Public Notice: 60 Day Comment Period on DEC Permits for Donlin Gold Project

The Alaska Department of Environmental Conservation (DEC) Wastewater Discharge Authorization Program has begun a 60 day public comment period for the issuance of: An Alaska Pollutant Discharge Elimination System (APDES) Individual Permit to Discharge to Waters of the United States and Waste Management Permit (WMP) for the Donlin Gold Project.

Tentative Determination:  DEC has tentatively determined to issue an APDES and WMP permits for the activity described in the permit application.

 See documents below for additional detail and how to submit your comments.



Deadline for Public Comments on the Donlin Gold DEIS Closes May 31.

Donlin Gold DEIS (Part2)

The purpose of this assessment of the Donlin DEIS is to provide additional information to consider when formulating public comments on primarily the proposed action (Alternative 2) in the DEIS.  At this phase in the NEPA process the Army Corps of Engineers (ACOE)  is seeking what are considered “substantive” public comments on the DEIS. As a reminder the ACOE considers substantive comment as:

“Those that suggest the analysis is flawed in a specific way. Generally they challenge the accuracy of information presented, challenge the adequacy, methodology or assumptions of the environmental or social analysis (with supporting rationale), present new information relevant to the analysis, or present reasonable alternatives (including mitigation) other than those presented in the document.”

The public comment period closes May 31, 2016 by COB, and can be emailed directly to:  or Fax comments to 907-753-5567.

Comments can be mailed to:

Keith Gordon, Project Manager

U.S. Army Corps of Engineers, Alaska District

CEPOA-RD-Gordon, P.O. Box 6898

JBER, AK, 99506-0898.

Please note: Comments sent via email, including all attachments, must not exceed a 25-megabyte file size per email. Please include in your comments your name, address, and affiliation (if any).

The following are areas of concern encountered in my review of the DEIS that we believe warrant additional study and/or discussion by the ACOE under NEPA guidelines, and should be addressed in a revised DEIS or in the final EIS:

  1. Hydrological modeling: The uncertainty associated with this model related to the permeability “K Factor” (low K = low permeability, high K = high permeability) of the substrates and bedrock underlying Crooked Creek is significant, specifically in the lower reaches. This modeling provides the foundation for subsequent assessments evaluating impacts to aquatic habitats, species, and fisheries.
  1. Modeled groundwater depletion and its effects on aquatic habitat: This evaluation is based on an integrated model (surface and ground water) which does not specifically evaluate the scenario of a high K Factor during baseflows conditions.
  1. Salmon productivity: The analysis is based on the proportion of salmon escaping past the weir on Crooked Creek relative to established salmon escapement goals for tributaries of the Kuskokwim River. The values presented in the DEIS cite incorrectly the number of established tributary escapement goals and therefore presumably also the aggregated numbers. Additionally, the presumption that this type of comparison (proportional abundance) is the only representative measure of salmon productivity does not reflect the best available science or current fisheries management practices and policy.
  1. Essential Fish Habitat (EFH): The EFH assessment was prepared by a private contractor who is required to consult with the NMFS. One of the requirements is that the EFH assessment must include the federal agency’s view of the effects (not the contractor’s) of the proposed action. No such assessment was included in the EFH assessment, or the DEIS.  The methodology used in the assessment did not take into consideration the high K scenario. Individual stream reaches were evaluated separately without consideration of cumulative effects. The conclusions of minor to no effects to EFH are flawed and directly contradict other assessments with no explanations provided.
  1. Cumulative Effects Assessment: The cumulative effects assessment in the DEIS does not adequately address active mining claims near the proposed project. Approximately 100 sq miles of active claims occur along a 100 mile long, by 20 mile wide corridor extending from the proposed mine site to Takotna: including active Donlin claims in the George River watershed, less than 50 miles to the NE. Future development of these claims either by Donlin or some other Claimant is a reasonably foreseeable future action, or possibly even a connected action if the infrastructure developed by Donlin for the proposed mine is utilized in anyway.
  1. Subsistence: The DEIS present two assessments of the impacts to subsistence; the ACOE assessment with a conclusion of only minor impacts, and the BLM 810 analysis which concludes that there will be significant restrictions to subsistence uses. The DEIS fails to provide any explanation of, or discussion on the two contradictory findings.

