradise Controlled Use Area identified 

by the Alaska Board of Game and the Federal Subsistence Board. That area is closed during 

moose hunting seasons to the use of aircraft for hunting moose. Since fly-in hunting is primarily 

recreational, the Paradise Controlled Use Area generally restricts recreational hunters. The bulk 

of recreational hunting on Innoko Refuge occurs in GMU 21A along the upper Innoko River. 

3-94 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Figure 3-31. Game management subunits and the Paradise Controlled Use Area 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-95 
Chapter 3: Refuge Resources 

In 1987, when the first Innoko Refuge Comprehensive Conservation Plan was completed, there 

were two permitted hunting guides, two permitted outfitters, and two permitted air taxis on the 

refuge. Collectively, those permit holders reported bringing approximately 50 moose hunters to 

the refuge for an average stay of around five days each. At that time, it was estimated that an 

additional 45 visitors hunted on the refuge without the use of any commercial services. Overall, 

moose hunters accounted for an estimated 500 visitor-use days in the mid to late 1980s. 

In 1993, permitting regulations were restructured on all Alaska national wildlife refuges and four, 

sole-use big-game guide areas were established on Innoko Refuge. A single 10-year permit was 

competitively issued for each guide area. Guide and air taxi permit holders reported a collective 

83 clients for that year. In 1995, one of the four refuge guide areas was eliminated due to concerns 

about potential conflicts with users of the adjacent Paradise Controlled Use Area. In 2003, the 

three remaining guide-area permits (Figure 3-32) were re-issued for another 10-year term. At 

present, there are two big-game guides permitted to operate on the refuge (one guide holds the 

permit for two areas). In 2006, guide and air taxi permit holders reported 46 clients for the year. 

Refuge commercial service providers are required to report the number of clients they serve 

annually as a condition of their permits. Although the reported client numbers are believed to be 

accurate, they only provide a partial picture of overall moose hunting activity because they do not 

represent visitors who hunt without guide or air taxi support. However, all Alaska moose hunters 

are required to file a harvest report indicating, among other things, where they hunted, how they 

accessed the area, and whether or not they were successful. The State of Alaska maintains a 

database with harvest reports from 1983 to the present. Compliance with harvest reporting 

requirements is known to be low in many rural communities where subsistence hunting occurs, 

but among recreational hunters, compliance is known to be excellent. Thus, harvest reports are 

generally agreed to be a reliable and accurate source of information about overall recreational 

moose hunting activity. 

For this discussion, refuge-specific, non-local moose harvest records were identified from the 

State of Alaska database according to the following criteria. 

 Hunt took place in one of the coded geographic areas shown in Figure 3-33 

 Report was filed by a non-Alaska resident or an Alaska resident from a community other 

than Anvik, Grayling, Holy Cross, Kaltag, or Shageluk (where most area subsistence hunters 

live) 

 Harvest occurred in September (effectively excluding subsistence-only hunts that often occur 

during other months of the year) 

Minor errors may have occurred when analyzing the 4,338 records when assigning residency 

status; however, the errors are likely minor in extent and do not substantially affect the analysis. 

Figure 3-34 shows the number of non-local moose hunters on Innoko Refuge for the period 1983 

through 2006. After nearly a decade of substantial annual growth, average annual participation 

began to level off in the early 1990s. Participation is variable from year to year, but average 

annual participation in the 1990s was nearly the same as for the period 2000–2005. Although 

overall numbers are little changed, the proportion of total hunters that are Alaska residents has 

declined measurably since 1999. 

3-96 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Figure 3-32. Big Game Guide Areas 
Chapter 3: Refuge Resources

3-98 
Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Figure 3-33. Uniform coding units used for non-local moose harvest analysis 
Chapter 3: Refuge Resources

3-100 
Chapter 3: Refuge Resources 

Figure 3-34. Residency of non-local moose hunters using Innoko Refuge, 1983–2006 

Despite an increase in the number of air taxis permitted to operate on the refuge, the relative 

proportion of non-local hunters who access the refuge by airplane has changed very little over 

time. Each year, 40–60 percent of non-local moose hunters arrive by airplane, and the others 

arrive by boat (Figure 3-35). 

Figure 3-36 shows the annual non-local moose harvest on the refuge for the period 1983–2006. 

For most of the last 20 years, harvest numbers generally exhibit the same trends as participation 

numbers but with slightly less variability from year to year. The peak harvest year was 1997 (129 

moose), and the peak participation year was 1999 (185 hunters). Since the late 1990s, harvest has 

declined more than participation. The all-time low harvest since 1983 was 33 moose, occurring in 

2006. Hunting participation, while also declining from 2000 through 2003, has remained high 

compared to pre-1990s levels. 

The most substantial change in non-local moose hunting on the refuge is shown in Figure 3-37, 

which plots hunting success rates from 1983 through 2006. The three-year running mean 

treatment shown in the figure reduces some of the year-to-year variability to highlight the overall 

trend. Moose hunting success rates by non-local hunters on the refuge have declined by half since 

1983, from 81 percent to 41 percent in 2006. 

 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-101 
Chapter 3: Refuge Resources 

Figure 3-35. Proportion of non-local moose hunters using boat or aircraft to access hunting areas on Innoko Refuge, 1983–2006 

 

Figure 3-36. Number of moose harvested on Innoko Refuge by non-local hunters, 1983–2006 

3-102 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Figure 3-37. Three-year running mean moose harvest success rate by non-local hunters on Innoko Refuge, 1983–2006. Total 

indicates the total harvest success rate by non-local hunters combined. 

3.4.6.3 Fishing 

Each year, Innoko Refuge issues one or two special use permits for fishing guides who primarily 

advertise opportunities to catch trophy-sized northern pike. Guided fishing within the refuge does 

not appear to be a stable or highly lucrative activity because the reported number of guided 

clients is tremendously variable from year to year, and several permitted guiding operations have 

come and gone over the years. In 1989, a lodge outside of Unalakleet reported 170 fishing clients 

using the lower Innoko and Iditarod rivers, but that high-use period was followed by several years 

with no reported use at all. More recently, refuge permit holders reported more than 200 guided 

fishing client-use days in both 2000 and 2001, followed by four consecutive years with less than 30 

client-use days (Table 3-18). It appears that a host of factors, including river water levels, fuel 

prices, and interest and effort on the part of guides and clients combine to influence annual fishing 

visitation. Refuge annual narratives have consistently indicated that “the potential for overuse of 

the pike fishery is a real concern,” but it appears that potential has not yet materialized into a 

management issue. 

3.4.6.4 Environmental Education and Interpretation Programs 

The Innoko Refuge continues to have a very active environmental education program. It is 

currently administered by the refuge information technician. The education program at Innoko 

combines modern biological science with traditional ecological knowledge. The major constituents 

of the program include annual week-long Earth Week event where refuge staff assists local 

schools with environmental awareness and resource conservation classes. The refuge coordinates 

and manages a week-long science camp each summer at the Round Mountain science camp 

building (Figure 3-38). This facility is located five miles down the Kuskokwim River from 

McGrath on Department of Natural Resources land. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-103 
Chapter 3: Refuge Resources 

Table 3-18. Reported guided fishing use on the Innoko Refuge, 1995–2005 

Year Number of 

Clients 

Number of Fishing 

Use-Days 

1995 0 0 

1996 0 0 

1997 0 0 

1998 8 15 

1999 24 84 

2000 91 205 

2001 126 246 

2002 4 8 

2003 4 28 

2004 3 3 

2005 4 28 

Figure 3-38. Round Mountain science camp lecture, 2007 session (Photo Jerry McDonnell) 

Refuge staff assists in the local school classrooms in environmental and resource education 

classes, including career days with McGrath and Yukon River schools. 

3.5 Wilderness Values 

Section 304(g) of ANILCA requires the Service to identify and describe the special values of the 

refuge, including wilderness values. The term “values” is often viewed synonymously with similar 

terms, from subjective beliefs and preferences (e.g., family values) to more objective functions, 

services, and benefits (e.g., ecological values). Of interest are the objective kinds of values, 

specifically those that are related to the condition and character of the natural environment. 

3-104 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

The 1964 Wilderness Act recognized wilderness as a resource in and of itself and also established 

a mechanism for preserving that resource in a national system of lands. The definition of 

wilderness found in the act provides a framework for identifying and describing wilderness values. 

According to the act, the fundamental qualities of wilderness are undeveloped, untrammeled, 

natural, and outstanding opportunities for solitude, or a primitive and unconfined type of 

recreation. In addition, the act states that wilderness “may also contain ecological, geological, or 

other features of scientific, educational, scenic, or historical value.” 

Undeveloped. This is the most immediately observable and easily measured wilderness quality. 

Undeveloped simply means free from roads, structures, and other evidence of modern human 

presence or occupation. The undeveloped quality strongly influences other core wilderness values—

in particular, experiential opportunities for solitude and primitive recreation. A lone structure may 

have only minimal affects on natural processes while still serving as a constant reminder of human 

influence for recreational visitors. Certain kinds of structures or improvements may be considered 

desirable in a given wilderness setting (e.g., trails) or acceptable according to specific legislation, but 

that does not diminish their negative impact on the undeveloped quality. 

Untrammeled. The Wilderness Act states that wilderness is “an area where the earth and its 

community of life are untrammeled by man.” In other words, wilderness is essentially 

uncontrolled or unrestricted by purposeful human actions. Synonyms for untrammeled include 

unhindered, unencumbered, free-willed, and wild (Landres et al. 2005). The untrammeled quality 

of the wilderness resource is diminished when ecological events or processes are constrained or 

redirected to suit modern human ends (e.g., by suppressing naturally ignited fires or introducing 

non-native plants or animals). 

Natural. Naturalness is a measure of the overall composition, structure, and function of native 

species and ecological processes in an area. In contrast to the quality of being untrammeled, the 

natural condition of an area may sometimes be enhanced through purposeful human action (e.g., 

to restore an eroded stream bank or eradicate an invasive weed). 

Outstanding Opportunities for Solitude. Solitude in the wilderness context is generally understood 

to mean freedom from sights, sounds, and other evidence of modern man (Landres et al. 2005). 

While the relative amount of freedom from these things necessary to experience solitude is highly 

personal and variable, the Wilderness Act states only that outstanding opportunities for solitude be 

provided. Accordingly, encountering other people, hearing mechanized sounds (from aircraft 

overflights, for example), or seeing the lights of a distant population center are all examples of 

things that may negatively affect solitude opportunities; while remoteness, low visitor density, and 

vegetative or topographic screening are things that may enhance solitude opportunities. 

Outstanding Opportunities for a Primitive and Unconfined Type of Recreation. Primitive and 

unconfined recreation occurs in an undeveloped setting and is relatively free from social or 

managerial controls. Primitive recreation in wilderness has largely been interpreted as travel by 

non-motorized and non-mechanical means. Primitive recreation is also characterized by experiential 

dimensions such as challenge, risk, and self-reliance. Dispersed use patterns, which frequently 

occur where there are no facilities to concentrate use, enhance opportunities for self-reliance and 

solitude. Conversely, some actions aimed at maintaining opportunities for solitude, such as limited 

permit management systems, may negatively affect opportunities for unconfined experiences. 

Other Special Features. Lands that exhibit the core wilderness qualities described above may 

also contain additional special features with scientific, educational, scenic, or historic value. While 

the Wilderness Act makes it clear that these features are not wilderness qualities in and of 

themselves, their presence may distinguish one area with wilderness values from another. In the 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-105 
Chapter 3: Refuge Resources 

context of Alaska refuges, special features might include such things as active volcanoes, unique 

abundance or concentrations of a given species, fossil deposits, or evidence of prehistoric cultures. 

In 1980, 1,240,000 acres of Innoko Refuge was designated as a Wilderness Area by ANILCA 

(Figure 3-39). Additionally, as directed by sections 304(g) and 1317 of ANILCA, lands currently 

administered by Innoko Refuge were reviewed during preparation of the first Comprehensive 

Conservation Plan in 1987 “as to their suitability or nonsuitability for preservation as wilderness.” 

The following identification and description of wilderness values is based on that previous review, 

with additions and amendments as appropriate. 

3.5.1 Characteristics Common to All Units 

In designating the Innoko Wilderness Area, Congress found that it exhibits the characteristics of 

wilderness described in the Wilderness Act. Most of the refuge lands within the Wapoo Hills and 

Kaiyuh Mountains units also exhibit all the core wilderness values. They are largely undeveloped, 

untrammeled, and highly natural, and support abundant opportunities for solitude and primitive 

recreation. All three management units support the full suite of fish and wildlife species and plant 

communities that represent area ecosystems. Although the units generally have very few visible 

signs of human manipulation or permanent human presence, there are scattered trapping cabins 

and remnants of other uses within each of them. As directed by sections 304(g) and 1317 of 

ANILCA, lands administered by the refuge were reviewed in 1987 during development of the 

refuge’s first Comprehensive Conservation Plan “as to their suitability or nonsuitability for 

preservation as wilderness.” The review found all non-designated refuge lands suitable for 

designation as wilderness. The Record of Decision signed by the Service Alaska regional director 

on December 29, 1987, did not recommend any additional lands for inclusion in the National 

Wilderness Preservation System. 

3.5.2 Designated Wilderness Unit 

The 1,315,747-acre designated wilderness is bounded on the west by the Innoko River and extends 

south and east to the refuge boundary. The majority of the wilderness unit is wetland and 

contains one large lake, Sixmile Lake. Travel in the interior of the unit is difficult, but the rivers 

of the unit are used as travel corridors. The Iditarod National Historic Trail traverses this unit. 

The Iditarod and Yetna River corridors contain opportunities for hunting the interior areas of the 

Wilderness Unit. Visitors can expect a high degree of solitude and ample opportunities to test 

their primitive recreation skills. 

3.5.3 Wapoo Hills Unit 

This 1,060,000-acre unit extends from the Innoko Wilderness Area upstream along the Innoko 

river. It is bounded on the west by Magitchlie Creek. The unit is dominated by vast wetlands 

with many feeder streams flowing into the Innoko River. These wetland areas commonly 

experience flooding in the spring, have high fertility, and are rich in invertebrates and aquatic 

plants. There are no developments other than the refuge’s field camp and very few human-use 

impacts of any kind. Cross-country travel is possible on frozen waterways in the winter but is 

generally limited to boats and airplanes in the summer. There is little to attract recreationists to 

the unit and thus, there are very few recreation visitors; but people who choose to visit can expect 

a high degree of solitude and ample opportunities to test their primitive recreation skills. 

3-106 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Figure 3-39. Innoko Wilderness Area and Wilderness study area units 
Chapter 3: Refuge Resources

3-108 
Chapter 3: Refuge Resources 

3.5.4 Kaiyuh Mountains Unit 

This 1,239,000-acre unit is bounded on the west by the Yukon River, and a portion of its eastern 

flank is defined by the Innoko River. The terrain is about evenly split between wetlands and hilly 

upland areas. Much of the land along the Yukon River boundary and some of the river islands are 

owned by Native corporations. The islands are unique and ecologically important. Travel in the 

interior of the unit is difficult, but the river boundaries are popular travel corridors. The Yukon 

River has substantial barge and boat traffic in the summer, and snowmachine traffic in the winter. 

Similar to the Wapoo Hills Unit, the interior of this unit has few attractions for the recreational 

visitor beyond its wild, natural character. Visitors can expect a high degree of solitude and ample 

opportunities to test their primitive recreation skills. 

3.6 River Values 

3.6.1 Introduction 

Section 304(g) of ANILCA requires the Service to identify and describe certain values of the 

refuge including “....archeological, cultural, ecological, geological, historical, paleontological, 

scenic, or wilderness values...” River resources may contain a variety of these and other values 

and thus need to be described and evaluated. 

The 1968 Wild and Scenic Rivers Act (U.S. Government 1968) provides a framework for 

identifying and describing river values. The act recognized the importance of a river’s freeflowing nature and specific “outstandingly remarkable values” such as scenery, recreation, 

geology, fish and wildlife, history, etc. An analysis of river resources consists of an examination of 

the river’s hydrology, including man-made alterations, and an inventory of its natural, cultural, 

and recreational resources. To be assessed as outstandingly remarkable, a river-related value 

must be a unique, rare, or exemplary feature that is significant at a comparative regional or 

national scale. While the spectrum of resources that may be considered is broad, all values should 

be directly river-related and should: 

 be located in the river or on its immediate shorelands (in Alaska, generally within one-half 

mile on either side of the river); 

 contribute substantially to the functioning of the river ecosystem; and/or 

 owe their location or existence to the presence of the river. 

This section describes ten rivers or segments of rivers that are free-flowing and have at least one 

outstandingly remarkable value (Figure 3-40). 

3.6.2 Outstandingly Remarkable Values 

An outstandingly remarkable value is defined in section 1(b) of the Wild and Scenic Rivers Act 

(U.S. Government 1968) as a unique, rare or exemplary feature that is significant at a comparative 

regional or national scale. 

The following criteria are offered to foster greater consistency within the Federal riveradministering agencies. They are intended to set minimum thresholds to establish outstandingly 

remarkable values and are illustrative but not all-inclusive. If utilized in an agency's planning 

process, these criteria may be modified to make them more meaningful in the area of comparison, 

and additional criteria may be included. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-109 
Chapter 3: Refuge Resources 

3.6.2.1 Scenic Values 

The landscape elements of landform, vegetation, water, color, and related factors result in notable 

or exemplary visual features and/or attractions. When analyzing scenic values, additional 

factors—such as seasonal variations in vegetation, scale of cultural modifications, and the length 

of time negative intrusions are viewed—may be considered. Scenery and visual attractions may 

be highly diverse over the majority of the river or river segment. 

3.6.2.2 Recreation Values 

Recreational opportunities are, or have the potential to be, popular enough to attract visitors from 

throughout or beyond the region of comparison or are unique or rare within the region. Visitors 

are willing to travel long distances to use the river resources for recreational purposes. Riverrelated opportunities could include but are not limited to sightseeing, wildlife observation, 

camping, photography, hiking, fishing, and boating. Interpretive opportunities may be exceptional 

and attract, or have the potential to attract, visitors from outside the region of comparison. The 

river may provide, or have the potential to provide, settings for national or regional usage or 

competitive events. 

3.6.2.3 Wildness Values 

The value or character of wildness represents vestiges of primitive America. Wild rivers may be 

characterized as being untrammeled, natural, and undeveloped, providing opportunities for 

solitude or a primitive and unconfined type of recreation. Untrammeled means unhindered and 

free from modern human control or manipulation. Natural means ecological systems are 

substantially free from the effects of modern civilization. Undeveloped means substantially 

without permanent improvements or modern human occupation. 

3.6.2.4 Geologic Values 

The river, or the area within the river corridor, contains one or more example of a geologic 

feature, process, or phenomenon that is unique or rare within the region of comparison. The 

feature(s) may be in an unusually active stage of development, represent a "textbook" example, 

and/or represent a unique or rare combination of geologic features (erosion, volcanic, glacial, or 

other geologic structures). 

3.6.2.5 Fish Values 

Fish values may be judged on the relative merits of fish populations, habitat, or a combination of 

these river-related conditions. 

Populations 

The river is nationally or regionally an important producer of resident and/or anadromous fish 

species. Of particular significance is the presence of wild stocks and/or Federal or State listed (or 

candidate) threatened, endangered or sensitive species. Diversity of species is an important 

consideration and could, in itself, lead to a determination of “outstandingly remarkable.” 

Habitat 

The river provides exceptionally high quality habitat for fish species indigenous to the region of 

comparison. Of particular significance is habitat for wild stocks and/or Federal or State listed (or 

candidate) threatened, endangered, or sensitive species. Diversity of habitats is an important 

consideration and could, in itself, lead to a determination of “outstandingly remarkable.” 

3-110 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Figure 3-40. Rivers with special values 
Chapter 3: Refuge Resources

3-112 
Chapter 3: Refuge Resources 

3.6.2.6 Wildlife Values 

Wildlife values may be judged on the relative merits of either terrestrial or aquatic wildlife 

populations or habitat or a combination of these conditions. 

Populations 

The river, or area within the river corridor, contains nationally or regionally important 

populations of indigenous wildlife species. Of particular significance are species considered to be 

unique and/or populations of Federal or State listed (or candidate) threatened, endangered or 

sensitive species. Diversity of species is an important consideration and could, in itself, lead to a 

determination of “outstandingly remarkable.” 

Habitat

The river, or area within the river corridor, provides exceptionally high quality habitat for wildlife 

of national or regional significance and/or may provide unique habitat or a critical link in habitat 

conditions for Federal or State listed (or candidate) threatened, endangered, or sensitive species. 

Contiguous habitat conditions are such that the biological needs of the species are met. Diversity 

of habitats is an important consideration and could, in itself, lead to a determination of 

“outstandingly remarkable.” 

3.6.2.7 Cultural Values 

The river or area within the river corridor contains archaeological sites or areas significant to 

traditional cultures. Examples might be American Indian burial grounds, petroglyphs, the oldest 

known human use site in a region, or streams that support traditional agriculture, subsistence 

fishing, or religious ceremonies. 

3.6.2.8 Historic Values 

The river or area within the river corridor contains a site(s) or feature(s) associated with a 

significant event, an important person, or a cultural activity of the past that was rare or one-of-akind in the region. Many such sites are listed on the National Register of Historic Places. A 

historic site(s) and/or features(s) is 50 years old or older, in most cases. 

3.6.2.9 Prehistoric Values 

The river, or area within the river corridor, contains a site(s) where there is evidence of occupation 

or use by Native Americans. Sites must have unique or rare characteristics or exceptional human 

interest value(s). Sites may have national or regional importance for interpreting prehistory; may 

be rare and represent an area where a culture or cultural period was first identified and 

described; may have been used concurrently by two or more cultural groups; and/or may have 

been used by cultural groups for rare sacred purposes. Many such sites are listed on the National 

Register of Historic Places, which is administered by the National Park Service. 

3.6.2.10 Other Values 

While no specific national evaluation guidelines have been developed for the “other similar values” 

category, assessments of additional river-related values consistent with the foregoing guidance 

may be developed, including but not limited to, hydrology, paleontology and botany resources. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-113 
Chapter 3: Refuge Resources 

3.6.3 Rivers and River Segments 

In interior Alaska, rivers provide vital habitat and function as important travel corridors for 

people and animals. Rivers support subsistence activities and attract recreational users 

interested in fishing, hunting, boating, and wildlife observation. Fish and wildlife travel and feed 

in and along rivers and rear young in associated terrestrial habitat, ponds, and wetlands. 

Based on the criteria listed in section 3.6.2, six rivers and/or river segments have been identified as 

exceptional examples of the rivers flowing through the refuge (Figure 3-40). 

3.6.3.1 Yukon River 

Outstandingly Remarkable Values: Fish, Wildlife 

Approximately 12 percent of the refuge drains directly into the Yukon River, which forms 105 

miles of the refuge’s western boundary (Figure 3-41). The river is a crucial migration corridor for 

anadromous fish, including smolts heading downstream to the ocean and adults returning 

upstream to spawn, and many of the islands found within it provide critical winter moose habitat. 

Figure 3-41. Yukon River in winter (Photo Robin Corcoran, USFWS) 

3.6.3.2 Innoko River 

Outstandingly Remarkable Values: Fish, Wildlife, Recreation 

The Innoko River (Figure 3-42), which is the primary drainage of the refuge and a major tributary 

of the Yukon River, flows for 250 miles within the boundaries of the refuge. The river provides 

important aquatic habitat for fish and is an important travel corridor for wildlife. Nine species of 

fish are known to occur in the upper Innoko River: Arctic grayling, broad whitefish, burbot, 

Chinook salmon, chum salmon, humpback whitefish, least cisco, northern pike, and sheefish. Fish 

use the river to migrate between seasonal ranges, and the river’s deeper pools provide important 

overwintering habitat, as associated deep lakes are only connected to the mainstream at flood 

stage. The river provides ideal habitat conditions for very large, old northern pike, which in turn 

provides for a world-class pike fishery. Moose commonly feed on the willows along the river. 

Bears opportunistically feed on fish, other wildlife, and vegetation in the corridor. Tracks and scat 

of brown and black bear, lynx, wolf, wolverine, beaver, river otter, and other mammals are 

3-114 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

commonly found along the river, though actual animals are observed less so. During the summer 

months, common birds on the river include white-fronted geese, lesser Canada geese, swallows, 

and numerous species of ducks. Several abandoned villages and sites that are important to Alaska 

Native and Gold Rush history are located along the Innoko River, including Holikachuk, 

Dishkakat, and Rennies Landing. 

Figure 3-42. Innoko River (Photo Leon Kolankiewicz) 

3.6.3.3 Dishna River 

Outstandingly Remarkable Values: Wilderness, Historic 

The Dishna River, a tributary of the Innoko River, is unique among rivers on the refuge in that it 

is shallower and faster than others, making it difficult to access by floatplane. As such, the river 

provides for recreation opportunities in a wilderness setting where solitude is of a degree 

uncommon to other areas of the refuge. The historic townsite of Tolstoi is in the Dishna drainage 

just outside the refuge boundary. 

3.6.3.4 Hather and Magitchlie Creeks 

Outstandingly Remarkable Value: Wilderness 

Hather Creek (Figure 3-43) and Magitchlie Creek drain approximately 520 square miles of the 

northwest section of the refuge. These creeks have relatively slow-moving currents and are only 125 

feet wide at their confluence 12 miles above the Innoko River. The creeks are difficult to access by 

floatplane, and as such, like the Dishna, provide for recreation opportunities in a wilderness setting 

where solitude is of a degree uncommon to other areas of the refuge. While traveling along this 

river, common wildlife sightings include moose, brown bear, and beaver. Waterfowl nest and rear 

young in the surrounding marshes. This area was once utilized by several trappers. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-115 
Chapter 3: Refuge Resources 

Figure 3-43. Hather Creek (Photo Robin Corcoran, USFWS) 

3.6.3.5 Iditarod River 

Outstandingly Remarkable Values: Historic, Wildlife, Hydrology 

The Iditarod River (Figure 3-44) originates near the Iditarod Nixon Fault and drains 3,194 square 

miles. Sites related to the Iditarod National Historic Trail occur along the Iditarod River. The lower 

Iditarod River system provides one of Alaska’s largest concentrations of interior white-fronted 

geese during the molting season; this area is the heart of Innoko Refuge’s waterfowl production. A 

unique feature of the lower Iditarod system, along with the Innoko River, is the hydrology. During 

spring floods, literally hundreds of square miles can be inundated with several feet of water. This 

natural function helps create the habitat required by waterfowl and many other species. 

Figure 3-44. Iditarod River (Photo Leon Kolankiewicz) 

3-116 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

3.6.3.6 Shageluk/Holikachuk Slough System 

Outstandingly Remarkable Values: Hydrology, Historic, Wildlife 

This system connects the Yukon River with the Innoko River. Water flows from the Yukon, about 

15 river miles upstream of Grayling, into the Shageluk Slough, which then flows into the Innoko 

River just below the refuge’s southern boundary. Shageluk Slough also splits into the Holikachuk 

Slough about 40 miles from the Yukon, and Holikachuk Slough then flows about 25 miles—

entering the Innoko River just upstream of the village of Holikachuk. This slough system has a 

large effect on the Innoko River below the refuge because two river systems merge together. It is 

also significant to the local population as a historic transportation route. The 

Shageluk/Holikachuk Slough system is unique in that it is located at the southernmost point of the 

Kayiuh Mountains and acts as a vast island situated between the Yukon and Innoko rivers, which 

provide habitat for a variety of wildlife throughout the year. 

 

3.7 Refuge Infrastructure and Administration 

3.7.1 Administrative Facilities 

The Innoko Refuge is administered out of the headquarters office in McGrath and a field camp 

complex on the Innoko River. The McGrath facilities consist of the office building, which is a 

leased three-story building, of which the refuge staff occupy about one-half the building. The 

refuge leases a lot at the McGrath Airport and has a weatherport structure and three aircraft tiedowns for storage. The refuge leases three homes in McGrath to provide housing for staff, and 

the refuge owns two houses and a small shop building within the city of McGrath. There is a 

floatplane dock, stairway, and ramp on the Kuskokwim River at the McGrath office. 

The Innoko field camp is located just off the Innoko River in the northern half of the refuge and 

consists of a kitchen and meeting facility, a log cabin and dry lab, shop and storage building, a 

generator shed, and six sleeping cabins. There are two floatplane docks located at “Camp Lake” 

on the Innoko River, and three 500-gallon double-walled fuel tanks. This facility is used all field 

season, from the end of May through the beginning of October, and for various survey work 

during the remainder of the year. 

Several historical cabins are located at the Rennies Landing site on Innoko Refuge. These 

buildings were constructed during the Gold Rush of the early 1900s and are in need of 

stabilization, as they are not unusable in their present condition. A proposal has been made by the 

refuge to stabilize and rebuild these structures. 

Other leased land sites include three radio repeater sites located off refuge property. Repeater 

sites, which consist of a structure enclosing a radio and battery bank, are located at Beaver 

Mountain and Mount Hurst (both to the east of the refuge) and at Blackburn Mountain (to the 

west of the refuge and Yukon River). 

3.7.2 Staffing 

The current staffing at Innoko Refuge consists of eight permanent positions. Seasonal and 

temporary employees are hired to assist permanent staff using various hiring authorities, 

including the Student Career Experience Program (SCEP). The refuge also has an active 

volunteer program in most years. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-117 
Chapter 3: Refuge Resources 

Current authorized Innoko staff include : 

 Wildlife refuge manager 

 Deputy wildlife refuge manager 

 Wildlife biologist 

 Fire management officer 

 Airplane pilot 

 Law enforcement officer/pilot 

 Refuge information technician 

 Administrative support assistant 

 Maintenance worker 

3.8 References Cited 

Alaska Community Database. 2007. 

www.commerce.state.ak.us.dca/commdb/CF_BLOCK.cfm 

Alaska Department of Commerce, Community, and Economic Development. 2008. Alaska 

Community Database Online, available at: 

www.commerce.state.ak.us.dca/commdb/CF_BLOCK.cfm 

Alaska Department of Fish and Game. 1998. Annual performance report, survey-inventory 

activities 1 July 1997-30 June 1998. MV Hicks, editor. Grant W-27-1. Study 3.0. 

Juneau, Alaska. 

Alaska Department of Fish and Game. 2001. Caribou management report of surveyinventory activities 1 July 1998-30 June 2000. C. Healy, editor. Project 3.0. 

Juneau, Alaska. 

Alaska Department of Fish and Game. 2006a. Our wealth maintained: a strategy for 

conserving Alaska’s diverse wildlife and fish resources. Alaska Department of 

Fish and Game. Juneau, Alaska. 

Alaska Department of Fish and Game. 2006b. Yukon-Innoko moose management plan for 

game management subunits 21A and 21E. Alaska Department of Fish and 

Game. Juneau, Alaska. 

Alaska Department of Fish and Game. 2006c. Yukon River Fall Chum Salmon Stock 

Status and Fall Season Fisheries: A Report to the Alaska Board of Fisheries. 

SP No. 06-36. http://www.sf.adfg.state.ak.us/FedAidPDFs/sp06-36.pdf 

Alaska Department of Fish and Game. 2007. Wood bison restoration in Alaska: a review of 

environmental and regulatory issues and proposed decisions for project 

implementation. Alaska Department of Fish and Game. Juneau, Alaska. 

Alaska Department of Fish and Game, Division of Commercial Fisheries. 2005. Regional 

Information Report: Subsistence and Personal Use Salmon Harvests in the 

Alaska Portion of the Yukon Drainage. 

Alaska Department of Natural Resources. 2006. Alaska DNR mining district. Lands 

Records Information Section. Anchorage, Alaska. Digital media. 

http://fox.dnr.state.ak.us/SpatialUtility/SUC?cmd=vmd&layerid=188 

Alaska Department of Natural Resources, Division of Land and Water Management. 1986. 

Kuskokwim Area Plan, Minerals Element. Anchorage, AK, 87pp. 

3-118 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Alaska Game Commission. 1931. Annual report of the executive officer to the Alaska Game 

Commission. US Fish and Wildlife Service. Juneau, Alaska. 

Alaska Natural Heritage Program. 2006. Weed ranking project. 

http://akweeds.uaa.alaska.edu/akweeds_ranking_page.htm, accessed 17 July 

2007. 

Alaska-Yukon Magazine, 1911. Trail Making in Alaska, by W.L. Goodwin. 1910. Pp 49–55. 

Alt, K.T. 1981. Life history study of sheefish in Alaska. Alaska Department of Fish and 

Game, Federal Aid in Fish Restoration, Project F-9-13, Study R-11, volume 22. 

Juneau, AK. 

Alt, K.T. 1983. Inventory and cataloging of sport fish and sport fish waters of western 

Alaska. Alaska Department of Fish and Game. Federal Aid in Fish 

Restoration Project F-9-15, Study Number G-1, Volume 24:34-71. 

Amaranthus, M., H. Jubas, and D. Arthur. 1989. Stream shading, summer streamflow and 

maximum water temperature following intense wildfire in headwater streams. 

Proceedings of the symposium on fire and watershed management. 109:75-78. 

Andersen, D.B. and C.L. Fleener 2001. Whitefish and beaver ecology of the Yukon Flats, 

Alaska. Alaska Department of Fish and Game, Division of Subsistence, Final 

Report No. FIS00-06. Fairbanks, Alaska. 74 pp. 

Andreev, V.N. 1977. Reindeer pastures in the subarctic territories of the USSR. Pages 

275-313 in Krause, editor. Handbook of vegetation science. Part XIII. 

Application of vegetation science to grassland husbandry. The Hague. 

Bailey, R.G. 1980. Descriptions of the ecoregions of the United States. USDA Forest 

Service Misc. Publ. No. 1391. Washington D.C. 

Ballard, W., J.S. Whitman, and D.J. Reed. 1991. Population dynamics of moose in southcentral Alaska. Wildlife Monographs. 114. 49 pp. 

Ballard, W.B., P.R. Krausman, S. Boe, S. Cunningham, and H.A. Whitlaw. 2000. Shorttern response of gray wolves, Canis lupis, to wildfire in northwestern Alaska. 

Canadian Field-Naturalist 114(2):241-247. 

Banfield, A.W.F. 1974. The mammals of Canada. University of Toronto Press. Toronto, 

Ontario, Canada. 

Bayley, S.E., and Prather, C.M. 2003. Do wetland lakes exhibit alternative stable states? 

Submersed aquatic vegetation and chlorophyll in western boreal shallow lakes. 

Limnol. Oceanogr. 48: 2335–2345. 

Beikman, H. 1974. Preliminary Geologic Map of the Southwest Quadrant of Alaska. In 

cooperation with the State of Alaska. U.S. Geological Survey Miscellaneous 

Field Studies Map MF-611. 

Bergelson, J. 1990. Life after death: site pre-emption by the remains of Poa annua. 

Ecology. 71(6): 2157-2165. 

Bergerud, A.T., and D.R. Miller. 1977. Population dynamics of Newfoundland beaver. 

Canadian Journal of Zoology. 55:1480-1492. 

Bliss, L.C.; and R.W. Wein. 1972. Plant community responses to disturbances in the 

western Canadian Arctic. Canadian Journal of Botany. 50: 1097-1109. 

Boreal Partners in Flight. 2006. Conservation of Landbirds in Alaska: Priority Species for 

Conservation. http://www.absc.usgs.gov/research/bpif/priority_spp.html 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-119 
Chapter 3: Refuge Resources 

Boreal Partners in Flight Working Group. 1999. Landbird conservation plan for Alaska 

biogeographic regions. Version 1.0. Unpublished report. US Fish and Wildlife 

Service. Anchorage, Alaska. 

Boudreau, T.A. 2001. Units 19ABC&D and 21A&E caribou management report. Pages 

114-122. In C. Healy, editor. Caribou Management report of survey-inventory 

activities 1 July 1998-30 June 2000. Alaska Department of Fish and Game. 

Federal Aid in Wildlife Restoration. Project 3.0. Juneau, Alaska. 

Boudreau, T.A. 2005. Units 19ABC&D and 21A&E caribou management report. Pages 

113-125. In C. Brown, editor. Caribou Management report of survey-inventory 

activities 1 July 2002-30 June 2004. Alaska Department of Fish and Game. 

Federal Aid in Wildlife Restoration. Project 3.0. Juneau, Alaska. 

Boutin, S., C.J. Krebs, R. Boonstra, M.R.T. Dak, S.J. Hannon, K. Martin, A.R.E. Sinclair, 

J.N.M. Smith, R. Turkington, M. Blower, A. Byron, F.I. Doyle, C. Doyle, D. 

Hik, L. Hofer, T. Karels, D. L. Murray, V. Nams, M. O’Donohue, C. Rohner, 

and S. Schwieger. 1995. Population changes of the vertebrate community 

during a snowshoe hare cycle in Canada’s boreal forest. Oikos 74:69-80. 

Brand, C.J., and L.B. Keith. 1979. Lynx demography during a snowshoe hare decline in 

Alberta. Journal of Wildlife Management 43:827-849. 

Brown, Caroline. 2007. Contemporary Subsistence Uses of Non-Salmon Fish in the Yukon 

Area, Alaska Department of Fish and Game, Briefing Note, January. 

Brown, Caroline; John Burr, Kim Elkin, and Robert J. Walker. 2005. Contemporary 

subsistence uses and population distribution of non-salmon fish in Grayling, 

Anvik, Shageluk, and Holy Cross. Technical Paper #289. Alaska Department 

of Fish and Game, Division of Subsistence. Fairbanks, Alaska. 

Brown, Caroline and David Koster. 2005. The 2003-2004 harvest of moose, caribou, bear, 

and wolves in the lower-middle Yukon River communities of Grayling, Anvik, 

Shageluk, and Holy Cross. Technical Paper #298. Results of the Big Game 

Harvest Assessment Project. Alaska Department of Fish and Game, Division 

of Subsistence. Juneau, Alaska. 

Brown, J., O.J. Ferrians, Jr., J.A. Heginbottom, and E.S. Melnikov. 1998, revised 

February 2001. Circum-arctic map of permafrost and ground ice conditions. 

Boulder, CO: National Snow and Ice Data Center/World Data Center for 

Glaciology. Digital media. 

Brown, R.J., N. Bickford, and K. Severin. 2007. Otolith trace element chemistry as an 

indicator of anadromy in Yukon River drainage Coregonine fishes. 

Transactions of the American Fisheries Society 136:678-690. 

Brown, R.J. and C. Fleener 2001. Beaver dam influence on fish distribution in lentic and 

lotic habitats in the Black River drainage, Alaska. Unpublished USFWS 

report, Fairbanks, Alaska. 42 pp. 

Bryant, J.M, B.D. Scotton, and M.R. Hans. 2005. Sympatric nesting range of trumpeter 

and tundra swans on the Koyukuk National Wildlife Refuge in northwest 

interior Alaska. US Fish and Wildlife Service, Galena, Alaska. Progress Report 

FY-05-02. 

Buklis, L.S. and L.H. Barton. 1984. Yukon River fall chum salmon biology and stock 

status. Alaska Department of Fish and Game, Commercial Fisheries Division, 

Technical Report. Anchorage, AK. 

3-120 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Bundtzen, T.K., B.C. Cox, and N.C. Veach. 1987. Heavy mineral provenance studies in 

the Iditarod and Innoko Districts, western Alaska. Alaska Division of 

Geological and Geophysical Surveys, Public-data File 87-16, 25pp. 

Bundtzen, T.K. 2004. Alaska Resource Date File Iditarod Quadrangle. U.S. Geological 

Survey Open-file Report No. 2004-1311, 373pp. 

Bureau of Land Management, Innoko National Wildlife Refuge, and Ducks Unlimited. 

2002. Innoko earth cover classification. Bureau of Land Management, 

Anchorage, Alaska. Technical Report 47. 

Busher, W.H. and T. Hamazaki. 2005. Subsistence and personal use salmon harvest in the 

Alaska portion of the Yukon River drainage, 2003. Alaska Department of Fish 

and Game, Division of Commercial Fisheries, Regional Information Report No. 

3A04-33. Anchorage, AK. 

Carbyn, L. N. 1987. Gray wolf and red wolf. Pages 359-376 in M. Novak, J. A. Baker, M. E. 

Obbard, and B. Mallock, editors. Wildlife furbearer management and 

conservation in North America. Ontario Trappers Association, Toronto, Canada. 

Chapin, F.S., III., M. Sturm, M.C. Serreze, J.P. McFadden, J.R. Key, A.H. Lloyd, A.D. 

McGuire, T.S. Rupp, A.H. Lynch, J.P. Schimel, J. Beringer, W.L. Chapman, 

H.E. Epstein, E.S. Euskirchen, L.D. Hinzman, G. Jia, C.L. Ping, K.D. Tape, 

C.D. C. Thompson, D.A. Walker, J.M. Welker. 2005. Role of land-surface 

changes in arctic summer warming. Science 310: 657-660. 

Chapin S.F. 2000. Climate-disturbance interactions in the Alaskan boreal forest. A proposal 

to renew interaction of multiple disturbances with climate in Alaskan boreal 

forests. Submitted to the LTER Program of the National Science Foundation. 

Chapin S.F. 2004. Alaska’s Changing Boreal Forest: Resilience and Vulnerability. 2004 

Bonanza Creek LTER Renewal Proposal. Submitted to the LTER Program of 

the National Science Foundation. 

Chapman, Robert M. 1963. Coal Deposits along the Yukon River Between Ruby and 

Anvik, Alaska. Pages 18-29 in U.S. Geological Survey. Contributions to 

Economic Geology of Alaska. USGS Bulletin 1155. [Washington D.C.], [1 vol.]. 

Charette, T., and E.E. Prepas. 2003. Wildfire impacts on phytoplankton communities of 

three small lakes on the boreal plain, Alberta, Canada: a paleolimnological 

study. Canadian Journal of Aquatic Science 60:584-593. 

Cheney, W.L. 1971. Life history investigations of northern pike in the Tanana River 

drainage. Alaska Department of Fish and Game, Federal Aid in Fish 

Restoration, Annual Progress Report, 1970-71, Project F-9-3, Study R-11, 

volume 12. Juneau, AK. 

Clark, Donald. 1991. Western Subarctic Prehistory. Canadian Museum of Civilization, 

Hull, Quebec. 

Clark, Donald. 2001. Microblade Culture Systematics in Far Northwestern Canada. 33rd

Annual Meeting of the Canadian Archaeological Association. 

Collins, R. 2006. University of Alaska, Fairbanks. Conversation with Steve Kovach about 

the history of moose in Interior Alaska. 

Collins, W.B., and D.J. Helm. 1997. Moose, Alces alces, habitat relative to riparian 

succession in the boreal forest, Susitna River, Alaska. Canadian FieldNaturalist 111(4):567-574. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-121 
Chapter 3: Refuge Resources 

Conant, B., J.I. Hodges, D.J. Groves, and J.G. King. 2007. Alaska Trumpeter Swan 

Status Report 2005. U.S. Fish and Wildlife Service Report, Juneau, Alaska. 

51pp. 

Courturier, S., J. Brunelle, D. Vandal, and G. St-Martian. 1990. Changes in population 

dynamics of the George River caribou herd, 1976-1987. Arctic 43:9-20. 

Dashevsky S.S. 2002a. Alaska Resource Date File Ophir Quadrangle. U.S. Geological 

Survey Open-file Report No. 02-77, 87pp. 

Dashevsky S.S. 2002b. Alaska Resource Date File Nulato Quadrangle. U.S. Geological 

Survey Open-file Report No. 02-54, 64pp. 

Dashevsky S.S. 2002c. Alaska Resource Date File Unalakleet Quadrangle. U.S. 

Geological Survey Open-file Report No. 02-95, 14pp. 

Davis, J.L. 1978. History and current status of Alaska caribou herds. Pages 1-8. In DR 

Klein and RG White, editors. Parameters of caribou population ecology in 

Alaska. Biological Papers of the University of Alaska. Special Report Number 

3. Fairbanks, Alaska. 

Davis, J.L., and A.W. Franzmann. 1979. Fire-moose-caribou interrelationships: a review 

and assessment. Alces. 17:80-118. 

Dice, L.R. 1921. Notes on the mammals of interior Alaska. Journal of Mammalogy. 

2(1):20-28. 

Doyle, T.J., S. Breeser, D.G. Kelleyhouse, and D.V. Grangaard. 1988. Early summer 

predation rates and movements of a denning wolf pack in east-central Alaska. 

Unpublished Report. U.S. Fish and Wildlife Service, Tok, Alaska, USA. 

Duchesne, L.C. and B.C. Hawkes. 2000. Chapter 3: Fire in northern ecosystems. Pages 

35-51. In Brown, James K; Smith, Jane Kapler, eds. Wildland fire in 

ecosystems: effects of fire on flora. Gen. Tech. Rep. RMRS-GTR-42-vol. 2. 

Ogden, UT: U.S. Department of Agriculture, Forest Service, Rocky Mountain 

Research Station. 257 p. 

Dumond, Don E. 2001. The Archaeology of Eastern Beringia: Some Contrasts and 

Connection. Arctic Anthropology 38(2):196-205. 

Eiler, J.H., T.R. Spencer, J.J. Pella, and M.M. Masuda. 2006a. Stock composition, run 

timing, and movement patterns of Chinook salmon returning to the Yukon 

River basin in 2004. National Marine Fisheries Service. NOAA Technical 

Memorandum NMFS-AFSC-165. Juneau, AK. 

Eiler, J.H., T.R. Spencer, J.J. Pella, and M.M. Masuda. 2006b. Stock composition, run 

timing, and movement patterns of Chinook salmon returning to the Yukon 

River basin in 2003. National Marine Fisheries Service. NOAA Technical 

Memorandum NMFS-AFSC-163. Juneau, AK. 

Eiler, J.H., T.R. Spencer, J.J. Pella, M.M. Masuda, and R.R. Holder. 2004. Distribution 

and movement patterns of Chinook salmon returning to the Yukon River basin 

in 2000-2002. National Marine Fisheries Service. NOAA Technical 

Memorandum NMFS-AFSC-148. Juneau, AK. 

Elliott, H.W. 1875. A report upon the condition of affairs in the Territory of Alaska. US 

Treasury Department, Special Agents Division. Washington, D.C. 

Ely, C.R. and J.A. Schmutz. 1999. Geographic variation in distribution and survival of mid 

continent greater white-fronted geese. Report submitted to the Central 

Flyway Technical Committee, March 5, 1999, Lawton, Oklahoma. 

3-122 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Ely, C.R. and J. Terenzi. 2004. Population discrimination and microgeographic 

structuring of molting greater white-fronted geese in interior Alaska. Poster 

presentation tenth Alaska Bird Conference. 

Ely, C.R., K.S. Bollinger, J.W. Hupp, D.V. Derksen, J. Terenzi, J.Y. Takekawa, D.L. 

Orthmeyer, T.C. Rothe, M.J. Petrula, and D.R. Yparraguirre. 2006. 

Traversing a boreal forest landscape: summer movements of tule greater 

white-fronted geese. Waterbirds 29:43-55. 

Fagerstone, K.A. 1987. Black-footed ferret, long-tailed weasel, short-tailed weasel, and 

least weasel. Pages 549-573 in M. Novak, J.A. Baker, M.E. Obbard, and B. 

Malloch, editors. Wild furbearer management and conservation in North 

America. Ministry of Natural Resources. Toronto, Ontario, Canada. 

Flora, B.K. 2002. Spatial comparison of interior Alaska snowshoe hare populations and 

assessment of the hare pellet: hare density relationship in Alaska. Unpublished 

M.S. thesis, University of Alaska Fairbanks, 94 pp. 

Foley, J.Y., T. Hinderman, C.C.Hawley and Associates, Incorporated, Anchorage, Alaska, 

U. Kirby & C,. Mardock, Albany Research Center, Albany Oregon, 1984. 

Chromite Occurrences in the Kaiyuh Hills, West-central Alaska. U.S. Dept. of 

the Interior. Bureau of Mines. Open File Report 178-84. 20 pp. 

Foote, M.J. 1983. Classification, description, and dynamics of plant communities after fire 

in the taiga of interior Alaska. USDA Pacific Northwest Forest and Range 

Experiment Station Research Paper PNW-307. Portland, OR. 108 pp. 

Ford, J., and Bedford, B.L. 1987. The hydrology of Alaskan wetlands, U.S.A.: a review. 

Arctic and Alpine Research 19: 209–229. 

Forman, R.T.T., and M. Godron. 1986. Landscape ecology. New York, NY: John Wiley 

and Sons. 

Fox, J.F. 1978. Forest fires and the snowshoe hare-Canada lynx cycle. Oecologia 31:349-374. 

Gallant, A.L., E.F. Binnian, J.M. Omernik, and M.B. Shasby. 1996. Ecoregions of Alaska. 

U.S. Geological Survey Professional Paper 1567. U.S. Government Printing 

Office, Washington, D.C. 

Gardner C.L. 2001b. Unit 20B, 20C, 20D, 20E, 25C, and adjacent Yukon, Canada. Herd: 

Fortymile. Pages 139-167 in C. Healy, editor. Caribou Management report of 

survey and inventory activities 1 July 1988- 30 June 2000. Alaska Department 

of Fish and Game. Federal Aid in Wildlife Restoration Grants W-27-2, W-27-3. 

Proj 3.0. Juneau, Alaska. 

Gasaway, W.C., R.D. Boertje, D.V. Grangaard, D.G. Kelleyhouse, R.O. Stephenson, and 

D.G. Larsen. 1992. The role of predation in limiting moose at low densities in 

Alaska and Yukon and implications for conservation. Wildlife Monograph 120. 

Gerken, J.D. 2006. Yukon River inseason salmon harvest interviews, 2005. U.S. Fish and 

Wildlife Service, Alaska Fisheries Data Series No. 2006-11. Fairbanks, AK. 

Gerken, J.D. and R.R. Holder. 2005. Yukon River inseason salmon harvest interviews, 

2003. U.S. Fish and Wildlife Service, Alaska Fisheries Data Series No. 2005-

14. Fairbanks, AK. 

Gillett, N.P., A.V. Weaver, F.W. Zwiers, and M.D. Flannigan. 2004. Detecting the effect 

of climate change on Canadian forest fires. Geophysical Research Letters 

31:18211, doi:10.1029/2004GL02876. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-123 
Chapter 3: Refuge Resources 

Goldsmith, Scott. 1986. Long-term economic and Demographic Projections for Alaska. 

ISER-MAP Economic Model Control Projection Report, June 1986. ISER 

Working Paper 86.4. University of Alaska, Institute of Social and Economic 

Research. Anchorage, AK. 1 vol. 

Griese, H. 1997. Alaska Department of Fish and Game. Conversation with Steve Kovach 

about moose movements related to the Millers Reach fire. 

Grower, S.T., J.G. Vogel, J.M. Norman, C.J. Kucharik, S.J. Steele, and T.K. Stow. 1997. 

Carbon distribution and aboveground net primary production in aspen, jack 

pine, and black spruce stands in Saskatchewan and Manitoba, Canada. Journal 

of Geophysical Research 102:29029-29042. 

Haber, G.C., and C.J. Walters. 1980. Dynamics of the Alaska-Yukon caribou herds and 

management implications. Pp. 645-663. In E. Reimers, E. Gaare, and S. 

Skjenneberg, eds. Proceedings of the Second International Reindeer Caribou 

Symposium, 1979. Trondheim, Norway. 

Healey, M.C. 1991. Life history of Chinook salmon. Pages 311-394 in C. Groot and L. 

Margolis, editors. Pacific Salmon Life Histories. UBC Press, Vancouver, 

B.C. Canada. 

Heglund, P.J., M. Maxwell, and P. Martin. 2002 (draft). Associations between wildland fire 

and the chemical characteristics of 16 lakes in the Kanuti River basin, Alaska. 

USFWS unpublished report, Anchorage, Alaska. 

Heinselman, M. L. 1981. Fire and succession in the conifer forests of northern North 

America. In: West, D. C.; Shugart, H. H.; Botkin, D. B., eds. Forest succession, 

concepts and application. New York: Springer Verlag: 374-405. 

Herron, First Lt. Joseph S., 8th Calvary. 1909. Explorations in Alaska, 1899. For an AllAmerican Overland Route from Cook Inlet, Pacific Ocean, to the Yukon. 

Government Printing Office, 1909. Pp 54. 

Hinkes, M.T., G.H. Collins, L.J. Van Daele, S.D. Kovach, A.R. Aderman, J.D. Woolington, 

and R.J. Seavoy. 2005. Influence of population growth on caribou herd identity, 

calving ground fidelity, and behavior. Journal of Wildlife Management. 

69(3):1147-1162. 

Hinzman, L.D., N.D. Bettez, W.R. Bolton, F.S. Chapin, M.B. Dyurgerov, C.L. Fastie, B. 

Griffith, R.D. Hollister, A. Hope, H.P. Huntington, A.M. Jensen, G.J. Jia, T. 

Jorgenson, D.L. Kane, D.R. Klein, G. Kofinas, A.H. Lynch, A.H. Lloyd, D. 

McGuire, F.E. Nelson, W.C. Oechel, T.E. Osterkamp, C.H. Racine, V.E. 

Romanovsky, R.S. Stone, D.A. Stow, M. Sturm, C.E. Tweedie, G.L. Vourlitis, 

M.D. Walker, D.A. Walker, P.J. Webber, J.M. Welker, K.S. Winker, and K. 

Yoshikawa. 2005. Evidence and Implications of Recent Climate Change in 

Northern Alaska and Other Arctic Regions. Climatic Change 72: 251-298. 

Hodges, K.E. 2000. The ecology of snowshoe hares in northern boreal forests. Pages 117-

161. In L.F. Ruggeiro, K.B. Aubry, S.W. Buskirk, G.M. Koehler, C.J. Krebs, 

K.S. McKelvey, and J.R. Squires, editors. Ecology and conservation of lynx in 

the United States. University Press of Colorado, Denver, Colorado, USA. 

Holmes. 2001. Tanana River Valley Archaeology Circa 14,000-9,000 BP. Arctic 

Anthropology 38(2): 154-170. 

3-124 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Holsten, E., P. Hennon, L. Trummer, and M. Schultz. 2001. Insects and diseases of 

Alaskan forests. Technical Publication R10-TP-87. USDA Forest Service, 

Juneau, Alaska. 

Hood, G.A., and S.E. Bayley. 2003. Fire and beaver in the boreal forest-grassland 

transition of western Canada – a case study fro Elk Island National Park, 

Canada. Lutra. 46(2):235-241. 

Hosley, Edward H. 1981 “Environment and Culture on the Alaska Plateau,” in Helm 1981. 

pp 533-545 

Huff, M.H., and J.K. Smith. 2000. Fire effects on animal communities. Pages 35-42 in J.K 

Smith, editor. Wildland fire in ecosystems: effects of fire on fauna. General 

Technical Report RMRS-GTR-42-vol. 1. U.S. Department of Agriculture, 

Forest Service, Rocky Mountain Research Station. Ogden, Utah. 

Intergovernmental Panel on Climate Change (IPCC) 2007. Climate Change 2007: Climate 

Change Impacts, Adaptation and Vulnerability. Contribution of Working 

Group II to the Fourth Assessment Report of the Intergovernmental Panel on 

Climate Change. 23pp. 

Jackson, R. 1990. Unpublished report of findings: Innoko National Wildlife Refuge placer 

mining study. Ecological Services, U.S. Fish and Wildlife Service, Anchorage, 

AK. n.p.

Johnson, E.A., and J.S. Rowe. 1975. Fire in the subarctic wintering ground of the Beverly 

Caribou Herd. American Midland naturalist. 94:1-14. 

Johnson, W.N., T.F. Paragi, and D.D. Katnik. 1995. The relationship of wildland fire to 

lynx and marten population and habitat in interior Alaska. Final Report. U.S. 

Fish and Wildlife Service. Galena, Alaska. 

Joint-Federal State Land Use Planning Commission. 1973. Major ecosystems of Alaska 

map. U.S. Geological Survey. Scale 1:2,500,000. 

Joly, K., B.W. Dale, W.B. Collins, and L.G. Adams. 2003. Winter habitat use by female 

caribou in relation to wildland fires in interior Alaska. Canadian Journal of 

Zoology. 81:1192-1201. 

Joly, K., L.G. Adams, B.W. Dale, and W.B. Collins. 2002. Evaluating the impacts of 

wildland fires on caribou in interior Alaska. Pages 63-67 in Myers, C.E., and 

J.R. Hough, editors. Arctic research of the United States. Volume 16. 

Interagency Arctic Research Policy Committee, national Science Foundation. 

Arlington, Virginia. 

Jorgenson, M.T., Racine, C.H., Walters, J.C., and Osterkamp, T.E. 2001. Permafrost 

degradation and ecological changes associated with a warming climate in 

Central Alaska. Climatic Change 48: 551–579. 

Keith, L.B. 1963. Wildlife’s ten year cycle. University Wisconsin Press, Madison, 

Wisconsin, USA. 

Keith, L.B. 1990. Dynamics of snowshoe hare populations. Pages 119-195 in H. H. 

Genoways, editor. Current Mammalogy. Plenum Press, New York, New 

York, USA. 

Keith, L.B., A.W. Todd, C.J. Brand, R.S. Adamcik, and D.H. Rusch. 1977. An analysis of 

predation during a cyclic fluctuation of snowshoe hares. International 

Congress of Game Biology 13:151-175. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-125 
Chapter 3: Refuge Resources 

Kellyhouse, D.G. 1979. Fire/wildlife relationships in Alaska. Pages 1-37 in M. Hoefs and D. 

Russell. editors. Wildlife and wildfire: Proceedings of workshop; 1979 

November 27-28; Whitehorse, YT. Yukon Wildlife Branch. Whitehorse, Yukon 

Territory, Canada. 

Kelsall, J.P., and E.S. Telfer. 1974. Biogeography of moose with particular reference to 

western north America. Naturaliste Canada. 101:117-130. 

Kelsall, J.P., E.S. Telfer, and T.D. Wright. 1977. The effects of fire on the ecology of the 

Boreal Forest, with particular reference to the Canadian north: a review and 

selected bibliography. Canadian Wildlife Service Occasional Paper No. 32. 

Klein, D.R., 1982. Fire, lichens, and caribou. Journal of Range management. 35(3):390-395. 

Klein, E., Berg, E.E., and Dial, R. 2005. Wetland drying and succession across the Kenai 

Peninsula Lowlands, south-central Alaska. Can. J. For. Res. 35: 1931–1941. 

Krauss, Michael and Mary Jane Golla. 1981. Northern Athabascan Languages. In: 

Handbook of North American Indians. June Helm ed. Vol. 6 Subarctic. 

Washington D.C. Smithsonian Institution, pps. 67-85. 

Krebs, C.J. 2001. General introduction. Pages 4-8 in C.J. Krebs, S. Boutin, and R. 

Boonstra, editors. Ecosystem dynamics of the boreal forest. The Kluane 

region. Oxford University Press. 

Krebs, C.J., B.S. Gilbert, S. Boutin, A.R.E. Sinclair, and J.N.M. Smith. 1986. Population 

biology of snowshoe hares: Demography of food-supplemented populations in 

the southern Yukon, 1976-1984. Journal of Animal Ecology 55:963-982. 

Krefting, L.W. 1974. Moose distribution and habitat selection in northcentral North 

America. Naturaliste Canada. 101:81-100. 

Kruse, J.J. and S. Patterson. 2007. Re-evaluation of Larch Sawfly Damage and Larch 

Regeneration: Innoko National Wildlife Refuge; August 2007. Biological 

Evaluation R10-TP-xx. USDA Forest Service. Anchorage, AK. DRAFT 

REPORT. 

Landres, Peter; Boutcher, Steve; Merigliano, Linda; Barns, Chris; Davis, Denis; Hall, 

Troy; Henry, Steve; Hunter, Brad; Janiga, Patrice; Laker, Mark; McPherson, 

Al; Powell, Douglas S.; Rowan, Mike; Sater, Susan. 2005. Monitoring selected 

conditions related to wilderness character: A national framework. General 

Technical Report-RMRS-GTR-151. USDA Forest Service, Rocky Mountain 

Research Station. Fort Collins, CO. 38 pp. 

Lipkin, R. 2007. Alaska natural heritage program rare vascular plant tracking list April 

2007. Alaska Natural Heritage Program. Anchorage, Alaska. Accessed 17 July 

2007 on the World Wide Web at: 

http://aknhp.uaa.alaska.edu/pdfs/botany/RPWG07_alpha.pdf . 

Lipovsky, P.S., J. Coates, A.G. Lewkowicz, and E. Trochim. 2006. Active-layer 

detachments following the summer 2004 forest fires near Dawson City, Yukon. 

In: Yukon Exploration and Geology 2005, D.S. Emond, G.D. Bradshaw, L.L. 

Lewis and L.H. Weston, editors. Yukon Geological Survey, p. 175-194. 

Lutz, H.J. 1960. History of the early occurrence of moose on the Kenai Peninsula and in 

other sections of Alaska. Miscellaneous Publication No. 1. Alaska Forest 

Research Center, USDA Forest Service. Juneau, Alaska. 

3-126 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Lyon, L.J., J.H. Huff, and J.K. Smith. 2000. Fire effects on fauna at landscape scales. 

