Appendix H 

 

 

 

Compatibility Determinations 

 

 Recreational Fishing (wildlife-dependent recreation) 

 Recreational Hunting (wildlife-dependent recreation) 

 Wildlife Viewing, Photography, Environmental Education, and Environmental Interpretation 

(wildlife-dependent recreation) 

 Commercially Guided Recreational Fishing Services 

 Commercially Guided Big-Game Hunting Services 

 Commercial Transporter Services 

 Subsistence Activities 

 Reburial of Archaeological Human Remains per State and Federal Guidelines 

 Scientific Research 

 State of Alaska Management Activities 
Appendix H 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-1 

Compatibility Determinations 

COMPATIBILITY DETERMINATION 

Use: Recreational Fishing (wildlife-dependent recreation) 

Refuge Name: Alaska Peninsula and Becharof National Wildlife Refuges, King Salmon, Alaska 

Establishing and Acquisition Authority(ies) 

In 1978, President Jimmy Carter established the 1,157,000-acre Becharof National 

Wildlife Monument with Presidential Proclamation 4613. The monument was established 

from lands in the public domain to protect the area, notably the unique brown bear 

denning islands in the Island Arm area of Becharof Lake. 

In 1980, the Alaska National Interest Lands Conservation Act (ANILCA) (§302) 

established the Alaska Peninsula National Wildlife Refuge and changed the Becharof 

National Wildlife Monument to a national wildlife refuge as part of the National Wildlife 

Refuge System. ANILCA (§303[1]) created the Alaska Maritime National Wildlife 

Refuge by redesignating 11 pre-existing refuges as units of the new refuge and by adding 

other public lands on islands, islets, rocks, reefs, spires, and designated capes and 

headlands in the coastal areas and adjacent seas of Alaska. 

In 1983, the U.S. Fish and Wildlife Service (Service) decided to manage the Ugashik and 

Chignik units of Alaska Peninsula Refuge, the 9,900-acre Seal Cape area of Alaska 

Maritime Refuge, and Becharof Refuge as a “complex” because they shared resources 

and resource issues. Distance and weather create barriers to managing the Pavlof and 

North Creek units from the King Salmon office, and management of these units was 

shifted to the Izembek Refuge. 

The Becharof Wilderness Area of the Becharof Refuge was designated in 1980 by 

ANILCA (§702 [4]). 

Refuge Purpose(s) 

ANILCA sets out the purposes for each refuge in Alaska. The purposes of the Alaska 

Peninsula and Becharof National Wildlife Refuges are described in Section 302(1)(B) and 

Section 302(2)(B). Purposes for the Alaska Maritime National Wildlife Refuge are 

described in Section 303(1)(B). The purposes identify the reasons why Congress 

established the Refuges and management priorities. 

The ANILCA purposes are follows (unless otherwise noted, the purposes apply to all 

units of the Refuges): 

• to conserve fish and wildlife populations and habitats in their natural diversity 

including, but not limited to . . . 

[Becharof] . . . brown bears, salmon, migratory birds, the Alaska Peninsula 

Caribou herd, and marine birds and mammals 
Appendix H: Draft Compatibility Determinations: Recreational Fishing 

H-2 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

[Alaska Peninsula] . . . brown bears, the Alaska Peninsula caribou herd, moose, 

sea otters and other marine mammals, shorebirds and other migratory birds, 

raptors, including bald eagles and peregrine falcons, and salmonids and other fish 

[Alaska Maritime] . . . marine mammals, marine birds and other migratory birds, 

the marine resources upon which they rely, bears, caribou and other mammals 

• to fulfill the international treaty obligations of the United States with respect to 

fish and wildlife and their habitats 

• to provide, in a manner consistent with the purposes set forth above, the 

opportunity for continued subsistence uses by local residents 

• [Alaska Maritime] to provide, in a manner consistent with the purposes set forth 

above, a program of national and international scientific research on marine 

resources 

• to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth above, water quality and necessary water quantity within the 

refuge 

[Supplemental Purposes of the Becharof Wilderness Area] The Wilderness Act of 1964 

(16 U.S.C. 1131-1136 § 2a), defines supplemental purposes of all designated wilderness 

areas. These apply to the Becharof Wilderness Area and are as follows: 

• to administer the wilderness for the use and enjoyment of the American people in 

such a manner as will leave it unimpaired for future use and enjoyment as 

wilderness, to provide for the protection of the area, for the preservation of its 

wilderness character, and for gathering and dissemination of information 

regarding its use and enjoyment as wilderness. 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network 

of lands and waters for the conservation, management, and, where appropriate, 

restoration of the fish, wildlife, and plant resources and their habitats within the United 

States for the benefit of present and future generations of Americans” (National Wildlife 

Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd-668ee]).

Description of Use(s) 

The Alaska Peninsula is world-renowned for its recreational fishing and provides 

excellent opportunities to catch a number of fish species. Angling opportunities include 

fishing for five species of Pacific salmon native to Alaska, rainbow trout, lake trout, Arctic 

grayling, Arctic char, Dolly Varden, burbot, and northern pike. Recreational fishing on 

the Refuges predates refuge establishment and has continued since their establishment 

in 1980. Recreational fishing is a wildlife-dependent priority public use (National Wildlife 

Refuge System Improvement Act of 1997, as amended, § 5C). Associated activities such 

as camping, backpacking, and hiking are also considered part of wildlife-dependent 

fishing activities. 

Recreational settings on the refuges are remote and inaccessible by road. Traditional 

forms of access for all areas on the Refuges include fixed-wing aircraft, motorboats, 

snowmachines, off-road vehicles (on designated trails within the Yantarni Moderate 

Management Area), nonpowered boats, foot, and other nonmotorized means. However, 
Appendix H: Compatibility Determinations: Recreational Fishing 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-3 

the vast majority of refuge visitors participating in the subject activities access the 

Refuges by commercial air taxis. The most common means of access by the relatively few 

recreational users not using commercial transporters is via private aircraft and boats. 

Helicopters, jet-powered watercraft, and use of airboats are specifically excluded from 

this evaluation. 

Recreational fishing use patterns are estimated primarily from direct observation by 

refuge staff and from annual reports provided by air-taxi operators because they 

transport nearly all recreational anglers to locations on the Refuges. Air-taxi operators 

provide information on their clients, including primary activity, location, length of stay, 

group size, and related information. 

Most recreational fishing occurs from May through October. Timing depends on the fish 

migrations and State fishing regulations. 

The most popular destinations on the Refuges for unguided recreational fishing include 

the Ugashik Narrows, Egegik River at Becharof Outlet, both King Salmon rivers, Ruth 

River, and Featherly Creek. From 1993 through 1997, angler use appeared to be stable 

at about 50 trips per year, or between 500 and 1,000 visitor days annually. Recently, the 

number of fishing trips has increased, with 80 trips in 1998, 84 trips in 1999, and 108 trips 

in 2000. In 2000, this included 267 anglers visiting the Refuges, not including the very 

limited number who accessed the Refuges by private means of transportation. With most 

trips being day trips, the number of actual visitor days has increased only slightly, if at 

all, from the mid-1990s. 

Availability of Resources 

Adequate refuge personnel and base operational funds are available to manage wildlifedependent recreational fishing activities at existing and projected levels. Administrative 

staff time (10–20 staff days) primarily involves phone conversations, written 

correspondence, personal interaction with visitors at the visitor center, and entering 

activity data into a database. Field work associated with administering the program 

primarily involves conducting law-enforcement patrols (as many as 15 staff days) via 

aircraft and boats to increase recreational users= compliance with state and federal 

regulations and to foster respect for local residents’ activities and property. 

Anticipated Impacts of the Use(s) 

Comprehensive state and federal regulations continually evolve to respond to fishery 

management needs. Regulations, combined with law-enforcement efforts of state and 

refuge personnel, minimize impacts of recreational fishing to other users and resources. 

Although potential impacts on refuge resources and/or other refuge users are more likely 

at several popular use areas such as the Island Arm area of Becharof Lake, Ugashik 

Narrows, the Egegik River, and Becharof Lake outlet, they are still below levels that 

would cause population, genetic, or natural diversity changes. 

Recreational fishing activities may, in some cases, result in some competition or 

interference with subsistence users and/or other refuge users for limited resources or 

preferred campsites and use areas (see following discussion). However, both the Federal 

Subsistence Board and Alaska Board of Fisheries regularly adopt regulations in response 

to fish population levels and management needs to reduce impacts to these resources and 
Appendix H: Draft Compatibility Determinations: Recreational Fishing 

H-4 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

to the opportunity for continued subsistence uses of these species by local residents. In 

recent years, these boards have made numerous regulations to address the Refuges’ fish 

and resource management needs. The refuge has imposed permit restrictions on 

commercial transporters in recent years to address various concerns. Regulations have 

also been implemented by the State of Alaska in recent years to address fishery resource 

concerns at specific refuge locations, including the Ugashik Narrows and the Egegik 

River. The Refuges and the King Salmon Fishery Resources Office have conducted creel 

surveys and established public-use monitoring camps at both of these sites to collect 

information on the amount of fishing pressure at these locations. Continued monitoring of 

angler use and its effect at key sites is planned. New information will be used to evaluate 

compatibility as part of the adaptive-management process. 

The estimated harvest of fish resources is well within the limits established in Alaska 

Department of Fish and Game and Refuge management plans. Past impact evaluations 

and studies have focused primarily on impacts to Arctic grayling in the Ugashik lakes 

and Becharof Lake systems and to rainbow trout in the King Salmon River system 

(Becharof Refuge). Recent studies of rainbow trout demonstrate that this population is 

healthy and has not been adversely impacted by current levels of fishing pressure. The 

depressed Arctic grayling population in the Ugashik system has been shown to be 

recovering under restrictive regulations established by the Board of Fisheries to address 

the problem. 

Refuge officers and state Bureau of Wildlife Enforcement State Troopers routinely 

patrol the Refuges to increase compliance with state and federal regulations and permit 

conditions. 

The vast majority of recreational anglers access the Refuges by means of commercial air 

taxis, which predominantly land on lakes and rivers with float-equipped aircraft. Impacts 

associated with transporter access are discussed in a separate compatibility 

determination specific to that use. Although the limited number of recreational anglers 

who access the refuges by means of personal transport also use float planes, use of 

wheeled planes and boats is more common. Because of river access by boats, types of 

landing areas being used by aircraft, and the relatively low overall levels of use and 

access, impacts to refuge habitat are minimized. A potential impact or threat associated 

with floatplane access is the introduction of invasive species carried in on the aircraft 

floats, although this is not known to have occurred on the Alaska Peninsula to date. 

Wheeled planes land on existing un-maintained landing strips, gravel bars, and 

unvegetated sand and cinder blows. Occasionally, landings are made on vegetated 

lowland tundra, usually with Piper Super Cubs or other light aircraft equipped with 

tundra tires. Disturbance to vegetation is minimal and short-term unless repeated 

landings are made in exactly the same location, which has not been observed to happen. 

Temporary displacement and/or disturbance to wildlife can occur during take-offs and 

approaches to landings. There are no known long-term impacts to refuge wildlife 

populations from this disturbance. 

The use of off-road vehicles, for other than subsistence purposes, is prohibited on the 

Refuges except on three designated trails in the Yantarni Moderate Management Area. 

Regulations promulgated in 1995 allow three- or four-wheeled vehicles with a gross 

weight of 650 pounds or less to be used on these trails. The use of off-road vehicles on 

these trails by nonlocal or unguided recreationists is not known to have occurred in the 
Appendix H: Compatibility Determinations: Recreational Fishing 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-5 

past. Very little future use is anticipated because of the expense of transporting off-road 

vehicles to this very remote location. Even if future use were to occur at moderate levels, 

there is little potential for soil and other resource damage because the trails are located 

on existing gravel roads and the airstrip (with the exception of a short stretch where the 

airstrip has been naturally eroded away by a change in course of a nearby stream). 

Impacts concerning the Refuges’ purpose—“to provide, in a manner consistent with the 

other refuge purposes, the opportunity for continued subsistence uses by local 

residents”—has been and must continue to be carefully addressed. An issue continually 

expressed by local subsistence users is conflict with recreational anglers. Sometimes this 

deals more with the opportunity to gather, hunt, and fish in preferred ways and at 

preferred places and times than with the availability of populations of fish, animals, and 

plants. Available information on recreational use patterns does not provide evidence that 

overall use is continuing to increase as it was in the 1980s and early 1990s. Use in recent 

years at most locations is lower than levels present in the mid-1990s.

Observation of and conversations with recreational visitors in the field takes place as part 

of routine patrols and during site-specific studies such as the public-use and creel surveys 

conducted in recent years at Ugashik Narrows, Becharof Outlet, and Island Arm. 

One site having potential for crowding is Ugashik Narrows, a short stretch of river 

between the Ugashik lakes on the Alaska Peninsula Refuge. Use at the Narrows 

fluctuated considerably from 1988 through 1997, with the greatest use occurring in 1994. 

During 1998 and 1999, use increased, pointing to the area=s increasing popularity. Aside 

from the weather and changes in use patterns at the Ugashik lakes lodges, one of the 

other factors affecting use at the Narrows may have been state fishing regulations. From 

1990 through 1994, the Ugashik drainage was closed to the taking of Arctic grayling. It is 

currently open only for catch-and-release fishing. 

Crowding and use at the Narrows appears to be somewhat self-regulating. Most of the 

anglers arrive by air taxi (although several lodges access the area by boat); if one or two 

floatplanes have already landed, late arrivals often continue to other fishing locations. 

Anglers at the site also appear to be able to space themselves out well because most of 

the reach can be fished from both sides by anglers using waders. There has been little or 

no evidence of significant subsistence use at the site during the summer months since the 

Refuges were established, apparently minimizing the potential for conflict between 

recreational anglers and subsistence users. However, some local residents have stated 

that they no longer visit the Narrows when recreational anglers are there because of 

crowding. 

Becharof Outlet, where the Egegik River flows out of Becharof Lake, is another area of 

concern related to potential conflicts with subsistence users. The Outlet is a 5-mile-long 

portion of the river that lies partly within Native corporation–owned lands and partly 

within the Refuges. The area is used by Egegik residents (who travel approximately 30 

miles upriver by motorboat) and by recreational anglers (who primarily fly in by 

airplane). Refuge staff began a monitoring program during the summer of 1999 and 

continued it through 2000 to study use patterns at the outlet and to identify possible 

crowding and conflicts. Public use for the years 1999 and 2000 was almost identical; there 

was little evidence of crowding or conflict during the time of year when most users visit. 

Most use occurred off the refuge. These results should be viewed tentatively, however, 
Appendix H: Draft Compatibility Determinations: Recreational Fishing 

H-6 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

because the coho salmon runs arrived several weeks later than normal and had belowaverage numbers in both 1999 and 2000. Midway through the 1999 coho run, the state 

reduced the daily bag and possession limit from five fish to one; this could have affected 

some people’s decisions to visit. Another consideration is that a state road project 

employed local residents in Egegik during August 1999 and continued into 2000. In a 

small community where wage jobs are limited, this could have significantly reduced the 

number of local people using the area. The Service plans to continue to watch this area to 

learn more about desired experiences, perceptions of crowding and conflict, and site 

characteristics. 

Recreational fishing occurs to some degree within the designated Becharof Wilderness 

Area, located in the southeast portion of Becharof Refuge. Fishing streams used within 

the designated Wilderness Area include primarily a short stretch on upper Gertrude 

Creek, Bible Creek, Becharof Creek, and Teresa Creek. The current low and projected 

numbers of anglers and associated activities in the Becharof Wilderness Area do not and 

should not significantly impact solitude and other wilderness values. 

Public Review and Comment 

The public was invited to comment on this compatibility determination and a number of 

other determinations during the public review period establised for the draft revised 

Comprehensive Conservation Plan. Public notice of the availability of the draft 

conservation plan and draft determinations was published in the Federal Register. The 

draft determinations were also posted on the Region 7 Refuge Conservation Planning 

and Policy Web pages. No substantive public comments pertaining to this determination 

were received. Where appropriate, comments addressing elements of the draft 

Comprehensive Conservation Plan revision that pertained to the specific uses evaluated 

in this determination were considered in preparing the final compatibility determination. 

Determination 

 Use is Not Compatible 

 X Use is Compatible 

Stipulations Necessary to Ensure Compatibility 

Management direction is provided in the revised Comprehensive Conservation Plan for 

the Refuges. This directs implementation of the Refuges’ fishery management plan and 

monitoring of wildlife-dependent recreational fishing activities. Findings from these 

monitoring efforts will be used to determine what additional management actions, if any, 

are needed to ensure all fishing activities remain compatible with refuge purposes. 

To minimize impacts on refuge lands and resources, law enforcement patrols will 

routinely be conducted in an effort to maximize compliance with the following policies, 

rules, and/or regulations: 

• All activities will be monitored by the refuge manager to ensure that wildlifedependent fishing and its effects remain compatible. 

• Participants will be monitored to ensure that permitted activities are conducted in 

compliance with refuge regulations. 
Appendix H: Compatibility Determinations: Recreational Fishing 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-7 

• State regulations on season, method of take, and bag limits apply. 

• The construction or clearing of landing strips or pads is prohibited. Incidental 

hand removal of rocks and other minor obstructions may be permitted. 

• The operation of aircraft at altitudes and in flight paths resulting in the herding, 

harassment, hazing, or driving of wildlife is prohibited. It is recommended that all 

aircraft, except for take-off and landing, maintain a minimum altitude of 2,000 feet 

above ground level. 

• Any problem with wildlife and/or animals taken in defense of life or property 

must be reported immediately to the refuge manager and the Alaska Department 

of Fish and Game; animals taken in defense of life or property must be salvaged 

in accordance with state regulations. 

• In accordance with the Archaeological Resources Protection Act (16 USC 470aa), 

the excavation, disturbance, collection, or purchase of historical, recent, 

ethnological, or archaeological specimens or artifacts is prohibited. 

• Construction of cabins or other permanent structures is prohibited. 

• The use of helicopters is prohibited unless specifically authorized. 

Justification 

All refuge lands in the Alaska Peninsula and Becharof Refuges are open to general public 

access unless specifically closed. The National Wildlife Refuge System Administration 

Act of 1997, as amended (§5C), identifies the priority public uses of the System as 

wildlife-dependent recreation, defined as uses of a refuge involving hunting, fishing, 

wildlife observation and photography, and environmental education and interpretation. 

These uses are generally encouraged and receive emphasis in management of public use 

of the Refuges. 

Over the past 24 years, means of access—including airplanes, motorboats, and 

snowmachines—for traditional activities, as provided by ANILCA and as currently 

regulated by the Service, have not materially interfered with or detracted from refuge 

purposes. Should motorized transportation grow to levels where it interferes with refuge 

purposes, steps would be taken to limit the use. 

Recreational fishing is a form of traditional activity that Congress intended to preserve 

when the Refuges were established by ANILCA. As previously stated, recreational 

fishing on the Refuges provides the public with high-quality, safe, and unique 

recreational fishing opportunities found in few places in the world. To reduce impacts to 

fishery resources and to provide the continued opportunity for subsistence uses of these 

species by local residents, both the Federal Subsistence Board and Alaska Board of 

Fisheries regularly adopt regulations in response to fish population levels and 

management needs. These regulations provide adequate protection for the Refuges’ 

fishery resources, continued subsistence opportunities, and other refuge purposes. After 

fully considering the impacts of this activity, as described previously in the “Anticipated 

Impacts” section of this Compatibility Determination, it is my determination that 

recreational fishing activities on the Refuges do not materially interfere with or detract 

from the purposes of the refuges or the mission of the National Wildlife Refuge System. 

Appendix H: Compatibility Determinations: Recreational Hunting 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-9 

COMPATIBILITY DETERMINATION 

Use: Recreational Hunting (wildlife-dependent recreation)

Refuge Name: Alaska Peninsula and Becharof National Wildlife Refuges, King Salmon, Alaska

Establishing and Acquisition Authority(ies) 

In 1978, President Jimmy Carter established the 1,157,000-acre Becharof National 

Wildlife Monument with Presidential Proclamation 4613. The monument was established 

from lands in the public domain to protect the area, notably the unique brown bear 

denning islands in the Island Arm area of Becharof Lake. 

In 1980, the Alaska National Interest Lands Conservation Act (ANILCA) (§302) 

established the Alaska Peninsula National Wildlife Refuge and changed the Becharof 

National Wildlife Monument into a national wildlife refuge as part of the National 

Wildlife Refuge System. ANILCA (§303[1]) created the Alaska Maritime National 

Wildlife Refuge by re-designating 11 pre-existing refuges as units of the new refuge and 

by adding other public lands on islands, islets, rocks, reefs, spires, and designated capes 

and headlands in the coastal areas and adjacent seas of Alaska. 

