U.S. Department of the Interior

U.S. Fish & Wildlife Service

http://www.fws.gov

July 2007
What is the Innoko Land Protection Plan? Private 

landowners own or have claims to nearly 240,000 

acres of land within the Innoko National Wildlife 

Refuge. The Land Protection Plan (LPP) identifies 

which privately-owned lands contain the highest 

quality fish and wildlife habitats. It also lists options, 

ranging from informal cooperative agreements, to 

land exchanges, to selling lands or easements, that 

some landowners may wish to pursue. The LPP serves 

primarily to foster communication between the refuge 

and interested landowners and to help us identify 

priority areas with high resource value. It provides a 

framework for working with interested landowners to 

protect key resources. Why do we prepare LPPs? U.S. Fish and Wildlife 

Service policy requires that we prepare an LPP 

for each refuge before we can obtain Land and Water 

Conservation Funds. The LWCF is the primary source 

of funding for buying easements or inholdings in Alaska 

refuges. As discussed below, the LPP process is simply 

proactive planning. The LPP is a planning tool, not an action plan. The LPP 

is a proactive planning tool that helps us evaluate 

opportunities when they arise. For instance, if several 

landowners approach us with offers to sell lands, the 

priorities identified in the LPP help us to make wise 

use of very limited funds. The LPP provides guidance, 

but does not require any action by the landowner or the 

Service. Rather it is one of the management tools that 

helps guide land conservation efforts. The LPP provides choices. The LPP provides 

options that may, in the right situation, benefit 

both the landowner and the Service. For instance, 

a Native corporation may propose a land exchange 

to obtain additional land around a village site or to 

trade wetlands for developable land. Another may be 

interested in selling easements or distant holdings to 

generate capital. Before pursuing any course of action, 

both parties must agree that it is in their best interest 

to proceed. Our priorities reflect the quality of the habitat. We use 

a computer model to analyze priorities. Criteria 

which rank fish and wildlife habitats and their ability 

to contribute to the refuge mission are mapped in 

overlapping layers with the land status data to give a 

numerical rank to each parcel of land. Public and State involvement is part of the process. We 

provide opportunities for local landowners and other 

interested parties to discuss the LPP process with us. 

State agencies review and comment on the LPP prior to 

publication and distribution.

Executive Summary

Land Protection Plan

for

Innoko National Wildlife Refuge

McGrath, Alaska

U.S. Department of the Interior

Fish and Wildlife Service

Region 7

Anchorage, Alaska

July 2007
If you have questions or comments about the Innoko Land Protection Plan, please contact 

us at one of the following locations:

Refuge Manager

Innoko National Wildlife Refuge

P.O. Box 69

Mail Stop 549

McGrath, Alaska 99627

(907) 524-3251

U.S. Fish and Wildlife Service

Division of Conservation, Planning & Policy

1011 E. Tudor Road

Anchorage, Alaska 99503

(907) 786-3357

U.S. Fish & Wildlife Service 
i

Contents

Tables ii

Figures ii

Introduction1

Important Resources3

Landscape3

Fish and Wildlife Resources 

4

A Changing Environment? 14

Land Status15

History 15 Village Native Corporation Land 16

Regional Native Corporation Lands

16

Native Allotments

16

Other Private Patents

19

State of Alaska

19

Submerged Lands 

20

17(b) Easements

20

Asserted RS-2477 Rights-of-Way

21

Mining Claims

22

Wilderness 

22

Refuge Management Concerns25

Maintaining Healthy Ecosystems 25 Wilderness Values 27

User Group Conflicts

27

Consolidating Land Ownership Patterns

28

Resource Protection Methods29

Existing Resource Protections 29

Options for Additional Resource Protection29

Resource Protection Priorities33

Background: The Alaska Priority System 33

Relative Resource Values34

Innoko Land Protection Priorities

34

Other Factors May Influence Priorities

39

Effects of Resource Conservation Measures43

Effects on Cultural/Historical Resources 43

Effects on Landowners44

Effects on the Economy

44

Effects on Public Access

45

Effects on Subsistence

46

Evaluating Land Conservation Proposals47

Public Involvement49

Land Protection Plan Revision 50

Sources of Information53

Appendix I: Priority Analysis 55

APS Model 55

The Ranking Process for the Innoko Refuge55
ii

Tables

Table 1. Land status overview for the Innoko Refuge as of March 2007 1

Table 2. Surface land status of the Innoko Refuge (Innoko Unit) as of March 2007 19

Table 3. Mileage of asserted RS-2477 rights-of-way within the Innoko Unit of the 

 Innoko Refuge 21

Figures

Figure 1. Land Status 17

Figure 2. State Asserted RS-2477 Rights-of-Way 23

Figure 3. Relative Resource Priorities 35

Figure 4. Relative Land Protection Priorities 37
1

The U.S. Fish and Wildlife Service manages the Innoko National 

Wildlife Refuge (Innoko Refuge) as a unit of the National Wildlife 

Refuge System. The refuge consists of two non-contiguous units. 

The larger southern unit (Innoko Unit), managed by the Innoko 

Refuge staff in McGrath, is the focus of this plan. The smaller 

northern unit is managed by the Koyukuk Refuge and will be 

included in the Koyukuk Land Protection Plan. 

The Service is charged with conserving the fish, wildlife and 

habitats of refuge lands for the benefit of present and future 

generations. However, this task is complicated by the fact that the 

Service does not own or have management authority over all of the 

land within the refuge boundaries. Of the 3,816,220 acres within the 

southern unit of the Innoko Refuge, other landowners have title or 

claims to about 239,586 acres* or about seven percent (Table 1). 

*Acreages are Geographic Information System (GIS) approximations and may differ 

from the official number published in the USFWS “Annual Report of Lands Under 

Control of the U.S. Fish & Wildlife Service” as of September 30, 2005.

Introduction

Table 1. Land status overview for the Innoko Refuge as of March 2007

Current Status Acres 1

Native Corporation (conveyed) 157,509

Native Corporation2

 (selected) 79,209

State of Alaska (selected) 129

Native Allotments (conveyed) 7,798

Native Allotments (selected) 762

Other Patents 3 12

Total Conflicting Claims (5,833)

Total Acreage Claimed by Other Entities 239,586

Refuge Land4 3,568,685

1 Acreage figures are GIS-calculated approximations and are subject to 

change. Land status acreage figures in Alaska will not be finalized until 

conflicting/overlapping claims are adjudicated by the Bureau of Land 

Management and all inholdings are surveyed. 2

 Includes conflicting claims: parcels claimed by two or more entities 

3

 Trade and manufacturing site 4

Refuge lands selected by other entities are excluded.

Refuge management may be 

complicated when refuge lands 

are interspersed with private 

lands.

Private landowners own or have 

selected about seven percent of 

the land within the southern unit 

boundary. 
Refuge lands are managed to conserve fish, wildlife, and their 

habitats in their natural diversity. However, fish and wildlife range 

freely between refuge and private lands and depend on the health 

of the entire ecosystem. Just as management actions on Service 

lands can affect private landowners, actions on private lands may 

affect our ability to conserve wildlife. It is important for us to work 

with landowners to improve management of the Innoko Refuge. 

Our success depends on developing good working relationships with 

adjacent landowners. 

This Land Protection Plan, or LPP, is the only report that focuses on 

private lands within the refuge boundaries. It explores the effects 

of private lands on refuge resources, and provides an opportunity 

to discuss key refuge issues and the ways we can work with private 

landowners to protect fish and wildlife resources.

As part of the LPP process, we prioritize all private lands in terms 

of their value to wildlife populations. In some cases, we may use 

these rankings to help us evaluate opportunities when they arise. 

For instance, if several landowners approach us with offers to 

sell, the priorities identified in the LPP help us spend our limited 

acquisition funds wisely. 

Although this plan identifies more than 55,000 acres of high-priority 

private land in the Innoko Refuge, most will remain in private 

ownership. The LPP provides guidance, but does not require any 

action by the landowner or the Service. Rather it is one of the 

management tools that helps guide land conservation efforts.

U.S. Fish & Wildlife Service

A Land Protection Plan does 

not obligate the Service or the 

landowner to take any action. 

Most of the private lands within 

the Innoko Refuge will always 

be owned and managed by 

Native corporations, the State of 

Alaska, or private individuals. 

The LPP provides a framework 

for working with interested 

landowners to conserve key 

resources. 
3

Landscape

Fires and floods shape the landscape of the Innoko Refuge. More 

than half of the refuge is low-lying, relatively flat, and blanketed 

with rivers, lakes, and sloughs. Natural features form some of the 

refuge boundaries: the Khotol Hills to the north, the Yukon River 

to the west and the Kuskokwim Mountains to the south and east. 

The Innoko River flows through the center of the refuge and forms 

the northern boundary of the Innoko Wilderness. 

An extensive lowland area, the Innoko lowlands, spans the length 

of the Innoko River. To the west of the lowlands are the Kaiyuh 

Mountains which parallel the Yukon River. The Kuskokwim 

Mountains project into the refuge along the southern and western 

borders. The highest point in the refuge (1,330 feet) is in the Kaiyuh 

Mountains. 

Flooding is common along the rivers and in the lowlands, especially 

during the spring. Seasonal flood cycles maintain extensive wet 

meadows of tussock grasses and sedges that are critically important 

to waterfowl. Bogs, with thick, floating mats of sphagnum moss and 

islands of black spruce and tamarack, are also scattered throughout 

the lowlands. They provide habitat for unusual plants, such as 

Andromeda (bog rosemary) and the carnivorous sundew.

Important Resources

U.S. Fish & Wildlife Service 

Fire and water shape the landscape of the Innoko Refuge.

The refuge is bisected by the 

Innoko River. Refuge lands south 

of the river have been designated 

the Innoko Wilderness.
Low hills of spruce and birch dominate upland areas. Sparse forests 

of stunted black spruce favor poorly-drained soils underlain by 

permafrost; white spruce covers well-drained hillsides and other 

areas where the permafrost layer is deep enough to permit their 

growth. 

Refuge vegetation represents a transition between the boreal 

forests of interior Alaska and the tundra communities of western 

and northern Alaska. Areas of subarctic tundra, underlain by 

permafrost, support a variety of scrub, peatland, heath meadow, 

marsh, and bog habitats. Tall scrub and forest habitats occur 

primarily in the northern portion of the refuge and along the Yukon 

River corridor. 

The vegetation is strongly influenced by both fire and flood. 

Between the years 1950 to 2005, lighting-strike fires burned an 

average of about 51,257 acres/year. Overall, about 52% of the Refuge 

burned during that period. However, fires rarely burn evenly across 

the landscape. The fire’s path is erratic—completely or partially 

burning some areas and jumping others. The result is a patchwork, 

or mosaic, of habitats in different stages of succession: a medley of 

meadows, shrublands, and forests of different ages. This variety of 

habitats can support more species than could a single habitat type. 

Each species has particular needs for food, shelter, and space that 

are best met by different habitats. In addition, the “edges” of a 

burn—where two or more plant communities meet—often supply 

a variety of needs for a variety of species. Therefore the mosaic 

created by recurrent fires and other natural disturbances can be 

beneficial to maintaining a healthy and diverse community of plants 

and animals.

Like fire, flooding is a defining force within the refuge. Much of 

the refuge is a relatively flat lowland drained by slow-moving 

river systems. Flooding at breakup is often extensive and tends to 

promote grass and sedge growth and inhibit the growth of woody 

shrubs. Flooding and subsequent drawdown of lakes and ponds 

recharges these systems with important nutrients and promotes 

lush vegetation growth.