Pages 43-49 in J.K Smith, editor. Wildland fire in ecosystems: effects of fire on 

fauna. General Technical Report RMRS-GTR-42-vol. 1. U.S. Department of 

Agriculture, Forest Service, Rocky Mountain Research Station. Ogden, Utah. 

MacDonald, S.O. 2003. The amphibians and reptiles of Alaska: a field handbook. Alaska 

Natural Heritage Program. http://aknhp.uaa.alaska.edu/herps 

Maddren, A. G. 1910. The Innoko Gold-Placer District Alaska with accounts of the Central 

Kuskokwim Valley and the Ruby Creek and Gold Hill Placers. Pp 235-238. 

Maier, J.A., J.M. Ver Hoef, A.D. McGuire, R.T. Bowyer, L. Saperstein, and H. Maier 2005. 

Distribution and density of moose in relation to landscape characteristics: 

Effects of scale. Canadian Journal of Forest Research. 35:2233-2243. 

Mallek, E.J. 1999. Plant architecture and forage selection by moose. MS Thesis. 

University of Alaska – Fairbanks. Fairbanks, Alaska. 

McDonald, K.C., J.S. Kimball, E. Njoku, R. Zimmermann, and M. Zhao. 2004. Variability 

in springtime thaw in terrestrial high latitudes: Monitoring a major control on 

the biospheric assimilation of atmospheric CO2 with spaceborne microwave 

remote sensing. Earth Interactions Volume 8:Paper No. 20, 23pp. 

McInnavile, W.B., Jr., and L.B. Keith. 1974. Ecology of red-tailed hawk and great-horned 

owl, Alberta. Canadian Field Naturalist 88:1-20. 

McIntyre, C.L. 1995. Nesting ecology of migratory golden eagles (Aquila chrysaetos) in 

Denali National Park, Alaska. Thesis. University of Alaska, Fairbanks, 

Alaska, USA. 

Miller, D. 2000. Lichens, wildfire, and caribou on the taiga ecosystem of northcentral 

Canada. Rangifer. Special Issue No. 12:197-207. 

Miller, D. J., Payne, T. G., and Gryc, George. 1959. Geology of possible petroleum 

provinces in Alaska: U.S. Geological Survey Bulletin 1094. 

Minshall, G.W., J.T. Brock, and J.D. Varley. 1989. Wildfires and Yellowstone’s stream 

ecosystems. BioScience 39(10):707-715. 

Minshall, G.W., T.V. Royer, and C.T. Robinson. 2001. Response of the Cache Creek 

macroinvertebrates during the first 10 years following disturbance by the 1988 

Yellowstone wildfires. Canadian Journal of Fisheries and Aquatic Science 

58:1077-1088. 

Mueller, K.A. and A.C. Matz. 2002. Water quality, and metal and metalloid concentrations in 

water, sediment, and fish tissues from Innoko National Wildlife Refuge, Alaska, 

1995-1997. U.S. Fish and Wildlife Service, Northern Alaska Ecological Services, 

Technical Report NAESTR-02-01. 155 pp.

Mueller, K.A., and A.C. Matz, and R. Skinner. 2000. Water quality, and metal and 

metalloid concentrations in water, sediment, and fish tissues from Innoko 

National Wildlife Refuge, Alaska, 1996-97, including sites from the upper Little 

Mud River. U.S. Fish and Wildlife Service Technical Report NAES-TR-00-03. 

Fairbanks, AK. 

Nelson, E.W., and F.W. True. 1887. Part II. Mammals of northern Alaska. Pages 227-293. 

In E.W. Nelson. Report upon natural history collections made in Alaska 

between the years 1877 and 1881. Arctic Series of Publications issued in 

connection with the Signal Service, U.S. Army. No. III. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-127 
Chapter 3: Refuge Resources 

Nowacki, G. and T. Brock. 1995. Ecoregions and Subregions of Alaska, EcoMap Version 

2.0 (map). USDA Forest Service, Alaska Region, Juneau, AK. 

Nowacki, G., P. Spencer, T. Brock, M. Fleming, and T. Jorgenson. 2001. Narrative 

descriptions for the ecoregions of Alaska and neighboring territories. U.S. 

Geological Survey, available at http://alaska.usgs.gov/ecoregions_expl.html. 

Odess, Daniel. University of Alaska Museum of the North, Curator of Archaeology. 

Personal communication with Debra Corbett, August 2005. 

Olsen, J.B., W.J. Spearman, G.K. Sage, S.J. Miller, B.G. Flannery, and J.K. Wenburg. 

2004. Variation in the population structure of Yukon River chum and coho 

salmon: evaluating the potential impact of localized habitat degradation. 

Transactions of the American Fisheries Society 133:476-483. 

Oliver, C.D., A. Osawa, and A. Camp. 1998. Forest dynamics and resulting animal and 

plant population changes at the stand and landscape levels. Journal of 

Sustainable Forestry. 6(3/4): 281-312. 

Omernik, J.M. 1987. Ecoregions of the conterminous United States. Annals of the 

Association of American Geographers 77(1):118-125. 

Orth, Donald J. 1971. Dictionary of Alaska Place Names. Geological Survey 

Professional Paper 567. United States Government Printing Office. 

Washington DC. 1,084 pp. 

Osterkamp, T.E., and Romanovsky, V.E. 1999. Evidence for warming and thawing of 

discontinuous permafrost in Alaska. Permafrost and Periglacial Processes 

10: 17–37. 

Overpeck, J., K. Hughen, D. Hardy, R. Bradley, R. Case, M. Douglas, B. Finney, K. 

Gajewski, G. Jacoby, A. Jennings, S. Lamoureux, A. Lasca, G. MacDonald, J. 

Moore, M. Retelle, S. Smith, A. Wolfe, and G. Zielinski. 1997. Arctic 

environmental change of the last four centuries. Science 278: 1251 – 1256. 

Palmer, L.J. 1942. Caribou versus fire in interior Alaska (a study of burned-over lichen 

ranges). Progress report. Juneau, Alaska. 

Paragi, T. 2007. Alaska Department of Fish and Game. Email communication with Steve 

Kovach and Bill Schaff about 2005 browse survey. March 2007. 

Paragi, T.F. 1999. Draft. Regional inferences on snowshoe hare demographics in interior 

Alaska. Unpublished proposal, Fairbanks, Alaska. 

Parmesan, C., and Yohe, G. 2003. A globally coherent fingerprint of climate change 

impacts across natural systems. Nature 421: 37–42. 

Parson, E.A., L. Carter, P. Anderson, B. Wang, and G. Weller. 2001. Potential 

consequences of climate variability and change for Alaska. Pages 283-312 in 

National Assessment Synthesis Team Climate Change Impacts on the United 

States: The Potential Consequences of Climate Variability and Change, report 

for the US Global Change Research Program, Cambridge University Press, 

Cambridge UK, 620pp. 

Patton, W.W. Jr. 1973. Reconnaissance Geology of the Northern Yukon-Koyukuk 

Province, Alaska. U.S. Geological Survey Professional Paper 774-A. l7 pp. 

Payette, S. 1992. Fire as a controlling process in the North American boreal forest. Pages 

144-169 in H.H. Shugart, R. Leemans, and G. Bonan, editors. A system 

analysis of the global boreal forest. Cambridge University Press. Cambridge, 

United Kingdom. 

3-128 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Peek, J.M. 1997. Habitat relationships. Pages 351-375 in A.W. Franzmann and C.C. 

Schwartz, editors. Ecology and management of North American moose. 

Wildlife Management Institute. Washington, D.C. 

Pegau, R.E. 1975. Analysis of the Nelchina Caribou range. Pages 316-323, in J.R. Luick, 

P.C. Lent, D.R. Klein, and R.G. White, editors. Proceedings of the 1st

international reindeer and caribou symposium, Fairbanks, Alaska 1972. 

Alaska Biological Papers Special Report Number 1. University of Alaska. 

Fairbanks, Alaska. 

Pegau, R.E. 1986. Unit 19 and 21 caribou management progress report of surveyinventory activities. Pages 23-26 in B. Townsend, editor. Annual report of 

survey-inventory activities. Part XI. Caribou. Volume XVII. Alaska 

Department of Fish and Game. Federal Aid in Wildlife Restoration Project 

Report. Project W-22-4. Job 3.0. Juneau, Alaska. 

Perham, C. J. 1995. Home range, habitat selection, and movements of lynx (Lynx 

 Canadensis) in eastern interior Alaska. Thesis. University of Alaska 

Fairbanks, Fairbanks, Alaska, USA. 

Peterson, R.O. 1977. Wolf Ecology and Prey Relationships on Isle Royale. National Park 

Service Scientific Monograph Series, No. 11. U.S. National Park Service, 

Washington, D.C. 210 pp. 

Peterson, S. 1980. “The Iditarod Trail: Route of the Miners—Seward to Nome,” in Robert 

D. Shaw, ed., Mining in Alaska’s Past, Alaska Division of Parks Office of 

History and Archaeology Publication No. 27:178-79. The Alaska Historical 

Society. Anchorage, AK. 

Prachar, R., R.W. Sage, Jr., and M.S. Deisch. 1988. Site occupancy, density, and spatial 

distribution of beaver colonies in burned and unburned areas in the 

Adirondacks. Transactions, Northeast Section of the Wildlife Society. 45: 74. 

Raymond, C.W. 1871. Report of a reconnaissance of the Yukon River, Alaska Territory. 

July to September 1896. 42nd Congress, 1st Session. Senate Executive 

Document No. 12. 

Raymond, C.W. 1873. The Yukon River region, Alaska. Journal of the American 

Geographical Society of New York. 3:158-192. 

Ream, C.H., compiler. 1981. The effects of fire and other disturbances on small mammals 

and their predators: an annotated bibliography. General Technical Report 

INT-106. U.S. Department of Agriculture, Forest Service, Intermountain 

Forest and Range Experiment Station. Ogden, UT. 

Reeves, M.K., C.L. Dolph, H. Zimmer, R.S. Tjeerdema, and K.A. Trust, 2008. Pond 

proximity increases risk of skeletal abnormalities in wood frogs from 

National Wildlife Refuges in Alaska. Environmental Health Perspectives 

116(3): 1009-1014. 

Reiger, S., D. Schoephorster, and C.E. Furbush. 1979. Exploratory soil survey of Alaska. 

U.S. Department of Agriculture, Soil Conservation Service. 1 vol. 

Rexstad, E. 2003. Small mammal community dynamics investigation for Mouse Lake, 

Kanuti National Wildlife Refuge 1993-2002. Kanuti NWR progress report 

FY03-03, Fairbanks, Alaska. 29 pp. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-129 
Chapter 3: Refuge Resources 

Ricketts, T., E. Dinerstein, D.M. Olson, C. Loucks. 1999. Who’s where in North America: 

Patterns of species richness and the utility of indicator species taxa for 

conservation. Bioscience 49(5). 

Rieman, B., and J. Clayton. 1997. Wildfire and native fish: issues of forest health and 

conservation of sensitive species. Fisheries 22(11):6-15. 

Riordan, B., D. Verbyla, and A.D. McGuire 2006. Shrinking ponds in subarctic Alaska 

based on 1950 – 2002 remotely sensed images. Journal of Geophysical 

Research, 111, G04002, doi:10.1029/2005JG000150. 

Roberts, W.S. 1984. Economic Potential for Chromium, Platinum, and Palladium in the 

Mount Hurst Ultramafics. West-Central area, Alaska. U.S. Dept. of the 

Interior, Bureau of Mines Open File Report 84-22. 1 vol. 

Rost, P. 1988. Innoko National Wildlife Refuge salmon spawning investigation, 1987. 

Unpublished data. U.S. Fish and Wildlife Service, Fishery Assistance Office, 

Fairbanks, AK. 

Rouse, W.R., Douglas, M.S.V., Hecky, R.E., Hershey, A.E., Kling, G.W., Lesack, L., 

Marsh, P., McDonald, M., Nicholson, B.J., Roulet, N.T., and Smol, J.P. 1997. 

Effects of climate change on the freshwaters of arctic and subarctic North 

America. Hydrol. Processes 11: 873–902. 

Rowe, J.S., J.L. Bergsteinsson, G.A. Padbury, and R. Hermish. 1974. Fire studies in the 

MacKenzie Valley. Department of Indian Affairs and North ALUR 73-74-61. 

Ottawa, Canada. 

Royer, F.R. Dickinson. 1999. Weeds of the northern U.S. and Canada. The University of 

Alberta Press. Calgary, Alberta, Canada. 

Rupp, T.S., M. Olson, L.G. Adams, B.W. Dale, K. Joly, J. Henkelman, W.B. Collins, and 

A.M. Starfield. 2006. Simulating the influences of various fire regimes on 

caribou winter habitat. Ecological Applications. 16(5):1730-1743. 

Rutledge, C.R., and T. McLendon. 1996. An assessment of exotic plant species of Rocky 

Mountain National Park. Department of Rangeland Ecosystem Science. 

Colorado State University. Fort Collins, Colorado. 

Sagar, G.R., and J.L. Harper. 1964. Plantago major L., P. media L. and P. lanceolata L. 

Journal of Ecology 52:189-122. 

Salo, E.O. 1991. Life history of chum salmon. Pages 231-310 in C. Groot and L. Margolis, 

editors. Pacific Salmon Life Histories. UBC Press, Vancouver, B.C. Canada. 

Sandercock, F.K. 1991. Life history of coho salmon. Pages 395-446 in C. Groot and L. 

Margolis, editors. Pacific Salmon Life Histories. UBC Press, Vancouver, 

B.C. Canada. 

Sapperstein, L. 2007. U.S. Fish and Wildlife Service. Conversation with Steve Kovach 

about fire effects on vole populations. May 2007. 

Scanlon, B. In press. Movements and fidelity of northern pike in the lower Innoko River 

drainage, 2002–2004. Alaska Department Fish and Game, Division of Sport 

Fish, Fishery Data Series No. 06-XX. Anchorage, AK. 

Schmoldt, D.L., D.L. Peterson, R.E. Keane, J.M. Lenihan, D. McKenzie, D.R. Weise, D.V. 

Sandberg. 1999. Assessing the effects of fire disturbance on ecosystems: a 

scientific agenda for research and management. General Technical Report 

PNW-GTR-455. U.S. Department of Agriculture, Forest Service, Pacific 

Northwest Research Station. Portland, Oregon. 

3-130 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Schott, W. 1849. Ueber ehtnographische Ergebnisse der Sagoskinschen Reise. Archiv für 

wissenschaftliche Kunde von Russland 7:480-512. 

Scotter, G.W. 1967. Effects of fire on barren-ground caribou and their forest habitat in 

northern Canada. Transactions of the North American Wildlife Conference. 

32:243-254. 

Scotter, G.W. 1971. Fire, vegetation, soil, and barren-ground caribou relations in northern 

Canada. Pages 209-226, in C.W. Slaughter, R.J. Barney, and G.M. Hansen, 

editors. Fire in the northern environment. U.S. Department of Agriculture, 

Forest Service Pacific Northwest Forest and Range Experiment Station. 

Portland, Oregon. 

Seavoy, R. 2006. Alaska Department of Fish and Game. Conversation with Steve Kovach 

about wildlife diseases and parasites. December, 2006. 

Seavoy, R. 2007. Alaska Department of Fish and Game. Conversation with Steve Kovach 

about aerial survey counts of the Beaver Mountain Caribou Herd. August 2007. 

Seavoy, R. 2007. Alaska Department of Fish and Game. Conversation with Steve Kovach 

about trapping in the Refuge area. April 2007. 

Selkregg, L.L. 1976. Alaska regional profiles: Yukon region. University of Alaska, 

Fairbanks. Arctic Environmental Information and Data Center, Anchorage, AK. 

Shepherd, P.E.K. 1981. Caribou survey-inventory progress report, Game management 

Units 19 and 21. Pages 32-34. In RA Hinman, editor. Annual report of surveyinventory activities. Part III. Bison, caribou, mountain goats, muskoxen and 

sheep. Alaska Department of Fish and Game. Federal Aid in Wildlife 

Restoration. Project W-17-12, Jobs Number 9.0, 3.0, 12.0, 6.0, 16.0, and 22.0. 

Juneau, Alaska. 

Skinner, R., W. Erickson, L.L. McDonald, and G. Minick. 1997. Estimating moose 

populations and trends using line transect sampling. Unpublished report. US 

Fish and Wildlife Service, McGrath, Alaska. 

Skoog, R.O. 1963. Caribou report. Alaska Department of Fish and Game. Annual Project 

Segment Report. Federal Aid in Wildlife Restoration. Project W-6-R-4, Work 

Plan C. 

Skoog, R.O. 1968. Ecology of the caribou (Rangifer tarandus granti) in Alaska. Ph.D. 

Dissertation. University of California. Berkeley, California. 

Skuncke, F. 1969. Reindeer ecology and management in Sweden. Biological Papers of the 

University of Alaska, Number 18. 

Slough, B.G., and R.M.F.S. Sadleir. 1977. A land capability classification system for beaver 

(Castor Canadensis Kuhl). Canadian Journal of Zoology. 55:1324-1335. 

Smith, L.C., Y. Sheng, G.M. MacDonald, and L.D. Hinzman. 2005. Disappearing Arctic 

lakes. Science 308: 1429. 

Smucker, K.M., R.L. Hutto, and B.M. Steele. 2005. Changes in bird abundance after 

wildfire: importance of fire severity and time since fire. Ecological Applications 

15(5):1535-1549 

Snodgrass, J.W. and G.K. Meffe 1999. Habitat use and temporal dynamics of blackwater 

stream fishes in and adjacent to beaver ponds. Copeia 3:628-639. 

Snow, Jean. 1981. Ingalik. In: Handbook of North American Indians. June Helm ed. 

Vol.6 Subarctic. Washington D.C. Smithsonian Institution, pps. 602-614. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-131 
Chapter 3: Refuge Resources 

Sobey, D.G. 1981. Biological flora of the British Isles. Stellaria media (L.) Vill. Journal of 

Ecology 69: 311-335. 

Soja, A.J., N.M. Tchebakova, N.H.F. French, M.D. Flannigan, H.H. Shugart, B.J. Stocks, 

A.I. Sukhinin, E.I. Parfenova, F.S. Chapin III, and P.W. Stackhouse, Jr. 2007. 

Climate-induced boreal forest change: Predictions versus current observations. 

Global and Planetary Change. 56: 274-96. 

Spencer, C.N., and F.R. Hauer. 1991. Phosphorus and nitrogen dynamics in streams 

during a wildfire. Journal of the North American Benthological Society 

10(1):24-30. 

Spindler, M.A. 1999. Trends in abundance and productivity of white-fronted geese in the 

taiga of northwest and interior Alaska. Report submitted to the Central 

Flyway Technical Committee, March 5, 1999, Lawton, Oklahoma. 

Stevens, C.E., C.A. Paszkowski, and G.J. Scrimgeour. 2006. Older is better: beaver ponds 

on boreal streams as breeding habitat for the wood frog. Journal of Wildlife 

Management. 70(5):1360-1371. 

Stocks, B.J., M.A. Fosberg, B.M. Wotton, T.J. Lynham, and K.C. Ryan. 2000. Climate 

change and forest fire activity in North American boreal forests. Pages 368-

376 in E.S. Kasischke and B.J. Stocks, editors. Fire, Climate Change, and 

Carbon Cycling in the Boreal Forest. Ecological Studies Series, SpringerVerlag, New York, 461pp. 

Stout, G.W. 2001. Unit 21 furbearer management report. Pages 290-300 in C. Healy, 

editor. Furbearer management report of survey and inventory activities 1 July 

1997-30 June 2000. Alaska Department of Fish and Game. Project 7.0. Juneau, 

Alaska. 

Stout, G.W. 2004. Unit 21 furbearer management report. Pages 293-303 in C. Brown, 

editor. Furbearer management report of survey and inventory activities 1 July 

2000-30 June 2003. Alaska Department of Fish and Game. Project 7.0. Juneau, 

Alaska. 

Swenson, J.E., S.J. Knapp, P.R. Martin, and T.C. Hinz. 1983. Reliability of aerial cache 

surveys to monitor beaver population trends on prairie rivers in Montana. 

Journal of Wildlife Management. 47(3):697-703. 

Szepanski, M.M. 2003. Unit 19 and 21 wolf management report. Pages 136-153 in C. Healy, 

editor. Wolf management report of survey and inventory activities 1 July 1999 

– 30 June 2002. Alaska Department of Fish and Game. Juneau, Alaska. 

Talbot, S. 2006. Conversation with Steve Kovach about sensitive plant species and Innoko 

Refuge. December 2006. 

Talbot, S. 2007. Conversation with Steve Kovach about likelihood of sensitive plant 

species occurring on Innoko Refuge. March 2007. 

Talbot, S.S., and C.J. Markon 1988. Intermediate-scale vegetation mapping of Innoko 

National Wildlife Refuge, Alaska using Landsat MSS digital data. 

Photogrammetric Engineering and Remote Sensing, 54(3):377-383. 

Tetlin National Wildlife Refuge. 1987. Annual Narrative Report, Calendar Year 1987. 

Narrative. U.S. Fish and Wildlife Service, Tetlin National Wildlife Refuge, 

Tok, Alaska, USA. 

Todd, A.W., L.B. Keith, and C.A. Fischer. 1981. Population ecology of coyotes during a 

fluctuation of snowshoe hares. Journal of Wildlife Management 45:629- 640. 

3-132 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Turkington, R., N.C. Kenkel and G.D. Franko. 1980. The biology of Canadian weeds. 42. 

Stellaria media (L.) Vill. Canadian Journal of Plant Science 60: 981-992. 

Trust, K.A. and H. Tangermann. 2002. National malformed amphibian study, FY2000: 

Kenai National Wildlife Refuge. Annual Progress Report. U.S. Fish and 

Wildlife Service Technical Report. WAES-TR-02-01. 

U.S. Bureau of Land Management. 1986. Iditarod National Historic Trail: Seward to 

Nome Route. A Comprehensive Management Plan. Prepared by Bureau of 

Land Management, Anchorage District Office, Anchorage, Alaska. 

USDA and USDOI. 2005. Wildland Fire Use Implementation Procedures Reference 

Guide. May 2005. Minor Revisions March and April 2006. Minor Correction 

May 2007. 

USDA Forest Service. 2002. akdamage89_2002. Geospatial vector data. Anchorage, 

Alaska. http://agdc.usgs.gov/data/projects/fhm/#K 

USDA Forest Service. 2005. akfordmg96_2005. Geospatial vector data. Anchorage, Alaska. 

http://agdc.usgs.gov/data/projects/fhm/#K 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final 

Comprehensive Conservation Plan, Environmental Impact Statement, and 

Wilderness Review. Anchorage, Alaska: U.S. Fish and Wildlife Service. 

U.S. Fish and Wildlife Service. 1993. Fishery Management Plan – Innoko National 

Wildlife Refuge. Innoko National Wildlife Refuge, McGrath, AK and Fishery 

Assistance Office, Fairbanks, AK. 

U.S. Fish and Wildlife Service. 1996. Service manual, planning and management series, 

part 052. http://www.fws.gov/policy/052fw1.html 

U.S. Fish and Wildlife Service. 2002. Birds of conservation concern 2002. Division of 

Migratory Bird Management, Arlington, Virginia. 

U.S. Fish and Wildlife Service. 2005. Fire Management Plan – Innoko National Wildlife 

Refuge. Innoko National Wildlife Refuge, McGrath, AK 

U.S. Government. 1968. "The Wild and Scenic Rivers Act." Accessed August 17, 2007. At 

http://www.rivers.gov/publications/act/current-act.pdf on the World Wide Web, 

produced by The Interagency Wild and Scenic Rivers Coordinating Council. 16 

USC, Sections 1271-1287. 

Van Cleve, K., C.T. Dyrness, L.A. Viereck, J. Fox, F.S. Chapin, III, and W. Oechel. 1983. 

Taiga ecosystems in interior Alaska. BioScience 33:39-44. 

Van Cleve, K., F.S. Chapin, III, C.T. Byrness, and L.A. Viereck. 1991. Element cycling in 

taiga forest: state-factor control. BioScience. 41:78-88. 

VanStone, J.W. 1959. Russian exploration in interior Alaska. Pacific Northwest Quarterly. 

50(2):34-47. 

VanStone, James and Ives Goddard. 1981. Territorial Groups of West Central Alaska 

Before 1898. In: Handbook of North American Indians. June Helm ed. Vol.6 

Subarctic. Washington D.C. Smithsonian Institution, pps. 556-561. 

Van Wagner, C. E. 1983. Fire behaviour in northern conifer forest and shrublands. Pages 

65-80 In R. W. Wein and D. A. MacLean, editors. The role of fire in northern 

circumpolar ecosystems. Scope 18. New York: John Wiley and Sons: 65-80. 

Viereck, L.A. 1973. Wildfire in the taiga of Alaska. Quaternary Research. 3:465-495. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-133 
Chapter 3: Refuge Resources 

Viereck, L.A. 1983. The effects of fire on black spruce ecosystems of Alaska and Northern 

Canada. In: Wein, R.W. and D.A. MacLean, eds. The role of fire in northern 

circumpolar ecosystems. Scope 18. New York: John Wiley and Sons: 201-220. 

International Journal of Wildland Fire. 3(3):169-178. 

Viereck, L. A.; Schandelmeier, L. A. 1980. Effects of fire in Alaska and adjacent Canada: a 

literature review. BLM Tech. Rep. No. 6. Alaska: U.S. Department of the 

Interior, Bureau of Land Management. 124 p. 

Waide, R.B., M.R. Willig, G. Mittelbach, C. Steiner, L. Gough, S.I. Dodson, G.P. Juday, 

and R. Parmenter. 1999. The relationship between productivity and species 

richness. Annual Review of Ecology and Systematics 30:257-300. 

Walther, Gian-Reto, Eric Post, Peter Convey, Annette Menzel, Camille Parmesan, Trevor 

J. Ove Hoegh-Guldbert and Franz Bairlien. 2002. Ecological responses to 

recent climate change. Nature 416:389-395. 

Werner, R.A., K.F. Raffa, and B.L. Illman. 2006. Dynamics of phytophagous insects and 

their pathogens in Alaskan boreal forests. Pages 133-146 in Chapin, III, F.S., 

M.W. Oswood, K. Van Cleve, L.A. Viereck, and D.L. Verbyla, editors. Alaska’s 

Changing Boreal Forest. Oxford University Press, New York 354pp. 

Whitman, J.S. 1995. Units 19A, B, C, and D and 21A and E. Pages 102-110. In MV Hicks, 

editor. Management report of survey-inventory activities 1 July 1992-30 June 

1994. Caribou. Alaska Department of Fish and Game. Federal Aid in Wildlife 

Restoration. Grants W-24-2 and W-24-3. Study 3.0. Juneau, Alaska. 

Whitman, J.S. 1997. Units 19A, B, C, and D and 21A and E. Pages 108-118. In MV Hicks, 

editor. Management report of survey-inventory activities 1 July 1994-30 June 

1996. Caribou. Alaska Department of Fish and Game. Federal Aid in Wildlife 

Restoration. Grants W-24-3 and W-24-4. Study 3.0. Juneau, Alaska. 

Whittaker, R.H. 1975. Communities and ecosystems. Macmillan, New York. 

Wilk, R. J. 1993. Observations on Sympatric Tundra Swans (Cygnus columbianus 

columbianus) and Trumpeter Swans (C. buccinator) in North-central Alaska, 

1989-1991. Canadian Field-Naturalist 107:64-68. 

Winder, M., and D.E. Schindler. 2004. Climate change uncouples trophic interactions in 

an aquatic ecosystem. Ecology 85: 2100–2106. 

Windisch-Cole, B. 2001. The Yukon-Koyukuk Census Area: A profile of rural Interior 

Alaska. Alaska Economic Trends, 21(2). 

Winton, M. 2006. Amplified arctic climate change: What does surface albedo feedback 

have to do with it? Geophysical Research Letters, 33, L03701, 

doi:10.1029/2005GL025244. 

Wolfe, Robert, 1987. The Super-Household: Specialization in Subsistence Economies. 

Paper presented at the 14th Annual Meeting of the Alaska Anthropological 

Association, March 12 and 13, 1987, Anchorage Alaska. 

Wolff, J. O. 1980. The role of habitat patchiness in the population dynamics of snowshoe 

hares. Ecological Monograph 50:111-130. 

Yoshikawa, K., W.R. Bolton, V.E. Romanovsky, M. Fukuda, and L.D Hinzman. 2003. 

Impacts of wildfire on the permafrost in the boreal forests of interior Alaska. 

Journal of Geophysical Research 107, 8148, doi:10.1029/2001JD000438. 

Zackrisson, O. 1977. Influence of forest fires on the North Swedish boreal forest. Oikos. 

29:22-23. 

3-134 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 3: Refuge Resources 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 3-135 

Zagoskin, Lavrentii Alekseevich. 1967. Lieutenant Zagoskin’s Travels in Russian America, 

1842-1844: The First Ethnographic and Geographic Investigations on the Yukon 

and Kuskokwim Valleys of Alaska. Henry N. Michael, ed. (Anthropology of the 

North: Translations from Russian Sources 7) Toronto: Published for the Arctic 

Institute of North America by University of Toronto Press. 

Zarnke, R.L., J.M. Ver Hoef, and R.A. DeLong. 2006. Geographic pattern of serum 

antibody prevalence for Brucella Spp. in caribou, grizzly bears, and wolves 

from Alaska, 1975-1998. Journal of Wildlife Diseases 42:570-577. 
Chapter 4: Implementation and Monitoring 

4. Implementation and Monitoring 

Implementation of the Innoko National Wildlife Refuge Comprehensive Conservation Plan (Plan) 

will be accomplished, in part, through various step-down plans (section 4.1). Each step-down plan 

has its own program focus, identifying and directing the implementation of strategies designed to 

achieve objectives outlined in the Plan (chapter 2, section 2.1). Implementation also includes 

identifying partnership opportunities that assist in accomplishing refuge objectives (see section 4.2). 

Monitoring the progress of plan implementation is accomplished by a variety of methods (section 

4.3). Evaluation of monitoring results may lead to amendment or revision of the Plan (section 4.4). 

Section 4.5 outlines additional funding and staffing needed to fully implement the Plan. 

4.1 Step-Down Plans 

Step-down management plans are plans that deal with specific management topics. They describe 

specific, topic-related management strategies and implementation schedules and provide details 

necessary to implement goals and objectives in this revised Plan. Step-down plans identified for 

the refuge include the following: 

 Inventory and Monitoring Plan, to be developed two years following completion of the 

biological program review 

 Fisheries Management Plan, 1993, to be updated within two years of completion of the 

Inventory and Monitoring Plan 

 Cultural Resource Guide, 1996, to be updated by 2010 

 Fire Management Plan, 2005, to be updated every five years 

 Land Protection Plan, 2007, updated only if necessary. 

 Station Safety Plan, 2007, reviewed annually 

 Occupant Emergency Plan, 2007, reviewed annually 

 Water Resources Inventory and Assessment: Plan of Study, 1996 

 Spill Prevention,Control, and Countermeasure Plan, 2000, updated periodically 

 Visitor Services Plan, to be prepared when necessary 

 Wilderness Stewardship Plan, to be prepared within two years of approval of refuge 

wilderness policy 

4.1.1 Inventory and Monitoring (I&M Plan) 

Wildlife and habitat inventory and monitoring plans have been required by U.S. Fish and Wildlife 

Service (Service) policy for a number of years. Refuge staff prepared a draft plan in the 1990s, 

but it was never completed or approved. Recently, the Alaska Region implemented a new policy 

mandating development of an Inventorying and Monitoring Plan (I&M Plan) for each refuge. The 

policy requires the I&M Plan to be reviewed every two years by the refuge, and by the Regional 

Office at 5–8 year intervals. Updates to the I&M Plan will be made as indicated from these 

reviews. Innoko Refuge proposes to conduct a review of its biological program prior to creating 

its I&M Plan. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 4-1 
Chapter 4: Implementation and Monitoring

4.1.2 Fisheries Management Plan 

The 1993 Innoko Fisheries Management Plan (FMP), which updated the 1989 Innoko Fisheries 

Management Plan, provides a description of habitats and fish species known or expected to occur 

within the refuge. It identifies the four purposes of the refuge as defined in the Alaska National 

Interest Lands Conservation Act (ANILCA) as goals, provides objectives for each goal, and lists 

tasks designed to meet the objectives. Some of the tasks list Alaska Department of Fish and 

Game (ADF&G) as the responsible office and may not fall under the jurisdiction of the refuge, 

although responsibilities may have changed since the FMP was developed. 

Many of the 10 objectives listed in the 1993 Innoko Fisheries Management Plan have not been 

addressed or have been only partially addressed, primarily due to lack of staffing and funding. 

Some progress has been made toward accomplishing the objectives about regulating harvest of 

refuge fish populations by issuing special use permits for guided sport fishing operations on the 

refuge and ongoing law enforcement coordination efforts during salmon runs. Monitoring and 

evaluating subsistence harvest of fish is an ongoing project with the Service Subsistence Office 

and the ADF&G Commercial Fish Division, which focuses on the subsistence harvest of salmon; 

information is collected based on personal interviews by Innoko’s refuge information technician 

and permit returns to ADF&G. 

The Innoko Fisheries Management Plan is was scheduled to be updated every five years and is 

now well over 10 years out of date. Innoko Refuge proposes to revise this plan within two years of 

approval of the I&M Plan. 

4.1.3 Cultural Resource Guide 

The Cultural Resource Guide assists the refuge staff in meeting legal requirements to protect and 

manage the cultural resources of the refuge. It provides a reference to the cultural resource 

guidance provided by law and regulation, the Service Manual, and the Cultural Resource 

Management Handbook. It outlines roles and responsibilities, summarizes legislation governing 

management of cultural resources, and contains information of potential use to the refuge 

manager. It describes the current state of knowledge of the prehistory and history of the region. 

It includes a list of projects that would fill in gaps in knowledge or complete existing work. This 

guide was completed in 1996 and will be updated by 2010. 

4.1.4 Fire Management Plan 

The Fire Management Plan describes how the refuge responds to wildland fires and includes 

appropriate management response options for fire management activities, including suppression, 

prescribed fire, and wildland fire use operations. The Fire Management Plan lists specific 

management objectives in regards to the use of fire and describes fire management strategies for 

fire suppression by refuge fire management units, including the Innoko Wilderness. The refuge 

has been classified and delineated with regard to suppression needs based on resources and 

structures at risk. The Fire Management Plan identifies refuge and agency responsibilities and 

interagency fire management coordination, and includes procedures for post-fire monitoring and 

evaluation. This plan was revised in March 2005. The refuge now has a full time fire management 

officer on staff who will guide implementation of the Fire Management Plan. Reviewed annually 

for adequacy, given current conditions, this plan is scheduled for revision in 2010. 

4-2 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 4: Implementation and Monitoring

4.1.5 Land Protection Plan 

The Innoko Refuge Land Protection Plan focuses on private lands within the refuge boundaries 

with the goal of identifying and conserving high-quality habitat on those lands (USFWS 2007). It 

provides a framework for refuge and private landowner cooperation. Land conservation measures 

will be pursued only with landowners who are willing to work with the Service and do not obligate 

the refuge or landowners to undertake any of the measures identified. The refuge must consider 

management goals, priorities, and availability of funds when approached by private landowners 

with land conservation proposals. The Innoko Land Protection Plan was completed in 2007. It will 

be revised in the future if changing land status warrants revision. 

4.1.6 Station Safety Plan and Occupant Emergency Plan 

These plans focus on providing a safe and healthful environment for employees and visitors. They 

aim to minimize the potential for injury to employees and the public and to prevent property 

damage. The Station Safety Plan describes programs needed to train personnel in how to deal 

with the environment, materials, and machines that may pose hazards, and its goal is making 

safety and environmental health integral parts of every task. These plans contain contact persons 

and phone numbers to be used in the event of an emergency and are posted at various locations in 

the McGrath administrative office and the Innoko field camp. Both plans are reviewed annually 

and revised as needed. 

4.1.7 Water Resources Inventory and Assessment: Plan of Study 

This plan, completed in December 1995, guides a seven-year inventory and assessment of the water 

resources of the refuge. Results of the study will be used to quantify in-stream flow water rights for 

the maintenance and protection of fish and wildlife habitat. Implementation will be determined by 

budget and personnel availability. 

4.1.8 Spill Prevention, Control, and Countermeasure Plan 

This plan outlines the procedures, methods, and equipment used at the refuge to comply with 

Environmental Protection Agency oil spill prevention, control, and countermeasure standards; 

and inspection, reporting, training, and recordkeeping requirements. The original plan was 

implemented in 2000 and was reviewed by the Regional Office Engineering staff in 2006. 

4.1.9 Visitor Services Plan 

Due to low levels of public use, the refuge does not have a separate Visitor Services Plan. Therefore, 

unless increased visitor use requires the refuge to prepare a Visitor Services Plan, this revised 

Comprehensive Conservation Plan will serve to guide public use management. 

4.1.10 Wilderness Stewardship Plan 

A Wilderness Stewardship Plan will be prepared for the Innoko Wilderness within two years of 

the Service adopting a national wilderness policy. This plan will provide additional detailed 

guidance for management of the Innoko Wilderness. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 4-3 
Chapter 4: Implementation and Monitoring

4.2 Partnership Opportunities 

Partnerships with other organizations are among the ways the Service fulfills its mission of 

“working with others to conserve, protect and enhance fish, wildlife, and plants and their habitats 

for the continuing benefit of the American people.” Partnership opportunities are consistent in 

both alternatives. 

The refuge exists within a dynamic ecosystem. Many of the resources within the refuge are of 

regional, State, national and international importance. The Service recognizes that the public, 

organizations, and other governmental agencies have interests in the refuge. Implementation of 

many refuge programs requires involvement from these interested parties. The refuge staff looks 

for opportunities to coordinate activities with the following (among others): 

 State of Alaska 

 Other Federal agencies 

 Federal Subsistence Western Interior Regional Advisory Council 

 Migratory Bird Co-management Council 

 Grayling, Anvik, Shageluk, and Holy Cross village councils 

 Grayling, Anvik, Shageluk, and Holy Cross village corporations 

 Tanana Chiefs Conference, Inc. (regional Native non-profit organization) 

 City of McGrath 

 Iditarod Area School District 

 Universities and museums 

 Nongovernmental organizations (including Friends of Alaska National Wildlife Refuges, 

Alaska Geographic, and Ducks Unlimited) 

Refuge biologists routinely cooperate with biologists from the ADF&G and Bureau of Land 

Management (BLM) to assess status and trends of moose on and near the refuge. The refuge has 

cooperated with the U.S. Geological Survey, Biological Resources Division, on regional projects 

ranging in subject from bird monitoring to goose loafing studies, and the U.S. Department of 

Agriculture Natural Resources Conservation Service on monthly snow depth surveys. A revised 

landcover map and report was developed for part of the refuge and surrounding areas in 2002 in 

cooperation with BLM and Ducks Unlimited (Bureau of Land Management et al. 2002). The 

refuge assists the Department of Defense (U.S. Air Force) by conducting annual breeding bird 

surveys at Tatilina Air Force Base. The refuge is an active participant in Boreal Partners in 

Flight, an organization comprised of bird biologists from agencies and organizations in Alaska and 

Canada. Boreal Partners in Flight provides a venue for biologists to share information on species 

of concern, discuss inventory and monitoring techniques, and pool resources and data to address 

questions about bird populations. 

Interagency cooperation is crucial when undertaking fire management activities. The BLM 

Alaska Fire Service (AFS) provides suppression services for Department of Interior agencies and 

is in charge of detecting, monitoring, and when appropriate and requested, suppressing fires on 

Federal lands in Alaska. The refuge’s fire management officer works closely with AFS when 

developing fire management plans, attends AFS briefings during the fire season, and coordinates 

with AFS on activities on the refuge. The refuge staff also works closely with fire personnel with 

the Alaska Department of Natural Resources, Division of Forestry, fire center in McGrath. 

4-4 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 4: Implementation and Monitoring

The refuge has worked cooperatively with facility and students at the University of Alaska Fairbanks 

and at other universities, and with other agency biologists and tribal council representatives. 

The refuge has been awarded Service challenge cost-share grants for activities on and near the 

refuge and in McGrath. Projects have included environmental education during Earth Week and a 

five-day summer science camp hosted by the refuge. Partners in McGrath-based cost-share 

projects included the Iditarod Area School District, Alaska Sealife Center, Alaska Bird 

Rehabilitation Center, Arctic Chapter of the Audubon Society, and ADF&G. 

Wildlife research and public use are expected to increase on the refuge. Public and private 

partners will be routinely sought where mutual interests exist in research and monitoring topics 

and objectives. Such collaboration would be consistent with the tradition and pattern of 

cooperative research and monitoring used by the refuge since 1981. 

4.3 Monitoring and Evaluation 

Monitoring helps refuge staff track the progress of Plan implementation. Results of monitoring 

activities show how objectives are being achieved and measure progress towards accomplishing 

goals. The refuge will be developing an inventory and monitoring step-down plan, and many of 

the refuge’s objectives involve collection of baseline data that may lead to additional monitoring 

efforts (see chapter 2, section 2.1). The step-down plans will provide detailed methods and 

frequencies for inventory and monitoring activities. Table 4-3 displays possible monitoring 

indicators and actions to be measured and possible management actions in response to indicators 

for fish and wildlife, their habitats, plants, recreational uses, and contaminants. Activities will be 

refined as step-down plans are prepared or revised. 

4.4 Plan Amendment and Revision 

Periodic review and change of this revised Comprehensive Conservation Plan and its various stepdown plans will be necessary. As knowledge of refuge resources, users, and uses improves, 

changes in management may be identified. Fish and wildlife populations, user groups, adjacent 

land users, and other management considerations change with time, often in unforeseen ways. 

Challenges also may be encountered in trying to implement the plan. 

Revisions are a necessary part of the adaptive management approach used by the Service. This 

means that objectives and strategies to reach goals can be adjusted. Most of the resulting changes 

will fine-tune the plan. These changes will not require modification of this document because 

minor changes will be addressed in the more detailed refuge step-down and annual work plans. 

Once the biological program review has been conducted and the Inventory and Monitoring Plan is 

approved, there may be a change in the direction of the biological program for Innoko Refuge. 

Only if a major change is required in management of the refuge would it be necessary to create a 

new revised Comprehensive Conservation Plan with a new environmental assessment. 

To enable refuge users; adjacent landowners; local, State, and Federal agencies; and other 

interested parties to express their views on how the refuge is being managed, the refuge will 

periodically hold meetings or use other techniques, such as comment cards and surveys, to solicit 

comments for evaluation purposes. By encouraging continuing public input, the refuge will be 

better able to serve the public, to determine potential problems before they occur, and to take 

immediate action to resolve existing problems. 

Periodically, refuge staff will review public comments, local and State government 

recommendations, staff recommendations, research studies, and other information to determine if 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 4-5 
Chapter 4: Implementation and Monitoring

4-6 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

revisions to the plan are necessary. If major changes are proposed, public meetings will be held, 

and a new environmental assessment or an environmental impact statement may be necessary. 

Full review and updating of this Comprehensive Conservation Plan will occur approximately 15 

years after its approval. 

4.5 Funding and Personnel Requirements 

The base refuge operational budget in FY 2007 was $1,197,000. To maintain the current level of 

services, an additional $428,000 will be necessary to balance the offsets of fixed costs and shortterm inflation. Long-term adjustments to the base budget reflect short-term adjustments and 

implementation of projects currently identified in the Refuge Operations Needs System (RONS) 

database. These figures represent the funding and accomplishment of established goals and 

objectives previously identified. Table 4-1 reflects the total funding necessary to fully implement 

the plan. Table 4-2 reflects staffing necessary to fully implement the plan. 

Table 4-1. Budget needs 

Item Short Term Needs 

(1–3 Years) 

Long Term Needs 

(3–15 Years) 

Refuge Operations $1,625,000 2,225,000 

Annual Maintenance 300,000 375,000 

Fire Funding 300,000 375,000 

Total Annual Budget Needs 2,225,000 2,975,000 

In the short term, additional personnel required to fully implement the plan include four 

permanent full-time employees (biologists and a maintenance worker), three additional permanent 

seasonal employees (for the biological and fire management programs), and 2.5 temporary 

seasonal employee equivalents. In the long-term, two additional permanent full-time employees 

(to support the biological and refuge operations programs) would be needed along with an 

additional 0.5 temporary seasonal employee equivalent. 

Table 4-2. Staffing needs beyond current levels 

Item Short Term Needs 

(1–3 Years) 

Long Term Needs 

(3–15 Years) 

Permanent Full-Time 

Employees 4 6 

Permanent Seasonal 

Employees 3 3 

Temporary Seasonal 

Employees 2.5 3 

Volunteers 4-6 6-8 

4.6 References Cited 

Bureau of Land Management, Innoko National Wildlife Refuge, and Ducks Unlimited. 

2002. Innoko earth cover classification. Bureau of Land Management, Anchorage, 

Alaska. Technical Report 47. 

USFWS. 2007. Land Protection Plan for Innoko National Wildlife Refuge. McGrath, 

Alaska. 
Chapter 4: Implem

Table 4-3. Examples of inventory or monitoring questions and possible management actions 

Inventory or Monitoring 

Question 

Measured Characteristics Goal(s) of Inventory or 

Monitoring Activity 

Possible Management 

Actions 

What wildlife and plant species occur on the refuge? 

Species, location, and density of birds Species, location, and density of small mammals Species and location of terrestrial insects Species, location, and density of herbaceous and woody plants Habitat information associated with bird, small mammal, and insect data 

Collect baseline information Collect baseline information Collect baseline information Collect baseline information Associate different habitats with various species of birds, small mammals, and insects 

NA: baseline data NA: baseline data NA: baseline data NA: baseline data Information will eventually allow the refuge to better predict how habitat disturbances may affect birds, small mammals, and insects 

BirpodisSmusiInsvarmePlavarranHaaccsta

How many moose are on the refuge, and what is their population trend? 

Population density Detect changes in 

population levels and distribution that can affect population 

Research potential causes of changes in populations Modify recreational and subsistence harvest regulations 

AededeintCatel

How many wolves use the refuge? 

Number, size, and distribution of packs 

Detect changes in number of packs, pack sizes, and distribution over time 

Research potential causes of population changes 

AeCatel

How many beaver are on the refuge? 

Number, distribution, and size of fall food caches 

Detect changes in number and sizes of active caches 

Research potential causes of change; modify trapping regulations if needed 

AeAe

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Chapter 4: Implementation and Monitoring 

4-8 Innoko National Wildlife Refuge Revised Compre

Inventory or Monitoring 

Question 

Measured Characteristics Goal(s) of Inventory or 

Monitoring Activity 

Possible Management 

Actions 

How does fire affect refuge resources? 

Small mammal species diversity and population density Plant species diversity and structure Forest age Fire intensity 

Document change in small mammal communities over time Document change in plant communities and habitats over time Document change in forest age and types over time Document change in area burned in different severity categories 

NA: Baseline data NA: Baseline data Allows better prediction of fire effects based on refugespecific information NA: Baseline data 

SaploSaploCoSaaer

Are there any invasive plants on the refuge? 

Presence of invasive plants Document location and 

diversity of invasive plants 

Eradication Di

op

What are the trends in goose populations on the refuge? 

Number and distribution of molting interior greater white-fronted and Canada geese 

Detect changes in goose numbers and/or distribution Provide data for regional investigations of interior greater white-fronted geese 

Research potential causes of changes in numbers Modify recreational harvest regulations along flyway and/or subsistence harvest regulations in Alaska 

Ae

How many swans utilize the refuge? 

Number of swans and cygnets on the refuge 

Document number and distribution of swans and cygnets on refuge 

Research potential causes of population changes 

Aesur

What are the trends in landbird populations? 

Species and number of birds 

Collect data to contribute to statewide and nationwide databases 

Research potential causes of populations changes 

Brrou

How many salmon migrate up the Innoko River onto the refuge? 

Species and number of salmon passing through a weir 

Collect data to contribute to management of Yukon River salmon fishery 

NA: Baseline data Do

nurun pa
Chapter 4: Implem

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Inventory or Monitoring 

Question 

Measured Characteristics Goal(s) of Inventory or 

Monitoring Activity 

Possible Management 

Actions 

What parts of the refuge do whitefish use on a seasonal basis? 

Locations of broad and humpback whitefish and least cisco 

Track movements of fish to identify migratory patterns, including spawning and wintering areas Collect morphological and genetic data on whitefish 

NA: Baseline data Protect important seasonal habitats Document movement of fish to off-refuge sites 

Ra

What are the current levels of visitor use on refuge lands and what are the trends? 

Number of visitors and parties, lengths of stay, sites visited, and activities occurring on the refuge 

Collect baseline data NA: Baseline data Co

guopob

Is recreational use on the refuge displacing subsistence users? 

Number and type of displacement incidents observed or reported 

Collect baseline data Increase visitor education 

Work with guides, transporters, and subsistence users to resolve issues Modify stipulations on permits 

Colocairsta

Are known historic mining sites along the Innoko, Mud, Dishna, or Iditarod rivers leaking containments into the river system? 

Water quality downstream of mining sites 

Collect baseline data To be determined based 

upon findings 

Me

How are visitors getting information on the refuge and are they finding the information they seek? 

Type of information requested, information sources, information lacking 

Collect baseline data Modify methods of 

information retrieval to increase ease of use, sources, and types of information available 

Invcomthe Asopsur Dispecon
Chapter 5: Consultation and Coordination with Others 

5. Consultation and Coordination with Others 

5.1 Interagency agreements 

5.1.1 Wildland fire suppression services 

The Bureau of Land Management (BLM) Alaska Fire Service has a memorandum of 

understanding for providing wildland fire suppression and preparedness services for the northern 

area of U.S. Fish and Wildlife Service (Service) Region 7 refuges (including the Innoko National 

Wildlife Refuge). 

5.1.2 Radio repeater sites 

Innoko National Wildlife Refuge (refuge, Innoko Refuge) and BLM have a memorandum of 

understanding for the placement of a radio repeater site on Blackburn Mountain. Two radio repeater 

sites are also located on State of Alaska lands at Mount Hurst and the Beaver Mountains. 

5.1.3 Others 

Innoko Refuge is party to several regional agreements between the Service and various State of 

Alaska departments and other federal agencies, including: 

 Law enforcement cooperation 

 Management of the Iditarod National Historic Trail 

 Conducting breeding bird surveys on and around Tatalina Air Force Base and the Early 

Warning Site 

 Yukon-Innoko Moose Management Plan 

5.2 Section 7 compliance 

No federally threatened or endangered species exist on the Innoko Refuge. Therefore, no action is 

required under the Endangered Species Act of 1973 (16 U.S.C. 1531 et seq: 87 stat 884, as amended). 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 5-1 
Appendix A: Legal Guidance and Planning Coordination 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan A-1 

1. Legal Guidance and Planning 

Coordination 

1.1 Introduction 

Management of Innoko National Wildlife Refuge (refuge, Innoko Refuge) is dictated, in large 

part, by the legislation that created the unit and the purposes and goals described in chapter 1. 

However, other laws, regulations, and policies also guide the management of the refuge. This 

appendix identifies the acts and policy guidance that are integral in the development of this 

Comprehensive Conservation Plan (Plan). 

1.2 Legal Guidance 

Operation and management of the refuge is influenced by a wide array of Federal laws, treaties, 

and executive orders. Among the most important are the National Wildlife Refuge System 

Administration Act, as amended by the National Wildlife System Improvement Act; the Refuge 

Recreation Act; the Endangered Species Act; and the Wilderness Act. These acts are described 

briefly along with other acts and legal guidance that influence management of the Innoko Refuge. 

1.2.1 International Treaties 

Several treaties affect how the U.S. Fish and Wildlife Service (Service) manages Innoko Refuge. 

Among these are migratory bird treaties with Canada, Mexico, Japan, and Russia; and the 

Convention on Nature Protection and Wildlife Conservation in the Western Hemisphere. These 

treaties differ in emphasis and species of primary concern, but collectively provide clear mandates 

for identifying and protecting important habitats and ecosystems and for protecting and 

managing individual species. 

Treaties for migratory bird protection include management provisions such as (1) prohibiting 

disturbance of nesting colonies; (2) allowing the Secretary of the Interior to establish seasons for 

the taking of birds and the collection of their eggs by “indigenous inhabitants” of Alaska for their 

own nutritional and other essential needs; (3) directing each nation to undertake, to the maximum

extent possible, measures necessary to protect and enhance migratory bird environments and t

prevent and abate pollution or detrimental alternation of their habitats; and (4) providing that 

protective measures under the treaty may be applied to species and subspecies not l

o 

isted in the 

pecific convention, but that belong to one of the families containing listed species. 

ed on the refuge, 118 are 

nown or believed to breed in the area, and the majority are migratory. 

s

Of the migratory bird species of concern in the treaties, those that use Innoko Refuge include 

several Species of Concern identified by the State of Alaska: American peregrine falcon, arctic

peregrine falcon, northern goshawk, olive-sided flycatcher, gray-cheeked thrush, Townsend’s 

warbler, and blackpoll warbler. Of 128 bird species that have been record

k
Appendix A: Legal Guidance and Planning Coordination 

A-2 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

1.2.2 National Guidance 

Alaska National Interest Lands Conservation Act of 1980 as amended, 16 U.S.C. 140hh-3233, 43 

U.S.C. 1602-1784 

ANILCA—in addition to amending the Alaska Native Claims Settlement Act, the Alaska 

Statehood Act, and the Wild and Scenic Rivers Act, and modifying portions of the Wilderness Act 

as it applies to Alaska lands—expanded the Federal conservation system in Alaska (including 

national parks, refuges, forests, Wilderness areas, and Wild and Scenic Rivers. Specifically, title 

III of ANILCA established new refuges, identified the purposes of each refuge, and provided 

administrative guidance for management of refuges in Alaska, including requiring the preparation 

and periodic updating of a comprehensive conservation plan for each refuge. 

In addition, ANILCA provided comprehensive management guidance for all Federal public lands 

in Alaska, including provisions regarding Wilderness; subsistence; transportation and utility 

corridors; oil and gas leasing; mining; public access; and hunting, fishing, and trapping. No Wild 

and Scenic Rivers were designated on Innoko Refuge by ANILCA. Section 1317 required that all 

refuge lands not designated as Wilderness be reviewed for their suitability for Wilderness 

designation, in accordance with the provisions of the Wilderness Act. The Wilderness Review 

conducted as part of the Final Innoko Comprehensive Conservation Plan recommended that—

although all refuge lands are suitable for designation as Wilderness—no additional lands would be 

recommended for inclusion in the National Wilderness Preservation System. 

Alaska Native Claims Settlement Act of 1971 as amended, 43 U.S.C. 1601-1624 

The purpose of this act was to provide for “...settlement of all claims by Natives and Native 

groups of Alaska, based on aboriginal land claims.” It provided for grants of land and money, and 

the establishment of Native corporations to maintain the economic affairs of Native organizations. 

In exchange, all aboriginal titles and claims, including any fishing and hunting rights, were 

extinguished. Section 12(a) allowed village corporations to select lands, with several stipulations, 

in national wildlife refuges. Section 22(g), however, stated that these lands were to “...remain 

subject to the laws and regulations governing use and development of such refuge.” Other refuge 

lands were selected under section 14(h)(1), which allowed regional corporations to select cemetery 

sites and historical places. Section 17(b) provided for public easement across Native lands for 

access to Federal lands. Section 17(d)(2)(A) provided the basis for the enactment of ANILCA. 

National Wildlife Refuge System Administration Act of 1966 as amended by the National 

n 

It 

 Act, 

 and 

laces restrictions on the transfer, exchange, or other disposal of lands within the System. 

Wildlife Refuge System Improvement Act of 1997, 16 U.S.C. 668dd-668ee 

This act establishes a unifying mission for the National Wildlife Refuge System (System), a missio

that, first and foremost, focuses on the conservation of fish, wildlife, plants, and their habitats. 

requires the preparation of a comprehensive conservation plan for each unit of the System. 

Furthermore, it reinforces and expands the “compatibility standard” of the Refuge Recreation

which requires that public uses must be determined to be compatible with refuge and agency 

missions and purposes before they can be allowed, and establishes a process for determining 

compatibility. The act also identifies six priority wildlife-dependent recreation uses, clarifies the 

authority of the Secretary of the Interior to accept donations of money for land acquisition,

p
Appendix A: Legal Guidance and Planning Coordination 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan A-3 

The Refuge Recreation Act of 1962 as amended, 16 U.S.C. 460k-460k-4 

This act requires that any recreation use on areas of the System be “compatible” with the primary

purpose(s) for which the area was acquired or established. It also requires that sufficient fund

be available for the development, operation, and m

ing 

aintenance of recreation uses that are not 

irectly related to the area’s primary purpose(s). 

(40 

f 

 Federal agencies, tribal governments, and public in the planning and decision 

ectly 

pecies or their critical habitat (section 7). 

he 

ilderness designation, but no lands were recommended for inclusion in the National Wilderness 

designated Wilderness. 

f water 

ivers. 

generations. For Wild and Scenic Rivers 

 Alaska, ANILCA also provided direction for management of designated rivers. No Wild and 

cenic Rivers have been designated on Innoko Refuge. 

d

National Environmental Policy Act of 1969 as amended, 42 U.S.C. 4321-4347 (NEPA) 

This act and the implementing regulations developed by the Council on Environmental Quality 

CFR 1500-1508) require Federal agencies to integrate the National Environmental Policy Act 

(NEPA) process with other planning at the earliest possible time to provide a systematic 

interdisciplinary approach to decision making; to identify and analyze the environmental effects o

their actions; to describe appropriate alternatives to the proposed actions; and to involve the 

affected State and

making process. 

Endangered Species Act of 1973 as amended, 16 U.S.C. 1231-1544 

The Endangered Species Act provides for the conservation of threatened and endangered species 

of fish, wildlife, plants, and their critical habitats by Federal action and by encouraging the 

establishment of State programs. Although not specifically addressing the System, it does dir

affect management activities on national wildlife refuges. It directs Federal agencies to take

actions that would further the purposes of the act and to ensure that actions they carry out, 

authorize, or fund do not jeopardize endangered s

The Wilderness Act of 1964, 16 U.S.C 1131-1136 

This act (P.L. 88-577) defined the Wilderness resource and established the National Wilderness 

Preservation System. It provides the framework for designation by Congress of new units to t

System and prescribes for their management. A Wilderness Review—which is required by section 

1317 of ANILCA—was undertaken during development of the refuge’s 1987 Comprehensive 

Conservation Plan and Environmental Impact Statement following the framework and guidance 

provided by the Wilderness Act. The review found all non-designated refuge lands suitable for

W

Preservation System. Innoko Refuge currently has 1,322,045 acres of 

The Wild and Scenic Rivers Act of 1968, 16 U.S.C. 1271-1287 

This act establishes a National Wild and Scenic Rivers System and describes the methods and 

standards through which additional rivers may be identified and added to the system. Section 

5(d)(1) requires that in all planning by Federal agencies—for the use and development o

and related land resources—consideration be given to potential wild, scenic, and recreation r

Rivers are added to the national system based on their free-flowing character and their 

outstandingly remarkable scenic, recreation, geologic, fish and wildlife, historic, cultural, 

ecological, or other values. Rivers in the system are managed to maintain and protect these 

outstandingly remarkable values for present and future 

in

S
Appendix A: Legal Guidance and Planning Coordination 

A-4 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

The Federal Water Pollution Control Act of 1972, as amended by The Clean Water Act of 1977, 3

U.S.C. s/s 1251 et seq. 

This act regulates the discharge of pollutants into waters of the United States. The act protects 

fish and wildlife, establishes operation permits for all major sources of water pollution, limits the

discharge of

3 

 pollutants or toxins into water, and makes it unlawful for any person to discharge any 

ollutant from a point source into navigable waters unless a permit is obtained under the Clean 

, commercial fishing, preservation and protection 

f cultural and historic resources, and other activities on Federal lands are also considered in the 

lanning process. 

ent 

ch of 

 by 

 description of this concept and of several of 

the national and regional (Alaska) management plans and programs that were considered during 

es, such as the compatibility policy, are described in 

h 

ions in 

opardy. Less obvious, but equally significant, are actions that restore important habitats, reduce 

 approach in which it works 

ith others to conserve the nation’s biological heritage will the goal be realized. An ecosystem 

p

Water Act. 

Other Laws 

Laws that affect mineral leasing, recreation use

o

comprehensive conservation p

1.3 Policy Guidance 

Programmatic guidance and policy documents provided additional direction for the managem

of national wildlife refuges throughout the System. While it is not practical to provide information 

about all of theses documents in this Plan, they are critical to management of the refuge. Mu

the management direction described in chapter 2 and throughout this Plan is influenced

guidance from these programmatic and policy documents. Several of these documents guide us to 

use an ecosystem approach in refuge management. In other words, the health of the entire 

ecosystem must be considered when managing the refuge. This concept requires close 

coordination with others. This section provides a brief

the development of this plan. Other key polici

chapter 2 because they provide guidance in this plan. 