In 1983, the U.S. Fish and Wildlife Service (Service) decided to manage the Ugashik and 

Chignik units of Alaska Peninsula Refuge, the 9,900-acre Seal Cape area of Alaska 

Maritime Refuge, and Becharof Refuge as a “complex” because they shared resources 

and resource issues. Distance and weather create barriers to managing the Pavlof and 

North Creek units from the King Salmon office, and management of these units was 

shifted to the Izembek Refuge. 

The Becharof Wilderness Area of the Becharof Refuge was designated in 1980 by 

ANILCA (§702 [4]). 

Refuge Purpose(s) 

ANILCA sets out the purposes for each refuge in Alaska. The purposes of the Alaska 

Peninsula and Becharof National Wildlife Refuges are described in Section 302(1)(B) and 

Section 302(2)(B). Purposes for the Alaska Maritime National Wildlife Refuge are 

described in Section 303(1)(B). The purposes identify the reasons why Congress 

established the Refuges and management priorities. 

The ANILCA purposes are as follows (unless otherwise noted, the purposes apply to all 

units of the Refuges): 

• to conserve fish and wildlife populations and habitats in their natural diversity 

including, but not limited to . . . 

[Becharof] . . . brown bears, salmon, migratory birds, the Alaska Peninsula 

Caribou herd, and marine birds and mammals 

[Alaska Peninsula] . . . brown bears, the Alaska Peninsula caribou herd, moose, 

sea otters and other marine mammals, shorebirds and other migratory birds, 

raptors, including bald eagles and peregrine falcons, and salmonids and other fish 

[Alaska Maritime] . . . marine mammals, marine birds and other migratory birds, 

the marine resources upon which they rely, bears, caribou and other mammals 
Appendix H: Compatibility Determinations: Recreational Hunting 

H-10 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

• to fulfill the international treaty obligations of the United States with respect to 

fish and wildlife and their habitats 

• to provide, in a manner consistent with the purposes set forth above, the 

opportunity for continued subsistence uses by local residents 

• [Alaska Maritime] to provide, in a manner consistent with the purposes set forth 

above, a program of national and international scientific research on marine 

resources 

• to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth above, water quality and necessary water quantity within the 

refuge 

[Supplemental Purposes of the Becharof Wilderness Area] The Wilderness Act of 1964 

(16 U.S.C. 1131-1136 Section 2a), defines supplemental purposes of all designated 

wilderness areas. These apply to the Becharof Wilderness Area and are as follows: 

• To administer the wilderness for the use and enjoyment of the American people in 

such a manner as will leave it unimpaired for future use and enjoyment as 

wilderness; to provide for the protection of the area, for the preservation of its 

wilderness character, and for gathering and dissemination of information 

regarding its use and enjoyment as wilderness.

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network 

of lands and waters for the conservation, management, and, where appropriate, 

restoration of the fish, wildlife, and plant resources and their habitats within the United 

States for the benefit of present and future generations of Americans” (National Wildlife 

Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd-668ee]).

Description of Use(s) 

The Alaska Peninsula is world-renowned for recreational hunting of a number of species. 

This activity predates refuge establishment and has continued on the Refuges since their 

establishment in 1980. Activities such as camping, backpacking, hiking, and other 

incidental uses are associated with wildlife-dependent recreational hunting activities. 

The majority of hunting has traditionally been for brown bear, moose, and caribou. To a 

much lesser extent, wolves, wolverine, waterfowl, and upland birds (primarily willow 

ptarmigan) are hunted. Because of a decline of the Northern Alaska Peninsula Caribou 

Herd, the Alaska Board of Game in 1999 adopted a Tier II subsistence hunt for Game 

Management Unit (GMU) 9E and the southern portion of GMU 9C (all Refuges lands are 

included within these units). The Federal Subsistence Board subsequently closed all 

lands within the Refuges to caribou hunting by nonlocal users. Therefore, hunting of 

caribou by other Alaskans and nonresidents will not be allowed on federal lands within 

the Refuges until the herd recovers and restrictions are lifted. 

The Refuges are remote and not accessible by road. Traditional forms of access include 

fixed-wing aircraft, motorboats, snowmachines, off-road vehicles, nonpowered boats, 

dogsled, foot, snowshoe, cross-country skis, and other nonmotorized means. The vast 

majority of visitors participating in recreational hunting access the Refuges by 

commercial air taxi. The most common means of access by those few recreational hunters 
Appendix H: Compatibility Determinations: Recreational Hunting 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-11 

not using commercial air taxis are private aircraft and boats. Off-road vehicles (ORVs) 

are only allowed on designated trails within the Yantarni Moderate Management Area. 

The use by nonlocal or unguided recreationists of ORVs in the Yantarni Moderate 

Management Area is not known to have occurred. Very little, if any, future ORV use is 

anticipated because of the expense of transporting ORVs to this remote location. Little 

cross-country skiing or snowshoeing occurs. Dogsledding as a means of access for 

recreational activities is not known to have occurred. Use of helicopters, jet-powered 

watercraft, and airboats is specifically excluded from this evaluation. 

Recreational hunting use patterns are estimated primarily from direct observation by 

refuge staff and from information in annual reports provided by air-taxi operators. Airtaxi operators provide information on primary activity, location, length of stay, group 

size, and related topics. 

Most recreational hunting occurs from May through October. From 1990 through 2004, 

the total number of air-taxi trips (for all uses) made to the Refuges fluctuated between 

140 and 190 per year. The annual number of visitor-use days on the Refuges associated 

with these trips ranged from 2,000 to 3,000. During the late 1990s, there was a reduction 

in the numbers of hunters and a shift in the type of hunting occurring on the Refuges, 

primarily because of the decline in the Northern Alaska Peninsula Caribou Herd and 

subsequent closure of the recreational hunting season. The closure of King Salmon Air 

Force Base in the mid-1990s was another contributing factor. 

During the 1990s, more trips were for caribou hunting than any other type of recreational 

hunting. Caribou-bear and bear-only trips were the next most frequent trip types, with 

just a few moose-only trips taken. Combining other animal hunts with bear or moose 

hunts may be the primary objective in combined trips, because bear and moose have 

shorter hunting seasons and provide more demanding hunts. In 1996, about 30 trips were 

bear only, 25 were caribou only, and 44 were caribou-moose. In 1997, about 40 trips were 

taken for caribou and the same number for caribou-moose; 30 trips were for caribou-bear. 

This difference reflects the change in hunting seasons in even and odd years (in evennumbered years, there were no caribou-bear hunts because bear hunting has a spring 

season only). There are no combination bear-moose hunts because those hunting seasons 

do not overlap. As stated previously, recreational hunting for caribou is not currently 

allowed on the Refuges. Air-taxi operators made 70 trips in 1998, 86 trips in 1999, and 81 

trips in 2000 to the Refuges for unguided recreational hunting, all decreases from the 

previous several years. The State of Alaska has harvest information for unguided hunters 

for GMUs 9C and 9E (which include all Refuges lands), but harvest information for just 

the refuge is not available except for guided hunting for big-game species. The range of 

harvested big game on the refuges by guided clients during the period 1993–2003 was as 

follows: moose (19–41), caribou (10–66, none after 1998), brown bear (27–55 ), wolves (0–3) 

and wolverine (0–1). 

This is an existing wildlife-dependent, priority public use that occurs throughout the 

Refuges. 

Availability of Resources 

Adequate refuge personnel and base operational funds are available to manage hunting 

activities at existing and projected levels. Administrative staff time (10–20 staff days) 
Appendix H: Compatibility Determinations: Recreational Hunting 

H-12 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

involves phone conversations, written correspondence, personal interaction with visitors 

at the visitor center, and entering activity data into a database for analysis. Field work 

associated with administering the activity primarily involves conducting law-enforcement 

patrols (as many as 20 staff days) via aircraft and boat to increase recreational hunters’ 

compliance with state and federal regulations and to foster respect for local residents’ 

activities and property. 

Anticipated Impacts of the Use(s) 

State and federal regulations continually evolve and respond to wildlife management 

needs. Regulations, combined with law-enforcement efforts of state and refuge personnel, 

minimize impacts of recreational hunting to wildlife resources, other refuge resources, 

other refuge users, and wilderness values. 

Recreational hunting activities may, in some cases, result in competition for limited 

resources such as preferred campsites or use areas, or in interference with subsistence 

users and/or other refuge users. Both the Federal Subsistence Board and the Alaska 

Board of Game regularly adopt regulations in response to wildlife population levels and 

management needs to reduce impacts to resources and to support opportunities for 

continued subsistence uses by local residents. Numerous regulation changes have been 

made by these boards in recent years to address the Refuges’ wildlife resource 

management needs. In recent years, the Refuges have also addressed concerns with 

imposed permit restrictions on commercial transporters and reductions in the number of 

clients for big-game guides. 

The estimated harvest of wildlife resources on the Refuges is well within the limits 

established in various Alaska Department of Fish and Game management plans. Past 

impact evaluations and studies have focused primarily on impacts to the brown bear, 

moose, and caribou populations. There have been no documented instances in recent 

years of defense of life or property (DLP) mortalities of bears by wildlife-dependent 

recreational users on the Refuges. Displacement of bears from favored feeding streams 

was demonstrated to be within acceptable limits. Recreational hunting of caribou has 

been closed, and moose and bear hunting seasons have been adjusted. 

Refuge officers and state Bureau of Wildlife Protection State Troopers routinely patrol 

the Refuges to increase compliance with state and federal regulations and permit 

conditions. 

As stated previously, the vast majority of the recreational hunters accessing the Refuges 

use commercial air taxis, which predominantly use float-equipped aircraft to land on 

lakes and rivers. Impacts associated with transporter access are discussed in a separate 

compatibility determination specific to that use. Although the subject users who access 

the Refuges by personal transport also use floatplanes, use of wheeled planes and boats is 

more common. Because of river access by boats, types of landing areas being used by 

aircraft, and the relatively low overall levels of use and access, impacts to refuge habitat 

from access are minimal. A potential impact or threat associated with floatplane access is 

the introduction of invasive species carried in on the aircraft floats, although this is not 

known to have occurred on the Alaska Peninsula to date. Wheeled planes land on 

existing, unmaintained landing strips, gravel bars, and unvegetated sand or cinder blows. 

Occasionally, landings are made on vegetated lowland tundra by light aircraft equipped 
Appendix H: Compatibility Determinations: Recreational Hunting 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-13 

with tundra tires. Disturbance to vegetation is minimal and short-term unless numerous 

landings are made in exactly the same location (a practice that has not been observed). 

Temporary displacement and/or disturbance to wildlife can occur during take-offs and 

landings. There are no known long-term impacts to refuge wildlife populations from this 

disturbance. 

The use of off-road vehicles (for other than subsistence purposes) by recreational hunters 

is prohibited on the Refuges except on three designated trails within the Yantarni 

Moderate Management Area. Regulations promulgated in 1995 allow three- or fourwheeled vehicles having a gross weight of 650 pounds or less on these trails. The trails 

are on an existing gravel airstrip and roads that were constructed for oil exploration prior 

to the Refuges’ acquisition of the area. The use of off-road vehicles on these designated 

trails by nonlocal or unguided recreationists is not known to have occurred in the past. 

Very little future use is anticipated because of the expense of transporting off-road 

vehicles to this remote location. Even if future use were to occur at moderate levels, there 

is little potential for soil and other resource damage because the trails are located on 

existing gravel roads and the airstrip (with the exception of a short stretch where the 

airstrip has been naturally eroded away by a change in course of a nearby stream). 

Impacts related the Refuges’ purpose, “to provide, in a manner consistent with the other 

refuge purposes, the opportunity for continued subsistence uses by local residents,” has 

been and must continue to be carefully addressed. An issue frequently raised by 

subsistence users is conflict with recreational hunters. Sometimes this deals more with 

the opportunity to gather, hunt, and fish in preferred ways and at preferred places and 

times than it does with the availability of populations of fish, animals, and plants. 

Available information on recreational use patterns does not provide evidence that overall 

hunting use is continuing to increase as it was in the 1980s and early 1990s. Use in recent 

years at most locations is lower than levels present in the mid-1990s. 

Observations of and conversations with recreational hunters in the field takes place as 

part of routine patrols and during site-specific public-use studies. 

A location of concern in recent years has been the Island Arm area of Becharof Lake. In 

1993, the Egegik Village Council submitted a proposal to the Federal Subsistence Board 

to close lands in the Severson Peninsula area of Becharof Lake to the taking of moose 

and caribou except by qualified rural residents. They stated, “Recreational hunting of 

moose and caribou in this area is affecting the migration path as well as the availability of 

caribou for the subsistence user.” Although the Federal Subsistence Board rejected the 

proposal, it directed that the refuge staff monitor hunting activity in the area and develop 

methods to resolve conflicts. Monitoring during 1994 did not find significant recreational 

hunting of caribou; however, it did find a high density of recreational hunting (19 camps 

with 36 hunters) during the September 10–20 state moose season. This recreational effort 

for moose presented significant competition to qualified rural subsistence hunters. The 

refuge manager worked with local air-taxi operators to reduce the numbers of 

recreational moose hunters using the Severson Peninsula area beginning in 1995. Since 

then, no air-taxi drop-off of moose hunters has been allowed in the area between the 

Severson Peninsula and the Burls Creek to Bear Creek line and a total of only five camps 

is allowed during the entire season in the remainder of the Island Arm area. 
Appendix H: Compatibility Determinations: Recreational Hunting 

H-14 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

Recreational hunting occurs to some degree within the designated Becharof Wilderness 

Area, located in the southeastern portion of Becharof Refuge. The current low and the 

anticipated amount of recreational hunting and its associated activities in the Becharof 

Wilderness Area do not and should not significantly affect solitude and other wilderness 

values. 

This existing activity is a wildlife-dependent, priority public use. Recreational hunting 

occurs throughout the Refuges during state-regulated hunting seasons. The magnitude of 

use is effectively regulated through state hunting regulations. Monitors will watch for 

indications of conflict between recreational and subsistence users. 

Public Review and Comment 

The public was invited to comment on this compatibility determination and a number of 

other determinations during the public review period establised for the draft revised 

Comprehensive Conservation Plan. Public notice of the availability of the draft 

conservation plan and draft determinations was published in the Federal Register. The 

draft determinations were also posted on the Region 7 Refuge Conservation Planning 

and Policy Web pages. No substantive public comments pertaining to this determination 

were received. Where appropriate, comments addressing elements of the draft 

Comprehensive Conservation Plan revision that pertained to the specific uses evaluated 

in this determination were considered in preparing the final compatibility determination. 

Determination 

 Use is Not Compatible 

 X Use is Compatible 

Stipulations Necessary to Ensure Compatibility 

Management direction is provided in the revised Comprehensive Conservation Plan for 

the Refuges, including implementation of applicable sections of the Refuges’ wildlife 

inventory plan; adequate monitoring of the wildlife-dependent recreational hunting 

activities will be used to determine what additional management actions, if any, are 

needed to ensure all hunting activities remain compatible with refuge purposes. 

To minimize impacts on refuge lands and resources, law-enforcement patrols will 

routinely be conducted in an effort to maximize compliance with the following policies, 

rules, and regulations: 

• All activities will be monitored by the refuge manager to determine if wildlifedependent recreation uses are within the rates projected by the Plan and EIS. 

• Participants will be monitored to ensure that permitted activities are conducted in 

compliance with refuge regulations. 

• State regulations on method of harvest and bag limits apply. 

• The construction or clearing of landing strips or pads is prohibited. Incidental 

hand removal of rocks and other minor obstructions may be permitted. 

• The operation of aircraft at altitudes and in flight paths resulting in the herding, 

harassment, hazing, or driving of wildlife is prohibited. It is recommended that all 
Appendix H: Compatibility Determinations: Recreational Hunting 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-15 

aircraft, except for take off and landing, maintain a minimum altitude of 2,000 feet 

above ground level. 

• Any problem with wildlife and/or animals taken in defense of life or property 

must be reported immediately to the Refuge manager and to the Alaska 

Department of Fish and Game; animals taken in defense of life or property must 

be salvaged in accordance with state regulations. 

• In accordance with the Archaeological Resources Protection Act (16 USC 470aa), 

the excavation, disturbance, collection, or purchase of historical, recent, 

ethnological, or archaeological specimens or artifacts is prohibited. 

• Construction of cabins or other permanent structures is prohibited. 

• The use of helicopters is prohibited. 

Justification 

All refuge lands in the Alaska Peninsula and Becharof Refuges are open to general public 

access unless specifically closed. The National Wildlife Refuge System Administration 

Act, as amended, identifies priority public uses of the System as wildlife-dependent 

recreation, further defined as uses of a refuge involving hunting, fishing, wildlife 

observation and photography, and environmental education and interpretation. These 

uses are generally encouraged and receive emphasis in management of public use of the 

refuges. 

Over the past 24 years, means of access for traditional activities, including airplanes, 

motorboats, and snowmachines, as provided by Alaska National Interest Lands 

Conservation Act (ANILCA) and as currently regulated by the Service, have not 

materially interfered with or detracted from refuge purposes. Should motorized means of 

transportation grow to levels where they interfere with refuge purposes, steps would be 

taken to bring them under control. 

Recreational hunting is a form of traditional activity that Congress intended to preserve 

with the enactment of ANILCA, which established the refuges. As stated previously, 

recreational hunting on the Refuges provides the public with high-quality, safe, and 

exceptional hunting opportunities found few places elsewhere in the world. In response to 

wildlife population levels and management needs, both the Federal Subsistence Board 

and the Alaska Board of Game regularly modify regulations to reduce impacts to wildlife 

resources and to provide the continued opportunity to pursue a subsistence lifestyle.

After fully considering the impacts of this activity as described previously in the 

“Anticipated Impacts” section of this compatibility determination, it is my determination 

that recreational hunting activities on the Refuges do not materially interfere with or 

detract from the purposes of the Refuges or the mission of the National Wildlife Refuge 

System. Recreational hunting is a wildlife-dependent priority public use. The use 

supports refuge goals and objectives.

Mandatory 10-Year Re-Evaluation Date (provide month and year for allowed uses only): NA 

Mandatory 15-Year Re-Evaluation Date (for priority public uses): January 2020 

Appendix H: Compatibility Determinations: Wildlife Viewing, Photography, 

Environmental Education and Interpretation 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-17 

COMPATIBILITY DETERMINATION 

Use: Wildlife Viewing, Photography, Environmental Education, and Environmental 

Interpretation (wildlife-dependent recreation) 

Refuge Name: Alaska Peninsula and Becharof National Wildlife Refuges, King Salmon, Alaska

Establishing and Acquisition Authority(ies) 

In 1978, President Jimmy Carter established the 1,157,000-acre Becharof National 

Wildlife Monument with Presidential Proclamation 4613. The monument was established 

from lands in the public domain to protect the area, notably the unique brown bear 

denning islands in the Island Arm area of Becharof Lake. 

In 1980, the Alaska National Interest Lands Conservation Act (ANILCA) (§302) 

established the Alaska Peninsula National Wildlife Refuge and changed the Becharof 

National Wildlife Monument into a national wildlife refuge as part of the National 

Wildlife Refuge System. ANILCA (§303[1]) created the Alaska Maritime National 

Wildlife Refuge by redesignating 11 pre-existing refuges as units of the new refuge and 

by adding other public lands on islands, islets, rocks, reefs, spires, and designated capes 

and headlands in the coastal areas and adjacent seas of Alaska. 

In 1983, the U.S. Fish and Wildlife Service (Service) decided to manage the Ugashik and 

Chignik units of Alaska Peninsula Refuge, the 9,900-acre Seal Cape area of Alaska 

Maritime Refuge, and Becharof Refuge as a “complex” because they share resources and 

resource issues. Management of the Pavlof and North Creek units of the Alaska 

Peninsula Refuge was shifted to the Izembek Refuge because distance and weather 

create barriers accessing them from King Salmon. 

The Becharof Wilderness Area of the Becharof Refuge was designated in 1980 by 

ANILCA (§702 [4]). 

Refuge Purpose(s) 

ANILCA sets out the purposes for each refuge in Alaska. The purposes of the Alaska 

Peninsula and Becharof National Wildlife Refuges are described in Section 302(1)(B) and 

Section 302(2)(B). Purposes for the Alaska Maritime National Wildlife Refuge are 

described in Section 303(1)(B). These purposes identify the reasons why Congress 

established the Refuges and establish management priorities. 