These two natural forces, fire and water, are the dominant influences 

on refuge vegetation. Together they create a healthy mosaic of 

habitats that support a wide variety of wildlife species.

Fish and Wildlife Resources

Birds –Numerous lakes, ponds, streams, bogs, marshes, upland 

forests and riparian corridors support a rich and varied community 

of bird species. An estimated 130 species of birds use the refuge and 

about 20 species are year-round residents.

The Innoko Refuge is one of the most important waterfowl 

production areas in interior Alaska. Thousands of white-fronted and 

Canada geese nest on scattered wetlands throughout the refuge. 

About 20,000 white-fronted geese molt in the southern part of the 

refuge, particularly along the Innoko and Iditarod rivers. 

An annual average of about 190,000 ducks were counted on the 

refuge for the 22-year period from 1977 through 1998 (Conant 1999). 

Many use the refuge to rest and feed, before migrating to breeding 

An average of nearly 200,000 

ducks return to the refuge each 

spring. 

U.S. Fish and Wildlife Service

The northern hawk owl prefers 

sparse, open forest habitats. They 

may be found at the edge of burns 

or other clearings (immature 

hawk owl pictured). 
5

The refuge is critically important to two species of 

Arctic nesting geese. Taverner’s Canada geese (above 

and left), a small-bodied race of Canada goose, nests 

and molts within the refuge, especially on the Innoko 

and Iditarod river systems. 

Thousands of greater white-fronted geese (below) 

also nest and molt in the refuge. Most belong to the 

mid-continent population that winters in Texas and 

Mexico. However, a small percentage are Pacific 

flyway white-fronts that winter in central California to 

Mexico. 

Small numbers of cackling Canada geese and Tule 

white-fronted geese also occur on the refuge.

U.S. Fish and Wildlife Service

U.S. Fish and Wildlife Service U.S. Fish and Wildlife Service
grounds further north; others remain to nest within the refuge. The 

northern pintail is the most numerous duck species, followed by 

American wigeon, green-winged teal, and northern shoveler.

Other waterbirds that nest on the refuge include tundra and 

trumpeter swans, red-throated and Pacific loons, and red-necked 

grebes. Sandhill cranes, known for their elaborate courtship rituals, 

choose remote, inaccessible wetlands for nesting and raising their 

young. 

U.S. Fish and Wildlife Service

Each year, loons return to the 

same area to breed and raise 

young. Nests are mounds of 

sticks or vegetation, typically 

constructed on island shorelines 

or points of land.

Least sandpipers are among 

the shorebird species that nest 

within the Innoko Refuge. These 

small shorebirds probe damp 

mud and shallow waters for their 

invertebrate prey. 

U.S. Fish and Wildlife Service
7

Many shorebird species, including greater and lesser yellowlegs, 

long-billed dowitchers, Wilson’s snipes, semipalmated plovers, 

Hudsonian godwits, northern phalaropes and several sandpiper 

species are known to breed in the expansive marshes, bogs and 

riparian areas of the Innoko Refuge. Shorebirds undertake 

impressive annual migrations that may exceed 10,000 miles. Some 

also have restricted breeding ranges. Hudsonian godwits, for 

instance, nest in only five limited areas of North America, including 

the Innoko Refuge. After leaving these breeding areas, most of the 

Hudsonian godwit population converges on James Bay, Ontario. 

From there, most fly directly to South America, crossing the 

western Atlantic in the process. 

Gulls, jaegers and Arctic terns also nest on the refuge. The Arctic 

tern is legendary for its long migrations — flying to the edge of the 

Antarctic ice pack after fledging young reared in the Innoko Refuge 

and other Arctic locations. Their round trip journey, about 20,000 

miles, is nearly the circumference of the earth.

Many landbirds breed within the refuge. Abundant insect 

populations, undisturbed riparian areas, and a mosaic of vegetation 

types provide habitat for a variety of songbirds, including warblers, 

sparrows, thrushes, finches, buntings, flycatchers, and waxwings. 

Most of these species winter in the lower-48 states, Mexico, the 

Caribbean, or Central and South America. However, some like the 

Arctic warbler return to wintering grounds on other continents. 

This diminutive warbler travels to wintering grounds in Asia after 

rearing young in the Innoko Refuge.

At least seventeen species of eagles, hawks, falcons, and owls have 

been observed on the refuge. Harlan’s hawk, a subspecies of the redtailed hawk, is the most common raptor. Ospreys have a worldwide 

distribution, but the Innoko Refuge is the northernmost limit of 

their breeding range in western Alaska. Within the Innoko Refuge, 

raptors commonly nest in isolated stands of trees, surrounded by 

graminoid and shrub habitats.

Peregine falcons (pictured 

above), ospreys, bald and golden 

eagles, and Harlan’s hawks are 

among the raptors that nest on 

the refuge. Previously listed as 

endangered, peregrines have 

rebounded throughout much of 

their range.

U.S. Fish and Wildlife Service

Mew gull

U.S. Fish and Wildlife Service
Lee Karney

American 

wigeon

Dave Menke

Green-winged teal

Northern 

shoveler

Ducks 

Dave Menke

Lee Karney

Greater scaup

Lee Karney

Lesser scaup
9

Northern pintails. Wyman Meinzer, U.S. Fish & Wildlife Service 

The wetlands of the Innoko Refuge are prime 

duck habitat. The northern pintail is the most 

numerous species. Aerial waterfowl breeding 

population surveys have counted an annual 

average of 56,000 pintails on the Innoko Refuge. 

The American wigeon is the second most 

numerous species (34,000), followed by greenwinged teal (25,000), northern shoveler (24,000), 

mallard (16,000), and scaup (16,000).

Many other species are present in relatively 

low numbers. For instance, an average of 3,000 

canvasbacks and less than 100 gadwalls use the 

refuge annually (Conant 1999). 

David Menke

Northern pintail

Canvasback

Gary Kramer

Dave Menke

Gadwall
10

Dave Menke

Dave Menke

Mosquitoes and 

other insects 

provide a rich food 

source for many 

bird species. At 

the height of the 

breeding season, 

the refuge is filled 

with the songs of 

thrushes, sparrows, 

warblers, and other 

songbirds. 

James Leupold

Whitecrowned 

sparrow

U.S. Fish & Wildlife Service

Yellow

warbler

Varied thrush

Gray-cheeked

thrush

U.S. Fish & Wildlife Service

Fox sparrow

Rusty 

blackbird

U.S. Fish & Wildlife Service
11

Fish and Amphibians – The Innoko Refuge is home to over 20 species 

of fish, including four species of salmon, several whitefish species, 

northern pike, Alaska blackfish, burbot, and pond smelt. The 

chinook salmon that spawn in the Innoko River are part of the 

Yukon River run, one of the largest natural salmon runs in the 

world. The Alaska record northern pike, weighing in at 38.5 pounds, 

was landed on the Innoko River in 1991. Some predict the next 

world-record pike will come from this area, as well.

A single amphibian, the wood frog, is found on the refuge. The 

wood frog is a small-sized frog and the only amphibian able to 

tolerate the severe winters of the Innoko Refuge. Wood frogs can 

withstand being frozen to at least -5o

 Celsius (23o Fahrenheit) by 

increasing the amount of glucose stored in their cells. The high 

glucose concentration acts as antifreeze, protecting the fluid inside 

the cell membrane from freezing. In addition, the interstitial fluid, 

or fluid between the cells, can freeze without killing the frog. In 

fact, the wood frog can survive the winter even if a third of its body 

fluids freeze solid (USGS 2002). Although common in insects, there 

are only a handful of vertebrate species that are able to tolerate 

freezing and thawing.

Mammals – The refuge provides habitat for a variety of mammals, 

including black and grizzly bears, moose, wolves, lynx, wolverines, 

river otters, beavers, muskrats, and porcupines. 

The refuge contains excellent moose habitat. Frequent flooding 

along rivers and streams enriches the soil and helps maintain the 

riparian willow habitat necessary for winter browse. The last 

complete moose survey of the Innoko Refuge occurred in the 

winters of 2000 and 2002 (one half of the refuge was covered each 

year). This survey resulted in a population estimate of 1,960 moose 

in the southern half, and 1,724 moose in the northern half of the 

refuge and a total population estimate of 3,684 moose (0.6 moose/

mi2

). In winter 2005, an interagency moose population estimate for 

the Yukon River valley from Blackburn Island (north of Grayling) 

to Pike Lake (south of Holy Cross), an area with even better moose 

habitat, found an average density of 0.9 moose/mi2

.

Wolves are present in low to medium densities throughout the 

Robert Hines Artwork

Dave Menke

U.S. Fish & Wildlife Service

Compared to other species, the 

wood frog develops very rapidly 

from egg to tadpole to frog. This 

rapid metamorphosis is an 

important adaptation to short 

northern summers.

Northern pike (above) and coho 

salmon (right) are common fish 

species in the refuge.
12

Tracy Brooks

Wolf

Lynx

Barry Reswig

Mammals

Erwin and Peggy Bauer

Grizzly bear

Mike Bender

Black bear
13

Bull moose: Mike Lockhart, U.S. Fish & Wildlife Service 

Dave Menke

Muskrat

Marten

Erwin and Peggy

Bauer

Lisa Haggblom

Red fox

Tom Smylie

Beaver

Dave Menke

River

otter
14

refuge. The number of wolves using the refuge is unknown, however 

ADFG estimates that 1330-1800 wolves range within a 60,500 mi2 

area that includes the 6,000 mi2 Innoko Refuge (ADFG 2003a). 

Other furbearers, including lynx, marten, red fox, wolverine, 

mink, beaver, river otter, and muskrat also live in the refuge. Lynx 

and marten inhabit upland areas; beaver occur throughout lowlying areas. The highest beaver densities occur along the Yukon 

River corridor. Wolverines are present in low to medium densities 

along the Yukon River corridor and a portion of the Innoko River. 

Furbearer populations, in general, are thought to be stable or 

increasing throughout the area (ADFG 2001). 

Both black and grizzly bears use the refuge. The higher elevation 

areas are moderately good grizzly bear habitat while the lowlying areas are less favorable. Black bears are most common in the 

forested areas of the refuge. 

A small herd of caribou, the Beaver Mountains Herd, uses refuge 

lands. The herd calves in the Beaver Mountains, south of the 

refuge, but postcalving and wintering groups regularly use the 

southern portions of the refuge. The herd appears to have declined 

substantially since the early 1960s. In 1963, the herd was estimated 

to number about 3,000 caribou; in 2003 herd size was estimated at 

150-200 caribou (ADFG 2003). 

A Changing Environment?

These habitats and others across Alaska appear to be on the brink 

of potentially significant changes as a result of a warming climate. 

Because climate is intricately intertwined with other components 

of the ecosystem it is hard to predict or fully understand all the 

potential ramifications. However recent trends suggest that 

the warming climate may increase surface drying — shrinking 

water bodies and lowering the water table (Riordan et al. 2006, 

Hinzman 2005). This in turn, may trigger more frequent fires and 

insect outbreaks. Thawing permafrost could further disrupt the 

normal hydrology of the area and produce changes in soils, plant 

communities and animal populations. Although our crystal ball does 

not allow a clear picture of what the Innoko Refuge may look like in 

100 years, it could change dramatically from its current state.