1.3.1 Ecosystem Approach to Management 

The goal of the Fish and Wildlife Service’s Ecosystem Approach is to constantly strive to 

contribute to “the effective conservation of natural biological diversity through perpetuation of 

dynamic, healthy ecosystems” while carrying out the Service’s mission and mandates and throug

working closely with others (USFWS 1996). This is an ambitious goal; success lies in the 

coordinated efforts of many public agencies, private organizations, landowners, and citizens. Many 

programs and initiatives contribute to the conservation of biological diversity. Most obvious are 

actions that lead to the protection of habitat and the recovery of fish and wildlife populat

je

environmental degradation and contamination, monitor the integrity of natural systems, regulate

the harvest of migratory birds, and provide technical assistance to private landowners. 

The Service cannot fulfill this goal alone; only through an ecosystem

w

approach to management recognizes that institutions other than refuges have responsibilities and

authorities for resources that lie both within and outside refuges. 
Appendix A: Legal Guidance and Planning Coordination 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan A-5 

Fish and wildlife population and habitat goals are based on species biology, population dynamics, 

and ecological processes that may be international in scope (e.g., migratory waterfowl). Managers

must think and function at multiple scales simultaneously. Planning and implementation of 

management actions within the U.S. Fish and Wildlife Service’s ecosystem units must be flexible 

rvation priorities and reflect the broader population and 

hip 

that migrate across State lines, 

ere are several national efforts designed to monitor and protect these species. These plans were 

e Plan to ensure that the revised management 

ded in the 1970s. The international partnership has worked to identify 

d goals and objectives for waterfowl populations 

s; 

onservation initiatives. Bird 

ach region to identify species and habitats most in need of 

 habitat is available in adequate quantity and quality to support shorebird populations in 

tion plan is to restore and maintain shorebird 

port a vision 

merica, and the Caribbean.” Their plan “provides a 

ontinental-scale framework for the conservation and management of 210 species of 

enough to address site-specific conse

habitat needs of widely ranging species. 

1.3.2 National Management Plans 

Nature is not constrained by the administrative boundaries that are used to determine owners

or management of specific areas of land. Without physical barriers and with available habitat, 

wildlife and fish will freely roam through lands and waters regardless of ownership or 

management. To ensure the conservation of the many species 

th

reviewed during the revision of the Innoko Refug

direction is consistent with these national conservation plans. 

North American Waterfowl Management Plan 

This conservation plan seeks to restore waterfowl populations in Canada, the United States, and

Mexico to levels recor

priority habitats for waterfowl and has establishe

and habitats (USFWS 1998). The Innoko Refuge provides breeding and migration habitat for a 

variety of waterfowl.

Partners in Flight – Bird Conservation Plans 

Partners in Flight is a cooperative effort involving partnerships among Federal, State, and local 

government agencies; philanthropic foundations; professional organizations; conservation group

industry; the academic community; and private individuals. Partners in Flight was created in 1990

in response to growing concerns about declines in the populations of many land bird species and to

emphasize the conservation of birds not covered by existing c

conservation plans are developed in e

conservation, to establish objectives and strategies to provide needed conservation activities, and 

to implement and monitor progress on the plans. 

U.S. Shorebird Conservation Plan 

This conservation plan seeks to stabilize populations of all shorebirds that are in decline because 

of factors affecting habitat in the United States At a regional level, the plan’s goal is to ensure that 

shorebird

each region. Ultimately, the goal of the conserva

populations throughout the Western Hemisphere through an international partnership (Brown et 

al. 2000). 

North American Waterbird Conservation Plan 

“Waterbird Conservation for the Americas” is a partnership that was created to “sup

in which the distribution, diversity, and abundance of populations and habitats of breeding, 

migratory, and non-breeding waterbirds are sustained or restored throughout the lands and 

waters of North America, Central A

c
Appendix A: Legal Guidance and Planning Coordination 

A-6 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

waterbirds...in 29 nations throughout North America...” Sixty species of migratory waterbirds, 

nnoko 

gement goals of neighboring lands of the region. Regional plans, and 

oals and objectives from other programs, were reviewed to understand how Innoko Refuge can 

onservation within the State or local region. This list is not intended to 

lan 

he Innoko National Wildlife Refuge has worked cooperatively with the Alaska Department of 

Fish and Game on a moose management plan for Game Management Units 21A and 21E and the 

is plan is a progressive plan with trigger points for different management 

options

(GASH

1.4

Brown, Harrington, eds. 2000. The U.S. shorebird conservation plan. 

Manomet, Massachusetts: Manomet Center for Conservation Sciences. 

USFWS. 1996. Service Manual 052 FW 1. Available at: 

http://www.fws.gov/policy/052fw1.html. Accessed: 5 September, 2007. 

USFWS. 1998. “Expanding the Vision: 1998 Update, North American Waterfowl 

Management Plan.” 

including such diverse groups as loons, grebes, cranes, jaegers, gulls, and terns, occur on I

Refuge, most of them as breeders.

1.3.3 Regional Management Plans 

In addition to the national conservation plans, the Innoko Refuge Plan must consider the 

conservation plans and mana

g

contribute to the goals for c

be comprehensive but demonstrates some of the major regional plans that were reviewed during

the development of this plan. When applicable, specific information from these plans has been 

incorporated into this plan. 

Moose Management P

T

Innoko Refuge area. Th

 for moose populations in the Innoko River and Grayling, Anvik, Shageluk, and Holy Cross 

) village areas. 

References 

 S., C. Hickey, and B.
Appendix B: Coordination with the State of Alaska 

1. Coordination with the State of Alaska, 

Including the Master Memorandum of 

Understanding with the Department of 

Fish and Game 

1.1 Introduction 

Consistent with the principles of ecosystem management and the laws and policies described in 

Appendix A, effective management of the Innoko National Wildlife Refuge (refuge, Innoko 

Refuge) must be done in close coordination with the State of Alaska. This appendix is not intended 

to be a comprehensive list of state agencies, but rather describe the primary state agencies that 

share concern and responsibilities for fish, wildlife, and other natural resources. 

1.2 Alaska Department of Fish and Game 

The Alaska Department of Fish and Game (ADF&G) has the primary responsibility for managing 

fish and resident wildlife populations. On refuge lands, the U.S. Fish and Wildlife Service 

(Service) and ADF&G share a mutual concern for all fish and wildlife resources and their habitats, 

and both are engaged in extensive fish and wildlife conservation, management, and protection 

programs. In 1982, the Service and ADF&G signed a Master Memorandum of Understanding 

(dated March 13, 1982) that defines the cooperative management roles of each agency (section 

1.2.1). This memorandum sets the framework for cooperation between the two agencies. 

Through the direction of the Boards of Fisheries and Game, the State of Alaska establishes 

fishing, hunting, and trapping regulations throughout the state. These regulations apply to 

Federal public lands unless superseded by federal subsistence regulations. The state is divided 

into 26 game management units (GMUs); most of these are further divided into subunits. State 

management objectives are developed for wildlife populations within the GMUs. All Innoko 

Refuge lands lie within GMU 21 (subunits A, D, and E). Management objectives for wildlife and 

fish populations on the Refuge are discussed in chapter 3. 

The state process for developing regulations involves substantial public input to the Alaska 

Boards of Fisheries and Game concerning changes in regulations and allocations. Input may be 

directly to the boards through testimony and proposals or indirectly through participation in local 

fish and game advisory committees. The advisory committees assist the boards in assessing local 

fish and wildlife issues and proposed regulations. Biological staff from ADF&G also provides data 

and analysis of proposals to the boards. Regulations may be changes by the boards at regular 

meetings, by emergency regulations, or by emergency order. 

Although many biologists within ADF&G have law enforcement authority, most enforcement of 

fishing and hunting regulations is carried out by refuge law enforcement officers and officers of 

the Alaska Department of Public Safety. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan B-1 
Appendix B: Coordination with the State of Alaska 

ADF&G’s Division of Wildlife Conservation works to conserve and enhance Alaska’s wildlife and 

to provide for a wide range of uses for the greatest benefit of current and future generations of 

people through management of wildlife populations and habitat, research, information transfer, 

regulatory activities, and public service. Wildlife Conservation is responsible for overseeing 

development of management plans for a variety of wildlife populations throughout the state. 

ADF&G’s Division of Sport Fish is responsible for the State’s recreational fishery resources: the 

conservation of self-perpetuating populations of fish; management of sport fisheries in both salt 

and fresh water; and hatchery production and release of fish for recreational fishing. The goals of 

the division are to conserve naturally reproducing populations of sport fish species, provide a 

diverse mix of recreational fishing opportunities, and optimize the social and economic benefits of 

Alaska’s recreational fisheries. 

ADF&G’s Division of Subsistence is the research branch of the department responsible for 

providing comprehensive information on the customary and traditional use of wild resources. 

Information is provided to meet management goals, aid in regulation development, facilitate 

collaborative agreements, assess environmental impacts, and describe the unique role of wild 

resources in Alaska. 

1.2.1 Master Memorandum of Understanding Between the Alaska Department of Fish and Game 

and the U.S. Fish and Wildlife Service 

This Master Memorandum of Understanding between the State of Alaska, Department of Fish 

and Game, hereinafter referred to as the Department, and the U.S. Fish and Wildlife Service, 

hereinafter referred to as the Service, reflects the general policy guidelines within which the two 

agencies agree to operate. 

WHEREAS, the Department, under the Constitution, laws, and regulations of the State of 

Alaska), is responsible for the management, protection, maintenance, enhancement, rehabilitation, 

and extension of the fish and wildlife resources of the State on the sustained-yield principle, 

subject to preferences among beneficial uses; and 

WHEREAS, the Service, by authority of the Constitution, laws of Congress, and regulations of 

the U.S. Department of Interior, has a mandated management responsibility for certain species or 

classes of wildlife, and is responsible for the management of Service lands in Alaska, and the 

conservation of fish and wildlife resources on these lands; and 

WHEREAS, the Department and the Service share a mutual concern for fish and wildlife 

resources and their habitats and both are engaged in extensive fish and wildlife conservation, 

management, and protection programs and desire to develop and maintain a cooperative 

relationship, which will be in the best interests of both parties, the concerned fish and wildlife 

resources, and their habitats, and produce the greatest public benefit; and 

WHEREAS, it has been recognized in the Alaska National Interest Lands Conservation Act and 

subsequent implementing Federal regulations that the resources and use of Service lands in 

Alaska are substantially different than those of other states; and 

B-2 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix B: Coordination with the State of Alaska 

WHEREAS, the Department and the Service recognize the increasing need to coordinate 

resource planning and policy development; 

NOW, THEREFORE, the parties hereto do hereby agree as follows: 

THE DEPARTMENT OF FISH AND GAME AGREES: 

1. To recognize the Service as the agency with the responsibility to manage migratory birds, 

endangered species, and other species mandated by Federal law, and on Service lands in 

Alaska to conserve fish and wildlife and their habitats and regulate human use. 

2. To manage fish and resident wildlife populations in their natural species diversity on 

Service lands. 

3. To consult with the Regional Director in a timely manner and comply with applicable 

Federal laws and regulations before embarking on enhancement or construction activities 

on Service lands. 

THE FISH AND WILDLIFE SERVICE AGREES: 

1. To recognize the Department as the agency with the primary responsibility to manage fish 

and resident wildlife within the State of Alaska. 

2. To recognize the right of the Department to enter onto Service lands at any time to 

conduct routine management activities which do not involve construction, disturbance to 

the land, or alterations of ecosystems. 

4. To cooperate with the Department in planning for enhancement or development activities 

on Service lands which require permits, environmental assessments, compatibility 

assessments, or similar regulatory documents by responding to the Department in a 

timely manner with requirements, timetables, and any other necessary input. 

5. To manage the fish and wildlife habitat on Service lands so as to ensure conservation of 

fish and wildlife populations and their habitats in their natural diversity. 

6. To consider carefully the impact of any proposed treaties or international agreements 

relating to fish and wildlife resources on the State of Alaska which could diminish the 

jurisdictional authority of’ the State and to consult freely with the State when these 

treaties or agreements have a primary impact on the State. 

7. To review present U.S. Fish and Wildlife Service policies and any future proposed changes 

in those policies in consultation with the Department to determine if modified or special 

policies are needed for Alaska. 

8. To adopt refuge management plans whose provisions—including provision for animal 

damage control—are in substantial agreement with the Department’s fish and wildlife 

management plans, unless such plans are determined formally to be incompatible with the 

purposes for which the respective refuges were established. 

9. To utilize the State’s regulatory process to maximum extent allowed by Federal law in 

developing new or modifying existing Federal regulations or proposing changes in 

existing State regulations governing or affecting the taking of fish and wildlife on 

Service lands in Alaska. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan B-3 
Appendix B: Coordination with the State of Alaska 

THE DEPARTMENT OF FISH AND GAME AND THE FISH AND WILDLIFE SERVICE 

MUTUALLY AGREE: 

1. To coordinate planning for management of fish and wildlife resources on Service lands so 

that conflicts arising from differing legal mandates, objectives, and policies either do not 

arise or are minimized. 

2. To consult with each other when developing policy and legislation which affect the 

attainment of wildlife resource management goals and objectives or management plans. 

3. To recognize that the taking of fish and wildlife by hunting, trapping, or fishing on Service 

lands in Alaska is authorized in accordance with applicable State and Federal law unless 

State regulations are found to be incompatible with documented Refuge goals, objectives, 

or management plans. 

4. To develop such supplemental memoranda of understanding between the Commissioner 

and the Regional Director as may be required to implement the policies contained herein. 

5. That this Master Memorandum of Understanding shall become effective when signed by 

the Commissioner of the Alaska Department of Fish and Game and the Alaska Regional 

Director of the U.S. Fish and Wildlife Service and shall continue in force until terminated 

by either party by providing notice in writing 120 days in advance of the intended date of 

termination. 

6. That amendments to this Master Memorandum of Understanding may be proposed by 

either party and shall become effective upon approval by both parties. 

STATE OF ALASKA U.S. DEPARTMENT OF THE INTERIOR 

Department of Fish and Game Fish and Wildlife Service 

/signed/ Ronald O. Skoog /signed/ Keith M. Schreiner

Commissioner Regional Director, Alaska 

March 13, 1982 March 13, 1982

Date Date 

1.3 Alaska Department of Natural Resources 

The Alaska Department of Natural Resources (DNR) and its divisions are also key management 

partners, coordinating with the Service and other Federal and State agencies in managing public 

lands (Federal and State) in Alaska. DNR manages all State-owned lands, water, and surface and 

subsurface resources except for fish and game. DNR’s Division of Mining, Land and Water 

mangers the state’s water and land interests within national wildlife refuges. These interests will 

become increasingly significant in the next 10 to 15 years, especially in regard to water rights, 

navigable waters, ownership of submerged lands, and rights-of-way over refuge lands. 

B-4 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix B: Coordination with the State of Alaska 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan B-5 

1.4 Alaska Department of Environmental 

Conservation 

The Alaska Department of Environmental Conservation (DEC) is also a key partner regarding 

refuge management efforts in light of its mission of “conserving, improving and protecting 

Alaska’s natural resources and the environment.” For example, DEC has direct, statewide 

responsibility for monitoring and maintaining air and water quality. Some of the interagency 

coordination agreements and mechanisms involving DEC also involve DNR and ADF&G; others 

are specific to DEC. Issues of interest to the refuge that may include authorizations from or 

cooperation with DEC include air and water quality monitoring, invasive species management, 

public health and safety, hazardous material spills, and chemical use. 
Appendix C: Predator Management 

1. Predator Management 

This document outlines out our current understanding of policy and the process we would have to 

follow to undertake predator management on Innoko Refuge. 

The U.S. Fish and Wildlife Service (Service) is responsible for managing national wildlife refuges. 

As the responsible land manager for the refuge, the Service acknowledges that wolves and bears can 

significantly affect prey population levels. The Service considers predator management a legitimate 

conservation tool when applied in a prudent and ecologically sound manner and when other 

alternatives are not practical. When predator management proposals or actions are in conformance 

with laws, regulations, and agency policies that govern management of national wildlife refuges, 

they would be considered by the Service. (See Section 2.4.11 for further discussion.) 

The low abundance of moose and high abundance of wolves were raised as issues in scoping 

meetings for this Comprehensive Conservation Plan. Responding to this, we have decided that we 

will use this appendix to outline the process necessary to consider individual predator 

management proposals. This would most likely be conducted in a subsequent detailed step-down 

plan and environmental analysis. We would consider guidelines prescribed by the legal and 

biological context to describe how such a step-down plan and environmental analysis could analyze 

a predator management proposal and what questions would likely need to be answered prior to 

authorizing a predator management program on a national wildlife refuge. 

The Alaska Department of Fish and Game (ADF&G) is recognized as the agency with the primary 

responsibility to manage fish and resident wildlife populations within the state, including refuges, 

unless that management is superseded by federal law. ADF&G has developed specific processes 

regarding the implementation of predator management programs. Any proposals for a predator 

management program would be evaluated in cooperation with ADF&G to ensure that they are in 

substantial agreement with State wildlife management plans, unless they are formally determined 

to be incompatible with the purposes of the Refuge. 

The Legal Context – What laws, regulations, and policies govern refuge decisions on predator 

management? 

The principal federal statutes affecting our management of predators and their prey on refuges are 

the Alaska National Interest Lands Conservation Act (ANILCA); the National Wildlife Refuge 

System Administration Act, as amended, (Refuge Administration Act); and the National 

Environmental Policy Act (NEPA). We follow the regulations and policies which implement those 

laws. Key provisions of these laws that pertain to refuge decisions on predator management follow. 

1. ANILCA –ANILCA established the Innoko National Wildlife Refuge and set forth the primary 

purposes for which it was established. One purpose is “to conserve fish and wildlife populations 

and habitats in their natural diversity...” Another is to provide, “in a manner consistent with” the 

conservation of wildlife populations in their natural diversity, “the opportunity for continued 

subsistence uses by local residents.” These purposes are described in Section 1.4.1. 

2. Refuge Administration Act, as amended in 1997, mandates that, in administering the National 

Wildlife Refuge System (System) and the purposes of each refuge, the Service shall “provide for 

the conservation of fish, wildlife, and plants, and their habitats” and “ensure that the biological 

integrity, diversity, and environmental health of the System are maintained for the benefit of 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan C-1 
Appendix C: Predator Management 

present and future generations of Americans.” Both the Refuge Improvement Act and ANILCA 

require uses of refuges be compatible with their purposes. 

The Refuge Improvement Act does not diminish the authority, jurisdiction, or responsibility of the 

states to manage, control, or regulate fish and resident wildlife under state law. 

In 2001, to implement provisions of the Refuge Administration Act, as amended, the Service 

established the Biological Integrity, Diversity, and Environmental Health Policy to describe the 

relationships among refuge purposes, the mission of the refuge System, biological integrity, 

diversity and environmental health of refuge resources, and resolution of the conflicts among them. 

Biological integrity is defined as the biotic composition, structure, and functioning at genetic, 

organism, and community levels comparable with historic conditions, including the natural biological 

processes that shape genomes, organisms, and communities. (601 FW 3.6B) The policy provides 

guidance on maintaining these elements of diversity and on restoring lost or degraded elements of 

integrity, diversity, and environmental health at the refuge scale and other appropriate landscape 

scales where it is feasible and supports the achievement of refuge purposes and the System mission. 

(601 FW 3.7D). Under this policy, the Service favors management that restores or mimics natural 

ecosystem processes or functions to achieve refuge purposes. (601 FW 3.7E) 

Wildlife populations, including predators and prey, are to be managed for natural densities and 

levels of variation using historical conditions as the frame of reference. Information on historic 

sources may be historical, archaeological, or other. Historical information can include the written 

and, in some cases, the pictographic accounts of Native Americans, explorers, surveyors, traders, 

and early settlers. Archaeological information comes from collections of cultural artifacts 

maintained by scientific institutions. We may obtain other data from a range of sources, including 

research, soil sediments, and tree rings (601 FW3.13 A) 

The Biological Integrity, Diversity, and Environmental Health Policy requires that refuge managers: 

A) Identify the refuge’s purpose(s), legislative responsibilities, and roles within the 

ecosystem and the System mission. 

B) Assess the current status of biological integrity, diversity, and environmental health 

on the refuge through baseline surveys and studies. 

C) Assess historic conditions and compare them to the current conditions. This will 

provide benchmarks to evaluate the relative intactness of ecosystem functions and 

processes. This assessment should include the opportunities and limitations to 

maintaining and restoring biological integrity, diversity, and environmental health. 

D) Consider the refuge’s importance to refuge, ecosystem, national and international 

landscape scales of biological integrity, diversity, and environmental health. 

E) Consider the relationships among refuge purposes and biological integrity, diversity, 

and environmental health, and resolve conflicts among them. 

F) Through the comprehensive conservation planning process, interim management 

planning, or compatibility reviews, determine the appropriate management direction 

to maintain and, where appropriate, restore biological integrity, diversity, and 

environmental health, while achieving refuge purposes(s). 

C-2 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix C: Predator Management 

G) Evaluate the effectiveness of our management by comparing results to desired 

outcomes. If the results of our management strategies are unsatisfactory, assess the 

causes of failure and adapt our strategies accordingly. 

3. National Environmental Policy Act (NEPA) 

Predator management of wolves and/or bears on national wildlife refuges is action subject to 

National Environmental Policy Act (NEPA) requirements, which could require preparation of an 

environmental assessment (EA) or an impact statement (EIS). As part of NEPA compliance, the 

Service would evaluate predator management in a legal context, such as conformity with the 

purposes of the Refuge, the Refuge Administration Act, as amended, and the Service’s Biological 

Integrity, Diversity, and Environmental Health Policy. NEPA and other laws, regulations, and 

policies would require a comprehensive analysis and public involvement process prior to 

implementing any predator management program. Additionally, as part of the NEPA process 

and documentation, we would evaluate the effects of proposed predator management actions on 

subsistence uses and needs as required by section 810 of ANILCA. 

The Biological Context – What do we need to know about predators and prey to consider 

requests /proposals for predator management on the Innoko National Wildlife Refuge? 

1. Consideration of requests/proposals for predator control on National Wildlife Refuges 

in Alaska: 

The refuge manager is the primary Service representative who determines whether a proposed 

predator management program is consistent with the refuge purposes and the Biological Integrity, 

Diversity, and Environmental Health Policy, and other laws, regulations and policies. As described 

in the following text, the refuge manager would need to assess the status of predator and prey 

populations and their habitats in relation to their historical abundance and fluctuations. A thorough 

evaluation must be given to substantiate the intended benefits of any predator management efforts. 

Alternatives to direct control must be evaluated as a practical means of achieving management 

objectives. Where there is insufficient predator, prey, or habitat information to make such an 

assessment, population surveys or other biological studies will be needed. The Innoko National 

Wildlife Refuge is presently conducting some of these studies. The need for additional studies and 

availability of funds for such work will be assessed by the refuge manager. 

The Service favors management that relies on natural ecosystem processes or functions to achieve 

refuge purposes. If prey densities are determined to be significantly reduced below historical levels 

as a result of predation (not including human harvest), and reduction of predators would be 

reasonably expected to benefit prey abundance, active management may be authorized. We would 

also need to evaluate whether habitat conditions have been or would be a limiting factor on prey 

populations before implementing any active management to reduce predator populations. The 

Refuge would also coordinate with ADF&G to determine how a predator management program on 

the Refuge would affect current or future wildlife management plans in the region. The Refuge 

would consider the following questions, among others, to analyze a predator management proposal: 

 What roles do the subject predator and prey have in contributing to the natural 

diversity of the Refuge? Are human influences, including landscape level changes 

such as global warming, altering that diversity? Are there other refuge purposes 

to consider? 

 What are historical levels of predator and prey populations? Historic conditions are 

defined as the “composition, structure, and functioning of ecosystems resulting 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan C-3 
Appendix C: Predator Management 

C-4 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

from natural processes that... were present prior to substantial human related 

changes to the landscape.” In many parts of Alaska, we would expect less than 

100 years of information would be available for our analysis of historical levels. 

 Humans have been and still are a part of the living and functioning landscape. 

 Are habitat conditions significant in limiting prey abundance regardless of predator 

levels? Lack of cover, nutritional value of forage during key seasons, and abundance 

of trails favoring access by predators are examples of habitat conditions that could 

be significant for a season or a vulnerable prey age class. Assessing carrying 

capacity of a habitat is a daunting endeavor and may not be necessary. However, if a 

particular age and/or gender class of prey is considered most important to 

population recovery, habitat conditions affecting that age and/or gender class could 

be examined. 

 Does the Refuge provide habitat of regional, national, or international significance 

for threatened, endangered, or other species of concern? Would predator 

management help in recovering these populations? 

Requests received by the Service, from Regional Advisory Councils (RAC’s) and subsistence 

users, for predator management on refuges assert that predation has reduced prey populations to 

the extent that it is difficult for subsistence users to provide for the nutritional and cultural needs 

of themselves and their families. Some RACs contend that meaningful subsistence harvests of 

moose and caribou from refuge lands are not being provided, and therefore, the refuge purpose of 

providing for continued opportunities for subsistence uses justifies predator management. As 

previously stated, for a predator management program to be authorized on a refuge, it would need 

to be consistent with the conservation of predators and prey in their natural diversity. Predators 

will not intentionally be reduced below a level consistent with the low-end of natural population 

cycles. The Service would not reduce predator populations solely to provide larger populations of 

prey species for hunters. To assess the issue of human impact on prey populations, the Refuge 

will likely consider the following questions. 

 How does harvest by humans affect the prey population? Have levels of harvest, 

and their effects on the prey population, changed over time? Does this target 

specific age and/or gender classes to the detriment of the population? 

 Have reductions in harvest by humans been attempted? Did the prey population 

respond? 

 Have there been significant changes in local harvest of predators? 

2. Implementation: 

Once these determinations and assessments are completed and a predator management program 

is initiated, associated actions and efforts would be monitored and evaluated by the Service and 

adjustments made as appropriate to meet program objectives. If the Service were to authorize 

predator management programs on refuges, we would either conduct the effort ourselves or 

cooperate with the State or private citizens as our agents. In either case, the action would be 

considered a refuge management activity and not subject to a compatibility determination. 
Appendix D: Glossary 

Adequate snow cover Snow cover of a sufficient depth to protect underlying 

vegetation and soil (50 CFR 36.2); generally about six inches 

within the Innoko NWR. 

air taxi operator/transporter A person who transports people, equipment, supplies, 

harvested fish and wildlife, or other personal property by 

means of aircraft for compensation or with the intent or 

agreement to receive compensation; a transporter who 

provides commercial transportation services by means of 

aircraft. Must have a special use permit to operate on 

Innoko National Wildlife Refuge. 

allowed Activity, use, or facility is allowed under existing National 

Environmental Policy Act (NEPA) analysis, a specific 

compatibility determination, and compliance with all 

applicable laws and regulations of the U.S. Fish and Wildlife 

Service, other Federal agencies and the State of Alaska. 

not allowed Activity, use, or facility is not allowed. 

alternatives Different ways to resolve issues, achieve refuge purposes, 

meet refuge goals, and contribute to the National Wildlife 

Refuge System mission. Alternatives provide different 

options to respond to major issues identified during the 

planning process. 

no-action alternative In the context of a comprehensive conservation plan, the 

current management direction. With this alternative, no 

change from the current Comprehensive Conservation Plan 

would be implemented. 

preferred alternative A proposed action in the NEPA document for the 

Comprehensive Conservation Plan identifying the 

alternative that the Service believes best achieves planning 

unit purposes, vision, and goals; helps fulfill the National 

Wildlife Refuge System (System) mission; maintains and, 

where appropriate, restores the ecological integrity of each 

refuge and the System; addresses the significant issues and 

mandates; and is consistent with principles of sound fish and 

wildlife management. 

 

archaeological resource Any material remains of past human life or activities that 

are of interest to the scientific study of historic or 

prehistoric peoples and their cultures. Materials that are 

capable of providing an understanding of past human 

behavior, cultural adaptation, and related topics through the 

application of scholarly or scientific techniques. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan D-1 
Appendix D: Glossary 

authorized Activity, use, or facility allowed upon issuance of a specialuse permit or other authorization. 

base camp Serves as a center of operations and overnight 

accommodations for people working in a remote part of the 

refuge (e.g., refuge staff, guides, and clients). A temporary 

base camp usually remains in place for the full season of use 

but may be removed within 48 hours. It generally consists of 

larger tents than do primitive camps and often has tent 

platforms or other rigid floors. The primary distinction 

between temporary base camps and primitive camps is the 

period of occupancy. The specific details of a temporary 

base camp located on refuge lands would be spelled out in 

the refuge special-use permit. 

big-game guide A person who is licensed by the State of Alaska to provide 

services, equipment, or facilities to a big-game hunter in the 

field. A big-game guide accompanies or is present with, 

personally or through an assistant, the hunter in the field. 

Must have a special use permit to operate on Innoko 

National Wildlife Refuge. 

big-game outfitter A person who provides for compensation or with the intent 

to receive compensation, services, supplies, or facilities to a 

big-game hunter in the field. The outfitter does not 

accompany nor provide an assistant to the hunter in the 

field. Must have a special use permit to operate on Innoko 

National Wildlife Refuge. 

biological diversity The variety of life, including the variety of living organisms, 

the genetic differences among them, and the communities in 

which they occur (Service Manual 602 FW 1.6). 

biological integrity Biotic composition, structure, and functioning at the genetic, 

organism, and community levels consistent with natural 

conditions, including the natural biological processes that 

shape genomes, organisms, and communities (Service 

Manual 602 FW 1.6). 

campsite hardening Actions undertaken to increase the durability of a campsite 

through manipulation, such as placing gravel on a place to 

pitch a tent or trails within the campsite. Does not include 

facilities normally associated with campgrounds, including 

outhouses, picnic tables, etc. 

categorical exclusion A category of actions that do not individually or 

cumulatively have a significant effect on the human 

environment and have been found to have no such effect in 

D-2 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan
Appendix D: Glossary 

procedures adopted by a Federal agency pursuant to the 

National Environmental Policy Act (40 CFR 1508.4). 

commercial recreational uses Recreational uses of lands, waters, and resources for 

business or financial gain; includes guided recreational 

fishing, guided recreational hunting, other guided 

recreation, and air-taxi services. 

commercial visitor service Any service or activity made available for a fee, commission, 

brokerage, or other compensation to persons who visit a 

refuge, including such services as providing food, 

accommodations, transportation, tours, and guides. 

compatible use A proposed or existing wildlife-dependent recreational use or 

any other use of a refuge that, based on sound professional 

judgment, will not materially interfere with or detract from 

the fulfillment of the mission of the System or the purposes of 

the refuge (Service Manual 603 FW 2 2.6). 

compatibility determination A written determination, signed and dated by the refuge 

manager and the Service regional chief, signifying that a 

proposed or existing use of a national wildlife refuge is a 

compatible use or is not a compatible use. The director of 

the Service makes this delegation through the regional 

director (Service Manual 603 FW 2 2.6). 

consumptive use Use of a refuge resource that removes the resource from the 

refuge (e.g., killing an animal to eat, catching and keeping 

fish, harvesting berries or plants, or removal of mineral or 

other specimens). 

cultural resources Fragile, nonrenewable properties, including any district, 

site, building, structure, or object significant in American 

history, architecture, archaeology, engineering, or culture. 

These resources are significant for information they contain 

or the associations they have with past people, events, or life 

ways (Service Manual 614 FW 1.7). 

ecological integrity The integration of biological integrity, natural biological 

diversity, and environmental health; the replication of natural 

conditions (Service Manual 602 FW 1.6). 

ecoregion Delimits large areas within which local ecosystems recur 

more or less throughout the region in a predictable pattern. 

ecosystem A biological community functioning together with its 

environment as a unit. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan D-3
Appendix D: Glossary 

environmental assessment A concise public document that provides a sufficient analysis 

for determining whether to prepare an environmental 

impact statement (EIS) or a finding of no significant impact. 

It also aids an agency’s compliance with NEPA when no 

EIS is necessary (40 CFR 1508.9). 

environmental health Abiotic (the nonliving features of the environment including 

light, temperature, and atmosphere) composition, structure, 

and functioning of the environment consistent with natural 

conditions, including the natural abiotic processes that shape 

the environment (Service Manual 602 FW 1.6). 

environmental impact statement A detailed written statement required by section 102(2)(C) 

of the National Environmental Policy Act (NEPA) that 

analyzes the environmental impacts of a proposed action; 

adverse effects of the project that cannot be avoided; 

alternative courses of action, short-term uses of the 

environment versus the maintenance and enhancement of 

long-term productivity; and any irreversible and 

irretrievable commitment of resources (40 CFR 1508.11). 

goal A descriptive, open-ended, and often broad statement of desired 

future conditions that conveys purposes but does not define 

measurable units (Service Manual 620 FW 1.6). 

guide Any person who has a special-use permit to provide a 

commercial visitor service for hire on the refuge. This term 

does not generally apply to air-taxi operators who only 

provide transportation services. 

habitat The physical and biological resources required by an 

organism for its survival and reproduction; these 

requirements are species-specific. Food and cover are major 

components of habitat and must extend beyond the 

requirements of the individual to include a sufficient area 

capable of supporting a viable population. 

helicopter use for recreation 

access Use of helicopters for other than official government 

management activities, search and rescue, or other 

authorized activities. 

incidental uses Recreational or public uses of refuge lands, waters and/or 

resources that are secondary to, or of less importance than, 

the primary recreational use in which a visitor is 

participating. An incidental use may or may not support a 

primary use. 

D-4 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan
Appendix D: Glossary 

issue Any unsettled matter that requires a management decision 

(e.g., a Service initiative, opportunity, resource management 

problem, threat to the resources of the unit, conflict in uses, 

public concern, or the presence of an undesirable resource 

condition) (Service Manual 602 FW 1.6). 

“leave no trace” principles Principles of outdoor recreation designed to minimize 

effects on the natural environment and other visitors. These 

principles are: (1) plan ahead and prepare, (2) travel and 

camp on durable surfaces, (3) dispose of waste properly, (4) 

leave what you find, (5) minimize campfire impacts, (6) 

respect wildlife, and (7) be considerate of other visitors 

(http://www.lnt.org, accessed May 11, 2004). 

muskeg A bog in northern North America characterized by an 

abundance of Sphagnum (moss) and a sparse cover of 

shrubs and small trees such as black spruce. 

national wildlife refuge A designated area of land, water, or an interest in land or 

water within the System; does not include coordination 

areas. Find a complete listing of all units of the Refuge 

System in the current Annual Report of Lands Under 

Control of the U.S. Fish and Wildlife Service (Service 

Manual 601 FW 1.3). 

native species A species, subspecies, or distinct population that occurs 

within its natural range or natural zone of potential 

dispersal (i.e., the geographic area the species occupies 

naturally or would occupy in the absence of direct or 

indirect human activity or an environmental catastrophe). 

This definition recognizes that ecosystems and natural 

ranges are not static; they can and do evolve over time. Thus 

a species may naturally extend its range onto (or within) a 

refuge and still be considered native.

navigable waters Under Federal law, for the purpose of determining 

ownership of submerged lands beneath inland water bodies 

not reserved at the date of statehood, navigable waters are 

waters used or susceptible to being used in their ordinary 

condition as highways of commerce over which trade and 

travel are, or may be conducted, in the customary modes of 

trade and travel on water. In situations where navigability 

and the ownership of submerged lands are disputed, the 

final authority for determining navigability rests with the 

Federal courts. 

National Environmental Policy Act This act, promulgated in 1969, requires all Federal agencies 

to disclose the environmental effects of their actions, 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan D-5
Appendix D: Glossary 

incorporate environmental information, and use public 

participation in the planning and implementation of all 

actions. Federal agencies must integrate NEPA with other 

planning requirements and must prepare appropriate 

NEPA documents to facilitate better environmental 

decision-making (from 40 CFR 1500). The law also 

established the Council on Environmental Quality to 

implement the law and to monitor compliance with the law. 

non-consumptive uses Recreational activities (e.g., hiking, photography, and 

wildlife observation) that do not involve the taking or 

catching of fish, wildlife, or other natural resources. 

non-commercial recreational uses Recreational uses of lands, waters, and resources not for 

business or financial gain, including recreational fishing and 

hunting, boating and floating, camping, hiking, photography, 

and sightseeing. 

non-native species A species, subspecies, or distinct population that has been 

introduced by humans (intentionally or unintentionally) outside 

its natural range or natural zone of potential dispersal. 

objective A concise statement of what we want to achieve, how much 

we want to achieve it, when and where we want to achieve it, 

and who is responsible for the work. Objectives derive from 

goals and provide the basis for determining strategies, 

monitoring refuge accomplishments, and evaluating the 

success of strategies. (Service Manual 602 FW 1.6). 

ordinary high-water mark The line on the shore established by the fluctuations of 

water and indicated by physical characteristics such as a 

clear, natural line impressed on the bank, shelving, changes 

in the character of soil, destruction of terrestrial vegetation, 

the presence of litter and debris, or other appropriate 

means that consider the characteristics of the surrounding 

area (33 CFR 328.3[e]). 

primitive tent camps Portable camps, normally consisting of small tents, used by 

people remaining overnight in remote parts of the refuge 

(e.g., refuge staff, nonguided, and guided visitors). Such 

camps usually remain in place when in use and then are 

disassembled and removed. 

 

prospectus The document that the Service uses in soliciting competition 

to award permits for commercial visitor services on a refuge. 

public Individuals, organizations, and groups; officials of Federal, 

State, and local government agencies; Indian tribes; Native 

D-6 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan
Appendix D: Glossary 

organizations; and foreign nations. Public may include 

anyone outside the core planning team. It includes those 

who may or may not have indicated an interest in Service 

issues and those who do or do not realize that Service 

decisions may affect them. 

public involvement A process that offers affected and interested individuals 

and organizations opportunities to become informed about, 

and to express their opinions on, Service actions and 

policies. In the process, these public views are studied 

thoroughly and are thoughtfully considered in shaping 

decisions for refuge management. 

purposes of the refuge The purposes specified in or derived from the law, 

proclamation, executive order, agreement, public land order, 

donation document, or administrative memorandum 

establishing, authorizing, or expanding a refuge, refuge unit, 

or refuge subunit (Service Manual 602 FW 1.6). 

quality recreation program A quality recreation program: 

 promotes safety of participants, other visitors, 

and facilities; 

 promotes compliance with applicable laws and 

regulations and responsible behavior; 

 minimizes or eliminates conflict with fish and 

wildlife population or habitat goals or objectives 

in an approved plan; 

 minimize or eliminates conflicts with other 

compatible wildlife-dependent recreation; 

 minimizes conflicts with neighboring landowners; 

 promotes accessibility and availability to a broad 

spectrum of the American people; 

 promotes resource stewardship and conservation; 

 promotes public understanding and increases 

public appreciation of America's natural 

resources and our role in managing and 

conserving these resources; 

 provides reliable/reasonable opportunities to 

experience wildlife; 

 uses facilities that are accessible to people and 

blend into the natural setting; and 

 uses visitor satisfaction to help define and 

evaluate programs (Service Manual 605 FW 1.6). 

recreation guide A commercial operator who accompanies clients on the refuge 

for photography, sightseeing, or other activities not related to 

hunting or fishing, for either day or overnight trips. Must 

have a special use permit to operate on the refuge. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan D-7
Appendix D: Glossary 

recreational fishing Taking or attempting to take for personal use, not for sale 

or barter, any fish by hook and line held in the hand or 

attached to a pole or rod that is held in the hand or is 

closely attended. 

recreational hunting Taking or attempting to take for personal use, not for sale 

or barter, a game animal (as defined by the regulatory 

agency) by any means allowed by the regulatory agency. 

recreational fishing or 

hunting guide A commercial operator who accompanies recreational 

fishing or hunting clients on the refuge for day or 

overnight trips. Must have a special use permit to operate 

on the refuge. 

scoping An early and open process with the public for determining 

the range of issues and the significant issues related to a 

proposed action (40 CFR 1501.7). 

special use permit A U.S. Fish and Wildlife Service authorization required for 

all commercial uses of refuge lands and waters. The Innoko 

National Wildlife Refuge Manager is responsible for issuing 

permits on the refuge. 

spike camp A temporary camp of a primitive nature set up by a guide or 

outfitter to provide overnight accommodations away from 

base camp. 

step-down management plan A plan that provides specific guidance on management 

subjects (e.g., habitat, public use, fire, safety) or groups of 

related subjects. It describes strategies and implementation 

schedules for meeting comprehensive conservation plan 

goals and objectives. 

subsistence uses The customary and traditional uses by rural Alaska 

residents of wild, renewable resources for direct personal or 

family consumption as food, shelter, fuel, clothing, tools, or 

transportation; for the making and selling of handicraft 

articles out of nonedible byproducts of fish and wildlife 

resources taken for personal or family consumption; for 

barter or sharing for personal or family consumption; and 

for customary trade (from section 803 of the Alaska 

National Interest Lands Conservation Act). 

unguided visitor A visitor who arranges, organizes and conducts his or her 

own trip without the assistance of a guide. 

D-8 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan
Appendix D: Glossary 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan D-9

use day A period of one calendar day (24 hours), or portion thereof, 

for each entity using a resource. When employed as a 

measure of human use, it is called a visitor use day, or client 

use day. 

vision statement A concise statement of the desired future condition of the 

planning unit, based primarily on the System mission, 

specific refuge purposes, and other relevant mandates 

(Service Manual 602 FW 1.6). 

wilderness An area essentially undisturbed by human activity, together 

with its natural ecosystem. 

 

wildlife-dependent recreation A use of a refuge involving hunting, fishing, wildlife 

observation and photography, or environmental education 

and interpretation. These are the six priority public uses of 

the Refuge System, as established in the National Wildlife 

Refuge System Administration Act, as amended. Wildlifedependent recreational uses, other than the six priority public 

uses, are those that depend on the presence of wildlife.
Appendix E: Yukon-Innoko Moose Management Plan 

1. Yukon-Innoko Moose Management Plan 

1.1 Mission 

Maintain healthy and abundant moose populations by proactively managing moose, predation and 

habitat and keeping moose harvest within sustained yield so that subsistence needs for moose are 

met on an annual basis and there is sufficient moose to provide for personal and family use of 

Alaska residents and some nonresident hunting opportunity for generations to come. 

1.2 Executive Summary 

The Yukon-Innoko Moose Management Plan (YIMMP) is intended to establish a proactive 

management program that will help to maintain an abundant moose population to provide for high 

levels of human consumptive uses. This approach is designed to help prevent a decline in the 

moose population to a low level that would be very difficult to reverse. The YIMMP is a 

comprehensive management plan. The plan includes recommendations to manage moose harvest 

conservatively, maintain moose habitat, to provide public information and education materials and 

to increase harvest of black bears, grizzly bears and wolves through hunting and trapping. 

The plan was developed through a cooperative effort involving a citizens’ advisory group called the 

Yukon-Innoko Moose Management Working Group (YIWG or Working Group) State and federal 

agency staff participated in the project as technical advisors. The Working Group includes 

representatives of the Grayling-Anvik-Shageluk-Holy Cross (GASH) and Lower Yukon Fish and 

Game Advisory Committees, the Western Interior and Yukon-Kuskokwim Delta Regional Advisory 

Councils, non-local hunters and representatives of commercial interests in hunting the region. 

Initially the planning effort was focused only on Unit 21E. Members of the Working Group noted 

that moose hunting that takes place in the Innoko River drainage in Unit 21A has a significant 

influence on moose management in Unit 21E. Based on the groups’ recommendation, the Innoko 

River drainage in Unit 21A is included in this plan. 

For several years prior to the planning process local residents and hunters reported observing a 

decline in the moose population in Game Management Unit 21E. In January 2003 the GASH 

Advisory Committee (AC) voted against reauthorizing the state winter antlerless moose hunt in 

Unit 21E to limit harvest of cow moose. This initial proactive action helped to maintain 

productivity of the moose population and may have prevented a significant decline. 

At the first planning meeting held in January 2005 the Working Group reviewed data from a 

February 2000 moose population estimation survey and identified the need for a new survey to 

provide a better basis for developing recommendations. The Alaska Department of Fish and 

Game (ADF&G or department) worked in cooperation with the U.S. Fish and Wildlife Service, 

Bureau of Land Management, Tanana Chiefs Conference, and the Association of Village Council 

Presidents and completed a new moose population estimation survey in Unit 21E in March 2005. 

The survey indicated the moose population is relatively stable but may have declined somewhat 

since the previous survey that was conducted in March 2000. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan E-1 
Appendix E: Yukon-Innoko Moose Management Plan 

E-2 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

The March 2005 moose population estimate and population modeling later conducted by ADF&G 

biologists indicated that, in order to prevent a decline in the population, harvest should be kept 

within 4% or less of the total moose population, and that only minimal cow harvest can be 

sustained. The current estimated annual harvest is near the upper end of the harvestable surplus. 

At the final meeting held in November 2005, the Working Group discussed how close the current 

level of harvest is to the maximum sustainable harvest. The group noted that a decline in the 

moose population would likely result in the need for more significant reductions in harvest, 

including the possibility of further action to reduce Alaska resident harvest. At this point, 

members of the Working Group who were present agreed to recommend reducing the nonresident 

season by 5 days and implementing a drawing permit system to prevent an increase in 

nonresident hunting at the current moose population level. 

Based on this situation, the Working Group felt compelled to recommend intensive management 

of moose in Unit 21E, including pursuing adoption of a wolf predation control implementation 

plan. Department staff advised the Working Group that the resources available to implement 

predation control programs are limited and that supporting the predation control programs that 

are already in place would be given priority. 

In March 2006 the Board of Game (board) endorsed the YIMMP and adopted the regulatory 

proposals recommended by the Working Group, with a few minor modifications. In May 2006 the 

YIMMP was endorsed by the Federal Subsistence Board. (The endorsements by the Board of 

Game and Federal Subsistence Board are provided in Appendix A of the moose management plan.) 

In their endorsement of the plan the board requested the department develop a plan for Intensive 

Management (IM) of moose in Unit 21E. The department will work with the GASH AC and 

others to prepare a plan that considers all options for Intensive Management in Unit 21E. The 

plan will be submitted for consideration by the board at the next interior Alaska meeting 

scheduled for March 2008. At that time the department will have to re-evaluate resources 

available and priorities for IM programs and advise the GASH AC and board whether the 

department will be able to develop and effectively implement a wolf predation control program or 

other options for IM in Unit 21E. 
Appendix F: Compatibility Determinations 

Compatibility Determinations 

Subsistence Activities ............................................................................................................................... F-3

Wildlife Observation, Wildlife Photography, Environmental Education, and Interpretation....... F-8

Recreational Hunting.............................................................................................................................. F-12

Recreational Fishing............................................................................................................................... F-17

Non-Wildlife-Dependent Recreational Activities ............................................................................... F-22

Trapping ................................................................................................................................................... F-25

Snowmobiling........................................................................................................................................... F-29

Temporary Camps................................................................................................................................... F-33

Subsistence Harvest of House Logs..................................................................................................... F-39

Scientific Research.................................................................................................................................. F-46

Helicopter Landings to Support Authorized Activities by Other Federal, Tribal, State, 

and Local Governments, Universities, etc. ................................................................................... F-53

Commercial Transporter Services........................................................................................................ F-59

Commercial Big Game Hunting Guide Services ................................................................................. F-67

Commercial Recreational Fishing Guide Services ............................................................................. F-76

Commercial Recreational Guide Services............................................................................................ F-83

State of Alaska Management Activities ............................................................................................... F-90

Reburial of Archaeological Human Remains per State and Federal Guidelines ........................... F-94

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-1 
Appendix F: Compatibility Determinations 

F-2 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: Subsistence Activities 

Primary Uses: Fishing, natural resource gathering, hunting, trapping, and subsistence (other). 

Supporting and Incidental Uses: Boating (motorized and non-motorized), snowmobiling, 

snowshoeing, trapping, firewood cutting, natural resource gathering, camping, cross-country 

skiing, dog sledding and skijoring, hiking and backpacking, picnicking, wildlife photography and 

videography, pets, wildlife observation, fixed-wing aircraft landings, swimming and beach use. 

Refuge Name: Innoko National Wildlife Refuge 

Establishment and Acquisition Authority: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents, and; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C. 668dd-668ee]). 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-3 
Appendix F: Compatibility Determinations 

Description of Uses: 

This is a re-evaluation of the compatibility of subsistence uses of Federal lands within Innoko 

Refuge. Subsistence was originally found to be a compatible use during the development of the 

Refuge Comprehensive Conservation Plan in 1987. Subsistence was again determined to be 

compatible, subject to reasonable regulation, in 1992. Subsistence activities addressed in this 

determination include hunting, fishing, trapping, firewood gathering, berry picking, and gathering 

of other plant materials. Consumptive uses of fish and game are generally regulated by State 

regulations (5AAC), or Federal subsistence regulations 50 CFR Part 100. Gathering of plant 

materials, including firewood, on the refuge, is regulated by 50 CFR Part 36. Snowmobiles and 

motorboats are the primary means of surface transportation traditionally employed for such 

purposes, as allowed under ANILCA section 811 and refuge regulations (50 CFR 36). Subsistence 

has also been historically supported by the occasional use of airplanes for access to remote 

locations surrounding some communities. 

Residents of Grayling, Anvik, Shageluk, Holy Cross, Kaltag and Takotna, located just outside of 

the refuge, have lifestyles and economies that depend on subsistence resources, including 

resources within the refuge. Subsistence activities are not just a way of obtaining food, but an 

important mechanism for maintaining cultural values such as kinship, community, respect for 

elders, hospitality, sharing resources, and the passing of values to younger generations. In 

addition, many residents in the area simply prefer the taste of traditional wild foods to that of 

commercially purchased foods. Mainstay subsistence foods for residents near Innoko Refuge are 

fish and moose. Waterfowl, black bear and small game--including grouse and snowshoe hare, 

beaver and furbearers--are at times important to local residents for food, fur, and traditional 

crafts. Berries and other plant materials such as firewood, house logs, and birch bark are also 

frequently gathered. Compatibility of gathering house logs for subsistence is evaluated under a 

separate determination. A detailed description of subsistence uses and harvest can be found in 

chapter 3 of the Innoko Refuge Revised Comprehensive Conservation Plan. 

Trappers operate within the refuge, harvesting marten, lynx, fox, wolves, beaver, river otter, and 

other small furbearers. The sale of these furs provides supplemental income to residents depending 

on a subsistence lifestyle. Trapping is also considered a subsistence activity, but the compatibility of 

trapping as a refuge use is considered elsewhere in this plan under a separate determination. 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage subsistence 

activities at existing and projected levels. Management primarily includes the inventory and 

monitoring of fish and wildlife subsistence species; surveys of public use and subsistence harvest 

in local communities; environmental education, such as steel shot clinics or other efforts aimed at 

improving public understanding of major conservation issues; and law enforcement patrols. 

During such patrols, refuge staff members opportunistically conduct outreach to increase 

subsistence user awareness of the status of local fish and wildlife populations, the relationship of 

regulations to sustainable yield, and the importance of knowing land ownership and regulatory 

boundaries when subsistence activities take place. Refuge staff members spend considerable time 

participating in and supporting the regulatory development process with the Federal Subsistence 

Board (FSB) and Alaska Boards of Fisheries and Game to ensure that harvest levels are 

sustainable. The refuge currently allocates over 10 percent of its budget towards managing 

F-4 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

subsistence resources and subsistence activities because it constitutes the primary public use of 

Innoko Refuge. 

Anticipated Impacts of the Uses: 

Fish and wildlife harvested by subsistence users at current and projected levels—in accordance with 

established State and Federal regulations pertaining to season, bag limits, and methods of harvest—

are not expected to have long-term impacts on the overall populations of fish and wildlife resources 

within the refuge. State and Federal biologists monitor fish and game populations, and State and 

Federal regulatory bodies continually respond to management needs by adopting regulations to 

ensure the continued health of fish and wildlife populations. The combination of Alaska State 

Hunting Regulations (5AAC) and the Federal Subsistence Regulations (50 CFR Part 100) are 

intended to provide a sustainable harvest over the long term. It is possible that localized or shortterm population reductions may occur due to unanticipated changes in physical condition of animals, 

environmental conditions, distribution, predation, and harvest pressure. Refuge staff will continue to 

monitor populations to avoid depletion of fish and wildlife resources by over harvesting. 

Impacts to resources from berry picking, firewood gathering, and other plant harvesting activities, 

at low intensity, are relatively insignificant. Impacts to habitat caused by aircraft, boats, and foot 

travel are generally minimal, but increased use could cause disturbance to wildlife and increased 

pressures on wildlife. Much of the access by subsistence users is by boat or snowmobile (in winter 

during adequate snow cover). Refuge staff members have observed that to date these activities 

have caused very little impact to habitats. The introduction of invasive plant species, perhaps 

from seeds carried on boats, snowmobiles, or dog mushing equipment, could affect refuge 

resources. Although invasive plants are not known to have been introduced by this method, there 

are a limited number of invasive species on Innoko Refuge. The refuge staff will be vigilant to 

prevent such introductions. Refuge staff will monitor subsistence use levels to determine if 

changes in conditions or intensity have the potential to impact refuge resources. 

If snowmobile or motorboat use on Innoko Refuge was to increase substantially, disturbance to 

important subsistence species, including moose, could occur (McTaggart-Cowan 1981, Creel et al. 

2002). Denning bears are most susceptible to snowmobile disturbance. Actions by ill-advised or 

uninformed snowmobile users could cause bears to abandon dens and harm newborn cubs 

incapable of travel (Jonkel 1980) Noise disturbance could also affect moose energy budgets, 

reproductive success, and long-term survival (Calef et al. 1976, Olliff et al. 1999). 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the Refuge’s Comprehensive 

Conservation Plan. The State of Alaska commented that the stipulations necessary to ensure 

compatibility for recreational hunting should be consistent with those for subsistence activities. 

We changed the stipulations to be more consistent among the compatibility determinations. 

Refuge Determination (check one below): 

_____Use is not compatible 

 X Use is compatible 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-5 
Appendix F: Compatibility Determinations 

Stipulations Necessary to Ensure Compatibility: 

Subsistence users will be required to comply with any regulations in place, such as seasonal 

closures for resource protection. 

Management direction provided in the revised Innoko Refuge Comprehensive Conservation Plan 

requires monitoring of subsistence use. To minimize impacts on lands and resources within the 

refuge, law enforcement patrols will be routinely conducted to maximize compliance with the 

existing policies, rules, and regulations. Should problems be detected through monitoring, 

appropriate management actions would be undertaken. 

Justification: 

One of the purposes of Innoko Refuge is to provide for continued subsistence uses by local 

residents, consistent with the other refuge purposes of conserving fish and wildlife populations 

and habitats in their natural diversity and fulfilling international treaty obligations with respect to 

fish and wildlife. ANILCA recognized that the continued opportunity for subsistence uses of 

public lands is critical to the physical, economic, traditional, social, and cultural existence of rural 

residents of Alaska. ANILCA established a preference for subsistence users, stating that the 

taking of fish and wildlife on public lands for nonwasteful subsistence use is given priority over 

other consumptive uses. In times of scarcity, recreational use is limited first. Section 811 of 

ANILCA ensures that subsistence users can access public lands by snowmobile, motorboat, and 

other traditionally used means of surface transportation, subject to reasonable regulation. After 

fully considering the impacts of this activity, as described previously in the “Anticipated Impacts 

of the Uses” section of this determination, it is my determination that subsistence activities within 

the refuge do not materially interfere with or detract from the purposes of the refuge or mission of 

the National Wildlife Refuge System. 

Supporting Documents: 

Brown, C., J. Burr, K. Elkin, K. and R.J. Walker, .2005. Contemporary Subsistence Uses and 

Population Distribution of Non-Salmon Fish in Grayling, Anvik, Shageluk, and Holy Cross, Alaska. 

Division of Subsistence Technical Paper no. 289. Alaska Dept. of Fish and Game, Anchorage, AK. 

Calef, G.W., E.A. DeBock, and G.M. Lortie. 1976. The reaction of barren-ground caribou to 

aircraft. Arctic 29(4):201-212. 

Creel, S., J.E. Fox, A. Hardy, J. Sands, B. Garrott, and R.O. Peterson. 2002. Snowmachine 

activity and glucocorticoid stress responses in wolves and elk. Conservation Biology 16:809-814. 

Jonkel, C. J. 1980. Black, brown, and polar bears. Pages 227–228 in Big game of North 

America: ecology and management. J. L. Schmidt and D.L. Gilbert, eds. Harrisburg, 

Pennsylvania: Stackpole Books. 

McTaggart-Cowan, I. 1981. Wildlife conservation issues in northern Canada. Canadian 

Environmental Advisory Council report, no. 11. University of Calgary, Canada. 

Olliff, T., K. Legg, and B. Kaeding, editors. 1999. Effects of winter recreation on wildlife of the 

Greater Yellowstone area: a literature review and assessment. Report to the Greater Yellowstone 

Coordinating Committee. Yellowstone National Park, Wyoming. 315 pages. 

F-6 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-7 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service. Anchorage, AK. 

U.S. Fish and Wildlife Service. 1992. Subsistence Management for Federal public Lands in 

Alaska, Final Environmental Impact Statement, Record of Decision, April 2, 1992. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: ___/s/ Kent A. Sundseth, acting_________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: _/s/ Todd J. Logan__________________ December 18, 2008

 (Signature) (Date) 

Mandatory 15-year Re-Evaluation Date (for priority public uses): 2023

__________Categorical Exclusion without Environmental Action Memorandum 

__________Categorical Exclusions and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

__________Environmental Impact Statement and Record of Decision 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Uses: Wildlife Observation, Wildlife Photography, Environmental Education, and Interpretation 

Primary Uses: Environmental education (education of teachers, group leaders, or students), 

interpretation, wildlife photography and videography, wildlife observation. 

Supporting and Incidental Uses: Boating (motorized and non-motorized), fixed-wing aircraft 

landings, fishing, hunting, trapping, natural resource gathering, camping, cross-country skiing, 

dog sledding and skijoring, snowmobiling, hiking and backpacking, firewood cutting, picnicking, 

pets, snowshoeing, swimming and beach use. 

Refuge Name: Innoko National Wildlife Refuge 

Establishing and Acquisition Authority: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within the 

refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

F-8 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C.668dd-668ee]). 

Description of Uses: 

This determination re-evaluates the following wildlife-dependent activities: wildlife observation, 

wildlife photography and videography, environmental education, and interpretation. These uses 

were found to be compatible under the original Refuge Comprehensive Conservation Plan in 1987 

and were again determined to be compatible in 1992. While some visitors come to the refuge 

specifically to engage in one or more of these non-consumptive activities, many visitors also 

include these activities as part of a refuge hunting or fishing trip. Compatibility of hunting and 

fishing is evaluated separately. Associated activities such as camping, backpacking, hiking, 

boating, and other incidental uses are considered part of these wildlife-dependent activities for the 

purposes of this evaluation. Of these priority public uses, wildlife observation and photography 

are by far the most widespread. 

Interpretive and educational efforts occur primarily in the communities of McGrath, Grayling, 

Anvik, Shageluk, Holy Cross, and Tokotna rather than on the refuge because of the lack of 

developed visitor facilities and difficult access to the refuge. Limited, informal interpretive and 

environmental education services are provided during contacts with visitors on the refuge by staff 

on routine patrol. No formal environmental education or interpretive programs are regularly 

conducted on the refuge, nor are any formal on-site programs planned under the revised 

Comprehensive Conservation Plan. 

Visitors take advantage of opportunities to view and photograph wildlife, plants, and landscapes 

within the refuge. Most of these activities predate the establishment of the refuge in 1980. 

Recreational settings on the refuge are remote. Typical forms of access for all areas of the refuge 

include fixed-wing airplanes, motorboats, non-motorized boats, hiking, snowshoeing, snowmobiles, 

cross-country skiing, and other non-motorized means. However, most non-local visitors access the 

refuge by commercial air taxis from McGrath, Galena, or Aniak. Private boats and airplanes are 

the most common means of access for local visitors or the relatively few visitors not using 

commercial transporters. Day trips to the refuge are uncommon for visitors interested in wildlife 

observation, wildlife photography, and sightseeing but do occasionally occur. Camping on the 

refuge usually extends for periods of several days and is often associated with hunting activities. 

Campers use tents ranging from small backpacking tents to larger multi-person tents. 

People can visit the refuge year-round, but most come to hunt, fish, or conduct subsistence 

activities during the warmer months. Use is concentrated in areas that are accessible to rivers or 

larger lakes. These areas generally provide reliable opportunities for wildlife observation, 

especially along major rivers, including the Yukon, Innoko, Iditarod, Mud, and Dishna rivers. 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage these wildlifedependent recreational activities. Administrative staff time primarily involves phone 

conversations, written correspondence, public use surveys, and interaction with visitors at the 

visitor center. Staff will also be involved with any subsequent step-down planning (public use 

management) and recreational monitoring. Field work associated with administering this use 

primarily involves conducting patrols to increase visitor compliance with State and Federal 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-9 
Appendix F: Compatibility Determinations 

regulations. Refuge staff members opportunistically conduct outreach to visitors to minimize the 

impacts of camping and to improve understanding of local residents’ subsistence activities and 

awareness of private inholdings and property. Outreach efforts at local villages emphasize “leave 

no trace” camping and hiking practices. 