The purposes of the Alaska Peninsula and Becharof Refuges are follows (unless 

otherwise noted, the purposes apply to all units of the Refuges): 

• to conserve fish and wildlife populations and habitats in their natural diversity 

including, but not limited to . . . 

[Becharof] . . . brown bears, salmon, migratory birds, the Alaska Peninsula 

Caribou herd, and marine birds and mammals 

[Alaska Peninsula] . . . brown bears, the Alaska Peninsula caribou herd, moose, 

sea otters and other marine mammals, shorebirds and other migratory birds, 

raptors, including bald eagles and peregrine falcons, and salmonids and other fish 
Appendix H: Compatibility Determinations: Wildlife Viewing, Photography, 

Environmental Education and Interpretation 

H-18 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

[Alaska Maritime] . . . marine mammals, marine birds and other migratory birds, 

the marine resources upon which they rely, bears, caribou and other mammals 

• to fulfill the international treaty obligations of the United States with respect to 

fish and wildlife and their habitats 

• to provide, in a manner consistent with the purposes set forth above, the 

opportunity for continued subsistence uses by local residents 

• [Alaska Maritime] to provide, in a manner consistent with the purposes set forth 

above, a program of national and international scientific research on marine 

resources 

• to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth above, water quality and necessary water quantity within the 

refuge 

[Supplemental Purposes of the Becharof Wilderness Area] The Wilderness Act of 1964 

(16 U.S.C. 1131-1136 § 2a) defines supplemental purposes of all designated wilderness 

areas. These apply to the Becharof Wilderness Area and are as follows: 

• to administer the wilderness for the use and enjoyment of the American people in 

such a manner as will leave it unimpaired for future use and enjoyment as 

wilderness; to provide for the protection of the area, for the preservation of its 

wilderness character, and for gathering and dissemination of information 

regarding its use and enjoyment as wilderness. 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network 

of lands and waters for the conservation, management, and, where appropriate, 

restoration of the fish, wildlife, and plant resources and their habitats within the United 

States for the benefit of present and future generations of Americans” (National Wildlife 

Refuge System Administration Act, as amended [16 U.S.C. 668dd-668ee]).

Description of Use(s) 

The Refuges provide excellent opportunities for “Big Six” wildlife-dependent, priority 

public uses, which are hunting, fishing, wildlife viewing, wildlife photography, and 

environmental education and interpretation. These activities predate refuge 

establishment in 1980. They occur throughout the Refuges and throughout the year. 

Hunting and fishing are discussed in other, separate compatibility determinations. 

Associated activities such as camping, backpacking, hiking, and other incidental uses are 

considered part of these wildlife-dependent activities. 

Recreational settings on the Refuges are remote and not accessible by road. Traditional 

forms of access for all areas on the Refuges include fixed-wing aircraft, motorboat, 

snowmachine, off-road vehicle (on designated trails in the Yantarni Moderate 

Management Area), nonpowered boats, dogsled, foot, snowshoes, cross-country skis, and 

other nonmotorized means. However, the vast majority of the visitors participating in 

these activities access the Refuges by commercial air taxi. The most common means of 

access by the relatively few recreational users not using commercial transporters (air 
Appendix H: Compatibility Determinations: Wildlife Viewing, Photography, 

Environmental Education and Interpretation 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-19 

taxis) are private aircraft and boats. Use of helicopters, jet-powered watercraft, and 

airboats is specifically excluded from this evaluation. 

Wildlife viewing and photography primarily occur incidentally to hunting and fishing 

activities. Increased use of the Refuges for ecotourism activities (which would include 

wildlife viewing) projected by the previous Public Use Management Plan have not 

occurred. Camping usually occurs for periods of several days. Camps range from small, 

backpack-type tent camps to larger, multiperson, fully equipped wall tents. 

Because of the lack of developed visitor facilities on the Refuges, interpretive and 

education efforts occur primarily off-refuge in King Salmon or in surrounding villages. 

The Refuges’ public-use staff manages and operates the King Salmon Interagency 

Visitor Center in cooperation with the National Park Service, Bristol Bay Borough, and 

Lake and Peninsula Borough. The center is located in a leased building at the airport in 

King Salmon. During 2000, more than 13,000 people visited the center. Visitors from 43 

states and 21 countries signed the guest register, reflecting the national and international 

appeal of the area’s attractions and opportunities. 

The visitor center contains a number of interpretive displays and exhibits, a theater, an 

interactive computer, and a bookstore sponsored by the Alaska Natural History 

Association. Exhibit topics include common fish of the Alaska Peninsula used for 

recreational purposes, birds, wildlife, Native peoples, and local history of the Alaska 

Peninsula. The center also contains a resource-lending library, which makes available 

books, videotapes, and audiovisual materials on natural and cultural resources. 

The Refuges have an active education and outreach program. Environmental education 

programs focus on the National Wildlife Refuge System, the purposes for which the 

Refuges were established, and significant resource-management issues. The Refuges also 

promote conservation of geese and waterfowl through the Western Alaska Goose 

Calendar Contest and the Alaska Junior Federal Duck Stamp Contest. Other topics have 

included predator-prey relationships and the conservation of bears, birds, caribou, moose, 

and marine mammals. Refuge public-use staff typically give 65-100 educational programs 

annually in 12 villages, working with more than 600 students. The Refuges conduct 

additional programs and activities for special events and occasions such as National 

Wildlife Refuge Week, National Wildlife Week, International Migratory Bird Day, and 

National Fishing Week. 

In cooperation with numerous other entities, the Refuges conduct a week-long residential 

camp—“Spirit of Becharof Lake” Ecosystem Science Camp—for area high school 

students. Facilities are located within the Becharof Wilderness Area on the Becharof 

National Wildlife Refuge. Sessions integrate western science methodology with 

traditional local knowledge . 

Availability of Resources 

Adequate refuge personnel and base operational funds are available to manage on-refuge 

wildlife-dependent recreational activities at existing and projected levels. Administrative 

staff time primarily involves phone conversations, written correspondence, and 

interaction with visitors at the visitor center. There is additional work entering activity 

data into a database. Field work (as many as 5 staff days) associated with administering 

the program related to wildlife viewing and photography primarily involves monitoring 
Appendix H: Compatibility Determinations: Wildlife Viewing, Photography, 

Environmental Education and Interpretation 

H-20 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

recreational users’ compliance with state and federal regulations. The only environmental 

education and interpretation occurring on the Refuges and under the scope of this 

compatibility determination are in conjunction with the annually conducted five-day long 

“Spirit of Becharof” science camp. The refuge contributes $17,000 to fund this camp in 

cooperation with the local school districts and several of contributing partners. 

Anticipated Impacts of the Use(s) 

Regulations, combined with law-enforcement efforts of state and refuge personnel, 

minimize impacts of wildlife-dependent uses on fish and wildlife, other refuge resources, 

other refuge users, and wilderness values. 

As stated previously, the vast majority of the recreational users access the Refuges using 

commercial air taxis, which predominantly land on lakes and rivers using float-equipped 

aircraft. Impacts associated with transporter access are discussed in a separate 

compatibility determination specific to that use. Although users who access the Refuges 

by personal transport also use float planes, use of boats and wheeled planes is more 

common. Because of river access by boats, types of landing areas used by aircraft, and 

the relatively low overall levels of use and access, impacts to refuge habitats are 

minimized. A potential impact or threat associated with floatplane access is the 

introduction of invasive species carried on the aircraft floats, although this has not been 

known to have happened on the Alaska Peninsula to date. Wheeled planes land on 

existing, un-maintained landing strips, gravel bars, and un-vegetated sand or cinder 

blows. Occasionally, landings are made on vegetated lowland tundra, usually with Piper 

Super Cubs or other light aircraft equipped with tundra tires. Disturbance to vegetation 

is minimal and short-term unless repeated landings are made in exactly the same location 

(this practice has not been observed to date). Temporary displacement and/or 

disturbance of wildlife can occur during take-offs and landings. There is no known longterm impact to refuge wildlife populations from this disturbance. 

The use of off-road vehicles (for other than subsistence purposes) by subject users is 

prohibited on the Refuges except on three designated trails in the Yantarni Moderate 

Management Area. Regulations promulgated in 1995 allow three- or four-wheeled 

vehicles having a gross weight of 650 pounds or less for general public use on these 

designated trails. The trails are on an existing gravel airstrip and roads that were 

constructed for oil exploration prior to the Refuges’ establishment. The use of off-road 

vehicles on these trails by nonlocal or unguided recreationists is not known to have 

occurred. Very little future use is anticipated because of the expense of transporting offroad vehicles to this very remote location. Even if future use were to occur at moderate 

levels, there is little potential for soil and other resource damage because the trails are 

located on existing gravel roads and the airstrip (with the exception of a short stretch 

where the airstrip has been naturally eroded away by a change in course of a nearby 

stream). 

Observation of and conversations with recreational visitors in the field takes place as part 

of routine patrols and during site-specific public-use studies, such as the public-use and 

creel surveys conducted in recent years at Ugashik Narrows, Becharof Outlet, and Island 

Arm. 
Appendix H: Compatibility Determinations: Wildlife Viewing, Photography, 

Environmental Education and Interpretation 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-21 

All recreational uses occur to some degree within the designated Becharof Wilderness 

Area, located in the southeastern portion of the Becharof Refuge. Very few trips solely 

for wildlife viewing and photography are made to the area. Nearly all environmental 

education and interpretation activities take place off the Refuges, creating no adverse 

impacts. The “Spirit of Becharof” science camp is the only organized environmental 

education event being conducted within the Wilderness Area. The current low and 

projected numbers of wildlife-dependent recreational visitors and activities to the 

Becharof Wilderness Area for environmental education and interpretation purposes 

should not significantly affect solitude and other wilderness values. 

In summary, the magnitude of use related to wildlife viewing and photography, 

environmental education and interpretation is not likely to change in the near future, and 

there will continue to be negligible direct or indirect effects on the refuge. 

Public Review and Comment 

The public was invited to comment on this compatibility determination and a number of 

other determinations during the public review period establised for the draft revised 

Comprehensive Conservation Plan. Public notice of the availability of the draft 

conservation plan and draft determinations was published in the Federal Register. The 

draft determinations were also posted on the Region 7 Refuge Conservation Planning 

and Policy Web pages. No substantive public comments pertaining to this determination 

were received. Where appropriate, comments addressing elements of the draft 

Comprehensive Conservation Plan revision that pertained to the specific uses evaluated 

in this determination were considered in preparing the final compatibility determination. 

Determination 

 Use is Not Compatible 

 X Use is Compatible 

Stipulations Necessary to Ensure Compatibility 

Management direction provided in the revised Comprehensive Conservation Plan for the 

Refuges will be implemented. This includes provisions for adequate monitoring of the 

wildlife-dependent recreational activities. Findings from these monitoring efforts will be 

used to determine what additional management actions, if any, are needed to ensure all 

wildlife-dependant recreational activities remain compatible with refuge purposes. 

The following stipulations apply to special-use permits issued for wildlife-dependent 

recreation (wildlife viewing, photography, environmental education, and interpretation). 

To minimize impacts on refuge lands and resources, law-enforcement patrols will 

routinely be conducted in an effort to maximize compliance with policies, rules, and 

regulations. 

• All activities will be monitored by the refuge manager to ensure that wildlifedependent recreation and its impacts remain compatible with refuge purposes. 

• Participants will be monitored to ensure that permitted activities are conducted in 

compliance with refuge regulations. 
Appendix H: Compatibility Determinations: Wildlife Viewing, Photography, 

Environmental Education and Interpretation 

H-22 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

• The construction or clearing of landing strips or pads is prohibited. Incidental 

hand removal of rocks and other minor obstructions may be permitted. 

• The operation of aircraft at altitudes and in flight paths resulting in the herding, 

harassment, hazing, or driving of wildlife is prohibited. It is recommended that all 

aircraft, except for take-off and landing, maintain a minimum altitude of 2,000 feet 

above ground level. 

• Any problem with wildlife and/or animals taken in defense of life or property 

must be reported immediately to the refuge manager and the Alaska Department 

of Fish and Game; animals taken in defense of life or property must be salvaged 

in accordance with state regulations. 

• In accordance with the Archaeological Resources Protection Act (16 USC 470aa), 

the excavation, disturbance, collection, or purchase of historical, recent, 

ethnological, or archaeological specimens or artifacts is prohibited. 

• Construction of cabins or other permanent structures is prohibited. 

• The use of helicopters is prohibited unless specifically authorized in writing in the 

permit. 

Justification 

All refuge lands in the Alaska Peninsula and Becharof Refuges are open to general public 

access unless specifically closed. The National Wildlife Refuge System Administration 

Act of 1997, as amended, (§5) identifies wildlife-dependent recreation as priority public 

uses of the System. These are defined as uses of a refuge involving hunting, fishing, 

wildlife observation and photography, and environmental education and interpretation. 

These uses are generally encouraged and are to receive emphasis in management of 

public uses of the Refuges. 

Over the past 24 years, means of access—including aircraft, motorboats, and 

snowmachines for traditional activities as provided by ANILCA and as currently 

regulated by the Service—have not materially interfered with or detracted from refuge 

purposes. Should the amount of motorized transportation grow to levels such that it 

interferes with refuge purposes, steps would be taken to bring the use under control. 

To protect and manage land and wildlife resources for the benefit of the American people 

is part of the Refuge System’s mission. It is important to provide the opportunity, when 

possible, for the public to visit the Refuges, allowing them to observe wildlife and its 

habitats in the simplest and most basic form. The Refuges provide an incredible 

opportunity to function as an outdoor classroom, promoting an awareness of ecological 

functions and the interrelationship between human activities and the natural system, and 

to educate and motivate future generations of people so that they effectively support 

wildlife conservation. For many, the only opportunity to gain that experience will be on a 

national wildlife refuge. The current and projected levels of wildlife-dependent 

recreational activities (wildlife observation, wildlife photography, environmental 

education, and interpretation) occurring on the Refuges are very low. After fully 

considering the impacts of this activity, as described previously in the “Anticipated 

Impacts” section of this compatibility determination, it is my determination that wildlife 

viewing and photography, environmental education, and environmental interpretation 

Appendix H: Compatibility Determinations: Commercially Guided Recreational Fishing Services 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-25 

COMPATIBILITY DETERMINATION 

Use: Commercially Guided Recreational Fishing Services

Refuge Name: Alaska Peninsula and Becharof National Wildlife Refuges, King Salmon, Alaska 

Establishing and Acquisition Authority(ies) 

In 1978, President Jimmy Carter established the 1,157,000-acre Becharof National 

Wildlife Monument with Presidential Proclamation 4613. The monument was established 

from lands in the public domain to protect the area, notably the unique brown bear 

denning islands in the Island Arm area of Becharof Lake. 

In 1980, the Alaska National Interest Lands Conservation Act (ANILCA) (§ 302) 

established the Alaska Peninsula National Wildlife Refuge and changed the Becharof 

National Wildlife Monument into a national wildlife refuge as part of the National 

Wildlife Refuge System. ANILCA (§ 303[1]) created the Alaska Maritime National 

Wildlife Refuge by redesignating 11 pre-existing refuges as units of the new refuge and 

by adding other public lands on islands, islets, rocks, reefs, spires, and designated capes 

and headlands in the coastal areas and adjacent seas of Alaska. 

In 1983, the U.S. Fish and Wildlife Service (Service) decided to manage the Ugashik and 

Chignik units of Alaska Peninsula Refuge, the 9,900-acre Seal Cape area of Alaska 

Maritime Refuge, and Becharof Refuge as a “complex” because they shared resources 

and resource issues. Distance and weather create barriers to managing the Pavlof and 

North Creek units from the King Salmon office, and management of these units was 

shifted to the Izembek Refuge. 

The Becharof Wilderness Area of the Becharof Refuge was designated in 1980 by 

ANILCA (section 702 [4]). 

Refuge Purpose(s) 

ANILCA sets out the purposes for each refuge in Alaska. The purposes of the Alaska 

Peninsula and Becharof National Wildlife Refuges are described in Section 302(1)(B) and 

Section 302(2)(B). Purposes for the Alaska Maritime National Wildlife Refuge are 

described in Section 303(1)(B). The purposes identify the reasons why Congress 

established the Refuges and management priorities. 

The ANILCA purposes are as follows (unless otherwise noted, the purposes apply to all 

units of the Refuges): 

• to conserve fish and wildlife populations and habitats in their natural diversity 

including, but not limited to . . . 

[Becharof] . . . brown bears, salmon, migratory birds, the Alaska Peninsula 

Caribou herd, and marine birds and mammals 

[Alaska Peninsula] . . . brown bears, the Alaska Peninsula caribou herd, moose, 

sea otters and other marine mammals, shorebirds and other migratory birds, 

raptors, including bald eagles and peregrine falcons, and salmonids and other fish 

[Alaska Maritime] . . . marine mammals, marine birds and other migratory birds, 

the marine resources upon which they rely, bears, caribou and other mammals 
Appendix H: Compatibility Determinations: Commercially Guided Recreational Fishing Services 

H-26 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

• to fulfill the international treaty obligations of the United States with respect to 

fish and wildlife and their habitats 

• to provide, in a manner consistent with the purposes set forth above, the 

opportunity for continued subsistence uses by local residents 

• [Alaska Maritime] to provide, in a manner consistent with the purposes set forth 

above, a program of national and international scientific research on marine 

resources 

• to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth above, water quality and necessary water quantity within the 

refuge 

[Supplemental Purposes of the Becharof Wilderness Area] The Wilderness Act of 1964 

(16 U.S.C. 1131-1136 § 2a), defines supplemental purposes of all designated wilderness 

areas. These apply to the Becharof Wilderness Area and are as follows: 

• to administer the wilderness for the use and enjoyment of the American people in 

such a manner as will leave it unimpaired for future use and enjoyment as 

wilderness, to provide for the protection of the area, for the preservation of its 

wilderness character, and for gathering and dissemination of information 

regarding its use and enjoyment as wilderness. 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network 

of lands and waters for the conservation, management, and, where appropriate, 

restoration of the fish, wildlife, and plant resources and their habitats within the United 

States for the benefit of present and future generations of Americans” (National Wildlife 

Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd-668ee]).

Description of Use(s) 

Rivers flowing into Bristol Bay, including several rivers flowing through the Refuges and 

their tributaries, are world-renowned for their recreational fishing opportunities. 

Commercially guided fishing services for the five species of Pacific salmon native to 

Alaska, rainbow trout, lake trout, Arctic grayling, Arctic char, Dolly Varden, burbot, and 

northern pike predate refuge establishment and have been operating on the Refuges 

since their establishment in 1980. Several other commercial uses conducted concurrently 

and incidentally to guided recreational fishing activities are routinely authorized; these 

include wildlife photography, guided small-game and waterfowl hunting, hiking, river 

floating, and other ecotourism-type activities. 

Although the number of commercially guided fishing businesses authorized to operate on 

the Refuges has not been limited, the number of permitted businesses that have run trips 

remained fairly steady throughout the 1990s and up to 2004, ranging from 21 to 27. In 

2004, there were 26 permitted recreational fishing guides. Four businesses were 

responsible for just more than half of the trips during that period. Some fishing guides 

use air taxis to fly in clients (about 8 percent of air taxi trips to the Refuges from 1988 

through 1997 were transporting guided fishing clients). 

One of the characteristics that guides are required to report—rod hours fished (number 

of people multiplied by the number of hours actually spent fishing)—did not exhibit a 
Appendix H: Compatibility Determinations: Commercially Guided Recreational Fishing Services 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-27 

trend from 1993 through 1997. The number of rod hours ranged from about 12,000 in 

1993 to more than 10,000 in 1997, with a low of around 7,200 in 1996 and a high of 

approximately 16,000 in 1994. 

Guided clients caught more char than any other species on the Refuges, consistently 

ranging from 6,000 to 7,500 fish per year in 1993 through 1997. The other dominant 

species caught was coho salmon. The peak annual catch (fish landed) was 5,000 silver 

salmon in 1994, with 1,200 fish kept (harvested). More cohos, ranging from nearly 1,200 in 

1994 to more than 400 in 1997, were kept than was the case with any other species. Arctic 

char was the only other species anglers tended to keep in any number. 