U.S. Fish and Wildlife Service

A small herd of caribou uses the 

southern portion of the refuge.

Large mammals such as wolf, 

moose, bear, lynx, and caribou 

are found on refuge lands.

 U.S. Fish and Wildlife Service
15

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 3,816,220 acres. Regional and village Native 

corporations currently own or claim about 236,718 acres. In 

addition, privately-owned or selected small parcels, including 71 

Native allotments are scattered across the refuge. The remaining 

3,568,685 acres of land are administered by the refuge (Figure 1). 

This chapter summarizes the history and current land ownership 

patterns on the refuge.

History

The Athabaskan people lived in this area long before the first 

white men explored interior Alaska. In addition to winter villages, 

the Athabaskans used a number of seasonal spring and summer 

campsites to harvest furbearers, waterfowl, caribou, and other 

game species. Other camps, often located near river forks or along 

the Yukon River, offered access to salmon, whitefish and seasonal 

berries. In the 1840s, a Russian exploration documented a number 

of villages along the Innoko River, including some that were 

probably seasonal camps (Michael 1967).

In the early 1900s, the discovery of gold along the Innoko River 

and its tributaries resulted in the first influx of white men into the 

area. Supply towns and connecting trails sprang up. Branch trails 

connected the gold-mining support towns of Iditarod and Dishkaket 

to the overland mail trail between Seward and Nome. The gold 

boom was short-lived, however, and many supply towns and 

roadhouses were soon abandoned. Today, there are no communities 

inside refuge boundaries. The native village of Holikachuk was 

the last to be abandoned after residents relocated to the village of 

Grayling in the early 1960s.

In 1971, the Alaska Native Claims Settlement Act passed into 

law. ANCSA legally settled Native aboriginal claims, while 

accommodating State and conservation interests. Three Native 

corporations, formed as a result of ANCSA, claimed lands that 

Land Status

Native village and regional 

corporations own or claim 

approximately 236,718 acres 

within the refuge boundaries.

The Innoko National Wildlife 

Refuge was established by 

ANILCA in 1980. 

Gold rush fever brought the 

first influx of non-natives to the 

region. 
16

were later incorporated within refuge boundaries. Nine years 

later, on December 2, 1980, President Jimmy Carter signed the 

Alaska National Interest Lands Conservation Act (94 Stat. 2371). 

Among other things, ANILCA established the Innoko Refuge. 

Its boundaries included lands previously selected by Native 

corporations and the State of Alaska.

Village Native Corporation Land

Two village Native corporations, the Zho-Tse Corporation 

(Shageluk) and Hee-yea Lingde, Incorporated (Grayling) have 

land holdings within the refuge. Each corporation has a total 

land entitlement of 92,160 acres and each has taken some of this 

entitlement outside the refuge as well as within. As of March 2007, 

about 15,327 acres inside the refuge have been conveyed to the ZhoTse Corporation and an additional 7,481 acres have been selected. 

These land selections, however, include 5,833 acres that are also 

selected by Doyon, Limited, the regional corporation (Table 2). The 

Hee-yea Lingde Corporation owns a total of 41,926 acres within the 

refuge and has selected another 12,501 acres. The land status within 

the refuge will change as selected lands are conveyed, relinquished, 

or rejected. However, under the provisions of the Alaska Land 

Transfer Acceleration Act of 2004 (P.L. 108-452) the land status 

should be finalized by 2009.

Regional Native Corporation Lands

Doyon, Limited, holds title to about 100,256 acres of land and has 

selected an additional 59,227 acres within the Innoko Refuge. About 

5,833 acres of these claims, however, conflict with those of the ZhoTse Corporation.

According to the conveyance rules of ANCSA [Section 14(f)], Doyon 

is granted the subsurface rights to the lands conveyed to both ZhoTse and Hee-yea 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. 

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 65 allottees have been deeded a total of 7,798 

acres within the southern unit. Another 762 acres (seven parcels) 

are selected, including a total of five Vietnam veteran allotment 

claims (about 547 acres).

The regional corporation, Doyon, 

Limited, owns or claims about 

159,483 acres of land inside the 

refuge.

Nearly 7,800 acres have been 

conveyed as Native allotments.

Certain Vietnam veterans or 

their heirs could apply for an 

allotment (160 acres or less) 

under the provisions of the 

Vietnam Veterans Allotment Act 

of 1998 as amended (Public Laws 

105-276 and 106-554).

Two village corporations own or 

claim about 77,235 acres of land 

inside the refuge. 

Refuge land status will continue 

to change as selected lands 

are conveyed, relinquished or 

rejected.
19

Other Private Patents

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.

State of Alaska

The State of Alaska has selected a 129-acre parcel of land on 

Bullfrog Island in the Yukon River (Figure 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 

Table 2. Surface land status1 of the Innoko Refuge (Innoko Unit) as of March 2007

 

Category of Lands Landowner Acres 

Conveyed2

Acres 

Selected

Total

Acres3

Conflicting

Land Claims4

Federal - Refuge United States 3,568,685 3,568,685 0

State Government State of Alaska 129 129 0

Native Allotments Many (71 landowners) 7,798 762 8,560 0

Regional Native 

Corporation

Doyon Ltd 100,256 59,227 159,483 5,833

Total Regional Corp. 100,256 59,227 159,483

Other Private 12 12 0

Village Native 

Corporation

Hee-yea Lingde, Incorp. 

(Grayling)

41,926 12,501 54,427 0

Zho-Tse Corporation 

(Shageluk)

15,327 7,481 22,808 5,833

Total Village 

Corporation

57,253 19,982 77,235

Total Conflicting Claims (5,833)

Total Lands (Acres) 

Conveyed/Selected

239,586

 

1

 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. 2 Includes patented and Interim Conveyed (IC) lands. Only land claims within the refuge boundary are 

reported. 3 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. 

Acreages figures include conflicting selections and may include land covered by water. 4 Acres of land selected by more than one entity

The State of Alaska has selected 

a 129-acre tract of land within the 

refuge.
20

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). 

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). 

Undoubtedly, the Innoko Refuge contains both navigable and nonnavigable 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 nonnavigable 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 regulation changes regarding recordable 

Disclaimers of Interest may provide an administrative means 

to clear title to submerged lands. Disclaimers of Interest (RDI) 

are legal documents that allow 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 a number of subsequent applications, 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 working with the State on a case-by-case basis regarding 

management of major waterways that may be determined 

navigable.

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) 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.

In most cases, ownership of 

submerged lands within refuge 

boundaries depends on whether 

the water body is navigable.

Easements reserved under 

section 17(b) of ANCSA provide 

access across private lands to 

public lands and waters.
21

Currently, there are two one-acre site easements and one trail 

easement in the Innoko Refuge (Figure 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. 

Asserted RS-2477 Rights-of-Way

The State of Alaska asserts numerous claims to roads, trails, and 

paths across Federal lands under Revised Statute 2477. This section 

of the Mining Act of 1866 (codified as 43 U.S.C. 932) provided that 

“the right-of-way for construction of highways over public lands, not 

reserved for public use, is hereby granted.” RS-2477 was repealed 

by the Federal Land Policy and Management Act of 1976, subject 

to valid existing claims. Under authority of the Federal Land Policy 

and Management Act, the Bureau of Land Management expanded 

the regulations at 43 CFR 1864 to allow the State of Alaska and 

others to apply for Federal “disclaimers” for routes of travel that 

applicants believe qualify as RS-2477 rights-of-way. 

The State considers a number of historical transportation routes 

within Alaskan refuges to be valid RS-2477 claims. Twelve routes 

totaling 292 miles are located within the Innoko Refuge (Figure 

2; Table 3). In addition to specific routes, the State also claims 

section line easements within the refuge. If any of these claims are 

Until its repeal in 1976, Revised 

Statute 2477 authorized the 

development of public access 

routes across unreserved public 

land. 

Table 3. Mileage of asserted RS-2477 rights-of-way within the Innoko 

Unit of the Innoko Refuge 

Reference

Number

Route Name Total Mileage 

in Refuge

731 Cripple-North Fork Innoko River 6.36

730 Cripple Landing-Rennie’s Landing 22.98

557 Dikemon-First Chance Creek Trail 14.64

63 Dishkaket-Kaltag Trail 40.91

556 First Chance Ck Across Glacier-Horsefly 

Trail

5.30

97 Iditarod-Dishkaket Trail 69.87

129 Lewis Landing-Dishkaket Trail 29.24

161 Nulato-Dishkaket Trail 40.91

164 Ophir-Dishkaket Trail 23.02

732 Rennie’s Landing-Cripple Landing (South) 27.06

506 Shageluk-Holikachuk Winter Trail 7.17

165 Ophir-Iditarod 4.54

Total Miles 292.00

1

 Information from State of Alaska RS-2477 database (digital date: March 

23, 2006)

The State has identified 12 

possible RS-2477 claims in the 

southern unit of the refuge.
22

determined to be valid, they could be developed as transportation 

corridors by the State.

Identification of potential rights-of-way does not establish the 

validity of these claims, nor the public’s right to use them. In 

the absence of specific regulation or law, the validity of all RS2477 rights-of-way will be determined on a case-by-case basis, 

either through the courts or by legally binding agreement of all 

landowners.

Mining Claims

Placer gold mining in the headwaters of the Innoko river drainage 

began with the discovery of gold in Ganes Creek in 1906. In 1908, 

gold was also discovered in the Iditarod River drainage. Although 

the boom days were short-lived, some mining activities have 

continued more or less continually in the Innoko and Iditarod river 

drainages since the first discovery. Most of the activity has occurred 

upstream of the refuge (Mueller and Matz 2002). 

Historically, there were 77 mining claims in what is now the Innoko 

Refuge. No active claims remain and Refuge land is closed to new 

claims. However, placer gold mines are still operating upstream of 

the refuge and private landowners may mine their refuge inholdings 

if they choose. Until its recent closure, the largest mine in the area 

was the Illinois Creek Mine, located about six miles north of the 

refuge (Figure 1). The first large-scale heap-leach gold mine in 

Alaska, the Illinois Creek Mine produced gold through a cyanide 

extraction process (Mueller and Matz 2002). The mine and facilities 

are located on State-owned land above both banks of Illinois Creek, 

a tributary of the Little Mud River. 

Placer gold and platinum metals are also being recovered from 

Boob Creek, just outside of the eastern refuge boundary (Figure 

1; Township 25 S, Range 10 E KM). The mining history of Boob 

Creek dates back to the winter of 1915-1916 when prospectors first 

discovered deposits of gold and platinum (Dashevsky et al. 2002). 

The discovery sparked a short-lived gold rush to the area that faded 

within a few years. Small-scale prospecting and mining continued 

intermittently until the mid-1960s. Boob Creek was re-staked 

during the 1980s and exploration and small-scale mining have 

continued since that time. 

Wilderness 

With the passage of ANILCA in 1980, Congress established the 

Innoko Wilderness. Most refuge land to the south and east of the 

Innoko River lies within this 1,321,890-acre Wilderness area. Much 

of the Innoko Wilderness is a low-lying wetland drained by two 

meandering rivers, the Yetna and Iditarod. Innumerable small 

lakes, streams, and bogs receive nutrient input from a cyclic flooding 

and drawdown regime. The result is an extremely productive area 

that is critically important to nesting and migrating waterfowl and 

many other bird species.

Leslie Kerr, U.S. Fish & Wildlife Service 

There are no lode or placer 

mining claims in the refuge.