For commercial videography, administrative staff time would primarily involve issuing permits 

and recording activity data. Field work associated with administering the program would 

primarily involve monitoring permittees’ compliance with the terms of the permits. Estimated 

staff time to annually administer and monitor these permits is less than one week. 

Anticipated Impacts of the Uses: 

Adverse impacts to refuge wildlife and habitats associated with these priority public uses and 

associated uses were evaluated in the Environmental Assessment for the Draft Revised Innoko 

Refuge Comprehensive Conservation Plan. Negligible impacts to habitats within the refuge from 

disturbance are anticipated. Possible localized adverse impacts to some plant and wildlife species 

could occur, but the proposed plan would not have any long-term population-level impacts on 

refuge plants and wildlife. The introduction of invasive plant species, perhaps from seeds carried 

on boats, airplane floats, snowmobiles, or dog sleds could affect refuge resources. To date, limited 

invasive species introduction known to have occurred on the Innoko Refuge. Refuge staff will be 

vigilant to prevent such introductions. Positive effects on the local economy, though small, are 

anticipated from these uses. 

Public Review and Comment: 

Public comment was solicited concurrently with public review of the draft revised comprehensive 

conservation plan. No comments were received on this compatibility determination. 

Refuge Determination (check one below): 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

Visitors will be required to comply with any regulations in place, such as seasonal closures for 

resource protection. 

Permits are required for all commercial videography, including filming of documentaries, 

travelogues, feature stories, and advertising. Liability insurance and bonding may be required, 

depending on the specific production activities proposed. Additionally, a $100 fee may be required. 

News gathering organizations are exempt from fee, insurance, and bonding requirements but may 

be required to obtain a special use permit to ensure compatibility with refuge purposes, avoid conflict 

with established public use or research; or to protect refuge resources. 

Justification: 

All refuge lands in the Innoko Refuge are open to public access unless specifically closed. The 

proposed uses represent four of the six priority public uses identified in the National Wildlife 

Refuge Administration Act (as amended). The law calls for the Service to ensure that 

opportunities are provided for these uses and requires that they receive enhanced consideration 

over other public uses in planning and management. Innoko Refuge provides ample opportunity to 

F-10 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

those seeking to view and photograph wildlife, and provides interpretive and educational 

experiences in nearby communities. The current and projected amount of these activities has 

been found to have insignificant adverse physical and biological effects in the draft refuge 

comprehensive conservation plan. After fully considering the impacts of these activities, as 

described previously in the “Anticipated Impacts of the Uses” section of this determination, it is 

my determination that wildlife observation, wildlife photography, environmental education, and 

interpretation activities within the refuge do not materially interfere with or detract from the 

purposes of the refuge or mission of the National Wildlife Refuge System. 

Supporting Documents: 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service. Anchorage, AK. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: ___/s/ Kent A. Sundseth, acting_________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: _/s/ Todd J. Logan_________________ December 19, 2008

 (Signature) (Date) 

Mandatory 15-Year Re-evaluation Date (for priority public uses): 2023. 

NEPA Compliance for Refuge Use Decision: 

__________Categorical Exclusion without Environmental Action Memorandum 

__________Categorical Exclusions and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

__________Environmental Impact Statement and Record of Decision 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-11 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: Recreational Hunting 

Primary Use: Hunting (big game, waterfowl, other migratory birds, and upland game). 

Supporting and Incidental Uses: Boating (motorized and non-motorized), fixed-wing aircraft 

landings, fishing, trapping, natural resource gathering, camping, firewood cutting, dog training, 

snowmobiling, hiking and backpacking, pets, wildlife photography, videography and audio 

recording, swimming and beach use, wildlife observation. 

Refuge Name: Innoko National Wildlife Refuge 

Establishing and Acquisition Authority: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C.668dd-668ee]). 

F-12 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Description of Use: 

Recreational hunting is re-evaluated in this determination. Recreational hunting was found to be 

compatible in the original Refuge Comprehensive Conservation Plan (1987) and was again 

determined to be compatible in 1992. Associated activities such as camping, backpacking, hiking, and 

other incidental uses are considered part of recreational hunting. The majority of recreational 

hunting has been for moose, but hunting for black bear, grizzly bear, wolf, small game and waterfowl 

also occurs on the refuge, usually as part of a moose hunt, as allowed under State of Alaska hunting 

regulations (5 AAC). Small game and waterfowl hunting often occurs in conjunction with big game 

hunts and fall fishing excursions. Recreation settings on the refuge are remote. The number of 

recreational use days for small game and waterfowl hunting on the refuge is unknown but thought to 

be minimal. In recent years, refuge staff members were aware of an annual range of 30-45 parties of 

recreational moose hunters using Innoko Refuge. Current means of access to the refuge include 

fixed-wing aircraft, motorboats, snowmobiles and non-motorized means. Levels of recreational 

hunting are estimated primarily from direct observation by refuge staff, annual reports provided by 

air-taxi operators who transport most recreational hunters to locations within the refuge, and 

information from State harvest tickets. Permitted air-taxi operators provide visitor information, 

including primary activity, location, length of stay, and group size. 

Most of Innoko Refuge is located within State of Alaska Game Management Unit (GMU) 21A, 

although a small part is within GMU 21E and 21D. Moose black and brown bear are the primary 

species sought after by hunters, but wolves and wolverine may be taken incidentally on Innoko 

Refuge. The Paradise Controlled Use Area (PCUA), which includes the southwestern portions of 

the refuge, was established by the State of Alaska in 1981. The PCUA restricts aircraft access for 

the transport of moose hunters, gear, or moose parts. (However, moose hunters, their gear, 

and/or moose parts may be transported by aircraft between publicly owned airports in the 

controlled use area or between a publicly owned airport within the area and points outside the 

area.) The PCUA is bounded by a line beginning at the old village of Paimiut, then north along the 

west bank of the Yukon River to Paradise, then northeast to the mouth of the Anvik River, then 

along the west bank of the Yukon River to the lower end of Eagle Island (approximately 45 miles 

north of Grayling), then to the mouth of the Iditarod River, then down the east bank of the Innoko 

River to its confluence with Paimiut Slough, then south along the east bank of Paimiut Slough to 

its mouth, and then to the old village of Paimiut. State of Alaska hunting regulations (5AAC) 

describe State seasons, bag limits, and regulations pertaining to hunting, fishing, and trapping. 

 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage recreational 

hunting activities at existing and projected levels. Administrative staff time primarily involves 

phone conversations and written correspondence to answer questions from hunters, attendance at 

regulatory meetings, and engagement in the regulatory review process. Field work associated 

with administering the program primarily involves conducting law enforcement patrols to ensure 

recreational hunter compliance with State and Federal refuge regulations. Refuge staff members 

opportunistically conduct outreach to hunters to increase their awareness of national wildlife 

refuge programs, the status of local wildlife populations, the relationship of regulations to 

sustainable yield, and the importance of knowing land ownership and regulatory boundaries in 

locations where hunting activities are to take place. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-13 
Appendix F: Compatibility Determinations 

Anticipated Impacts of the Use: 

The refuge is directly involved in review and implementation of the regulatory process and 

administrative oversight of the activity. Because of combined regulatory and law enforcement 

efforts of the State and refuge personnel, direct impacts from recreational hunting under existing 

management should have minimal impacts to fish and wildlife resources, other resources, or other 

refuge users. 

Moose hunting locations outside of the PCUA are concentrated in narrow river corridors along the 

many rivers and sloughs within the Innoko Refuge. Recreational hunters may, in some cases, 

compete with subsistence users for the limited number of game animals in these corridors. Air 

taxi operators are discouraged from dropping hunters in areas used by subsistence hunters. Most 

subsistence hunting occurs in areas of the refuge where refuge and private lands are intermingled. 

 Boundaries of private lands can be difficult to distinguish, and inadvertent trespass could occur 

because non-local hunters would not be aware of the mixed ownership. Refuge staff members are 

aware of these potential conflicts and monitor use levels each hunting season. Should conflicts 

arise, the Service will work to address them through the Federal Subsistence Board and Alaska 

Board of Game. These boards have established regulations aimed at managing populations of 

animals at sustainable levels and preventing conflicts among user groups. 

Impacts to refuge habitats are considered minimal because access is primarily by boat or plane, 

with planes landing on lakes and rivers with floats. Disturbance to vegetation is minimal and 

short-term and would likely be restricted to campsites that receive repetitive use. Temporary 

displacement and or disturbance to wildlife can occur with any form of motorized transport 

(Bouffard 1982, Calef et al. 1976, Miller 1994, Ward et al. 1994). A large increase in recreational 

hunting on the refuge could cause user conflicts, wildlife disturbance, and in some cases, 

undermine the wild character of the refuge. The introduction of invasive plant species carried on 

boats or aircraft floats could affect refuge resources. Limited introductions have occurred on 

Innoko Refuge to date and staff will be vigilant to prevent such occurrences. 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the Refuge’s Comprehensive 

Conservation Plan. The State of Alaska commented that the stipulations necessary to ensure 

compatibility for recreational hunting should be consistent with those for subsistence activities. 

We changed the stipulations for subsistence activities to be more consistent with the stipulations 

for recreational hunting. We made no changes to this compatibility determination. 

Refuge Determination (check one below): 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

Visitors will be required to comply with any regulations in place, such as seasonal closures for 

resource protection. 

Management direction provided in the revised Innoko Refuge Comprehensive Conservation Plan 

requires adequate monitoring of visitor use, including recreational hunting. To minimize impacts 

F-14 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

on lands and resources within the refuge, law enforcement patrols will be routinely conducted to 

maximize compliance with the existing policies, rules, and regulations. Should problems be 

detected through monitoring, appropriate management actions would be undertaken . 

Justification: 

All lands in the Innoko Refuge are open to public access with some exceptions: the Paradise 

Controlled Use Area (restrictions for moose hunting only) and private inholdings. The National 

Wildlife Refuge System Administration Act of 1966 (as amended by the Refuge Improvement Act 

of 1997) identifies recreational hunting as one of six priority public uses of national wildlife refuge 

system lands. The law states that, “when managed in accordance with principles of sound fish and 

wildlife management, administration of this use has been and is expected to continue to be 

generally compatible and that priority public uses should receive enhanced consideration over 

other general public uses in refuge planning and management.” The law also states that the 

Service should provide increased opportunities for families to experience compatible wildlifedependent recreation, particularly opportunities for parents and their children to safely engage in 

traditional outdoor activities such as hunting. 

Means of access by airplanes, motorboats, and non-motorized means for traditional activities, as 

provided by ANILCA and as currently regulated by the Service, have not materially interfered 

with or detracted from refuge purposes. Should motorized transportation grow to levels where it 

interferes with refuge purposes, staff would work with hunters and the State of Alaska to address 

impacts and resolve compatibility concerns. Recreational hunting is an activity that Congress 

intended to preserve when the refuge was established by ANILCA. As stated previously, 

recreational hunting on the refuge provides the public with quality, safe, and unique hunting 

opportunities found few places elsewhere in the world. To ensure sustainability of harvest of 

wildlife resources and to provide the continued opportunity for subsistence uses of these species 

by local residents, both the Federal Subsistence Board and State Board of Game regularly adopt 

regulations in response to wildlife population levels and management needs. These regulations 

provide adequate protection for the refuge’s wildlife resources, continued hunting opportunities, 

and other refuge purposes. After fully considering the impacts of these activities, as described 

previously in the “Anticipated Impacts of the Use” section of this determination, it is my 

determination that recreational hunting within the refuge does not materially interfere with or 

detract from the purposes of the refuge or mission of the National Wildlife Refuge System. 

Supporting Documents: 

Alaska Department of Fish and Game. 2006. Alaska hunting regulations effective dates July 1, 

2006–June 30, 2007, governing general, subsistence, and commercial uses of Alaska’s wildlife. 

Juneau, AK. Viewed December, 2006 at www.state.ak.us/adfg/wildlife/wildmain.htm. 

Bouffard, S. 1982. Wildlife values versus human recreation: Ruby Lake National Wildlife Refuge. 

Transactions of the North American Wildlife and Natural Resources Conference 47:553-558. 

Calef, G.W., E.A. DeBock, and G.M. Lortie. 1976. The reaction of barren-ground caribou to 

aircraft. Arctic 29(4):201-212. 

Miller, M. W. 1994. Route selection to minimize helicopter disturbance of molting Pacific black 

brant: a simulation. Arctic 47: 341–349. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-15 
Appendix F: Compatibility Determinations 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service. Anchorage, AK. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Ward, D. H., R. A. Stehn, D. V. Derksen. 1994. Response of staging brant to disturbance at the 

Izembek Lagoon, Alaska. Wildl. Soc. Bull. 22: 220–228. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: ___/s/ Kent A. Sundseth, acting_________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: _/s/ Todd J. Logan_________________ December 19, 2008

 (Signature) (Date) 

Mandatory 15-Year Re-evaluation Date (for priority public uses): 2023

NEPA Compliance for Refuge Use Decision: 

__________Categorical Exclusion without Environmental Action Memorandum 

__________Categorical Exclusions and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

__________Environmental Impact Statement and Record of Decision 

F-16 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: Recreational Fishing 

Primary Use: Fishing (general and other). 

Supporting and Incidental Uses: Boating (motorized and non-motorized), fixed-wing aircraft 

landings, hunting, firewood cutting, trapping, camping, hiking and backpacking, picnicking, pets, 

natural resource gathering, wildlife photography and videography, swimming and beach use, 

wildlife observation, snowmobiling. 

Refuge Name: Innoko National Wildlife Refuge 

Establishing and Acquisition Authority: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon: 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C.668dd-668ee]). 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-17 
Appendix F: Compatibility Determinations 

Description of Use: 

This determination re-evaluates recreational fishing as a compatible use on Innoko Refuge. 

Recreational fishing was originally found to be compatible in the original Refuge Comprehensive 

Conservation Plan (1987) and was again determined to be compatible in 1992. Means of access for 

recreational fishing include fixed-wing floatplanes, motorboats, non-motorized boats, hiking, and 

snowmobiling. Associated activities such as camping, backpacking, hiking, and other incidental 

uses are considered part of wildlife-dependent recreational fishing activities. Recreational fishing 

occurs spring through fall, with limited ice fishing occurring in early spring, and is managed under 

State of Alaska fishing regulations (5AAC). Of the four major rivers on the refuge, all could be 

classified as having good recreational fishing opportunities, based on reasonable accessibility by 

float plane or boat, and sustainable populations of anadromous and/or resident fish. Although all 

these drainages provide opportunities for day use and overnight primitive camping, cost of 

traveling to these areas for day-use fishing is prohibitive for most visitors. All drainages provide 

opportunities for northern pike fishing and have seasonal salmon runs that attract recreational 

fishing. Arctic grayling, whitefish, and Dolly Varden are also available in some waters within the 

refuge in the headwaters of the Innoko River. Recreational fishing patterns are estimated 

primarily through direct observation by refuge staff and reports from local residents. Use is very 

low outside of the hunting season. Refuge staff members are aware of only a few public 

recreational trips per year, mainly motorized river trips from local villages. 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage recreational 

fishing at existing levels. Administrative staff time primarily involves phone conversations and 

written correspondence. It could involve regulatory review. Field work associated with 

administering the program primarily involves conducting law enforcement patrols to ensure 

recreational users’ compliance with State fishing regulations and refuge regulations and working 

with adjacent land owners to monitor public use on rivers flowing onto Innoko Refuge. It is 

estimated that less than two weeks of staff time is required to manage this use on Innoko Refuge. 

Anticipated Impacts of the Use: 

Both the Federal Subsistence Board and State Board of Fisheries regularly adopt regulations in 

response to fish population levels and to address issues of fishery allocation. Providing an 

opportunity for continued subsistence uses of fishery resources by local residents receives the 

highest priority from the Federal Subsistence Board. Although salmon experienced a worrisome 

decline in the late 1990s, recent run strengths indicate that a recreational fishery on salmon 

currently is sustainable. The Innoko Refuge Fisheries Management Plan (USFWS 1993) warned 

that refuge fish populations could decline without sufficient data to measure population trends. 

Based on guidance provided in the Fisheries Management Plan, refuge staff members continue to 

work with the Fairbanks Fish and Wildlife Field Office and Alaska Department of Fish and Game 

(ADF&G) to implement inventories and studies in the Plan and to conduct other research aimed at 

understanding fish populations and key habitats on Innoko Refuge. At current levels, recreational 

fishing harvests require little monitoring, and there are no anticipated deleterious effects on fish 

habitat. There are presently two sport fish guides utilizing the Innoko Refuge. Should intensity of 

use increase, refuge staff would increase monitoring efforts. If necessary, refuge staff would 

review regulations and propose changes to protect fishery resources and subsistence fishing 

opportunities for people living near the refuge. 

F-18 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Additional potential impacts or threats are associated with floatplane or motorboat access. The 

introduction of invasive plant species carried on boats or aircraft floats could affect refuge 

resources, although it is not known to have occurred via this mode of transportation on the Innoko 

Refuge to date. In addition, frequent motorboat or aircraft traffic could impact nesting, molting, 

or staging birds (Bouffard 1982, Miller 1994, Ward et al. 1994). Temporary displacement and/or 

disturbance to wildlife can also occur in response to low level overflights and during aircraft 

takeoffs and approaches to landings (Calef et al. 1976). 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the refuge’s Comprehensive 

Conservation Plan. No comments were received on this compatibility determination. 

Refuge Determination (check one below): 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

Visitors will be required to comply with any regulations in place, such as seasonal closures for 

resource protection. 

The Fisheries Management Plan for Innoko Refuge (1993) will be used to identify specific 

management actions to ensure that recreational fishing and related activities continue to 

remain compatible with refuge purposes. 

Justification: 

The National Wildlife Refuge System Administration Act (as amended by the Refuge 

Improvement Act of 1997) identifies compatible recreational fishing as one of six priority public 

uses of national wildlife refuges. The law states that when managed in accordance with principles 

of sound fish and wildlife management, administration of these uses has been, and is expected to 

continue to be, generally compatible, and that priority public uses should receive enhanced 

consideration over other general public uses in refuge planning and management. The law also 

states that the Service should provide increased opportunities for families to experience 

compatible wildlife-dependent recreation, particularly opportunities for parents and their children 

to safely engage in traditional outdoor activities such as fishing. 

Means of access by airplanes, motorboats, snowmobiles and non-motorized means for traditional 

activities, as provided by ANILCA and as currently regulated by the Service, have not materially 

interfered with or detracted from refuge purposes. Should motorized transportation in support of 

recreational fishing increase to levels where it interferes with refuge purposes, staff would work 

with anglers and ADF&G to address impacts and resolve compatibility concerns. 

Recreational fishing is an activity that Congress intended to preserve when the refuge was 

designated by ANILCA. As stated previously, recreational fishing within the refuge provides the 

public with safe and unique recreational fishing opportunities of a quality found few places 

elsewhere in the world. The State Board of Fisheries and the Federal Subsistence Board manager 

 public fishery resources through regulations. They provide the continued opportunity for 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-19 
Appendix F: Compatibility Determinations 

subsistence fishing by local residents in response to changing fish population levels and harvest 

patterns. These regulations provide adequate protection for the refuge’s fishery resources and 

continued subsistence opportunities in balance with other refuge purposes. After fully considering 

the impacts of these activities, as described previously in the “Anticipated Impacts of Use” section 

of this determination, it is my determination that recreational fishing within the refuge does not 

materially interfere with or detract from the purposes of the refuge or mission of the National 

Wildlife Refuge System. 

Supporting Documents: 

Bouffard, S. 1982. Wildlife values versus human recreation: Ruby Lake National Wildlife Refuge. 

Transactions of the North American Wildlife and Natural Resources Conference 47:553-558. 

Calef, G.W., E.A. DeBock, and G.M. Lortie. 1976. The reaction of barren-ground caribou to 

aircraft. Arctic 29(4):201-212. 

Innoko National Wildlife Refuge, Fisheries Management Plan 1993, U.S. Fish and Wildlife 

Service, Fairbanks, AK, 52pp. 

Miller, M. W. 1994. Route selection to minimize helicopter disturbance of molting Pacific black 

brant: a simulation. Arctic 47: 341–349. 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service. Anchorage, AK. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Ward, D. H., R. A. Stehn, D. V. Derksen. 1994. Response of staging brant to disturbance at the 

Izembek Lagoon, Alaska. Wildl. Soc. Bull. 22: 220–228. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: __/s/ Kent A. Sundseth, acting___________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: _/s/ Todd J. Logan___________________ December 19, 2008

 (Signature) (Date) 

 

Mandatory 15-Year Re-Evaluation Date (for priority public uses): 2023

F-20 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

NEPA Compliance for Refuge Use Decision: 

__________Categorical Exclusion without Environmental Action Memorandum 

__________Categorical Exclusions and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

__________Environmental Impact Statement and Record of Decision 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-21 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: Non-Wildlife-Dependent Recreational Activities 

Primary Uses: Picnicking, boating (motorized and non-motorized), fixed-wing aircraft landings, 

natural resource gathering, camping, cross-country skiing, dog training, dog sledding and 

skijoring, snowmobiling, hiking and backpacking, pets, videography and audio recording, 

snorkeling and scuba diving, snowshoeing, swimming and beach use, firewood cutting. 

Supporting and Incidental Uses: None 

Refuge Name: Innoko National Wildlife Refuge 

Establishing and Acquisition Authorities: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife National 

Wildlife Refuge System (Department of the Interior) in 1980. 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C.668dd-668ee]). 

F-22 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Description of Uses: 

This determination evaluates general public uses not covered in other compatibility 

determinations, including camping, hiking, backpacking, firewood cutting for recreational 

purposes, boating (motorized and non-motorized), plant gathering (including berry picking), rock 

gathering, cross-country skiing, dog sledding, skijoring, snowmobiling, beach use, snowshoeing, 

and other general outdoor recreation when the uses are not associated with one of the other uses 

evaluated elsewhere for compatibility. These uses could occur year-round; though most are 

common in summer. The uses probably occur infrequently when not in association with other 

uses. Most of these uses were originally found to be compatible during preparation of the Refuge 

Comprehensive Conservation Plan in 1987,and were again determined to be compatible, subject to 

reasonable, regulation in 1992. 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage these uses. 

Management consists of refuge staff contacting visitors on an opportunistic basis when in the field 

for other purposes. 

Anticipated Impacts of the Uses: 

These activities are anticipated to have negligible effects on refuge resources and other visitors, 

primarily because they occur so infrequently. For example, most berry picking occurs as a 

subsistence activity or by visitors engaged in another activity such as wildlife observation, hunting, 

or fishing. 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the Refuge’s Comprehensive 

Conservation Plan. No comments were received on this compatibility determination. 

Refuge Determination (check one below): 

_____Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

Visitors will be required to comply with any regulations in place, such as seasonal closures for 

resource protection. 

Justification: 

These uses, at the levels anticipated, are not likely to have any adverse effects on refuge resources 

or other visitors. The activities have been found compatible when conducted in relation to other 

refuge uses such as wildlife observation and photography, hunting, fishing, trapping, or 

subsistence activities. Because the refuge is remote and only accessible by boat, airplane, 

snowmobile, dogsled, or arduous cross-country travel on foot, it is extremely unlikely that many 

visitors will travel to Innoko Refuge to engage solely in these non-priority public use activities. 

After fully considering the impacts of these activities, as described previously in the “Anticipated 

Impacts of the Uses” section of this determination, it is my determination that these non-priority 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-23 
Appendix F: Compatibility Determinations 

public use activities within the refuge do not materially interfere with or detract from the 

purposes of the refuge or mission of the National Wildlife Refuge System. 

Supporting Documents: 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service. Anchorage, AK. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: __/s/ Kent A. Sundseth, acting___________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: _/s/ Todd J. Logan___________________ December 19, 2008

 (Signature) (Date) 

Mandatory 10-Year Re-evaluation Date (for allowed uses only): 2018

NEPA Compliance for Refuge Use Decision: 

__________Categorical Exclusion without Environmental Action Memorandum 

__________Categorical Exclusions and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

__________Environmental Impact Statement and Record of Decision 

F-24 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Compatibility Determination 

 

Use: Trapping 

Supporting and Incidental Uses: Fixed-wing aircraft landings, snowmobiling, boating (motorized 

and non-motorized), fishing, hunting, natural resource gathering, camping, cross-country skiing, 

dog sledding and skijoring, hiking and backpacking, wildlife photography and videography, 

snowshoeing, swimming, wildlife observation, pets, and firewood cutting. 

Refuge Name: Innoko National Wildlife Refuge 

Establishing and Acquisition Authorities: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within the 

refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C. 668dd-668ee]). 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-25 
Appendix F: Compatibility Determinations 

Description of Use: 

This determination re-evaluates the compatibility of furbearer trapping as a use of Innoko Refuge. 

Trapping was originally found to be a compatible use during preparation of the refuge 

Comprehensive Conservation Plan in 1987. Trapping was again determined to be compatible, 

subject to reasonable regulation, in 1992. Wolves, fox, beaver, marten, lynx, snowshoe hares, 

wolverine, ermine, and river otters are regularly trapped on Innoko Refuge. Trapping occurs 

during winter on the refuge in accordance with State of Alaska trapping regulations and seasons 

(5 AAC). Trapping activity on Innoko Refuge has generally been decreasing since the 1980s 

The majority of trapping activities within Innoko Refuge are based out of Grayling, Anvik, 

Shageluk, and Holy Cross. Access to trapping areas is primarily by snowmobile. Currently, only 

a small number of traplines are active. By tradition, each trapline tends to be used by a particular 

family or clan in a village; different traplines are usually separated by several miles and respected 

locally as exclusive trapping use areas. Most trapping activities can be characterized as an 

extension of subsistence because much of the fur harvest is used for clothing, including hats, parka 

ruffs, and gloves. Income and products from trapping add to the self sufficiency of people living in 

remote regions of Alaska. 

 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage trapping on 

Innoko Refuge. A few days of staff time are required annually to survey and map traplines, 

review harvest estimates, and consider the occasional application for related permits (e.g., 

trapping cabin permits). 

Anticipated Impacts of the Use: 

No long-term adverse impacts on wildlife populations or other refuge resources are likely to occur 

due to continuation of trapping on the refuge. State trapping regulations are established to ensure 

healthy, sustainable furbearer populations. These regulations also provide potential for income 

from a renewable natural resource that supports local subsistence. Trapping can be an integral 

part of furbearer studies when biologists have sufficient funding to conduct trapper interviews and 

occasionally purchase large numbers of carcasses to determine population parameters such as 

productivity and reproductive history. Intensity of harvest and density of traplines on Innoko 

Refuge are very low, and overall trapping pressure has declined since the 1980s. Therefore, 

except for the occasional harvest of non-targeted animals, trapping has little impact on the refuge. 

 Diminishing trapping activity seems to have been the result of low fur prices, high energy prices, 

and an increasing number of people leaving the village for seasonal jobs outside of the area. 

Refuge staff will monitor harvest to the extent possible and attempt to determine trends through 

field observations and trapper interviews. If population concerns manifest, the Service will 

become engaged in review of the appropriate State of Alaska trapping regulations. The refuge 

will also be engaged in field enforcement of trapping regulations. 

The introduction of invasive plant species, perhaps from seeds carried on equipment used in 

support of trapping efforts (e.g., boats, snowmobiles, dogsleds, and straw bedding), could affect 

refuge resources, although it is not known to have occurred on the Innoko Refuge. The Service 

will be vigilant to prevent such introductions. 

F-26 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the refuge’s Comprehensive 

Conservation Plan. No comments were received on this compatibility determination. 

Refuge Determination (check one below): 

_____Use is Not Compatible 

 X Use is Compatible 

Stipulations Necessary to Ensure Compatibility: 

Visitors will be required to comply with any regulations in place, such as seasonal closures for 

resource protection. 

Justification: 

Trapping is a long-established use of the refuge. The State of Alaska manages harvest of 

furbearers to ensure their long-term sustainability. Most trapping occurs at the time of year when 

there are few visitors on the refuge. The majority of trapping effort on the refuge may be 

characterized as an extension of local subsistence activities. The current level of trapping, or even 

an increase in trapping activities, would likely have a negligible effect on the resources of Innoko 

Refuge. After fully considering the impacts of this activity, as described previously in the 

“Anticipated Impacts of Use” section of this determination, it is my determination that trapping 

activities within the refuge do not materially interfere with or detract from the purposes of the 

refuge or mission of the National Wildlife Refuge System. 

Supporting Documents: 

Marcotte, J.R. and T.L. Haynes. 1985. Contemporary resource use patterns in the upper 

Koyukuk region, Alaska. Division of Subsistence Technical Paper No. 93. Alaska Dept. of Fish 

and Game, Anchorage, AK. 

Strong, B.J. and E. W. McIntosh. 1985. Resource harvest by local residents of the Upper 

Koyukuk Region in 1984. U.S. Fish and Wildlife Service, Fairbanks, AK. 51pp. 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service, Anchorage, AK 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Wildlife Society Position Statement on Traps, Trapping and Furbearer Management. 2005. 

http://www.wildlife.org/policy/positionstatements/09-Trapping.pdf. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-27 
Appendix F: Compatibility Determinations 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: __/s/ Kent A. Sundseth, acting__________ December 17, 2008

 (Signature) (Date) 

 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: _/s/ Todd J. Logan__________________ December 19, 2008

 (Signature) (Date) 

Mandatory 10-year Re-Evaluation Date (for allowed uses only): 2018

NEPA Compliance for Refuge Use Decision: 

__________Categorical Exclusion without Environmental Action Memorandum 

__________Categorical Exclusions and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

__________Environmental Impact Statement and Record of Decision 

F-28 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: Snowmobiling 

Primary Use: Snowmobiling 

Supporting and Incidental Uses: Hunting, fishing, trapping, natural resource gathering, firewood 

cutting, camping, picnicking, cross-country skiing, wildlife photography and videography, 

snowshoeing, pets, research, scientific collecting, surveys, wildlife observation. 

Refuge Name: Innoko National Wildlife Refuge 

Establishing and Acquisition Authority: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C.668dd-668ee]). 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-29 
Appendix F: Compatibility Determinations 

Description of Use: 

This determination re-evaluates use of snowmobiles for access to Innoko Refuge. Snowmobiles 

were originally found to be compatible during preparation of the Refuge Comprehensive 

Conservation Plan in 1987. Snowmobiles were again determined to be compatible, subject to 

reasonable regulation, in 1992. The Alaska refuge regulations define a snowmobile as “a selfpropelled vehicle intended for off-road vehicle travel primarily on snow [and] having a curb 

weight of not more than 1,000 pounds, driven by track or tracks in contact with the snow and 

driven by a ski or skis in contact with the snow (50 CFR 36.32).” Alaska refuge regulations also 

specify that snowmobiles are only allowed during periods of adequate snow cover. Adequate 

snow cover is defined as an amount of snow, distributed in a continuous manner, which will 

protect underlying vegetation from adverse effects. Innoko Refuge staff consider adequate 

snow cover for this use to be at least six inches. Snowmobile use occurs during winter, mostly 

from the villages of Grayling and Shageluk. Although the exact amount of snowmobile use on 

the refuge is not documented, it is not believed to be substantial. Snowmobiles are an important 

means of access for subsistence and trapping activities and are a means of access for non-local 

recreation in winter. The majority of snowmobile use on Innoko Refuge takes place along wellestablished inter-village trails, along traditional trapline trails, or to access refuge inholdings. 

(See also compatibility determinations on trapping and non-wildlife-dependent recreation 

activities.) 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage this use. 

Currently, monitoring is conducted by talking with local residents and, during winter and spring, 

through overflights of the refuge conducted for other purposes. 

Anticipated Impacts of the Use: 

Potential impacts of snowmobile use include disturbance of underlying vegetation and wildlife, and 

noise pollution. Because the majority of snowmobile use occurs on established trails, many of 

which are ice covered rivers, disturbance to vegetation above and beneath the snow is minimal and 

localized. In areas where snowmobiles leave established trails, there may be small amounts of 

damage to shrub branches above the snow level. 

If snowmobile use on Innoko Refuge increased substantially, such as from additional activity 

associated with the Iditarod Dogsled race, disturbance to important subsistence species, including 

moose and limited caribou groups could occur (McTaggart 1981, Creel et al. 2002). Denning bears 

are most susceptible to snowmobile disturbance. Actions by ill-advised or uninformed snowmobile 

user could cause bears to abandon dens and harm newborn cubs incapable of travel (Jonkel 1980). 

Snowmobile use could also affect moose and caribou energy budgets, reproductive success, and 

long-term survival (Fancy and White 1985). Disturbance from noise could have an adverse effect; 

however, the presence of snowmobile trails could provide access through deep snow in winter. In 

addition, the wild character of Innoko Refuge and Innoko Wilderness could be altered by 

increased noise disturbance; this disturbance is expected to be minimal as there are very few 

winter visitors who are not using snowmobiles. 

The introduction of invasive plant species, perhaps from seeds carried on snowmobiles or sleds, 

could affect refuge resources, although it is not known to have occurred on the Innoko Refuge. 

Refuge staff will be vigilant to prevent such introductions. 

F-30 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the refuge’s Comprehensive 

Conservation Plan. The State of Alaska recommended that we reference both the trapping and 

non-wildlife dependent recreation activities compatibility determinations in the “Description of 

Use” section of this compatibility determination. The State also requested we include a reference 

to ANILCA provisions for snowmobiles to the Justification section of this compatibility 

determination. We added the references requested by the State. 

Refuge Determination (check one below): 

_____Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

Visitors will be required to comply with any regulations in place, such as seasonal closures for 

resource protection. 

Justification: 

ANILCA section 811 provides for snowmobile access for subsistence purposes, and section 1110 

allows the use of snowmobiles for traditional activities and for travel to and from villages and 

home sites. Snowmobiles allow access for a majority of winter activities on the refuge, and 

present use levels support compatible refuge activities. Regulations defining the size and weight 

of snowmobiles, coupled with the requirement that adequate snow cover be present, eliminate 

most potential for damage to habitat. The current low level of snowmobile use on Innoko Refuge 

would have negligible adverse effects on wildlife and habitat. If the intensity of snowmobile use 

increases greatly, which is a real possibility if the Iditarod National Historic Trail were to be used 

as a modern race trail and recreational trail ride were to follow, disturbance to sensitive wildlife 

species and habitats, such as denning bears and wind-scoured areas with insufficient snow cover, 

may occur. The refuge will continue to monitor snowmobile use levels and winter travel conditions 

and may take restrictive action if conditions warrant. After fully considering the impacts of this 

activity, as described previously in the “Anticipated Impacts of Use” section of this determination, 

it is my determination that snowmobile use within the refuge does not materially interfere with or 

detract from the purposes of the refuge or mission of the National Wildlife Refuge System. 

Supporting Documents: 

Creel, S., J.E. Fox, A. R. Hardy, J. Sands, B. Garrot, and R.O. Peterson. 2002. Snowmobile 

activity and glucocorticoid stress responses in wolves and elk. Conservation Biology 16(3);809 

http://www.montana.edu/wwwbi/staff/creel/snomoGC.pdf 

Fancy, S. G., and R. G. White. 1985. Energy expenditures by caribou while cratering in snow. 

Journal of Wildlife Management 49(4):987-993. 

Jonkel, C. J. 1980. Black, brown, and polar bears. Pages 227–228 in Big game of North 

America: ecology and management. J. L. Schmidt and D.L. Gilbert, eds. Harrisburg, 

Pennsylvania: Stackpole Books. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-31 
Appendix F: Compatibility Determinations 

McTaggart-Cowan, I. 1981. Wildlife conservation issues in northern Canada. Canadian 

Environmental Advisory Council report, no. 11. University of Calgary, Canada. 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service. Anchorage, AK. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: __/s/ Kent A. Sundseth, acting_________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: _/s/ Todd J. Logan_________________ December 18, 2008

 (Signature) (Date) 

Mandatory 10-Year Re-evaluation Date (for allowed uses only): 2018

NEPA Compliance for Refuge Use Decision: 

__________Categorical Exclusion without Environmental Action Memorandum 

__________Categorical Exclusions and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

__________Environmental Impact Statement and Record of Decision 

F-32 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: Temporary Camps 

Primary Use: Temporary camps. 

Supporting and Incidental Uses: Boating (motorized and non-motorized), fixed-wing aircraft 

landings, hunting, natural resource gathering, camping, picnicking, snowmobiling, hiking and 

backpacking, pets, wildlife photography and videography, swimming and beach use, firewood 

cutting. 

Refuge Name: Innoko National Wildlife Refuge 

Establishment and Acquisition Authority: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C. 668dd-668ee]). 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-33 
Appendix F: Compatibility Determinations 

Description of Use: 

This determination re-evaluates existing temporary camps and the potential for additional 

temporary camps to support the taking of fish and wildlife. This use was originally found to be 

compatible in the Refuge Comprehensive Conservation Plan (1987). Two temporary camps exist 

on the refuge that are not under permit. Most local rural residents conduct these uses on refuge 

lands supported by use of cabins that are located on private native allotments; however, it is 

possible that there may be future applications for temporary camp permits. Applications for 

permits for new trapping or subsistence cabins will be evaluated in separate compatibility 

determinations. 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage temporary camps 

at current and projected levels. Administrative staff time primarily would involve phone 

conversations and written correspondence, and issuing permits. Field work associated with 

administering permits would primarily involves monitoring permittees’ compliance with the terms 

of the permits and evaluating potential damage caused by wildfires. Estimated staff time to 

annually administer and monitor these permits would be one week or less. 

Anticipated Impacts of the Use: 

Special conditions attached to each special use permit are designed to minimize the chances of 

adverse effects to resources within the refuge and to its visitors. There are two primary concerns: 

 wildlife and habitat impacts and visual impacts. Most wildlife using the area near such structures 

is likely habituated to the presence of these structures and the activities that routinely occur in 

and near them. The structures provide relatively secure storage for food, trapping supplies and 

bait, and other materials that might attract bears. 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the Refuge’s Comprehensive 

Conservation Plan. The State of Alaska requested we delete the phrase “local rural residents” 

because the use of trapping cabins is not limited to local rural residents. We deleted this phrase. 

We also changed the description of use to indicate that for we are evaluating temporary camps 

only as there are currently no trapping or subsistence cabins authorized on the refuge. The 

previous holder of cabin permits let the permits expire and abandoned the structures. The 

compatibility of any new cabins would be evaluated in separate compatibility determinations. 

Refuge Determination (check one below): 

 Use is Not Compatible 

X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

A special use permit with stipulations may be required. The permit includes details of the 

specific use. In the following section are typical special use permit stipulations, some of which 

are necessary for compatibility. Site-specific special use conditions related to maintenance of 

defensible space would be incorporated into permits on a case-by-case basis. Other specific 

stipulations may be included in individual permits. 

F-34 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

The management direction provided in the revised Comprehensive Conservation Plan for the 

refuge will be implemented. Monitoring would be used to determine what additional management 

actions, if any, would be needed to ensure compatibility. Continuing law enforcement and 

administrative monitoring of permits would ensure compliance with the following conditions that 

are incorporated into all permits to minimize impacts on lands and resources within the refuge. 

These stipulations will be updated, if necessary, to comply with the requirements of future stepdown plans. 

Regional Standard Special Conditions

 Failure to abide by any part of this special use permit; violation of any refuge related 

provision in titles 43 (part 36) or 50 (subchapters B and C) of the Code of Federal 

Regulations; or violation of any pertinent State regulation (e.g., fish or game violation) will, 

with due process, be considered grounds for immediate revocation of this permit and could 

result in denial of future permit requests for lands administered by the U.S. Fish and 

Wildlife Service. This provision applies to all persons working under the authority of this 

permit (e.g., assistants). Appeals of decisions relative to permits are handled in accordance 

with 50 Code of Federal Regulations 36.41. 

 The permittee is responsible for ensuring that all employees, party members, contractors, 

aircraft pilots, and any other persons working for the permittee and conducting activities 

allowed by this permit are familiar with and adhere to the conditions of this permit. 

 Any problems with wildlife and/or animals taken in defense of life or property must be 

reported immediately to the refuge manager and the Alaska Department of Fish and 

Game, and animals taken must be salvaged in accordance with State regulations. 

 In accordance with the Archaeological Resources Protection Act (16 U.S.C. 470aa), the 

removal or disturbance of archaeological or historical artifacts is prohibited. The excavation, 

disturbance, collection, or purchase of historical, ethnological, or archaeological specimens or 

artifacts is prohibited. 

 Permittees shall maintain their use areas in a neat and sanitary condition. Latrines must 

be located at least 150 feet from springs, lakes, and streams to avoid contamination of 

water resources. All property (except cabins and/or tent frames) of the permittee must be 

removed from refuge lands upon completion of permitted activities. 

 The construction of landing strips or pads is prohibited. Incidental hand removal of rocks 

and other minor obstructions may be permitted. 

 The use of off-road vehicles (except snowmobiles with adequate snow cover) is prohibited 

unless specifically authorized in writing in this permit. 

 The operation of aircraft at altitudes and in flight paths resulting in the herding, 

harassment, hazing, or driving of wildlife is prohibited. It is recommended that all aircraft, 

except for takeoff and landing, maintain a minimum altitude of 2,000 feet above ground. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-35 
Appendix F: Compatibility Determinations 

 Fuel caches are allowed only in designated areas and must be approved by the refuge 

manager or his or her designate prior to caches being established. If caches are established, 

fuel containers must be clearly marked with the permittee’s name, address, local contact 

telephone number, and type of fuel. 

 Any major exterior rehabilitation of or additions to existing structures must have the 

refuge manager’s prior approval in writing. This does not include minor remodeling or 

routine maintenance. 

 Subject to available suppression resources and taking into consideration specific site 

conditions (including human presence), permitted cabins, structures, and/or related 

facilities may be protected from wildfire to the extent possible. Human safety will receive 

the highest priority consideration by land managers and fire suppression personnel. 

 This permit authorizes use on State selected lands. If any of these lands are conveyed 

during the term of this permit, the permittee will no longer be authorized to use those 

lands until and unless permission is obtained from the Alaska Department of Natural 

Resources. 

 This permit authorizes use only on the Native selected lands specifically identified in the 

description block of this permit. If any of these Native selected lands are conveyed 

during the term of this permit, the permittee will no longer be authorized to use those 

lands unless permission is obtained from the Native corporation to which land ownership 

has been conveyed. 

 Any action by a permittee or the permittee's employees that unduly interferes with or 

harasses other refuge visitors or impedes access to any site is strictly prohibited. 

Examples of prohibited acts include but are not limited to 1) intentional low flights over 

camps or persons at less than 500 feet except when necessary for takeoff and landing; 2) 

parking aircraft or placing other objects (rocks, tents, etc.) on any landable area so as to 

restrict use by other aircraft; 3) otherwise intentionally interfering in the activity of other 

refuge users; and 4) engaging in activity that is contrary to State and Federal laws. 

Refuge-Specific Special Conditions

 All garbage and noncombustible debris will be removed from the refuge. Food, garbage, 

and/or other materials will be stored so as not to attract bears and other wildlife. 

 Use of cabins is authorized for trapping or subsistence related activities only. Use of the 

cabin for any other purposes is prohibited and will result in revocation of the permit. The 

permittee must notify the refuge manager of any proposed or ongoing changes in use or in 

cabin users. 

 This permit is not marketable or transferable and is subject to renewal five years from the 

date of issuance. 

F-36 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

 The permittee acknowledges that he/she has no interest in the real property on which the 

cabin(s) and related structures are located. The granting of this permit in no way implies that 

the permittee has exclusive use of the site or lands covered by the permit, or of local resources. 

 The permittee agrees to vacate the cabin(s) and related structures within one year of 

nonrenewal or revocation of this permit and will leave the surrounding grounds in a neat, 

clean, and orderly condition. If the permittee fails to remove all personal property within one 

year, the permittee will be liable for the cost of its removal and the restoration of the site. 

 The permittee will take no action that interferes with subsistence activities of rural users 

or restricts the reasonable access of subsistence users to refuge lands. This may include 

but is not limited to disturbance of wildlife and their movements near subsistence hunters, 

and damage to cabins, trails, traditional campsites, or caches used by subsistence users. 

 A valid copy of the issued special use permit, signed by the refuge manager or designee, must 

be in the permittee’s possession at all times while exercising the privileges of the permit. 

Justification: 

The impacts of these permanent and semi-permanent facilities to refuge resources and other 

refuge users were considered in detail during the permit application and renewal process. 

Regulations at 50 CFR 36.33 (d) state in part that “a nontransferable, five-year special use permit 

shall only be issued upon a determination that the proposed construction, use and maintenance of 

the cabin is compatible with refuge purposes and that the cabin use ...is needed for continuation of 

an ongoing activity or use otherwise allowed within the refuge where the applicant lacks a 

reasonable off-refuge site. In addition these activities must have historically been supported by 

the construction and use of cabins in the geographic area. In general, new cabins will be given 

only to local residents to pursue a legitimate subsistence activity....” Trapping and subsistence 

are the primary uses that historically have been supported by cabins in the Innoko Refuge area, 

therefore, the refuge manager must issue a permit if it is otherwise compatible with refuge 

purposes. Refuge staff will monitor compliance with permit special conditions to ensure that the 

cabins and use of the cabins will not adversely affect resources within the refuge or other visitors. 

After fully considering the impacts of these activities, as described previously in the “Anticipated 

Impacts of Use” section of this determination, it is my determination that subsistence and 

trapping cabin use within the refuge does not materially interfere with or detract from the 

purposes of the refuge or mission of the National Wildlife Refuge System. 

Supporting Documents: 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service. Anchorage, AK. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-37 
Appendix F: Compatibility Determinations 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: __/s/ Kent A. Sundseth, acting_________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: _/s/ Todd J. Logan___________________ December 19, 2008

 (Signature) (Date) 

Mandatory 10-Year Re-Evaluation Date: 2018

NEPA Compliance for Refuge Use Decision: 

 Categorical Exclusion without Environmental Action Memorandum 

 Categorical Exclusions and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

F-38 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: Subsistence Harvest of House Logs 

Primary Use: Construction of homes or outlying cabins.

Supporting and Incidental Uses: Boating (motorized and non-motorized), snowmobiling, camping, 

picnicking, hiking and backpacking, pets, wildlife photography and videography, and firewood 

cutting. 

Refuge Name: Innoko National Wildlife Refuge 

Establishment and Acquisition Authority: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C. 668dd-668ee]). 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-39 
Appendix F: Compatibility Determinations 

Description of Use: 

This determination re-evaluates subsistence house log cutting as a use of Innoko Refuge. 

Subsistence log cutting was originally found to be compatible in the Refuge Comprehensive 

Conservation Plan (1987) and was again determined to be compatible in 1992. Associated uses 

include hunting, fishing, trapping, firewood gathering, berry picking, and gathering of other plant 

materials while harvesting trees for house building. These uses also include motorboat access and 

other means of surface transportation traditionally employed for such subsistence purposes, as 

allowed under ANILCA section 811. According to 50 CFR, 36.15, “Notwithstanding any other 

provision of this part, the noncommercial cutting of live standing timber by local rural residents 

for appropriate subsistence uses, such as firewood or house logs, may be permitted in Alaska 

National Wildlife Refuges as follows: For live standing timber greater than six inches diameter at 

breast height (4 1⁄2 feet above ground level), the Refuge Manager may allow cutting in accordance 

with the specifications of a special use permit if such cutting is determined to be compatible with 

the purposes for which the refuge was established.” 

Residents of Grayling, Anvik, Shageluk, and Holy Cross, located near Innoko Refuge, have 

lifestyles and economies that depend on subsistence resources. Subsistence activities described 

here focus primarily on cutting house logs greater than six inches diameter at breast height for 

local cabin construction, and firewood collecting that may be associated with the logging. Innoko 

Refuge has some limited historical data on the number of house logs or intensity of harvest for 

subsistence prior to or shortly after refuge establishment. Permits issued early in the history of 

the refuge did not assign specific cutting areas. Refuge staff members have issued house log 

cutting permits since the refuge was established. Most of the permits were to cut logs for 

personal residences in Grayling. A few permits were issued for logging on refuge lands near 

private Native allotments where the permittee intended to build a subsistence cabin. Most 

permits were for 40 logs. Occasionally, materials not suitable for house logs are salvaged for use 

as firewood. Each permit application is evaluated on its own merits prior to approval. 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage subsistence house 

log harvest activities at existing and projected levels. Management primarily includes surveys 

conducted specifically for the management of house logs and firewood collecting. Surveys will be 

conducted from the air and from motor boats and will be used to determine where adequate stands 

of large white spruce occur and how many trees can be removed while allowing sustainability of 

riparian spruce stands. It is anticipated that management of these permits will require no longer 

than one week of staff time annually. 

Anticipated Impacts of the Use: 

White spruce is the favored timber species for logging. It occurs throughout central Alaska on 

well-drained floodplain soils, uplands, and south-facing slopes where seasonal thaw is deep. Most 

white spruce stands in floodplains and on uplands consist of trees 40-50 feet tall and 8-16 inches in 

diameter. Exceptional trees with diameters of 24-36 inches at breast height and 100 feet tall may 

occur on floodplain islands that have not been burned for a long time. Stands of white spruce of a 

size usable for house logs are mainly limited to the Kaiyuh Hills between the Yukon and Innoko 

rivers. The nearest study aimed at examining sustainability of white spruce logging was about 100 

miles south at Nowitna Refuge, where Lambrecht (2004) estimated a sustainable harvest of one 

house log per 2.5 acres per year in ideal riparian white spruce habitat on islands along the Yukon 

F-40 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

River. Current permits assign cutting areas, and staff will conduct follow-up site visits to examine 

cutting intensity. If cutting intensity increases, refuge staff will make an effort to determine 

sustainable harvest levels and regeneration time for riparian white spruce. In the meantime, trees 

will be taken based on sustainability recommendations adopted from Koyukuk and Nowitna 

refuges. Possible impacts to anadromous fish will be minimized by following appropriate sections 

of the Alaska Forest Resources & Practices Act (Alaska Statutes 41.17 sec. 115-119). 

Impacts to habitat caused by supporting aircraft, boats, snowmobiles, and foot travel are generally 

believed to be minimal. Much of the access by subsistence users is by boat (spring and summer) or 

snowmobile (winter) during adequate snow cover. Impacts to the wild character of Innoko Refuge 

will be minimized through special conditions limiting the number of trees that can be taken within 10 

feet of river banks. The introduction of invasive plant species, perhaps from seeds carried on boats, 

snowmobiles, or dog sleds, could affect refuge resources, although it is not known to have occurred 

on the Innoko Refuge. Logging sites may be particularly vulnerable to establishment of non-native, 

noxious weeds if the ground is disturbed. Refuge staff will be vigilant to prevent such introductions. 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the refuge’s Comprehensive 

Conservation Plan. No comments were received on this compatibility determination. 

Refuge Determination (check one below): 

______Use is not compatible 

 X Use is compatible 

Stipulations Necessary to Ensure Compatibility: 

A special use permit with stipulations is required for some house log cutting. The permit includes 

details of the specific use. In the following section are typical special use permit stipulations some 

of which are necessary for compatibility. Site specific special use conditions related to 

maintenance of defensible space will be incorporated into permits on a case-by-case basis. Other 

project-specific stipulations may be included in individual permits. Monitoring of permits will be 

carried out to ensure compliance with the terms of the permit (including the special conditions) to 

minimize impacts on lands and resources within the refuge. 

Regional Standard Special Conditions

 Failure to abide by any part of this special use permit; violation of any refuge related 

provision in titles 43 (part 36) or 50 (subchapters B and C) of the Code of Federal 

Regulations; or violation of any pertinent State regulation (e.g., fish or game violation) will, 

with due process, be considered grounds for immediate revocation of this permit and could 

result in denial of future permit requests for lands administered by the U.S. Fish and 

Wildlife Service. This provision applies to all persons working under the authority of this 

permit (e.g., assistants). Appeals of decisions relative to permits are handled in accordance 

with 50 Code of Federal Regulations 36.41. 

 The permittee is responsible for ensuring that all employees, party members, contractors, 

aircraft pilots, and any other persons working for the permittee and conducting activities 

allowed by this permit are familiar with and adhere to the conditions of this permit. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-41 
Appendix F: Compatibility Determinations 

 Any problems with wildlife and/or animals taken in defense of life or property must be 

reported immediately to the refuge manager and the Alaska Department of Fish and 

Game, and must be salvaged in accordance with State regulations. 

 This permit does not grant the permittee and his/her employee’s exclusive use of the site(s) 

or lands covered by the permit. 

 This permit may be canceled or revised at any time by the refuge manager in case of 

emergency (e.g., high fire danger, flooding, unusual resource problems, etc.). 

 The permittee or his/her designee shall notify the refuge manager during refuge working 

hours in person or by telephone before beginning and upon completing activities allowed 

by this permit. 

 The permittee shall provide the refuge manager with a report including the number of 

trees harvested, estimate of size (length & diameter) of logs, and which area(s) logs were 

harvested from) under this permit within 30 days of permit expiration. 

 In accordance with the Archaeological Resources Protection Act (16 U.S.C. 470aa), the 

removal or disturbance of archaeological or historical artifacts is prohibited. The 

excavation, disturbance, collection, or purchase of historical, ethnological, or archaeological 

specimens or artifacts is prohibited. 

 Permittees shall maintain their use areas in a neat and sanitary condition. Latrines must 

be located at least 150 feet from springs, lakes, and streams to avoid contamination of 

water resources. All property (except cabins and/or tent frames) of the permittee must be 

removed from refuge lands upon completion of permitted activities. 

 The construction of landing strips or pads is prohibited. Incidental hand removal of rocks 

and other minor obstructions may be permitted. 

 The use of off-road vehicles (except snowmobiles with adequate snow cover) is prohibited 

unless specifically authorized in writing in this permit. 

 Fuel caches are allowed only in designated areas and must be approved by the refuge 

manager or his or her designate prior to caches being established. If caches are established, 

fuel containers must be clearly marked with the permittee’s name, address, local contact 

telephone number, and type of fuel. 

 Construction of cabins or other permanent structures is prohibited. 

 This permit authorizes use on State selected lands. If any of these lands are conveyed 

during the term of this permit, the permittee will no longer be authorized to use those 

lands until and unless permission is obtained from the Alaska Department of Natural 

Resources. 

 This permit authorizes use only on the Native selected lands specifically identified in the 

description block of this permit. If any of these Native selected lands are conveyed during the 

F-42 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

term of this permit, the permittee will no longer be authorized to use those lands unless 

permission is obtained from the Native corporation to which land ownership has been 

conveyed. 

 Any action by a permittee or the permittee's employees that unduly interferes with or 

harasses other refuge visitors or impedes access to any site is strictly prohibited. 

Examples of prohibited acts include but are not limited to 1) intentional low flights over 

camps or persons at less than 500 feet, except when necessary for takeoff and landing; 2) 

parking aircraft or placing other objects (rocks, tents, etc.) on any landable area so as to 

restrict use by other aircraft; 3) otherwise intentionally interfering in the activity of other 

refuge users; and 4) engaging in activity which is contrary to State and Federal laws.

Refuge Special Conditions

 All garbage and non-combustible debris will be removed from the refuge. Food, garbage, 

and/or other materials will be stored so as not to attract bears and other wildlife. 

 Collection of logs is limited to permitted area. 

 The permit authorizes the harvest of logs only for permittee’s personal use for 

construction of subsistence cabins and houses. Harvest of logs for commercial use is 

prohibited. 

 The permittee is not authorized to clear cut or group harvest an area, and is required to 

follow selective cutting procedures when harvesting trees (e.g., after harvesting one tree, 

the next tree harvested must be a minimum of 100 feet away from the previously cut tree). 

 This 100-foot restriction does not apply to trees that are ready to fall in the river 

(“leaners”). Trees should be cut no closer than 10 feet from the river banks, although 

“leaners” may be cut if desired. 

 The permittee is required to lop and scatter all slash (i.e., all branches must be cut off the 

bole, with the remaining bole cut every four feet). Cut limbs may not be concentrated on 

the site—all tree harvest debris must be scattered to avoid fuel accumulations and 

eliminate potential spruce bark beetle habitat. 

 The permittee is required to utilize as much of the harvested tree as possible. 

Justification: 

One of the purposes of Innoko Refuge is to provide for continued subsistence uses by local 

residents, consistent with the other refuge purposes of conserving fish and wildlife populations 

and habitats in their natural diversity and fulfilling international treaty obligations with respect to 

fish and wildlife. ANILCA recognized that the continued opportunity for subsistence uses of 

public lands is critical to the physical, economic, traditional, social, and cultural existence of rural 

residents of Alaska. ANILCA established a preference for subsistence users, stating that the 

taking of fish and wildlife on public lands for non-wasteful subsistence use is given priority over 

other consumptive uses. Previous studies on a nearby refuge estimated the allowable sustainable 

cut for house logs. Our management of log cutting permits on Innoko Refuge will strive to allow 

cutting at sustainable rates. Section 811 of ANILCA ensures that subsistence users can access 

public lands by snowmobile, motorboat, and other traditionally used means of transportation, 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-43 
Appendix F: Compatibility Determinations 

subject to reasonable regulation. After fully considering the impacts of these activities, as 

described previously in the “Anticipated Impacts of the Use” section of this determination, it is my 

determination that subsistence house-log gathering within the refuge does not materially interfere 

with or detract from the purposes of the refuge or mission of the National Wildlife Refuge System. 

Supporting Documents: 

Code of Federal Regulations, 50, U.S. Government Printing Office, Washington: 2003. 

Division of Forestry, Department of Natural Resources, 2000. Alaska Forest Resources and 

Practices Regulations. 

Klein, David R., David F. Murray, Robert H. Armstrong, and Betty A. Anderson. 2005. 

Status and Trends of the Nation’s Biological Resources. Alaska. 

http://biology.usgs.gov/s+t/SNT/noframe/ak177.htm 

Lambrecht, R. 2004. Forest Inventory - Nowitna NWR Islands. Unpubl. report in files, USFWS, 

Galena, AK. 4pp. 

McGee, R. and E. W. McIntosh. 1984. Local resident harvest inventory – Phase II, Upper 

Koyukuk Subsistence Study. U.S. Fish and Wildlife Service, Kanuti NWR, Fairbanks, AK. 16pp. 

Strong, B.J. and E.W. McIntosh. 1985. Resource harvest by local residents of the Upper 

Koyukuk Region in 1984. U.S. Fish and Wildlife Service, Kanuti NWR, Fairbanks, AK. 51 pp. 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service. Anchorage, AK. 

USFWS. 1992. Subsistence Management for Federal Public Lands in Alaska, Final 

Environmental Impact Statement, Record of Decision, April 2, 1992. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: __/s/ Kent A. Sundseth, acting___________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: _/s/ Todd J. Logan___________________ December 19, 2008

 (Signature) (Date) 

F-44 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Mandatory 10-year Re-evaluation Date (for allowed uses only): 2018

NEPA compliance for Refuge Use Decision: 

___________ Categorical Exclusion without Environmental Action Memorandum 

___________ Categorical Exclusion and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

___________ Environmental Impact Statement and Record of Decision 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-45 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: Scientific Research 

Primary Use: Research and surveys. 

Supporting and Incidental Uses: Fixed-wing aircraft landings, helicopter landings, boating 

(motorized and non-motorized), snowmobiling, environmental education and interpretation (not 

conducted by refuge staff or authorized agents), fishing, firewood cutting, trapping, natural 

resource gathering, camping, picnicking, cross-country skiing, hiking and backpacking, wildlife 

photography, videography, and audio recording, snorkeling and scuba diving, snowshoeing, 

swimming and beach use, scientific collecting, wildlife observation. 

Refuge Name: Innoko National Wildlife Refuge 

Establishing and Acquisition Authority: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

F-46 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-47 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C.668dd-668ee]). 

Description of Use: 

This compatibility determination is a re-evaluation of an existing public use that was originally 

found to be compatible in 1992. Scientific research has been and would continue to be a common 

activity within Innoko Refuge. Research activities would occur at all times of the year but mostly 

in the spring, summer, and fall. A partial list of research categories includes biology, ecology, 

botany, entomology, geology, climatology, paleontology, archaeology, paleoecology, sociology, 

hydrology, and anthropology. 

This compatibility determination addresses the full spectrum of uses associated with the scientific 

research and surveys of fish, wildlife, habitat, and other refuge resources. It includes all means of 

access, lodging and facilities, and other elements identified in the research proposal. Research 

proposals that substantially differ in scope and purpose from the activities covered by this 

compatibility determination will require a separate determination for compatibility. The scope of 

this determination includes research conducted by all agencies or entities other than the Service. 

Scientific research that is part of a collaborative effort or part of a cooperative effort with the U.S. 

Fish and Wildlife Service is not subject to a formal compatibility determination.1

 

Most activities occur during spring, summer, and fall, but winter research and surveys are also 

possible. Since establishment, Innoko Refuge has issued one to four scientific research permits 

annually. Permits have been issued primarily to universities for academic research and to other 

government agencies, such as the U.S. Geological Survey, the Bureau of Land Management, the 

U.S. Forest Service, and State agencies. 

Scientific research may employ a wide spectrum of methods from many disciplines of science. 