Over the seven-year period from 1993 through 1999, the nine most popular fishing areas 

were the King Salmon River (366 trips), Egegik River (208 trips), Gertrude Creek (150 

trips), Ruth River (122 trips), and Featherly Creek (119 trips) on the Becharof Refuge 

and Ugashik Narrows (320 trips), the Nakalilok Bay area (277 trips), Painter Creek (266 

trips), and the Yantarni Strip area (190 trips) on the Alaska Peninsula Refuge. The 

Yantarni and Nakalilok Bay areas, located on the Pacific coast, are each used primarily 

by one guide business, while the other areas are used by many guides as well as by airtaxi operators and local villagers (whose use is not included here). 

The top four streams on the Refuges show somewhat different trends in guided use from 

1993 through 1999. Guided use at Nakalilok Bay appears to be decreasing, levels on the 

King Salmon River and Painter Creek are steady, while use at Ugashik Narrows has 

shown an upward trend since 1995. 

This compatibility determination addresses the full spectrum of uses associated with the 

overall activity of commercially guided recreational fishing, including all means of access, 

lodging and facilities and other elements identified in the guides’ operations plans. Means 

of authorized access include fixed-wing aircraft, motor boats, nonpowered boats, off-road 

vehicles (only on designated trails within the Yantarni Moderate Management Area), and 

on foot. One guide in recent years has used a commercial helicopter transporter to deliver 

his clients to areas just outside refuge boundaries or to state-owned lands within the 

refuges; the clients then access nearby refuge streams by foot. Note that this 

compatibility determination does not address helicopter access. A separate compatibility 

determination covering commercial helicopter operations would be necessary before that 

use could be authorized. Two guides have authorized base camps on the Refuges. These 

lodging facilities consist of weatherports, tents with and without platforms, and 

equipment/food caches. Currently all authorized use is for day use only. 

This is an existing commercial activity that supports a wildlife-dependent priority public 

use. 

Availability of Resources 

Adequate refuge personnel and base operational funds are available to manage guided 

recreational fishing activities at current and projected levels. Approximately $20,000–

$25,000 in visitor use fees over and above base operational funds collected annually are 

returned to the refuge to use to manage commercial recreational activities. 

Administrative time (20–25 staff days) primarily involves issuing permits, ensuring that 

licenses and certifications are current, collecting client use-day fees, and entering activity 

information into a database for analysis. Field work associated with administering the 
Appendix H: Compatibility Determinations: Commercially Guided Recreational Fishing Services 

H-28 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

program primarily involves monitoring the permittees’ compliance with the terms of the 

permits. 

Anticipated Impacts of the Use(s) 

Impacts to fish and wildlife resources, other refuge resources, other refuge users, and 

wilderness values from commercially guided recreational fishing services (at existing 

levels) are generally minimal for the majority of refuge areas. This minimal impact is due 

to the Refuge’s administrative oversight, comprehensive state and federal regulations 

that continually evolve to respond to fishery resource management needs, and combined 

law-enforcement efforts of state and refuge personnel. Potential impacts to refuge 

resources or other refuge users are, however, somewhat greater at several of the more 

popular areas such as Ugashik Narrows and the Egegik River at Becharof Lake outlet. 

Both the Federal Subsistence Board and Alaska Board of Fisheries regularly adopt 

regulations in response to fish population levels and management needs to maintain fish 

populations and the opportunity for continued subsistence uses of these species by local 

residents. Regulations have been implemented in recent years to address resource 

concerns at specific locations, including Ugashik Narrows and Egegik River. The 

Refuges and King Salmon Fishery Resources Office have conducted creel surveys and 

established public use–monitoring camps at both of these locations to collect information 

on the amount of fishing pressure at these locations by guided and nonguided anglers. 

The estimated guided recreational fishing pressure and harvest of the fishery resources 

appears to be well within acceptable limits. Past impact evaluations have focused on 

impacts to the brown bear population, Arctic grayling in the Ugashik Lakes and Becharof 

Lake systems, and rainbow trout in the King Salmon River system (Becharof Refuge). 

For brown bear, there have been no documented instances of bear mortalities in defense 

of life or property (DLP) by recreational anglers on the Refuges. Displacement of bears 

from favored feeding streams was demonstrated to be within acceptable limits. Recent 

studies of rainbow trout show that this population is healthy and has not been adversely 

affected by current levels of fishing pressure. The depressed Arctic grayling population 

in the Ugashik system has been shown to be recovering under restrictive regulations 

established by the Board of Fisheries to address the problem. 

Refuge officers and state Bureau of Wildlife Protection State Troopers routinely patrol 

the Refuges to monitor compliance with state regulations and permit conditions. 

Because the vast majority of the commercial guides access the Refuges by landing on 

lakes and rivers with float-equipped aircraft, impacts on refuge habitat are minimized. A 

potential impact or threat associated with floatplane access is the introduction of invasive 

species carried in on the aircraft floats, although that is not known to have occurred on 

the Alaska Peninsula. Less frequently, recreational fishing guides access fishing areas on 

the Refuges by using wheeled planes to land on existing, un-maintained landing strips, 

gravel bars, and unvegetated sand or cinder blows. Rarely, landings are made on 

vegetated lowland tundra, usually with Piper Super Cubs or other small, light aircraft 

equipped with tundra tires. Disturbance to vegetation is minimal and short-term unless 

numerous landings are made repeatedly in exactly the same location (this practice has 

not been observed). Temporary displacement and/or disturbance to wildlife can occur 
Appendix H: Compatibility Determinations: Commercially Guided Recreational Fishing Services 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-29 

during take-offs and approaches to landings. There are no known long-term impacts to 

refuge wildlife populations from this disturbance. 

The use of off-road vehicles (for other than subsistence purposes) by recreational fishing 

guides and their clients, as well as all for other nonsubsistence related activities, is 

prohibited on the refuge except on three designated trails in the Yantarni Moderate 

Management Area. Only one recreational fishing guide is authorized to establish a base 

camp in the Yantarni area. He uses off-road vehicles, principally on the airstrip and the 

one-half mile trail from the air strip to the beach to transport clients to several nearby 

fishing streams. The beach (below mean high tide) is state-owned and not subject to 

refuge regulations. Because the trails are located on existing gravel roads and on the 

airstrip (with the exception of a short stretch where the airstrip has been eroded away by 

a change in course of a nearby stream), there is little potential for soil and other resource 

damage with the current type and level of off-road vehicle use. 

Commercial recreational fishing guide operations occur at very low levels and only on a 

day-use basis within the designated Becharof Wilderness Area. All restrictions of the 

Wilderness Act (with ANILCA provisions) for the general public also apply to 

commercial guiding operations. Primary streams used within the designated Becharof 

Wilderness Area include portions of upper Gertrude Creek, Bible Creek, Becharof 

Creek, and Teresa Creek. The current low and projected number of clients and trips 

made to these areas should not significantly affect solitude and other wilderness values. 

Public Review and Comment 

The public was invited to comment on this compatibility determination and a number of 

other determinations during the public review period establised for the draft revised 

Comprehensive Conservation Plan. Public notice of the availability of the draft 

conservation plan and draft determinations was published in the Federal Register. The 

draft determinations were also posted on the Region 7 Refuge Conservation Planning 

and Policy Web pages. No substantive public comments pertaining to this determination 

were received. Where appropriate, comments addressing elements of the draft 

Comprehensive Conservation Plan revision that pertained to the specific uses evaluated 

in this determination were considered in preparing the final compatibility determination. 

Determination 

 Use is Not Compatible 

 X Use is Compatible 

Stipulations Necessary to Ensure Compatibility 

Management direction provided in the revised comprehensive conservation plan for the 

Refuges includes implementation of applicable sections of the Refuges’ fishery 

management plan. Adequate monitoring of commercial recreational fishing guide 

activities and other associated public-use activities will be conducted to provide 

information for determining what additional management actions, if any, are needed to 

ensure all commercial recreational fishing guide activities remain compatible with refuge 

purposes. 
Appendix H: Compatibility Determinations: Commercially Guided Recreational Fishing Services 

H-30 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

The following stipulations apply to special-use permits issued for commercially guided 

recreational fishing services. Continuing law enforcement and administrative monitoring 

of permittees will be carried out to ensure compliance with the following conditions that 

are incorporated into all permits in order to minimize impacts on refuge lands and 

resources. 

• Failure to abide by any part of this special-use permit; violation of any refugerelated provision in Titles 43 (Part 36) or 50 (sub-chapters B and C) of the Code of 

Federal Regulations; or violation of any pertinent state regulation (e.g., fish or 

game violation) will, with due process, be considered grounds for immediate 

revocation of this permit and could result in denial of future permit requests for 

lands administered by the U.S. Fish and Wildlife Service. This provision applies 

to all persons working under the authority of this permit (e.g., assistants). 

Appeals of decisions relative to permits are handled in accordance with Title 50 

Code of Federal Regulations, Part 36.41. 

• A copy of this permit must be in the permittee’s possession at all times while 

exercising the privileges of this permit. 

• The permittee is responsible for ensuring that all employees, party members, 

aircraft pilots, and any other persons working for the permittee and conducting 

activities allowed by this permit are familiar with and adhere to the conditions of 

this permit. 

• Any problem with wildlife and/or animals taken in defense of life or property 

must be reported immediately to the refuge manager and to the Alaska 

Department of Fish and Game; animals taken in defense of life or property must 

be salvaged in accordance with state regulations. 

• The use of Native or state lands that have been conveyed (patented) is not 

authorized by this permit. 

• The permittee and permittee’s clients do not have the exclusive use of the site(s) 

or lands covered by this permit, except for authorized camp facilities. 

• This permit may be canceled or revised at any time by the refuge manager in case 

of emergency (e.g., high fire danger, flooding, unusual resource problems). 

• The permittee shall notify the refuge manager during refuge working hours in 

person or by telephone before beginning and upon completion of activities allowed 

by this permit. 

• Prior to beginning any activities allowed by this permit, the permittee shall 

provide the refuge manager with the following: (1) proof of appropriate 

comprehensive general liability ($300,000 each occurrence, $500,000 aggregate), 

marine liability, and/or aviation passenger liability insurance covering all aspects 

of operations throughout the annual use period; (2) aircraft and other vehicle 

types to be used, with identification information, if different from the operational 

plan; (3) changes in names of assistant guides and other employees; and (4) any 

other changes in information provided in the operational plan. 

• The permittee is responsible for accurate record-keeping and will provide the 

refuge manager with a comprehensive summary report of the number of clients, 

and number of client days per activity type by December 31 for all uses during 

that calendar year, unless stated otherwise in the permit. 
Appendix H: Compatibility Determinations: Commercially Guided Recreational Fishing Services 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-31 

• Failure to report the actual number of client-use days per type of authorized 

activity by December 31 of the permit calendar year and to pay the Service’s 

established fees (client-use day and reserved land site) within 30 days after 

receiving a bill for collection will be grounds for denial of future permits. 

• In accordance with the Archaeological Resources Protection Act (16 USC 470aa), 

the excavation, disturbance, collection, or purchase of historical, recent, 

ethnological, or archaeological specimens or artifacts is prohibited. 

• Permittees shall maintain their use areas in a neat and sanitary condition. Per 

Alaska Department of Environmental Conservation Code 18 AAC 72.021(e),(h), 

latrines, seepage pits, etc., must be located at least 150 feet, measured 

horizontally, from the nearest edge of the mean annual high water level of lakes, 

rivers, streams, springs, sloughs, or mean higher high water level of coastal 

waters. No privies are to be installed in areas subject (no less than 4 feet to 

maximum water table elevation) to flooding. All property of the permittee (except 

authorized cabins and/or tent frames) must be removed from refuge lands upon 

completion of permitted activities. 

• All noncombustible waste materials must be removed from the refuge (not 

buried) upon the permittee’s and/or clients’ departure. The permittee is 

responsible for removal of clients’ garbage. 

• The construction or clearing of landing strips or pads is prohibited. Incidental 

hand removal of rocks and other minor obstructions may be permitted. 

• The use of off-road vehicles (except snowmachines) , for other than subsistence 

purposes, is prohibited unless specifically authorized in writing in this permit. 

• The operation of aircraft at altitudes and in flight paths resulting in the herding, 

harassment, hazing, or driving of wildlife is prohibited. It is recommended that all 

aircraft, except for take-off and landing, maintain a minimum altitude of 2,000 feet 

above ground level. 

• The use of helicopters is prohibited unless specifically authorized in writing in this 

permit. 

• Fuel caches are allowed only in areas designated in permittee’s operational plan. 

Containers shall be properly stored and marked with the owner’s name, address, 

and type of fuel. 

• Construction of cabins or other permanent structures is prohibited. 

• All aircraft being used in a commercial guiding operation must have 12" 

identification numbers in contrasting colors that are readily visible. 

• Motorboat operators must possess a U.S. Coast Guard (USCG) license for all 

passenger carrying operations, if required by USCG regulations. 

• Any action by a permittee or the permittee’s employees that unduly interferes 

with or harasses other refuge visitors or impedes access to any site is strictly 

prohibited. Examples of prohibited acts include flights over camps or persons at 

less than 500 feet (unless landing) and parking aircraft or placing other objects 

(rocks, tents, etc.) on any landable area in a manner that restricts use by other 

aircraft or persons. 

• This permit authorizes use of the Native selected lands identified in the 

description block of this permit. If any of these Native selected lands are 
Appendix H: Compatibility Determinations: Commercially Guided Recreational Fishing Services 

H-32 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

conveyed during the term of this permit, the permittee will no longer be 

authorized to use those lands. The permittee must negotiate with the new Native 

corporate landowner for continued rights to use the land 

• The permittee’s operation plan, as amended and accepted by the U.S. Fish and 

Wildlife Service, is hereby incorporated in its entirety as a special condition. All

deviations from the operations plan must receive prior written approval by the 

refuge manager or his designee. 

This use supports the System Mission by enabling recreational anglers to utilize refuge 

resources. It provides a safer experience for anglers then they would have accessing the 

refuge on their own. It does not have serious impacts on other users or on refuge 

resources. 

Justification 

Commercially guided recreational fishing service is a form of traditional activity that 

Congress intended to preserve with the enactment of ANILCA, which established the 

refuges. This service supports not only fishing, but also other activities, including wildlife 

observation and photography, which the National Wildlife Refuge System Administration 

Act (as amended) identifies as priority public uses. Recreational fishing guide operations 

on the Refuges provide the public with safe recreational fishing opportunities of a quality 

found few other places in the world. These visitor services are a valuable benefit to a 

segment of the public that is either not physically able to, not comfortable with, or for 

other reasons chooses not to participate in unguided fishing trips in the extremely remote 

and harsh wilderness environment of these Refuges. After fully considering the impacts 

of this activity as described in the “Anticipated Impacts” section of this compatibility 

determination, it is my determination that commercially guided fishing activities on the 

Refuges contribute to the achievement of the purposes of the Refuges or the mission of 

the National Wildlife Refuge System. 

Mandatory 10-Year Re-Evaluation Date (provide month and year for allowed uses only): January 2015 

Mandatory 15-Year Re-Evaluation Date (for priority public uses): NA 

NEPA Compliance for Refuge Use Decision 

 Categorical Exclusion without Environmental Action Memorandum 

 Categorical Exclusions and Environmental Action Memorandum 

 Environmental Assessment and Finding of No Significant Impact 

 X Environmental Impact Statement and Record of Decision 
Appendix H: Compatibility Determinations: Commercially Guided Recreational Fishing Services 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-33 

Supporting Documents 

• USFWS. 1994. Decision Notice and Finding of No Significant Impact, Alaska 

Peninsula/Becharof National Wildlife Refuge Complex Public Use Management 

Plan. U.S. Fish and Wildlife Service. May 12, 1994. Anchorage, Alaska: U.S. Fish 

& Wildlife Service. 

• USFWS. 1994. Final Alaska Peninsula/Becharof National Wildlife Refuge 

Complex Public Use Management Plan. Anchorage, Alaska: U.S. Fish and 

Wildlife Service. March 1, 1994. 

• USFWS. 1994. Compatibility Determination, Final Public Use Management Plan, 

Alaska Peninsula/Becharof National Wildlife Refuge Complex. Anchorage, 

Alaska: U.S. Fish and Wildlife Service. May 16, 1994. 

• USFWS. 1994. Compatibility Determination, Guided Sport Fishing, Alaska 

Peninsula/Becharof National Wildlife Refuge Complex. Anchorage, Alaska: U.S. 

Fish and Wildlife Service. June 10, 1994. 

• USFWS. 2004. Draft Revised Comprehensive Conservation Plan and 

Environmental Impact Statement: Alaska Peninsula and Becharof National 

Wildlife Refuges. Anchorage, Alaska: U.S. Fish & Wildlife Service, Region 7, 

Division of Refuge Conservation Planning and Policy. 

• USFWS. 1994. Fishery Management Plan for Alaska Peninsula and Becharof 

National Wildlife Refuges: Fiscal Years 1994–1998” King Salmon, Alaska: U.S. 

Fish & Wildlife Service, Fishery Resource Office. May 1, 1994. 

• USFWS. 1994 Final Fishery Management Plan, Alaska Peninsula Becharof 

National Wildlife Refuges. U.S. Fish & Wildlife Service, Region 7, Alaska. 

• Medeiros, A., and J. Larson. 1996. Estimates of Angling Effort, Catch, Harvest, 

and Population Structure of Coho Salmon Caught and Harvested by Sport and 

Subsistence Fisheries at the Outlet of Becharof Lake, Becharof National Wildlife 

Refuge, Alaska, 1994 and 1995. U.S. Fish & Wildlife Service, Region 7, Fishery 

Resources. (Alaska Fisheries Data Series Number 96-2) 

• Adams, F.J. 1999. Status of Rainbow Trout in Tributaries of the Upper King 

Salmon River, Becharof National Wildlife Refuge, Alaska, 1990–92. King Salmon, 

Alaska: U.S. Fish & Wildlife Service, King Salmon Fishery Resource Office. 

(Alaska Fisheries Technical Report Number 53) 

• Adams, F.J., and M. Edwards. (2005: in process). Status of Arctic Grayling and 

Dolly Varden Char and the Fishery in Featherly Creek, Becharof National 

Wildlife Refuge, Alaska, 1994–96. King Salmon, Alaska: U.S. Fish & Wildlife 

Service, King Salmon Fishery Resource Office. 

• Villegas, S.V. 1993. “Arctic Grayling in the Ugashik Drainage.” M.S. Thesis. 

University of Arizona, Graduate College. 

• Eaton, D.M. 1993. “Ecology of Arctic Grayling in Becharof Lake tributaries.” 

M.S. Thesis. University of Arizona, Graduate College. 

Appendix H: Compatibility Determinations: Commercially Guided Big-Game Hunting Services 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-35 

COMPATIBILITY DETERMINATION 

Use: Commercially Guided Big-Game Hunting Services

Refuge Name: Alaska Peninsula and Becharof National Wildlife Refuges, King Salmon, Alaska 

Establishing and Acquisition Authority(ies) 

In 1978, President Jimmy Carter established the 1,157,000-acre Becharof National 

Wildlife Monument with Presidential Proclamation 4613. The monument was established 

from lands in the public domain to protect the area, notably the unique brown bear 

denning islands in the Island Arm area of Becharof Lake. 

In 1980, the Alaska National Interest Lands Conservation Act (ANILCA) (§ 302) 

established the Alaska Peninsula National Wildlife Refuge and changed the Becharof 

National Wildlife Monument into a national wildlife refuge as part of the National 

Wildlife Refuge System. ANILCA (§ 303[1]) created the Alaska Maritime National 

Wildlife Refuge by redesignating 11 pre-existing refuges as units of the new refuge and 

by adding other public lands on islands, islets, rocks, reefs, spires, and designated capes 

and headlands in the coastal areas and adjacent seas of Alaska. 

In 1983, the U.S. Fish and Wildlife Service (Service) decided to manage the Ugashik and 

Chignik units of Alaska Peninsula Refuge, the 9,900-acre Seal Cape area of Alaska 

Maritime Refuge, and Becharof Refuge as a “complex” because they shared resources 

and resource issues. Distance and weather create barriers to managing the Pavlof and 

North Creek units from the King Salmon office, and management of these unit was 

shifted to the Izembek Refuge headquartered in Cold Bay. 

The Becharof Wilderness Area of the Becharof Refuge was designated in 1980 by 

ANILCA (§ 702 [4]). 

Refuge Purpose(s) 

ANILCA sets out the purposes for each refuge in Alaska. The purposes of the Alaska 

Peninsula and Becharof National Wildlife Refuges are described in Section 302(1)(B) and 

Section 302(2)(B). Purposes for the Alaska Maritime National Wildlife Refuge are 

described in Section 303(1)(B). The purposes identify the reasons why Congress 

established the Refuges and management priorities. 