The Innoko Wilderness was 

created by ANILCA in 1980. 
25

The Innoko Refuge is managed to conserve native fish and wildlife 

populations and habitats, while providing opportunities for 

subsistence and compatible types of wildlife-dependent recreation 

(e.g. hunting, fishing, wildlife viewing, and photography). In 

practice, management issues are often complex; management 

decisions may be a compromise between conflicting values and 

competing interests of various user groups. The task is complicated 

if there is a patchwork of public and private lands within refuge 

boundaries. 

The Innoko Refuge contains less private land than most Alaska 

refuges; about seven percent is privately owned or selected. 

Most of these lands will always be owned and managed by Native 

corporations or private individuals. Refuge goals and policies are 

designed to accommodate the rights of these landowners while 

conserving refuge resources. However, building cooperative 

agreements and/or acquiring key lands or easements from willing 

owners may help us address management concerns.

This section is not an exhaustive discussion of all refuge 

management issues. Instead, it briefly reviews some refuge 

management concerns that might be addressed through particular 

land actions. 

Maintaining Healthy Ecosystems

The Innoko Refuge currently supports relatively undisturbed 

and intact ecosystems. Maintaining the integrity of these systems 

is one of our primary concerns. Characteristics such as species 

diversity, functioning of natural ecological processes, patterns and 

connectivity of lands and waters, and the balance between species 

and their environment are indicators of the health of the system. 

While humans can be an integral part of such a system, they also 

have the potential to alter its delicate balance.

Disruption of Natural Balance - Every species is part of a food 

web. These webs, which represent feeding relationships among 

the various species, may be relatively simple or quite complex. In 

an undisturbed natural system, predator and prey coexist in an 

equilibrium. Their interactions may result in cycles in population 

numbers, but each species coexists with the others through time. In 

many cases, humans have been a part of this equilibrium for eons. 

However, if new or rapidly expanding human populations are added 

to the equation, the impacts can be both complex and unexpected.

Certain species readily adapt and thrive near human populations. 

Their success may then impact other species in the food web. 

Ravens, for example, are adept at scavenging discarded human 

food wastes and thrive near human habitation. The local raven 

Refuge Management 

Concerns

The Innoko Refuge is managed to 

conserve refuge resources while 

accommodating the rights of 

private landowners.

There will always be private 

lands within the Innoko Refuge.

Land conservation measures can 

help us maintain the health and 

integrity of the entire system.
26

population may increase as food resources become more abundant 

and dependable. In turn, this increase may depress numbers of 

the raven’s natural prey, as the inflated raven population preys on 

seasonally available eggs of nesting bird species. Without a source 

of human food, the growing raven population would likely plummet 

when its natural food supply is exhausted, allowing the prey species 

to recover. However, the addition of the human component—and 

a reliable back-up food supply—may permanently alter the 

equilibrium of the natural system.

Fragmentation - From the standpoint of maintaining integrity 

and biodiversity, it is important to protect the natural pattern 

and connectivity of habitats. Larger blocks of habitat are better 

for maintaining some wildlife populations than smaller blocks; 

connected blocks of habitat are better than isolated ones. Wellplanned development can minimize or prevent adverse impacts by 

preserving migration corridors and concentrating development 

in localized areas away from sensitive habitats and wildlife 

concentrations.

Habitat Loss and Displacement - In some sensitive locations, land 

uses such as major construction projects, resource extraction, and 

road construction have the potential to displace wildlife, degrade 

habitat, and impact fish and wildlife populations. These land uses 

may modify the surface vegetation, change water flow and drainage 

patterns, increase soil erosion and sedimentation, and fragment or 

degrade key wildlife habitats.

In some cases, wildlife may abandon key habitats or stop using 

traditional migration routes. Fencing may influence animal 

movements or prevent access to former habitat areas. Domesticated 

animals, especially dogs and cats, may kill or harass wildlife. 

Unintentional pollution from faulty septic systems and landfills, 

or run-off from roads, construction sites, mines, waste piles, and 

tailings can pollute lands and waters. Fuels, oil, cleaning agents, 

and sewage are among the common pollutants that leach into 

surface waters. These chemicals can easily spread long distances via 

waterways—affecting fish, wildlife, and water quality far from the 

source.

Some private lands within the refuge have the potential for 

development as camps, lodges, or eco-tourism operations. When 

operated with care, commercial services and facilities improve 

opportunities for public use of refuge lands and waters. Compatible 

recreational activities such as hunting, fishing, wildlife observation, 

photography, and environmental education are recognized in 

law as priority public uses on National Wildlife Refuges and are 

encouraged and promoted on refuge lands. In some situations, 

however, lodges can act as a point from which human disturbance 

spreads out into the surrounding refuge lands. Popular destinations 

and major travel routes may receive much more use if there are 

commercial guides or lodges in operation. If this use occurs in the 

more sensitive habitats, wildlife species may be affected.

Tundra swans, for example, are very sensitive to disturbance during 

the nesting season. They are likely to abandon nest sites that are 

repeatedly disturbed by airplanes, boats, or foot traffic. Minimizing 

disturbance in key habitats during critical time periods is essential 

Minimizing fragmentation 

helps maintain natural species 

diversity.

Human disturbance in key 

habitats can displace sensitive 

wildlife species. 

Some species may thrive near 

human habitation at the expense 

of other species. Ravens and red 

foxes are among the species that 

readily adapt to humans.

By acquiring key parcels, we 

may be able to minimize negative 

impacts to fish and wildlife in the 

refuge.

Commercial lodges and 

ecotourism operations on 

private lands can improve the 

opportunities for public use and 

enjoyment of adjacent refuge 

lands.
27

to the continued health of species that are sensitive to noise and 

visual disturbance during part of their life cycle.

Wilderness Values 

The Wilderness Act of 1964 defines Wilderness as “untrammeled 

by man ... retaining a primeval character and influence, and without 

permanent improvements or human habitation.” Wilderness 

offers “outstanding opportunities for solitude or a primitive and 

unconfined type of recreation.” 

The Service is committed to the preservation of refuge Wilderness 

qualities. Certain uses on private lands have the potential to 

affect the aesthetic, experiential, and symbolic values of adjacent 

Wilderness areas. Even noise and visual presence can have effects 

that reach beyond property boundaries to degrade Wilderness 

values on surrounding refuge lands. 

Section 1110(a) of ANILCA authorizes the use of snowmachines 

(during periods of adequate snow cover and frozen river conditions), 

motorboats, and airplanes for traditional activities and for travel 

to and from villages and homesites. In addition, under §1110(b) 

any landowner with a valid refuge inholding, including property 

within a Wilderness area, is ensured adequate and feasible access 

to their property for economic or other purposes. Access routes 

across Wilderness lands to private parcels may degrade Wilderness 

characteristics. Motorized travel can disrupt the quietude of refuge 

visitors using non-motorized access methods to seek a Wilderness 

experience.

Complex intermixed land ownership patterns can complicate 

Wilderness management. Within the Innoko Wilderness boundary, 

more than 6,200 acres have been conveyed to, or selected by, 

private landowners (Figure 1). The conveyances include 14 Native 

allotments (15 parcels) totaling nearly 1,400 acres, and Native 

corporation conveyances (Zho-Tse, Incorporated) and conflicting 

selections (Zho-Tse, Incorporated and Doyon, Limited). Human 

activity or development on these private inholdings has the 

potential to affect the Wilderness qualities of adjacent refuge lands. 

User Group Conflicts

Residents in communities near the refuge devote a considerable 

amount of time to subsistence hunting, fishing, and gathering. 

The subsistence lifestyle is part of the cultural fabric of Native 

communities. Providing the opportunity for this lifestyle is one of 

the primary purposes of the Innoko Refuge.

Wildlife-dependent recreational activities are also recognized in law 

as priority public uses on National Wildlife Refuges. Innoko offers 

both hunting and fishing opportunities that are likely to attract 

increasing numbers of visitors to the refuge. 

Visitors often have values and cultural backgrounds that differ 

substantially from those of local residents. For instance, many sport 

fishers employ catch-and-release fishing. Often local residents view 

catch-and-release fishing as disrespectful and fear that it may result 

in a loss of those resources for future generations. Local residents 

are also concerned that non-local hunting will affect either the 

local abundance, or the migration path of traditionally harvested 

Access to refuge inholdings is 

guaranteed by ANILCA.

Noise, permanent structures and 

other evidence of human presence 

can alter nearby Wilderness 

values.

Providing the opportunity for 

a subsistence lifestyle is an 

important purpose of the Innoko 

Refuge.
28

animals. Local communities and kinship groups often view certain 

areas as traditional subsistence-use sites. When subsistence users 

find a traditional site occupied by recreational users, conflicts can 

occur. Direct confrontations are rare, but subsistence users may be 

displaced from their usual fishing or hunting time or place.

Recreational users may also inadvertently stray onto private lands 

that are scattered throughout the refuge. It is often difficult for 

refuge visitors to tell where private lands begin. Trespass issues 

and competition for refuge resources may lead to conflicts between 

visitors and local residents.

Consolidating Land Ownership Patterns

Land ownership patterns can substantially influence resource 

management options for wildlife refuges. Within the Innoko Refuge, 

most of the lands selected by or conveyed to village and regional 

Native corporations are found in large contiguous blocks. Many 

of the individual Native allotments are concentrated in these 

areas. However, there are also numerous private parcels that are 

surrounded by refuge lands. Depending on how these parcels are 

used, they have the potential to fragment wildlife habitats, affect 

natural disturbance processes, and limit the management tools 

available to refuge managers.

Complex land ownership patterns also increase the potential for 

conflict between landowners and refuge users. Refuge visitors are 

often unaware of ownership boundaries, and may wander onto or 

use private lands as if they were refuge lands.

Wildlife-dependent recreational 

activities are recognized in 

law as priority public uses on 

National Wildlife Refuges.
29

Existing Resource Protections

State and Federal Laws and Regulations: Various Federal and State 

laws have been enacted to protect certain key resources. For 

example, development in the vicinity of lakes or rivers is subject to 

State water quality laws and the Federal Clean Water Act. Other 

Federal laws regulate human activities affecting migratory birds, 

wetlands, and threatened or endangered species. 

The State imposes regulations to conserve fish and game species. 

Fishing, hunting and trapping regulations strive to limit harvest to 

a sustainable level. The Alaska Department of Fish and Game has 

the primary responsibility for managing and conserving resident 

fish and wildlife populations throughout the State.

Mineral Development: No recoverable quantities of oil have been 

discovered on the Innoko Refuge and the potential appears to 

be low. However, private landowners can pursue oil and gas 

development on their lands if they choose. By contrast, oil and gas 

exploration and development on refuge lands would only be allowed 

if the Secretary of the Interior determined these uses to be in the 

national interest and if the refuge Comprehensive Conservation 

Plan were amended (CCP amendments include a public review 

process and the completion of a refuge compatibility determination). 

Seismic and geophysical exploration would require a Special Use 

Permit with site-specific stipulations to ensure compatibility with 

refuge purposes and consistency with CCP management objectives.

Under the authority of Section 304(c) of ANILCA, the refuge is 

closed to new locations, entries, and patents. Mineral assessment 

techniques that do not have lasting impacts are permitted 

throughout the refuge, but such activities require a Special Use 

Permit complete with provisions to ensure compatibility with refuge 

purposes and consistency with CCP management objectives.