Hydrogeology Modeling

Groundwater hydrology is described in Chapter 3, section. 3.6 in the DEIS. The existing conditions and associated impacts for each of the alternatives is based on modeling well, bore hole, surface hydrology, and geologic data collected at various locations throughout the proposed project site, primarily at a local scale.  The purpose of the hydrological modeling is stated on page 3.6-13 in the DEIS:

“A three-dimensional mathematical model of the groundwater flow system in the vicinity of the proposed mine pit and process facilities area has been constructed by BGC (2011d, h, i, 2014g, c) in order to accomplish the following primary goals:

  • Better understand pre-mining groundwater flow through the region;
  • Plan mine dewatering facilities;
  • Estimate the potential effects of the proposed mine on flow in local surface water, in particular Crooked Creek;
  • Estimate the effects of proposed tailings storage on groundwater flow;
  • Estimate the amount of groundwater that would be collected by the proposed tailings storage facility (TSF) underdrain and seepage collection systems; and
  • Estimate the amount of time it would take for the pit lake to fill after mining.”

Under NEPA requirements the ACOE is required to ensure the scientific integrity of all discussions and analyses presented in the DEIS, providing a “full and fair” discussion on the environmental effects of any proposed actions.  Given that the hydrological modeling and more specifically the groundwater model is a fundamental component to evaluate the effects of many of the major aspects of the project, getting it “right” is imperative.

The DEIS states on page 3.6-25, emphasis added:

 “The effects of pit dewatering on Crooked Creek are largest in the winter when streamflow is most supported by groundwater as baseflow. The base case groundwater model that simulates the mine scenario (see Section predicts that some flow of Crooked Creek would be diverted to the pit dewatering system through stream leakage and groundwater flow. Sensitivity analysis simulations (see discussion below in this section) suggest that prediction of the amount of streamflow depletion is difficult.”

Furthermore the DEIS goes on to state on page 3.6-30, emphasis added:

“Using the integrated modeling approach, and examining the 10th percentile low flow and high hydraulic conductivity scenario, Crooked Creek is expected to go dry above American Creek during the low flow  season (Table 3.5-26 in Section 3.5, Surface Water Hydrology). Under this scenario and compared to the low flow base-case hydraulic conductivity scenario, the maximum summertime predicted reduction in flow increases from 26 percent to 61 percent and the annual average predicted reduction in flow increases from 22 percent to 46 percent. This verifies that the hydraulic conductivity of the bedrock aquifer is an important parameter of the model. Use of the base case results, even though they remain probable, should include consideration that other potential outcomes of the model, some quite different, are plausible. This is because bedrock hydraulic conductivity tends to vary from place to place by about three orders of magnitude and model projections based on a single realization of these values at or near the mean values have significant uncertainty.

Similarly, a second sensitivity analysis was conducted that simulates hydraulic conductivity zones associated with known faults. Observations in the areas of the faults have not indicated that these faults exhibit high hydraulic conductivity and the base case model did not assign values to faults any different than the surrounding rock. Conceptually, this scenario evaluates the situation where faults subcrop beneath Crooked Creek and extend for some distance away from the creek. Similarly to the high-hydraulic conductivity analysis described above, the calibration worsens under this scenario. The maximum percent reduction in flow of Crooked Creek at Station CCBO during wintertime increases from 30 percent to 83 percent of flow under this scenario. The maximum summertime reduction in flow increases from 9 percent to 16 percent and the maximum average reduction in flow increases from 20 percent to 49 percent.”