Researchers would be required to submit investigation plans or proposals, annual activity reports, 

and copies of publications resulting from the research. Proposed research and investigation plans 

developed for research on the refuge are expected to be peer reviewed. The type and level of 

review should be commensurate with the potential significance of the scientific information and its 

likely influence on policy and management actions. Researchers would also be encouraged to 

communicate research activities and findings to refuge staff, communities near the refuge, and the 

public. 

Researchers will be required to minimize impacts on refuge resources and on other users of refuge 

lands, and to minimize negative encounters with wildlife. When justified to collect important data 

not otherwise available, lethal sampling may be allowed. All applicable permits related to lethal 

sampling must be obtained. Equipment for sampling may include both hand-powered and 

motorized instruments (tools). Logistical support for research activities may include base camps 

with tents, tent frames, spike camps, weatherports, removable floors, existing administrative 

cabins, satellite communication systems, human waste management, and temporary fuel and 

supply caches. Any scientific research activity that involves an invasive procedure or that harms or 

 

1 Scientific research done by the Service is a refuge management activity and thus is exempt from the compatibility 

determination process. Regulations at 50 CFR 25.12 defines refuge management activities as any activity conducted by 

the Service or a Service-authorized agent to fulfill one or more purposes of the National Wildlife Refuge, or the National 

Wildlife Refuge System Mission. Service-authorized agents include contractors, cooperating agencies, cooperating 

associations, refuge support groups, and volunteers. 
Appendix F: Compatibility Determinations 

materially alters the behavior of an animal under study must be reviewed and approved by a 

recognized Institutional Animal Care and Use Committee pursuant to the Animal Welfare Act 

before implementing field work. 

When a special use permit is required, stipulations are included to ensure compatibility. When 

requested, the permittee would provide logistical support for site visits. Logistical support may 

include transportation from McGrath or a community adjacent to the refuge. An administrative 

fee is charged to private companies and for-profit organizations seeking to do research or data 

collection on the refuge. This fee is waived for research associated with public agencies and 

educational institutions. 

Specific authorized means of access for all areas on the refuge will be described in each special use 

permit. Potential means of access include fixed-wing aircraft, helicopter, motor boats, nonmotorized boats, hiking, snowshoeing, snowmobiles (providing there is adequate snow cover), and 

cross-country skiing. Requests for access by helicopter are anticipated and would be considered on 

a case-by-case basis with regard to refuge purposes, helicopter use in the Innoko Wilderness will 

be required to meet a the minimum tool requirement through the “Minimum Requirements 

Decision Guide” process. 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage research activities 

at existing and projected levels. Administrative staff time primarily involves phone conversations, 

written correspondence, proposal review, and interaction with researchers. Field work associated 

with administering the program primarily involves monitoring researchers’ compliance with the 

terms of the permit. Total staff time required is less than two weeks per year. 

Anticipated Impacts of the Use: 

The refuge manager will assist the applicant with obtaining appropriate collection permits for 

research involving fish and wildlife. Factors such as targeted research species, number of 

researchers, transportation modes, number of aircraft and amount of aircraft use, number of 

watercraft and frequency of use, fuel storage, garbage and human waste management, type and 

location of lodging, and location of access points will determine the extent of impacts on the refuge. 

 The introduction of invasive species carried on boats or aircraft floats could affect refuge 

resources. There have been a limited number of invasive species introductions on Innoko Refuge 

and refuge staff will be vigilant to prevent future occurrences. 

Frequency of this activity may rise in the next 10 years as interest in arctic and sub-arctic 

ecosystems and global climate change increases. This could lead to more aircraft landings, natural 

resource collection, and conflicts with refuge visitors. However, special conditions imposed on 

scientific research and associated activities would ensure these activities would not have 

significant impacts on wildlife resources, water quality, soil, vegetation; or other refuge users, 

especially subsistence users. Anticipated impacts to natural resources and refuge visitors from 

this activity at present levels, as well as the levels expected to occur in the next 10 years, are 

minimal. 

F-48 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the Refuge’s Comprehensive 

Conservation Plan. The State of Alaska requested clarification that special use permits are not 

required for all scientific research under the “Description of Use” section. We made the 

requested change. 

Refuge Determination (check one below):

 Use is Not Compatible 

X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

Refuge staff will monitor all research being conducted on the refuge. Findings from monitoring will 

be used to determine what additional management actions, if any, are needed to ensure research 

activities remain compatible with refuge purposes. Unless access is specifically authorized as part of 

a cooperative research project with the Service, seasonal access limits may apply to research 

activities. 

A special use permit with stipulations is required for most scientific research on Innoko Refuge. 

The permit includes details of the specific research. In the following section are typical special use 

permit stipulations, some of which are necessary for compatibility. Site-specific special use 

conditions related to maintenance of defensible space will be incorporated into permits on a caseby-case basis. Other project specific stipulations may be included in individual permits. 

Continued monitoring of all authorized research activities will be carried out to ensure compliance 

with specific terms and conditions tailored for each research project’s permit and to ensure that 

permittee is following general conditions that are incorporated into all research permits to minimize 

impacts on refuge lands and resources. 

Regional Standard Special Conditions:

 Failure to abide by any part of this special use permit; violation of any refuge related 

provision in titles 43 (part 36) or 50 (subchapters B and C) Code of Federal Regulations; or 

violation of any pertinent State regulation (e.g., fish or game violation) will, with due 

process, be considered grounds for immediate revocation of this permit and could result in 

denial of future permit requests for lands administered by the U.S. Fish and Wildlife 

Service. This provision applies to all persons working under the authority of this permit 

(e.g., assistants). Appeals of decisions relative to permits are handled in accordance with 

50 Code of Federal Regulations 36.41. 

 The permittee is responsible for ensuring that all employees, party members, contractors, 

aircraft pilots, and any other persons working for the permittee and conducting activities 

allowed by this permit are familiar with and adhere to the conditions of this permit. 

 Any problems with wildlife and/or animals taken in defense of life or property must be 

reported immediately to the refuge manager and the Alaska Department of Fish and 

Game, and animals taken must be salvaged in accordance with State regulations. 

 This permit does not grant the permittee and his/her employees or coworkers exclusive 

use of the site(s) or lands covered by the permit. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-49 
Appendix F: Compatibility Determinations 

 This permit may be canceled or revised at any time by the refuge manager in case of 

emergency (e.g., high fire danger, flooding, unusual resource problems, etc.). 

 The permittee or his/her designee shall notify the refuge manager during refuge working 

hours in person or by telephone before beginning and upon completing activities allowed 

by this permit. 

 Prior to beginning activities allowed by this permit, the permittee shall provide the refuge 

manager with (1) the name and method of contact for the field party chief and/or 

supervisor; (2) the aircraft and other vehicle types to be used, including identification 

information; (3) names of assistant guides and helpers; and (4) any changes to information 

provided in the original permit application. 

 The refuge manager, upon request, shall be afforded the opportunity and logistical support 

from the nearest commercial transportation site to accompany the permittee for the 

purpose of inspection and monitoring permittee activities. A final inspection trip provided 

by the permittee of the areas of use may be required by the refuge manager to determine 

compliance with the terms of this permit. 

 The permittee shall provide the refuge manager with a report of activities under this 

permit within 30 days of permit expiration. 

 In accordance with the Archaeological Resources Protection Act (16 U.S.C. 470aa), the 

removal or disturbance of archaeological or historical artifacts is prohibited. The 

excavation, disturbance, collection, or purchase of historical, ethnological, or archaeological 

specimens or artifacts is prohibited. 

 Permittees shall maintain their use areas in a neat and sanitary condition. Latrines must 

be located at least 150 feet from springs, lakes, and streams to avoid contamination of 

water resources. All property (except cabins and/or tent frames) of the permittee must be 

removed from refuge lands upon completion of permitted activities. 

 The construction of landing strips or pads is prohibited. Incidental hand removal of rocks 

and other minor obstructions may be permitted. 

 The use of off-road vehicles (except snowmobiles with adequate snow cover) is prohibited 

unless specifically authorized in writing in this permit. 

 The operation of aircraft at altitudes and in flight paths resulting in the herding, 

harassment, hazing, or driving of wildlife is prohibited. It is recommended that all aircraft, 

except for takeoff and landing, maintain a minimum altitude of 2,000 feet above ground. 

 The use of helicopters may be authorized, provided that landing is prohibited except for the 

direct support of the activity covered by this permit and emergencies (no recreational use of 

helicopters is permitted), and no clearing of vegetation for landing and/or takeoff is 

permitted. 

 Fuel caches are allowed only in designated areas and must be approved by the refuge 

manager or his/her designate prior to caches being established. If caches are established, 

fuel containers must be clearly marked with the permittee’s name, address, local contact 

telephone number, and type of fuel. 

 Construction of cabins or other permanent structures is prohibited. 

F-50 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

 This permit authorizes use on State selected lands. If any of these lands are conveyed during 

the term of this permit, the permittee will no longer be authorized to use those lands until 

and unless permission is obtained from the Alaska Department of Natural Resources. 

 This permit authorizes use only on the Native selected lands specifically identified in the 

description block of this permit. If any of these Native selected lands are conveyed 

during the term of this permit, the permittee will no longer be authorized to use those 

lands unless permission is obtained from the Native corporation to which land ownership 

has been conveyed. 

 Any action by a permittee or the permittee's employees that unduly interferes with or 

harasses other refuge visitors or impedes access to any site is strictly prohibited. 

Examples of prohibited acts include but are not limited to 1) intentional low flights over 

camps or persons at less than 500 feet, except when necessary for takeoff and landing; 2) 

parking aircraft or placing other objects (rocks, tents, etc.) on any landable area so as to 

restrict use by other aircraft; 3) otherwise intentionally interfering in the activity of other 

refuge users; and 4) engaging in activity that is contrary to State and Federal laws. 

Refuge Special Conditions:

 All information, reports, photos, data, collections, and observations obtained as a result 

of this permit must be accessible from the permittee at any time upon request by the 

Service at no cost unless specific arrangements are made to the contrary. The Service 

recognizes the proprietary nature of scientific data and will respect the researcher’s 

privileged position regarding first publication. These data may be used in resource 

management decisions by the Service prior to their publication, however. Proprietary 

data of commercial value will be treated confidentially upon request but may also be 

used in management decisions. 

 Prior to implementing field work, the permittee must provide documentation that activities 

that involve an invasive procedure that harms or materially alters the behavior of an 

animal under study have been reviewed and approved by an Institutional Animal Care and 

Use Committee (IACUC) pursuant to the Animal Welfare Act. 

 Some activities may not be permitted in certain areas and/or during some sensitive time 

periods. Area closures and effective dates may be modified by the refuge manager as 

needed. Specific authorization to use localities within special areas may sometimes be 

obtained on a case-by-case basis, depending on the location of animal concentrations, high 

public use areas, access routes, proposed activity, within Wilderness, etc. 

 

Justification: 

Section 101 of ANILCA states, in part, the intent of Congress to maintain opportunities for scientific 

research on conservation system units, including National Wildlife Refuges. The U.S. Fish and 

Wildlife Service supports research as described in the Refuge Manual (4 RM 6.1), which states: 

“Natural and social science information is necessary for the proper management of the 

National Wildlife Refuge System. It is the policy of the Service to encourage and support 

research and management studies in order to provide scientific data upon which decisions 

regarding management of units of the refuge system may be based. The Service will also 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-51 
Appendix F: Compatibility Determinations 

permit the use of a refuge for other investigatory scientific purposes when such use is 

compatible with the objectives for which the refuge is managed. Priority will be given to 

studies that contribute to the enhancement, protection, use, preservation, and 

management of native wildlife populations and their habitats in their natural diversity.” 

The refuge manager also may permit the use of a refuge for other investigatory purposes when 

such use is compatible with the purposes for which the refuge is managed. Priority will be given to 

studies that contribute to the enhancement, protection, use, conservation, and management of 

native wildlife populations and their habitats in their natural diversity. All proposed research 

conducted by other agencies or entities will be thoroughly evaluated prior to authorization and 

then monitored closely to ensure that the activities do not materially interfere with or detract from 

the purposes of the refuge or the mission of the National Wildlife Refuge System. 

Scientific investigations of wildlife, resources, and social interactions will support the refuge’s 

ability to provide for wildlife-dependent priority public uses and to meet other refuge purposes. 

These investigations must be conducted safely. After fully considering the impacts of this activity, 

as described previously in the “Anticipated Impacts of the Use” section of this determination, it is 

my determination that scientific research activities within the refuge do not materially interfere 

with or detract from the purposes of the refuge or mission of the National Wildlife Refuge System. 

Supporting Documents: 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service. Anchorage, AK. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: __/s/ Kent A. Sundseth, acting__________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: _/s/ Todd J. Logan__________________ December 19, 2008

 (Signature) (Date) 

Mandatory 10-Year Re-evaluation Date (for allowed uses only): 2018

NEPA Compliance for Refuge Use Decision: 

__________Categorical Exclusion without Environmental Action Memorandum 

__________Categorical Exclusions and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

__________Environmental Impact Statement and Record of Decision 

F-52 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: Helicopter Landings to Support Authorized Activities by Other Federal, Tribal, State, and 

Local Governments, Universities, etc. 

Primary Use: Helicopter landings.

Supporting and Incidental Uses: Research, scientific collecting, surveying, rights-of-way (utility). 

Refuge Name: Innoko National Wildlife Refuge 

Establishment and Acquisition Authority: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

 

Innoko Refuge Purpose: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C. 668dd-668ee]). 

Description of Use: 

This determination re-evaluates helicopter use to support authorized activities of local, State, or 

tribal governments; other Federal agencies; or universities. This use was originally found to be 

compatible in the refuge Comprehensive Conservation Plan (1987). One to four applications per 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-53 
Appendix F: Compatibility Determinations 

year are normally received to allow helicopter landings as part of some other authorized use such 

as scientific research (geologic, fire ecology, archaeology, etc.), State of Alaska wildlife capture 

work, and fish or wildlife surveys. Permits could be issued at any time of the year but are most 

likely to be for activities during spring, summer, or fall. Routine State law enforcement use of 

helicopters would typically be limited to special cases and would normally be preceded by close 

coordination between the Alaska State Troopers and the refuge manager. 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage helicopter use to 

support authorized activities at existing levels. Administrative staff time primarily involves phone 

conversations and written correspondence. Field work associated with administering the use 

primarily involves monitoring compliance with the terms of the permit. It is estimated that less 

than a week of staff time is required to manage this use on Innoko Refuge. 

Anticipated Impacts of the Use: 

Adverse impacts associated with helicopter landings on the refuge would be associated with 

displacement of wildlife, particularly during ungulate calving and bird nesting seasons (Calef et al. 

1976, Gunn et al. 1985, Miller 1994, Ward et al. 1994). The experience of refuge visitors could also 

be adversely affected by noise disturbance. Hunters would likely be especially vulnerable to 

disturbance by helicopters, because of wildlife displacement and noise. 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the refuge’s Comprehensive 

Conservation Plan. The State of Alaska requested that we change the Regional Special Use 

Permit Condition regarding helicopter use. We did not make the requested change. The section 

previous to the special conditions states, “In the following section are typical special use permit 

stipulations, some of which are necessary for compatibility.” The specifics of any helicopter 

landings special use permit will be addressed in the face of the permit and the special conditions 

attached to that permit. 

Refuge Determination (check one below): 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

A special use permit with stipulations is required for most helicopter landings on Innoko Refuge. 

The permit includes details of the specific use. In the following section are typical special use 

permit stipulations, some of which are necessary for compatibility. Site-specific special use 

conditions related to maintenance of defensible space will be incorporated into permits on a caseby-case basis. Other specific stipulations may be included in individual permits. Monitoring will 

be carried out to ensure compliance with the terms of the permit (including the special conditions) 

to minimize impacts on lands and resources within the refuge. 

F-54 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Regional Standard Special Conditions 

 Failure to abide by any part of this special use permit; violation of any refuge related 

provision in titles 43 (part 36) or 50 (subchapters B and C) of the Code of Federal 

Regulations; or violation of any pertinent State regulation (e.g., fish or game violation) will, 

with due process, be considered grounds for immediate revocation of this permit and could 

result in denial of future permit requests for lands administered by the U.S. Fish and 

Wildlife Service. This provision applies to all persons working under the authority of this 

permit (e.g., assistants). Appeals of decisions relative to permits are handled in accordance 

with 50 Code of Federal Regulations 36.41. 

 The permittee is responsible for ensuring that all employees, party members, contractors, 

aircraft pilots, and any other persons working for the permittee and conducting activities 

allowed by this permit are familiar with and adhere to the conditions of this permit. 

 Any problems with wildlife and/or animals taken in defense of life or property must be 

reported immediately to the refuge manager and the Alaska Department of Fish and 

Game, and animals taken must be salvaged in accordance with State regulations. 

 This permit does not grant the permittee and his/her client’s exclusive use of the site(s) or 

lands covered by the permit. 

 This permit may be canceled or revised at any time by the refuge Manager for 

noncompliance or in case of emergency (e.g., public safety, unusual resource problems). 

 The permittee or his/her designee shall notify the refuge manager during refuge working 

hours in person or by telephone before beginning and upon completing activities allowed 

by this permit. 

 Prior to beginning activities allowed by this permit, the permittee shall provide the refuge 

manager with (1) the name and method of contact for the field party chief and/or 

supervisor; (2) the aircraft and other vehicle types to be used, including identification 

information; (3) names of assistant guides and helpers; and (4) any changes to information 

provided in the original permit application. 

 The refuge manager, upon request, shall be afforded the opportunity and logistical support 

from the nearest commercial transportation site to accompany the permittee for the 

purpose of inspecting and monitoring permittee activities. A final inspection trip provided 

by the permittee of the areas of use may be required by the refuge manager to determine 

compliance with the terms of this permit. 

 The permittee shall provide the refuge manager with a report of activities under this 

permit within 30 days of permit expiration unless stated otherwise in the permit. 

 In accordance with the Archaeological Resources Protection Act (16 U.S.C. 470aa), the 

removal or disturbance of archaeological or historical artifacts is prohibited. The 

excavation, disturbance, collection, or purchase of historical, ethnological, or archaeological 

specimens or artifacts is prohibited. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-55 
Appendix F: Compatibility Determinations 

 Permittees shall maintain their use areas in a neat and sanitary condition. Latrines must 

be located at least 150 feet from springs, lakes, and streams to avoid contamination of 

water resources. All property (except cabins and/or tent frames) of the permittee must be 

removed from refuge lands upon completion of permitted activities. 

 The construction of landing strips or pads is prohibited. Incidental hand removal of rocks 

and other minor obstructions may be permitted. 

 The use of off-road vehicles (except snowmobiles with adequate snow cover) is prohibited 

unless specifically authorized in writing in this permit. 

 The operation of aircraft at altitudes and in flight paths resulting in the herding, 

harassment, hazing, or driving of wildlife is prohibited. It is recommended that all aircraft, 

except for takeoff and landing, maintain a minimum altitude of 2,000 feet above ground. 

 Fuel caches are allowed only in designated areas and must be approved by the refuge 

manager or his/her designate prior to caches being established. If caches are established, fuel 

containers must be clearly marked with the permittee’s name, address, local contact 

telephone number, and type of fuel. 

 Construction of cabins or other permanent structures is prohibited. 

 All aircraft being used in commercial operations must have 12-inch identification numbers 

in contrasting colors, which are readily visible. 

 This permit authorizes use on State selected lands. If any of these lands are conveyed during 

the term of this permit, the permittee will no longer be authorized to use those lands until 

and unless permission is obtained from the Alaska Department of Natural Resources. 

 This permit authorizes use only on the Native selected lands specifically identified in the 

description block of this permit. If any of these Native selected lands are conveyed during 

the term of this permit, the permittee will no longer be authorized to use those lands 

unless permission is obtained from the Native corporation to which land ownership has 

been conveyed. 

 Any action by a permittee or the permittee's employees that unduly interferes with or 

harasses other refuge visitors or impedes access to any site is strictly prohibited. 

Examples of prohibited acts include but are not limited to 1) intentional low flights over 

camps or persons at less than 500 feet, except when necessary for takeoff and landing; 2) 

parking aircraft or placing other objects (rocks, tents, etc.) on any landable area so as to 

restrict use by other aircraft; 3) otherwise intentionally interfering in the activity of other 

refuge users; and 4) engaging in activity that is contrary to State and Federal laws. 

Refuge-Specific Special Conditions

 All garbage and non-combustible debris will be removed from the refuge. Food, garbage, 

and/or other materials will be stored so as not to attract bears and other wildlife. 

F-56 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

 The permittee will take no action that interferes with subsistence activities of rural users 

or restricts the reasonable access of subsistence users to refuge lands. This may include 

but is not limited to disturbance of wildlife and their movements near subsistence hunters, 

and damage to cabins, trails, traditional campsites or caches used by subsistence users. To 

minimize the potential for conflicts with subsistence users, the permittee must review the 

Innoko National Wildlife Refuge land status maps to ascertain the location of selected and 

conveyed lands within refuge boundaries. 

 Permittee will ensure that all aircraft transiting the refuge actively avoid large mammals 

(including moose, caribou, grizzly bears, black bears, wolves, active bald eagle nests, and 

large flocks of waterfowl). “Active avoidance” includes making a vertical or lateral 

deviation from a flight path within flight safety parameters to minimize or prevent adverse 

impact on the animals. 

 A valid copy of the issued special use permit, signed by the refuge manager or designee, must 

be in the party leader’s possession at all times while exercising the privileges of the permit. 

Justification: 

Under 43 CFR 36.11(4), helicopter use on national wildlife refuges requires a special use permit. 

The 1987 Comprehensive Conservation Plan (page 121, Access and Transportation) states, “The 

use of helicopters will be permitted on the refuge only with the issuance of a special use permit.” 

As only occasional and limited use of helicopters would be authorized, the potential for adverse 

effects to resources and visitors within the refuge would be negligible. It is recommended that all 

aircraft fly 2,000 feet above ground level when possible. When weather conditions do not permit, 

aircraft should maintain an altitude of at least 800 feet above ground level if at all possible. 

Helicopter landings would only be authorized when other means of access are impractical or 

unsafe. After fully considering the impacts of these activities as described previously in the 

“Anticipated Impacts of the Use” section of this document, it is my determination that under 

specific conditions, helicopter use within the refuge does not materially interfere with or detract 

from the purposes of the refuge or mission of the National Wildlife Refuge System. 

Supporting Documents: 

Calef, G.W., E.A. DeBock, and G.M. Lortie. 1976. The reaction of barren-ground caribou to 

aircraft. Arctic 29(4):201-212. 

Gunn, A., F.L. Miller, R. Glaholt and K. Jingfors. 1985. Behavioural responses of barren-ground 

caribou cows and calves to helicopters on the Beverly herd calving grounds, Northwest Territories. In 

Proceedings of the First North American Caribou Workshop, ed. Martell, A.M. and D.E. Russell. 

Whitehorse, Yukon, p10-14. 

Miller, M. W. 1994. Route selection to minimize helicopter disturbance of molting Pacific black 

brant: a simulation. Arctic 47: 341–349. 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service. Anchorage, AK. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-57 
Appendix F: Compatibility Determinations 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Ward, D.H., R.A. Stehn, D.V. Derksen, 1994. Response of staging brant to disturbance at the 

Izembek Lagoon, Alaska. Wildl. Soc. Bull. 22:220-228. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: __/s/ Kent A. Sundseth, acting___________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: _ /s/ Todd J. Logan___________________ December 19, 2008

 (Signature) (Date) 

Mandatory 10-Year Re-Evaluation Date: 2018

NEPA Compliance for Refuge Use Decision: 

 Categorical Exclusion without Environmental Action Memorandum 

 Categorical Exclusions and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

F-58 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: Commercial Transporter Services 

Primary Use: Transporter Services.

Supporting and Incidental Uses: Boating (motorized and non-motorized), fixed-wing aircraft 

landings, environmental education, interpretation, fishing (guided and non-guided), hunting 

(guided and non-guided), trapping, natural resource gathering, camping, picnicking, cross-country 

skiing, dog sledding and skijoring, pets, hiking and backpacking, wildlife photography, 

videography and audio recording, snowshoeing, swimming and beach use, research, scientific 

collecting, surveys, and wildlife observation. 

 

Refuge Name: Innoko National Wildlife Refuge 

Establishing and Acquisition Authority: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-59 
Appendix F: Compatibility Determinations 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C. 668dd-668ee]). 

Description of Use: 

This description of use includes a re-evaluation of the compatibility of use of Federal lands within 

Innoko Refuge for commercial transporter services. These services allow the public to hunt, fish, 

or enjoy other outdoor activities on the remote and largely inaccessible Innoko Refuge. 

Commercial transporter use was originally found to be compatible in 1987 during the development 

of the original Comprehensive Conservation Plan for Innoko Refuge. Commercial transporter use 

was again determined to be compatible in 1992, subject to reasonable regulation. Since 

establishment, Innoko Refuge has issued 4-10 special use permits annually to commercial air taxi 

businesses desiring to provide transportation services within the refuge. In most recent years, 

there have usually been 8-10 commercial transporters permitted to operate on the refuge. These 

transporters have provided services to an average of 35-45 parties per year, primarily for hunting, 

fishing, or river floating. The lengths of typical trips made by commercially transported clients 

are usually in the range of 7-10, although shorter trips sometimes occur. 

The objective of allowing commercial transporter services in national wildlife refuges is to make 

available a variety of quality opportunities for the public to hunt, fish, or enjoy outdoor activities 

where such activities are compatible with the refuge’s purposes, resources, and management 

objectives. Furthermore the Congressional Committee Report on the National Wildlife Refuge 

System Improvement Act of 1997 states: “It establishes as the policy of the United States that 

wildlife-dependent recreation, when it is compatible, is a legitimate and appropriate public use of the 

Refuge System, through which the American public can develop an appreciation for fish and 

wildlife.” 

Most of Innoko Refuge is located within State of Alaska Game Management Unit (GMU) 21A, 

although a small part is within GMU 21E and 21D. Moose, some caribou, black bear, and brown 

bear are available, and wolves and wolverine may be taken incidentally within Innoko Refuge. The 

Paradise Controlled Use Area (PCUA), which includes the southwestern portions of the refuge, 

was established by the State of Alaska in 1981. The PCUA restricts aircraft access for the 

transport of moose hunters, gear, or moose parts. (However, moose hunters, their gear, and/or 

moose parts may be transported by aircraft between publicly owned airports in the controlled use 

area or between a publicly owned airport within the area and points outside the area.) The PCUA 

is bounded by a line beginning at the old village of Paimiut, then north along the west bank of the 

Yukon River to Paradise, then northeast to the mouth of the Anvik River, then along the west 

bank of the Yukon River to the lower end of Eagle Island (approximately 45 miles north of 

Grayling), then to the mouth of the Iditarod River, then down the east bank of the Innoko River to 

its confluence with Paimiut Slough, then south along the east bank of Paimiut Slough to its mouth. 

and then to the old village of Paimiut. State of Alaska hunting regulations (5AAC) describe State 

seasons, bag limits, and regulations pertaining to hunting, fishing, and trapping. 

Commercial transporters provide a service that most non-local visitors require to access the 

refuge. Most commercial transporting activities on Innoko Refuge are conducted by air taxis with 

float-equipped aircraft. There are also two commercial boat transporters permitted on the refuge. 

 Transporters are required, as a condition of their permits, to provide information on the primary 

activity, location, length of stay, group size, and other related items. These reports provide the 

most accurate and reliable information the Service has on refuge use by unguided visitors. 

F-60 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Commercial transporter-related services contribute to fulfillment of refuge purposes and the 

National Wildlife Refuge System mission by providing access for refuge visitors unable to provide 

their own access, and therefore facilitate priority public uses such as recreational hunting, fishing, 

and wildlife observation, and other uses found compatible in separate compatibility 

determinations. Many of these compatible public uses contribute directly to maintaining healthy 

fish and wildlife populations through managed use. 

Operators are required to submit an annual report of client trips to refuge lands. There is 

currently no limit to the number of trips or clients air taxi operators can take to the refuge, nor is 

there a limit to the number of air taxi operators permitted to operate on Innoko Refuge. There is 

an open period in the spring in which all commercial transporters must apply for their special use 

permits for that year: this action prohibits an operator from accepting a number of clients at the 

last moment and just dropping clients off, potentially producing an overcrowded situation. This is 

an existing activity that supports wildlife-dependent priority public uses. Activities generally 

occur May through September since timing typically coincides with State fishing and hunting 

seasons. 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage commercial 

transporter service activities at existing and projected levels. Administrative staff time primarily 

involves reviewing permit applications, responding to applicants, issuing and renewing special use 

permits and collecting client use fees. Field work associated with administering the program 

primarily involves patrolling during hunting and fishing seasons to monitor permittees’ 

compliance with permit terms, and to determine whether unpermitted operators are using the 

refuge. It is anticipated that this use will require a total of one week of staff time for permit 

issuance and/or renewal, activity reporting, administration of use-day fees, and field compliance 

checks. An administrative fee of $100 fee is assessed when each special use permit is issued. In 

addition, client use-day fees are assessed for each day a transporter drops off and/or picks up a 

client on the refuge. Fees collected are returned to the refuge to administer the program. 

Anticipated Impacts of the Use: 

Impacts associated with the activities that occur on Innoko Refuge as a result of commercial 

transporters providing the public access to the refuge are addressed in the respective 

compatibility determinations for each activity. The refuge is directly involved in review and 

implementation of the regulatory process and administrative oversight of the activity. Because of 

combined law enforcement efforts of State and refuge personnel, direct impacts from commercial 

transporter services under existing management should have minimal affects to fish and wildlife 

resources within the refuge, other resources, or other visitors. 

Available moose hunting areas outside of the PCUA are concentrated in narrow river corridors 

along the Innoko Refuge river systems and hence do not afford compelling opportunities for users 

to hunt in isolation or with little competition. Commercially transported non-local big game 

hunters may, in some cases, result in some competition or interference with subsistence users for 

the limited number of game animals in these corridors. Refuge staff are aware of these potential 

conflicts and monitor use levels each hunting season. Should conflicts arise, the Service will work 

to address them through the Federal Subsistence Board and Alaska Board of Game. These 

Boards have established regulations aimed at managing populations of animals at sustainable 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-61 
Appendix F: Compatibility Determinations 

levels and avoiding conflicts between user groups. The refuge staff was a very active cooperator in 

the completion of the State’s Unit 21E Moose Management Plan; implementation of which will 

hopefully alleviate some of these issues. 

Impacts to refuge habitats would be minimal and transitory because access to the refuge would be 

primarily by landing float-equipped aircraft on lakes and rivers, or by boats on the same rivers. 

Landings on vegetated lowland tundra and disturbance to vegetation would be limited under the 

stipulations of the special use permit. The introduction of invasive species carried on aircraft 

floats and boat hulls could affect refuge resources, although it is not known to have occurred via 

this transmission method within Innoko Refuge to date, and staff will be vigilant to prevent such 

occurrences. In addition, frequent aircraft traffic could impact nesting, molting or staging birds 

(Ward et al. 1994). Winter access would be by aircraft fitted with skis. Disturbance to vegetation 

would be limited by conditions within the special use permit. Temporary displacement and/or 

disturbance to wildlife can occur in response to low level overflights and during takeoffs and 

approaches to landings (Calef et al. 1976), but impacts would likely be short term and minimal. 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the refuge’s Comprehensive 

Conservation Plan. The State of Alaska requested we add the word “potentially” in front of 

“producing an overcrowded situation” in the last paragraph of the “Description of Use” section. 

We made the change. 

Refuge Determination (check one below): 

___ Use is Not Compatible 

X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

A special use permit with stipulations is required for commercial transporter services. The permit 

includes the details of the services provided. In the following section are typical special use permit 

conditions, some of which are necessary for compatibility. Site-specific special use conditions related 

to maintenance of defensible space will be incorporated into permits on a case-by-case basis. 

Continued law enforcement and administrative monitoring of permittees will be carried out to ensure 

compliance with the terms of the permits including the special conditions. and to minimize impacts to 

refuge lands and resources. 

Regional Standard Special Conditions

 Failure to abide by any part of this special use permit; violation of any refuge related 

provision in titles 43 (part 36) or 50 (subchapters B and C) of the Code of Federal 

Regulations; or violation of any pertinent State regulation (e.g., fish or game violation) will, 

with due process, be considered grounds for immediate revocation of this permit and could 

result in denial of future permit requests for lands administered by the U.S. Fish and 

Wildlife Service. This provision applies to all persons working under the authority of this 

permit (e.g., assistants). Appeals of decisions relative to permits are handled in accordance 

with 50 Code of Federal Regulations 36.41. 

F-62 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

 The permittee is responsible for ensuring that all employees, party members, contractors, 

aircraft pilots, and any other persons working for the permittee and conducting activities 

allowed by this permit are familiar with and adhere to the conditions of this permit. 

 Any problems with wildlife and/or animals taken in defense of life or property must be 

reported immediately to the refuge manager and the Alaska Department of Fish and 

Game, and must be salvaged in accordance with State regulations. 

 This permit does not grant the permittee and his/her clients’ exclusive use of the site(s) or 

lands covered by the permit. 

 This permit may be canceled or revised at any time by the refuge manager in case of 

emergency (e.g., high fire danger, flooding, unusual resource problems, etc.). 

 The permittee or his/her designee shall notify the refuge manager during refuge working 

hours in person or by telephone before beginning and upon completing activities allowed by 

this permit. 

 Prior to beginning activities allowed by this permit, the permittee shall provide the refuge 

manager with (1) the name and method of contact for the field party chief and/or supervisor; 

(2) the aircraft and other vehicle types to be used, including identification information; (3) 

names of assistant guides and helpers; and (4) any changes to information provided in the 

original permit application. 

 The permittee shall maintain, throughout the use period specified on this permit, 

insurance (passenger liability of $150,000 per seat plus $100,000 on property) covering 

his/her refuge air taxi/transporter operations. This insurance is required for all aircraft 

operations involving clients. 

 The permittee shall provide the refuge manager with a report that includes the number 

and species of all animals transported, pick up and drop off locations, numbers of clients, 

and number of client use days per type of activity. This report is due within 30 days of 

permit expiration unless stated otherwise in the permit. For law enforcement purposes, 

the permittee may be required to provide names and addresses of clients. 

 In accordance with the Archaeological Resources Protection Act (16 U.S.C. 470aa), the 

removal or disturbance of archaeological or historical artifacts is prohibited. The 

excavation, disturbance, collection, or purchase of historical, ethnological, or archaeological 

specimens or artifacts is prohibited. 

 Permittees shall maintain their use areas in a neat and sanitary condition. Latrines must 

be located at least 150 feet from springs, lakes, and streams to avoid contamination of 

water resources. All property (except cabins and/or tent frames) of the permittee must be 

removed from refuge lands upon completion of permitted activities. 

 The construction of landing strips or pads is prohibited. Incidental hand removal of rocks 

and other minor obstructions may be permitted. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-63 
Appendix F: Compatibility Determinations 

 The use of off-road vehicles (except snowmobiles with adequate snow cover) is prohibited 

unless specifically authorized in writing in this permit. 

 The operation of aircraft at altitudes and in flight paths resulting in the herding, harassment, 

hazing, or driving of wildlife is prohibited. It is recommended that all aircraft, except for 

takeoff and landing, maintain a minimum altitude of 2,000 feet above ground level. 

 Fuel caches are allowed only in designated areas and must be approved by the refuge 

manager or his/her designate prior to caches being established. If caches are established, fuel 

containers must be clearly marked with the permittee’s name, address, local contact 

telephone number, and type of fuel. 

 Construction of cabins or other permanent structures is prohibited. 

 All aircraft being used in commercial operations must have 12-inch identification numbers 

in contrasting colors, which are readily visible. 

 This permit authorizes use on State selected lands. If any of these lands are conveyed during 

the term of this permit, the permittee will no longer be authorized to use those lands until 

and unless permission is obtained from the Alaska Department of Natural Resources. 

 This permit authorizes use only on the Native selected lands specifically identified in the 

description block of this permit. If any of these Native selected lands are conveyed during 

the term of this permit, the permittee will no longer be authorized to use those lands 

unless permission is obtained from the Native corporation to which land ownership has 

been conveyed. 

 Any action by a permittee or the permittee's employees which unduly interferes with or 

harasses other refuge visitors or impedes access to any site is strictly prohibited. 

Examples of prohibited acts include but are not limited to 1) intentional low flights over 

camps or persons at less than 500 feet, except when necessary for takeoff and landing; 2) 

parking aircraft or placing other objects (rocks, tents, etc.) on any landable area so as to 

restrict use by other aircraft; 3) otherwise intentionally interfering in the activity of other 

refuge users; 4) and engaging in activity which is contrary to State and Federal laws. 

Refuge-Specific Special Conditions

 Motorboat operators must possess U.S. Coast Guard (USCG) licenses for all passengercarrying operations if required by USCG regulations, and all boats will be operated safely 

in accordance with 50 CFR, subpart C, 27.32. 

 The permittee may not sublet any part of the authorized use area and is prohibited from 

subcontracting clients with any other transporter. 

 The permittee will take no action that interferes with subsistence activities of rural users or 

restricts the reasonable access of subsistence users to refuge lands. This may include but is 

not limited to disturbance of wildlife and their movements near subsistence hunters, and 

damage to cabins, trails, traditional campsites, or caches used by subsistence users. To 

F-64 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

minimize potential for conflicts with subsistence users, the permit holder must a) review 

Innoko National Wildlife Refuge land status maps to ascertain location of the Paradise 

Controlled Use Area (when transporting moose hunters) and the location of selected and 

conveyed lands within the refuge boundary; and b) advise clients that campsites may not be 

located on selected or conveyed lands without permission of land owners. A copy of this special 

use permit must be in the airplane at all times while exercising the privileges of the permit. 

Justification: 

Commercial transporting has been found to be compatible with the purposes of Innoko Refuge and 

with the National Wildlife Refuge System Mission. Commercial transporting services provide the 

public with safe access to unique hunting, fishing, wildlife observation, wildlife photography, and 

environmental education opportunities found few places elsewhere in the world. These are all 

activities that the National Wildlife Refuge System Administration Act (as amended) identifies as 

priority public uses. These visitor services are a valuable benefit to a segment of the public that does 

not have other means of access to the extremely remote environment of the refuge. 

Commercial transporters are the Service’s primary source of information about unguided use of 

the refuge. After fully considering the impacts of this activity, as described previously in the 

“Anticipated Impacts of the Use” section of this document, it is my determination that commercial 

transporter activities within the refuge do not materially interfere with or detract from the 

purposes of the refuge or mission of the National Wildlife Refuge System. 

Supporting Documents: 

Calef, G.W., E.A. DeBock, and G.M. Lortie. 1976. The reaction of barren-ground caribou to 

aircraft. Arctic 29(4):201-212. 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service. Anchorage, AK. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Ward, D. H., R. A. Stehn, D. V. Derksen. 1994. Response of staging brant to disturbance at the 

Izembek Lagoon, Alaska. Wildl. Soc. Bull. 22: 220–228. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: __/s/ Kent A. Sundseth, acting___________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: __/s/ Todd J. Logan__________________ December 19, 2008

 (Signature) (Date) 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-65 
Appendix F: Compatibility Determinations 

Mandatory 10-year Re-evaluation Date (for allowed uses only): 2018

NEPA compliance for Refuge Use Decision: 

___________ Categorical Exclusion without Environmental Action Memorandum 

___________ Categorical Exclusion and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

___________ Environmental Impact Statement and Record of Decision 

F-66 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: Commercial Big Game Hunting Guide Services 

Primary Use: Hunting (big-game guiding and outfitting). 

Supporting and Incidental Uses: Fixed-wing aircraft landings, boating (motorized and nonmotorized), snowmobiling, environmental education and interpretation (not conducted by refuge 

staff or authorized agents), fishing, hunting (non big-game), firewood cutting, natural resource 

gathering, camping, picnicking, hiking and backpacking, snowshoeing, pets, swimming and beach 

use, wildlife photography and videography, wildlife observation. 

Refuge Name: Innoko National Wildlife Refuge 

Establishing and Acquisition Authority: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-67 
Appendix F: Compatibility Determinations 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C. 668dd-668ee]). 

Description of Use: 

This is a re-evaluation of the compatibility of use of Federal lands within Innoko Refuge for biggame guided hunting. The compatibility of recreational hunting on Innoko Refuge is evaluated in 

a separate compatibility determination. Compatibility of big game guiding was determined during 

the development of the original Comprehensive Conservation Plan for Innoko Refuge in 1987. 

Guided hunting was again determined to be compatible, subject to reasonable regulation, in 1992. 

Commercial guide services have periodically been offered on the refuge since its establishment in 

1980. Innoko Refuge has three exclusive commercial big-game guiding areas. These areas were 

awarded to three guides to 2005, and to two different guides from 2005 to present. The area was 

reduced from four units to three units to eliminate the competition between subsistence and nonsubsistence hunters in the southwestern corner of the refuge: this area is predominantly 

corporation land. 

The 2005 prospectus under which proposals for big-game guiding on Innoko Refuge were 

solicited states: 

“The objective of allowing commercial big game guiding is to make available to the public 

a variety of quality recreational hunts on areas of the refuge where such activities are 

compatible with the mission of the National Wildlife Refuge System and the refuge’s 

purposes, and consistent with management objectives. Refuge policies require that sport 

hunting must reflect well on the refuge and on the tradition of hunting. It must promote 

positive hunting values and hunter ethics such as fair chase, and provide participants 

with reasonable harvest opportunities, less crowding, less competition, fewer conflicts 

between hunters, relatively undisturbed wildlife, greater hunter safety, less than average 

crippling loss, and less interference from or dependence on mechanized aspects of the 

sport. Commercial guiding activities authorized on refuge lands should contribute to 

these policies.” 

The congressional committee report on the National Wildlife Refuge System Improvement Act of 

1997 states: “It establishes as the policy of the United States that wildlife-dependent recreation, 

when it is compatible, is a legitimate and appropriate public use of the Refuge System, through 

which the American public can develop an appreciation for fish and wildlife.” 

Most of Innoko Refuge is located within State of Alaska Game Management Unit (GMU) 21A, 

although a small part is within GMU 21E and 21D. Moose, black bear, and brown bear are the 

primary species sought after by hunters, but wolves and wolverine may be taken incidentally on 

Innoko Refuge. The Paradise Controlled Use Area (PCUA), which includes the southwestern 

portions of the refuge, was established by the State of Alaska in 1981. The PCUA restricts 

aircraft access for the transport of moose hunters, gear, or moose parts. (However, moose 

hunters, their gear, and/or moose parts may be transported by aircraft between publicly owned 

airports in the controlled use area or between a publicly owned airport within the area and points 

outside the area.) The PCUA is bounded by a line beginning at the old village of Paimiut, then 

north along the west bank of the Yukon River to Paradise, then northeast to the mouth of the 

Anvik River, then along the west bank of the Yukon River to the lower end of Eagle Island 

(approximately 45 miles north of Grayling), then to the mouth of the Iditarod River, then down the 

F-68 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

east bank of the Innoko River to its confluence with Paimiut Slough, then south along the east 

bank of Paimiut Slough to its mouth, and then to the old village of Paimiut. State of Alaska 

hunting regulations (5AAC) describe State seasons, bag limits, and regulations pertaining to 

hunting, fishing, and trapping. 

Big game guides are competitively selected to operate on refuge lands through a formal process, 

established by regional policy in 1992 and later codified (50 CFR subpart F, 36.41). Competitive 

selection is intended to limit or manage commercial guiding to a level compatible with refuge 

purposes and to ensure that quality guiding services are available to the public. Guides must be 

qualified and licensed by the State and are required to follow written operations plans, which are 

evaluated by Service personnel during the competitive selection process. These operations plans 

include 1) dates of field operations; 2) species to be hunted; 3) maximum and expected number of 

clients for each species hunted; 4) number and type of existing or new camps (i.e., tent, tent 

platform. boat), including other needed facilities such as caches and weatherports; 5) access points 

and mode(s) of transportation (e.g., airplanes, boats, snowmobiles, pack animals, and other 

nonmotorized means); 6) fuel storage needs; and 7) services provided by others (e.g., contracts for 

transportation, food services). 

This compatibility determination addresses the full spectrum of uses associated with the overall 

activity of commercially guided hunting of big game, including all means of access, lodging, 

facilities, and other elements identified in the guides’ operations plans. Authorized modes of 

access for all areas within Innoko Refuge include fixed-wing aircraft, motor boats, snowmobiles, 

non-motorized boats, dogsled, foot, snowshoe, and cross-country skis. Lodging and facilities 

include tents, tent frames, tent platforms, weatherports, and caches. The use of off-road vehicles 

by big game hunting guides and their clients is not authorized on Innoko Refuge. 

This is an existing activity that supports wildlife-dependent priority public uses. Activities would 

occur throughout Innoko Refuge during State regulated hunting seasons. 

Availability of Resources: 

Permits are issued competitively for five years, with provision for automatic renewal for a second 

five years. The competitive process requires a significant level of time and effort for the 

applicants, refuge staff, and agency staff. Adequate refuge personnel and base operational funds 

are available to manage guided big-game hunting activities at existing and projected levels. 

Refuge staff participation includes the following. During the initial competitive process, the 

refuge manager spends approximately one month writing and/or reviewing the prospectus, 

conducting guide interviews and making a selection, writing decision documents, and potentially 

dealing with appeals that may result in litigation. The deputy refuge manager assists the refuge 

manager throughout the decision process. After initial selection, the refuge manager may spend 

about 10 days per year on oversight, permit compliance, and other guiding issues. The deputy 

refuge manager may spend one week issuing or renewing permits, administering use-day fee 

collections, monitoring permit compliance, and conducting related activities. Non-refuge staff 

(e.g., law enforcement officers from other refuges or the zone officer for northern refuges) may be 

required to spend an average of one week per year monitoring permit and hunting regulation 

compliance. In summary, administrative staff time primarily involves reviewing applications, 

researching and writing decisions, responding to appeals and conducting regional office briefings 

if appeals occur, issuing and renewing special use permits every five years, ensuring licenses and 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-69 
Appendix F: Compatibility Determinations 

certificates are current; collecting client use-day fees, and reporting data on an annual basis. Field 

work associated with administering the program primarily involves patrolling during hunting 

seasons and monitoring permittees’ compliance with permit conditions. Estimated costs to 

administer commercial guided hunting on Innoko Refuge are over $20,000 in a year during which 

the permit is open to competition, and about $15,000 per year for the intervening years. An 

administrative fee of $100 is assessed when each permit is issued. In addition, client use-day fees 

are assessed for each day a guide has a client on the refuge. Fees collected are returned to the 

refuge to administer the program. 

 

Anticipated Impacts of the Use: 

Criteria in the competitive scoring and selection process used to select big game guide permittees 

attempt to address minimizing impacts to refuge resources and to other visitors. These criteria 

include impacts on wildlife resources; other refuge resources such as water quality, soil, 

vegetation; and other refuge users, especially subsistence users. The criteria address such factors 

as target species, number of clients, transportation modes, amount of aircraft use, fuel storage, 

garbage and human waste management, methods to protect wildlife and habitat, type and location 

of lodging, and location of access points. These selection criteria are used to rank or score 

applicants and provide a strong incentive to maintain a low-impact guide service. Permit 

conditions and stipulations noted in the following sections also contribute to minimizing potential 

impacts. 

Commercial big game hunting is also regulated by the State, and new draft regulations (AS 08.54 

and 12 AAC 75) are under review by the Big Game Commercial Services Board. Commercial big 

game guiding operations may, in some cases, result in some competition or interference with 

subsistence users and/or other non-guided recreational hunters for the limited number of game 

animals in river corridors. Refuge staff members are aware of these potential conflicts and 

monitor use levels each hunting season. Should allocation conflicts arise, the Service will work to 

address them through the Federal Subsistence Board and Alaska Board of Game. These boards 

establish regulations aimed at managing populations of animals at sustainable levels and avoiding 

conflicts among user groups. 

 

Impacts to refuge habitats would be minimal and transitory. Access to the refuge during summer 

months would be primarily by landing float-equipped aircraft on lakes and rivers, or by motor 

boat, or by floating into the refuge. Landings on vegetated lowland tundra and disturbance to 

vegetation would be limited under the stipulations of the special use permit. The introduction of 

invasive species carried on boats and aircraft floats could affect refuge resources. Invasive species 

are not know to have been introduced by this method within Innoko Refuge to date. Refuge staff 

will be vigilant to prevent such occurrences. In addition, frequent motorboat or aircraft traffic 

could affect nesting, molting, or staging birds (Bouffard 1982, Miller 1994, Ward et al. 1994). 

Winter access could be by dog sled, cross-country skis, snowmobile or aircraft fitted with skis. 

Disturbance to vegetation would be limited by conditions within the special use permit. Temporary 

displacement and/or disturbance to wildlife can occur in response to low level overflights and 

during takeoffs and approaches to landings (Calef et al. 1976), but impacts would likely be short 

term and minimal. 

Compliance with regulations and permit conditions will be routinely checked by officers. Refuge 

officers and State wildlife protection officers would routinely patrol the refuge during hunting 

F-70 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

seasons. The use of cabins in association with commercial guiding would be authorized in 

accordance with 50 CFR 36.33. 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the refuge’s Comprehensive 

Conservation Plan. The State of Alaska requested that we note that future allocations would 

utilize the more recent processes described in the Service Manual. The process we use for 

selecting commercial big game hunting guide services follows our Alaska-specific regulations in 50 

CFR 36.41. We did not change the “Description of Use” section of the compatibility 

determination. 

Refuge Determination (check one below): 

___ Use is Not Compatible 

X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

A special use permit with stipulations is required for commercially guided recreational hunting 

services. The permit includes details of the specific operation. In the following section are typical 

special user permit conditions, some of which are necessary for compatibility. Site-specific special 

use conditions related to maintenance of defensible space will be incorporated into permits on a 

case-by-case basis. 

Continued law enforcement and administrative monitoring of permittees will be carried out to 

ensure compliance with the terms of the permit and special conditions to minimize impacts on 

refuge lands and resources. 

Regional Standard Special Conditions

 Failure to abide by any part of this special use permit; violation of any refuge related 

provision in titles 43 (part 36) or 50 (subchapters B and C) of the Code of Federal 

Regulations; or violation of any pertinent State regulation (e.g., fish or game violation) will, 

with due process, be considered grounds for immediate revocation of this permit and could 

result in denial of future permit requests for lands administered by the U.S. Fish and 

Wildlife Service. This provision applies to all persons working under the authority of this 

permit (e.g., assistants). Appeals of decisions relative to permits are handled in accordance 

with 50 Code of Federal Regulations 36.41. 

 The permittee is responsible for ensuring that all employees, party members, aircraft 

pilots, and any other persons working for the permittee and conducting activities allowed 

by this permit are familiar with and adhere to the conditions of this permit. 

 The permittee may not sublet any part of the authorized use area and is prohibited from 

subcontracting clients with any other guide. The permittee must also be personally present 

with each client in the refuge designated use area at least once during each contracted hunt. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-71 
Appendix F: Compatibility Determinations 

 Any problems with wildlife and/or animals taken in defense of life or property must be 

reported immediately to the refuge manager and/or Alaska Department of Fish and Game, 

and must be salvaged in accordance with State regulations. 

 The permittee and permittee’s clients do not have the exclusive use of the site(s) or lands 

covered by this permit, except for the authorized camp facilities. 

 This permit may be canceled or revised at any time by the refuge manager in case of 

emergency (e.g., high fire danger, flooding, unusual resource problems, etc.). 

 The permittee shall notify the refuge manager during refuge working hours, in person or by 

telephone, before beginning and upon completion of annual activities allowed by this permit. 

 Prior to beginning any activities allowed by this permit, the permittee shall provide the 

refuge manager with (1) proof of comprehensive general liability insurance ($300,000 each 

occurrence, $500,000 aggregate) covering all aspects of operations throughout the annual 

use period; (2) aircraft and other vehicle types to be used, with identification information, if 

different from the original permit or previous year; (3) changes in names of assistant 

guides and other employees; and (4) any other changes in information provided in the 

original permit and/or proposed operations plan. 

 The permittee is responsible for accurate recordkeeping and will provide the refuge 

manager with a comprehensive summary report of the number of clients and number of 

client days per activity type by December 31 for all uses during that calendar year unless 

stated otherwise in the permit. A legible copy of the State's “Hunt Record” for each client 

will be required in addition to the summary report. 

 Failure to report the actual number of client use days per type of authorized activity by 

December 31 of each calendar year and annually pay the Service's established fees (client 

use day and reserved land site) within 30 days after receiving a bill for collection will be 

grounds for revocation of this permit. 

 This permit authorizes use on State selected lands. If any of these lands are conveyed 

during the term of this permit, the permittee will no longer be authorized to use those 

lands until and unless permission is obtained from the Alaska Department of Natural 

Resources. 

 This permit authorizes use only on the Native selected lands specifically identified in the 

description block of this permit. If any of these Native selected lands are conveyed during the 

term of this permit, the permittee will no longer be authorized to use those lands unless 

permission is obtained from the Native corporation to which land ownership has been 

conveyed. 

 In accordance with the Archaeological Resources Protection Act (16 U.S.C. 470aa), the 

removal or disturbance of archaeological or historical artifacts is prohibited. The 

excavation, disturbance, collection, or purchase of historical, ethnological, or archaeological 

specimens or artifacts is prohibited. 

F-72 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

 Permittees shall maintain their use areas in neat and sanitary condition. Latrines must be 

located at least 150 feet from springs, lakes, and streams to avoid contamination of water 

resources. All property (except cabins and/or tent frames) of the permittee must be 

removed from refuge lands upon completion of permitted activities. 

 The construction or clearing of landing strips or pads is prohibited. Incidental hand 

removal of rocks and other minor obstructions may be permitted. 

 The use of off-road vehicles (except snowmobiles with adequate snow cover) is prohibited 

unless specifically authorized in writing in this permit. 

 The operation of aircraft at altitudes and in flight paths resulting in the herding, harassment, 

hazing, or driving of wildlife is prohibited. It is recommended that all aircraft, except for 

takeoff and landing, maintain a minimum altitude of 2,000 feet above ground level. 

 All aircraft being used in commercial operations must have 12-inch identification numbers 

in contrasting colors, which are readily visible. 

 Motorboat operators must possess a U.S. Coast Guard (USCG) license for all passengercarrying operations if required by USCG regulations. 

 Construction of cabins or other permanent structures is prohibited. 

 The permittee's operation plan, as amended and accepted by the U.S. Fish and Wildlife 

Service, is hereby incorporated in its entirety as a special condition. All deviations from 

the operations plan must receive prior written approval by the refuge manager or 

his/her designee. 

 Any action by a permittee or the permittee’s employees that unduly interferes with or 

harasses other refuge visitors or impedes access to any site is strictly prohibited. 

Examples of prohibited acts include but are not limited to low flights over camps or 

persons at less than 500 feet (unless landing) and parking aircraft or placing other objects 

(rocks, tents, etc.) on any landable area to restrict use by other aircraft or persons. 

Refuge-Specific Special Conditions

 Base camp locations must be approved by the refuge manager. Base camps will be located 

on durable surfaces or relocated at intervals adequate to prevent site impacts. 

 All temporary accommodations will be constructed of materials that blend with the 

immediate surroundings. Campsites, shelters, and equipment will be used and maintained in 

a manner consistent with the protection of area resources, including wilderness character. 

 Provisions for human waste management and disposal must be approved by the 

refuge manager. 

 Equipment caches may be located in approved areas. Contact the refuge manager for 

approval. The cache will be clearly marked with the permittee’s name, will be designed to 

blend in with the surrounding environment, and will be bear-proof. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-73 
Appendix F: Compatibility Determinations 

 Use of gasoline or similar fuel for heating and cooking is encouraged. However, driftwood, 

standing dead trees, and brush may be used for firewood; but standing vegetation may not 

be cut within 200 feet of streams or lake shores. 

 All garbage and trash will be secured in a manner that minimizes attraction to wildlife and 

must be removed from the field before vacating the site for the season. 

 Fuel storage sites must be approved by the refuge manager. Preparations to prevent and 

respond to a fuel spill must be fully adequate at all sites for the amount of fuel stored on site. 

All containers must be properly stored and marked with the permittee’s name, address, and 

type of fuel. 

 The permittee will take no action that interferes with subsistence activities of rural users 

or restricts the reasonable access of subsistence users to refuge lands. This may include 

but is not limited to disturbance of wildlife and their movements near subsistence hunters; 

and damage to cabins, trails, traditional campsites, or caches used by subsistence users. 

 The permittee shall ensure that all employees and clients seek to minimize the effect of 

their activities on the wilderness character of the land, wildlife, and the unique experience 

available there. 

Justification: 

Recreational hunting has been found to be compatible with the purposes of Innoko Refuge and 

with the National Wildlife Refuge System Mission. Commercial big-game guiding and outfitting 

services are a form of traditional Alaskan activity that Congress intended to preserve with 

enactment of the Alaska National Interest Lands Conservation Act, which designated Innoko 

Refuge. These services support hunting and other activities, including wildlife observation and 

photography; these are three of the priority public uses of national wildlife refuges. Most nonAlaska residents would not be able to hunt on Innoko Refuge if guiding were not allowed. 

Requirements placed on commercial hunting guides by the Service through the original selection 

process, the terms of their special use permits, and regulations of the State of Alaska ensure that 

these commercial operators provide safe, high-quality experiences for their clients. These operations 

can help the refuge achieve its purposes of protecting fish and wildlife resources of the refuge and 

meeting legal requirements to provide compatible opportunities for the public to use and enjoy these 

resources. After fully considering the impacts of this activity, as described previously in the 

“Anticipated Impacts of Use” section of this document, it is my determination that commercially 

guided recreational big game hunting activities on the refuge do not materially interfere with or 

detract from the purposes of the refuge or mission of the National Wildlife Refuge System. 

Supporting Documents: 

Bouffard, S. 1982. Wildlife values versus human recreation: Ruby Lake National Wildlife Refuge. 

Transactions of the North American Wildlife and Natural Resources Conference 47:553-558. 

Calef, G.W., E.A. DeBock, and G.M. Lortie. 1976. The reaction of barren-ground caribou to 

aircraft. Arctic 29(4):201-212. 

F-74 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Miller, M. W. 1994. Route selection to minimize helicopter disturbance of molting Pacific black 

brant: a simulation. Arctic 47: 341–349. 

U.S. Fish and Wildlife Service. 1987 Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service. Anchorage, AK. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Ward, D. H., R. A. Stehn, D. V. Derksen. 1994. Response of staging brant to disturbance at the 

Izembek Lagoon, Alaska. Wildl. Soc. Bull. 22: 220–228. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: __/s/ Kent A. Sundseth, acting___________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: __/s/ Todd J. Logan__________________ December 19, 2008

 (Signature) (Date) 

Mandatory 10-year Re-evaluation Date (for allowed uses only): 2018

NEPA compliance for Refuge Use Decision: 

___________ Categorical Exclusion without Environmental Action Memorandum 

___________ Categorical Exclusion and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

___________ Environmental Impact Statement and Record of Decision 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-75 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: Commercial Recreational Fishing Guide Services 

Primary Use: Fishing (guiding and outfitting.) 

Supporting Uses: Fixed-wing aircraft landings, boating (motorized and non-motorized), 

snowmobiling, environmental education and interpretation (not conducted by refuge staff or 

authorized agents), hunting, firewood cutting, natural resource gathering, camping, picnicking, 

hiking and backpacking, snowshoeing, pets, swimming and beach use, wildlife photography and 

videography, wildlife observation. 

 

Refuge Name: Innoko National Wildlife Refuge 

Establishing and Acquisition Authority: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of fish, wildlife, 

and plant resources and their habitats within the United States for the benefit of present and 

F-76 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

future generations of Americans (National Wildlife Refuge System Administration Act of 1966, as 

amended [16 U.S.C.668dd-668ee]). 

Description of Use: 

This description of use includes a re-evaluation of the compatibility of use of Federal lands within 

Innoko Refuge for commercially guided recreational fishing. The original compatibility 

determination for commercially guided recreational fishing was made in 1992, subject to 

reasonable regulation and special conditions provided with a special use permit. This 

compatibility determination addresses the full spectrum of uses associated with commercially 

guided recreational fishing. This includes all means of access, lodging and facilities, and other 

elements identified in the guides’ operations plans. The compatibility of recreational fishing on 

Innoko Refuge is evaluated in a separate compatibility determination. Commercial fishing guides 

could target three species of Pacific salmon, plus northern Pike, and Whitefish that occur within 

Innoko Refuge. Commercially guided recreational fishing and related services could contribute to 

the fulfillment of refuge purposes and the National Wildlife Refuge System Mission by facilitating 

priority public use and management of healthy fish populations through managed fishing. 

Historically, there have been two commercial fishing guides operating on Innoko Refuge. Guided 

fishing also has taken place ancillary to guided hunting and commercially guided wildlife 

observation tours, and it is anticipated that this use may increase in the future. 