Options for Additional Resource Protection

Interested landowners can work with us in a variety of ways to 

further protect natural resources on their lands. The options range 

from simple cooperative land management agreements, to selling 

key parcels of land to the Service. It is important to note that these 

options are entirely voluntary on the part of the landowner. We 

will take no action unless the landowner wants to work with us. 

Together the Service and a willing landowner may find that one of 

the following methods provides a mutually beneficial way to protect 

natural resources.

Cooperative Agreement: A landowner and the Service may establish 

a formal written agreement in which each party agrees to manage 

the land in a manner that benefits wildlife (Sections 304(f) and 809 

Resource Protection 

Methods

Nationwide environmental 

legislation, including the Federal 

Clean Water Act, the Clean Air 

Act, and the Endangered Species 

Act provide a level of resource 

protection on both public and 

private land.

Participation in any of these 

options is entirely voluntary.

The Service will consider only 

those resource protection options 

beneficial to both the landowner 

and the Service.
30

of ANILCA). For example, a landowner may agree to maintain or 

restore important wildlife habitats located on their lands. In return, 

we may help develop land management plans or provide expertise 

and assistance restoring damaged wildlife habitats. 

Cooperative agreements place no legal restrictions on the land. No 

money is involved, and either party may cancel the agreement after 

giving adequate notice to the other party. Because landowners or 

management priorities may change, cooperative agreements do not 

grant permanent protection to fish and wildlife resources. However, 

cooperative agreements can help develop positive, working 

relationships between local landowners and the refuge. 

Lease: A lease is a short-term agreement for full or specified use 

of a parcel of land. The lease generally gives the Service occupancy 

rights and the landowner receives a rental payment based on fair 

market value. When the lease is terminated, all rights revert back 

to the landowner. This option is useful when management objectives 

are short-term, or the owners are unable to provide other forms of 

land transfer. We will rarely enter into a long-term lease because 

the cost of the lease can eventually exceed the cost of purchasing 

the land outright.

Easement: An easement is the transfer of limited property rights 

to another. Easements specifically allow or prohibit certain land 

uses. For example, an easement may allow public access across 

the property or restrict certain types of development that are not 

compatible with resource management objectives. Easements are 

legal agreements that become part of the title to the property and 

are usually permanent. If the property is sold or inherited, the 

easements continue as part of the title.

A conservation or non-development easement is one of the most 

common easements acquired for land protection. Designed to 

prevent destruction or degradation of wildlife habitat, these 

easements often limit or prevent land development while allowing 

the landowner to retain the property. They may also allow refuge 

staff to manage uses of the land to benefit wildlife. Typically, we 

consider purchasing conservation easements only when lands 

supporting key wildlife habitats are at high risk for development. 

The terms of each conservation easement are unique. We must work 

with the landowner to develop the specific conditions or restrictions 

to be included in a particular conservation easement. Once in place, 

conservation easements must be monitored by refuge staff to ensure 

that the terms of the agreement are being met. 

Easements usually reduce the market value of a piece of property. 

The tax assessed value of property with a conservation easement 

is often lower than the market value. The result is a tax savings 

for the landowner, but only if the land is taxable. The tax relief 

benefits of conservation easements are rarely important in Alaska 

since undeveloped Native corporation lands cannot be taxed, and 

only incorporated boroughs or municipalities tax property owners. 

In Alaska, we occasionally purchase conservation easements, but 

generally for large parcels of land only.

Land Exchange: Sometimes a landowner wants to trade land for 

other lands managed by the Service. We are willing to consider 

these proposals in situations where both parties will benefit. 

For example, a landowner may wish to trade an isolated tract of 

A cooperative agreement is a 

working partnership between a 

landowner and the Service.

A lease is a short-term rental of 

property.

A conservation easement is a 

transfer of limited property 

rights and is intended to restrict 

certain types of development.
31

wetlands for a more accessible upland parcel that is less costly to 

develop. A land exchange may help consolidate land ownership, 

eliminating isolated tracts or checkerboard ownership patterns. 

However, because there are high administrative costs associated 

with land exchanges, we usually pursue exchanges only when large 

acreages are involved, when the parcel we would acquire by the 

Service has very high habitat values, and/or when the exchange 

would result in a significant consolidation of lands.

Usually the lands (or interests in lands) to be exchanged must have 

approximately equal market value as determined by an appraisal. 

The market value for a property is based on the price paid for 

similar land being sold at the same time in the same general area. 

For the purposes of a land exchange, oil, gas, and mineral rights 

are considered interests in land. Due to differences in per acre land 

value, the size of parcels being exchanged may be quite different. In 

cases where the lands to be exchanged have substantially different 

values, cash payments may be used to make up the difference.

Most exchanges involve lands having equal value. However, Section 

1302 of ANILCA authorizes exchanges of lands with unequal 

value in special circumstances. In these situations, both parties to 

the exchange must agree, and the Secretary of the Interior must 

determine the exchange to be in the public interest.

Donation: Some people choose to donate lands or interests in lands 

to the Service to benefit conservation programs and receive tax 

benefits. Land preservation may be an important legacy within a 

landowner’s family, and land donation is a means of achieving that 

legacy. The landowner may place restrictions or reservations on 

the donated property. For example, a donor may want to reserve 

life-use of the donated land. In this case, the Service receives title to 

the land, but the donor has the right to continue to use the property 

during their life­time, in accordance with the terms of the deed. 

Another option, donation by will, takes effect only upon the death of 

the donor.

Rather than making a donation directly to us, a landowner might 

consider donating land to a private conservation organization. 

Several organizations, such as The Nature Conservancy and 

The Conservation Fund, accept donations of land for wildlife 

conservation. These organizations may hold and monitor the 

donation themselves, or they may put the donated land in trust for 

future addition to the refuge. Donations of land to a conservation 

organization can often be accomplished quickly.

When a landowner donates lands to the Service or a conservation 

organization they may be eligible for some Federal income tax 

benefits. For additional information, interested landowners should 

consult with a tax advisor, local Internal Revenue Service office, 

or a private conservation organization that specializes in land 

conservation.

Purchase: In some cases, a property owner may want to sell their 

land to the Service. Purchasing land is the most direct means we 

have for obtaining land title. However, funding for land acquisition 

is very limited and competitive. Consequently, we must carefully 

prioritize the use of these funds. In most cases, lands we purchase 

are considered a high priority for resource protection at the 

National level. 

A land exchange is the trade of 

lands having equal market value.

Permanent resource protection 

and tax benefits are incentives for 

land donations.
32

Our policy is to buy land only from people willing to sell. All 

purchases by the Federal government must be based on fair 

market value as determined by qualified appraisers. Usually, we 

only consider “fee title purchase” which means the government 

would acquire most rights to the property. However, in some cases 

the landowner may choose to withhold certain rights (such as use 

reservation, water rights, or mineral rights), or we may choose not 

to acquire these land interests. As with land donations, many types 

of use reservations can be negotiated.

In Alaska, the Service must offer to exchange lands prior to 

purchasing them outright (Public Law 105-277, Section 127). If 

the landowner is only interested in selling, he or she must indicate 

that the exchange offer was refused before the land purchase can 

proceed. Lands purchased by the refuge are managed in the same 

manner as the surrounding refuge land.

As with donations, non-profit conservation organizations may 

be able to purchase lands with exceptional wildlife values from a 

willing landowner. These organizations might then sell or donate the 

lands to the Service at a later date. Regardless of the method used 

to purchase lands, our policy is to buy land only from willing sellers.

Condemnation: The Alaska Native Claims Settlement Act stipulated 

that ANCSA lands could not be condemned (taken without the 

consent of the owner). Then in 1987, an amendment to ANCSA 

made all Native land and interests in land, conveyed pursuant to 

ANCSA, subject to condemnation for public purposes. However, 

it is a long-standing Service policy in Alaska that lands will not be 

acquired through adverse condemnation. We will acquire land only 

from landowners who want to sell their land.

No Action: The landowner or the Service may decide not to 

take action to protect wildlife resources on a particular piece of 

property. There are several reasons for a “no action” decision. 

Some landowners may not be interested in the land protection 

options available, and our policy is to work only with owners who 

want to work with us. On the other hand, even if the landowner is 

interested, we may decide that a parcel does not contain key wildlife 

habitat or that further protection is not warranted.

A final reason for “no action” is that the Service may not have 

funding to pursue resource protection on a parcel of land. There 

are millions of acres of inholdings in Alaskan wildlife refuges and 

many of our methods have an associated cost. Many landowners 

desire to sell their properties, but acquisition is expensive. Even if 

we wanted to, we could not afford to acquire all refuge inholdings. 

There will always be inholdings in Alaska refuges, and cooperation 

with private landowners is often the best way to achieve fish and 

wildlife conservation on private lands.

The Service may buy land from a 

willing seller.

We do not condemn land in 

Alaska.

In Alaska, we must offer 

landowners the opportunity to 

exchange lands before we will 

consider purchase.

Funds are limited, and the 

Service can only consider 

lands having a high priority for 

resource protection.
33

We set land conservation priorities for non-Federal lands inside 

the Innoko Refuge by considering habitat values, land ownership 

patterns, and other factors. We quantified and used some of these 

criteria in a geographic information system (GIS) computer model. 

Other criteria are more subjective and must be considered on a 

case-by-case basis.

The following sections explain why we develop land protection 

priorities, how priorities are established, and the priorities for the 

Innoko Refuge. 

Background: The Alaska Priority System

In 1988, the Alaska Submerged Lands Act (Public Law 100-395) 

mandated that the Service identify statewide acquisition priorities 

for all inholdings within national wildlife refuges in Alaska. This was 

a huge task. Within Alaska refuges there are 16 million acres of land 

that have been conveyed to Native corporations, private parties, 

or the State. To rank these inholdings, the Service developed the 

Alaska Priority System (APS), a GIS model that overlays species 

distribution and abundance data with land status information.

The first step in using the APS model was to map the distribution 

and relative abundance of key species within each Alaska refuge. 

We concentrated on those species and groups for which we have a 

Federal trust responsibility, including migratory birds, endangered 

species, certain marine mammals and anadromous fish, and species 

whose conservation was identified in ANILCA as a purpose of 

individual refuges. We also mapped geographic areas within each 

refuge that had important management concerns involving public 

use, access, and wilderness management. Using a computer model 

this information was combined with the land status information and 

each private parcel was given a numeric score and a statewide rank. 

Although originally developed to set statewide acquisition priorities, 

the model was subsequently modified for prioritizing parcels within 

individual refuges. We now use the model to rank privately-owned 

habitats for individual refuge Land Protection Plans.

In preparing the Innoko Land Protection Plan, we used a modified 

APS model (Appendix 1) to address resource issues specific to 

the Innoko Refuge. To the original model we added some species 

identified by the refuge staff as being of special interest or concern 

and eliminated others. Species were eliminated from the model if 

little was known about their distribution and relative density. We 

used the model to rank all conveyed Native corporation land, as well 

as conveyed or selected small parcels of 160 acres or less (referred 

to simply as “private lands”). Our model is a dynamic, rather than 

a static model, and may evolve over time as Service mandates and 

priorities change.

Resource Protection 

Priorities
34

Relative Resource Values

About 24% of the total land area inside the refuge boundary 

ranks high priority in our GIS model (Figure 3). The majority 

of these lands are along river corridors or in wetlands in the 

Innoko Wilderness. About 51% of the land ranks low priority. It 

is important to note that none of the private lands are in these 

low priority areas. About 69% of the private lands are in medium 

priority areas; 15% are in medium-high areas; and 16% are in the 

highest priority areas. This indicates that all the private lands in 

the Innoko Refuge have important biological values worthy of 

protection. Our last step in the prioritization process was to use our 

GIS model to rank the private lands against one another — to get 

the relative priorities of just the private lands.

