Citizens’ Bristol Bay Area Plan

Public Review Draft – May 2013

Leave a comment about the Citizens’ Alternative at the bottom of this page.

We also encourage you to learn about the State Plan and urge you to SUBMIT A COMMENT asking the state to give serious consideration to proposals contained in the Citizens’ Alternative Bristol Bay Area Plan for State Lands.

Citizens' Alternative Bristol Bay Area Plan Bay



For Display Use Only No Permission to Reproduce in Any Form

The State of Alaska owns about twelve million acres of land in the Bristol Bay drainages. In Alaska, Area Plans guide state land use decisions such as whether to allow development like the proposed Pebble mine on those state lands. Area plans were put in place to help ensure that State land management decisions achieve sustained use of renewable resources, keep a balance between development and environmental concerns, and protect public access and use to state land and its resources. State agencies take the plan into account when deciding whether or not to approve the use of specified areas of state lands for particular activities or development, and regulators take it into account when considering permits for activities or development that does occur.

The first area plan for Bristol Bay was adopted in 1984. It emphasized protecting fish and wildlife habitat, as well as hunting and fishing.

In 2005 the Alaska Department of Natural Resources (DNR) revised the Bristol Bay Area Plan (BBAP). The 2005 plan was drastically different from the 1984 plan. It eliminated nearly all prior classifications of land for habitat and for hunting and fishing and classified land with mineral deposits as solely mineral land. This included the land at the Pebble deposit. Under this plan, mineral development like the proposed Pebble mine does not have to be compatible with habitat or public hunting and fishing, including subsistence.

The 2005 BBAP made mining and mineral exploration the only designated use on 9.4 million acres within Bristol Bay’s drainages – nearly 80% of the state-owned land in the region. This transformed habitat, subsistence, and recreation into “prohibited uses” whenever they conflict with mining or mineral exploration.

Out of concern that the 2005 BBAP did not strike the right balance to protect subsistence and fish and wildlife, six Bristol Bay Tribes and commercial and sport fishing organizations sued the Alaska Department of Natural Resources over the 2005 BBAP changes. To settle this litigation, the State agreed to revise the 2005 Plan. The State’s review and revision process has now begun. The official comment period ends on May 6, 2013.



Plaintiffs from the original lawsuit have gathered input from Bristol Bay residents and created the Citizen’s Alternative Bristol Bay Area Plan. The Citizens’ Alternative is an unusual “public comment” that offers a new and better plan for the region. We developed it because after the 2005 BBAP used marine criteria to exclude inland habitat far from the coast, defined recreation as excluding sport hunting and fishing, and used navigability as a criterion to designate anadromous streams as habitat, we have concluded that the Citizens’ Alternative Plan is the best way to proceed.

Letter to the Alaska Department of Natural Resources

The Citizens’ Alternative offers a better vision of the BBAP that is embraced by stakeholders. It rests upon these core principles:

1. The Citizens’ Alternative relies on science and better mapping to designate primary uses and improve public participation.

The Citizens’ Alternative contains GIS maps depicting essential and important habitat, and subsistence and sport hunting and fishing use areas, as reflected in data from ADF&G, DNR and other sources. In contrast, DNR’s 2005 BBAP did not contain a single map of any habitat type or subsistence or recreation use areas. DNR’s 2013 proposed amendments contain only one habitat map, and it is for moose. The lack of such maps departs from the previous 1984 BBAP, frustrates meaningful public participation, and leads to inconsistent results. For example, DNR proposes to designate some moose wintering areas as habitat, but not those near Pebble in the Upper Talarik Creek. Our reliance on maps avoids inconsistent, subjective judgments that lack foundation in the record and appear to be arbitrary.

Unlike DNR’s approach, the Citizens’ Alternative justifies each designated use and corresponding classification using maps to avoid confusion and fully inform the public. We hope DNR will adopt this approach. To do otherwise hinders management decisions and frustrates the public process

 2. The Citizens’ Alternative is consistent with the vision statement of the Bristol Bay Visioning Project and the history of state, federal, local and tribal efforts to balance conservation and development in the Bristol Bay drainages.