Means of authorized access for commercially guided fishing could include fixed-wing airplanes, 

motorboats, non-motorized boats, and hiking. Guided recreational fishing occurs spring through 

fall. Recreational fishing is managed under State of Alaska fishing regulations. Of the major 

rivers on the refuge, all could be classified as having good recreational fishing opportunities, based 

on reasonable accessibility by float plane or boat, and sustainable populations of anadromous 

and/or resident fish. Although all these drainages provide opportunities for day use and overnight 

primitive camping, cost of traveling to these areas for day-use fishing is prohibitive for most 

visitors. All drainages provide opportunities for northern pike fishing; however, only the Yukon 

and mainstem Innoko rivers could support guided salmon fishing. 

Recreational fishing guides under permit from the refuge may operate from a temporary camp on 

a river or lake or from a floating base. Each guide would submit a year-end report to the refuge 

identifying the number of clients guided, the location(s) of fishing activities, and the number of fish 

caught by species. 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage commercially 

guided recreational fishing activities at current and projected levels. Administrative staff time 

primarily involves issuing permits, ensuring that licenses and certifications are current, collecting 

client use-day fees, and recording activity data. Fieldwork associated with administering the 

program primarily involves monitoring permittees’ compliance with the terms of the permits and 

conducting resource law enforcement patrols. Estimated staff time to annually administer and 

monitor these permits is three weeks. An administrative fee of $100 is assessed when each permit 

is issued. In addition, a client use fee is assessed for each day a guide has a client on the refuge. 

Fees collected are returned to the refuge to manage the program. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-77 
Appendix F: Compatibility Determinations 

Anticipated Impacts of the Use: 

Both the Federal Subsistence Board and State Board of Fisheries regularly adopt regulations in 

response to fish population levels and to address issues of fishery allocation. Providing an 

opportunity for continued subsistence uses of fishery resources by local residents receives the 

highest priority from the Federal Subsistence Board. Although salmon experienced a worrisome 

decline in the late 1990s, recent run strengths indicate that a small recreational fishery would be 

sustainable. The Refuge’s Fisheries Management Plan (USFWS 1993) warned that fish 

populations within the refuge could decline without sufficient data to measure population trends. 

Based on guidance provided in the Fisheries Management Plan, the refuge continues to work with 

the Fairbanks Fish and Wildlife Field Office to implement inventories and studies in the plan and 

to conduct other research aimed at understanding fish populations on Innoko Refuge. Guided 

recreational harvests are monitored closely to protect fish, which are an extremely important 

subsistence resource to people living near the refuge. 

Impacts to refuge habitats would be minimal and transitory because access to the refuge would be 

primarily by landing float-equipped aircraft on lakes and rivers, or by operating boats on the same 

rivers. Landings on vegetated lowland tundra and disturbance to vegetation would be limited 

under the stipulations of the special use permit. The introduction of invasive species carried on 

aircraft floats and boat hulls could affect refuge resources, although it is not known to have 

occurred via this transmission method within Innoko Refuge to date, and staff will be vigilant to 

prevent such occurrences. In addition, frequent aircraft traffic could affect nesting, molting, or 

staging birds (Ward et al. 1994). Winter access would be by aircraft fitted with skis. Disturbance 

to vegetation would be limited by conditions within the special use permit. Temporary 

displacement and/or disturbance to wildlife can occur in response to low level overflights and 

during takeoffs and approaches to landings (Calef et al. 1976), but impacts would likely be short 

term and minimal. 

Compliance with regulations and permit conditions will be routinely checked by officers. Refuge 

officers and State wildlife protection officers would routinely patrol the refuge during use seasons. 

 The use of cabins in association with commercial guiding would be authorized in accordance with 

50 CFR 36.33. 

Public Review and Comment: 

Public comment was solicited concurrently with revision of the refuge’s Comprehensive 

Conservation Plan. There were no comments on this compatibility determination. 

Refuge Determination (check one below): 

 Use is Not Compatible 

X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

A special use permit with stipulations is required for commercially guided recreational fishing 

services. In the following section are typical special user permit conditions, some of which are 

necessary for compatibility. Site-specific special use conditions related to maintenance of defensible 

space will be incorporated into permits on a case-by-case basis. Continued law enforcement and 

F-78 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

administrative monitoring of permittees will be carried out to ensure compliance with the terms of 

the permit and special conditions to minimize impacts on refuge lands and resources. 

Regional Standard Special Conditions

 Failure to abide by any part of this special use permit; violation of any refuge related 

provision in titles 43 (part 36) or 50 (subchapters B and C) of the Code of Federal 

Regulations; or violation of any pertinent State regulation (e.g., fish or game violation) will, 

with due process, be considered grounds for immediate revocation of this permit and could 

result in denial of future permit requests for lands administered by the U.S. Fish and 

Wildlife Service. This provision applies to all persons working under the authority of this 

permit (e.g., assistants). Appeals of decisions relative to permits are handled in accordance 

with 50 Code of Federal Regulations 36.41. 

 The permittee is responsible for ensuring that all employees, party members, contractors, 

aircraft pilots, and any other persons working for the permittee and conducting activities 

allowed by this permit are familiar with and adhere to the conditions of this permit. 

 Any problems with wildlife and/or animals taken in defense of life or property must be 

reported immediately to the refuge manager and the Alaska Department of Fish and 

Game, and animals taken must be salvaged in accordance with State regulations. 

 This permit may be canceled or revised at any time by the refuge manager for 

noncompliance or in case of emergency (e.g., public safety, unusual resource problems). 

 This permit does not grant the permittee and his/her client’s exclusive use of the site(s) or 

lands covered by the permit. 

 This permit may be canceled or revised at any time by the refuge manager in case of 

emergency (e.g., high fire danger, flooding, unusual resource problems, etc.). 

 The permittee or his/her designee shall notify the refuge manager during refuge working 

hours in person or by telephone before beginning and upon completing activities allowed 

by this permit. 

 Prior to beginning activities allowed by this permit, the permittee shall provide the refuge 

manager with (1) the name and method of contact for the field party chief and/or 

supervisor; (2) the aircraft and other vehicle types to be used, including identification 

information; (3) names of assistant guides and helpers; and (4) any changes to information 

provided in the original permit application. 

 The permittee shall maintain, throughout the use period specified on the permit, 

Comprehensive General Liability Insurance ($300,000 each occurrence; $500,000 annual 

aggregate) covering all ground or water based operations and (unless air transportation is 

already covered) aviation passenger liability ($150,000 per seat plus $100,000 on property) 

covering all aircraft operations involving clients. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-79 
Appendix F: Compatibility Determinations 

 The permittee shall provide the refuge manager with a report of the number and species of 

all fish taken, locations, numbers of clients, and number of client use days per trip. This 

report is due within 30 days of permit expiration unless stated otherwise in the permit. 

 In accordance with the Archaeological Resources Protection Act (16 U.S.C. 470aa), the 

removal or disturbance of archaeological or historical artifacts is prohibited. The 

excavation, disturbance, collection, or purchase of historical, ethnological, or archaeological 

specimens or artifacts is prohibited. 

 Permittees shall maintain their use areas in a neat and sanitary condition. Latrines must 

be located at least 150 feet from springs, lakes, and streams to avoid contamination of 

water resources. All property (except cabins and/or tent frames) of the permittee must be 

removed from refuge lands upon completion of permitted activities. 

 The construction of landing strips or pads is prohibited. Incidental hand removal of rocks 

and other minor obstructions may be permitted. 

 The use of off-road vehicles (except snowmobiles with adequate snow cover) is prohibited 

unless specifically authorized in writing in this permit. 

 The operation of aircraft at altitudes and in flight paths resulting in the herding, 

harassment, hazing, or driving of wildlife is prohibited. It is recommended that all aircraft, 

except for takeoff and landing, maintain a minimum altitude of 2,000 feet above ground. 

 Fuel caches are allowed only in designated areas and must be approved by the refuge 

manager or his/her designate prior to caches being established. If caches are established, fuel 

containers must be clearly marked with the permittee’s name, address, local contact 

telephone number, and type of fuel. 

 Construction of cabins or other permanent structures is prohibited. 

 All aircraft being used in commercial operations must have 12-inch identification numbers 

in contrasting colors, which are readily visible. 

 This permit authorizes use on State selected lands. If any of these lands are conveyed 

during the term of this permit, the permittee will no longer be authorized to use those 

lands until and unless permission is obtained from the Alaska Department of Natural 

Resources. 

 This permit authorizes use only on the Native selected lands specifically identified in the 

description block of this permit. If any of these Native selected lands are conveyed during the 

term of this permit, the permittee will no longer be authorized to use those lands unless 

permission is obtained from the Native corporation to which land ownership has been 

conveyed. 

 Any action by a permittee or the permittee's employees that unduly interferes with or 

harasses other refuge visitors or impedes access to any site is strictly prohibited. 

Examples of prohibited acts include but are not limited to 1) intentional low flights over 

F-80 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

camps or persons at less than 500 feet, except when necessary for takeoff and landing; 2) 

parking aircraft or placing other objects (rocks, tents, etc.) on any landable area so as to 

restrict use by other aircraft; 3) otherwise intentionally interfering in the activity of other 

refuge users; and 4) engaging in activity which is contrary to State and Federal laws. 

Refuge-Specific Special Conditions

 All garbage and noncombustible debris will be removed from the refuge. Food, garbage, 

and/or other materials will be stored so as not to attract bears and other wildlife. 

 Motorboat operators must possess U.S. Coast Guard (USCG) licenses for all passengercarrying operations if required by USCG regulations. 

 The permittee may not sublet any part of the authorized use and is prohibited from 

subcontracting clients with any other guide. 

 The permittee will take no action that interferes with subsistence activities of rural users or 

restricts the reasonable access of subsistence users to refuge lands. This may include but is 

not limited to disturbance of wildlife and their movements near subsistence hunters, and 

damage to cabins, trails, traditional campsites, or caches used by subsistence users. To 

minimize the potential for conflicts with subsistence users, the permittee must review the 

Innoko National Wildlife Refuge land status maps to ascertain the location of selected and 

conveyed lands within refuge boundaries. 

 Provisions for human waste management and disposal must be approved by the 

refuge manager. 

 A valid copy of the issued special use permit, signed by the refuge manager or designee, must 

be in the party leader’s possession at all times while exercising the privileges of the permit. 

Justification: 

Commercially guided fishing services are a form of traditional activity that Congress intended to 

preserve with enactment of the Alaska National Interest Lands Conservation Act, which 

designated the refuge. Guides support angling and other activities, including wildlife observation 

and photography, all of which the National Wildlife Refuge System Administration Act of 1966 (as 

amended by the Refuge Improvement Act of 1997) identifies as priority public uses. Guided 

recreational fishing operations on the refuge would provide the public with quality, safe, and 

unique recreational fishing opportunities found few places in the world. These visitor services are 

a valuable benefit to a segment of the public that is not physically able to, not comfortable with, or 

chooses not to participate in unguided fishing trips within the refuge. 

Recreational fishing has been found compatible with refuge purposes and is one of the priority 

public uses of national wildlife refuges. Guides help facilitate public participation in this activity. 

After fully considering the impacts of this activity, as described previously in the “Anticipated 

Impacts of Use” section of this document, it is my determination that commercially guided 

recreational fishing services within the refuge do not materially interfere with or detract from the 

purposes of the refuge or mission of the National Wildlife Refuge System. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-81 
Appendix F: Compatibility Determinations 

Supporting Documents: 

Bouffard, S. 1982. Wildlife values versus human recreation: Ruby Lake National Wildlife Refuge. 

Transactions of the North American Wildlife and Natural Resources Conference 47:553-558. 

Calef, G.W., E.A. DeBock, and G.M. Lortie. 1976. The reaction of barren-ground caribou to 

aircraft. Arctic 29(4):201-212. 

Innoko Comprehensive Conservation Plan 1987, Wilderness Review, and Environmental Impact 

Statement. U.S. Fish and Wildlife Service, Anchorage, AK. 

Innoko National Wildlife Refuge, Fisheries Management Plan 1993, U.S. Fish and Wildlife 

Service, Fairbanks, AK, 

Miller, M. W. 1994. Route selection to minimize helicopter disturbance of molting Pacific black 

brant: a simulation. Arctic 47: 341–349. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Ward, D. H., R. A. Stehn, D. V. Derksen. 1994. Response of staging brant to disturbance at the 

Izembek Lagoon, Alaska. Wildl. Soc. Bull. 22: 220–228. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: __/s/ Kent A. Sundseth, acting__________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: _/s/ Todd J. Logan___________________ December 19, 2008

 (Signature) (Date) 

Mandatory 10-Year Re-evaluation Date (for allowed uses only): 2018

NEPA Compliance for Refuge Use Decision: 

_____Categorical Exclusion without Environmental Action Memorandum 

_____Categorical Exclusions and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

_____Environmental Impact Statement and Record of Decision 

F-82 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: Commercial Recreational Guide Services 

Primary Use: Environmental education and interpretation (not conducted by Refuge staff or 

authorized agents), wildlife photography and videography, and wildlife observation. 

Supporting Uses: Boating (motorized and non-motorized), fixed-wing aircraft landings, 

snowmobiling, dog sledding, cross-country skiing, skijoring, camping, picnicking, hiking and 

backpacking, wildlife photography and videography, snowshoeing, wildlife observation, natural 

resource gathering, pets, firewood cutting, swimming and beach use. 

Refuge Name: Innoko National Wildlife Refuge 

Establishing and Acquisition Authority: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-83 
Appendix F: Compatibility Determinations 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C. 668dd-668ee]). 

Description of Use: 

This description of use includes a re-evaluation of the compatibility of use of Federal lands within 

Innoko Refuge for all types of guided recreation (except hunting and fishing). The original 

compatibility determination for guided recreation was made in 1992, subject to reasonable 

regulation and special conditions provided with a special use permit. Historic activity in this use 

has been minimal. Since 1980, a limited number permits have been issued for commercial 

recreation guiding businesses, although in any typical year one permit was issued, and there were 

many years in which no permits were issued. It has been many years since the last commercially 

guided recreation tour services have operated on Innoko Refuge; however, it is anticipated that 

this use could occur again in the future 

Commercially guided recreation tours are an activity that supports wildlife-dependent priority 

public uses. The objective of guided tour services in national wildlife refuges is to make available a 

variety of quality opportunities for the public to enjoy outdoor activities where such activities are 

compatible with the refuge’s purposes, resources, and management objectives. Furthermore, the 

congressional committee report on the National Wildlife Refuge System Improvement Act of 1997 

states: “It establishes as the policy of the United States that wildlife-dependent recreation, when 

it is compatible, is a legitimate and appropriate public use of the Refuge System, through which 

the American public can develop an appreciation for fish and wildlife.” 

Recreational guides provide a service that visitors often require to access the refuge and gain an 

appreciation for its resources. In the past, guided recreational activities on Innoko Refuge have 

been conducted in summer as river float trips and during winter using dog sleds and 

snowmobiles. Guided recreational services considered here include activities occurring 

throughout the year. Guided recreational tour providers are required, as a condition of their 

permits, to provide information on the primary activity, location, length of stay, group size, and 

other related items. These reports can provide the most accurate and reliable information the 

Service has on refuge use by visitors. Guided recreational activities contribute to fulfillment of 

the National Wildlife Refuge System mission by providing access for non-local refuge visitors 

and therefore facilitate priority public uses and other uses found compatible in separate 

compatibility determinations. 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage commercial guided 

recreational activities at existing and projected levels. 

Administrative staff time primarily involves issuing permits, ensuring that licenses and 

certifications are current, collecting client use-day fees, and recording activity data. Fieldwork 

associated with administering the program primarily involves monitoring permittees’ compliance 

with the terms of the permits. Estimated staff time to annually administer and monitor these 

permits is one week. 

F-84 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Anticipated Impacts of the Use: 

Impacts associated with guided tours on Innoko Refuge are addressed in the respective 

compatibility determinations for each activity. We anticipate minimal impacts to fish and wildlife 

resources, other refuge resources, or other refuge users. The refuge’s administrative oversight of 

the activity and comprehensive State and Federal regulations continually evolve to respond to 

wildlife management needs. Law enforcement efforts of the State and refuge personnel will also 

help minimize direct impacts from tour guiding services. 

Impacts to refuge habitats would be minimal and transitory because access to the refuge would be 

primarily by landing float-equipped aircraft on lakes and rivers, or by operating boats on the same 

rivers. Landings on vegetated lowland tundra and disturbance to vegetation would be limited 

under the stipulations of the special use permit. The introduction of invasive species carried on 

aircraft floats and boat hulls could affect refuge resources, although it is not known to have 

occurred via this transmission method within Innoko Refuge to date, and staff will be vigilant to 

prevent such occurrences. In addition, frequent aircraft traffic could affect nesting, molting, or 

staging birds (Ward et al. 1994). Winter access would be by aircraft fitted with skis. Disturbance 

to vegetation would be limited by conditions within the special use permit. Temporary 

displacement and/or disturbance to wildlife can occur in response to low level overflights and 

during takeoffs and approaches to landings (Calef et al. 1976), but impacts would likely be short 

term and minimal. 

Compliance with regulations and permit conditions will be routinely checked by officers. Refuge 

officers and State wildlife protection officers would routinely patrol the refuge during use seasons. 

 The use of cabins in association with commercial guiding would be authorized in accordance with 

50 CFR 36.33. 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the refuge’s Comprehensive 

Conservation Plan. There were no comments on this compatibility determination. 

Refuge Determination (check one below): 

___ Use is Not Compatible 

X Use is Compatible with Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

A special use permit with stipulations is required for guided recreational activities. In the 

following section are typical special user permit conditions, some of which are necessary for 

compatibility. Site-specific special use conditions related to maintenance of defensible space will 

be incorporated into permits on a case-by-case basis. Continued law enforcement and 

administrative monitoring of permittees will be carried out to ensure compliance with the terms of 

the permit and special conditions to minimize impacts on refuge lands and resources. 

Regional Standard Special Conditions

 Failure to abide by any part of this special use permit; violation of any refuge related 

provision in titles 43 (part 36) or 50 (subchapters B and C) of the Code of Federal 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-85 
Appendix F: Compatibility Determinations 

Regulations; or violation of any pertinent State regulation (e.g., fish or game violation) will, 

with due process, be considered grounds for immediate revocation of this permit and could 

result in denial of future permit requests for lands administered by the U.S. Fish and 

Wildlife Service. This provision applies to all persons working under the authority of this 

permit (e.g., assistants). Appeals of decisions relative to permits are handled in accordance 

with 50 Code of Federal Regulations 36.41. 

 The permittee is responsible for ensuring that all employees, party members, contractors, 

aircraft pilots, and any other persons working for the permittee and conducting activities 

allowed by this permit are familiar with and adhere to the conditions of this permit. 

 Any problems with wildlife and/or animals taken in defense of life or property must be 

reported immediately to the refuge manager and the Alaska Department of Fish and 

Game, and animals taken must be salvaged in accordance with State regulations. 

 This permit may be canceled or revised at any time by the refuge manager for 

noncompliance. 

 This permit does not grant the permittee and his/her client’s exclusive use of the site(s) or 

lands covered by the permit. 

 This permit may be canceled or revised at any time by the refuge manager in case of 

emergency (e.g., high fire danger, flooding, unusual resource problems, etc.). 

 The permittee or his/her designee shall notify the refuge manager during refuge working 

hours in person or by telephone before beginning and upon completing activities allowed 

by this permit. 

 Prior to beginning activities allowed by this permit, the permittee shall provide the refuge 

manager with (1) the name and method of contact for the field party chief and/or 

supervisor; (2) the aircraft or other vehicle types to be used, including identification 

information; (3) names of assistant guides and helpers; and (4) any changes to information 

provided in the original permit application. 

 The permittee shall maintain, throughout the use period specified on the permit, 

comprehensive general liability Insurance ($300,000 each occurrence; $500,000 annual 

aggregate) covering all ground or water based operations and (unless air transportation is 

already covered) aviation passenger liability ($150,000/seat plus $100,000 property) 

covering all aircraft operations involving clients. 

 The permittee shall provide the refuge manager with a report of activities under this 

permit, including pick up and drop off locations, numbers of clients, and number of client 

use days per trip. This report is due within 30 days of permit expiration unless stated 

otherwise in the permit. 

 In accordance with the Archaeological Resources Protection Act (16 U.S.C. 470aa), the 

removal or disturbance of archaeological or historical artifacts is prohibited. The 

F-86 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

excavation, disturbance, collection, or purchase of historical, ethnological, or archaeological 

specimens or artifacts is prohibited. 

 Permittees shall maintain their use areas in a neat and sanitary condition. Latrines must 

be located at least 150 feet from springs, lakes, and streams to avoid contamination of 

water resources. All property (except cabins and/or tent frames) of the permittee must be 

removed from refuge lands upon completion of permitted activities. 

 The construction of landing strips or pads is prohibited. Incidental hand removal of rocks 

and other minor obstructions may be permitted. 

 The use of off-road vehicles (except snowmobiles with adequate snow cover) is prohibited 

unless specifically authorized in writing in this permit. 

 The operation of aircraft at altitudes and in flight paths resulting in the herding, 

harassment, hazing, or driving of wildlife is prohibited. It is recommended that all aircraft, 

except for takeoff and landing, maintain a minimum altitude of 2,000 feet above ground. 

 Fuel caches are allowed only in designated areas and must be approved by the refuge 

manager or his designate prior to caches being established. If caches are established, fuel 

containers must be clearly marked with the permittee’s name, address, local contact 

telephone number, and type of fuel. 

 Construction of cabins or other permanent structures is prohibited. 

 All aircraft being used in commercial operations must have 12-inch identification numbers 

in contrasting colors, which are readily visible. 

 This permit authorizes use on State selected lands. If any of these lands are conveyed during 

the term of this permit, the permittee will no longer be authorized to use those lands until 

and unless permission is obtained from the Alaska Department of Natural Resources. 

 This permit authorizes use only on the Native selected lands specifically identified in the 

description block of this permit. If any of these Native selected lands are conveyed during 

the term of this permit, the permittee will no longer be authorized to use those lands 

unless permission is obtained from the Native corporation to which land ownership has 

been conveyed. 

 Any action by a permittee or the permittee's employees that unduly interferes with or 

harasses other refuge visitors or impedes access to any site is strictly prohibited. 

Examples of prohibited acts include but are not limited to 1) intentional low flights over 

camps or persons at less than 500 feet, except when necessary for takeoff and landing; 2) 

parking aircraft or placing other objects (rocks, tents, etc.) on any landable area so as to 

restrict use by other aircraft; 3) otherwise intentionally interfering in the activity of other 

refuge users; and 4) engaging in activity which is contrary to State and Federal laws. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-87 
Appendix F: Compatibility Determinations 

Refuge-Specific Special Conditions

 All garbage and non-combustible debris will be removed from the refuge. Food, garbage, 

and other materials will be stored so as not to attract bears and other wildlife. 

 Motorboat operators must possess U.S. Coast Guard (USCG) licenses for all passengercarrying operations if required by USCG regulations. 

 The permittee may not sublet any part of the authorized use and is prohibited from 

subcontracting clients with any other guide. 

 The permittee will take no action that interferes with subsistence activities of rural users 

or restricts the reasonable access of subsistence users to refuge lands. This may include 

but is not limited to disturbance of wildlife and their movements near subsistence hunters; 

and damage to cabins, trails, traditional campsites or caches used by subsistence users. To 

minimize the potential for conflicts with subsistence users, the permittee must review the 

Innoko National Wildlife Refuge land status maps to ascertain the location of selected and 

conveyed lands within refuge boundaries. 

 Provisions for human waste management and disposal must be approved by the 

refuge manager. 

 A valid copy of the issued special use permit, signed by the refuge manager or 

designee, must be in the party leader’s possession at all times while exercising the 

privileges of the permit. 

Justification: 

Commercially guided recreational activities have been found to be compatible with the purposes of 

Innoko Refuge and with the National Wildlife Refuge System Mission. Commercial recreational 

guiding services provide the public with safe access to unique wildlife observation, wildlife 

photography, and environmental education opportunities found few places elsewhere in the world. 

 These are all activities that the National Wildlife Refuge System Administration Act (as 

amended) identifies as priority public uses. These visitor services are a valuable benefit to a 

segment of the public that does not have other means of access to the extremely remote 

environment of the refuge. 

Through required client use reports, guided recreational activities can provide an important 

source of information about use of the refuge. After fully considering the impacts of this activity, 

as described previously in the “Anticipated Impacts of Use” section of this document, it is my 

determination that guided recreational activities within the refuge do not materially interfere with 

or detract from the purposes of the refuge or mission of the National Wildlife Refuge System. 

Supporting Documents: 

Bouffard, S. 1982. Wildlife values versus human recreation: Ruby Lake National Wildlife Refuge. 

Transactions of the North American Wildlife and Natural Resources Conference 47:553-558. 

Calef, G.W., E.A. DeBock, and G.M. Lortie. 1976. The reaction of barren-ground caribou to 

aircraft. Arctic 29(4):201-212. 

F-88 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Miller, M. W. 1994. Route selection to minimize helicopter disturbance of molting Pacific black 

brant: a simulation. Arctic 47: 341–349. 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service. Anchorage, AK. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Ward, D. H., R. A. Stehn, D. V. Derksen. 1994. Response of staging brant to disturbance at the 

Izembek Lagoon, Alaska. Wildl. Soc. Bull. 22: 220–228. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: __/s/ Kent A. Sundseth, acting___________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: __/s/ Todd J. Logan__________________ December 19, 2008

 (Signature) (Date) 

Mandatory 10-year Re-evaluation Date (for allowed uses only): 2018

NEPA compliance for Refuge Use Decision: 

___________ Categorical Exclusion without Environmental Action Memorandum 

___________ Categorical Exclusion and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

___________ Environmental Impact Statement and Record of Decision 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-89 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: State of Alaska Management Activities 

Primary Use: Uses (other) - State of Alaska management activities. 

Supporting Uses: Boating (motorized and non-motorized), fixed-wing aircraft landings, helicopter 

landings, snowmobiling, environmental education and interpretation (not conducted by refuge 

staff or authorized agents), firewood cutting, fishing, natural resource gathering, camping, 

picnicking, cross-country skiing, hiking and backpacking, wildlife photography, videography, audio 

recording, snorkeling and scuba diving, snowshoeing, swimming and beach use, research, scientific 

collecting, surveys, wildlife observation. 

Refuge Name: Innoko National Wildlife Refuge 

Establishment and Acquisition Authority: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

 

Innoko Refuge Purposes: 

ANILCA sets out the primary purposes for each refuge in Alaska. The purposes of the Innoko 

National Wildlife Refuge are described in section 302 (4) (B) of ANILCA and are as follows: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to, waterfowl, peregrine falcons, other migratory birds, black 

bear, moose, furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish 

and wildlife and their habitats; 

(iii) to provide, in a manner consistent with the purposes set forth in subparagraphs (i) and 

(ii), the opportunity for continued subsistence uses by local residents; 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in paragraph (i), water quality and necessary water quantity within 

the refuge. 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

F-90 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C. 668dd-668ee]). 

Description of Use: 

This compatibility determination addresses routine management activities conducted by the 

Alaska Department of Fish and Game and the Alaska Division of Wildlife Troopers that are not 

cooperative projects with the Service. These projects may not be encompassed by the Master 

Memorandum of Understanding between the Alaska Department of Fish and Game, Juneau, 

Alaska, and the U.S. Fish and Wildlife Service, Department of the Interior, Anchorage, Alaska, 

signed March 13, 1982, and/or may not be law enforcement activities conducted by Alaska Division 

of Wildlife Troopers. This includes the following activities: fish and wildlife surveys conducted by 

boat, foot, or other means not restricted by regulation or policy; aircraft landings in support of 

aerial fish and wildlife surveys; vegetation and habitat classification and surveys; and law 

enforcement activities. 

This compatibility determination does not address predator management, fish and wildlife control 

(with the exception of animals taken in defense of life or property), reintroduction of species, 

native fish introductions, non-native species introductions, non-native species management, pest 

management, disease prevention and control, fishery restoration, fishery enhancement, 

construction of facilities, or any other unpermitted activity that could alter ecosystems within the 

refuge. Separate compatibility determinations addressing specific proposals will be required for 

those activities. Management and research activities conducted by the Alaska Department of Fish 

and Game under a specific cooperative agreement with the U.S. Fish and Wildlife Service to fulfill 

one or more purposes of the refuge or the National Wildlife Refuge System mission are not 

subject to a compatibility determination. 

Potential means of access include fixed-wing aircraft, motorboats, snowmobiles, non-motorized 

boats, foot, snowshoes, and cross-country skis. Helicopter access is addressed in a separate 

compatibility determination. Potential lodging and facilities include tents, tent frames, tent 

platforms, weatherports, existing permitted cabins, and caches. 

Availability of Resources: 

Adequate refuge personnel and base operational funds are available to manage activities at 

existing and projected levels. Administrative staff time (as many as 10 staff days per year) 

primarily involves phone conversations, written correspondence, and personal interaction with 

State personnel regarding ongoing activities. Field work associated with administering the 

program primarily involves monitoring (when applicable) the State’s activities to ensure all 

activities remain compatible. 

Anticipated Impacts of the Use: 

Because Alaska Department of Fish and Game personnel and Alaska Division of Wildlife Troopers 

personnel are trained professionals, the Service anticipates that routine law enforcement and fish 

and wildlife monitoring and management activities would have positive overall impacts on wildlife 

resources, other resources within the refuge (such as water quality, soil, and vegetation), and 

visitors. These positive impacts would support refuge purposes and goals and the Service mission. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-91 
Appendix F: Compatibility Determinations 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the refuge’s Comprehensive 

Conservation Plan. There were no comments on this compatibility determination. 

Refuge Determination (check one below): 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

A compatibility determination is not required for State activities on lands within the refuge where 

a pre-established agreement or memorandum of understanding is in place. Refuge staff will 

monitor State activities within the refuge. Findings from these monitoring efforts will be used to 

determine what additional management actions, if any, would be needed to ensure State activities 

remain compatible with refuge purposes and in compliance with established agreements. 

Justification: 

The State of Alaska and the Service are partners in the management of many resources on Innoko 

Refuge. Natural and social science information is necessary for the proper management of the 

National Wildlife Refuge System. It is the policy of the Service to encourage and support 

research and management studies to provide scientific data upon which decisions regarding 

management of units of the Refuge System may be based. State research, management, and law 

enforcement activities support achieving refuge purposes and goals, and the System mission and 

would have favorable affects on resources within the refuge and wildlife-dependent priority public 

uses. After fully considering the impacts of these activities, as described previously in the 

“Anticipated Impacts of Use” section of this document, it is my determination that State of Alaska 

management activities within the refuge do not materially interfere with or detract from the 

purposes of the refuge or mission of the National Wildlife Refuge System. 

Supporting Documents: 

U.S. Fish and Wildlife Service. 1987. Innoko National Wildlife Refuge Final Comprehensive 

Conservation Plan, Wilderness Review, and Environmental Impact Statement. U.S. Fish and 

Wildlife Service. Anchorage, AK. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: _/s/ Kent A. Sundseth, acting____________ December 17, 2008

 (Signature) (Date) 

F-92 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: __/s/ Todd J. Logan__________________ December 19, 2008

 (Signature) (Date) 

Mandatory 10-Year Re-evaluation Date: 2018

NEPA Compliance for Refuge Use Decision 

 Categorical Exclusion without Environmental Action Memorandum 

 Categorical Exclusions and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-93 
Appendix F: Compatibility Determinations 

Compatibility Determination 

Use: Reburial of Archaeological Human Remains per State and Federal Guidelines 

Primary Use: Use (other) - Reburial of archaeological human remains. 

Supporting and Incidental Uses: Boating (human-powered), boating (motorized), camping, hiking 

and backpacking, photography, video, filming, audio recording (non wildlife-dependent, 

recreational—other), fixed-wing aircraft, indigenous cemetery. 

Refuge Name: Innoko National Wildlife Refuge 

Establishing and Acquisition Authorities: 

The Alaska National Interest Lands Conservation Act (ANILCA) established the 3.82 million acre 

Innoko National Wildlife Refuge (Innoko Refuge) as part of the U. S. Fish and Wildlife Service 

National Wildlife Refuge System (Department of the Interior) in 1980. 

 

Innoko Refuge Purposes: 

Section 302(4) (B) of ANILCA sets forth the following major purposes for which Innoko Refuge 

was established and shall be managed: 

(i) to conserve fish and wildlife populations and habitats in their natural diversity, including, 

but not limited to, waterfowl, peregrine falcons, other migratory birds, black bear, moose 

furbearers, and other mammals and salmon; 

(ii) to fulfill the international treaty obligations of the United States with respect to fish and 

wildlife and their habitats; 

(iii) to provide, in a manner consistent with purposes set forth in subparagraphs (i) and (ii), 

the opportunity for continued subsistence uses by local residents; and 

(iv) to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth in subparagraph (i), water quality and necessary water quantity within 

the refuge.” 

[Innoko Wilderness] to secure an enduring resource of wilderness, to protect and preserve 

the wilderness character of the area as part of the National Wilderness Preservation 

System, and to administer the area for the use and enjoyment of the American people in a 

way that will leave it unimpaired for future use and enjoyment as wilderness.

National Wildlife Refuge System Mission: 

The mission of the National Wildlife Refuge System is to administer a national network of lands 

and waters for the conservation, management, and where appropriate, restoration of the fish, 

wildlife, and plant resources and their habitats within the United States for the benefit of present 

and future generations of Americans (National Wildlife Refuge System Administration Act of 

1966, as amended [16 U.S.C.668dd-668ee]). 

F-94 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

Description of Use: 

The refuge anticipates requests to rebury human remains eroding from recorded and unrecorded 

prehistoric sites and remains that have been removed from prehistoric sites. The inadvertent 

discovery section of the Native American Graves Protection and Repatriation Act of 1990 (Public 

Law 101-601) requires that the land management agency identify and notify the closest Native 

group and then, if requested, provide for the repatriation of the remains. With this in mind, the 

refuge has prepared this compatibility determination to cover an expected several burial requests 

over the next 10 years. Each proposed burial and its proposed reburial location would need to be 

approved by the regional historic preservation officer, who will ensure compliance with the 

National Historic Preservation Act section 106 prior to issuance of a permit for this activity. 

Reburial of repatriated human remains would take place near the place of discovery of such 

remains or near their original burial place. Each burial would involve a small excavation with 

hand tools. Impacts to Refuge resources would be negligible and short term, with no foreseeable 

long-term effects and would not affect subsistence use of the refuge. A copy of the global 

positioning system (GPS) coordinates and contents of the burial site will be filed at refuge 

headquarters and with the regional historic preservation officer. The remains should be buried 

with a modern object (e.g., coin, button, with date) to indicate it is a historical reburial. 

Availability of Resources: 

Except for issuance of the permit, no refuge resources would be needed to administer use. All 

activities associated with use would be accomplished by the permittee. 

Anticipated Impacts of the Use: 

Reburials would result in minimal and short-term impacts to refuge resources, involving a few 

small-scale excavations with hand tools and then interment of the remains. 

Public Review and Comment: 

Public comment was solicited concurrently with the revision of the refuge’s comprehensive 

conservation plan. The State of Alaska commented that we had not indicated this compatibility 

determination was available for public review in this section of the draft. They were correct. The 

State objected to the regional special use permit condition that prohibits helicopter use when 

helicopter use can be allowed by permit under regulation. We chose to not allow helicopter use for 

this activity, as we do not believe it is necessary. No change was made to this compatibility 

determination. 

Refuge Determination (check one below): 

 Use is Not Compatible 

 X Use is Compatible with the Following Stipulations 

Stipulations Necessary to Ensure Compatibility: 

A special use permit with stipulations is required for reburial of archaeological human remains. 

Site-specific special use conditions related to maintenance of defensible space will be incorporated 

into permits on a case-by-case basis. Following are typical special use permit stipulations, some of 

which are necessary for compatibility. Note that the following special conditions for a special use 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-95 
Appendix F: Compatibility Determinations 

permit for "Reburial of Archaeological Human Remains per State and Federal Guidelines” may be 

updated to reflect changes, if any, due to step-down plans completed in the future. 

Regional conditions

 Failure to abide by any part of this special use permit; violation of any refuge-related 

provision in titles 43 or 50 of the Code of Federal Regulations; or violation of any pertinent 

State regulation (e.g., fish or game violation) will be considered grounds for immediate 

revocation of this permit and could result in denial of future permit requests for lands 

administered by the U.S. Fish and Wildlife Service. This provision applies to all persons 

working under the authority of this permit (e.g., assistants or contractors). Appeals of 

decisions relative to permits are handled in accordance with 50 Code of Federal 

Regulations 36.41. 

 The permittee is responsible for ensuring that all employees, party members, contractors, 

aircraft pilots, and any other persons working for the permittee and conducting activities 

allowed by this permit are familiar with and adhere to the conditions of this permit. 

 Any problems with wildlife and/or animals taken in defense of life or property must be 

reported immediately to the refuge manager, the Alaska Department of Fish and 

Game, and the Alaska State Troopers. Animals taken must be salvaged in accordance 

with State regulations. 

 The permittee and permittee’s employees do not have the exclusive use of the site(s) or 

lands covered by the permit. 

 This permit may be cancelled or revised at any time by the refuge manager for 

noncompliance or in case of emergency (e.g., public safety, unusual resource problems). 

 The permittee or party chief shall notify the refuge manager during refuge working hours 

in person or by telephone before beginning and upon completion of activities allowed by 

this permit. 

 Prior to beginning any activities allowed by this permit, the permittee shall provide the 

refuge manager with (1) name and method of contact for the field party chief and/or 

supervisor; aircraft and other vehicle types to be used, including identification information 

for these vehicles; and names of crew members; and (2) any changes in information 

provided in the original permit application. 

 In accordance with the Archaeological Resources Protection Act (16 U.S.C. 470aa), the 

disturbance of archaeological or historical sites, and the removal of artifacts are 

prohibited. The excavation, disturbance, collection, or purchase of historical, ethnological, 

or archaeological specimens or artifacts is prohibited. 

 Permittees shall maintain their use areas in a neat and sanitary condition. Latrines must 

be located at least 150 feet from springs, lakes, and streams. All property of the permittee 

except for cabins and tent frames is to be removed from refuge lands upon completion of 

permitted activities. 

 The construction of landing strips or pads is prohibited. Incidental hand removal of rocks 

and other minor obstructions may be permitted. 

F-96 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix F: Compatibility Determinations 

 The use of off-road vehicles (except snowmobiles with adequate snow cover) is prohibited 

unless specifically authorized in writing in this permit. 

 The operation of aircraft at altitudes and in flight paths resulting in the herding, harassment, 

hazing, or driving of wildlife is prohibited. It is recommended that all aircraft, except for 

takeoff and landing, maintain a minimum altitude of 2,000 feet above ground level. 

 The use of helicopters is prohibited. 

 Unauthorized fuel caches are prohibited. Fuel storage, if any, will be in compliance with 

regional Service fuel storage policy. 

Refuge Conditions

 Visitors will be required to comply with any temporary restrictions, emergency orders, or 

other types of regulatory actions promulgated by the refuge manager to prevent resource 

problems or conflicts or in cases of emergency (public safety, unusual resource problems, etc.). 

 The use of Native or State lands that have been conveyed (patented) is not authorized by 

this permit. 

 Use of Native or State lands that have been selected but not yet conveyed is prohibited 

unless a letter of concurrence from the State, village or Native corporation is submitted to 

the refuge manager prior to beginning any activities allowed by this permit. 

 A copy of this special use permit must be in the party leader’s possession at all times while 

exercising the privileges of the permit. 

 Cabins on refuge lands shall not be used by the permittee without the permission of the 

refuge manager except in cases of dire emergency for survival purposes. 

 Food or garbage attractive to bears or other wildlife will be immediately disposed of. No 

attractive nuisance for bears or other wildlife shall be created by food storage, improper 

disposal of garbage (includes of burying of garbage), fish smoking, salting, drying, or other 

uses. 

 Combustibles (paper, wood, etc.) may be burned, but all other debris, including cans, 

bottles, fuel containers, and any other noncombustible material, shall be removed and 

disposed of off-refuge when departing camps. 

 Reburial of repatriated human remains will take place near the place of discovery of such 

remains and/or near the place of their original burial. 

 The permittee or permittees’ representatives will make the smallest possible excavation, 

using only hand tools. 

 The Global Positioning System (GPS) coordinates and a list of the contents of the burial 

site will be filed at refuge headquarters and with the Regional Historic Preservation 

Officer within 30 days of burial. 

 Remains shall be buried with a modern object (e.g., coin, button, etc.—with date) to 

indicate that it is a historical reburial. 

 The discharge of firearms is prohibited except in conjunction with authorized hunting 

seasons or for protection of life or property. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan F-97 
Appendix F: Compatibility Determinations 

F-98 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Justification: 

The proposed use is limited and short term and thus will result in minimal impact to refuge 

resources. This use is necessary for the refuge to comply with the Native American Graves 

Protection and Repatriation Act of 1990. It will not interfere with nor detract from the National 

Wildlife Refuge System mission or the purposes of the refuge. 

Supporting Documents: 

U.S. Fish and Wildlife Service (USFWS). 1987. Innoko National Wildlife Refuge Final 

Comprehensive Conservation Plan, Wilderness Review, and Environmental Impact Statement. 

U.S. Fish and Wildlife Service, Anchorage, AK. 

U.S. Fish and Wildlife Service, 1994. Native American Policy. U.S. Fish and Wildlife Service 

National Policy Issuance #94-10 and appendix. Washington, D.C. 13 pages, available at 

http://policy.fws.gov/npi94_10.html. 

U.S. Fish and Wildlife Service. 2008. Draft Revised Comprehensive Conservation Plan and 

Environmental Assessment for the Innoko National Wildlife Refuge. U.S. Fish and Wildlife 

Service. Anchorage, AK. 

Refuge Determination: 

Refuge Manager / 

Project Leader Approval: __/s/ Kent A. Sundseth, acting________ December 17, 2008

 (Signature) (Date) 

Concurrence: 

Regional Chief, 

National Wildlife 

Refuge System: _/s/ Todd J. Logan___________________ December 17, 2008

 (Signature) (Date) 

Mandatory 10-Year Re-evaluation Date: 2018

NEPA Compliance for Refuge Use Decision 

 Categorical Exclusion without Environmental Action Memorandum 

 Categorical Exclusions and Environmental Action Memorandum 

 X Environmental Assessment and Finding of No Significant Impact 

 Environmental Impact Statement and Record of Decision 
Appendix G: Species List 

1. Species Lists 

Plants and animals known or suspected to occur on Innoko Refuge. 

Table G-1. Vascular plant currently known to exist on Innoko Refuge based on collections and field studies. Taxonomic order (to 

Order level) and names follow the US Department of Agriculture, Natural Resource Conservation Service Plants database 

Order Family Scientific Name Common Name Species Code

Equisetales Equisetaceae Equisetum arvense field horsetail EQAR 

Equisetum fluviatile water horsetail EQFL 

Equisetum palustre marsh horsetail EQPA 

Equisetum pratense meadow horsetail EQPR 

Equisetum sylvaticum woodland horsetail EQSY 

Lycopodiales Lycopodiaceae Lycopodium alpinum alpine clubmoss LYAL3 

Lycopodium

annotinum 

stiff clubmoss LYAN2 

Lycopodium clavatum running clubmoss LYCL 

Lycopodium

complanatum 

groundcedar LYCO3 

Huperzia selago densa fir clubmoss HUSED 

 Polypodiales Aspidiaceae Dryopteris expansa spreading 

woodfern 

DREX2 

Dryopteris fragrans fragrant woodfern DRFR 

Gymnocarpium

robertianum 

scented oakfern GYRO 

Athyriaceae Cystopteris fragilis brittle bladderfern CYFR2 

Cystopteris montana mountain 

bladderfern 

CYMO3 

Pinales Pinaceae Larix laricina tamarack LALA 

Picea glauca white spruce PIGL 

Picea mariana black spruce PIMA 

Alismatales Alismataceae Sagittaria cuneata arumleaf 

arrowhead 

SACU 

Najadales Juncaginaceae Triglochin maritima seaside arrowgrass TRMA20 

Potamogetonaceae Potamogeton

gramineus 

variableleaf 

pondweed 

POGR8 

Potamogeton natans floating pondweed PONA4 

Potamogeton

richardsonii 

Richardson's 

pondweed 

PORI2 

Arales Araceae Calla palustris water arum CAPA 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan G-1 
Appendix G: Species Lists 

G-2 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Order Family Scientific Name Common Name Species Code

Lemnaceae Lemna minor common duckweed LEMI3 

Lemna trisulca star duckweed LETR 

Cyperales Cyperaceae Carex spp. sedge CAREX 

Carex aquatilis 

aquatilis 

water sedge CAAQA 

Carex bigelowii Bigelow's sedge CABI5 

Carex canescens 

Carex chordorrhiza creeping sedge CACH5 

Carex lapponica Lapland sedge CALA15 

Carex lasiocarpa 

americana 

American 

woollyfruit sedge 

CALAA 

Carex limosa mud sedge CALI7 

Carex livida livid sedge CALI 

Carex loliacea ryegrass sedge CALO4 

Carex lugens spruce muskeg 

sedge 

CALU2 

Carex membranacea fragile sedge CAME4 

Carex pauciflora fewflower sedge CAPA19 

Carex rostrata beaked sedge CARO6 

Carex rotundata round sedge CARO7 

Eleocharis acicularis needle spikerush ELAC 

Eleocharis palustris common spikerush ELPA3 

Eriophorum

angustifolium

subarcticum 

tall cottongrass ERANS2 

Eriophorum

brachyantherum 

northland 

cottonsedge 

ERBR6 

Eriophorum

vaginatum vaginatum 

tussock cottongrass ERVAV 

Schoenoplectus

tabernaemontani 

softstem bulrush SCTA2 

Trichophorum 

alpinum 

alpine bulrush TRAL7 

Poaceae Agrostis spp. bentgrass AGROS2 

Alopecurus aequalis shortawn foxtail ALAE 

Arctagrostis latifolia

arundinacea 

wideleaf polargrass ARLAA5 
Appendix G: Species List 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan G-3 

Order Family Scientific Name Common Name Species Code

Beckmannia

syzigachne 

American 

sloughgrass 

BESY 

Calamagrostis 

canadensis 

bluejoint CACA4 

Deschampsia

caespitosa 

tufted hairgrass DECA18 

Elymus alaskanus

alaskanus 

Alaskan 

wheatgrass 

ELALA2 

Elymus macrourus tufted wheatgrass ELMA7 

Glyceria grandis

grandis 

American 

mannagrass 

GLGRG 

Hierochloe alpina alpine sweetgrass HIAL3 

Poa spp. bluegrass POA 

Poa annua annual bluegrass POAN 

Poa glauca glaucous bluegrass POGL 

Trisetum spicatum spike trisetum TRSP2 

Juncales Juncaceae Juncus arcticus

littoralis

Baltic rush JUARL 

Juncus bufonius toad rush JUBU 

Juncus filiformis thread rush JUFI 

Juncus stygius moor rush JUST 

Luzula arctica arctic woodrush LUAR9 

Luzula arcuata

unalaschcensis 

Alaska curved 

woodrush 

LUARU 

Luzula rufescens rufous woodrush LURU2 

Luzula spicata spiked woodrush LUSP4 

Luzula wahlenbergii Wahlenberg's 

woodrush 

LUWA 

Typhales Sparganiaceae Sparganium

angustifolium 

narrowleaf burreed SPAN2 

Sparganium natans small bur-reed SPNA 

Liliales Iridaceae Iris setosa interior wild flag IRSEI2 

Liliaceae Tofieldia coccinea northern asphodel TOCO 

Orchidales Orchidaceae Spiranthes 

romanzoffiana 

hooded lady's 

tresses 

SPRO 

Asterales Asteraceae Achillea borealis boreal yarrow ACMIB 

Antennaria friesiana

alaskana

Fries' pussytoes ANFRA 
Appendix G: Species Lists 

G-4 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Order Family Scientific Name Common Name Species Code

Arnica sp. arnica ARNIC 

Artemisia arctica

arctica 

boreal sagebrush ARARA2 

Artemisia tilesii

elatior 

Tilesius' wormwood ARTIE 

Bidens cernua radiata nodding beggartick BICER 

Chrysanthemum 

bipinnatum

bipinnatum 

Lake Huron tansy TABIB 

Erigeron acris politus bitter fleabane ERACP2 

Eurybia sibirica arctic aster EUSI13 

Gnaphalium 

uliginosum 

marsh cudweed GNUL 

Matricaria discoidea pineapple weed MADI 

Matricaria 

matricarioides 

disc mayweed MADI6 

Petasites frigidus arctic sweet 

coltsfoot 

PEFR5 

Senecio congestus marsh fleabane SECO2 

Solidago canadensis

salebrosa 

salebrosa 

goldenrod 

SOCAS 

Solidago multiradiata

multiradiata 

Rocky Mountain 

goldenrod 

SOMUM 

Callitrichales Callitrichaceae Callitriche 

hermaphroditica 

northern waterstarwort CAHE2 

Callitriche palustris vernal waterstarwort 

CAPA52 

Haloragaceae Hippuris vulgaris common mare's-tail HIVU2 

Myriophyllum 

spicatum 

shortspike 

watermilfoil 

MYSI 

Myriophyllum 

verticillatum 

whorl-leaf 

watermilfoil 

MYVE3 

Campanulales Campanulaceae Campanula lasiocarpa 

lasiocarpa 

mountain harebell CALA7 

Dipsacales Caprifoliaceae Linnaea borealis twinflower LIBO3 

Viburnum edule squashberry VIED 

Valerianaceae Valeriana capitata captiate valerian VACA3 

Lamiales Boraginaceae Mertensia paniculata

paniculata 

tall bluebells MEPAP 
Appendix G: Species List 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan G-5 

Order Family Scientific Name Common Name Species Code

Plagiobothrys 

cognatus 

sleeping 

popcornflower 

PLSCH 

Lamiaceae Mentha arvensis wild mint MEAR4 

Plantaginales Plantaginaceae Plantago major common plantain PLMA2 

Rubiales Rubiaceae Galium boreale northern bedstraw GABO2 

Galium trifidum

trifidum 

threepetal 

bedstraw 

GATRT5 

Scrophulariales Lentibularuaceae Utricularia 

intermedia 

flatleaf 

bladderwort 

UTIN2 

Utricularia 

macrorhiza 

common 

bladderwort 

UTMA 

Utricularia minor lesser bladderwort UTMI 

Orobanchaceae Boschniakia rossica northern 

groundcone 

BORO 

Scrophulariaceae Castilleja sp. Indian paintbrush CASTI2 

Limosella aquatica water mudwort LIAQ 

Pedicularis 

labradorica 

Labrador 

lousewort 

PELA 

Pedicularis langsdorfii

arctica 

arctic lousewort PELAA2 

Pedicularis parviflora

parviflora 

smallflower 

lousewort 

PEPAP6 

Pedicularis lanata woolly lousewort PELA14 

Solanales Gentianaceae Menyanthes trifoliata buckbean METR3 

Polemoniaceae Polemonium 

acutiflorum 

tall Jacob's-ladder POAC 

Polemonium 

pulcherrimum 

Jacob's-ladder POPU3 

Caryophyllales Caryophyllaceae Cerastium 

beeringianum

grandiflorum 

Bering chickweed CEBEG3 

Cerastium 

fischerianum

Fischer's 

chickweed 

CEFI 

Minuartia arctica arctic stitchwort MIAR3 

Minuartia yukonensis Yukon stitchwort MIYU 

Moehringia lateriflora bluntleaf sandwort MOLA6 

Stellaria calycantha northern starwort STCA 

Stellaria crassifolia fleshy starwort STCR 

Stellaria longipes longstalk starwort STLO2 
Appendix G: Species Lists 

G-6 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Order Family Scientific Name Common Name Species Code

Stellaria medi common chickweed STME2 

Wilhelmsia physodes merckia WIPH 

Chenopodiaceae Chenopodium album lambsquarters CHAL7 

Polygonales Polygonaceae Polygonum 

alaskanum 

Alaska wild 

rhubarb 

POAL11 

Polygonum 

amphibium

stipulaceum 

water smartweed POAMS 

Polygonum aviculare prostrate knotweed POAV 

Polygonum bistorta

plumosum

meadow bistort POBIP 

Polygonum 

caurianum 

Alaska knotweed POCA10 

Polygonum 

lapathifolium 

curlytop knotweed POLA4 

Rumex arcticus arctic dock RUAR6 

Rumex sibiricus Siberian dock RUSI 

Capparales Brassicaceae Arabis lyrata lyrate rockcress ARLY2 

Barbarea orthoceras American 

yellowrocket 

BAOR 

Capsella bursapastoris 

shepherd's purse CABU2 

Cardamine pratensis

angustifolia 

cuckoo flower CAPRA 

Erysimum

cheiranthoides 

wormseed 

wallflower 

ERCH9 

Rorippa barbareifolia hoary yellowcress ROBA 

Rorippa palustris 

fernaldiana 

Fernald's 

yellowcress 

ROPAF2 

Diapensiales Diapensiaceae Diapensia lapponica

obovata 

pincushion plant DILAO2 

Ericales Ericaceae Andromeda polifolia bog rosemary ANPO 

Arctostaphylos alpina alpine bearberry ARAL2 

Arctostaphylos uvaursi 

kinnikinnick ARUV 

Chamaedaphne 

calyculata 

leatherleaf CHCA2 

Empertrum nigrum

hermaphroditum 
Appendix G: Species List 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan G-7 

Order Family Scientific Name Common Name Species Code

Ledum palustre

decumbens 

marsh Labrador 

tea 

LEPAD 

Ledum groenlandicum bog Labrador tea LEGR 

Loiseleuria 

procumbens 

alpine azalea LOPR 

Vaccinium oxycoccos small cranberry VAOX 

Vaccinium uliginosum bog blueberry VAUL 

Vaccinium vitis-idaea

minus 

northern mountain 

cranberry 

VAVIM 

Pyrolaceae Moneses uniflora single delight MOUN2 

Pyrola asarifolia

asarifolia

liverleaf 

wintergreen 

PYASA 

Pyrola chlorantha greenflowered 

wintergreen 

PYCH 

Orthilia secunda sidebells 

wintergreen 

ORSE 

Nepenthales Droseraceae Drosera anglica English sundew DRAN 

Drosera rotundifolia roundleaf sundew DRRO 

Primulales Primulaceae Lysimachia 

thyrsiflora 

tufted loosestrife LYTH2 

Trientalis europaea arctic starflower TREU 

Salicales Salicaceae Populus balsamifera

balsamifera 

balsam poplar POBAB2 

Populus tremuloides quaking aspen POTR5 

Salix alaxensis feltleaf willow SAAL 

Salix arbusculoides littletree willow SAAR3 

Salix arctica arctic willow SAAR27 

Salix bebbiana Bebb willow SABE2 

Salix fuscescens Alaska bog willow SAFU 

Salix lucida lasiandra Pacific willow SALUL 

Salix phlebophylla skeletonleaf willow SAPH 

Salix pulchra tealeaf willow SAPU15 

Salix richardsonii Richardson's willow SARI4 

Salix scouleriana Scouler's willow SASC 

Violales Violaceae Viola epipsila repens dwarf marsh violet VIEPR 

Fagales Betulaceae Alnus viridis Sitka alder ALVIS 

Alnus incana

tenuifolia 

thinleaf alder ALINT 
Appendix G: Species Lists 

G-8 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Order Family Scientific Name Common Name Species Code

Betula glandulosa resin birch BEGL 

Betula nana exilis dwarf birch BENAE 

Betula neoalaskana resin birch BENE4 

Myricales Myricaceae Myrica gale sweetgale MYGA 

Nymphaeales Nymphaeaceae Nuphar polysepala Rocky Mountain 

pond-lily 

NULUP 

Nymphaea tetragona pygmy waterlily NYTE 

Ranunculales Ranunculaceae Aconitum

delphiniifolium

delphiniifolium 

larkspurleaf 

monkshood 

ACDED3 

Actaea rubra rubra red baneberry ACRUR2 

Anemone sp. anemone ANEMO 

Caltha natans floating marsh 

marigold 

CANA 

Caltha palustris

radicans

yellow marsh 

marigold 

CAPAR3 

Ranunculus gmelinii Gmelin's buttercup RAGM 

Ranunculus 

hyperboreus 

high northern 

buttercup 

RAHY2 

Ranunculus macounii Macoun's buttercup RAMA2 

Ranunculus 

pensylvanicus 

Pennsylvania 

buttercup 

RAPE2 

Ranunculus repens creeping buttercup RARE3 

Ranunculus 

trichophyllus 

threadleaf crowfoot RATR 

Thalictrum alpinum alpine meadow-rue THAL 

Thalictrum 

sparsiflorum 

fewflower meadowrue THSP 

Apiales Apiaceae Cicuta mackenzieana Mackenzie's water 

hemlock 

CIVI5 

Cnidium cnidiifolium Jakutsk 

snowparsley 

CNCN 

Ligusticum 

mutellinoides alpinum 

Macoun's woodroot POMA18 

Sium suave hemlock 

waterparsnip 

SISU2 

Heracleum lanatum common 

cowparsnip 

HEMA80 

Cornales Cornaceae Cornus canadensis bunchberry 

dogwood 

COCA13 
Appendix G: Species List 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan G-9 

Order Family Scientific Name Common Name Species Code

Cornus sericea sericea redosier dogwood COSES 

Fabales Fabaceae Lathyrus palustris marsh pea LAPA4 

Lupinus arcticus arctic lupine LUAR2 

Oxytropis nigrescens blackish oxytrope OXNI 

Geraniales Balsaminaceae Impatiens noli-tangere western touch-menot IMNO 

Myrtales Onagraceae Circaea alpina small enchanter's 

nightshade 

CIAL 

Chamerion

angustifolium

angustifolium 

fireweed CHANA2 

Epilobium 

hornemannii 

Hornemann's 

willowherb 

EPHO 

Chamerion latifolium dwarf fireweed CHLA13 

Rosales Saxifragaceae Chrysosplenium 

tetrandrum 

northern golden 

saxifrage 

CHTE3 

Parnassia palustris marsh grass of 

Parnassus 

PAPA8 

Ribes hudsonianum northern black 

currant 

RIHU 

Ribes triste red currant RITR 

Saxifraga bronchialis

funstonii 

Funston's saxifrage SABRF 

Saxifraga cernua nodding saxifrage SACE2 

Saxifraga nelsoniana heartleaf saxifrage SANEN 

Saxifraga reflexa reflexed saxifrage SARE8 

Rosaceae Argentina anserina silverweed 

cinquefoil 

ARAN7 

Dryas octopetala

octopetala 

eightpetal 

mountain-avens 

DROCO 

Geum macrophyllum

perincisum 

largeleaf avens GEMAP 

Potentilla fruticosa shrubby cinquefoil DAFRF 

Potentilla hookeriana

hookeriana 

Hooker's cinquefoil POHOH 

Potentilla norvegica

monspeliensis 

Norwegian 

cinquefoil 

PONOM 

Comarum palustre purple marshlocks COPA28 

Potentilla villosa villous cinquefoil POVI4 
Appendix G: Species Lists 

G-10 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Order Family Scientific Name Common Name Species Code

Rosa acicularis prickly rose ROAC 

Rubus arcticus

arcticus 

dwarf raspberry RUARA2 

Rubus chamaemorus cloudberry RUCH 

Rubus idaeus grayleaf red 

raspberry 

RUIDS2 

Sanguisorba 

officinalis 

official burnet SAOF3 

Sanguisorba 

canadensis

Canadian burnet SACA14 

Sorbus scopulina Greene's mountain 

ash 

SOSC2 

Spiraea beauverdiana beauverd spirea SPST3 

Santalales Santalaceae Geocaulon lividum false toadflax GELI2 
Appendix G: Species List 

Table G-2. Lichens currently known to exist on the Innoko Refuge based on collections and field studies. Taxonomic order (to 

Order level) and names follow the US Department of Agriculture, Natural Resources Conservation Service database 

Order Family Scientific Name Common Name Species Code 

Lecanorales Cladoniaceae Cladina arbuscula reindeer lichen CLAR60 

Cladina rangiferina greygreen reindeer 

lichen 

CLRA60 

Cladina stellaris star reindeer lichen CLST60 

Cladonia sp. cup lichen CLADO3 

Collemataceae Leptogium sp. skin lichen LEPTO14 

Parmeliaceae Cetraria islandica island cetraria lichen CEIS60 

Cetraria laevigata cetraria lichen CELA60 

Flavocetraria

cucullata

cetraria lichen FLCU 

Flavocetraria nivalis cetraria lichen FLNI 

Hypogymnia sp. tube lichen HYPOG2 

Parmelia fraudans shield lichen PAFR60 

Stereocaulaceae Stereocaulon 

paschale 

snow lichen STPA60 

Leotiales Baeomycetaceae Icmadophila

ericetorum 

peppermint drop 

lichen 

ICER 

Peltigerales Nephromataceae Nephroma arcticum arctic kidney lichen NEAR60 

Peltigeraceae Peltigera aphthosa felt lichen PEAP60 

Peltigera 

leucophlebia 

felt lichen PELE61 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan G-11 
Appendix G: Species Lists 

Table G-3. Bryoflora currently known to exist on the Innoko Refuge based on collections and field studies. Taxonomic order (to 

Order level) and names follow the US Department of Agriculture, Natural Resources Conservation Service database 