The ANILCA purposes are follows (unless otherwise noted, the purposes apply to all 

units of the Refuges): 

• to conserve fish and wildlife populations and habitats in their natural diversity 

including, but not limited to . . . 

[Becharof] . . . brown bears, salmon, migratory birds, the Alaska Peninsula 

Caribou herd, and marine birds and mammals 

[Alaska Peninsula] . . . brown bears, the Alaska Peninsula caribou herd, moose, 

sea otters and other marine mammals, shorebirds and other migratory birds, 

raptors, including bald eagles and peregrine falcons, and salmonids and other fish 

[Alaska Maritime] . . . marine mammals, marine birds and other migratory birds, 

the marine resources upon which they rely, bears, caribou and other mammals 
Appendix H: Compatibility Determinations: Commercially Guided Big-Game Hunting Services 

H-36 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

• to fulfill the international treaty obligations of the United States with respect to 

fish and wildlife and their habitats 

• to provide, in a manner consistent with the purposes set forth above, the 

opportunity for continued subsistence uses by local residents 

• [Alaska Maritime] to provide, in a manner consistent with the purposes set forth 

above, a program of national and international scientific research on marine 

resources 

• to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth above, water quality and necessary water quantity within the 

refuge 

[Supplemental Purposes of the Becharof Wilderness Area] The Wilderness Act of 1964 

(16 U.S.C. 1131-1136 § 2a), defines supplemental purposes of all designated wilderness 

areas. These apply to the Becharof Wilderness Area and are as follows: 

• to administer the wilderness for the use and enjoyment of the American people in 

such a manner as will leave it unimpaired for future use and enjoyment as 

wilderness, to provide for the protection of the area, for the preservation of its 

wilderness character, and for gathering and dissemination of information 

regarding its use and enjoyment as wilderness. 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network 

of lands and waters for the conservation, management, and, where appropriate, 

restoration of the fish, wildlife, and plant resources and their habitats within the United 

States for the benefit of present and future generations of Americans” (National Wildlife 

Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd-668ee]).

Description of Use(s) 

The Alaska Peninsula is world-renowned for its big-game hunting opportunities. 

Commercial guiding services for hunting caribou, moose, and brown bear have operated 

on the Refuges since their establishment in 1980. Caribou hunting by nonlocal users was 

closed by the Federal Subsistence Board in 1999 following changes in state game 

regulations. Because of a decline of the Northern Alaska Peninsula Caribou Herd, the 

Alaska Board of Game adopted a Tier II subsistence hunt for Game Management Unit 

9E and the southern portion of Game Management Unit 9C. These areas include all 

Refuges lands. Therefore, hunting of big-game species by guided clients is currently 

limited to brown bear and moose, with incidental take of wolves and wolverine. The range 

of annual harvest by guided clients from 1993 through 2003 was moose (19–43), caribou 

(10–66, 1993–1998), brown bear (27–65 ), wolves (0–3), and wolverine (0–1). Several other 

commercial uses conducted concurrently with and incidentally to big-game guiding 

activities are routinely authorized. These include wildlife photography, guided smallgame and waterfowl hunting, hiking, river floating, and other ecotourism-type activities. 

Big-game guides are competitively selected to operate on refuge lands through a formal 

process, established by regional policy in 1992, to limit or manage commercial guiding 

activities at a level compatible with refuge purposes and to ensure that high-quality 

guiding services are available to the public. There are 21 established big-game guide-use 
Appendix H: Compatibility Determinations: Commercially Guided Big-Game Hunting Services 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-37 

areas on the Refuges. Most of the use areas are designated as sole-use areas and are 

limited to one authorized guide. However, several are designated as joint-use areas and 

have two authorized guides operating in them. Individual guides are limited to having 

special-use permits for three use areas on refuge lands in Alaska at any one time. As of 

January 2005, there are 16 guides operating on the Refuges. 

Guides must be qualified and licensed by the state and are required to follow written 

operations plans, which are evaluated by Service personnel during the competitiveselection process. These operations plans include the following: 1) dates of field 

operations; 2) species to be hunted; 3) maximum and expected number of clients for each 

species hunted; 4) number and type of existing or new camps (i.e., tent, tent platform or 

frame, cabin, boat) including other needed facilities such as caches and weatherports; 5) 

access points and mode(s) of transportation (e.g., airplanes, boats, snowmachines, pack 

animals, and other nonmotorized means); 6) fuel storage needs; and 7) services provided 

by others (e.g., contracts for transportation, food services). 

This compatibility determination addresses the full spectrum of uses associated with the 

overall activity of commercially guided hunting of big game, including all means of access, 

lodging and facilities, and other elements identified in the guides’ operations plans. 

Authorized modes of access for all areas on the Refuges include fixed-wing aircraft, 

motor boats, snowmachines, nonpowered boats, dogsled, foot, snowshoe, and crosscountry ski. Lodging and facilities include tents, tent frames, tent platforms, 

weatherports, existing cabins, and caches. The use of off-road vehicles (for other than 

subsistence purposes) by big-game hunting guides and their clients is prohibited on the 

Refuges except on three trails within the designated Yantarni Moderate Management 

Area. The currently permitted guide operating in the Yantarni Moderate Management 

area does not use off-road vehicles because his authorized operations plan does not 

include them. There are currently 18 cabins on the Refuges that are authorized for use in 

conjunction with big-game guiding operations. All of these cabins were existing when the 

Refuges were established and are allowed to remain in accordance with the intent of 

ANILCA, Section 1303(b). There are also 19 authorized reserved land sites for 

temporary facilities such as tent platforms and weatherports. 

This is an existing activity that supports wildlife-dependent priority public uses. 

Activities would occur throughout the refuges during state regulated hunting seasons. 

Availability of Resources 

Adequate refuge personnel and base operational funds are available to manage guided 

big-game hunting activities at existing and projected levels. Approximately $20,000–

25,000 in visitor use fees over and above base operational funds are collected annually and 

are returned to the refuge to use to manage commercial recreation activities. 

Administrative time (15–20 staff days) primarily involves issuing permits, ensuring that 

licenses and certifications are current, collecting client use-day fees, and entering activity 

information into a database for analysis. Field work associated with administering the 

program primarily involves monitoring the permittees’ compliance with the terms of the 

permits. 
Appendix H: Compatibility Determinations: Commercially Guided Big-Game Hunting Services 

H-38 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

Anticipated Impacts of the Use(s) 

Because of the Refuges’ administrative oversight of the activity, comprehensive state and 

federal regulations that continually evolve to respond to fisheries and wildlife 

management needs, and combined law-enforcement efforts of state and refuge personnel, 

existing and projected levels of commercially guided big-game guiding services should 

have minimal impacts on fish and wildlife resources, other refuge resources, other refuge 

users, and wilderness values, as discussed subsequently. 

A competitive scoring process is used to select big-game guide permittees. Three of the 

criteria used to evaluate applications address minimizing impacts to refuge resources. 

These include impacts on wildlife resources; on other refuge resources such as water 

quality, soil, and vegetation; and on other refuge users, especially subsistence users. The 

criteria address such factors as target species, number of clients, transportation modes, 

number of aircraft and amount of aircraft use, fuel storage, garbage and human waste 

management, type and location of lodging, and access points. These criteria, used to rank 

or score applicants, provide a strong incentive to maintain a low-impact guiding service. 

Permit conditions and stipulations (noted in a following section) contribute to minimizing 

potential impacts. 

Commercial big-game guiding operations may, in some cases, result in some competition 

for limited numbers of game animals or for preferred campsites or in interference with 

subsistence users and/or other unguided recreational hunters. However, both the 

Federal Subsistence Board and Alaska Board of Game regularly adopt regulations in 

response to big-game population levels and management needs to reduce impacts to biggame populations and to the opportunity for continued subsistence uses of these species 

by local residents. 

Refuge officers and state Bureau of Wildlife Protection State Troopers routinely patrol 

the Refuges during the relatively short big-game hunting seasons. Compliance with 

regulations and permit conditions by guides is excellent because of the combination of 

being routinely checked by officers and of potential negative impacts of a citation. 

Although a guide could lose his permit immediately due to a citation for a severe 

infraction, any citation would be a negative factor during the next competitive selection 

process. 

Because the majority of the guides access the Refuges by landing on lakes and rivers 

with float-equipped aircraft, impacts on refuge habitat are minimized. A potential impact 

or threat associated with floatplane access is the introduction of invasive species carried 

in on the aircraft floats, although that is not known to have occurred on the Alaska 

Peninsula to date. Most wheeled-plane landings occur on existing unmaintained landing 

strips, gravel bars, and unvegetated sand or cinder blows. Some landings are made on 

vegetated lowland tundra or ridge tops, usually with Piper Super Cubs or other small, 

light aircraft equipped with tundra tires. Disturbance to vegetation is minimal and shortterm unless numerous landings are made repeatedly in exactly the same location (this 

practice has not been observed to date). Temporary displacement and/or disturbance to 

wildlife can occur during take-offs and approaches to landings. There are no known longterm impacts to refuge wildlife populations from this disturbance. 
Appendix H: Compatibility Determinations: Commercially Guided Big-Game Hunting Services 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-39 

The 18 authorized, pre-ANILCA cabins associated with guiding activities are managed 

under separate special-use permits, in accordance with established regional policy and 

regulations, to ensure impacts are minimized. In accordance with regulations, no new 

cabins will be authorized in the future. Therefore, there may be a reduction in authorized 

cabins and associated impacts in the near future depending on how many of the current 

guides who have permitted cabins are selected during the next competitive selection 

cycle. 

Only three commercial guiding operations occur within the designated Becharof 

Wilderness Area. All restrictions and provisions of the Wilderness Act (with ANILCA 

exceptions) for the general public also apply to commercial guiding operations. Due to the 

limited number of authorized clients and the low-impact nature of these guides=

operations plans with respect to their temporary facilities and access methods, solitude 

and other wilderness values are not compromised. 

Commercial big-game guiding activities on the Refuges do not materially interfere with 

or detract from the purposes of the Refuges or the mission of the National Wildlife 

Refuge System. 

Public Review and Comment 

The public was invited to comment on this compatibility determination and a number of 

other determinations during the public review period establised for the draft revised 

Comprehensive Conservation Plan. Public notice of the availability of the draft 

conservation plan and draft determinations was published in the Federal Register. The 

draft determinations were also posted on the Region 7 Refuge Conservation Planning 

and Policy Web pages. No substantive public comments pertaining to this determination 

were received. Where appropriate, comments addressing elements of the draft 

Comprehensive Conservation Plan revision that pertained to the specific uses evaluated 

in this determination were considered in preparing the final compatibility determination. 

Determination 

 Use is Not Compatible 

 X Use is Compatible 

Stipulations Necessary to Ensure Compatibility 

As directed in the Refuges’ revised Comprehensive Conservation Plan and wildlife 

inventory plan, adequate monitoring of commercial big-game guided hunting activities 

(and other public-use activities) will be conducted. Findings from these monitoring efforts 

will be used to determine what additional management actions, if any, are needed to 

ensure all commercial big-game guided hunting activities remain compatible with 

Refuges purposes. 

The Refuges recently completed the selection process for guides authorized to operate on 

the Refuges for the period of January 1, 2004, through December 31, 2008. During this 

selection process, all elements of the proposed operations plans, (e.g., access, use of 

cabins and other facilities, fuel storage) were carefully considered by the selection panel 
Appendix H: Compatibility Determinations: Commercially Guided Big-Game Hunting Services 

H-40 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

to ensure that future commercial guiding operations remain compatible with Refuges 

purposes. 

To minimize impacts on refuge lands and resources, law-enforcement and administrative 

monitoring of permittees will be continued to ensure compliance with the following 

conditions, which are incorporated into all commercial big-game guiding special-permits: 

• Failure to abide by any part of this special-use permit; violation of any refugerelated provision in Titles 43 (Part 36) or 50 (sub-chapters B and C) Code of 

Federal Regulations; or violation of any pertinent state regulation (e.g., fish or 

game violation) will, with due process, be considered grounds for immediate 

revocation of this permit and could result in denial of future permit requests for 

lands administered by the U.S. Fish and Wildlife Service. This provision applies 

to all persons working under the authority of this permit (e.g., assistants). 

Appeals of decisions relative to permits are handled in accordance with Title 50 

Code of Federal Regulations Part 36.41. 

• State regulations regarding season, method of take, and limits apply. 

• The permittee is responsible for ensuring that all employees, party members, 

aircraft pilots, and any other persons working for the permittee and conducting 

activities allowed by this permit are familiar with and adhere to the conditions of 

this permit. 

• The permittee may not sublet any part of the authorized use area and is 

prohibited from subcontracting clients with any other guide. 

• Any problem with wildlife and/or animals taken in defense of life or property 

must be reported immediately to the refuge manager and the Alaska Department 

of Fish and Game; animals taken in defense of life or property must be salvaged 

in accordance with state regulations. 

• The permittee and permittee’s clients do not have the exclusive use of the site(s) 

or lands covered by this permit, except for authorized camp facilities. 

• This permit may be canceled or revised at any time by the refuge manager in case 

of emergency (e.g., high fire danger, flooding, unusual resource problems). 

• The permittee shall notify the refuge manager during refuge working hours in 

person or by telephone before beginning and upon completion of annual activities 

allowed by this permit. 

• Prior to beginning any activities allowed by this permit, the permittee shall 

provide the refuge manager with the following: (1) proof of appropriate 

comprehensive general liability ($300,000 each occurrence, $500,000 aggregate), 

marine liability, and/or aviation passenger liability insurance covering all aspects 

of operations throughout the annual use period; (2) aircraft and other vehicle 

types to be used, with identification information, if different from the original 

permit or previous year; (3) changes in names of assistant guides and other 

employees; and (4) any other changes in information provided in the original 

permit or proposed operations plan. 

• The permittee is responsible for accurate record-keeping and will provide the 

refuge manager, by December 31, with a comprehensive summary report of the 

number of clients and number of client days per activity type for all uses during 

that calendar year, unless stated otherwise in the permit. A legible copy of the 
Appendix H: Compatibility Determinations: Commercially Guided Big-Game Hunting Services 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-41 

state’s “Hunt Record” for each client will be required in addition to the summary 

report. 

• Failure to report the actual number of client-use days per type of authorized 

activity by December 31 of each calendar year and to annually pay the Service’s 

established fees (client-use day and reserved-land site) within 30 days after 

receiving a bill for collection will be grounds for revocation of this permit. 

• The permittee will not be required to provide a letter of concurrence from the 

State of Alaska before the use of state-selected lands can be authorized. However, 

if any of these selected lands are conveyed to the state during the term of the 

permit, the permittee will be required to obtain permission from the state’s 

Department of Natural Resources to continue operating on state land. 

• In accordance with the Archaeological Resources Protection Act (16 U.S.C. 

470aa), the removal or disturbance of archaeological or historic artifacts is 

prohibited. The excavation, disturbance, collection, or purchase of historical or 

archaeological specimens or artifacts on refuge lands is prohibited. 

• Permittees shall maintain their use areas in a neat and sanitary condition. To 

comply with Alaska Department of Environmental Conservation Code 18 AAC 

(§72.021[e],[h]), latrines, seepage pits, etc., must be located at least 150 feet, 

(measured horizontally), from the nearest edge of the mean annual high-water 

level of lakes, rivers, streams, springs, sloughs, or mean higher high water level of 

coastal waters. No privies are to be installed in areas subject to flooding (no less 

than 4 feet to maximum water table elevation). All property of the permittee 

(except authorized cabins and/or tent frames) must be removed from refuge lands 

upon completion of permitted activities. 

• The construction or clearing of landing strips or pads is prohibited. Incidental 

hand removal of rocks and other minor obstructions may be permitted. 

• The use of off-road vehicles (except snowmachines), for other than subsistence 

purposes, is prohibited unless specifically authorized in writing in this permit. 

• The operation of aircraft at altitudes and in flight paths resulting in the herding, 

harassment, hazing, or driving of wildlife is prohibited. It is recommended that all 

aircraft, except for take off and landing, maintain a minimum altitude of 2,000 feet 

above ground level. 

• All aircraft being used in a commercial guiding operation must have 12-inch 

identification numbers in contrasting colors that are readily visible. 

• Motorboat operators must possess a U.S. Coast Guard (USCG) license for all 

passenger-carrying operations, if required by USCG regulations. 

• Construction of cabins or other permanent structures is prohibited. 

• Any action by a permittee or the permittee’s employees that unduly interferes 

with or harasses other refuge visitors or impedes access to any site is strictly 

prohibited. Examples of prohibited acts include flights over camps or persons at 

less than 500 feet (unless landing) and parking aircraft or placing other objects 

(rocks, tents, etc.) on any landable area in a manner that restricts use by other 

aircraft or persons. 

• Subject to available suppression resources, all permitted cabins will be protected 

from wildfire to the extent possible. Human safety will receive the highest 

priority consideration by land managers and fire-suppression personnel. 
Appendix H: Compatibility Determinations: Commercially Guided Big-Game Hunting Services 

H-42 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

• The permittee’s operation plan, as amended and accepted by the U.S. Fish and 

Wildlife Service, is hereby incorporated in its entirety as a special condition. All

deviations from the operations plan must receive prior written approval from the 

refuge manager or designee.

• A copy of this permit must be in the permittee’s possession at all times while 

exercising the privileges of this permit. 

• All noncombustible waste materials must be removed from the refuge upon the 

permittee’s and/or clients’ departure. The permittee is responsible for removal of 

clients’ garbage. 

• The use of helicopters is prohibited. 

• Fuel caches are allowed only in areas designated in permittee’s operational plan. 

Containers shall be properly stored and marked with the owner’s name, address, 

and type of fuel. 

Justification 

Commercial big-game guiding services are a form of traditional activity that Congress 

intended to preserve with the enactment of ANILCA. This activity supports not only 

hunting but other wildlife-dependent activities, including fishing, wildlife observation, 

and photography, which the National Wildlife Refuge System Administration Act (as 

amended) has identified as priority public uses. Guided big-game hunting services 

provide the public with high-quality, safe, and exceptional recreational hunting 

opportunities found few places elsewhere in the world. These guiding services provide 

valuable benefits to those people who are required by state regulation or who simply 

choose to employ a commercial big-game hunting guide. People choose to hire a guide for 

many reasons: they may not be physically able to enter into, or are not comfortable with, 

unguided hunting in the extremely remote and harsh wilderness environment of these 

Refuges. After fully considering the impacts of this activity, as described previously in 

the “Anticipated Impacts” section of this compatibility determination, it is my 

determination that commercial big-game guiding activities on the Refuges support our 

mission by providing support for priority public uses and that they contribute to the 

achievement of the purposes of the refuges or the mission of the National Wildlife Refuge 

System. 

Mandatory 10-Year Re-Evaluation Date (provide month and year for allowed uses only): January 2015 

Mandatory 15-Year Re-Evaluation Date (for priority public uses): NA 

NEPA Compliance for Refuge Use Decision 

 Categorical Exclusion without Environmental Action Memorandum 

 Categorical Exclusions and Environmental Action Memorandum 

 Environmental Assessment and Finding of No Significant Impact 

 X Environmental Impact Statement and Record of Decision 


Appendix H: Compatibility Determinations: Commercial Transporter Services 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-45 

COMPATIBILITY DETERMINATION 

Use: Commercial Transporter Services

Refuge Name: Alaska Peninsula and Becharof National Wildlife Refuges, King Salmon, Alaska 

Establishing and Acquisition Authority(ies) 

In 1978, President Jimmy Carter established the 1,157,000-acre Becharof National 

Wildlife Monument with Presidential Proclamation 4613. The monument was established 

from lands in the public domain to protect the area, notably the unique brown bear 

denning islands in the Island Arm area of Becharof Lake. 

In 1980, the Alaska National Interest Lands Conservation Act (ANILCA) (§ 302) 

established the Alaska Peninsula National Wildlife Refuge and changed the Becharof 

National Wildlife Monument into a national wildlife refuge as part of the National 

Wildlife Refuge System. ANILCA (§ 303[1]) created the Alaska Maritime National 

Wildlife Refuge by redesignating 11 pre-existing refuges as units of the new refuge and 

by adding other public lands on islands, islets, rocks, reefs, spires, and designated capes 

and headlands in the coastal areas and adjacent seas of Alaska. 