Based on the sensitivity analysis, and the uncertainty associated with modeling groundwater flux throughout the project site the DEIS concludes on page 3.6-30, emphasis added:

“Together, these scenarios demonstrate that the model results showing impacts to Crooked Creek should be regarded as uncertain and that the analysis of project effects should include scenarios other than the base case (e.g., the sensitivity analyses described above). Should most or all of the water (at least during winter) in Crooked Creek be diverted by groundwater conditions similar to these sensitivity analysis scenarios, the loss of streamflow and creek habitat could be of high magnitude and extend to a more regional distance downstream (but still limited by the mouth of Crooked Creek). The effect would be long-term, lasting as long as the dewatering system is active during mine operations and with gradually declining impacts, through the closure period as the groundwater system recharges.”  

Despite the precautions mentioned by the analysts that developed the groundwater model the DEIS summarizes the impacts to groundwater hydrology in Table 3.6-4, as minor to moderate.  This conclusion appears to be arrived at by only considering the dewatering that will potentially occur around the open pit site, i.e. at a local scale.  However, the model authors clearly state that under a low flow, high hydrologic conductivity (High K) scenario the effect could be observed at a more regional scale, possibly extending to the mouth of Crooked Creek.

Rationale provided in the DEIS to explain why the ACOE chose to consider the precautionary recommendation for some of the impacts i.e. magnitude or intensity, but not others, i.e. the scope of the dewatering being limited to just around the pit site as described on page 3.6-42 is unclear, but addressed in the footnote at the bottom of Table 3.6-4 which states:

“The summary impact rating accounts for impact reducing design features proposed by Donlin Gold and Standard Permit Conditions and BMPs that would be required. It does not account for additional mitigation or monitoring and adaptive management measures the Corps is considering.”

Given the stated uncertainty in the groundwater model a reviewer is not able to determine if, and or how these “design features, standard permit conditions, and BMP’s “would mitigate impacts to groundwater hydrology, and to what degree.  The ACOE proposed further mitigation to address this data gap, specifically on page 3.6- 44-45 the ACOE suggested:

“As a result of the recognized uncertainty of model results, the groundwater flow model should be reexamined 3 years after the commencement of pit dewatering to minimize uncertainty about dewatering effects, with a 5-year review frequency thereafter, or when noteworthy unexpected conditions are encountered. Unexpected conditions should be used to revise projections and adjust management plans as needed. As required by permit conditions, relevant groundwater data such as production rates and water table levels) should be collected as mining progresses to facilitate model revisions;”

Again, it is unclear how requiring additional monitoring and adaptive management practices would mitigate groundwater impacts. Presumably a revised model with less uncertainty would provide a better understanding of the groundwater flux throughout the project site and the impacts from proposed actions. However, given the possibility that the magnitude and scope of impacts could be significantly greater than those presented in the DEIS (as suggested by some subject matter experts, Myers Memo 2016) it is uncertain that simply modifying management plans would be sufficient mitigation. It is more likely that should significant differences in groundwater flux be revealed that corresponding significant changes to the project design would also be required to mitigate the impacts. Without adequate consideration of this potential in the DEIS or FEIS, the decision to approve permitting of the project by the ACOE based on the current understanding of groundwater flux would appear to be pre-decisional.

The technical aspects of the groundwater model are complex, and in reality, the validity of the model can only be fairly evaluated by subject matter experts.  The numeric model was prepared by an independent contractor and provided to the ACOE for inclusion in the DEIS, stating in the DEIS that the modeling met industry standard. However, given the stated uncertainty in the model and the fundamental role it plays in the evaluation of impacts and consideration of alternatives a third party independent peer review of the model should have been conducted and provided in the FEIS, or a supplemental DEIS.

To our knowledge only one such review by a qualified expert has been conducted, by a Dr. Tom Myers under commission by the Northern Alaska Environmental Center. Dr. Myers Technical Memorandum “Review of the Draft Environmental Impact Statement for the Donlin Gold Project” provides a comprehensive review of the numerical groundwater model. His comments regarding the model presented on page 28-43 of the memo are incorporated by reference into this document, and included as an appendix.