Order Family Scientific Name Common Name Species Code 

Bryales Aulacomniaceae Aulacomnium 

palustre

aulacomnium moss AUPA70 

Aulacomnium 

turgidum

turgid 

aulacomnium moss 

AUTU70 

Dicranales Dicranaceae Dicranum 

elongatum 

elongate dicranum 

moss 

DIEL70 

Dicranum tauricum dicranum moss DITA 

Dicranum 

undulatum 

undulate dicranum 

moss 

DIUN8 

Ditrichaceae Ceratodon 

purpureus 

ceratodon moss CEPU12 

Funariales Splachnaceae Splachnum luteum yellow moosedung 

moss 

SPLU7 

Hypnales Amblystegiaceae Calliergon 

stramineum 

calliergon moss CAST70 

Drepanocladus 

aduncus 

drepanocladus 

moss 

DRAD2 

Sanionia uncinatus sanionia moss SAUNU 

Warnstorfia

fluitans

warnstorfia moss WAFLF 

Brachytheciaceae Brachythecium sp. brachythecium 

moss 

BRACH10 

Hylocomiaceae Hylocomium 

splendens 

splendid feather 

moss 

HYSP70 

Pleurozium 

schreberi 

Schreber's big red 

stem moss 

PLSC70 

Hypnaceae Hypnum sp. hypnum moss HYPNU2 

Pylaisiella 

polyantha 

pylaisiella moss PYPO3 

Ptilium cristacastrensis 

knights plume 

moss 

PTCR70 

Rhytidiaceae Rhytidium rugosum rhytidium moss RHRU70 

Polytrichales Polytrichaceae Polytrichum 

juniperinum 

juniper 

polytrichum moss 

POJU70 

Polytrichum 

piliferum 

polytrichum moss POPI10 

Sphagnales Sphagnaceae Sphagnum 

angustifolium 

sphagnum SPAN11 

Sphagnum jensenii Jensen's sphagnum SPJE 

G-12 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix G: Species List 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan G-13 

Order Family Scientific Name Common Name Species Code 

Sphagnum arcticum arctic sphagnum SPAR6 

Sphagnum balticum Baltic sphagnum SPBA70 

Sphagnum 

fimbriatum 

sphagnum SPFI4 

Sphagnum fuscum sphagnum SPFU70 

Sphagnum 

girgensohnii 

Girgensohn's 

sphagnum 

SPGI70 

Sphagnum lenense sphagnum SPLE5 

Sphagnum lindbergi Lindberg's 

sphagnum 

SPLI70 

Sphagnum 

magellanicum 

Magellan's 

sphagnum 

SPMA70 

Sphagnum majus sphagnum SPMA11 

Sphagnum obtusum sphagnum SPOB70 

Sphagnum 

papillosum 

papillose sphagnum SPPA71 

Sphagnum 

riparium 

streamside 

sphagnum 

SPRI70 

Sphagnum rubellum sphagnum SPRU4 

Sphagnum russowii Russow's 

sphagnum 

SPRU6 

Sphagnum 

squarrosum 

sphagnum SPSQ70 

Marchantiales Marchantiaceae Marchantia 

polymorpha 

liverwort MAPO16 
Appendix G: Species List 

Table G-4. Mammals currently known or suspected to exist on the Innoko Refuge based on collections and field studies. Names 

follow Wilson and Reeder (2005) 

Order Family Scientific Name Common Name Status 

Insectivora Soricidae Sorex cinereus common shrew Known 

Sorex hoyi American pygmy 

shrew 

Known 

Sorex monticolus dusky shrew Known 

Sorex palustris American water shrew Suspected 

Sorex tundrensis tundra shrew Known 

Sorex yukonicus Alaska tiny shrew Suspected 

Chiroptera Vespertilionidae Myotis lucifugus little brown bat Suspected 

Carnivora Canidae Canis latrans coyote Suspected 

Canis lupus gray wolf Known 

Vulpes vulpes red fox Known 

Felidae Lynx canadensis Canada lynx Known 

Mustelidae Lontra canadensis northern river otter Known 

Gulo gulo wolverine Known 

Martes americana American martin Known 

Mustela erminea ermine Suspected 

Mustela nivalis least weasel Known 

Mustela vison American mink Known 

Ursidae Ursus americanus American black bear Known 

Ursus arctos brown bear Known 

Artiodactyla Cervidae Alces alces moose Known 

Rangifer tarandus caribou Known 

Bovidae Ovibos moschatus muskox Known 

Rodentia Sciuridae Spermophilus parryii arctic ground squirrel Suspected 

Tamiasciurus 

hudsonicus 

red squirrel Known 

Glaucomys sabrinus northern flying 

squirrel 

Suspected 

Castoridae Castor canadensis American beaver Known 

Dipodidae Zapus hudsonius meadow jumping 

mouse 

Known 

Muridae Clethrionomys rutilus northern red-backed 

vole 

Known 

Dicrostonyx 

groenlandicus 

Greenland collared 

lemming 

Suspected 

G-14 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix G: Species List 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan G-15 

Order Family Scientific Name Common Name Status 

Lemmus sibiricus brown lemming Suspected 

Microtus miurus singing vole Suspected 

Microtus oeconomus tundra vole Known 

Microtus 

pennsylvanicus 

meadow vole Suspected 

Microtus 

xanthognathus 

taiga vole Known 

Ondatra zibethicus muskrat Known 

Synaptomys borealis northern bog lemming Suspected 

Erethizontidae Erethizon dorsatum common porcupine Known 

Lagomorpha Leporidae Lepus americanus snowshoe hare Known 
Appendix G: Species List 

Table G-5. Fish of the Innoko Refuge, listed in taxonomic order 

Order Family Scientific Name Common Name 

Petromyzontiformes Petromyzontidae Lampetra camtschatica Arctic lamprey 

Cypriniformes Cyprinidae Couesius plumbeus lake chub 

Catastomidae Catostomus catostomus longnose sucker 

Esociformes Esocidae Esox lucius northern pike 

Umbridae Dallia pectoralis Alaska blackfish 

Osmeriformes Osmeridae Hypomesus olidus pond smelt 

Salmoniformes Salmonidae Coregonus lauretta Bering cisco 

Coregonus nasus broad whitefish 

Coregonus pidschian humpback whitefish 

Coregonus sardinella least cisco 

Prosopium cylindraceum round whitefish 

Stenodus leucichthys sheefish 

Thymallus arcticus Arctic grayling 

Oncorhynchus gorbuscha pink salmon 

Oncorhynchus keta chum salmon 

Oncorhynchus kisutch coho salmon 

Oncorhynchus nerka sockeye salmon 

Oncorhynchus tshawytscha Chinook salmon 

Salvelinus malma dolly varden char 

Percopsiformes Percopsidae Percopsis orniscomaycus trout perch 

Gadiformes Gadidae Lota lota burbot 

Scorpaeniformes Cottidae Cottus cognatus slimy sculpin 

Table G-6. Amphibians of the Innoko Refuge 

Order Family Scientific Name Common Name 

Anura Ranidae Rana sylvatica wood frog 

G-16 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix G: Species List 

Table G-7. Birds known to exist on the Innoko Refuge based on field studies. Sequence and names follow the 7th edition of the 

American Ornithologists’ Union Check-list of North American Birds, 48th Supplement (2007) 

Order Family Scientific Name Common Name AbundanceStatus 

Species 

Code 

Anseriformes Anatidae Anser albifrons Greater Whitefronted Goose C-B GWFG 

 Chen 

caerulescens 

Snow Goose R-M GSGO 

 Branta 

canadensis 

Canada Goose C-B CAGO 

 Cygnus 

columbianus 

Tundra Swan U-B TUSW 

 Cygnus 

buccinator 

Trumpeter Swan C-B TRUS 

 Anas penelope Eurasian Wigeon U-V EUWI 

 Anas americana American 

Wigeon 

C-B AMWI 

 Anas 

platyrhynchos 

Mallard C-B MALL 

 Anas discors Blue-winged Teal U-B BWTE 

 Anas clypeata Northern 

Shoveler 

C-B NSHO 

 Anas acuta Northern Pintail C-B NOPI 

 Anas crecca Green-winged 

Teal 

C-B AGWT 

 Aythya 

valisineria 

Canvasback R-B CANV 

 Aythya 

americana 

Redhead R-B REDH 

 Aythya collaris Ring-necked 

Duck 

R-B RNDU 

 Aythya marila Greater Scaup C-B GRSC 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan G-17 
Appendix G: Species Lists 

G-18 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Order Family Scientific Name Common Name AbundanceStatus 

Species 

Code 

 Aythya affinis Lesser Scaup C-B LESC 

 Histrionicus 

histrionicus 

Harlequin Duck U-B HARD 

 Melanitta 

perspicillata 

Surf Scoter C-B SUSC 

 Melanitta fusca White-winged 

Scoter 

U-B WWSC 

 Melanitta nigra Black Scoter C-B BLSC 

 Clangula 

hyemalis 

Long-tailed Duck U-B LTDU 

 Bucephala 

albeola 

Bufflehead U-B BUFF 

 Bucephala 

clangula 

Common 

Goldeneye 

C-B COGO 

 Bucephala 

islandica 

Barrow’s 

Goldeneye 

C-B BAGO 

 Mergus serrator Red-breasted 

Merganser 

U-B RBME 

Galliformes Phasianidae Bonasa 

umbellus 

Ruffed Grouse C-A RUGR 

 Falcipennis 

canadensis 

Spruce Grouse C-A SPGR 

 Lagopus 

lagopus 

Willow 

Ptarmigan 

U-A WIPT 

 Tympanuchus 

phasianellus 

Sharp-tailed 

Grouse 

U-A STGR 

Gaviiformes Gaviidae Gavia stellata Red-throated 

Loon 

C-B RTLO 

 Gavia pacifica Pacific Loon C-B PALO 

 Gavia immer Common Loon U-B COLO 

Podicipediformes Podicipedidae Podiceps 

auritus 

Horned Grebe U-B HOGR 
Appendix G: Species List 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan G-19 

Order Family Scientific Name Common Name AbundanceStatus 

Species 

Code 

 Podiceps 

grisegena 

Red-necked 

Grebe 

C-B RNGR 

Falconiformes Accipitridae Pandion 

haliaetus 

Osprey C-B OSPR 

 Haliaeetus 

leucocephalus 

Bald Eagle C-B BAEA 

 Circus cyaneus Northern 

Harrier 

C-B NOHA 

 Accipiter 

striatus 

Sharp-shinned 

Hawk 

U-B SSHA 

 Accipiter 

gentilis 

Northern 

Goshawk 

U-A NOGO 

 Buteo 

jamaicensis 

Red-tailed Hawk C-B RTHA 

 Buteo lagopus Rough-legged 

Hawk 

C-B RLHA 

 Aquila 

chrysaetos 

Golden Eagle U-B GOEA 

 Falconidae Falco 

columbarius 

Merlin R-B MERL 

 Falco rusticolus Gyrfalcon R-A GYRF 

 Falco 

peregrinus 

Peregrine Falcon U-B PEFA 

Gruiformes Gruidae Grus canadensis Sandhill Crane U-B SACR 

Charadriiformes Charadriidae Pluvialis 

squatarola 

Black-bellied 

Plover 

U-M BBPL 

 Pluvialis 

dominica 

American Golden 

Plover 

U-B AMGP 

 Charadrius 

semipalmatus 

Semipalmated 

Plover 

C-B SEPL 

 Scolopacidae Actitis 

macularius 

Spotted 

Sandpiper 

C-B SPSA 
Appendix G: Species Lists 

G-20 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Order Family Scientific Name Common Name AbundanceStatus 

Species 

Code 

 Tringa solitaria Solitary 

Sandpiper 

C-B SOSA 

 Tringa 

melanoleuca 

Greater 

Yellowlegs 

U-B GEYE 

 Tringa flavipes Lesser 

Yellowlegs 

C-B LEYE 

 Numenius 

phaeopus 

Whimbrel U-B WHIM 

 Limosa 

haemastica 

Hudsonian 

Godwit 

C-B HUGO 

 Arenaria 

melanoce 

phala 

Black Turnstone R-M BLTU 

 Calidris pusilla Semipalmated 

Sandpiper 

U-B SESA 

 Calidris 

minutilla 

Least Sandpiper C-B LESA 

 Calidris 

melanotos 

Pectoral 

Sandpiper 

C-B PESA 

 Limnodromus 

scolopaceus 

Long-billed 

Dowitcher 

C-M LBDO 

 Gallinago 

delicata 

Wilson’s Snipe C-B COSN 

 Phalaropus 

lobatus 

Red-necked 

Phalarope 

C-B RNPH 

 Laridae Larus 

philadelphia 

Bonaparte’s Gull C-B BOGU 

 Larus canus Mew Gull U-B MEGU 

 Larus 

argentatus 

Herring Gull U-M HEGU 

 Larus 

glaucescens 

Glaucous-winged 

Gull 

U-B GWGU 
Appendix G: Species List 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan G-21 

Order Family Scientific Name Common Name AbundanceStatus 

Species 

Code 

 Larus 

hyperboreus 

Glaucous Gull U-B GLGU 

 Sterna 

paradisaea 

Arctic Tern C-B ARTE 

 Stercorariidae Stercorarius 

pomarinus 

Pomarine Jaeger R-V POJA 

 Stercorarius 

parasiticus 

Parasitic Jaeger U-B PAJA 

 Stercorarius 

longicaudus 

Long-tailed 

Jaeger 

U-B LTJA 

Strigiformes Strigidae Bubo 

virginianus 

Great Horned 

Owl 

U-A GHOW 

 Bubo 

scandiacus 

Snowy Owl R-W SNOW 

 Surnia ulula Northern Hawk 

Owl 

C-A NHOW 

 Strix nebulosa Great Gray Owl U-A GGOW 

 Asio flammeus Short-eared Owl C-B SEOW 

 Aegolius 

funereus 

Boreal Owl U-A BOOW 

Coraciiformes Alcedinidae Ceryle alcyon Belted 

Kingfisher 

C-B BEKI 

Piciformes Picidae Picoides 

pubescens 

Downy 

Woodpecker 

U-A DOWO 

 Picoides villosus Hairy 

Woodpecker 

U-A HAWO 

 Picoides 

dorsalis 

American Threetoed Woodpecker U-A TTWO 

 Picoides 

arcticus 

Black-backed 

Woodpecker 

U-A BBWO 
Appendix G: Species Lists 

G-22 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Order Family Scientific Name Common Name AbundanceStatus 

Species 

Code 

 Colaptes 

auratus 

Northern Flicker U-B GIFL 

Passeriformes Tyrannidae Contopus 

cooperi 

Olive-sided 

Flycatcher 

U-B OSFL 

 Contopus 

sordidulus 

Western Wood 

Peewee 

U-B WEWP 

 Empidonax 

alnorum 

Alder Flycatcher C-B ALFL 

 Empidonax 

hammondii 

Hammond’s 

Flycatcher 

U-B HAFL 

 Sayornis saya Say’s Phoebe U-B SAPH 

 Corvidae Perisoreus 

canadensis 

Gray Jay C-A GRAJ 

 Corvus corax Common Raven C-A CORA 

 Hirundinidae Tachycineta 

bicolor 

Tree Swallow C-B TRES 

 Tachycineta 

thalassina 

Violet-green 

Swallow 

C-B VGSW 

 Riparia riparia Bank Swallow C-B BANS 

 Petrochelidon 

pyrrhonota 

Cliff Swallow U-B CLSW 

 Paridae Poecile 

atricapillus 

Black-capped 

Chickadee 

C-A BCCH 

 Poecile 

hudsonica 

Boreal Chickadee C-A BOCH 

 Regulidae Regulus 

calendula 

Ruby-crowned 

Kinglet 

C-B RCKI 

 Sylviidae Phylloscopus 

borealis 

Arctic Warbler U-B ARWA 

 Turdidae Myadestes 

townsendi 

Townsend’s 

Solitaire 

R-B TOSO 
Appendix G: Species List 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan G-23 

Order Family Scientific Name Common Name AbundanceStatus 

Species 

Code 

 Catharus 

minimus 

Gray-cheeked 

Thrush 

C-B GCTH 

 Catharus 

ustulatus 

Swainson’s 

Thrush 

C-B SWTH 

 Catharus 

guttatus 

Hermit Thrush U-B HETH 

 Turdus 

migratorius 

American Robin C-B AMRO 

 Ixoreus naevius Varied Thrush C-B VATH 

 Motacillidae Anthus 

rubescens 

American Pipit U-M AMPI 

 Bombycillidae Bombycilla 

garrulous 

Bohemian 

Waxwing 

C-B BOWA 

 Parulidae Vermivora 

celata 

Orange-crowned 

Warbler 

C-B OCWA 

 Dendroica 

petechia 

Yellow Warbler C-B YWAR 

 Dendroica 

coronata 

Yellow-rumped 

Warbler 

C-B MYWA 

 Dendroica 

townsendi 

Townsend’s 

Warbler 

U-B TOWA 

 Dendroica 

striata 

Blackpoll 

Warbler 

C-B BLPW 

 Seiurus 

noveboracensis 

Northern 

Waterthrush 

C-B NOWA 

 Wilsonia pusilla Wilson’s Warbler C-B WIWA 

 Lanius 

excubitor 

Northern Shrike U-B NSHR 

 Emberizidae Spizella arborea American Tree 

Sparrow 

C-B ATSP 

 Spizella 

passerina 

Chipping 

Sparrow 

U-B CHSP 
Appendix G: Species Lists 

G-24 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Order Family Scientific Name Common Name AbundanceStatus 

Species 

Code 

 Passerculus 

sandwichensis 

Savannah 

Sparrow 

C-B SAVS 

 Passerella iliaca Fox Sparrow C-B FOSP 

 Melospiza 

lincolnii 

Lincoln’s 

Sparrow 

C-B LISP 

 Zonotrichia 

leucophrys 

White-crowned 

Sparrow 

C-B WCSP 

 Junco hyemalis Dark-eyed Junco C-B SCJU 

 Plectrophenax 

nivalis 

Snow Bunting U-M SNBU 

 Icteridae Euphagus 

carolinus 

Rusty Blackbird C-B RUBL 

 Fringillidae Pinicola 

enucleator 

Pine Grosbeak U-A PIGR 

 Loxia 

leucoptera 

White-winged 

Crossbill 

U-A WWCR 

 Carduelis 

flammea 

Common Redpoll C-A CORE 

 Carduelis 

hornemanni 

Hoary Redpoll U-A HORE 

Abundance: Status: 

C-Common B – Breeding in summer 

U-Uncommon A – Resident all year round, breeding 

R-Rare M – Migrates through the refuge but not known to breed 

W – Winter resident, non-breeding 

V – Vagrant 
Appendix H: Landcover 

1. Landcover 

1.1 Landcover Classes and Subclasses 

Table H-1. Comparison of landcover classes and subclasses used on Innoko NWR 

Class Subclasses 

Talbot and Markon (1988) Bureau of Land Management et al. (2002) 

Forest Closed Needleleaf 

Open Needleleaf Open Needleleaf 

Open Needleleaf – Lichen 

Needleleaf Woodland Woodland Needleleaf 

Woodland Needleleaf – Lichen 

Broadleaf/Tall Shrub Closed Deciduous 

Open Deciduous 

Mixed Forest Closed Mixed Needleleaf/Deciduous 

Open Mixed Needleleaf/Deciduous 

Shrub Tall Shrub 

Lowland Shrub 

Erect Dwarf Shrub Heath 

Dwarf Shrub – Graminoid Peatlanda 

Dwarf Shrub Raised Boga 

Dwarf Shrub – Graminoid Marsha 

Low Shrub 

Low Shrub – Lichen 

Dwarf Shrub – Graminoid Tussock 

Peatlanda 

Low Shrub – Tussock Tundra 

Low Shrub – Willow/Alder 

Subalpine Shrub 

Prostrate Dwarf Shrub Tundraa 

Dwarf Shrub 

Dwarf Shrub – Lichen 

Herbaceous Graminoid Bog 

Graminoid Marsh 

Wet Graminoid 

Wet Forb 

Graminoid Tussock – Dwarf Shrub 

Peatland 

Tussock Tundra 

Tussock Tundra – Lichen 

Lichen 

Moss 

Mesic/Dry Graminoid 

Mesic/Dry Forb 

Aquatic Vegetation Aquatic Bed 

Emergent 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan H-1 
Appendix H: Landcover 

H-2 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Class Subclasses 

Talbot and Markon (1988) Bureau of Land Management et al. (2002) 

Barren Sparse Vegetation 

Scree Rock/Gravel 

Floodplain Non-vegetated Soil 

Water Clear Clear 

Sedimented Turbid 

a

 Listed under a Dwarf Shrub class by Talbot and Markon (1988). 

1.2 Landcover class and subclass definitions used 

by Talbot and Markon (1988) 

Forest Tree species at least 16 feet tall or secondary tree growth 

temporarily less than 16 feet in height (i.e., intermediate 

successional stages). Five subclasses are contained with 

this cover class. 

 Closed Needleleaf Forest is characterized by a needleleaf tree canopy cover of 50–

100 percent. Predominate species are white spruce and 

black spruce. 

 Open Needleleaf Forest is characterized by a needleleaf tree canopy cover of 20–50 

percent. Black spruce typically is the dominate tree species. 

 Needleleaf Woodland is characterized by needleleaf trees at least 16 feet tall with 

widely a canopy cover of 5–20 percent. Black spruce is 

typically the dominate tree species, but larch is also occur. 

Broadleaf Forest/Tall Shrub is characterized by broadleaf deciduous trees with 25–100 

percent crown cover. The most common tree species include 

paper birch, quaking aspen, and balsam poplar. Common 

shrubs include green alder and a variety of willow species. 

Mixed Forest is characterized by a mixture of deciduous broadleaf and 

evergreen needleleaf trees with 25–100 percent canopy 

cover. Trees are usually 33–66 feet tall. 

Shrub Comprised of deciduous woody plants 1.6–16 feet in height. 

Included are multiple-stemmed tree species like green alder 

and willow, and single-stemmed tree species like paper 

birch. Three subclasses are contained in this cover class. 

Lowland Shrub is associated with alluvial sites along large rivers and 

peatlands. Overall plant species diversity is relatively low. 

Frequently flooded sites have shrubs that are often very 

tall, 6.5–33 feet, and outside the normal range of shrub 

height; willows and various forbs dominate. On alluvial sites 
Appendix H: Landcover 

that flood less frequently, shrubs are lower (1.3–13 feet) in 

stature; common species include willows, green alder, dwarf 

birch, various dwarf shrubs and forbs. 

Subalpine Shrub occurs above timberline and is dominated by green alder. 

Dwarf shrubs, forbs, and mosses are commonly associated 

in this subclass. 

 Upland Burn Regeneration is associated with recently burned areas. Species 

composition is highly varied depending on the time since the 

wildfire, species composition at the time of the wildfire, fire 

intensity, and soil moisture. 

Dwarf Shrub Comprised of slow growing shrubs less than 1.6 feet in 

height. Species are predominately ericacous and 

empetracous shrubs. An abundance of mosses and lichens 

are associated with dwarf shrubs. Six subclasses are 

contained in this cover class. 

 Prostrate Dwarf Shrub Tundra is a low growing plant community found above timberline in 

mountainous areas. Common shrubs include crowberry, 

lowbush cranberry, and bearberry. Forbs, grasses, mosses, 

and lichens are also common. 

 Erect Dwarf Shrub Heath occurs at lower elevations than the dwarf shrub tundra or on 

lower elevation hilltops. This plant community tends to be 

more erect that the dwarf shrub tundra community. 

Common shrubs include dwarf birch, Labrador tea, 

blueberry, and lowbush cranberry. Forbs, grasses, mosses, 

and lichens are also common. 

Dwarf Shrub – 

 Graminoid Peatland peatlands are areas of organic terrain covered by peat 

greater than one foot in depth. These lowland areas are 

characterized by small raised areas with hollows in between. 

The hollows are dominated by graminoids. The raised areas 

are dominated by dwarf birch, Labrador tea, bog blueberry, 

and lowbush cranberry; forbs, graminoids, mosses, and 

lichens can also be found. 

Dwarf Shrub 

 Graminoid Tussock 

 Peatland Graminoid Tussock Peatland is found on the lower slopes of 

hillsides and mountains. Graminoid tussocks are abundant 

in this dwarf shrub community. Common shrubs include 

Labrador tea, crowberry, bog blueberry, lowbush 

cranberry, and dwarf birch. Forbs, graminoids, mosses, and 

lichens can also be found. 

 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan H-3 
Appendix H: Landcover 

Dwarf Shrub 

 Raised Bog is composed of raised ombrotrophic peat plateaus. As peat 

accumulates by the growth of Sphagnum and other species 

on low-lying, flat areas, a bog is formed; the raised surface 

prevents the inflow of water from mineral soil below. These 

bogs are therefore dependent on rain fall and snow melt for 

water. Characteristic species are black spruce, dwarf shrubs 

(Labrador tea, lowbush cranberry, bog rosemary, dwarf 

birch, and crowberry), graminoids, mosses, and lichens. 

Dwarf Shrub – 

 Graminoid Marsh are wet areas periodically inundated up to 1.3 feet of standing 

or moving water; water remains in the rooting zone for at least 

part of the growing season. Common species are diamond-leaf 

willow, bog willow, and dwarf birch. Forbs, graminoids, and 

mosses are common throughout this community. 

Herbaceous Comprised of plants without significant woody tissue and 

die back to the ground surface each year. The two major 

growth forms are graminoids and forbs. Graminoids include 

grasses, sedges, and cotton grass. Three subclasses are 

contained in this cover class. 

Graminoid Marsh is typically found in frequently flooded sites along rivers or 

lake shores. This subclass also includes graminoid meadows 

typically associated with alluvial areas and dried oxbow 

lakes. These sites are relatively wetter than the Dwarf 

Shrub–Graminoid marsh subclass. Common dwarf shrubs 

include diamond-leaf willow and bog willow; forbs, 

graminoids, and mosses are common. 

 Graminoid Tussock – 

 Dwarf Shrub Peatland is similar to the dwarf shrub – Graminoid tussock peatland 

subclass is there is a greater dominance of Graminoid 

tussocks in this subclass. This subclass is common in the 

alpine zone. Typical dwarf shrubs include dwarf birch, bog 

blueberry, lowbush cranberry, crowberry, Labrador tea. 

Cotton grass and sedges are the dominate graminoids. 

Forbs, mosses, and lichens are also commonly found. 

Graminoid Bog are peat covered areas with a high water table and a 

surface cover of mosses, primarily Sphagnum. Typical 

dwarf shrubs (bog cranberry, bog rosemary, dwarf birch), 

forbs, and mosses are present. Sedges and cotton grass 

dominate the graminoids. 

Scarcely Vegetated In this class, plants are scattered or absent; bare mineral 

soil or rock dominate the overall appearance of the site. 

There are two subclasses in this class. 

H-4 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix H: Landcover 

Scree is composed of more or less unstable, steep slopes of 

various sized rocks. This subclass grades into the dwarf 

shrub tundra subclass. 

 Floodplain is the result of the initial invasion of plants onto river alluvium 

(e.g., sand bars). Species that typically colonize these areas are 

horsetail, herb willows, willows, and graminoids. 

Water Includes water bodies such as lakes, ponds, and rivers. 

Associated vegetation is composed of rooted fresh water 

aquatic communities dominated by water lily and pond weeds. 

The two subclasses are distinguished by water clarity. 

 Clear contains little particulate matter. 

Sedimented are turbid and contain visible sediments; usually rivers. 

1.3 Landcover class and subclass definitions used 

by Bureau of Land Management et al. (2002). 

Forest Needleleaf and deciduous tree species. Needleleaf species 

generally found are white spruce (Picea glauca) and black 

spruce (P. mariana). The deciduous tree species generally 

found were paper birch (Betula papyrifera), aspen (Populus 

tremuloides), and cottonwood (P. balsamifera and P. 

trichocarpa). Under some conditions willow (Salix spp.) and 

alder (Alnus rubra) formed a significant part of the tree 

canopy. Eight subclasses are contained with this cover class. 

Open Needleleaf is characterized by tree coverage of 25–59 percent, of which 

at least 75 percent are needleleaf species greater than 3.3 

feet in height. Black spruce typically is the dominate tree 

species. The understory is varied with a wide variety of low 

and tall shrubs, fors, grasses, sedges, horsetails, mosses, 

and lichens. 

 Open Needleleaf – Lichen is a subform of the open needleleaf subclass. This type has 

the same characteristics as the open needleleaf forest, but 

has 20 percent or more of the understory comprised of 

lichen species. 

Woodland Needleaf is characterized by a tree cover of 10–24 percent, of which at 

least 75 percent are needleleaf species. The understory is 

extremely varied and includes most of the typical shrubs, 

herbs, and graminoid types 

 

 

 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan H-5 
Appendix H: Landcover 

 Woodland Needleaf – 

 Lichen is a subform of the woodland needleaf subclass. This type 

has the same characteristics as the woodland needleaf 

forest, but has 20 percent or more of the understory 

comprised of lichen species.

Closed Deciduous is characterized by a tree cover of at least 60 percent, of 

which at least 75 percent are deciduous species. Paper 

birch, aspen, and cottonwood are the most common 

deciduous tree species. 

 Open Deciduous is characterized by a tree cover of 25 – 59 percent, of which 

at least 75 percent are deciduous species. Paper birch, 

aspen, and cottonwood are the most common deciduous tree 

species. Needleleaf trees were also commonly associated 

with this subclass. 

Closed Mixed 

 Needleleaf/Deciduous is characterized by a tree cover of at least 60 percent. 

Neither needleleaf trees or deciduous trees comprised 

greater than 75 percent of the tree cover. 

 Open Mixed 

 Needleleaf/Deciduous is characterized by a tree cover of 25–59 percent. Neither 

needleleaf trees or deciduous trees comprised greater than 

75 percent of the tree cover. This subclass is a common 

community in areas that have been burned. 

Shrub Comprised of deciduous woody plants. This class includes 

both tall and low shrub species. Willows, dwarf birch 

(Betula nana and B. glandulosa), and berry (Vaccinium spp.) 

species are common throughout this class. Alder is common 

in tall shrub areas but uncommon in low shrub areas. The 

height of the shrub species making up the largest 

proportion of the site dictates whether the site is a low or 

tall shrub subclass. Seven subclasses are contained in this 

cover class. 

 Tall Shrub is characterized by shrubs making up 25–100 percent of the 

cover and either 25 percent or more are shrubs at least 4.3 

feet in height or shrubs at least 4.3 feet in height were the 

most common shrubs present. This subclass usually has a 

major willow component, or was dominated by nearly pure 

stands of alder. 

 Low Shrub is characterized by shrubs making up 25–100 percent of the 

cover and either 25 percent or more are shrubs less than 4.3 

feet in height or shrubs less than 4.3 feet in height were the 

most common shrubs present. 

H-6 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix H: Landcover 

 Low Shrub – Lichen has the same general characteristics as the low shrub subclass, 

generally dominated by dwarf birch. Lichen comprises 20 

percent or more of the total cover in this subclass. 

 Low Shrub – Tussock Tundra has the same general characteristics as the low shrub 

subclass, but at least 35 percent of the cover is comprised of 

tussock forming cotton grass (Eriophorum vaginatum). 

Ericaceous shrubs, and willow are common; black spruce 

can occasionally be found in this subclass. 

 Low Shrub – Willow/Alder has the same general characteristics as the low shrub 

subclass, but at least 75 percent of the cover is comprised of 

willow and/or alder. 

Dwarf Shrub is characterized by dwarf ericaceous shrubs and mountainavens (Dryas spp.) species, but often includes a variety of 

forbs and graminoids. 

Dwarf Shrub – Lichen has the same general characteristics as the dwarf shrub 

subclass, but has lichen comprising 20 percent or more of 

the total cover. 

Herbaceous Comprised of plants without significant woody tissue and die back 

to the ground surface each year. The major growth forms are 

graminoids, forbs, and bryoids. Graminoids include grasses, 

sedges, and cotton grass. Bryoids and forbs are present as a 

component of the understory in both of the previous classes. 

Eight subclasses are present in this cover class. 

Wet Graminoid is characterized by at least 40 percent herbaceous species, 

5–25 percent water or at least 20 percent sedge, and at least 

50 percent of the herbaceous cover is graminoids. This 

subclass includes seasonally flooded sites. This subclass 

often occurred in in stands too small to be mapped with the 

methods used. 

Wet Forb is characterized by at least 40 percent herbaceous species, 

5–25 percent water or at least 20 percent sedge, and less 

than 50 percent of the herbaceous cover is graminoids. 

Lichen is characterized by at least 40 percent herbaceous species, 

less than 25 percent water and at least 50 percent bryoid 

species of which at least 50 percent are lichen species. 

Moss is characterized by at least 40 percent herbaceous species, 

less than 25 percent water and at least 50 percent bryoid 

species of which at least 50 percent are moss species. 

Mesic/Dry Forb is characterized by at least 40 percent herbaceous species, 

less than 5 percent water and less than 35 percent tussocks. 

Non-bryoid herbaceous species are at least 50 percent 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan H-7 
Appendix H: Landcover 

graminoids but neither grasses or sedges were greater than 

50 percent of the graminoid cover. 

Mesic/Dry Graminoid is characterized by at least 40 percent herbaceous species, 

less than 5 percent water, and non-bryoid herbaceous 

species are less than 50 percent graminoids. Regenerating 

burned areas dominated by fireweed (Epilobium 

angustifolium) are included in this subclass. 

Tussock Tundra is characterized by at least 40 percent herbaceous species 

and less than 26 percent water. At least 50 percent of the 

herbaceous cover are graminoids and at least 35 percent of 

the cover consists of tussock forming cotton grass. 

Ericaceous shrubs, willow, forbs, and bryoids are common in 

this subclass. 

Tussock Tundra – Lichen has the same characteristics as tussock tundra, but at least 

20 percent of the cover are lichens. 

 Aquatic Vegetation In this class, standing water is present and aquatic 

vegetation comprises at least 20 percent of the cover. Two 

subclasses are present in this cover class. 

 Aquatic Bed is characterized by at least 20 percent of the aquatic 

vegetation being comprised of plants with floating leaves. 

This subclass is generally dominated by pond lilies (Nuphar 

polysepalum), pondweeds (Potamogeton spp.), and burreeds (Sparghanium spp.). 

Emergent Vegetation is characterized by at least 20 percent of the aquatic 

vegetation being comprised of plants other than pond lilies. 

Freshwater herbs such as horsetails (Equisetum spp.), 

marestail (Hippuris spp.), and buckbean (Menyanthes 

trifoliate) are common. 

Barren In this class, plants are scattered or absent, but consist of 

less than 50 percent of the total cover. Bare mineral soil or 

rock dominate the overall appearance of the site. There are 

3 subclasses in this class. 

Sparse Vegetation is characterized by at least 20 percent of the site does have 

live vegetation (typically herbs, graminoids, and bryoids) 

present. This subclass is typical of gravel bars along rivers 

and on rocky or very steep slopes. 

Rock/Gravel is characterized by at least 50 percent of the site consisting 

of rock and/or gravel with live vegetation consisting of less 

than 20 percent of the cover. 

Non-vegetated Soil is characterized by at least 50 percent of the cover 

consisting of mud, silt, sand, or soil; vegetation makes up 

H-8 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix H: Landcover 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan H-9 

less than 20 percent of the total cover. This subclass is 

generally associated with rivers and lake shorelines. 

Water Includes water bodies such as lakes, ponds, and rivers; open 

water consists of at least 80 percent of the cover. Associated 

vegetation is composed of rooted fresh water aquatic 

communities dominated by water lily and pond weeds. The 

two subclasses are distinguished by water clarity. 

Clear contains little particulate matter. 

Turbid are turbid and contain visible sediments; usually rivers. 
Appendix I: Preparers 

NAME / TITLE EXPERTISE / FUNCTION DEGREE(S) EXPERIENCE (YEARS) 

REFUGE STAFF 

Bill Schaff 

Refuge Manager 

Refuge Management BS Wildlife Biology Refuge Management 

(24) 

Law Enforcement (5) 

Greg Birkenfeld 

Deputy Refuge 

Manager 

Refuge Management BS Wildlife Biology Natural Resources 

Management (10) 

Wildlife Biology (12) 

Robin Corcoran 

Wildlife Biologist 

Birds MS Zoology 

BS Biology & 

Natural Resource 

Management 

Biological Research 

(14) 

Wildlife Research 

and Management (6) 

Clara Demientieff 

Refuge Information 

Technician 

Subsistence, Public 

Involvement, Liaison 

with communities 

Administrative, 

clerical and 

interpretation (37) 

Steve Kovach 

Lead Wildlife 

Biologist 

Mammals, Habitat 

Relationships, and 

GIS 

BS Wildlife 

Management 

Wildlife 

Management and 

Research (29) 

Dave Martin 

Fire Management 

Officer 

Fire Management B.S. Wildland Fire 

Science (TFM) 

A.A.S Forestry 

Management 

Fire Management 

(13) 

REGION 7 PLANNING STAFF 

Rob Campellone, 

Natural Resources 

Planner 

Team Leader MS Forest 

Resources Planning 

& Management 

BS Environmental 

Science 

Natural Resources 

Planning and Land 

Management (13) 

Helen Clough 

Planning and Policy 

Division Chief 

NEPA, Policy, 

ANILCA Compliance 

BA Anthropology Refuge Planning 

(15) 

Public Land 

Management (19) 

Brian Glaspell, 

Social Scientist 

Social Sciences PhD Recreation / 

Wilderness Mgt. 

MS Natural 

Resources 

Management 

BS Geography 

Social Aspects of 

Public Land and 

Natural Resource 

Management (12) 

OTHER FISH AND WILDLIFE SERVICE STAFF 

Jeff Adams 

Branch Chief – 

Fisheries and Habitat 

Restoration 

Fishery Research and 

Management 

MS Fishery Science 

BS Wildlife 

Management 

Fish Research and 

Management (20) 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan I-1 
Appendix I: Preparers 

I-2 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

NAME / TITLE EXPERTISE / FUNCTION DEGREE(S) EXPERIENCE (YEARS) 

Bill Perry 

Natural Resources 

Planner (Region 5) 

Planning Assistance MS Wildlife Biology 

BS Natural 

Resource Studies 

Natural Resources 

Planning and Social 

Aspects of Resource 

Management (10) 

Rob Siciliano 

Cartographer 

Map production, land 

status information 

BA Environmental 

Science 

GIS (9) 

STATE OF ALASKA STAFF 

Brad Palach, Alaska 

Dept. of Fish and 

Game, 

Natural Resource 

Specialist 

Liaison with State of 

Alaska 

BA Justice Fish and Wildlife 

Management (22) 

Sara Taylor, Alaska 

Dept. of Natural 

Resources, 

Natural Resource 

Specialist 

Liaison with State of 

Alaska 

BS Environmental 

Sciences 

Wildlife Biology (8) 

Biometry (2) 

Resource 

Management (3) 

OTHERS 

Leon Kolankiewicz 

Mangi 

Environmental Group 

Contractor Assistance MS Environmental 

Planning 

BS Forestry and 

Wildlife 

Management 

Environmental 

Planning and 

Natural Resources 

Management (25) 
Appendix J: Response to Comments 

1. Response to Comments 

The Draft Revised Comprehensive Conservation Plan (Plan) and Environmental Assessment for 

Innoko National Wildlife Refuge (Innoko Refuge; refuge) was released for public review on May 

14, 2008, with a Notice of Availability published in the Federal Register (73 FR 27842). The 

comment period closed on July 22, 2008. A public meeting was held in McGrath, but no one 

attended it. Contacts with other communities indicated that people were not available for 

meetings due to busy summer schedules. Comments were received from the State of Alaska; 

Alaska Chapter, Sierra Club; the Wilderness Society; Alaska’s Kenai Peninsula Chapter of Safari 

Club International; Don’s Alaskan Guide Service; and two individuals. 

One individual requested a ban on all hunting, trapping, logging, new roads, and prescribed 

burning on in the refuge. The other individual recommended that the Refuge Headquarters be 

moved to Galena. Alaska’s Kenai Peninsula Chapter of Safari Club International requested that 

the refuge be aware that wood bison could be future residents of the refuge and recommended 

that provisions for this are included in the revised plan. This letter also opposed allowing 

subsistence hunting of wood bison because it could defeat establishment of an animal listed under 

the Endangered Species Act. The letter from Don’s Alaskan Guide Service expressed concern 

about management of air taxis and management of hunting within the refuge. The Wilderness 

Society and the Sierra club both requested that the revised plan include Wilderness and Wild and 

Scenic River studies and recommendations. The Wilderness Society also provided comment on 

motorized and mechanized activities, and on climate change, and supported disclosure of 

information about RS 2477 claims of the State of Alaska. The Sierra Club provided a number of 

specific comments on access and fisheries enhancement in wilderness, and provided 

recommendations for the final revised plan. 

Specific comments from letters, emails, and phone call notes with responses appear in subsequent 

text. The entire text of the letters from the State of Alaska, Sierra Club, and the Wilderness 

Society are shown, along with our responses to the specific comments. 

Comment: Ban all hunting, trapping, logging, new roads, and prescribed burning in the Refuge. 

Response: Hunting and trapping are allowed under State regulations and Federal regulations. 

One of these purposes of the refuge is to provide the opportunity for continued subsistence uses by 

local residents. This includes subsistence use of wildlife and fish. ANILCA specifies that these 

activities will be allowed as long as they are consistent with the other refuge purposes of (a) 

conserving fish and wildlife populations and habitats in their natural diversity and (b) meeting 

international treaty obligations. The National Wildlife Refuge System Administration Act 

identified six priority public uses to be facilitated on refuges when they are compatible with 

refuge purposes. These priority public uses include hunting, fishing, wildlife viewing and 

photography, and environmental education and interpretation. Recreational hunting, trapping, 

commercial big game hunting guide services, and subsistence activities have been determined to 

be compatible with refuge purposes (see Appendix F: Compatibility Determinations). 

Logging would only be allowed under very limited circumstances on the refuge. Subsistence 

gathering of house logs is found compatible (see aAppendix F, compatibility determination for 

subsistence harvest of house logs). Commercial timber harvest (including commercial harvest of 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-1 
Appendix J: Response to Comments 

firewood) within the Minimal management category would only be allowed when an approved 

refuge fire management plan identifies the need to reduce fuel loads in an area. Commercial 

harvest of timber and firewood is not allowed within designated Wilderness. New roads are not 

allowed in Minimal management and Wilderness. Management direction for prescribed fire is 

in section 2.4.10.2 of the plan. Detailed plans are required, and prescribed fires must comply 

with the Alaska Enhanced Smoke Management Plan for Prescribed Fire. 

Comment: Move the refuge headquarters to Galena. 

Response: The Service has no plans to relocate the refuge headquarters. McGrath was selected as 

the site of refuge headquarters due to its location and community infrastructure. As noted in the 

plan, the northern unit of Innoko Refuge is managed from Galena, as it is located closer to that 

office and is not included in this plan. 

Comment: Be aware that wood bison could be future residents of the refuge and be sure that 

provisions for this are included in the revised plan. Subsistence hunting of wood bison should not 

be allowed. 

Response: Objectives 2 (Inventory and Monitoring Plan), 11(wildlife and habitat studies), and 

22(waterfowl abundance and productivity studies) directly or indirectly address wood bison. 

Future hunting, if any, of wood bison would be up to the Alaska Board of Game and the Federal 

Subsistence Board. 

Comment: I enjoyed reading the Innoko Refuge Vision, but I would like to see in the Innoko 

Refuge Vision verbiage, more language that relates to why the Refuge was established and 

Refuge Goals, to me a Vision Statement is “Where we are Going and Why”. To me it reads more 

like a promotion Ad than a Vision Statement. 

Response: Refuge purposes and goals are listed separately in chapter 1. The Service Manual 

defines a vision statement as “...a concise statement of what the planning unit should be, or what 

we hope to do, based primarily upon the Refuge System mission, specific refuge purposes, and 

other mandates.” 

Comment: Refuge Goals: Goal 1 Improve knowledge is very important of fish and wildlife 

species. However, I believe there needs to be stronger verbiage about actually taking timely and 

appropriate actions as needed to maintain healthy populations of both. 

Response: One of the purposes of Innoko Refuge is to conserve populations of fish and wildlife in 

their natural diversity. Goals are stepped down from refuge purposes to be more specific. We 

believe the goals and objectives outlined in chapter 2 meet the refuge purposes. They also reflect 

that we believe we need more information to be able to effectively conserve fish and wildlife and 

habitats as required in the Innoko Refuge purposes.

Comment: In addition to implementing the Yukon-Innoko Moose Management Plan the Refuge 

could use fixes other Refuges used working with other agencies such as: Limit Entry Permit 

moose hunting, Create Control Use Area like the Koyukuk, No Fly Zones. The refuge should 

limit air taxis on how many moose hunters they can bring into the refuge during moose season 

just like the Registered hunting Guide Special Use Permit holders are. “No Fly Zones” need to 

J-2 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

be created across the refuge to preserve areas of pristine setting and will enhance all users 

Refuge experiences while on the Refuge. This would cut down on the impact from the increasing 

small aircraft traffic and provide areas free of the increasing airplane noise on the Refuge. 

Another option would be making the Refuge “No Fly 4 days.” Have limited access moose hunt 

permits for the refuge in September. Change the current regulation in GMU 21A to an “antler 

restriction.” Work with ADF&G to implement the latest predator control tools. The entire refuge 

should go to a limited entry draw for moose with separate allocations for residents, non-residents, 

and un-guided hunters and non-resident guided hunters. 

Response: Most of the proposals listed (e.g., limited entry permit moose hunting, controlled use 

areas) would require action by the Board of Game to be implemented. Current refuge data does 

not suggest that we need to limit the number of air taxis at this time. Objectives 75 (multiple-day 

recreation opportunities), 76 (public use monitoring), 77 (special use permits), 78 (law 

enforcement) and 80 (visitor services plan development) directly or indirectly address air taxi 

use. Many of the wildlife and habitat objectives address our concerns about moose populations 

(e.g., objectives 6–population estimates, 52–forage data, 53–forage condition, 54–fire and habitat 

relationships). Refuge surveys have not shown an increase in wolf numbers in the last five years. 

As indicated in appendix C, the Service has different management responsibilities than the State 

of Alaska relative to predator management. 

Comment: Air taxi and private small plane owners using the Refuge are having a “devastating” 

effect on the refuge. A solid plan needs to be immediately implemented to restrict the lighted 

regulated air taxi’s numbers of moose hunters they can bring to the refuge and the number of 

private small plane operators than can hunt on the refuge during moose season. 

Response: As indicated previously, we do not believe additional limitation of air taxi operators 

by the Service is warranted at this time. We have not documented an increase in private aircraft 

use of the refuge during our regular moose season law enforcement patrols. 

______________________________________________________________________________ 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-3 
Appendix J: Response to Comments 

 

 ANILCA IMPLEMENTATION PROGRAM 

 Office of Project Management and Permitting 

SARAH PALIN, Governor 

550 W. 7TH AVENUE, SUITE 705 

ANCHORAGE, ALASKA 99501 

PH: (907) 269-7529 / FAX: (907) 334-2509 

susan.magee@alaska.gov

 July 22, 2008 

Bill Schaff, Refuge Manager 

Innoko National Wildlife Refuge 

P.O. Box 69 

McGrath, AK 99627 

Dear Mr. Schaff: 

The State of Alaska reviewed the Draft Revised Comprehensive Conservation Plan (CCP) and 

Environmental Assessment (EA) for Innoko National Wildlife Refuge. The following represents 

the consolidated views of the State’s resource agencies. 

We appreciate the overall level of coordination that occurred during this planning process. As a 

result, we have few substantive comments. Our primary comments relate to the characterization 

of the State’s wood bison project and the portrayal of Refuge concerns regarding fisheries. The 

remaining comments are primarily informative in nature and often request inclusion of additional 

information or clarification in the final plan. Comments have been organized into the following 

categories: 

• Wood Bison 

• Fisheries Management 

• Goals and Objectives 

• Appendix C 

• Management Policies and Guidelines 

• Page-Specific Comments 

• Compatibility Determinations 

Wood Bison 

The State has a high interest in restoring wood bison to Alaska. In preparation, the Alaska 

Department of Fish and Game (ADF&G) recently transported over 50 wood bison from Canada that 

are now undergoing a 2-year quarantine before release. Three wood bison restoration areas are 

currently under consideration: Yukon Flats, Minto Flats and the lower Innoko/Yukon River area. Due 

to logistic and cost considerations, wood bison restoration in each area would initially involve release 

on private lands near a local community, with the understanding that bison would likely range onto 

other lands as the population grew. Bison would be expected to eventually expand to state and/or 

federal public lands, including the Innoko Refuge. 

J-4 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-5 

Currently the plan describes the wood bison project as an “introduction” in some sections and a 

“reintroduction” in others. (See pages 1-25, 2-2, 2-5, 2-93 and 3-85). These terms have different 

meanings and management implications and we find the term “introduction” problematic. For these 

reasons we request the CCP refer to the wood bison effort as “the State’s wood bison restoration 

project” (or simply “wood bison project”).

______________________________________________________________________________ 

Response: We changed references to wood bison to “the State of Alaska’s wood bison project.” 

______________________________________________________________________________ 

Moving beyond terminology, we understand that if wood bison populations expand on to the 

Refuge, the US Fish and Wildlife Service (Service) has a responsibility to monitor potential 

impacts and take or recommend management actions if necessary. Therefore, the State supports 

the general intent of Objective 11 on page 2-5 to monitor current and future wildlife populations 

and plant communities. We agree that “no data exist regarding how resident wildlife populations 

(such as small mammals, ground nesting birds, medium to large carnivores, and existing 

ungulates) and plant communities changed once wood bison were introduced.” Much is known, 

however, about bison and grazing ecology in northern latitudes. Also, the 2007 Environmental 

Review conducted by ADF&G1

, the joint Service/ADF&G review of wood bison restoration2, and 

other independent reviews3

 together indicate that, at the densities expected, bison will likely have 

negligible or beneficial effects on other wildlife and the environment. The discussion of potential 

long term monitoring efforts is also reasonable, while understanding there will be little or no 

measurable effects for several years following a restoration since bison numbers will remain small 

for some time. We invite the Innoko Refuge staff to contact ADF&G to clarify any questions or 

concerns about the project as it moves forward. 

The rationale for Objective 11 also appears to question whether wood bison existed in the area in 

relatively recent times. Although we recognize that no remains have yet been found on the Innoko 

Refuge, in a broader context, wood bison were very likely present in the Innoko region. Remains 

have been documented approximately 150 miles east, near Tanana; and 100 miles west, near St. 

Michael.4

 More recently, an oral history from an elder in Galena noted that he has heard stories 

referring to wood bison (the “big animal”) being present in the Kaiyuh Hills area in more recent 

times, though a specific date is unknown5

. 

It is not surprising remains have not been found on Innoko Refuge, given the terrain (silty rivers 

with mud banks yield few remains compared to waterways with gravel bars). In addition, focused 

 

1

 Wood Bison Restoration in Alaska: A Review of Environmental and Regulatory Issues and Proposed 

Decisions for Project Implementation, 2007 

2

 found in Appendix A in the above-referenced Environmental Review 3

 conducted by the Wildlife Society-Alaska Chapter and the Wildlife Transplant Policy review committee as 

reported in Appendix F of the above-referenced Environmental Review 4

 Skinner, M.F., and O.C. Kaisen ,1947. The Fossil Bison of Alaska and Preliminary Revision of the Genus. 

Bulletin of the American Museum of Natural History 89:126-256; as noted in STEPHENSON, R. O., S. C.

GERLACH, R. D. GUTHRIE, C. R. HARINGTON, R. O. MILLS, AND G. HARE. 2001. AND Wood bison in late 

Holocene Alaska and adjacent Canada: paleontological, archaeological and historical records. Wildlife 

and People in Northern North America. Essays in honor of R. Dale Guthrie. S. C. Gerlach, and M. S. 

Murray, editors. British Archaeological Reports, International Series 944.) 

5

 personal communication from Glenn Stout, Galena Area Biologist, ADF&G 
Appendix J: Response to Comments 

efforts to search for wood bison remains on the refuge itself have not occurred; although, the 

remains of earlier forms of bison have been found in the region. Lastly, the ample suitable habitat in 

the area further supports the premise that wood bison occurred on the Refuge in the recent past. 

______________________________________________________________________________ 

Response: No response necessary. 

______________________________________________________________________________ 

Fisheries Management 

3.3.3.10 Fish

The following comments address sections located on page 3-86. We recognize the purpose of 

these sections is to address Refuge concerns regarding fisheries; however, the discussion appears 

overly negative without also recognizing existing management practices or other sections of the 

plan that help alleviate the concerns. 

Increased Fishing Pressure 

We appreciate the discussion in Environmental Consequences (Page 4-6, Section 4.2.2.2 Fish 

Populations) that recognizes “neither alternative is anticipated to result in over-harvesting under 

current or projected levels of fishing pressure” and that “the refuge would work with the 

appropriate State and Federal regulatory or management bodies should adverse effects occur.” 

We request this information as well as references to the fishery-related Objectives (2, 17, 34, 69 

and 74) be referenced in this section so readers are aware of proposed actions to address these 

concerns. 

______________________________________________________________________________ 

Response: We added a sentence listing the objectives that address this concern. 

______________________________________________________________________________ 

Alteration of Wild Salmon Stocks Caused by Artificial Salmon Enhancement 

Some stocks of salmon in the Yukon Drainage have shown variability in abundance, which is 

normal in wild salmon stocks. While a limited mitigation program exists to supplement Chinook 

salmon production lost to the Whitehorse Dam in Canada, there are no enhancement programs 

presently contemplated elsewhere in the Yukon. The discussion of potential impacts of salmon 

enhancement activities seems unnecessarily pessimistic and does not account for state procedures 

in place to prevent these impacts. Also, since Yukon River hatcheries are unlikely, a specific 

reference to hatchery fish seems unnecessary and is already covered by the general statements. 

Finally, should enhancement programs be proposed and evaluated, ADF&G has highly developed 

processes to ensure the genetic viability and maintenance of all affected fish stocks. To address 

these concerns, we recommend the following revision of the last half of this section: 

However, enhancement could develop large populations of particular stocks that would be 

heavily exploited. Such high exploitation of enhanced stocks could lead to pressure on 

more vulnerable smaller stocks. However, ADF&G has rigorous policies and guidelines 

for preventing or mitigating the potential for inadequate escapement, loss of genetic 

diversity, or an unsustainable harvest. If carefully planned and implemented under both 

State and Service protocols, enhancement could supplement wild salmon production and 

safely increase salmon harvests. 

J-6 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

______________________________________________________________________________ 

Response: We made the requested changes with a few edits.

______________________________________________________________________________ 

In addition, we request the word “artificial” be removed from both the heading and the second 

sentence. “Artificial” is not defined, while the term “enhancement” is consistent with the 

Management Policies and Guidelines outlined in Section 2.4, and Table 2-2. 

______________________________________________________________________________ 

Response: We deleted the word “artificial” as requested. 

______________________________________________________________________________ 

Off-Refuge Harvest of Refuge Whitefish and Salmon Stocks 

This section correctly states that mixed stock harvests can affect population size and structure; 

however, management of salmon harvests in the Yukon River is specifically designed to avoid 

affecting individual stocks of fish. Genetic sampling techniques can rapidly identify particular 

stocks of fish in-season, but it is expensive and not often done. We therefore request revision of 

the second sentence: “Because genetic fish sampling that can rapidly identify particular fish 

stocks is expensive and rarely used, individual fish stocks could be disproportionately harvested 

during a harvest.” We also request the addition of a new sentence at the end of this section to 

avoid the impression that these legitimate management issues are not routinely addressed: 

“ADF&G considers all these factors in fishery management to avoid long term detrimental 

impacts.” 

______________________________________________________________________________ 

Response: We made the requested changes. 

______________________________________________________________________________ 

Other Page-Specific Fishery Comments

Page 3-99, 3.4.5, Subsistence, fourth paragraph: We request noting that while salmon stocks had 

reduced abundance from 1998-2002, overall they have displayed the normal variability in 

abundance expected for wild salmon stocks. There was a record fall chum run in 2005 and near 

record summer chum run in 2006. As currently written the paragraph gives the impression of 

steadily declining stocks of salmon, which is not the case. Windisch-Cole is dated and more recent 

information is available. Please see: 

• Yukon River Fall Chum Salmon Stock Status and Fall Season Salmon Fisheries; a 

 Report to the Alaska Board of Fisheries (SP No. 06-36 - PDF file (1010K) 

http://www.sf.adfg.state.ak.us/FedAidPDFs/sp06-36.pdf

• Yukon River Summer Chum Salmon Stock Status, 2006; a Report to the Alaska Board of 

Fisheries (SP No. 06-34) - PDF file (354K) 

http://www.sf.adfg.state.ak.us/FedAidPDFs/sp06-34.pdf

• Potential Causes of Size Trends in Yukon River Chinook Salmon Populations 

(RIR No. 06-07) - PDF file (405K) 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-7 
Appendix J: Response to Comments 

http://www.cf.adfg.state.ak.us/region3/pubs/yukon/06bofjtcchin.pdf

The following is a suggested rewrite of the fourth and fifth paragraphs of section 3.4.5 (Subsistence) 

that we feel provides a more appropriate description of the status of fish in the region: 

Fish are the most relied upon subsistence resource in the Innoko Region. Subsistence 

fishing occurs year-round, although summer and fall salmon runs have historically been 

the most important in terms of catch volume. Salmon and other fish are typically 

harvested with nets and preserved for later use. The Yukon River and its tributaries 

provide the bulk of salmon harvested, but these stocks can show substantial variability in 

seasonal abundance, as normally expected in wild salmon stocks. Very low salmon 

returns were recorded in the Yukon River drainage in 2000 and 2001, but some stocks 

rebounded with record or near record returns for portions of the chum salmon run in 

2005 and 2006. (ADF&G 2006)

Specific subsistence harvest figures for salmon are not available for individual area 

villages over time, but in 2005, 159 households in Grayling, Anvik, Shageluk, and Holy 

Cross reported harvesting a combined total of 6,321 Chinook and 8,296 chum salmon 

(ADF&G 2005). In 1990-91, these residents harvested approximately 61,000 pounds nonsalmon fish species. During periods of low salmon returns, such as those experienced in 

2000-01, subsistence users reliance on species of fish other than salmon increased. These 

include whitefish, northern pike, sheefish, burbot, Arctic grayling, longnose sucker, 

Alaska blackfish, and lampreys. (Brown 2007)

______________________________________________________________________________ 

Response: The requested changes were made. 

______________________________________________________________________________ 

Management Policies and Guidelines 

The revised draft CCP does not contain the most recent language in the Regional Management 

Policies and Guidelines. A number of technical changes and updates have been made since 

January 2007. Attachment A itemizes requested changes that represent the most recently 

agreed-upon version of this mutually acceptable language. 

______________________________________________________________________________ 

Response: The technical corrections requested were made. 

______________________________________________________________________________ 

Goals and Objectives 

Page 2-3, 2.1, Objective 6, Rationale, first paragraph, last sentence: The Alaska Board of Game 

and the Federal Subsistence Board make decisions concerning allocation of wildlife. The refuge 

provides information to these deliberative boards to aid in decision making processes. We suggest 

the following revision: 

Refuge Managers need current information on the status and trend of the moose 

population to assist with decisions affecting allocation of this resource and to continue 

participating.... 

J-8 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

______________________________________________________________________________ 

Response: The sentence was rewritten to read as follows: “Refuge managers need current 

information on the status and trend of the moose population to assist with decisions affecting 

management of this resource and to continue participating....” 

______________________________________________________________________________ 

Page 2-16, 2.1, Objective 54, Rationale, first sentence: Moose are important to subsistence users 

as well as others, both locally and regionally. Consistent with Objective 27, we suggest the first 

sentence be revised as follows: 

Both moose and caribou are important to humans in Interior Alaska, and it is... 

______________________________________________________________________________ 

Response: No change was made. The statement reflects the rationale documenting the refuge 

staff’s rationale for the objective. 

______________________________________________________________________________ 

Page 2-17, Objective 54, Rationale, last sentence: Consistent with our comment for Objective 6, 

we request the following revision: 

This information will assist the refuge, agencies and Boards responsible for management 

of moose and caribou populations, as well as fire. 

______________________________________________________________________________ 

Response: The sentence was changed to read as follows: “This information will assist agencies 

and Boards in managing moose and caribou populations and fire.” 

______________________________________________________________________________ 

Appendix C, Predator Control

We understand this appendix is currently under review and may change. If retained, we request 

use of the revised version. 

______________________________________________________________________________ 

Response: The revised version of the appendix appears in the final plan. 

______________________________________________________________________________ 

Page Specific Comments

Page 2-81, 2.9.2, Management Categories, Wilderness Management, fourth sentence: Though we 

recognize this language is carried forward from the previous CCP, the reference to “traditional 

motorized access” nonetheless mischaracterizes access provisions in the Alaska National Interest 

Lands Conservation Act (ANILCA). ANILCA Section 1110(a) allows specific modes of access for 

“traditional activities.” ANILCA Section 811(b) references “and other means of surface 

transportation traditionally employed...” To avoid the need to clarify these nuances, we 

recommend the sentence be rewritten as follows: 

Motorized access pursuant to ANILCA Sections 811 and 1110 is allowed. 