Innoko Land Protection Priorities

We used the model to classify the private lands as high, medium, 

or low priority with approximately 33% of the total acreage in each 

category. Figure 4 shows the relative priorities of these private 

lands. Lands identified as high priority have the highest relative 

importance to the most species in our GIS model. In general, the 

highest ranking private lands are in riparian corridors, wetlands, 

and the Innoko Wilderness. Some are large tracts of Native 

corporation land; others are small parcels of 160 acres or less. 

A total of 61 small parcels (6,570 acres), ranging in size from 9 to 

160 acres, are surrounded by refuge land (Figure 4). About 46% 

(3,060 acres) of these parcels ranked high priority in our GIS model. 

Because small parcels are easily bought and sold on the open real 

estate market, we recommend acquiring priority small parcels if 

landowners wish to sell. Acquiring scattered parcels in sensitive 

habitats ensures the land will remain in its natural state, simplifies 

refuge management by consolidating land ownership patterns, and 

increases recreational and subsistence opportunities. 

Small parcels that are not on rivers or lake shores tend to be lower 

priorities. Limited access makes it unlikely that these lands will be 

developed. These parcels also tend to have lower biological values 

because they are located away from the more productive wetland 

and riparian habitats. However, acquiring these parcels would 

consolidate land ownership patterns. Any opportunity to purchase 

these parcels should be considered on a case-by-case basis.

We do not recommend pursuing additional land conservation 

measures for the large tracts of Native corporation land, even if 

they ranked high in our GIS model. In general, these lands are 

consolidated in large, contiguous blocks and pose no threat to 

refuge resources. We believe additional conservation measures are 

unnecessary at this time.

In addition, land acquisition is not always the best means for 

addressing resource threats or management concerns on these large 

tracts of land. In some cases, purchases, exchanges, or conservation 

easements are the most effective means to reduce impacts to 

refuge resources. Other times, cooperative agreements or other 

management or administrative strategies may provide a more costeffective way to resolve a potential threat to refuge resources. 

Our GIS analysis indicates 

which lands we believe have the 

highest value to fish and wildlife.

Cooperative agreements and 

conservation easements are 

valuable tools for protecting 

resources on large tracts of 

private land.

Consolidating lands may 

simplify management for both the 

refuge and private landowners.

We recommend purchasing 

priority small parcels if the 

owners wish to sell.

Some corporation lands have 

high habitat value, but are not in 

need of additional conservation 

measures at this time.
39

Furthermore, land exchanges and purchases are expensive options. 

Although large-tract landowners may be interested in pursuing 

one of these options, a lack of funding may limit our ability to act. 

We are always willing to consider proposals from landowners, but 

each must be evaluated on a case-by-case basis and may be declined 

because of insufficient funds.

Although there are many high-priority parcels in the Innoko 

Refuge, we do not intend nor expect to purchase all of these 

lands. For many high-value lands, current uses are compatible 

with wildlife, and additional resource protection measures are 

unnecessary. Even if additional protection is warranted and the 

landowner wishes to sell, limited funding is a concern. We are 

unlikely to acquire sufficient funds to purchase more than a small 

number of the high-value private lands within the refuge. However, 

should there be willing sellers, acquiring priority parcels would 

merit consideration.

Other Factors May Influence Priorities

Our GIS model ranks lands based on its perceived biological values, 

but obviously other factors may influence our final priorities. These 

“other factors” are less tangible than the scores calculated by the 

model, but they can influence our actions, especially when we have 

the opportunity to buy land. For instance, if several landowners 

wish to sell parcels with similar priority scores, these factors can 

help us choose the wisest use for limited funds. Some of the factors 

we consider are:

• the location of a parcel relative to villages, other private 

lands, and to refuge land

• the potential to consolidate ownership patterns and simplify 

management

• the type and ease of access to a parcel

• current and potential uses

Location: Whenever a landowner offers to sell, we consider 

the location of the parcel in relation to other private lands. 

Acquiring small parcels embedded in a larger block of private 

land provides little benefit to refuge resources and can create 

additional management problems. Habitats located near a village or 

commercial development may already be affected by development. 

Acquiring a conservation easement or title to these lands may 

provide little benefit for fish and wildlife. Therefore, small parcels 

located near villages or within conveyed lands are usually low 

priority for additional protection measures.

On the other hand, small, isolated parcels embedded in refuge lands 

have the potential for far-reaching impacts on adjacent refuge 

resources, depending on their use and location. The parcel may act 

as a point from which human disturbance, habitat destruction or 

pollution radiates out into surrounding refuge lands. Protecting 

these isolated tracts can be very beneficial. 

The presence of isolated private tracts may also complicate or 

preclude some types of management. For example, the difficulty 

and expense of protecting isolated private parcels may exclude the 

use of certain habitat restoration techniques, such as prescribed 

We do not intend to acquire all 

lands with high resource values.

The Service seldom acquires 

small parcels embedded in 

larger tracts of private lands.
40

burning, on adjoining refuge lands. 

Consolidation: It is advantageous to both the Service and private 

landowners to manage large contiguous holdings, rather than 

numerous small tracts interspersed with lands controlled by other 

landowners. Native corporation lands are relatively compact and 

contiguous in the Innoko Refuge. The small parcels are much less 

consolidated than corporation land. Many are entirely surrounded 

by refuge lands. Acquisition of key parcels can be an important 

mechanism to consolidate refuge lands.

Access: The Innoko Refuge, like other national wildlife refuges 

in Alaska, is open to public and subsistence access in compliance 

with ANILCA. This includes the use of snowmachines, motorboats, 

airplanes, and non-motorized surface transportation for conducting 

traditional activities, and travel to and from villages and homesites. 

However, the Service can regulate access if necessary to protect 

refuge resources from damage. In addition to public access, the 

Service must provide reasonable access to all inholders. In some 

situations, access needs of private landowners could become a 

concern for the refuge. For instance, constructing a road through 

sensitive nesting habitat to develop private lands could impact 

refuge wildlife populations. 

When we develop land conservation priorities, we must consider our 

responsibility to allow access to inholdings, provide opportunities 

for public use of refuge lands, and protect fish and wildlife resources 

from the impacts of these uses. In some cases, we may be interested 

in acquiring certain lands to improve public access or to manage 

access for the purpose of protecting resources in key areas.

Current and Potential Land Uses: When setting priorities, we 

consider existing or potential land uses that could affect wildlife, 

their habitats, or other important refuge resources. Certain parcels 

are more likely to be developed in ways that can harm wildlife. Site 

characteristics, location, or even proximity to popular recreation 

sites can make a parcel very attractive for building a commercial 

lodge or camp. Other sites, especially those near roads or villages, 

may have a higher potential for commercial or residential 

development. Some may have the potential for commercial resource 

extraction due to the abundance of a quality commercial resource. 

The ease and economic feasibility of transporting equipment, 

products, and labor to and from the extraction site also affects 

development potential.

A wide variety of land use practices can affect wildlife and habitats. 

Direct effects such as destruction of nesting habitat may be 

easily identified and measured. Indirect effects, such as habitat 

fragmentation or human disturbance in key habitat areas, may be 

much more difficult to quantify. Certain uses on private lands may 

affect important resources found on adjacent or even distant refuge 

lands. For example, commercial or industrial development along 

a river which flows into a refuge can impact downstream lands. 

Spilled fuel, oil, or chemicals can be easily transported into the 

refuge, contaminating water and habitats far from the source. 

Development on private lands can have more subtle, indirect 

impacts on refuge resources as well. Lodges, camps, or other 

commercial facilities often use adjacent refuge land for recreational 

activities, including hunting, fishing, or wildlife viewing. In most 

We consider access issues when 

setting land protection priorities.

Certain land uses on private 

property can affect important 

resources on adjacent refuge 

lands.
41

cases, these types of uses are compatible with refuge purposes and 

are encouraged. However, there is the potential for refuge impacts 

if these facilities or activities occur within sensitive wildlife habitats 

or near populations vulnerable to human disturbance.

The potential threat posed by a specific type of land use or 

development may vary substantially depending on where the parcel 

is located. Land uses that could seriously impact lands supporting 

key wildlife habitats may be of only minor concern in a less sensitive 

area. For instance, a commercial lodge operating on a remote lake 

critical to nesting tundra swans might be a concern, while a similar 

operation on a lake used by less sensitive species might not.

The potential threats to refuge wildlife populations and their 

habitats, and our ability to minimize them, are important 

considerations in developing a Land Protection Plan. Parcels with 

exceptional wildlife values may not be a high priority for protection 

if it is likely the land will always be used in wildlife-compatible 

ways. Conversely, the imminent risk of incompatible land use 

practices could elevate a lower ranking parcel to higher priority. 

Both the resource value of the land and the potential opportunity 

for reducing impacts to refuge resources influence our priorities.

Land acquisition opportunities 

will be considered on a case-bycase basis.

U.S. Fish & Wildlife Service

Red-necked grebes are among 

the many species of waterbirds 

that nest and rear young on the 

refuge. They nest in lakes and 

ponds, laying four to five eggs 

on floating mats of dead grass, 

sedges, and rushes. 
42

Meandering rivers and streams, 

lakes, bogs, and vast wetlands 

are important habitats within the 

refuge.

U.S. Fish & Wildlife Service

U.S. Fish & Wildlife Service

Sidney Charbonet

Sundews are carnivorous 

wetland plants that trap and 

digest insects on their sticky 

hairlike tentacles. The name 

refers to the glistening drops of 

mucilage that resemble morning 

dew. 
43

Refuge management actions may affect people and other refuge 

resources as well as fish and wildlife. In this chapter, we briefly 

address potential effects of land protection measures on the human 

environment, including cultural resources and the local economy. 

Effects on Cultural/Historical Resources

The Athabaskan people traditionally lived in an expansive area of 

interior Alaska including the Innoko and Iditarod River drainages. 

Native villages, now abandoned, include Dishkaket, Dementi, 

Holikachuk, and Old Shageluk. 

The discovery of gold in the early 1900s brought prospectors and 

white settlements to the area. Following traditional travel routes, 

an overland winter supply trail brought mail and supplies to the 

supply towns that sprang up in response to the influx of miners. 

This winter trail, known as the Iditarod Trail, is now a designated 

National Historical Trail.

There are 77 historic sites listed in the Alaska Heritage Resources 

Survey (AHRS) database for this region (Corbett 1995). The list 

includes historic buildings (roadhouses and cabins), abandoned 

settlements, mines, trails and cemetaries. There are 40 known 

cultural resource sites within the southern unit of the Innoko 

Refuge (Corbett, pers. comm. 2006). Nineteen of these are historic 

sites associated with the Iditarod National Historic Trail; ten 

are trail segments; two are prehistoric and the remainder are 

prehistoric with historic components. Thirteen of the sites in the 

refuge are not listed in the AHRS database because their exact 

locations are unknown. 

Relatively little archaeological work has been done on the 

Innoko Refuge and additional sites probably exist. The available 

information was collected in response to specific legal requirements 

and is proportional to survey effort. Systematic surveys and oral 

history collection might identify more historic and culturally 

important locations.

