The potential for damage to fish habitat from the mining of sulfide mineral deposits like Pebble is a recognized fact. Addressing this risk to Bristol Bay's salmon habitat presents a large hurdle for permitting the Pebble mine. The Pebble Partnership has long stated that “development of Pebble should be based on the established, stringent regulatory process and sound science, not politics. Pebble's CEO John Shively said, “If it’s a choice between fish and mining, we go away.”

The Bristol Bay Area Plan (BBAP) adopted in 1984 reflected the policy of multiple-use by co-classifying most state lands in Bristol Bay as habitat / public recreation / mineral land, and required that any mineral development be compatible with habitat and public recreation. Less than 2 percent of state land was permanently closed to mining to protect salmon streams.

Evidently, the Murkowski administration was unwilling to leave the fate of the mine up to the existing state process, so in 2005, the Alaska Dept. of Natural Resources changed the basic planning document — the BBAP. The 2005 BBAP rewrite eliminated most prior classifications of land for wildlife habitat, hunting, and fishing, and made mining and mineral exploration the only designated use on nearly 80 percent of the state land in Bristol Bay. It simply ignored the value of salmon habitat in the watersheds directly in the way of the Pebble Mine. In a bald display of politics trumping due process, DNR moved the goal posts. 
In 2009, six Bristol Bay tribes and commercial and sport fishing organizations sued the DNR over the 2005 BBAP changes. To settle this litigation, the state agreed to revise the 2005 plan. The State’s revision process is now under way.

DNR has published its Public Review Draft, Bristol Bay Area Plan Amendment 2012 http://dnr.alaska.gov/mlw/planning/areaplans/bristol/amend/, for public comment. The comment period has been extended to May 6.

A significant lapse in the draft plan is its failure to include non-navigable streams as fish habitat, thus meshing neatly with the Pebble Partnership's assertion that its project would only impact 1 precent of Bristol Bay's watersheds.

Plaintiffs from the original lawsuit have submitted the Citizen’s Alternative Bristol Bay Area Plan to DNR. Their plan seeks to hold the BBAP to the requirements of state law, and recommends using modern GIS technology with broad agency and public input to accurately classify state lands and waters. You can read their plan and learn more about the issue online at www.savebristolbay.org/bbap.

DNR's revised plan will be the basis for state land and water management in Bristol Bay for the next 20 years. Please send your comments on the BBAP to Ray Burger, Alaska DNR, Division of Mining, Land and Water, 550 West 7th Ave, Suite 1050, Anchorage, AK 99501-3579.

You can submit comments by email at dnr.bbapamend@alaska.gov.

On March 24-26, DNR plans to hold public meetings in Bristol Bay communities to get input on its proposed changes. To request that DNR plan a meeting in Kodiak, call Marty Parsons, deputy director of the Division of Mining, Land and Water, at 907-269-8532.

Rolan Ruoss is a member of the Kodiak Fish and Game advisory committee and a floatplane pilot.

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