______________________________________________________________________________ 

Response: No change made, as this section does not appear in the final plan. 

______________________________________________________________________________ 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-9 
Appendix J: Response to Comments 

Page 2-86, 2.10.2, last sentence: It is inaccurate to indicate that “any activity” conducted in 

Wilderness would be subject to a minimum requirements analysis. Please clarify that this applies 

only to certain administrative activities as shown in the footnote and associated notation within 

Table 2-2. 

______________________________________________________________________________ 

Response: This section is not in the final plan. References to minimum requirements analyses 

indicate that they apply to read: “Management activities.” 

______________________________________________________________________________ 

Page 2-93, Table 2-8, Air Taxi Issue, Alternative B: We request that the table be revised 

consistent with Table 1 in the Summary of the Draft Revised CCP and EA (see also section 1.9.2, 

page 1-24), which states: 

The Refuge proposes to address this issue through continued monitoring of air taxi 

operators and potential future visitor service planning.

______________________________________________________________________________ 

Response: No change is necessary, as this table does not appear in the final plan. 

______________________________________________________________________________ 

Page 3-5 and 3-6, 17(b) Easements and Figure 3-1: Our records show the three listed easements 

(site 39aC5, site 1D1 and trail 8D1) but also show the following two easements in the Holy Cross, 

D-2 Quad: trails EIN 39a C5 and 22 C5. A more thorough review of the conveyance files was not 

performed; however, the Quad maps showing these easements are assumed by the BLM to be 

accurate and are updated with each Decision document. The Holy Cross, D-2 Quad revisions were 

done in 2003. 

______________________________________________________________________________ 

Response: Currently, there are two one-acre site easements and one trail easement in the Innoko 

Refuge (figure 3-1). However, additional 17(b) easements may be created as the Bureau of Land 

Management conveys remaining land entitlements to Native corporations. Currently, a one-acre 

site easement (39a C5) and two trail easements (39 C5 and 22 C5) have been proposed. These 

easements do not exist because the lands have not been conveyed. We do not show “proposed” 

easements on our maps. 

______________________________________________________________________________ 

Page 3-6, 3.1.1.8, RS 2477 Rights-of-Way: Please revise this section to reflect our most recent 

agreement on May 28, 2008. An alternative solution might be to limit this section to only Table 3-2 

and a reference to section 2.4.13.9. 

______________________________________________________________________________ 

Response: The language has been changed as requested. 

______________________________________________________________________________ 

Page 3-73, 3.3.2.4, Wolf, second paragraph: The density of wolves appears to be incorrectly 

referenced. The given estimate likely applies to density per 1,000 square miles rather than per 

square mile. 

J-10 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

______________________________________________________________________________ 

Response: We made the correction; the density is per 1,000 square miles rather than per square 

mile. 

______________________________________________________________________________ 

Page 3-85, 3.3.3.6, Moose, first paragraph, second sentence: Please replace the reference to 

“sport” hunters with “non-local” hunters. State general hunting regulations no longer reference 

the term “sport.” “Non-local” adequately distinguishes between the two user groups in this 

context. 

______________________________________________________________________________ 

Response: We changed the sentence to read “other hunters.” 

______________________________________________________________________________ 

Page 3-85, 3.3.3.7, Predator Control: While the discussion of the subject is accurate, we request 

that the heading and narrative be revised to change the term “control” to “management.” This 

term more accurately reflects recent discussions and direction taken concerning the management 

of predator populations in Alaska. 

______________________________________________________________________________ 

Response: We did not change this section, as the State of Alaska Web site and recent public 

information provided by the Alaska Department of Fish and Game titles this particular 

management as “predator control.” Note that appendix C uses the phrase “predator 

management,” as it is broader in scope. 

______________________________________________________________________________ 

Page 3-85, section 3.3.3.8. This discussion notes that “little time is available to document existing 

conditions from which to measure future changes, if any.” Since it will be at least several years 

before bison are likely to make their way to the Refuge from the initial off-Refuge project location, 

we question the basis for the concern that the Refuge may not have enough time to design and 

implement any actual monitoring that might be determined necessary. See general wood bison 

comment. 

______________________________________________________________________________ 

Response: The most recent information provided to the refuge was that wood bison could be 

placed near the refuge in 2011. Therefore, the section has not been changed. 

______________________________________________________________________________ 

Pages 3-99 thru 3-101, Section 3.4.5, Subsistence: Harvest data for refuge area communities 

compiled by the Division of Subsistence are the primary source of information used in this section 

and are believed to be reasonably accurate. However, where harvest numbers are presented, we 

request the text be revised to read similar to the following: “A total of 118 moose were reported

harvested,” “just two caribou were reported as being harvested,” etc. The qualifier “reported” is 

important because it is possible that household surveys did not capture all the resources 

harvested, either because all households were not interviewed or a small number of households 

may have underreported their harvest. 

______________________________________________________________________________ 

Response: The requested changes were made. 

______________________________________________________________________________ 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-11 
Appendix J: Response to Comments 

Page 3-115, 3.5.1, Characteristics Common to All Units, first paragraph, second sentence: 

Consistent with the 1988 Innoko Record of Decision and pages 1-6 and 2-65 of the current draft, 

we request these pages be referenced and the section clarify that the Wapoo Hills and Kaiyuh 

Mountains units were not recommended for designation in the previous wilderness review. We 

suggest the following revision: 

Though not recommended for designation in the previous wilderness review, most of the 

refuge lands within the Wapoo Hills and Kaiyuh Mountains units also exhibit all the 

core wilderness values. 

______________________________________________________________________________ 

Response: We have added the language on page 2.65 of the draft plan to section 3.5.1 of the final 

plan because that section of the draft plan does not appear in the final plan. 

______________________________________________________________________________ 

Page 4-11, Section 4.6, Section 810 Evaluation. Although this is a very short and general 

evaluation, it is likely sufficient. We note, however, the 810 analysis in the Tetlin CCP is also short 

but provides more detail. A similar level of detail might be useful in the 810 analysis for the 

Innoko plan. It may also be helpful to clarify that subsequent 810 analyses will be done as needed 

if specific commercial or other activities are proposed in the refuge that could potentially affect 

subsistence uses or resources. We offer the following revision to the last sentence of the 810 

analysis: 

This evaluation concludes that the actions proposed in this management plan would not 

result in restrictions of subsistence uses; however, additional 810 analyses may be 

required during the implementation of this plan for specific proposals and actions. 

______________________________________________________________________________ 

Response: No changes were made, as this section does not appear in the final plan. 

______________________________________________________________________________ 

Compatibility Determinations 

The term “high quality” is found in several compatibility determinations (CDs) (e.g., pages F-15, 

F-74, F-81, and F-84). We request all references to “high quality” be revised consistent with 

Service Manual 605 FW 1.6, which provides direction applicable to both commercial and 

recreational uses on refuges. FWS policy defines “quality” but not “high quality.” Use of “high 

quality” implies that other areas or experiences may be of low quality, which is not a desirable 

message. More importantly, we are concerned when this terminology is used in a management 

direction or objectives context, as it appears to set a high bar for management purposes but 

without any definition or standards. We suggest performing a word search on all CDs to remove 

“high quality” qualifiers when they may indicate or imply a management standard for experiential 

purposes. 

______________________________________________________________________________ 

Response: The word “high” was eliminated from the phrase “high-quality” in all the 

compatibility determinations except the Commercial Big Game Hunting Guide Services 

compatibility determination. The ability to provide high-quality hunts as defined in the 

prospectus is a key selection factor for big game hunting guide applicants. 

______________________________________________________________________________ 

J-12 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

Pages F-14 and F-15, Recreational Hunting, Stipulations (also relating to page F-4, Subsistence): 

No stipulations are required for subsistence use or many other uses, such as determining 

sustainability of practices through harvest monitoring, enforcement, etc. In contrast, similar 

activities by the small fraction of recreational hunters have such stipulations. An explanation of 

these inconsistencies is warranted or, consistent with recent resolution for this same issue in the 

Kanuti CCP/EA, we suggest imposing similar or identical stipulations for both subsistence and 

recreational hunting. 

______________________________________________________________________________ 

Response: We added a similar stipulation to the subsistence compatibility determination. 

______________________________________________________________________________ 

Page F-29, Snowmobiling, Description of Use: Snowmobiling is also addressed as a primary use 

in another CD. To avoid confusion, we recommend the following edit to the last sentence: 

(See also Compatibility Determinations on Trapping and Non-Wildlife Dependant 

Recreation Activities)

______________________________________________________________________________ 

Response: We made the suggested change. 

______________________________________________________________________________ 

Page F-30, Snowmobiling, Justification: We recommend incorporating a reference to ANILCA 

provisions, particularly for Titles VIII and XI, into this section. 

______________________________________________________________________________ 

Response: We added a reference to the ANILCA provisions about snowmobiles. 

______________________________________________________________________________ 

Page F-33, Subsistence and trapping cabins, Description of Use, first paragraph, last sentence: 

We request “local rural residents” be changed to “other trappers” because use of trapping cabins 

is not limited to local rural residents. 

______________________________________________________________________________ 

Response: We deleted the phrase “local rural residents.” 

______________________________________________________________________________ 

Page F-42, Subsistence Harvest of House Logs, Refuge Special Conditions, fourth bullet: When 

evaluating permits on their merits, as noted in the Description of Use, we recommend the Refuge 

consider both the needs of the applicant as well as the following considerations for the resource. 

Concerns for clear-cutting or group selection are not well explained and, if the intent is to 

maintain white spruce in the area, seem counterproductive. If impacts to wild character from 

overly large openings or loss of diversity are the concern, group selection could still be a good 

choice. One of the benefits of group selection can be the long-term maintenance of white spruce 

stands, as the opening will warm the forest soils, thus preventing the development of permafrost. 

Riparian white spruce stands in the far north typically begin to cool as the trees mature and the 

organic layer accumulates to greater depths. This cooling can result in the development of 

permafrost and the loss of the white spruce stands, which then convert to black spruce. In 

addition, because the Anticipated Impacts of Use section addresses minimizing impacts to 

anadromous fish, we question why the restrictions specifically do not apply to “leaners.” These 

trees would contribute large woody debris to the river more rapidly than trees further from the 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-13 
Appendix J: Response to Comments 

river bank. Large woody debris has been shown to be of significant value to fish habitat and 

stream/river dynamics, even in very active rivers in the far north. 

______________________________________________________________________________ 

Response: We did not make the recommended changes. We are not trying to change forest 

succession in the area. Also, while “leaners” may contribute to large woody debris, they have 

traditionally been harvested by local residents for many years with no evidence of adverse effects 

on aquatic habitats. 

______________________________________________________________________________ 

Page F-47, Scientific Research, first full paragraph on page: Not all refuge uses which are 

“allowed” require a special use permit. We suggest the following revision of the first sentence: 

A special use permit may be required before certain uses on the refuge may be authorized. 

This permit may contain stipulations to help ensure compatibility with refuge purposes. 

______________________________________________________________________________ 

Response: We changed the section to read as follows: “When a special use permit is required, 

stipulations are included to ensure compatibility.” 

______________________________________________________________________________ 

Page F-56, Helicopter Landings, Stipulations, third bullet: We understand the introductory 

paragraph currently indicates regional stipulations are “typical” and may not appear in all 

permits. However, since certain activities may require flying a helicopter at altitudes below 2000 

feet and/or herding wildlife for scientific research or management, we request substituting the 

more comprehensive introductory language from the Tetlin Refuge CDs (noted below). For 

consistency, we recommend also including it in other CDs with permit stipulations: 

The conditions listed below are generally included on refuge permits issued for 

[helicopter landings], mostly to minimize impacts and ensure compatibility of these uses 

with refuge purposes. Conditions included on each permit may vary somewhat as needed 

or appropriate for the specific operations being proposed, and if changing situations 

warrant revisions. 

______________________________________________________________________________ 

Response: We did not make the change requested. The specifics of any helicopter landing special 

use permit will be addressed on the face of the permit and in the special conditions attached to the 

permit. We further clarified this under the stipulations section of the compatibility 

determination. 

______________________________________________________________________________ 

Page F-61, Commercial Transporter Services, Description of Use, last paragraph: It is unclear 

how advance permitting prevents overcrowding when there is no limit on the number of trips or 

clients that can be dropped off. There is also no data provided to link the number of clients being 

dropped off with the quality of experience and no programs to understand the experiential values 

of the area. We recommend ending the third sentence as follows: “...and potentially producing 

an overcrowded situation.” 

______________________________________________________________________________ 

Response: We made the requested change. 

______________________________________________________________________________ 

J-14 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

Page F-68, Commercial Big Game Hunting Guide Services, italicized paragraph on 2005 

Prospectus: While we understand that the 2005 prospectus was allocated using this direction, it 

would be useful to note that future allocations would utilize the more recent processes described in 

605 FW 1 General Guidelines for Wildlife-Dependent Recreation and 605 FW 2 Hunting. 

______________________________________________________________________________ 

Response: We did not make the requested change. The process we use for selecting Commercial 

Big Game Guide Hunting Services follows our Alaska specific regulations in 50 CFR 36.41. 

______________________________________________________________________________ 

Page F-95, Reburial of Archaeological Human Remains per State and Federal Guidelines, Public 

Review and Comment: We assume this text is in error, as it appears in the public review draft of 

the revised CCP and comments are still being accepted. 

______________________________________________________________________________ 

Response: The comment is correct. 

______________________________________________________________________________ 

Page F-97, Reburial of Archaeological Human Remains, second bullet on page: It is unclear why 

this CD includes a condition prohibiting helicopter use when it can be allowed by special use 

permit under 43 CFR 36.11(f)(4). We understand this is a “typical” regional stipulation, therefore, 

we again request the introductory language from the Tetlin CDs (see above comment for F-56) be 

applied to this CD. 

______________________________________________________________________________ 

Response: We did not make the requested changes. We chose to not allow helicopter use for this 

activity, as we do not believe it is necessary. 

______________________________________________________________________________ 

Regional Stipulations Necessary to Ensure Compatibility

We understand many of the compatibility stipulations are also regional permit conditions. We 

have brought the following comments to the attention of the Region to address in a region-wide 

review of permit stipulations. We provide them here for your information within the context of 

this review. 

• “Use of off road vehicles (except snowmachines with adequate snow cover) is prohibited 

unless specifically authorized in writing in this permit.” 

 50 CFR 36.2 specifically excludes snowmachines from the definition of ORVs. Including 

“except snowmachines” in this stipulation inaccurately implies snowmachines are ORVs. 

We request the phrase in parentheses be removed and when necessary, snowmachine use 

be addressed by separate stipulation(s). 

 

• “The permittee will take no action that interferes with subsistence activities...” 

As written, this stipulation provides no allowance for accidental incidents or instances 

where a permit holder is not aware they are interfering with subsistence uses. For 

clarification and enforcement reasons, we suggest inserting “intentionally” before 

“interferes.” 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-15 
Appendix J: Response to Comments 

• “The permittee or his/her primary users shall notify the refuge manager during refuge 

working hours in person or by telephone before beginning and upon completing activities 

allowed by this permit.” and; 

• “Prior to beginning any activities allowed by this permit, the permittee shall...” 

 

For the two bullets above, it may be useful to include more specific timeframes in which 

notification must occur. 

______________________________________________________________________________ 

Response: As indicated in the beginning of the comment, no response is necessary. These 

comments have been previously provided to the division responsible for regional special use 

permit conditions. 

______________________________________________________________________________ 

Thank you for this opportunity to comment. Please contact me at (907) 269-7529 if you have 

any questions. 

 Sincerely, 

 /ss/ 

 Susan E. Magee 

 ANILCA Project Coordinator 

cc: Sally Gibert, ANILCA Program Coordinator 

______________________________________________________________________________ 

J-16 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

Bill Schaff, Refuge Manager 

Innoko National Wildlife Refuge 

P.O. Box 69 

McGrath, AK 99627 

(Innoko@fws.gov) 

(fw7_Innoko_planning@fws.gov) 

(Sent via electronic mail) 

July 22, 2008 

RE: INNOKO NATIONAL WILDLIFE REFUGE CCP REVISION 

Dear Mr. Schaff: 

Thank you for the opportunity to comment on the Draft Environmental Assessment of the Innoko 

National Wildlife Refuge Comprehensive Conservation Plan (CCP) Revision. Please accept the 

following as comments submitted by The Wilderness Society. 

The Wilderness Society (TWS), founded in 1935, is a non-profit membership organization devoted 

to preserving wilderness and wildlife, protecting America's prime forests, parks, rivers, deserts, 

and shorelines, and fostering an American land ethic. With 225,000 members nationwide, TWS 

has approximately 758 members in Alaska, all of whom share an interest in how the Innoko 

National Wildlife Refuge is managed. 

First, we recognize and commend the good work that has gone into identifying the purposes, 

values and research goals of the Refuges outlined by the U.S. Fish and Wildlife Service (the 

Service) in the Draft CCP. In general, we support the Service’s goals and objectives for the 

Refuge, and the Service’s preferred alternative. 

We also appreciate that the Service is planning to maintain all non-designated wilderness lands in 

the refuge in the minimal management category. We strongly support this choice. 

We also support the vision that the Service has outlined in terms of growth and necessary 

additional staff, and we support the requests for additional funding for the refuge. 

Finally, we are encouraged to see that the Service has included climate change as an issue within 

the Draft CCP revision. Please refer to additional comments regarding climate change below. 

TWS does have some significant concerns with the Draft CCP, and these along with other 

specific comments are as follows: 

I. Wilderness Reviews: 

The Service has clarified that the CCP revision process is one where refuges will be evaluated and 

lands designated related to their resources and values. In a newsletter regarding the Kenai 

National Wildlife Refuge CCP revision process, for example, the agency indicated: 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-17 
Appendix J: Response to Comments 

These plans designate areas within the Refuge according to their resources and values; 

specify programs for conserving fish and wildlife and maintaining other special values of 

the Refuge . . .. 

Both existing and potential future designated wilderness is a resource and a value of the refuges 

which must be addressed. The Service’s laws and policies require that wilderness reviews be 

conducted as part of the CCP process. However, the Service has failed to complete wilderness 

reviews or make recommendations for future wilderness designation thus far in the CCP revision 

process for Innoko Refuge. 

For example, Section 304(g)(1) and (2) of the Alaska National Interest Lands Conservation Act 

(ANILCA) directs the Service to develop and periodically revise CCP’s which must identify and 

describe the special values of the refuge, including wilderness values. Specifically, the Alaska 

National Interest Lands Conservation Act (ANILCA) Section 304(g) states: 

(1) The Secretary shall prepare, and from time to time, revise, a comprehensive 

conservation plan (hereinafter in this subsection referred to as the ‘plan’) for each refuge. 

(2) Before developing a plan for each refuge, the Secretary shall identify and describe – 

 (A) the populations and habitats of the fish and wildlife resources of the refuge; 

 (B) the special values of the refuge, as well as any other archeological, cultural, 

ecological, geological, historical, paleontological, scenic, or wilderness value of the refuge;” 

Additionally, Section 1317(a) of ANILCA directs the Service to study all of the non-wilderness 

lands in Alaska refuges and recommend areas suitable for inclusion in the National Wilderness 

Preservation System. Section 1317(a) of ANILCA states: 

Within five years from the date of enactment of this Act, the Secretary shall, in accordance 

with the provisions of section 3(d) of the Wilderness Act relating to public notice, public 

hearings and review by State and other agencies, review, as to their suitability or 

nonsuitability for preservations as wilderness, all lands within units of the National Park 

System and units of the National Wildlife Refuge System in Alaska not designated as 

wilderness by this Act and report his findings to the President. 

While the Service completed a process to determine wilderness recommendations in the 1980’s, 

the Secretary of the Interior never forwarded the recommendations to the President. Therefore, 

the Service still has not met the requirements of Section 1317 of ANILCA. 

Additionally, the National Environmental Policy Act requires that an agency analyze a reasonable 

range of alternatives in every agency action, such as a planning process like the CCP Revision. 

Because all values and uses of the refuges must be considered in a broad planning effort such as a 

CCP revision, analysis of wilderness recommendations is included within the reasonable range of 

alternatives. 

The Service’s Refuge Planning Policy (65 Federal Register 33892, May 25, 2000), which “applies to 

all units of the National Wildlife Refuge System” (ie., it applies to refuges in Alaska) (602 FW 1.2), 

also requires that a new wilderness review be conducted as one of the required elements of all 

CCP's. Specifically, the Service’s planning policy directs the following: 

J-18 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

• “Concurrent with the CCP process, we will conduct a wilderness review and incorporate a 

summary of the review into the CCP” (602 FW 3.4(C)(1)(c); 

• “Identify and describe the following conditions and their trends for the planning unit and, as 

appropriate, for the planning area: ... (xx) Existing special management areas, or the potential 

for such designations (e.g. wilderness, research natural areas, and wild and scenic rivers” (602 

FW 3.4(C)(1)(e); 

• “Develop a range of alternatives, or different approaches to planning unit management, that 

we could reasonably undertake ... to help achieve the goals of the National Wilderness 

Preservation System” (602 FW 3.4(C)(4)(b); 

• The “Checklist of Required Comprehensive Conservation Plan Elements” found in Exhibit 3-3 

of the planning policy includes “Wilderness review.” “Wilderness review” is defined in the 

policy as “[t]he process we use to determine if we should recommend Refuge System lands and 

waters to Congress for wilderness designation. The wilderness review process consists of 

three phases: inventory, study, and recommendation. The inventory is a broad look at the 

refuge to identify lands and waters that meet the minimum criteria for wilderness. The study 

evaluates all values (ecological, recreational, cultural), resources (e.g. wildlife, water, 

vegetation, minerals, soils), and uses (management and public) within the Wilderness Study 

Area. The findings of the study determine whether we will recommend the area for 

designation as wilderness.” 

Additionally, “Fulfilling the Promise: The National Wildlife Refuge System”, the Service’s vision 

document, released in March 1999, guides administration of the Refuge System. That document 

directs in part that: 

The Service should evaluate lands added to the System since the Service completed its 

wilderness reviews and recommend suitable areas for designation. In addition, the Service 

should take a fresh look at areas previously studied for suitability as wilderness that were 

not recommended. For example, while the Service determined, in 1985, that 52.7 million 

acres of refuge lands in Alaska qualified for designation as wilderness, only 3.4 million 

acres were recommended for such designation. On many refuges, circumstances and 

management may have changed since the recommendations were made (pg. 23). 

Thus, the legal requirements for including wilderness reviews and recommendations within CCP 

revision processes are clearly laid out, and TWS requests that the Service sufficiently review 

wilderness lands and make a range of wilderness recommendations within the Alternatives to be 

analyzed in the CCP revision process. Without completing a wilderness review and/or making 

recommendations for wilderness, we believe the Service is out of compliance with ANILCA, the 

National Environmental Policy Act (NEPA) and the agency’s own policies and guidelines. The 

U.S. District Court ruled in 2001 (Sierra Club v. Lyons, No. J00-0009-CV (D. Alaska March 30, 

2001)) in a similar situation that the Forest Service needed to complete a wilderness review and 

analyze wilderness recommendations for the Tongass Land Management Plan in order to satisfy 

requirements of NEPA. At this time we do not believe the Service has met the legal and 

regulatory requirements for refuge CCP planning. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-19 
Appendix J: Response to Comments 

We believe the Service’s decision not to review or recommend lands for wilderness 

recommendations is lacking and out of compliance with federal laws and agency regulations. We 

strongly urge the Service to complete wilderness reviews and recommendations in this 

comprehensive conservation planning process. 

______________________________________________________________________________ 

Response: After a thorough review of ANILCA section 304(g) planning requirements and the 

Refuge System planning policy, the Service determined that, until our wilderness review policy 

is complete, we could best meet the ANILCA requirements by identifying the special values of the 

refuge and providing clearer direction for how the refuge will be administered to protect these 

values without conducting a wilderness review. See section 2.7.2 of the draft plan. Wilderness 

values are described in chapter 3. Note: The Service wilderness policy released on November 17, 

2008, states (610 FW 5.17), “We have completed wilderness reviews for refuges in Alaska in 

accordance with section 1317 of ANILCA. Additional wilderness reviews as described in the 

refuge planning policy (602 FW 1 and 3) are not required for refuges in Alaska. During 

preparation of comprehensive conservation plans for refuges in Alaska, we follow the provisions 

of section 304(g) of ANILCA, which requires us to identify and describe the special values of the 

refuge, including wilderness values. Subsequently, the comprehensive conservation plan must 

designate areas within the refuge according to its respective resources and values, and specify the 

programs for maintaining those values. However, ANILCA does not require that we incorporate 

formal recommendations for wilderness designation in comprehensive conservation plans and 

comprehensive conservation plan revisions.” 

______________________________________________________________________________ 

II. Wild and Scenic Rivers: 

There are currently no designated Wild and Scenic Rivers within the Innoko National Wildlife 

Refuge. As is true with wilderness recommendations, the Service has opted not to include Wild 

and Scenic River recommendations in this CCP revision process. 

We believe the Service is missing an important opportunity to recommend Wild and Scenic Rivers 

for the Refuge. We believe the Service must give consideration to potential national wild, scenic 

and recreational river areas. 16 U.S.C. Sec. 1276(d)(1). The draft CCP identifies outstanding 

rivers and river segments, but the Service should do more, including evaluating and 

recommending whether these rivers should be designated as Wild and Scenic Rivers. 

______________________________________________________________________________ 

Response: After a thorough review of ANILCA section 304(g) planning requirements and Refuge 

System planning policy, we determined that we would best meet ANILCA requirements by 

identifying the special values of the refuge without conducting a wild and scenic rivers review. 

Section 2.7.1 of the draft plan provides the Service’s rationale for not conducting wild and scenic 

river reviews. River values are described in chapter 3. 

______________________________________________________________________________ 

III. Motorized and Mechanized Activities: 

Congress created limited exceptions in ANILCA to the restrictions normally implemented for 

motorized uses in conservation system units, including designated wilderness. These were 

important exceptions designed to accommodate and maintain opportunities for legitimate 

subsistence uses, which honor Alaska Natives and other rural Alaskans and their subsistence way 

of life. Specifically, ANILCA allows for subsistence purposes the use of snowmachines, 

motorboats and “other means of surface transportation traditionally employed for subsistence.” 

J-20 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-21 

In addition, ANILCA allows snowmachines, motorboats and fixed-wing aircraft to be used in 

designated wilderness and other conservation system units for “traditional activities” and travel to 

and from homesites. 

As outlined in the ANILCA Report of the Senate Committee on Energy and Natural Resources, 

traditional activities include “traditional and customary activities,” such as subsistence and sport 

hunting, fishing, berrypicking and travel between villages and homesites (Senate Report 96-413, 1979). 

Congress never intended to include recreational activities in the category of traditional activities. 

TWS strongly supports the restrictions regarding motorized access outlined in Table 2-2 of the 

draft revised CCP EA and believe they are in keeping with ANILCA. We also feel strongly that 

the restrictions related to ORV use are very important ecologically. Studies have shown that ATV 

use, for example, causes compaction and displacement of soils, erosion and sedimentation of 

riparian areas, air pollution, spread of invasive species, habitat destruction and fragmentation, and 

displacement and stress to wildlife populations. Studies in Wrangell St. Elias National Park and 

Preserve found that low levels (10 passes) of ATV use over tussock-shrub terrain causes 

substantial resource damage.6

 We believe that cross-country, disbursed ATV travel and the 

resultant proliferation of user-developed routes are especially damaging to Refuge lands. 

The Service has a responsibility to take protective measures before damage occurs. U.S. Fish and 

Wildlife Service regulations implementing ANILCA Section 811 stated: 

The Refuge manager may restrict a route or area to the use of snowmobiles, motorboats, 

dog teams and other means of surface transportation traditionally employed by local rural 

residents engaged in subsistence uses if the Refuge Manager determines that such use is 

causing or is likely to cause an adverse impact on public health and safety, resource 

protection, protection of historic or scientific values, subsistence uses, conservation of 

endangered or threatened species, or other purposes and values for which the refuge was 

established. 50 CFR Sec. 36.12(b). (Emphasis added). 

ANILCA Section 811 and U.S. Fish and Wildlife regulations at 50 CFR 36.12 directed the Service 

to proactively manage subsistence ATV use to prevent adverse impacts. On average, national 

ATV sales have increased 10 percent each year since 1996 and the vehicles are now going faster 

and further into the backcountry than ever before. It is widely accepted among land managers, 

scientists, and the general public that disbursed ATV use causes adverse impacts. 

Additionally, the compatibility standard must be applied to all transportation activities in refuges. 

Also, the traditional motorized modes allowed under Section 1110 of ANILCA should not exceed 

the levels that existed at the time ANILCA was passed. This limitation is stated very clearly in 

the legislative history: 

Even in wilderness, access by airplane and motorized boat may be permitted at existing 

levels of intensity. (Sen. Rep. No. 96-413 p. 247) 

 

6

 National Park Service, U.S. Department of the Interior, “Response of Tussock-Shrub terrain to 

Experimental All-Terrain Vehicle Tests in Wrangell-St. Elias National Park and Preserve, Alaska, A 

Progress Report,” by Charles H. Racine and Gary M. Ahlstrand. 1985. 
Appendix J: Response to Comments 

J-22 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

These approaches are consistent with the wilderness management concept that motorized 

intrusions are to be minimized or eliminated as appropriate. While the Congressional 

compromises made in ANILCA included certain accommodations to allow, where necessary, 

traditional uses at levels existing in 1980, this does not exempt refuge management from 

responsible management of motorized access or the requirements of the Wilderness Act or the 

National Wildlife Refuge System Administration Act. Management is still bound by guidelines set 

forth in the Refuge Manual and the Wilderness Handbook, which were written in conformance 

with these laws. 

For these and other reasons, we strongly support the closure of ORV use within Innoko Refuge. 

______________________________________________________________________________ 

Response: Regulations (43 CFR 36.11) prohibit use of ORVs on refuge lands for recreational 

purposes, except on established roads, parking areas, and routes designated by the agency. There 

are no established roads, parking areas, or designated routes on the refuge, and none are planned. 

Compatible public recreational activities are allowed on Alaska refuges under 50 CFR 36.31(a). 

We have not defined traditional as it applies to this refuge; however, we have found recreational 

use to be a compatible use at current levels. We have also found current and projected use of 

motorboats, snowmobiles, and airplanes compatible with refuge purposes (see Appendix F: 

Compatibility Determinations). 

______________________________________________________________________________ 

C. Helicopters: 

We strongly support the prohibition on recreational helicopter access in all refuges in Alaska as well 

as Innoko’s restriction to this use. We believe that the social and ecological impacts from this type of 

access are significant and will alter the overall wilderness and natural character of the Refuge. 

______________________________________________________________________________ 

Response: Service policy is that applications for permits to land helicopters for recreational 

purposes shall be considered on a case-by-case basis. 

______________________________________________________________________________ 

D. Airboats: 

The Service should clarify that airboats are prohibited on the Refuges because they were not 

found to be a traditional mode of access under ANILCA Title XI. The preamble to 50 CFR 

36.39(i)(3)(i), a U.S. Fish and Wildlife Service regulation implementing ANILCA Title XI (as 

referenced in the preamble to the 2000 NPS Personal Watercraft Rule) states, “[w]ith respect to 

airboats, section 1110(a) of ANILCA and its legislative history indicate that motorboats were the 

only methods of motorized water transport that were to be given special access to conservation 

units.”7

 We object to all airboat use on any Alaska refuges because of their significant impacts to 

fish, wildlife, natural soundscapes, vegetation, and soils. 

The Service also needs to review impacts from airboat use on navigable waters in the Draft CCP. 

If the use of airboats on navigable waters would disturb wildlife, then the Service has the 

authority, grounded in its Property Clause authority, to manage the public lands and to restrict 

the use of airboats even if the state has regulatory authority over the navigable waters. 

 

7

 Personal Watercraft Use Within the NPS System, 65 Fed. Reg. 15082, 15082-3 (April 20, 2000). 
Appendix J: Response to Comments 

______________________________________________________________________________ 

Response: By regulations, airboats are classified as off-road vehicles. Current regulations 

prohibit their use, except on designated routes or areas or under special use permits. Currently, 

there are no designated routes or areas or special use permits authorizing their use—nor are any 

planned. Airboats are not an issue on the refuge.

______________________________________________________________________________ 

E. Jet-skis: 

Regardless of the national policy being determined by the Service at this time, jet-skis should not 

be allowed on Alaskan Refuges. These joy-riding machines fall far outside the purposes of the 

Refuges, are nontraditional, and are known to disrupt sensitive wildlife, subsistence activities, and 

other recreational experiences. We encourage the Service to ban jet-skis from Innoko Refuge. 

______________________________________________________________________________ 

Response: The use of jet-skis on refuges is being debated. However, as the jurisdiction of 

navigability on many Alaska waters is in dispute, jet-skis would likely fall under State 

jurisdiction. At this time, we have not documented any use of jet-skis within the refuge. If policy 

is developed on their use, the Plan will be reviewed to determine if an amendment is necessary. 

Before any restrictions could be implemented, the Service would have to go through the rulemaking procedures and develop regulations. 

______________________________________________________________________________ 

IV. Climate Change: 

Climate Change is one of the greatest threats facing ecosystems and wildlife populations today, 

and the Service should make this issue a priority, taking it into account and incorporating it into 

all planning and management strategies. The revised CCP will likely be in place a minimum of 

fifteen years. There is a clear scientific consensus on the impacts from climate, and many changes 

will no doubt take place within the CCP’s timeframe due to climate change. It is imperative that 

the Service make climate change a priority for Alaska’s refuges, for their administration, 

protection and service to the public. 

For example, according to a study published in the Journal of Climate, if carbon dioxide rises 

0.45% a year (the current rate is 0.50%), then the Arctic will see more warming than anywhere 

else, with average temperatures in many parts of northern North America rising more than 25 

degrees by 2100. Arctic tundra would decline from 8% of the world’s land area to about 1.8 %, 

and Alaska would lose almost all of its evergreen boreal forests. In response to this study,

authored by scientists from the Energy Department’s Lawrence Livermore National Laboratory 

and Stanford University, a climate modeler at the National Center for Atmospheric Research 

stated: “The message is not to give up because the changes appear overwhelming, but instead the 

message should be the longer we wait to do something, the worse the consequences.” (New York 

Times November 1, 2005). 

______________________________________________________________________________ 

Response: The Service is addressing climate change on national, regional, and local levels. 

While the plan addresses climate change at the refuge level, refuge staff are also involved in some 

national and regional initiatives. Climate change was identified as an important issue to be 

addressed in the plan (see sections 1.9.5 and 3.3.3.1). Climate change is explicitly and implicitly 

related to many of the objectives identified for the refuge. For example, information that would 

be collected under baseline inventory objectives (e.g., Objective 4) would be necessary to identify 

effects of climate change. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-23 
Appendix J: Response to Comments 

______________________________________________________________________________ 

The following are 8 points of discussion we believe the Service should incorporate into the Revised 

CCP. They are as follows: 

1) Providing training on climate change and variability for all wildlife managers; 

______________________________________________________________________________ 

Response: Training would be provided on a national and regional level. The Service is 

hosting a series of regional workshops on climate change. The Alaska Region hosted the 

first workshop, which served as a model for the national effort. 

______________________________________________________________________________ 

2) Encouraging wildlife managers to consider climate change and variability whenever 

long-range wildlife management plans and strategies are developed; 

______________________________________________________________________________ 

Response: Climate change would be considered in any long-range plans. See rationale 

for Objective 2 as an example. 

______________________________________________________________________________ 

3) Implementing monitoring programs for impacts to wildlife and wildlife habitats 

expected to be most sensitive to climate change; 

______________________________________________________________________________ 

Response: More details related to this recommendation will be developed in step-down 

plans, especially the refuge’s Inventory and Monitoring Plan (see Objective 2). 

______________________________________________________________________________ 

4) Educating the public about climate change and its effects on wildlife; 

______________________________________________________________________________ 

Response: Climate change education is more appropriately addressed at the national 

and regional level. The refuge would incorporate available materials into their 

environmental education programs. Due to the small size of the staff and small outreach 

program, developing a refuge outreach program on climate change is not a priority for 

Innoko Refuge. Priorities for the refuge outreach and environmental educuation 

program are displayed in the objectives listed under Goal 6. 

______________________________________________________________________________ 

5) Establishing and maintaining migration corridors that allow species movement and 

vegetation shifts among islands of suitable habitat; 

6) Increasing buffer zones around refuges that will increase options for species under 

various climate change scenarios; 

7) Removing impediments to inland migration of coastal and wetland communities; and 

______________________________________________________________________________ 

Response: These recommendations are being addressed in national and regional 

responses to climate change. 

______________________________________________________________________________ 

J-24 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

8) Making the reduction and elimination of human-induced synergistic effects a top 

priority for refuge management. 

______________________________________________________________________________ 

Response: Modification of human activity implicated in climate change on a broader level is 

beyond the purview of the refuge.

______________________________________________________________________________ 

The Service should fully integrate these discussion points in the goals and objectives listed for the 

refuge. Further, an additional objective should be included where the Service incorporates 

studying impacts of climate change on subsistence resources and practices. Please refer to Dr. 

Kocan’s studies on diseases in Yukon Chum salmon which have found that approximately 25% – 

33% of salmon caught in the Yukon river is diseased. 

______________________________________________________________________________ 

Response: As noted in section 2.1 of the plan, many of the objectives important for managing 

subsistence activities on the refuge require monitoring or improving knowledge of the natural 

resources linked to these activities. Many of the objectives under goals1 and 2 relate to 

subsistence and would provide information useful for addressing the impacts of climate change 

on subsistence. For example, Objective 6 pertains to moose population estimates, and Objective 

28 discusses caribou. 

______________________________________________________________________________ 

The Service should incorporate studying impacts of climate change on water resources. Please 

refer to the recent UAF lake and surface water study related to lakes drying up in Alaska, “Using 

Remote Sensing to Examine Changes of Closed – Basin Surface Water Area in Interior Alaska 

from 1950 – 2002, by Alan Riordan, and also the Kenai Refuge study. Of the nine regions studied 

by Riordan, which included Yukon Flats and Innoko National Wildlife Refuge lands, six showed 

substantial reductions in surface water area. The regions with the most dramatic changes showed 

losses of up to 25 – 31 % water reduction. According to another recently published study, the 

Kenai National Wildlife Refuge has changed dramatically in the last five decades. Methodically 

comparing aerial photos from 1950 with photos from 1996, Eric Klein and his colleagues found 

that wetlands have decreased by 88%, open areas have decreased by 35%, and water/lakes have 

decreased by 14%. Bushes, such as dwarf birch and blueberries, have now grown up in areas 

where wetlands existed for 8,000 to 12,000 years. Co-author Ed Berg notes that “When you dig 

down into the peat, you don’t see any stems or shrubs. Had they grown there in the past, they 

would have been preserved.” (Anchorage Daily News, October 4, 2005) Klein further notes that 

“There is an overall environment shift occurring in Alaska...it’s a bioindicator of climate change 

and what is happening to the planet as a whole.” (ENS September 28). Management implications 

of these landscape-level changes identified in both of these studies should be considered in 

Innoko’s CCP revision. 

______________________________________________________________________________ 

Response: The refuge is currently supporting a doctoral candidate’s work that is expanding 

upon Riordan’s work. 

______________________________________________________________________________ 

The Service also should incorporate studying the impacts of climate change on erosion of 

archeological values, caused by rising sea levels, more violent storms, etc.. For example, while the 

nation recently focused on hurricanes in the Gulf of Mexico, western Alaska has experienced 

brutal storms which have adversely affected over thirty communities. In one storm in 2005, the 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-25 
Appendix J: Response to Comments 

storm surge in Nome was 9 feet above normal high tides with waves of 12 to 15 feet. Newtok saw 5 

to 10 feet of beach disappear along with equipment like a 1,000 gallon fuel tank (Newtok has lost 2 

– 3 miles of land between it and the ocean in the last 40 years). Unalakleet lost 10 to 20 feet of 

beach. (Anchorage Daily News, September 28, 2005). 

Sea levels will also be affected by decreasing sea ice levels. According to scientists at NASA and 

the National Snow and Ice Data Center, there have been record low amounts of sea ice over the 

last few summers in the Arctic Ocean. It is as if an area the size of Texas had melted away since 

1979. The biological and other ramifications are stunning, and if the sea ice continues to shrink at 

the same rate, the Arctic Ocean could be completely ice-free well before the end of this century. 

Notes climate researcher Mark Serezze: “My view is it’s getting increasingly difficult to argue 

against the notion that what we’re seeing is a greenhouse gas effect taking hold.” (Anchorage 

Daily News, September 29, 2005)

______________________________________________________________________________ 

Response: Refuge staff does not anticipate that climate change, especially within the time frame 

of this plan, will affect erosion on this refuge. The refuge is over 50 miles straight-line distance 

from the coast. 

______________________________________________________________________________ 

We believe that maintaining healthy, wild ecosystems is critical towards helping all organisms, 

including humans, adapt to climate change. The Innoko NWR is an excellent example of such an 

ecosystem. Keeping this area wild and protected from adverse levels of anthropogenic stressors, 

which include increasing wildlife harvest demands and mining, will be important towards 

promoting resiliency and adaptation in the face of rapid environmental change. 

Having provided a number of specific concerns regarding climate change impacts on refuge 

resources and having identified 8 important management objectives outlined above for the CCP 

revision process for Alaska refuges , we are pleased to see the revised CCP draft EA include 

several of these objectives within the Wildlife and Habitat goals aimed at assessing natural 

resources within the refuge and region with climate change in mind. However, we feel that there 

are many instances where relevant climate change impacts have been overlooked. These include 

incorporation into other relevant goals, including Subsistence, Cultural Resources and Outreach 

and Environmental Education. We would like to see climate change presented as an integral part 

of the CCP, given that it is has been identified as a priority for FWS in Alaska and there is 

evidence that indicates impacts are already occurring. 

______________________________________________________________________________ 

Response: See previous responses about climate change and how it is addressed in this plan and 

at the national and regional level. 

______________________________________________________________________________ 

The goals and objectives outlined in the revised CCP draft EA are described as being the guide 

and basis for developing step-down plans (p. 5-1); these plans will ultimately address the specific 

assessment of climate change impacts. For this reason, we feel that it is important that climate 

change be more implicitly incorporated into the Goals and Objectives. We feel that explicitly 

identifying the importance of assessing climate change impacts on individual species, on habitats, 

and on ecosystems in the CCP is critical towards insuring that the I&M and other step-down plans 

are designed to appropriately address climate change. For example, there is no mention of 

climate change impacts within the Wildlife Research Objectives (objectives 20-35; p. 2-7:11) 

J-26 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

despite the fact that most if not all of these research elements are likely to capture the impacts of 

climate change. By adding specific language to these sections, we would hope that comprehensive 

hypotheses, that include climate change among other relevant considerations (hunting, wildfire 

management, development), would be developed. 

While there is some uncertainty about the specific magnitude and impacts of climate change at the 

regional scale, there is a substantial amount of information from research and modeling efforts to 

guide refuge scientists and managers towards developing testable hypotheses. For example, 

downscaled climate projections for temperature and precipitation are available through the 

University of Alaska’s Scenarios Network for Alaska Planning (SNAP) program. These 

projections, and other models which build off these data, can be used to guide inventorying, 

monitoring and assessment programs designed to understand the true direction and magnitude of 

change. For example, predictions from a climate x fire x vegetation model (ALFRESCO) suggest 

that interior Alaska, including Innoko NWR, are likely to be subject to frequent and severe fires 

in the next several decades, resulting in potentially significant changes in landcover, including 

moose and caribou habitat (Rupp et al. 2006; Rupp et al. unpublished data). The hypothesis that 

increased temperatures and drier conditions will promote more severe fires that increase 

deciduous forest cover would be important to test, and would be relevant to wildlife and habitat 

objectives related to avian, moose, furbearer, beaver, hare, wood bison, fish etc. populations as 

well as landcover, fire management, permafrost, water resources, subsistence resources etc.. 

Thus, there is a substantial amount of published and publically available data available that can be 

used to refine the revised CCP draft EA towards more comprehensive objectives. 

______________________________________________________________________________ 

Response: We did not explicitly include climate change in every objective statement. As 

explained previously, most of the wildlife and habitat objectives directly or indirectly relate to 

climate change. Climate change is mentioned in the rationales for 10 objectives. See objectives 2 

(inventory and monitoring planning) and 36 (habitat management planning). Climate change 

will be more explicitly addressed as these important step-down plans are prepared. 

______________________________________________________________________________ 

Another critical component of assessing climate change which we feel should be more strongly 

addressed in the revised CCP draft EA is climate monitoring. The refuge appears to have only 

one weather monitoring (RAWS) facility or possibly may have a mobile and a 

stationary/permanent RAWS facility (p. 2-13). First, we would strongly discourage movement of 

an existing facility, as this will make it impossible to determine long-term trends in weather and, 

thus, assess climate change. Cutting off the record now will restart the monitoring clock, and it 

takes decades of data to establish trends. While the specific weather may be variable across the 

refuge, we urge the refuge to examine their existing data and consult with other experts to 

determine if climatic trends can be applied more broadly from the existing RAWS site. For 

example, while temperature and precipitation may vary across the refuge, an absolute change (e.g. 

2°F warmer) may be ubiquitous across the region. Further, including an objective to expand 

weather monitoring across the refuge would be important for understanding both wildlife and 

habitat management goals. 

______________________________________________________________________________ 

Response: The refuge maintains one permanent Remote Automated Weather Station (RAWS). 

A second portable station will be used for fire data; when not needed for fire support, it will be 

used to calibrate the permanent station and collect micro-climatic data. 

______________________________________________________________________________ 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-27 
Appendix J: Response to Comments 

Incorporating a network or flow diagram to aid in elucidating the cause-and-and effect 

relationships within the refuge’s ecosystems and in this region of the interior may help to insure 

appropriate prioritization of objectives, given time and funding limitations, and that the ultimate 

choice of methods maximizes realization of the top objectives. 

______________________________________________________________________________ 

Response: This recommendation would be addressed in the Inventory and Monitoring Plan 

identified in Objective 2. 

______________________________________________________________________________ 

In summary, by better integrating climate change into the goals and objectives in the CCP and 

clarifying the linkages among natural resources and their assessment (i.e. objectives), it seems 

that subsequent plans will be more successful at capturing hard to elucidate impacts and changes. 

V. RS2477: 

We agree with the Service that the identification of RS 2477 rights-of-way by the State of Alaska 

does not automatically make them valid; rather, such claimed rights-of-way are not valid until they 

have been determined to be so through a legitimate process applying the proper standards. 

Under no circumstances may section line easements be legitimate RS 2477 rights-of-way. We 

appreciate the Service’s attempt to disclose the States assertions regarding RS2477. 

VII. Conclusion: 

In conclusion, the Innoko National Wildlife Refuge plays a significant role in the preservation of the 

ecological diversity and integrity of interior Alaska. For this reason, it is imperative that the Refuge 

continues to be an undisturbed and quiet retreat for both species and people alike. Overall, we 

support the conservation measures taken in the revised CCP draft EA, and encourage the Service to 

revise some of the proposals that we have expressed concern over in this letter, such as wilderness 

reviews and recommendations, wild and scenic river recommendations, and a greater emphasis and 

integration of climate change measures in planning and future management.

We appreciate the opportunity to submit these comments on behalf of our members in Alaska and 

nationwide. 

Sincerely, 

Nicole Whittington-Evans 

Associate Regional Director, Alaska 

And 

Wendy Loya, PhD 

Ecologist 

The Wilderness Society 

430 West 7th Ave., Ste. 210 

Anchorage, AK 99501 

J-28 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

 Alaska Chapter, Sierra Club 

 330 W. 4th Avenue, Suite 307 

 Anchorage, AK 99501 

 July 28, 2008 

Via electronic mail 

Helen Clough 

Fish & Wildlife Service 

1011 East Tudor Road, MS-231 

Anchorage, AK 99503 

Re: Comments on Innoko National Wildlife Refuge Draft Revised Comprehensive Plan and Draft 

Environmental Assessment 

Dear Ms. Clough: 

The Alaska Chapter, Sierra Club appreciates the Fish and Wildlife Service’s invitation to 

comment on the Innoko Draft Revised Innoko NWR Comprehensive Conservation Plan (Draft). 

Our comments focus on the issues of wilderness review of the roughly two-thirds of the Innoko 

Refuge in non-wilderness status; wild and scenic river recommendations; motorized access for 

subsistence purposes; recreational and commercial helicopter access; and fisheries enhancement 

in designated wilderness. 

Wilderness and wild/scenic river reviews

Sec. 1317 of ANILCA provides for review of the non-wilderness areas in the refuge for suitability 

or non-suitability as potential additions to the Wilderness System. Wild and scenic river reviews 

are authorized pursuant to the Wild and Scenic Rivers Act. 

Nevertheless, the Draft states that the Fish and Wildlife Service (Service) does not intend to 

conduct such reviews. Instead, the Service is content to describe the special values of the nonwilderness areas and the rivers, and manage both as minimal management areas over the life of 

the revised plan. 

In explaining its decision to not conduct the reviews, the Service says that it made its decision 

after it analyzed the State of Alaska’s “concerns,” and lets it go at that--the “concerns” and the 

Service’s analysis are not revealed. 

What exactly were the State’s “concerns,” i.e., objections? What, specifically, are the findings of 

the Service’s analysis of the State’s objections? Why did the Service allow the State’s opposition 

to the reviews take precedence over Congressional intent in ANILCA and the Wild and Scenic 

Rivers Act? Please include your answers to these questions in the final RCCP. 

Inasmuch as the Service has produced informal wilderness and wild river reviews as shown by the 

Draft RCCP’s extensive discussion of the special and outstandingly remarkable values of these 

resources, we urge the Service include in the final RCCP its recommendations for potential 

additions to the Wilderness and Wild and Scenic Rivers Systems. This would restore the public’s 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-29 
Appendix J: Response to Comments 

confidence in the agency as the governing management authority willing to comply with the intent 

of Congress despite the ill-conceived objections of the State, or any other special interests. 

______________________________________________________________________________ 

Response: Refer to the previous responses provided to The Wilderness Society letter in this 

document. 

______________________________________________________________________________ 

Access for subsistence purposes

The Draft begs the question of whether off-road vehicles are allowed for subsistence activities 

under Alternatives A and B. Under ANILCA, off-road vehicles are permitted for subsistence 

access, subject to reasonable regulation to protect refuge resources and values, only if found to 

have been traditionally employed prior to the Act. 

There is no indication in the Draft that the Service has undertaken a traditional use determination 

for subsistence off-road vehicles. Until there is such a formal determination, the issue of whether 

or not off-road vehicles are allowed for subsistence remains unresolved. In order to resolve this 

issue, the final Revised CCP should include a determination, and adopt the appropriate policy. 

______________________________________________________________________________ 

Response: Currently available information suggests that off-road vehicles were not used 

traditionally on the refuge. Conducting a study to make a formal determination is not a priority 

with the refuge because off-road vehicles are not currently being used on the refuge. Refuge 

terrain is such that even newer vehicles are very unlikely to be used for access. If issues arise 

during implementation of the plan, the refuge could shift priorities, undertake a formal study, 

and proceed with addressing the use. 

______________________________________________________________________________ 

Public access

A. Off-road vehicles. Under Alternatives A and B off-road vehicles are defined to include 

airboats, air-cushioned vehicles (presumably meaning hovercraft), and “motorized wheeled 

vehicles.” Although not defined, motorized wheeled vehicles include, but may not be limited to, 

three-wheelers, four-wheelers, and motorcycles (trail bikes). 

These off-road vehicles “may be allowed” only on designated routes or trails within Intensive and 

Moderate Management Areas. Chapter 2, p. 51. However, there are no intensive or moderate 

management areas in alternatives A and B, just minimal management and wilderness areas. 

What is the Service’s policy on recreational off-road vehicles in these latter areas? On what law, if 

any, is the Service basing its allowance of off-road vehicles in moderate and intensive management 

areas? ANILCA only authorizes non-motorized surface transportation methods for certain public 

purposes in addition to snowmobiles, airplanes, and motorboats. 

______________________________________________________________________________ 

Response: Regulations in 43 CFR 36.11 define off-road vehicles and prohibit their use in 

locations other than established roads, parking areas, and areas designated for their use or by 

special use permit. Legal authorities cited in the Code of Federal Regulations are 16 U.S.C. 1, 3, 

688dd et seq, and 3101 et set and 43 U.S.C. 1201. Innoko Refuge is all Wilderness or Minimal 

management where roads, parking areas, or designated off-road vehicle use is not allowed. We 

J-30 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

do not anticipate authorizing special use permits for any off-road vehicle use on the refuge by the 

public during the life of this plan. 

______________________________________________________________________________ 

B. Helicopters. The Draft states that helicopter landings by commercial operators and for general 

public access are “generally not allowed,” but “may” be allowed if such landings were established 

prior to the Wilderness designation, i.e., prior to ANILCA of 1980. 

Here the Service’s policy is in direct conflict with ANILCA, Sec. 1110(a), which authorizes the use 

of airplanes for public access; it did not authorize the use of helicopters, which come under the 

category of aircraft. In this connection, we note that National Park Service regulations 

specifically and flatly prohibit the use of helicopters for public access in all units of the park 

system in Alaska. 

In order for the Service to comply with the Act, its helicopter policy in the Draft needs to be 

replaced by a prohibition on such use in all refuge management categories. Citizens should not 

have to ask the federal courts and Congress to straighten this matter out, but that will be citizens’ 

recourse should the agency persist in misinterpreting the law. 

Does the Service intend to prohibit helicopter landings for commercial and recreational public 

access in the final Revised CCP? 

______________________________________________________________________________ 

Response: The authority for allowing helicopter access is 43 CFR 36.11 (f)(4). We did not change 

this section of the plan. Current Service policy is that applications for permits to land 

helicopters for recreational purposes shall be considered on a case-by-case basis. Other use of 

helicopters is addressed in the compatibility determination in appendix F 

______________________________________________________________________________ 

Fisheries enhancement in designated wilderness

The Draft states that fisheries enhancement may be allowed in minimal management areas and, 

subject to “minimum requirements analysis,” in designated wilderness areas. 

The Draft defines fisheries enhancement as follows: 

Fisheries enhancement is any management action or set of actions that is applied 

to a fishery stock to supplement numbers of harvestable fish to a level beyond that 

which could be naturally produced based on a determination or reasonable 

estimate of historic levels. This could be accomplished by stocking barren lakes, 

providing access to barren spawning areas, (fish passages), constructing 

hatcheries, outstocking in productive streams, or fertilizing barren streams, or 

fertilizing rearing habitat. 

However, ANILCA Sec. 1315 (b) allows fisheries enhancement of the kind quoted above only in 

national forest designated wilderness at the discretion of the Secretary. This puts the Draft’s 

policy in direct conflict with the Act. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-31 
Appendix J: Response to Comments 

ANILCA’s restriction of aquaculture to national forest wilderness areas was tested in the case of 

fish stocking by the Alaska Department of Fish and Game in Tustemena Lake within the Kenai 

Wilderness of the Kenai NWR. The Service permitted the stocking, but a federal court held that 

stocking in order to enhance the existing natural run of sockeye salmon was species manipulation 

in wilderness areas, a practice prohibited by ANILCA. 

Will the Service correct its fisheries enhancement policy for wilderness areas in the final RCCP? 

______________________________________________________________________________ 

Response: Fish stocking within wilderness would have to meet the minimum tool requirements 

and would only be allowed if it were necessary for management of the area as wilderness. Due to 

this, the situations in which fisheries enhancement would be allowed within wilderness would be 

very limited. 

______________________________________________________________________________ 

Recommendation for Alternative

Table 2, Comparison of the Alternatives, found in the Summary of the Draft, is helpful in the task 

of choosing between Alternatives A and B. We recommend a mix of policies from A and B that in 

our opinion best reflects the intent of Congress in ANILCA. 

Research and Management Facilities. Recommendation: Modify Alternative B to preclude 

permanent structures and camps in wilderness and minimal management categories. Such 

facilities are incompatible in wilderness, and should be avoided in minimal management pending 

eventual congressional and future administration consideration of wilderness proposals involving 

minimal management areas. 

______________________________________________________________________________ 

Response: These facilities would be subject to minimum tool analysis as indicated in section 

2.4.19 and table 2-2 within Wilderness. While such facilities would be allowed within Minimal 

management, guidelines for Minimal management would ensure that the presence of such 

facilities would not make the area unsuitable for Wilderness designation in the future if 

Congress chooses to designate additional Wilderness on the Refuge. 

______________________________________________________________________________ 

Fish and Wildlife Habitat Management-Chemical Treatment. Alternative B, which apparently 

does not involve permanent structures in wilderness or minimal management areas. 

______________________________________________________________________________ 

Response: Alternative B was adopted as the revised plan for Innoko Refuge. 

______________________________________________________________________________ 

Native Fish Introduction. Alternative C: No native fish transplants in wilderness management, 

or in minimal management areas pending congressional review of wilderness proposals involving 

these areas. 

______________________________________________________________________________ 

Response: The revised plan allows native fish introductions within Wilderness subject to 

minimum tool analysis and within Minimal management. Given that other areas containing

introduced fish have been designated Wilderness (e.g., Kootznoowoo Wilderness), if fish were 

introduced to a Minimal management area of the refuge, Congress could still designate it as 

Wilderness in the future. 

______________________________________________________________________________ 

J-32 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 
Appendix J: Response to Comments 

Visitor Contact Facilities. Alternative A. Such facilities have no place in designated wilderness 

areas or in minimal management areas pending Congressional review of wilderness proposals 

covering minimal management areas. 

______________________________________________________________________________ 

Response: As described in sections 2.3.5 and 2.4.19, visitor contact facilities are generally not 

allowed in wilderness. None are planned for wilderness or Minimal management under the 

current plan. If a visitor contact facility were planned for wilderness, it would be subject to a 

minimum requirements analysis. A facility designed for Minimal management would be very 

minimal and would not affect suitability of the area for wilderness designation. 

______________________________________________________________________________ 

Administrative cabins. Alternative A, which recognizes that administrative cabins should be built 

in wilderness only if needed for the protection of public health and safety. 

______________________________________________________________________________ 

Response: The revised plan indicates that administrative cabins in Wilderness would be subject 

to minimum tool analysis as indicated in section 2.4.19 and table 2-2 within Wilderness. This 

analysis sets a high standard for allowing facilities, and public health and safety would be part of 

that analysis. There are no administrative cabins proposed to be constructed in Wilderness 

under the revised plan.

______________________________________________________________________________ 

Administrative Field Camps. Alternative A modified to permit only temporary structures in 

minimal management areas pending Congressional review of wilderness proposals involving these 

areas. 

______________________________________________________________________________ 

Response: While such facilities would be allowed within Minimal management, guidelines for 

Minimal management would ensure that the presence of such facilities would not make the area 

unsuitable for Wilderness designation in the future if Congress chooses to designate additional 

Wilderness on the Refuge.

______________________________________________________________________________ 

Boat Launches and Docks. Alternative A, which does not permit designated sites in minimal 

management and wilderness areas, in contrast to Alternative B, which does permit such facilities. 

______________________________________________________________________________ 

Response: These facilities would be subject to minimum tool analysis as indicated in section 

2.4.19 and table 2-2 within Wilderness. While such facilities would be allowed within Minimal 

management, guidelines for Minimal management would ensure that the presence of such 

facilities would not make the area unsuitable for Wilderness designation in the future if 

Congress chooses to designate additional Wilderness on the Refuge. 

______________________________________________________________________________ 

Surface Geological Studies. Alternative B, which does not allow studies in wilderness areas, 

including helicopter and fixed-wing airplane access. When Congress adds a refuge area to the 

Wilderness System, it permanently precludes mineral extraction. 

Other Geophysical Studies. Alternative B, which allows studies in minimal management areas but 

not in wilderness areas. 

Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan J-33 
Appendix J: Response to Comments 

J-34 Innoko National Wildlife Refuge Revised Comprehensive Conservation Plan 

Staffing and Budget Needs. Alternative B, which calls for increases in permanent and temporary 

staff, and nearly a 50 percent increase in the annual budget. 

______________________________________________________________________________ 

Response: The three components of Alternative B mentioned were all selected by the Regional 

Director as part of the approved plan. 

______________________________________________________________________________ 

Thank you for considering our views and recommendations. 

Jack Hession 

Executive Committee 

Alaska Chapter, Sierra Club 

Innoko National Wildlife Refuge 

P.O. Box 69 

McGrath, AK 99627 

Telephone: 907-524-3251 

Fax: 907-524-3141 

http://innoko.fws.gov 

U.S. Fish and Wildlife Service 

Region 7, Alaska 

1011 East Tudor Rd. MS-231 

Anchorage, AK 99503 

Telephone: 907-786-3357 

Fax: 907-786-3965 

http://www.r7.fws.gov 

U.S. Fish and Wildlife Service 

1-800-344-WILD 

http://www.fws.gov 

November 2008