The Citizen’s Alternative is consistent with the vision statement adopted by the Bristol Bay Visioning Project. It was a multi-year project of the Bristol Bay Native Association, Bristol Bay Native Corporation, Bristol Bay Economic Development Corporation, Bristol Bay Housing Authority, and Bristol Bay Area Health Corporation. The vision statement seeks: to protect subsistence; to protect salmon, other fish, wildlife, waters and renewable resources; to protect and encourage a local economy based upon renewable resources; and to allow non-renewable resource development that doesn’t threaten the above.

The Citizens’ Alternative is also consistent with past state, federal, local and tribal efforts to balance conservation and development in the Bristol Bay drainages and to conserve the Kvichak and Nushagak drainages in particular. In fact, DNR’s historical record makes it crystal clear that the State acquired the lands at the Pebble deposit, not by selection under the Statehood Act as it often claims, but by land exchange in order to protect fish.

 See the BBAP Timeline for further detail

 3. The Citizens’ Alternative improves area-wide management guidelines.

The Citizens’ Alternative significantly revises the area-wide guidelines to ensure that habitat, recreation, and subsistence are protected. Some of the revisions are:

• an automatic instream flow protection for salmon

• use of the “precautionary principle” when making any land use decisions that may significantly impact salmon

• a presumption that all waters in the Bristol Bay region are anadromous

• prohibition of metallic sulfide mining in the Nushagak and Kvichak watersheds

• a new mineral closing order that would ban new mining claims on or along salmon spawning streams potentially threatened by mining

For more information read these handouts:

Bristol Bay Area Plan Balance

Bristol Bay Area Plan DNR’s 2005 Plan


If you wish to leave a comment about the Public Review Draft of the Citizens’ Alternative you may do so by email to the land trust or by leaving a comment below.


  1. Rick and Barbara Jones says:

    We have reviewed the State’s 2005 Bristol Bay Area Plan and the proposed amendments. We would like to remind the State to consider recreational fishing and protecting the rivers, streams and lakes that make Alaska what it is, one of the world’s last frontiers for wildlife and nondestructive recreational use. We have lived all over the world and have seen beautiful landscapes void of wildlife, and littered with evidence of human’s need for monetary success. We visit our son in Alaska twice a year and enjoy the opportunity to visit unspoiled wild land. Please consider The Citizen’s Alternative as it includes many of the reasons why we visit Bristol Bay and all parts of Alaska.

  2. Joe McCullough says:

    I reviewed the State’s 2005 Bristol Bay Area Plan and the proposed amendments and at the risk of being cynical was disappointed but not surprised. The plan doesn’t seem to address the publics wishes at all. I wish the State would consider the many interests/viewpoints expressed in this process when developing the Bristol Bay Area Plan. I do support the Citizens’ Alternative Bristol Bay Area Plan and wish I could believe that the State had Alaskan’s interests in mind but we are talking about a commissioner that wanted to change his agency’s mission statement so he could mine Alaska until it was barren and a governor that no longer cares what his constituents think now that he has been re-elected and will tell us what we want to hear and do whatever he wants. I really can’t believe (well maybe I can) that the State won’t at least be transparent and offer maps to let the public know more about how they plan to use the land.

  3. Cory Luoma says:

    I have reviewed the State’s 2005 Bristol Bay Area Plan and the proposed amendments. I would recommend the State consider a broader approach to the Bristol Bay Area Plan. I have also reviewed the Citizens’ Alternative Bristol Bay Area Plan, and I endorse its approach for managing state lands. The State’s plan places too little emphasis on recreational fishing and protecting the rivers, streams and lakes that support this established multi-million dollar segment of Bristol Bay’s local economy. The Citizen’s Alternative, while not perfect, does a much better job of addressing the reasons why I work in and visit Bristol Bay.

Leave a Comment