In 1983, the U.S. Fish and Wildlife Service (Service) decided to manage the Ugashik and 

Chignik units of Alaska Peninsula Refuge, the 9,900-acre Seal Cape area of Alaska 

Maritime Refuge, and Becharof Refuge as a “complex” because they shared resources 

and resource issues. Distance and weather create barriers to managing the Pavlof and 

North Creek units from the King Salmon office, and management of these units was 

shifted to the Izembek Refuge. 

The Becharof Wilderness Area of the Becharof Refuge was designated in 1980 by 

ANILCA (§ 702 [4]). 

Refuge Purpose(s) 

ANILCA sets out the purposes for each refuge in Alaska. The purposes of the Alaska 

Peninsula and Becharof National Wildlife Refuges are described in Section 302(1)(B) and 

Section 302(2)(B). Purposes for the Alaska Maritime National Wildlife Refuge are 

described in Section 303(1)(B). The purposes identify the reasons why Congress 

established the Refuges and management priorities. 

ANILCA purposes are as follows (unless otherwise noted, the purposes apply to all units 

of the Refuges): 

• to conserve fish and wildlife populations and habitats in their natural diversity, 

including, but not limited to . . . 

[Becharof] . . . brown bears, salmon, migratory birds, the Alaska Peninsula 

Caribou herd, and marine birds and mammals 

[Alaska Peninsula] . . . brown bears, the Alaska Peninsula caribou herd, moose, 

sea otters and other marine mammals, shorebirds and other migratory birds, 

raptors, including bald eagles and peregrine falcons, and salmonids and other fish 

[Alaska Maritime] . . .marine mammals, marine birds and other migratory birds, 

the marine resources upon which they rely, bears, caribou and other mammals 
Appendix H: Compatibility Determinations: Commercial Transporter Services 

H-46 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

• to fulfill the international treaty obligations of the United States with respect to 

fish and wildlife and their habitats 

• to provide, in a manner consistent with the purposes set forth above, the 

opportunity for continued subsistence uses by local residents 

• [Alaska Maritime] to provide, in a manner consistent with the purposes set forth 

above, a program of national and international scientific research on marine 

resources 

• to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth above, water quality and necessary water quantity within the 

refuge 

[Supplemental Purposes of the Becharof Wilderness Area] The Wilderness Act of 1964 

(16 U.S.C. 1131-1136 § 2a), defines supplemental purposes of all designated wilderness 

areas. These apply to the Becharof Wilderness Area and are as follows: 

• to administer the wilderness for the use and enjoyment of the American people in 

such a manner as will leave it unimpaired for future use and enjoyment as 

wilderness, to provide for the protection of the area, for the preservation of its 

wilderness character, and for gathering and dissemination of information 

regarding its use and enjoyment as wilderness. 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network 

of lands and waters for the conservation, management, and, where appropriate, 

restoration of the fish, wildlife, and plant resources and their habitats within the United 

States for the benefit of present and future generations of Americans” (National Wildlife 

Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd-668ee]).

Description of Use(s) 

The Alaska Peninsula is world-renowned for its hunting and fishing opportunities and for 

its scenic landscape. Commercial transport of clients to access the peninsula to hunt, fish, 

and participate in other outdoor recreational activities predates refuge establishment in 

1980. Commercial transporters provide a service that most refuge visitors require to 

access the Refuges. Although almost all commercial transporting activities on the 

Refuges are conducted by air-taxi operators (predominantly with float-equipped aircraft), 

several permits have been issued in the past to transporters using power boats. One 

commercial transporter in recent years has used a helicopter to deliver recreational 

anglers to areas just outside refuge boundaries or to state-owned land within the 

Refuges. These clients would then access nearby refuge streams by foot. Note that this 

compatibility determination does not address commercial helicopter transporter services 

on refuge-owned lands and waters. If the Service were to authorize a commercial 

helicopter operation, a separate compatibility determination covering that use would be 

necessary. Air-taxi operators are required, as a condition of their permits, to provide 

information on their clients, including; the primary activity, location, length of stay, group 

size, and other related information. 

The trend in the number of air-taxi operators authorized to operate on the Refuges 

increased, ranging from two in 1988 to 27 in 1999. However, the number of permits has 
Appendix H: Compatibility Determinations: Commercial Transporter Services 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-47 

fallen recently, with only 15 permits issued 2000, 16 in 2001, 18 in 2002, 15 in 2003, and 16 

in 2004. It should also be noted that not all of the permitted businesses actually operate 

within the Refuges each year. Most use occurs from May through October. The number 

of commercial transporter trips made to the Refuges fluctuated between 140 and 190 per 

year during most of the 1990s. Use during the last two years has been in the lower end of 

this range. One company accounts for approximately half of the flights. The annual 

number of visitor-use days on the Refuges associated with these trips ranged from 2,000 

to 3,000. During the early 1990s, more hunters than anglers used commercial 

transporters to access the refuge. Now, with a decline in the number of hunters, a higher 

percentage of transporters’ clients are anglers. This reduction and shift in numbers is 

due primarily to the recent decline in the Northern Alaska Peninsula Caribou Herd and 

subsequent closure of the recreational hunting season for caribou. 

This activity (commercial transporter services) occurs throughout the Refuges and 

supports wildlife-dependent recreational activities. Timing of this activity would 

primarily be in response to state fishing and hunting seasons. 

Availability of Resources 

Adequate refuge personnel and base operational funds are available to manage 

commercial transporter activities at current and projected levels. Approximately 

$20,000–25,000 in visitor use fees are collected annually, which are returned to the refuge 

to use to manage commercial recreational activities over and above base operational 

funds. Administrative time (10–15 staff days) primarily involves annually issuing permits, 

ensuring that licenses and certifications are current, collecting client use-day fees, and 

entering activity data into a database. Field work associated with administering the 

program primarily involves monitoring the permittee’s compliance with the terms of the 

permits. 

Anticipated Impacts of the Use(s) 

Because of the refuge=s administrative oversight of the activity, comprehensive state and 

federal regulations (which continually evolve to respond to fisheries and wildlife 

management needs) and because of combined law-enforcement efforts of state and refuge 

personnel, direct impacts from commercial transporter services at existing and projected 

levels should have minimal impacts to fish and wildlife resources, other refuge resources, 

other refuge users, and wilderness values. Impacts associated with the activities that 

occur on the refuge as a result of the commercial transporters providing the public access 

to the refuges are addressed in the respective compatibility determination for each 

activity. 

Because the vast majority of transporters access the refuge by landing, with floatequipped aircraft, on lakes and rivers, potential impacts to refuge habitats are minimized. 

Although it is not known to have occurred on the Alaska Peninsula to date, one potential 

impact or threat associated with floatplane access is the introduction of invasive species 

carried in on the aircraft floats. Most wheel-plane landings occur on existing 

unmaintained landing strips, gravel bars, or unvegetated sand and cinder blows. A few 

landings by commercial transporters are made on vegetated lowland tundra or ridge 

tops, usually with Piper Super Cubs or other small, light aircraft equipped with tundra 

tires. Disturbance to vegetation is minimal and short-term unless repeated landings are 
Appendix H: Compatibility Determinations: Commercial Transporter Services 

H-48 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

made in exactly the same location (this practice has not been observed to date). 

Temporary displacement and/or disturbance to wildlife can occur during take-offs and 

landings. There are no known long-term impacts to refuge wildlife populations from this 

disturbance. 

The numbers of commercial transporter flights and landings currently occurring within 

the designated Becharof Wilderness Area do not significantly impact solitude 

characteristics or other wilderness values. The following stipulations in each operator’s 

permit have been included to lessen or eliminate adverse effects. 

Public Review and Comment 

Draft compatibility determinations are published as a portion of the Draft Revised 

Comprehensive Conservation Plan, and public review is invited with comments on the 

plan. Public involvement includes: a notice of availability published in the Federal 

Register, mailings to the Refuges mailing list, meetings in villages near the Refuges, and 

posting on the Region 7 Web page (www.r7.fws.gov/compatibility).

Determination 

 Use is Not Compatible 

 X Use is Compatible 

Stipulations Necessary to Ensure Compatibility 

Management direction provided in the revised Comprehensive Conservation Plan for the 

Refuges, particularly adequate monitoring of commercial transporter activities and other 

associated public-use activities, will be conducted. Findings from the monitoring efforts 

will be used to determine what additional management actions, if any, are needed to 

ensure that commercial transporter activities remain compatible with refuge purposes. 

The following stipulations apply to special-use permits issued for commercial transporter 

services. Continuing law-enforcement and administrative monitoring of permittees will 

be carried out to ensure compliance with the following conditions that are incorporated 

into all commercial transporter permits in order to minimize impacts on refuge lands and 

resources: 

• Failure to abide by any part of this special-use permit; violation of any refugerelated provision in Titles 43 (Part 36) or Title 50 (subchapters B and C) of the 

Code of Federal Regulations; or violation of any pertinent state regulation (e.g., 

fish or game violation) will, with due process, be considered grounds for 

immediate revocation of this permit and could result in denial of future permit 

requests for lands administered by the U.S. Fish and Wildlife Service. This 

provision applies to all persons working under the authority of this permit (e.g., 

assistants). Appeals of decisions relative to permits are handled in accordance 

with Title 50 Code of Federal Regulations, Part 36.41. 

• A copy of this permit must be in the permittee’s possession at all times while 

exercising the privileges of this permit. 

• The permittee is responsible for ensuring that all employees, party members, 

aircraft pilots, and any other persons working for the permittee and conducting 
Appendix H: Compatibility Determinations: Commercial Transporter Services 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-49 

activities allowed by this permit are familiar with and adhere to the conditions of 

this permit. 

• Any problem with wildlife and/or animals taken in defense of life or property 

must be reported immediately to the refuge manager and to the Alaska 

Department of Fish and Game; any animal taken in defense of life or property 

must be salvaged in accordance with state regulations. 

• The use of Native or state lands that have been conveyed (patented) is not 

authorized by this permit. 

• This permit may be canceled or revised at any time by the refuge manager in case 

of emergency (e.g., high fire danger, flooding, unusual resource problems). 

• Prior to beginning any activities allowed by this permit, the permittee shall 

provide the refuge manager with the following: (1) name and method of contact 

for the field party chief or supervisor and (2) any changes in information provided 

in the original permit application. 

• Prior to beginning any activities allowed by this permit, the permittee shall 

provide the refuge manager with the following: (1) proof of appropriate aviation 

passenger liability ($150,000 per seat plus $100,000 property damage), marine 

liability, and/or comprehensive general liability insurance covering all aspects of 

operations throughout the annual use period; (2) aircraft and other vehicle types 

to be used, with identification information, if different from those described in the 

permit application; (3) changes in names of pilots; and (4) any other changes in 

information provided in the operations plan. 

• In accordance with the Archaeological Resources Protection Act (16 USC 470aa), 

the excavation, disturbance, collection, or purchase of historical, recent, 

ethnological, or archaeological specimens or artifacts is prohibited. 

• All noncombustible waste materials must be removed from the refuge (not 

buried) upon the permittee’s and/or clients’ departure. The permittee is 

responsible for removal of clients’ garbage. 

• The construction or clearing of landing strips or pads is prohibited. Incidental 

hand removal of rocks and other minor obstructions may be permitted. 

• The operation of aircraft at altitudes and in flight paths resulting in the herding, 

harassment, hazing, or driving of wildlife is prohibited. It is recommended that all 

aircraft, except for take off and landing, maintain a minimum altitude of 2,000 feet 

above ground level. 

• The use of helicopters is prohibited unless specifically authorized. 

• Fuel caches are allowed only in areas designated in permittee’s operational plan. 

Containers shall be properly stored and marked with the owner’s name, address, 

and type of fuel. 

• All aircraft being used in a commercial operation must have 12-inch identification 

numbers in contrasting colors that are readily visible. 

• Failure to report the actual number of client-use days per type of authorized 

activity by December 31 of the permit calendar year and to pay the Service’s 

established fees (client-use day) within 30 days after receiving a bill for collection 

will be grounds for denial of future permits. 
Appendix H: Compatibility Determinations: Commercial Transporter Services 

H-50 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

• Motorboat operators must possess a U.S. Coast Guard (USCG) license for all 

passenger-carrying operations, if required by USCG regulations. 

• Any action by a permittee or the permittee’s employees that unduly interferes 

with or harasses other refuge visitors or impedes access to any site is strictly 

prohibited. Examples of prohibited acts include flights over camps or persons at 

less than 500 feet altitude (unless landing) and parking aircraft or placing other 

objects (rocks, tents, etc.) on any landable area to restrict use by other aircraft or 

persons. 

• This permit authorizes use of the Native-selected lands identified in the 

description block of this permit. If any of these Native-selected lands are 

conveyed during the term of this permit, the permittee will no longer be 

authorized to use those lands until and unless permission is obtained from the 

Native entity to which land ownership has been conveyed. 

• Commercial operators who transport persons by air for compensation or hire 

must comply with all Federal Aviation Administration regulatory requirements 

for air carriers and commercial operators. 

• The permittee and permittee’s clients do not have the exclusive use of the site(s) 

or lands covered by this permit. 

Justification 

Commercial transporting is a traditional activity that Congress intended to preserve 

when it established the Refuges with the enactment of ANILCA. Commercial 

transporter services provide the public with safe access for the wildlife-dependent 

priority public uses of hunting, fishing, wildlife viewing, wildlife photography, and 

environmental education. These are activities that the National Wildlife Refuge System 

Improvement Act of 1997 (§ 5) identifies as priority public uses. Commercial transporter 

services are necessary to a segment of the public that does not have other means of 

access to the extremely remote environment of these Refuges. After fully considering the 

impacts of this activity, as described previously in the AAnticipated Impacts@ section of 

this compatibility determination, it is my determination that commercial transporter 

services contribute to the achievement of the purposes of the Refuges or the mission of 

the National Wildlife Refuge System. 

Mandatory 10-Year Re-Evaluation Date (provide month and year for allowed uses only): 

January 2015 

Mandatory 15-Year Re-Evaluation Date (for priority public uses): NA 

NEPA Compliance for Refuge Use Decision 

 Categorical Exclusion without Environmental Action Memorandum 

 Categorical Exclusions and Environmental Action Memorandum 

 Environmental Assessment and Finding of No Significant Impact 

 X Environmental Impact Statement and Record of Decision 

Appendix H: Compatibility Determinations: Subsistence Activities 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-53 

COMPATIBILITY DETERMINATION 

Use: Subsistence Activities

Refuge Name: Alaska Peninsula and Becharof National Wildlife Refuges, King Salmon, Alaska 

Establishing and Acquisition Authority(ies) 

In 1978, President Jimmy Carter established the 1,157,000-acre Becharof National 

Wildlife Monument with Presidential Proclamation 4613. The monument was established 

from lands in the public domain to protect the area, notably the unique brown bear 

denning islands in the Island Arm area of Becharof Lake. 

In 1980, the Alaska National Interest Lands Conservation Act (ANILCA) (§302) 

established the Alaska Peninsula National Wildlife Refuge and changed the Becharof 

National Wildlife Monument into a national wildlife refuge as part of the National 

Wildlife Refuge System. ANILCA (§303[1]) created the Alaska Maritime National 

Wildlife Refuge by redesignating 11 pre-existing refuges as units of the new refuge and 

by adding other public lands on islands, islets, rocks, reefs, spires, and designated capes 

and headlands in the coastal areas and adjacent seas of Alaska. 

In 1983, the U.S. Fish and Wildlife Service (Service) decided to manage the Ugashik and 

Chignik units of Alaska Peninsula Refuge, the 9,900-acre Seal Cape area of Alaska 

Maritime Refuge, and Becharof Refuge as a “complex” because they shared resources 

and resource issues. Distance and weather create barriers to managing the Pavlof and 

North Creek Units from the King Salmon office, and management of these units was 

shifted to the Izembek Refuge. 

The Becharof Wilderness Area of the Becharof Refuge was designated in 1980 by 

ANILCA (§702 [4]). 

Refuge Purpose(s) 

ANILCA sets out the purposes for each refuge in Alaska. The purposes of the Alaska 

Peninsula and Becharof National Wildlife Refuges are described in Section 302(1)(B) and 

Section 302(2)(B). Purposes for the Alaska Maritime National Wildlife Refuge are 

described in Section 303(1)(B). The purposes identify the reasons why Congress 

established the Refuges and management priorities. 

The ANILCA purposes are follows (unless otherwise noted, the purposes apply to all 

units of the Refuges): 

• to conserve fish and wildlife populations and habitats in their natural diversity 

including, but not limited to . . . 

[Becharof] . . . brown bears, salmon, migratory birds, the Alaska Peninsula 

Caribou herd, and marine birds and mammals 

[Alaska Peninsula] . . . brown bears, the Alaska Peninsula caribou herd, moose, 

sea otters and other marine mammals, shorebirds and other migratory birds, 

raptors, including bald eagles and peregrine falcons, and salmonids and other fish 

[Alaska Maritime] . . . marine mammals, marine birds and other migratory birds, 

the marine resources upon which they rely, bears, caribou and other mammals, 
Appendix H: Compatibility Determinations: Subsistence Activities 

H-54 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

• to fulfill the international treaty obligations of the United States with respect to 

fish and wildlife and their habitats, 

• to provide, in a manner consistent with the purposes set forth above, the 

opportunity for continued subsistence uses by local residents, 

• [Alaska Maritime] to provide, in a manner consistent with the purposes set forth 

above, a program of national and international scientific research on marine 

resources, 

• to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth above, water quality and necessary water quantity within the 

refuge, 

[Supplemental Purposes of the Becharof Wilderness Area] The Wilderness Act of 1964 

(16 U.S.C. 1131-1136 Section 2a), defines supplemental purposes of all designated 

wilderness areas. These apply to the Becharof Wilderness Area and are as follows: 

• to administer the wilderness for the use and enjoyment of the American people in 

such a manner as will leave it unimpaired for future use and enjoyment as 

wilderness, to provide for the protection of the area, the preservation of its 

wilderness character, and for gathering and dissemination of information 

regarding its use and enjoyment as wilderness 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network 

of lands and waters for the conservation, management, and, where appropriate, 

restoration of the fish, wildlife, and plant resources and their habitats within the United 

States for the benefit of present and future generations of Americans” (National Wildlife 

Refuge System Administration Act of 1966 [16 U.S.C. 668dd-668ee]).

Description of Use(s) 

Subsistence activities are an existing use provided for in the Refuge purposes. They 

occur year-round throughout the Refuges. 

Subsistence activities addressed in this document include hunting, fishing, trapping, 

firewood gathering, berry picking, gathering of other plant materials (e.g., Labrador tea, 

petruski, wild spinach, grass), and the continued use by authorized permittees of three 

existing subsistence cabins. It also includes associated means of transport, including 

fixed-winged aircraft, motorboats, snowmachines, off-road vehicles as defined in refugespecific regulations, and other traditional nonmotorized surface methods of 

transportation, including dogsledding, hiking, cross-country skiing, and snowshoeing. 

Residents of villages located near the Refuges have lifestyles and economies that depend 

on subsistence resources. Subsistence activities are not just a way of obtaining food, but 

are an important mechanism for maintaining cultural values such as kinship, community, 

respect for elders, hospitality, sharing resources, and the passing of values to younger 

generations. In addition, many residents in the area prefer the taste of traditional wild 

foods to commercially purchased foods. 

The mainstay subsistence food for the Refuges= nearby communities is salmon, which is 

obtained by subsistence harvest as well as retained from the commercial catch. All five 
Appendix H: Compatibility Determinations: Subsistence Activities 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-55 

species of Pacific salmon native to Alaska are used, although chinook, sockeye, and coho 

are preferred. Freshwater species—including rainbow trout, Arctic char, Arctic grayling, 

Dolly Varden, lake trout, burbot, and northern pike—are also used, but to a much lesser 

extent. The majority of the local villages= subsistence harvest of fish does not occur within 

refuge waters.

The Northern Alaska Peninsula caribou herd (NAPCH) has provided abundant food to 

local villages for more than a generation (Krieg et al. 1998; Krieg et al. 1996). Caribou 

were traditionally the most widely used of the three terrestrial species (moose, bear, and 

caribou) by residents of the local villages. They were harvested in large quantities, 

thoroughly used, and widely shared (Fall 1993). During the mid-1990s, 4 to 9 percent of 

the animals harvested were reported taken within the boundaries of the Refuges; in 

1996–1997, none of the five communities with the highest harvest levels (King Salmon, 

Naknek, South Naknek, Port Heiden, and Pilot Point) reported harvesting caribou from 

the Refuges. Currently, 40 federal harvest permits (10 percent of the 400 state-issued 

Tier II permits) are issued to local residents for harvest of NAPCH caribou within the 

Refuges and on other federal lands. 