It is our belief to provide a “full and fair” discussion on the environmental effects of the proposed actions, and allow the reviewer to make a “reasoned choice” among alternatives the ACOE must conduct, and provide the results from an independent peer review of the numerical groundwater model used in the DEIS, prior to the release of the FEIS.

Ground and Surface Water Depletion and its Effects on Aquatic Habitats

The assessment of impacts to aquatic habitats begins on page 3.13-81 of the DEIS.  The section on assessment of changes in streamflow and its effects is unnecessarily confusing. The information was analyzed and presented in such a way that did not allow for direct comparison of the estimated reductions in habitat (Table 3.13-27 and 28) to the descriptions beginning on page 3.13-93, or the summary impacts shown in Table 3.13-30.  This confusion results from the different assumptions about the degree of dewatering used in the various analyses.  An example of this incongruence from the DEIS (page 3.13-96) is illustrated below, emphasis added:

“As shown in Table 3.13-28, the number of off-channel units and corresponding areas connected to the main channel relative to estimates of total off-channel habitat surface area were calculated for baseflow conditions minus 16 percent, at baseflow, and at increasing levels of flow representing 25, 50, 75, and 100 percent of bankfull stage (OtterTail 2012e).”

And, from page 3.13-94:

“During Year 20 of operations, the maximum winter flow reductions in stream reaches near the mine site and in lower Crooked Creek would vary from:

85-100 percent in March based on a low flow year and High K scenario; flows would be reduced by 85 percent at Crevice Creek, 40 percent below Getmuna Creek, and 31 percent below Bell Creek.”

Additionally the DEIS goes on to summarize the impacts of reduced streamflow and Mainstem Aquatic Habitats and states that the analysis presents the “most conservative case”. This clearly is not the case, since the DEIS then goes on to say the High K scenario was not considered in the analysis which,  as shown above would represent the most conservative case,  page 3.13-98, emphasis added:

“Estimates of Crooked Creek habitat loss were predicted based on Year 20, monthly 10-year low flow projections (Table 3.13-27). As described in the sections below, estimates for summer and winter low-flow scenarios provide a high-end (most conservative case) estimate of potential aquatic habitat loss as a result of proposed project operations (however, they did not predict habitat losses corresponding to High K scenario flow reductions).”

This use of different assumptions occurred consistently throughout most of the analysis presented in section 3.13 of the DEIS.  This results in summary impact (Table 3.13-30) conclusions that run the full range of possibilities, i.e. from negligible to major for the same components at the same locations, which is effectively meaningless without proper context.  This then leaves it up to the reviewer to decide which scenario is most appropriate to use, but (as discussed previously) the DEIS provides no basis of direct comparison between scenarios.

The issues discussed in the previous section regarding the uncertainty associated with the groundwater model are obviously the major contributing factor to the previous discussion.  We believe that until those issues are satisfactorily resolved, and a reanalysis and conclusions (based on consistent assumptions) are provided a rational evaluation of the potential impacts to fish and aquatic resources is not possible.

Salmon Productivity

The assessment of streamflow reductions in Crooked Creek and its tributaries on salmon productivity (beginning on page 3.13-108) is conceptually inadequate.  In addition to suffering from the same issues raised in the previous two sections: it also limits the scope of the analysis to only the abundance of Crooked Creek salmon populations(s) within the context of the overall Kuskokwim Basin salmon population(s).

It is recognized by fisheries scientists that salmon “productivity” is not strictly a numbers game, but that biological diversity also plays a critical role in the long term sustainability of fish populations, and is inherent in any assessment of “productivity”.  Lichatowich and Williams said it best in their 2015 report to the Bering Sea Fisherman’s Association titled: A Rationale For Place-Based Salmon Management:

“Genetic diversity, life history diversity, and population diversity are ways salmonids respond to their complex and connected habitats. Those factors are the basis of salmonid productivity and contribute to the ability of salmonids to cope with environmental variation that is typical of freshwater and marine environments.”