The Service is committed to protecting cultural resources on 

refuge lands and willing to assist private landowners in protecting 

resources on their lands. The assistance may take the form of 

advice, jointly prepared preservation plans, or technical assistance.

If the Service acquires properties containing cultural resources, 

they are protected under Section 106 of the National Historic 

Preservation Act of 1966. The Act requires Federal agencies 

to consider the effects of agency actions on cultural properties. 

The sites are also protected under the Archaeological Resources 

Protection Act which requires permits for research and provides 

criminal and civil penalties for looting or vandalism of sites. 

Effects of Resource 

Conservation Measures

The Service will protect cultural 

resources on acquired lands.
44

Effects on Landowners

There are no communities within the boundaries of the Innoko 

Refuge, but the village corporations of Grayling and Shageluk 

and the regional corporation, Doyon Limited, own lands within 

the boundaries. The villages of Anvik and Shageluk are located 

within 15 miles of the refuge boundary and the villages of Takotna 

and Holy Cross within about 40 miles. The refuge headquarters is 

located in the local transportation hub of McGrath. 

The private lands within the Innoko Refuge are largely undeveloped 

and owned by Native corporations or by Native allottees who 

use the land for subsistence purposes. Most of these landowners 

will not be effected by this Land Protection Plan. However, some 

landowners interested in selling could receive a cash payment 

for their land. In Alaska, we must offer to exchange lands prior 

to purchasing lands outright (Public Law 105-277, Section 127). 

Therefore, if the landowner is interested only in selling, he or 

she must indicate that the exchange offer was refused before the 

purchase can proceed. 

In some cases, landowners may be interested in exchanging their 

land for Service-owned uplands more suitable for development. For 

example, privately-owned wetlands with high wildlife value might 

be exchanged for Service land in more desirable building locations, 

or for Service-owned subsurface (sand, gravel, rock, etc.) beneath 

private lands. In some cases, land exchanges can help consolidate 

both public and private holdings. However, the Service will consider 

land exchanges only if they will benefit the refuge as well as the 

private landowner.

The Land Protection Plan could benefit large landowners by 

providing opportunities to improve management of both private and 

public resources through cooperative management agreements or 

conservation easements.

Any land the Service acquires will be preserved in its present state, 

or restored to former natural conditions, and managed in the same 

manner as the surrounding or nearby refuge lands. All acquired 

lands are available for subsistence and recreational uses.

Effects on the Economy

The communities near the Innoko Refuge support a mixed 

subsistence / cash economy. Local residents rely heavily on hunting, 

fishing, trapping, gathering and gardening to obtain food and 

materials for their own consumption. Salmon, moose, black bear, 

small game and waterfowl are important resources. Employment 

is primarily seasonal work. In 2004, nine of the 182 residents of 

Grayling and one of Shageluk’s 129 residents held commercial 

fishing permits.

Subsistence fishing is an important source of food for area residents. 

However, the abundance of salmon stocks is cyclical and periodic 

declines have occasionally reduced opportunities for subsistence and 

commercial harvest. In 2001, there was no commercial harvest of 

summer chum salmon in the Yukon River. Since 2002, salmon runs 

have increased dramatically and the 2006 summer chum run was the 

second largest on record (Clark et al. 2006). The commercial fishery 

has resumed, however, market demand has been low. 

Implementing this plan will have 

minimal effects on most local 

residents. 

Some landowners may wish 

to exchange their lands for 

others with greater development 

potential.

A mixed subsistence/cash 

economy predominates in nearby 

communities. 
45

Currently, recreational use of the refuge by people living outside 

the local area is low, but these lands and waters provide excellent 

opportunities for sport fishing and hunting. Pike fishermen visit 

during the summer months and moose hunters during the fall. As 

these hunting and fishing areas become better known, the demand 

for visitor services is expected to increase. The Service gives 

preference to local residents and to those Native corporations most 

affected by the establishment of the refuge (ANILCA § 1307(b)), 

when contracting for the provision of visitor services. Visitor 

services include any service available for a fee, such as providing 

food, accommodations, transportation, tours, and guides, with the 

exception of guided hunting and fishing (ANILCA § 1307(c)). In 

addition, Native lands are given priority consideration in the siting 

of refuge administration sites and visitor facilities. Native lands may 

be leased, or acquired by purchase or exchange. 

Land protection measures may have a positive effect on these 

industries. Land conservation measures within the refuge 

boundaries may prove beneficial by helping to protect the 

watersheds and drainages that serve as spawning and rearing areas 

for anadromous species. Conservation of habitat and resources 

through public stewardship will benefit recreational and subsistence 

uses. Managing the resource to provide habitat for wildlife and 

fish will ensure that hunting, fishing and other recreational and 

subsistence opportunities continue.

The local economy may benefit if an active land acquisition or 

exchange program develops in the future. Some landowners could 

receive a cash payment for their land, or for an interest in their 

land (such as a conservation easement). The local economy receives 

direct benefits from the refuges through the Refuge Revenue 

Sharing Act. Designed to assist communities located near refuges, 

the Act authorizes annual payments to the local government for 

any inholdings acquired by a refuge. If local communities are not 

yet organized into a regional government with taxing authority, the 

payments authorized under this act are paid to the State.

Effects on Public Access

Access is a component of public use that can be affected by land 

ownership. In Alaska, most refuge lands are open to public access. 

Most non-local visitors access the refuge via air taxi or private 

plane, while local residents rely on the full range of access modes 

identified under ANILCA Section 1110. Access can be regulated 

if needed to protect refuge resources. In some cases, specific types 

of access may be prohibited, but only after public hearings and a 

determination that the use is detrimental to area resources.

Section 17(b) of ANCSA provides public access across Native 

corporation lands. This section provides for public use easements 

across lands and at periodic points along major waterways within 

Native conveyed lands. There are currently three easements within 

the refuge boundaries, including two one-acre site easements 

and one trail easement. Unfortunately, recreationists often have 

difficulty determining whether they are on public or private land, 

especially in areas of checkerboard ownership. The result is a 

tendency to use private lands as though they are part of the refuge.

Any new land acquired by the refuge will be managed in the same 

Tourism and the demand for 

visitor services is likely to 

increase over time.

Land protection measures help 

ensure healthy watersheds and 

populations.
46

manner as the surrounding refuge lands. Traditional public access to 

the acquired property will generally be maintained. The refuge may 

impose some regulations on public use to protect resources, but in 

the long-term, private landowners are more likely to restrict public 

access or require user fees. All commercial ventures occurring on 

the acquired lands, including guided fishing and hunting, would 

be subject to the same special use permit restrictions required on 

adjacent refuge land.

Effects on Subsistence

Subsistence is a primary purpose of this refuge. Furthermore, 

Title VIII of ANILCA established in law special protection for 

subsistence activities on most Federal lands in Alaska. Rural 

residents receive a priority to harvest wildlife for subsistence 

purposes on all refuge lands where the Federal Subsistence Board 

has determined that there is a customary and traditional use of a 

particular wildlife population or fish stock. The subsistence harvest 

may be restricted if wildlife population numbers fall to dangerously 

low levels. However, the subsistence harvest is resumed when 

populations recover to healthy levels.

Unlike land purchases in the private sector, land acquisition by 

the Service ensures a subsistence priority for rural residents on 

the acquired lands. For further information, see the Subsistence 

Management Regulations for Federal Public Lands in Alaska 

(USFWS 2006).

Polly Wheeler

In Alaska, most refuge lands are 

open to public access.

In general, traditional public 

access is maintained on lands 

acquired by a refuge.

A subsistence priority for rural 

residents is ensured on acquired 

lands.

Salmon drying in the sun on the 

banks of the Yukon River.
47

When a landowner or the Service proposes resource protection 

measures, each proposal is evaluated individually. In most cases, 

land conservation decisions on the Innoko Refuge will be based on 

the following guidelines:

1. Relative rank in the GIS model

• Our GIS model divides the total acreage of non-Federal 

lands within the refuge boundary into three priority 

categories according to relative resource values.

• High priority to medium priority lands have sufficient 

resource values for the Service to consider acquiring an 

interest in the land.

• Typically, higher ranked lands are acquired before lower 

ranked lands.

• Some low priority lands may have noteworthy resources 

that warrant protection.

2. Special management values

• Protecting or acquiring certain non-Federal lands could help 

the refuge meet specific management goals and objectives. 

• Special management values include consolidating refuge 

ownership or improving management of public access.

3. Development potential and its effect on refuge resources

• While some types of development may increase the 

opportunities for public use and enjoyment of the refuges, 

others may seriously impact refuge wildlife, habitats, or 

other resources. The threat of incompatible development 

adds urgency to the need for protection. 

4. Effect of land conservation measures on overall refuge management

• Land conservation measures should simplify, not complicate, 

refuge management.

• We seldom acquire tracts of land embedded in larger blocks 

of private property.

5. Effect of land conservation measures on biological integrity, diversity, and the 

environmental health of the refuge

• Land conservation strategies should preserve or increase 

biological diversity, integrity and environmental health. 

• To protect key habitats or geographic areas, we may 

consider adopting similar land protection measures across 

all lands in the area of interest, regardless of their ranking 

in our GIS model. 

Evaluating Land Conservation 

Proposals

Many factors influence our land 

protection priorities.

In general, isolated parcels with 

high biological value warrant 

land protection.

Emerging development pressures 

or management concerns may 

cause priorities to change over 

time.

A parcel surrounded by private 

land is generally unsuitable for 

acquisition.

We consider the ecology of the 

entire area.
48

• We are interested in strategies that allow us to work 

cooperatively with landowners to protect the ecosystem now 

and in the future.

6. Landowner’s willingness to work with us to protect natural resources on their 

land

• We acquire land or interests in lands only from willing 

sellers.

• Interest in land can be obtained by lease, easement, 

exchange, donation, or fee title purchase. 

• Cooperative agreements with landowners may adequately 

protect resources if acquisition is not necessary, or if the 

landowner is willing to consider resource protections other 

than selling specific land interests. 

7. The availability of funds for land acquisition or other protection measures

• Funds are not always available for land protection 

measures. 

• Each refuge must compete nationally with other national 

wildlife refuges for acquisition funding. 

Subsurface interests are not evaluated in this land protection plan. 

In Alaska, the Service rarely acquires subsurface interests because: 

1) surface use is already regulated if the surface is refuge land; and 

2) the vast amount of privately-owned surface land must receive 

primary consideration. We generally acquire subsurface interests 

only through special mandates in response to legislative action.

Sunset on the Innoko Refuge.

U.S. Fish & Wildlife Service 

Our GIS model provides a 

relative ranking, so some 

low-scoring parcels may have 

noteworthy resource values that 

warrant protection.

All our land protection methods 

require the cooperation of 

the landowner. We will take 

action only if the landowner is 

interested.

Funding shortfalls may limit our 

ability to take action.

The Service does not prioritize 

subsurface interests.
49

Wildlife conservation is the driving mission behind the National 

Wildlife Refuge System, but people are part of the equation. 

ANILCA states that one purpose for designating Conservation 

System Units in Alaska, including National Wildlife Refuges is to:

“...preserve for the benefit, use, education and inspiration 

of present and future generations certain lands and waters 

in the State of Alaska that contain nationally significant 

natural, scenic, historic, archeological, geological, scientific, 

wilderness, cultural, recreational, and wildlife values...”