Although traditionally not used by as many households as is caribou (Krieg et al. 1998; 

Krieg et al. 1996), moose is another important subsistence species for residents of Alaska 

Peninsula communities. Data are not available for every year, but in 1995–1996, about 42 

moose, which were approximately 36 percent of the moose harvested by local refuge 

villages, were taken within the boundaries of the Refuges (Krieg et al. 1998; Krieg et al. 

1996). Of these, about 75 percent were taken within Alaska Peninsula Refuge boundaries. 

The number taken within refuge boundaries dropped considerably in 1996–1997, to just 

12 moose (all within Alaska Peninsula Refuge boundaries), which represented 19 percent 

of the total number of moose harvested. The only communities not harvesting significant 

portions of their moose on the Refuges were King Salmon, Naknek, South Naknek, Pilot 

Point, and Egegik. 

During the most recent years—when brown bear use was studied in detail by the Alaska 

Department of Fish and Game’s Subsistence Division—Chignik Lake, Perryville, and 

Ivanof Bay were the only three communities that showed much use of brown bear. In 

1995–1996, 29 individuals reported hunting brown bear, and 15 were successful; this 

compares with 19 individuals hunting in 1996–1997, with eight bears being reported as 

harvested. Most bear hunting took place in Pacific communities in Game Management 

Unit 9E. In both study years, a majority of the bears were taken within the boundaries of 

the Alaska Peninsula Refuge: 70 percent in 1995–1996 and 81 percent in 1996–1997. 

Birds and their eggs are also important subsistence foods used by local residents. Recent 

subsistence studies, covering the period of 1996–1998 (Wong and Wentworth 1999), 

indicated that ptarmigan was the bird most commonly harvested, followed by mallards, 

pintails, green-winged teal, lesser Canada geese, and cackling Canada geese. The vast 

majority of eggs harvested were from glaucous-winged gulls, followed by mew gulls and 

Arctic terns. 

A few local trappers operate within the Refuges harvesting beaver, wolves, wolverine, 

lynx, river otter, and other small fur-bearing mammals. The sale of these furs provides 

supplemental income to residents of some communities adjacent the Refuges. The 

average annual number of trapper-related visits and harvest of furbearers occurring on 
Appendix H: Compatibility Determinations: Subsistence Activities 

H-56 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

the Refuges is not available, but the numbers are small because the total number of 

furbearers reported taken in recent years in all of state Game Management Units 9C and 

9E is relatively low (typically much less than 100 animals per year for each species). 

Availability of Resources 

Adequate refuge personnel and base operational funds are available to manage 

subsistence activities at existing and projected levels. Approximately 700 staff days and 

$500,000 are typically spent managing this activity on an annual basis. Activity related 

tasks are primarily conducted by the refuge manager, deputy refuge manager, 

subsistence coordinator, pilot/refuge officer and two park rangers. Management 

primarily includes conducting wildlife and public-use studies and surveys specifically for 

the management of subsistence species, conducting harvest surveys in the local 

communities, and participating in the regulatory development process with the Federal 

Subsistence Board and Alaska Boards of Fisheries and Game. 

Anticipated Impacts of the Use(s) 

Fish and wildlife harvested by subsistence users at current and projected levels—in 

accordance with established state and federal regulations pertaining to season, bag limits 

and methods of harvest—are not expected to have significant long-term impacts on the 

overall populations of refuge fish and wildlife resources. State and federal biologists 

monitor fish and game populations and state and federal regulatory bodies continually 

respond to management needs by adopting regulations to ensure the continued health of 

fish and wildlife populations. 

Impacts to the resources from berry picking and other plant-harvesting activities are 

insignificant. Impacts to habitat caused by accessing refuge resources via aircraft, 

snowmachine, boats, and foot are generally minimal. Much of the access by subsistence 

users is by boat, thereby causing very little impact to refuge habitat. Snowmachine use 

occurs in the winter when there is adequate snow cover to prevent impacts to vegetation 

and soils. Aircraft landings on the refuge by subsistence users are relatively few and 

occur primarily on existing unmaintained landing strips, gravel bars, and unvegetated 

sand or cinder blows. 

The most serious potential access-related impacts to habitat are from off-road vehicles 

used year-around in areas of the refuge that are located near the villages. Refuge-specific 

regulations promulgated in 1995 limit the size of authorized off-road vehicles to three- or 

four-wheeled vehicles with a maximum gross weight of 650 pounds. Prior to development 

of these regulations, field visits by refuge staff were made to sites where off-road vehicle 

use was known or reported to occur on the Refuges. Observed conditions were 

documented with photographs and narratives. The field review showed no significant 

habitat damage. Upon review of the public comments, the new data, relevant scientific 

literature, and legal requirements for managing subsistence use of off-road vehicles, the 

Service concluded that the current level of off-road vehicle use is not “causing (n)or is 

likely to cause an adverse impact on public health or safety, resource protection, 

protection of historic or scientific values, subsistence uses . . . or other purposes for which 

the refuge was established.” The refuge conducts periodic monitoring of these sites to 

ensure that conditions and impacts are not significantly changing (USFWS 1994). 
Appendix H: Compatibility Determinations: Subsistence Activities 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-57 

Subsistence activities are an existing use, provided for in the Refuges purposes, and are 

provided for in the refuge management goals. They occur year round throughout the 

Refuges. 

Public Review and Comment 

The public was invited to comment on this compatibility determination and a number of 

other determinations during the public review period establised for the draft revised 

Comprehensive Conservation Plan. Public notice of the availability of the draft 

conservation plan and draft determinations was published in the Federal Register. The 

draft determinations were also posted on the Region 7 Refuge Conservation Planning 

and Policy Web pages. No substantive public comments pertaining to this determination 

were received. Where appropriate, comments addressing elements of the draft 

Comprehensive Conservation Plan revision that pertained to the specific uses evaluated 

in this determination were considered in preparing the final compatibility determination. 

Determination 

 Use is Not Compatible 

 X Use is Compatible 

Stipulations Necessary to Ensure Compatibility 

Although specific stipulations for subsistence activities are not necessary, management 

direction is provided in the revised Comprehensive Conservation Plan for the Refuges. 

This direction includes implementation of applicable sections of the Refuges’ wildlife 

inventory plan, adequate monitoring of public-use activities, and continued monitoring of 

areas used by off-road vehicles. Findings from these wildlife, public-use, and habitatmonitoring efforts will be used to determine what additional management actions, if any, 

are needed to ensure that subsistence activities remain compatible with refuge purposes. 

Justification 

One of the purposes of the Refuges, as established by ANILCA, is to provide for 

continued subsistence uses by local residents, consistent with the other refuge purposes 

of conserving fish and wildlife populations and habitats and fulfilling international treaty 

obligations with respect to fish and wildlife. ANILCA recognized that the continued 

opportunity for subsistence uses of public lands is critical to physical, economic, 

traditional, social, and cultural existence of rural Native and non-Native residents of 

Alaska. ANILCA established a preference for subsistence users, stating that the taking 

of fish and wildlife on public lands for nonwasteful subsistence use is given priority over 

other consumptive uses; in times of scarcity, recreational use is limited first. Section 811 

of ANILCA ensures that subsistence users can access public lands by snowmachine, 

motorboat, and other traditionally used means of transportation, subject to reasonable 

regulation. In conclusion, current subsistence activities occurring on the Refuges 

contribute to one of the purposes of the Refuges while not materially interfering with or 

detracting from the other purposes of the Refuges or the mission of the National Wildlife 

Refuge System. 
Appendix H: Compatibility Determinations: Subsistence Activities 

H-58 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

Mandatory 10-Year Re-Evaluation Date (provide month and year for allowed uses only): 

January 2015 

Mandatory 15-Year Re-Evaluation Date (for priority public uses): NA 

EPA Compliance for Refuge Use Decision 

 Categorical Exclusion without Environmental Action Memorandum 

 Categorical Exclusions and Environmental Action Memorandum 

 Environmental Assessment and Finding of No Significant Impact 

 X Environmental Impact Statement and Record of Decision 

Supporting Documents 

• Fall, J.A. 1993. “An overview of subsistence uses of the Northern Alaska 

Peninsula Caribou Herd by communities of game management unites 9C and 

9E.” Technical Paper. No. 224. Juneau, Alaska: Alaska Department of Fish and 

Game, Division of Subsistence. 

• Krieg, T.M., J.A. Fall, C.J. Utermohle, and L. Brown. 1998. “Subsistence harvests 

and uses of caribou, moose, and brown bear in 12 Alaska Peninsula communities, 

1995/96 and 1996/97.” Technical Paper. No. 244. Juneau, Alaska: Alaska 

Department of Fish and Game, Division of Subsistence. 

• Krieg, T.M., P.C. Kenner, L. Hutchinson-Scarbrough, and L. Brown. 1996. 

“Subsistence harvests and uses of caribou, moose, and brown bear in 12 Alaska 

Peninsula communities, 1994/95.” Technical Paper. No. 240. Juneau, Alaska: 

Alaska Department of Fish and Game, Division of Subsistence. 

• USFWS. 1994. “Alaska Peninsula/Becharof National Wildlife Refuge Complex 

Final Public Use Management Plan.” Anchorage, Alaska: U.S. Fish and Wildlife 

Service. 

• Wong, D., and C. Wentworth. 1999. “Subsistence waterfowl harvest survey, 

Bristol Bay 1995-1998.” Anchorage, Alaska: U.S. Fish and Wildlife Service, 

Migratory Bird Management. (Data also available at 

http://www.r7.fws.gov/mbm/HarvestSurvey/data/9599akpe.htm.) 

• USFWS. 1994. Decision Notice and Finding of No Significant Impact, Alaska 

Peninsula/Becharof National Wildlife Refuge Complex Public Use Management 

Plan, May 12, 1994. Anchorage, Alaska: U.S. Fish & Wildlife Service. 

• USFWS. 1992. Subsistence Management for Federal Public Lands in Alaska, 

Final Environmental Impact Statement, Record of Decision, signed April 2, 1992. 

Anchorage, Alaska: U.S. Fish & Wildlife Service. 

• USFWS. 1994. Compatibility Determination, Final Public Use Management Plan, 

Alaska Peninsula/Becharof National Wildlife Refuge Complex, May 16, 1994. 

Anchorage, Alaska: U.S. Fish & Wildlife Service. 

• USFWS. 1994. Compatibility Determination and ANILCA Section 810 

Determinations, Subsistence Fishing, Gathering Hunting and Trapping, Alaska 

Peninsula/Becharof National Wildlife Refuge Complex, May 9, 1994. Anchorage, 

Alaska: U.S. Fish & Wildlife Service 

Appendix H: Compatibility Determinations: Reburial of Archaeological Human Remains 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-61 

COMPATIBILITY DETERMINATION 

Use: Reburial of Archaeological Human Remains per State and Federal Guidelines 

Refuge Name: Alaska Peninsula and Becharof National Wildlife Refuges, King Salmon, Alaska 

Establishing and Acquisition Authority(ies) 

In 1978, President Jimmy Carter established the 1,157,000-acre Becharof National 

Wildlife Monument with Presidential Proclamation 4613. The monument was established 

from lands in the public domain to protect the area, notably the unique brown bear 

denning islands in the Island Arm area of Becharof Lake. 

In 1980, the Alaska National Interest Lands Conservation Act (ANILCA) (section 302) 

established the Alaska Peninsula National Wildlife Refuge and changed the Becharof 

National Wildlife Monument into a national wildlife refuge as part of the National 

Wildlife Refuge System. ANILCA (section 303[1]) created the Alaska Maritime National 

Wildlife Refuge by redesignating 11 pre-existing refuges as units of the new refuge and 

by adding other public lands on islands, islets, rocks, reefs, spires, and designated capes 

and headlands in the coastal areas and adjacent seas of Alaska. 

In 1983, the U.S. Fish and Wildlife Service (Service) decided to manage the Ugashik and 

Chignik units of Alaska Peninsula Refuge, the 9,900-acre Seal Cape area of Alaska 

Maritime Refuge, and Becharof Refuge as a “complex” because they shared resources 

and resource issues. Distance and weather create barriers to managing the Pavlof and 

North Creek units from the King Salmon office, and management of these units was 

shifted to the Izembek Refuge. 

The Becharof Wilderness Area of the Becharof Refuge was designated in 1980 by 

ANILCA (§ 702 [4]). 

Refuge Purpose(s) 

ANILCA sets out the purposes for each refuge in Alaska. The purposes of the Alaska 

Peninsula and Becharof National Wildlife Refuges are described in §302(1)(B) and 

Section 302(2)(B). Purposes for the Alaska Maritime National Wildlife Refuge are 

described in Section 303(1)(B). The purposes identify the reasons why Congress 

established the Refuges and management priorities. 

The ANILCA purposes are follows (unless otherwise noted, the purposes apply to all 

units of the Refuges): 

• to conserve fish and wildlife populations and habitats in their natural diversity 

including, but not limited to . . . 

[Becharof] . . . brown bears, salmon, migratory birds, the Alaska Peninsula 

Caribou herd, and marine birds and mammals 

[Alaska Peninsula] . . . brown bears, the Alaska Peninsula caribou herd, moose, 

sea otters and other marine mammals, shorebirds and other migratory birds, 

raptors, including bald eagles and peregrine falcons, and salmonids and other fish 

[Alaska Maritime] . . . marine mammals, marine birds and other migratory birds, 

the marine resources upon which they rely, bears, caribou and other mammals 
Appendix H: Compatibility Determinations: Reburial of Archaeological Human Remains 

H-62 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

• to fulfill the international treaty obligations of the United States with respect to 

fish and wildlife and their habitats 

• to provide, in a manner consistent with the purposes set forth above, the 

opportunity for continued subsistence uses by local residents 

• [Alaska Maritime] to provide, in a manner consistent with the purposes set forth 

above, a program of national and international scientific research on marine 

resources 

• to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth above, water quality and necessary water quantity within the 

refuge 

[Supplemental Purposes of the Becharof Wilderness Area] The Wilderness Act of 1964 

(16 U.S.C. 1131-1136 § 2a), defines supplemental purposes of all designated wilderness 

areas. These apply to the Becharof Wilderness Area and are as follows: 

• to administer the wilderness for the use and enjoyment of the American people in 

such a manner as will leave it unimpaired for future use and enjoyment as 

wilderness, to provide for the protection of the area, for the preservation of its 

wilderness character, and for gathering and dissemination of information 

regarding its use and enjoyment as wilderness. 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network 

of lands and waters for the conservation, management, and, where appropriate, 

restoration of the fish, wildlife, and plant resources and their habitats within the United 

States for the benefit of present and future generations of Americans” (National Wildlife 

Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd-668ee]).

Description of Use(s) 

The Refuges anticipate requests to rebury human remains eroding from recorded and 

unrecorded prehistoric sites and remains that have been removed from prehistoric sites. 

The Inadvertent Discovery section (§ [3][d]) of the Native American Graves Protection 

and Repatriation Act of 1990 (Public Law 101-601) requires that the land management 

agency identify and notify the closest Native group and then, if requested, provide for the 

repatriation of the remains. 

With this in mind, we have prepared this compatibility determination to cover an 

expected one to three reburial requests annually for the next 10 years. Each proposed 

burial and its proposed reburial location would need to be approved by the Regional 

Historic Preservation Officer, who will ensure compliance with the National Historic 

Preservation Act (§106) prior to issuance of a permit. 

Reburial of repatriated human remains would take place near the place of discovery of 

such remains and/or near their original burial place. Each burial would involve a small 

excavation with hand tools. Impacts to refuge resources would be negligible and shortterm, with no foreseeable long-term effects, and would not affect subsistence use of the 

refuge. A copy of the Global Positioning System (GPS) coordinates and contents of the 

burial site will be filed at the Refuges’ headquarters and with the Regional Historic 
Appendix H: Compatibility Determinations: Reburial of Archaeological Human Remains 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-63 

Preservation Officer. The remains should be buried with a modern object (e.g., coin, 

button—with date) to indicate it is a historical reburial. 

Availability of Resources 

Except for issuance of the permit, no refuge resources are needed to administer use. All 

activities associated with use will be accomplished by the permittee. 

Anticipated Impacts of the Use(s) 

This project will result in minimal and short-term impacts to refuge resources, involving 

a few small-scale excavations with hand tools and then reburial. 

Public Review and Comment 

The public was invited to comment on this compatibility determination and a number of 

other determinations during the public review period establised for the draft revised 

Comprehensive Conservation Plan. Public notice of the availability of the draft 

conservation plan and draft determinations was published in the Federal Register. The 

draft determinations were also posted on the Region 7 Refuge Conservation Planning 

and Policy Web pages. No substantive public comments pertaining to this determination 

were received. Where appropriate, comments addressing elements of the draft 

Comprehensive Conservation Plan revision that pertained to the specific uses evaluated 

in this determination were considered in preparing the final compatibility determination. 

Determination 

 Use is Not Compatible 

 X Use is Compatible 

Stipulations Necessary to Ensure Compatibility 

The following stipulations will be made part of a special-use permit for Reburial of 

Archaeological Human Remains per State and Federal Guidelines 

• Failure to abide by any part of the special-use permit for this activity; violation of 

any refuge-related provision in Titles 43 (Part 36) or 50 (subchapters B and C) 

Code of Federal Regulations; or violation of any pertinent state regulation (e.g., 

fish or game violation) will, with due process, be considered grounds for 

immediate revocation of the permit and could result in denial of future permit 

requests for lands administered by the U.S. Fish and Wildlife Service. This 

provision applies to all persons working under the authority of this permit (e.g., 

assistants). Appeals of decisions relative to permits are handled in accordance 

with Title 50 Code of Federal Regulations Part 36.41. 

• The permittee is responsible for ensuring that all employees, party members, 

aircraft pilots, and any other persons working for the permittee and conducting 

activities allowed by this permit are familiar with and adhere to the conditions of 

the permit. 

• Reburial of repatriated human remains will take place near the place of discovery 

of such remains and/or near their original burial place. 
Appendix H: Compatibility Determinations: Reburial of Archaeological Human Remains 

H-64 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

• The permittee or permittees representatives will make the smallest possible 

excavation, using only hand tools 

• The Global Positioning System (GPS) coordinates and contents of the burial site 

will be filed at the Refuges’ headquarters and with the Regional Historic 

Preservation Officer. 

• Remains shall be buried with a modern object (e.g., coin, button, etc.—with date) 

to indicate that it is a historical reburial. 

• Any problem with wildlife and/or animals taken in defense of life or property 

must be reported immediately to the refuge manager and the Alaska Department 

of Fish and Game; animals taken in defense of life or property must be salvaged 

in accordance with state regulations. 

• The use of Native or state lands that have been selected but not yet conveyed is 

prohibited unless a letter of concurrence from the interested party is submitted to 

the refuge manager prior to beginning any activities allowed by the permit. 

• The permittee shall notify the refuge manager during refuge working hours in 

person or by telephone before beginning and upon completion of activities allowed 

by the permit. 

• Prior to beginning any activities allowed by this permit, the permittee shall 

provide the refuge manager with the following: (1) name and method of contact 

for the field party chief or supervisor; (2) aircraft and other vehicle types to be 

used, with identification information. 

• The refuge manager, upon request, shall be afforded the opportunity and 

logistical support, from the nearest commercial transportation site, to accompany 

the permittee for the purpose of inspection and monitoring permittee activities. A 

final inspection trip, provided by the permittee, of the areas of use may be 

required by the refuge manager to determine compliance with the terms of this 

permit. 

• The operation of aircraft at altitudes and in flight paths resulting in the herding, 

harassment, hazing, or driving of wildlife is prohibited. It is recommended that all 

aircraft, except for take off and landing, maintain a minimum altitude of 2,000 feet 

above ground level. 

• A copy of this permit must be in the permittee’s possession at all times while 

exercising the privileges of this permit. 

• All noncombustible waste materials must be removed from the refuge (not 

buried) upon the permittee’s departure. 

• The permittee shall provide the refuge manager with a report of activities under 

this permit within 30 days of permit expiration. 

Justification 

The proposed use is limited and short-term and thus will result in minimal impact to 

refuge resources. This use is necessary for the Refuges to comply with the Native 

American Graves Protection and Repatriation Act of 1990 (Public Law 101-601). It will 

not interfere with or detract from the National Wildlife Refuge System mission or the 

purposes of the Refuges. 

