What Is the Proposal?
Instream flow reservation regulations allow water to remain in rivers, streams, and lakes to support fish habitat and other public values. The Alaska Department of Natural Resources (DNR) is considering changes to the state’s instream flow reservation regulations, known as 11 AAC 93.
While DNR has stated that the proposed changes are intended to improve efficiency, many revisions would make it even more difficult and expensive for Alaskans, Tribes, watershed groups, and conservation organizations to secure and maintain instream flow reservations that protect salmon habitat.
Changes would include:
- Five-Year Data Set: Applicants would be required to provide at least 5 years of monthly data, along with detailed information on fish, habitat, and land ownership.
- Reservation Ownership: If a Tribe, nonprofit, community group, or individual is successful in their application, DNR, not the applicant, would hold the certificate.
- Monitoring: DNR could require measuring devices, monitoring, and reporting.
- Cost Burden: DNR could assign the costs of extra research and data collection to the applicant or certificate holder.
Why Does It Matter?
Alaska’s wild salmon depend on clean, cold water. Instream flow reservations are among the few tools available to ensure that enough water remains in rivers and streams for salmon to spawn, rear, and migrate.
Current regulations already place a significant burden on those seeking to protect water for fish. If a corporation wants to withdraw water from a stream, it can apply for a water right and ask the state to determine whether that use is in the public interest. But Alaskans seeking to reserve water for salmon often must conduct extensive studies, collect years of data, and navigate a lengthy regulatory process before water can be legally protected.
That imbalance becomes more concerning as Alaska faces increasing pressure from development and climate change. Scientists project that air and stream temperatures will continue to rise across the state, making cold-water habitat even more important for salmon survival.
Rather than create new barriers to protecting water, Alaska should act now to make it easier for communities to safeguard important salmon streams and ensure that those seeking to remove water from fish habitat demonstrate that their actions will not cause undue harm.
How to Write Your Comment Today
DNR is accepting public comments on the proposed regulations through June 30, 2026. This is a critical opportunity to speak up now for healthy salmon streams and a fair water management system.
When writing your comment, start with why this matters to you. Share how you use these waters or why healthy rivers and salmon matter to you, then consider addressing the following points:
- Wild salmon need sufficient water to spawn, rear, and migrate.
- Rising air and stream temperatures will make healthy instream flows even more important in the future.
- The current instream flow reservation process is already costly and time-consuming.
- Regulations should reduce barriers to protecting fish habitat, not create new ones.
- The burden of demonstrating that water withdrawals will not harm fish habitat should fall on those seeking to remove water from streams, not on members of the public trying to protect salmon.
Submit Your Comment
Online Comment Portal:
Email:
dnr.water.regulation@alaska.gov
Mail:
Alaska Department of Natural Resources
Division of Mining, Land & Water
Program Support Section
Attn: Brandon McCutcheon
550 W. 7th Avenue, Suite 1070
Anchorage, AK 99501-3579
Questions about the proposed regulations must be submitted by June 20, 2026, at 5:00 PM.
For accommodations, contact Brandon McCutcheon by June 20, 2026, at dnr.water.regulation@alaska.gov or 907-269-8511.
Short on time? A short comment in your own words carries the most weight. If you’re short on time, our friends at Susitna River Coalition have created a comment builder that lets you quickly highlight the issues you care about most and personalize your comment in minutes. Try it out here.
Want to learn more? Susitna River Coalition hosted Michael Lilly of Geo-Watersheds Scientific for a 45-minute webinar on water reservations in Alaska. This recording provides useful background on how water reservations work and why they are an important tool for protecting instream flows for salmon, wildlife, and public use.
Watch the webinar: https://www.youtube.com/watch?v=Y7CRm8ao5u8