Furthermore, in a combined analysis for Chinook salmon in the AYK region, particularly the Kuskokwim, McPhee et al. (2009), Waples (2009), and Utter et al. (2009) recommended that Chinook salmon to be managed at a local population level to preserve biological diversity.

Sustained productivity of salmon has been shown to be possible only if genetic diversity and population structure are maintained (NRC 1996; Hilborn et al. 2003). Only a few studies specific to the genetic diversity of Kuskokwim Chinook salmon have been conducted, and none included the Crooked Creek population. One of the conclusions reached by researchers, Templin, et al. (2004) when looking at the genetic diversity of Kuskokwim salmon was:

“Significant population structure exists among populations of Chinook salmon from the Kuskokwim Management Area. In particular, populations spawning upriver of the confluence with the Holitna River are particularly genetically divergent, both within and between populations.”

In another study, Olsen et al. (2004) evaluating the effective population sizes of Kuskokwim River tributaries with small populations of Chinook salmon writes:

“Maintaining genetic diversity is necessary for maintaining healthy, viable populations. This tenet of conservation is most relevant for populations that are small or are experiencing significant declines in abundance. Small populations are of particular concern because loss of genetic diversity is inversely proportional to population abundance. In this context, abundance refers to the effective size of the population (Ne), not the census size (N), and theory suggests genetic diversity is lost at a rate equal to 1/(2Ne) per generation. Thus, the Ne is an important indicator of the genetic health and viability of a population. Conservation guidelines have been established from theoretical studies that suggest isolated populations having an Ne below 500 (50) are at risk of significant long-term (short-term) loss of genetic diversity. These threshold values of 500 and 50 provide a yardstick with which to evaluate Ne estimates.”

The Olsen study further goes on to provide Ne/N ratios that can be used as surrogates when genetic information is not available to estimate the effective population size for Chinook populations where demographic information is available.  Olsen calculated the average Ne/N ratio to be (0.28 ± 0.12) assuming a 1:1 sex ratio, no immigration, and random variation in reproductive success.  For discussion purposes if we apply Olsen’s surrogate ratio to the average Chinook escapement reported in the DEIS (59 Chinook), we can estimate an effective population size (Ne) at 16.5 fish. This means that the population is actually losing genetic diversity at the rate of the Ne population size (16.5), and not the census size (59). Estimating the genetic loss per generation (using the formula provided above) we can arrive at approximately 3.0 % per generation for a Ne (16.5), and 0.8 % for N (59).  Assuming an average generation time for Kuskokwim Chinook to be 5 years, we can then get a rough idea of the genetic diversity of Crooked Creek Chinook salmon over time under current conditions, Table 1.

Table 1. Estimated Loss of Genetic Diversity for Crooked Creek Chinook over Time

Size Loss over      1 gen or 5 yr. Loss over

4 gen or 20 yr.

Loss over

10 gen or 50 yr.

Loss over

20 gen or 100 yr.

N (census size) 59 0.8% 3.2% 8% 16%
Ne (effective size) 16.5 3.0% 12% 30% 60%

The purpose of the previous exercise and discussion was not to precisely attempt to quantify the biological diversity of Crooked Creek salmon but simply to demonstrate their possible vulnerability, and that while these populations may be small in the overall context of the Kuskokwim, they are important as reservoirs of genetic diversity.  Fisheries Managers and Biologists on the Kuskokwim River recognize the importance of this fact, and are currently (or attempting to) employ strategies to preserve biological diversity. These strategies are well documented in studies evaluating what has been termed the “portfolio effect” (Schindler et al. 2010) and how it contributes to long term productivity and provides for sustainable yield.