Appendix H: Compatibility Determinations: Scientific Research 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-67 

COMPATIBILITY DETERMINATION 

Use: Scientific Research 

Refuge Name: Alaska Peninsula and Becharof National Wildlife Refuges, King Salmon, Alaska

Establishing and Acquisition Authority(ies) 

In 1978, President Jimmy Carter established the 1,157,000-acre Becharof National 

Wildlife Monument with Presidential Proclamation 4613. The monument was established 

from lands in the public domain to protect the area, notably the unique brown bear 

denning islands in the Island Arm area of Becharof Lake. 

In 1980, the Alaska National Interest Lands Conservation Act (ANILCA) (§302) 

established the Alaska Peninsula National Wildlife Refuge and changed the Becharof 

National Wildlife Monument into a national wildlife refuge as part of the National 

Wildlife Refuge System. ANILCA (§303[1]) created the Alaska Maritime National 

Wildlife Refuge by redesignating 11 pre-existing refuges as units of the new refuge and 

by adding other public lands on islands, islets, rocks, reefs, spires, and designated capes 

and headlands in the coastal areas and adjacent seas of Alaska. 

In 1983, the U.S. Fish and Wildlife Service (Service) decided to manage the Ugashik and 

Chignik units of Alaska Peninsula Refuge, the 9,900-acre Seal Cape area of Alaska 

Maritime Refuge, and Becharof Refuge as a “complex” because they shared resources 

and resource issues. Distance and weather create barriers to managing the Pavlof and 

North Creek units from the King Salmon office, and management of these units was 

shifted to the Izembek Refuge. 

The Becharof Wilderness Area of the Becharof Refuge was designated in 1980 by 

ANILCA (§702 [4]). 

Refuge Purpose(s) 

ANILCA sets out the purposes for each refuge in Alaska. The purposes of the Alaska 

Peninsula and Becharof National Wildlife Refuges are described in Section 302(1)(B) and 

Section 302(2)(B). Purposes for the Alaska Maritime National Wildlife Refuge are 

described in Section 303(1)(B). The purposes identify the reasons for which Congress 

established the Refuges and management priorities. 

ANILCA purposes are follows (unless otherwise noted, the purposes apply to all units of 

the Refuges): 

• to conserve fish and wildlife populations and habitats in their natural diversity 

including, but not limited to . . . 

[Becharof] . . . brown bears, salmon, migratory birds, the Alaska Peninsula 

Caribou herd, and marine birds and mammals 

[Alaska Peninsula] . . . brown bears, the Alaska Peninsula caribou herd, moose, 

sea otters and other marine mammals, shorebirds and other migratory birds, 

raptors, including bald eagles and peregrine falcons, and salmonids and other fish 

[Alaska Maritime] . . . marine mammals, marine birds and other migratory birds, 

the marine resources upon which they rely, bears, caribou and other mammals 
Appendix H: Compatibility Determinations: Scientific Research 

H-68 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

• to fulfill the international treaty obligations of the United States with respect to 

fish and wildlife and their habitats 

• to provide, in a manner consistent with the purposes set forth above, the 

opportunity for continued subsistence uses by local residents 

• [Alaska Maritime] to provide, in a manner consistent with the purposes set forth 

above, a program of national and international scientific research on marine 

resources 

• to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth above, water quality and necessary water quantity within the 

refuge 

[Supplemental Purposes of the Becharof Wilderness Area] The Wilderness Act of 1964 

(16 U.S.C. 1131-1136 § 2a), defines supplemental purposes of all designated wilderness 

areas. These apply to the Becharof Wilderness Area and are as follows: 

• to administer the wilderness for the use and enjoyment of the American people in 

such a manner as will leave it unimpaired for future use and enjoyment as 

wilderness, to provide for the protection of the area, for the preservation of its 

wilderness character, and for gathering and dissemination of information 

regarding its use and enjoyment as wilderness. 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network 

of lands and waters for the conservation, management, and, where appropriate, 

restoration of the fish, wildlife, and plant resources and their habitats within the United 

States for the benefit of present and future generations of Americans” (National Wildlife 

Refuge System Administration Act of 1966, as amended [16 U.S.C. 688dd-688ee]).

Description of Use(s) 

This compatibility determination addresses the full spectrum of uses associated with the 

scientific research of fish, wildlife, habitat, and other refuge resources. It includes all 

means of access, lodging, facilities, and other elements that would be included in a typical 

research proposal. The scope of this determination includes research conducted by all 

agencies or entities other than the Service and the Alaska Department of Fish and Game. 

Specific authorized means of access for all areas on the Refuges will be noted in each 

special-use permit. Potential means of access include fixed-wing aircraft, helicopter, 

motorboat, snowmachine, off-road vehicle, nonpowered boat, dogsled, foot, snowshoes, 

and cross-country skis. Potential lodging and facilities includes tents, tent frames, 

weatherports, existing cabins, and caches. 

A wide range of various research activities (e.g., biological, paleontological, volcanological 

and medicinal) have been conducted on the Refuges since their creation. Future activities 

would likely be dispersed and be of low magnitude. 

Availability of Resources 

Adequate refuge personnel and base operational funds are available to manage research 

activities at existing (generally no more than two requests per year) and projected levels. 

Administrative staff time (not more than five days) primarily involves phone 

conversations, written correspondence, proposal review, and personal interaction with 
Appendix H: Compatibility Determinations: Scientific Research 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-69 

researchers. Field work associated with administering the program primarily involves 

monitoring researchers’ compliance with the terms of the permit. 

Anticipated Impacts of the Use(s) 

Factors such as target species, number of researchers, transportation modes, number of 

aircraft and anticipated amount of aircraft use, fuel storage, garbage and human waste 

management, type and location of lodging, and location of access points will determine 

the extent of impacts on the Refuges. However, scientific research and associated 

activities should not have significant impacts on the wildlife resources, other refuge 

resources (e.g., water quality, soil, and vegetation), and other refuge users, especially 

subsistence users, because of the limited scope and the complete administrative oversight 

of research. 

Prior to initiating field work, the permittee must provide documentation that recognized 

Institutional Animal Care and Use Committee (IACUC) personnel have reviewed and 

approved (as required by the Animal Welfare Act) activities and proposed procedures 

involving invasive procedures or procedures that could harm or materially alter the 

behavior of an animal under study. 

For all projects proposed in the designated Becharof Wilderness Area, analysis of each 

proposal will be conducted to ensure compliance with the minimum-requirement 

philosophy to ensure that the project is essential to protect physical, biological, or 

experiential resources of the wilderness. In addition, minimum-tool analysis will be 

conducted to ensure that the methods and equipment have the least impact and are the 

least manipulative or restrictive means of achieving the research project. No research 

will be permitted that will significantly affect solitude or other wilderness values. 

Research concerning fish, wildlife, and other refuge resources is expected to contribute to 

Refuges purposes of conserving fish and wildlife populations and protecting resources of 

the refuges. 

Public Review and Comment 

The public was invited to comment on this compatibility determination and a number of 

other determinations during the public review period establised for the draft revised 

Comprehensive Conservation Plan. Public notice of the availability of the draft 

conservation plan and draft determinations was published in the Federal Register. The 

draft determinations were also posted on the Region 7 Refuge Conservation Planning 

and Policy Web pages. No substantive public comments pertaining to this determination 

were received. Where appropriate, comments addressing elements of the draft 

Comprehensive Conservation Plan revision that pertained to the specific uses evaluated 

in this determination were considered in preparing the final compatibility determination. 

Determination 

 Use is Not Compatible 

 X Use is Compatible 

Stipulations Necessary to Ensure Compatibility 

Refuge staff will monitor all research being conducted on the refuges. Findings from 

these monitoring efforts will be used to determine what additional management actions, if 
Appendix H: Compatibility Determinations: Scientific Research 

H-70 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

any, are needed to ensure that research activities remain compatible with refuge 

purposes. Monitoring of all authorized research activities will be continued to ensure 

compliance with specific terms and conditions tailored for each research project=s permit 

as well as with the following general conditions that are incorporated into all research 

permits to minimize impacts on refuge lands and resources. 

• Failure to abide by any part of this special-use permit; violation of any refugerelated provision in Titles 43 (Part 36) or 50(sub-chapters B and C), Code of 

Federal Regulations; or violation of any pertinent state regulation (e.g., fish or 

game violation) will, with due process, be considered grounds for revocation of 

this permit and could result in denial of future permit requests for lands 

administered by the U.S. Fish and Wildlife Service. This provision applies to all 

persons working under the authority of this permit. Appeals of decisions relative 

to permits are handled in accordance with Title 50 Code of Federal Regulations 

Part 36.41. 

• The permittee is responsible for obtaining appropriate collection permits from the 

State of Alaska, Department of Fish and Game, for research involving fish and 

wildlife. 

• The permittee is responsible for ensuring that all employees, party members, 

aircraft pilots, and any other persons working for the permittee and conducting 

activities allowed by this permit are familiar with and adhere to the conditions of 

this permit. 

• A copy of this permit must be in the permittee’s or field party chief’s possession 

at all times while exercising the privileges of this permit. 

• Any problems with wildlife and/or animals taken in defense of life or property 

must be reported immediately to the refuge manager and to the Alaska 

Department of Fish and Game; animals taken in defense of life or property must 

be salvaged in accordance with state regulations. 

• The permittee does not have the exclusive use of the site(s) or lands covered by 

this permit. 

• The use of Native or state lands that have been conveyed (patented) is not 

authorized by this permit. 

• Use of Native or state lands that have been selected but not yet conveyed is 

prohibited unless a letter of concurrence from the interested party is submitted to 

the refuge manager prior to beginning any activities allowed by this permit. 

• This permit may be canceled or revised at any time by the refuge manager in case 

of emergency (e.g., high fire danger, flooding, unusual resource problems etc.). 

• The permittee or party chief shall notify the refuge manager during refuge 

working hours in person or by telephone before beginning and upon completion of 

activities allowed by this permit. 

• Prior to beginning any activities allowed by this permit, the permittee shall 

provide the refuge manager with the following: (1) name and method of contact 

for the field party chief or supervisor; aircraft and other vehicle types to be used, 

identification information for these vehicles; and names of assistants (2) any 

changes in information provided in the original permit application. 
Appendix H: Compatibility Determinations: Scientific Research 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-71 

• The refuge manager, upon request, shall be afforded the opportunity and 

logistical support to accompany the permittee from the nearest commercial 

transportation site for the purpose of inspection and monitoring permittee 

activities. A final inspection trip provided by the permittee of the areas of use may 

be required by the refuge manager to determine compliance with the terms of 

this permit. 

• The permittee shall provide the refuge manager with a report of activities under 

this permit within 30 days of permit expiration. 

• In accordance with the Archaeological Resources Protection Act (16 USC 470aa), 

the excavation, disturbance, collection, or purchase of historical, recent, 

ethnological, or archaeological specimens or artifacts is prohibited. 

• Permittees shall maintain their use areas in a neat and sanitary condition. 

Latrines must be located at least 150 feet from springs, lakes, and streams to 

avoid contamination of water resources. All property (except cabins and/or tent 

frames) of the permittee must be removed from refuge lands upon completion of 

permitted activities. 

• All noncombustible waste materials must be removed from the refuge (not 

buried) upon the permittee’s departure. 

• The construction of landing strips or pads is prohibited. Incidental hand removal 

of rocks and other minor obstructions may be permitted. 

• The use of off-road vehicles (except snow machines), for other than subsistence 

purposes, is prohibited except in designated areas. 

• The operation of aircraft at altitudes and in flight paths resulting in the herding, 

harassment, hazing, or driving of wildlife is prohibited. It is recommended that all 

aircraft, except for take-off and landing, maintain a minimum altitude of 2,000 feet 

above ground level. 

• Fuel caches are prohibited. 

• Construction of cabins or other permanent structures is prohibited. 

• Activity will be curtailed if the Service does not have adequate staff, equipment, 

or supplies to ensure proper monitoring. 

Justification 

Natural and social science information is necessary for the proper management of units 

within the National Wildlife Refuge System. It is the policy of the Service (4 RM 6.1) to 

encourage and support research and management studies in order to provide scientific 

data upon which to base decisions regarding management of units of the refuge system. 

The Service will also permit the use of a refuge for other investigatory scientific purposes 

when such use is compatible with the objectives for which the refuge is managed. Priority 

will be given to studies that contribute to the enhancement, protection, use, preservation, 

and management of native wildlife populations and their habitats in their natural 

diversity. All proposed research conducted by other agencies or entities will be 

thoroughly evaluated prior to authorization and then monitored closely to ensure that the 

activities do not materially interfere with or detract from the purposes of the Refuges or 

the mission of the National Wildlife Refuge System. 

Appendix H: Compatibility Determinations: State of Alaska Management Activities 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-73 

COMPATIBILITY DETERMINATION 

Use: State of Alaska Management Activities

Refuge Name: Alaska Peninsula and Becharof National Wildlife Refuges, King Salmon, Alaska 

Establishing and Acquisition Authority(ies) 

In 1978, President Jimmy Carter established the 1,157,000-acre Becharof National 

Wildlife Monument with Presidential Proclamation 4613. The monument was established 

from lands in the public domain to protect the area, notably the unique brown bear 

denning islands in the Island Arm area of Becharof Lake. 

In 1980, the Alaska National Interest Lands Conservation Act (ANILCA) (§302) 

established the Alaska Peninsula National Wildlife Refuge and changed the Becharof 

National Wildlife Monument into a national wildlife refuge as part of the National 

Wildlife Refuge System. ANILCA (§303[1]) created the Alaska Maritime National 

Wildlife Refuge by redesignating 11 pre-existing refuges as units of the new refuge and 

by adding other public lands on islands, islets, rocks, reefs, spires, and designated capes 

and headlands in the coastal areas and adjacent seas of Alaska. 

In 1983, the U.S. Fish and Wildlife Service (Service) decided to manage the Ugashik and 

Chignik units of Alaska Peninsula Refuge, the 9,900-acre Seal Cape area of Alaska 

Maritime Refuge, and Becharof Refuge as a “complex” because they shared resources 

and resource issues. Distance and weather create barriers to managing the Pavlof and 

North Creek units from the King Salmon office, and management of these units was 

shifted to the Izembek Refuge to be managed out of Cold Bay. 

The Becharof Wilderness Area of the Becharof Refuge was designated in 1980 by 

ANILCA (§702 [4]). 

Refuge Purpose(s) 

ANILCA sets out the purposes for each refuge in Alaska. The purposes of the Alaska 

Peninsula and Becharof National Wildlife Refuges are described in Section 302(1)(B) and 

Section 302(2)(B). Purposes for the Alaska Maritime National Wildlife Refuge are 

described in Section 303(1)(B). The purposes identify the reasons why Congress 

established the Refuges and management priorities. 

The ANILCA purposes are as follows (unless otherwise noted, the purposes apply to all 

units of the Refuges): 

• to conserve fish and wildlife populations and habitats in their natural diversity 

including, but not limited to . . . 

[Becharof] . . . brown bears, salmon, migratory birds, the Alaska Peninsula 

Caribou herd, and marine birds and mammals 

[Alaska Peninsula] . . . brown bears, the Alaska Peninsula caribou herd, moose, 

sea otters and other marine mammals, shorebirds and other migratory birds, 

raptors, including bald eagles and peregrine falcons, and salmonids and other fish 
Appendix H: Compatibility Determinations: State of Alaska Management Activities 

H-74 Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan 

[Alaska Maritime] . . . marine mammals, marine birds and other migratory birds, 

the marine resources upon which they rely, bears, caribou and other mammals 

• to fulfill the international treaty obligations of the United States with respect to 

fish and wildlife and their habitats 

• to provide, in a manner consistent with the purposes set forth above, the 

opportunity for continued subsistence uses by local residents 

• [Alaska Maritime] to provide, in a manner consistent with the purposes set forth 

above, a program of national and international scientific research on marine 

resources 

• to ensure, to the maximum extent practicable and in a manner consistent with the 

purposes set forth above, water quality and necessary water quantity within the 

refuge 

[Supplemental Purposes of the Becharof Wilderness Area] The Wilderness Act of 1964 

(16 U.S.C. 1131-1136 § 2a), defines supplemental purposes of all designated wilderness 

areas. These apply to the Becharof Wilderness Area and are as follows: 

• to administer the wilderness for the use and enjoyment of the American people in 

such a manner as will leave it unimpaired for future use and enjoyment as 

wilderness, to provide for the protection of the area, for the preservation of its 

wilderness character, and for gathering and dissemination of information 

regarding its use and enjoyment as wilderness. 

National Wildlife Refuge System Mission 

The mission of the National Wildlife Refuge System is “to administer a national network 

of lands and waters for the conservation, management, and, where appropriate, 

restoration of the fish, wildlife, and plant resources and their habitats within the United 

States for the benefit of present and future generations of Americans” (National Wildlife 

Refuge System Administration Act of 1966, as amended [16 U.S.C. 668dd–668ee]).

Description of Use(s) 

This compatibility determination addresses routine management activities conducted by 

the Alaska Department of Fish and Game that may not be encompassed by the Master 

Memorandum of Understanding between the Alaska Department of Fish and Game, 

Juneau, Alaska, and the U.S. Fish and Wildlife Service, Department of the Interior, 

Anchorage, Alaska, signed March 13, 1982, and law enforcement activities conducted by 

Alaska Department of Public Safety Fish and Wildlife Protection Officers. This includes 

the following activities: fish and wildlife surveys conducted by boat, foot, or other means 

not restricted by regulation or policy; aircraft landings in support of aerial fish and 

wildlife surveys; vegetation and habitat classification and surveys; and law-enforcement 

activities. This compatibility determination does not address predator management, fish 

and wildlife control (with the exception of emergency removal of individual rogue 

animals), reintroduction of species, nonindigenous species management, pest 

management, disease prevention and control, fishery restoration, fishery enhancement, 

indigenous fish introductions, nonindigenous species introductions, construction of 

facilities, or any other nonpermitted activity that could alter Refuges’ ecosystems.

Separate compatibility determinations addressing specific proposals will be required for 

those activities. All management and research activities conducted by the Alaska 
Appendix H: Compatibility Determinations: State of Alaska Management Activities 

Alaska Peninsula and Becharof NWR Comprehensive Conservation Plan H-75 

Department of Fish and Game under a specific cooperative agreement with the Fish and 

Wildlife Service to fulfill one or more purposes of the refuge or the National Wildlife 

Refuge System mission are not subject to a compatibility determination. 

Potential means of access include fixed-wing aircraft, helicopter, motorboats, 

snowmachines, off-road vehicles, nonpowered boats, dogsled, foot, snowshoes, and crosscountry skis. Potential lodging and facilities include tents, tent frames, tent platforms, 

weatherports, existing permitted cabins, and caches. 

Availability of Resources 

Adequate refuge personnel and base operational funds are available to manage activities 

at existing and projected levels. Administrative staff time (as many as 10 staff days 

annually) primarily involves phone conversations, written correspondence, and personal 

interaction with state personnel regarding ongoing activities. Field work associated with 

administering the program primarily involves monitoring (when applicable) the state’s 

activities to ensure all activities are compatible with the Master Memorandum of 

Understanding. 

Anticipated Impacts of the Use(s) 

Because ADF&G and Public Safety personnel are trained professional, we anticipate that 

routine law-enforcement and fish and wildlife–monitoring and –management activities 

will have positive overall impacts on the wildlife resources, other refuge resources (such 

as water quality, soil, and vegetation), and refuge users. These positive impacts will 

support refuge purposes and goals and the Service mission. 

For all projects proposed in the designated Becharof Wilderness Area, analysis of 

projects will be conducted to ensure compliance with the “minimum-requirement”

philosophy to ensure that the project is essential to protect physical, biological, or 

experiential resources of the wilderness. In addition, “minimum-tool” analysis will be 

conducted to ensure that the methods and equipment have the least impact and are the 

least manipulative or restrictive means of achieving the project. 

Public Review and Comment 

The public was invited to comment on this compatibility determination and a number of 

other determinations during the public review period establised for the draft revised 

Comprehensive Conservation Plan. Public notice of the availability of the draft 

conservation plan and draft determinations was published in the Federal Register. The 

draft determinations were also posted on the Region 7 Refuge Conservation Planning 

and Policy Web pages. No substantive public comments pertaining to this determination 

were received. Where appropriate, comments addressing elements of the draft 

Comprehensive Conservation Plan revision that pertained to the specific uses evaluated 

in this determination were considered in preparing the final compatibility determination. 

Determination 

 Use is Not Compatible 

 X Use is Compatible