Refuge lands represent many things to many people. Alaska refuges 

have an allure that can capture the hearts and minds of people in 

distant locales. Many people care about refuge lands even though 

they may never experience them firsthand. Refuge lands have 

a different significance for those who live, work, and play within 

refuge borders. Generations of Alaska Natives have depended on 

the cyclical flow of the seasons to provide food, shelter, and a link to 

their cultural past. 

Since land protection measures can influence wildlife resources and 

the management of wildlife refuges, we want to involve the public 

in the planning process. Input from interested individuals helps 

us tailor land protection plans to meet the needs of landowners, 

wildlife, the Service, and the public. We encourage landowners and 

interested members of the public to learn more about these refuges 

and help us identify important land conservation and management 

issues. 

The planning process began with statewide public meetings in 

Anchorage and Fairbanks during October 1990 to announce the 

beginning of the land protection planning process for all refuges in 

Alaska. 

In early 2007, refuge staff met with representatives from McGrath, 

Takotna, Holy Cross, Anvik, Grayling, Shageluk, and Kaltag to brief 

them on this plan as well as the Comprehensive Conservation Plan 

revision. Participants were told that we would willingly schedule 

additional meetings at the request of interested individuals or 

groups. 

Land Protection Plan Revision

Land ownership on the Innoko Refuge will change as land is 

conveyed, relinquished, subdivided, or sold. We maintain a 

computerized database of land ownerships and a list of owners 

who express an interest in land conservation opportunities. The 

following page contains a form that landowners can use to express 

Public Involvement

We encourage landowners, and 

other interested public, to be 

involved in the land conservation 

planning process.

The Service contacted the public 

as part of the planning process.
50

interest in working with us. Just fill in the form, tear it out, fold it, 

and mail it to the address preprinted on the back.

We will periodically review the Innoko Land Protection Plan. If land 

ownership or land uses change enough to alter our land protection 

priorities, we will consider revising the plan. Whenever we propose 

significant revisions, we will notify landowners and the public.

Anna Ramsburg

Land protection planning is an 

ongoing process.

If you have any questions or 

would like to request a meeting, 

please contact the Innoko Refuge.
Would you like to work with us to protect wildlife on your land?

Would you like to receive future mailings concerning the Innoko Refuge 

Land Protection Plan?

Landowners:

Refuge Planning 

Participants:

Please use this form to express your interest in the refuge Land Protection Plan. The information you 

provide here will be used primarily for planning purposes, and does not constitute an offer to buy land.

Name:__________________________________________________________________________

Address:________________________________________________________________________

_______________________________________________________________________________

Telephone:______________________________________________________________________

Please check this box if you would like your name added to the Innoko Land Protection 

Plan mailing list.

There are 6 basic options that have been identified in the Plan. Please check the options in which you 

have interest.

No Action (I am not interested in participating)

Cooperative Agreement (An agreement between a landowner and the Service to 

help each other manage land. No money is involved.)

Conservation Easement (Landowner keeps title to land but sells development 

rights to the Service).

Exchange land for other Federal land

Sell land to the Fish and Wildlife Service

Donate land to the Fish and Wildlife Service

Legal Description of my parcel or allotment (on the Deed or other official correspondence):

T______N R______E Section ______ Lot _______________________________________________

Kateel River Meridian

Comments: ________________________________________________________________________________

__________________________________________________________________________________________

__________

If you have any questions, please contact:

Refuge Manager U.S. Fish and Wildlife Service

Innoko National Wildlife Refuge Division of Conservation, Planning & Policy

P.O. Box 69 1011 E. Tudor Road

McGrath, Alaska 99627 Anchorage, AK 99503

(907) 524-3251 (907) 786-3357

Please fold form and mail to address on other side.
From:

Fold Here

Place

Stamp

Here

To: U.S. Fish & Wildlife Service

Division of Conservation, Planning & Policy

Mail Stop 231

1011 East Tudor Road

Anchorage, Alaska 99503-6119 
53

Alaska Department of Fish and Game (ADFG). 2001. Furbearer management report of 

survey-inventory activities, 1 July 1997-30 June 2000. C. Healy, editor. Division of 

Wildlife Conservation. Project 7.0. Juneau, Alaska. 

Alaska Department of Fish and Game (ADFG). 2003a. Wolf management report of surveyinventory activities, 1 July 1999-30 June 2002. C. Healy, editor. Division of Wildlife 

Conservation, Juneau, Alaska.

Alaska Department of Fish and Game (ADFG). 2003b. Caribou management report of 

survey-inventory activities, 1 July 2000-30 June 2002. C. Healy, editor. Division of 

Wildlife Conservation, Juneau, Alaska.

Clark, Kevin J., D Bergstrom, D. Evenson. 2006. Yukon River summer chum salmon stock 

status, 2006; a report to the Alaska Board of Fisheries. Alaska Department of Fish 

and Game, Divisions of Sport Fish and Commercial Fisheries. Special Publication No. 

06-34. Anchorage, Alaska.

Conant, Bruce. 1999. Waterfowl estimates from annual Alaska-Yukon Waterfowl Breeding 

Population surveys, 1977-1998. Unpublished data, U.S. Fish and Wildlife Service, 

Waterfowl Management, Juneau, Alaska.

Corbett, Debra. 2007. Personal communication. Regional Archeologist, U.S. Fish and 

Wildlife Service, Anchorage, Alaska.

Corbett, D. and M. Arend. 1995. Innoko National Wildlife Refuge guide for managing 

cultural resources. Unpublished report. U.S. Fish and Wildlife Service, Anchorage, 

Alaska.

Dashevsky, Samuel, D. Clark, D. Wilt, D. Sherrer. 2002 gold and platinum mining at Boob 

Creek, Tolstoi Mining District, Southwestern Alaska. Abstracts of the Alaska Miners 

Association 2002 Annual Convention.

Hinzman, L. D., N. D. Bettez, W. R. Bolton, and F. S. Chapman. 2005. Evidence and 

implications of recent climate change in northern Alaska and other arctic regions. 

Climate Change 72: 251-298.

Michel, Henry (Ed.). 1967. Lieutenant Zagoskin’s travels in Russian America 1842-1844. 

Toronto: University of Toronto Press.

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 NAES-TR-02-01. 155 pp.

Riordan, B., D. Verbyla, A. D. McGuire. 2006. Shrinking ponds in subarctic Alaska based 

on 1950-2002 remotely sensed images. Journal of Geophysical Research, vol. 111.

Sources of Information
54

Skinner, Robert. 2002. Personal communication. Biologist, Innoko National Wildlife 

Refuge. 

U.S. Fish and Wildlife Service (USFWS). 1988. Acquisition of inholdings in Alaska 

National Wildlife Refuges: Draft Legislative Environmental Impact Statement. 

U.S. Department of the Interior, Anchorage, Alaska. 

U.S. Fish and Wildlife Service (USFWS). 1987. Innoko National Wildlife Refuge: final 

comprehensive conservation plan, environmental impact statement, Wilderness 

review. U.S. Department of the Interior, Anchorage, Alaska. 255 pp.

U.S. Fish and Wildlife Service (USFWS). 1990. Alaska submerged lands report: analysis 

of inholdings, acquisition priorities and recommendations to reduce impacts on 

Conservation System Units in Alaska. U.S. Fish and Wildlife Service. Anchorage, 

Alaska. 183 pp.

U.S. Fish and Wildlife Service (USFWS). 1995. The Alaska Priority System. 

Unpublished report (draft). U.S. Fish and Wildlife Service, Division of Realty, 

Anchorage, Alaska. 46 pp.

U.S. Fish and Wildlife Service (USFWS). 2006. Subsistence management regulations for 

federal public lands in Alaska. U.S. Fish and Wildlife Service, Anchorage, Alaska.

U.S. Geological Survey (USGS). 2002. Wood frog, Rana sylvatica. Northern Prairie 

Wildlife Research Center. URL: http://www.npwrc.usgs.gov/narcam
55

The Alaska Priority System (APS) model was developed to set 

State-wide priorities for all refuge inholdings. In other words, the 

private lands in each refuge in Alaska were compared with all the 

other private lands in each of the 16 National Wildlife Refuges in 

Alaska to come up with a prioritized ranking of inholdings. To set 

priorities for the Innoko Refuge, we modified the APS model to 

make it specific to the Innoko Refuge. For example, we eliminated 

from the model certain species that do not occur in the Innoko 

Refuge. The following is a brief discussion of the APS model and 

how it was modified for use in the Innoko Land Protection Plan 

process.

APS Model

The APS model uses seven resource and two management 

criteria to rank land and resources. The seven resource criteria 

are: endangered species, migratory birds, diversity of wetlands, 

diversity of uplands, marine mammals, resident refuge purpose 

species, and fisheries. The two management criteria are public use 

and refuge management — the capacity of acquisition to enhance 

management of refuge lands. 

Point values are assigned to each category (species) in the model 

based on the densities, distribution, and/or diversity of specific 

wildlife populations. Overlaying each of these layers, and adding 

their associated point scores, produces a “priority map.” Areas 

with the highest scores are those areas that are most important 

to the most species. Overlaying this priority map with the land 

status layer helps us evaluate which private lands have the highest 

biological value. The APS process is discussed in more detail in “The 

Alaska Priority System” (USFWS 1995). 

The Ranking Process for the Innoko Refuge

The ranking process began with the gathering and mapping of 

fish and wildlife data and management information. Refuge and 

Regional Office staff worked together to identify the fish and 

wildlife species, habitats, and management issues most important 

in terms of refuge purposes. We acquired the best available 

information for our analysis of species distribution and abundances. 

Sources of information ranged from hand-drawn distribution/

relative abundance maps, based on the professional judgement of 

the refuge staff, to detailed survey data.

We used a variety of processes to translate this information into 

digital ArcGIS (software by Environmental Systems Research 

Institute 2006) maps. Hand-drawn maps were digitized using 

ArcMap GIS software. We assigned relative density or relative 

habitat quality values to the resulting vector maps. Survey data 

Appendix I: Priority Analysis
56

(such as aerial waterfowl surveys conducted by the Migratory Bird 

Office) were converted directly from data tables (GPS coordinates) 

into point maps. We used the ArcGIS tool, Spacial Analyst, to create 

density maps from those data sets containing species counts or 

population data. 

In the Innoko APS model, we created a total of 25 different 

maps or layers. Of these, 23 maps displayed distribution and 

relative abundance of important species and two showed special 

management areas (fire management and Wilderness management). 

The mapped species layers included birds (American wigeon, 

American green-winged teal, scaup, northern pintail, mallard, ringnecked duck, greater white-front goose, Canada goose, sandhill 

crane, swans, peregrine falcon, and bald eagle/osprey), mammals 

(grizzly bear, black bear, caribou, moose, wolf, marten, lynx, 

beaver, and wolverine), and fish (salmon) and one species group 

(waterbirds). 

To facilitate analysis, we converted all vector data to a raster 

format. Each species layer (data layer) had the same potential 

minimum and maximum scores In this case, the maximum possible 

score was 7 and the minimum possible score was 0 (no-use). For 

example, in the mallard duck layer (map), those areas of the refuge 

not used by mallards were coded 0; areas heavily used by mallards 

were coded “7.” 

We used Spatial Analyst to sum the scores for all 25 layers and 

overlayed these with the land status map. The result is a “priority 

map” — each private parcel has an associated point score. Higher 

scores indicate use by a higher number of species and/or higher 

densities. We classified these scores into three categories (high, 

medium, and low priority). 

 Mammals

High

 Wilderness

 

 5

 7

8

3