Fundamentally the assessment as presented in the DEIS suggest that the proportion of Crooked Creek salmon to the overall Kuskokwim Basin salmon returns is so minor that the loss of some, or potentially all the salmon would be inconsequential to “productivity”.  The DEIS summaries on page 3.13-124 all mine site area impacts to salmon as:

“Potential impacts from anticipated flow reductions in Crooked Creek would be minor relative to broader populations of fish in the Kuskokwim River. “

For reasons previously stated, a conclusion that only considers this broader context is not an accepted principle of fisheries management, conservation, and contrary to specific direction provided in policy. For example despite not being mentioned in the DEIS Regulatory Framework section on page 3.13-4: the State of Alaska Policy for the Management of Sustainable Salmon Fisheries (5 AAC 39.222) provides detailed and clear direction on the management and conservation of salmon.  Any future assessment should contain a thorough discussion on the principles found in the Sustainable Salmon Fisheries Policy, and how any proposed activities will comply with the direction contained within it.

Essential Fish Habitat Assessment

The Essential Fish Habitat Assessment (EFH) was prepared by a private contractor and provided to the ACOE for inclusion in the DEIS, as Appendix Q, page 1 states the following:

“Section 305(b)(2) of the MSFCMA requires federal agencies to consult with National Marine Fisheries Service (NMFS) on all actions or proposed actions authorized, funded, or undertaken by the agencies that might adversely affect EFH.

The EFH Guidelines, 50 Code of Federal Regulation (CFR) 600.05 – 600.930, outline procedures that federal agencies must follow to satisfy MSFCMA consultation requirements. Federal agencies must provide the NMFS with an EFH Assessment if the federal action may adversely affect EFH. An EFH assessment is to include the following contents (50 CFR 600.920(e)): 1) a description of the action, 2) an analysis of the potential effects of the action on EFH and managed species, 3) the federal agency’s view of the effects of the action, and 4) proposed mitigation, if necessary.”

As specified above the ACOE is required to submit the EFH report to the NMFS for review and consultation, no record of that occurring is included in Chapter 6: Consolation and Coordination of the DEIS.  Additionally no “federal agency’s view” (also stipulated above), from either the ACOE, or the NMFS is included in the EFH assessment. The oversight agency’s (NMFS) views on the assessment would be invaluable at determining the validity of the EFH assessment, and their comments should have been included in the DEIS, as required by 50 CFR 600.920(e)): 3.

Fundamentally, the EFH assessment is wholly inadequate because it does not take into consideration in its assessments of impacts to Crooked Creek the potential of increased dewatering of the High K scenario, previously discussed.  Additionally, the EFH assessment evaluates impacts only within the broader context of Kuskokwim returns, stating on page 32 of the EFH assessment:

“While salmon escapement values for the entire Kuskokwim River system are not available, because all tributaries are not surveyed or enumerated, annual ADF&G Chinook salmon escapement goals for all 14 monitored tributaries combined were 25,050 to 59,730 (aggregate escapement goal range) (Conitz et al., 2012). By comparison, the average 2008 to 2012 Chinook salmon escapement at the Crooked Creek weir represents between 0.1% and 0.2% of the total escapement goal range for all 14 Kuskokwim River stocks for which escapement goals have been established.”

The statement above is factually incorrect. The Kuskokwim River currently has only 3 established Chinook escapement goals on tributaries with weirs, which provide estimate of total escapement, a fourth goal for the Tuluksak River was dropped in 2010.  In 2013 a Basin Wide goal of 65,000-120,000 was also established.  A total of 12 aerial index sites are surveyed intermittently, 7 of which have established escapement goals, and these however are only proportional indices of the total escapement. The remaining three goals referred to above are not for tributaries of the Kuskokwim River, but instead for Kuskokwim Bay.

Recognizing, if such a comparison were to be made it would be more appropriate to use the established Basin Wide escapement goal range of 65,000-120,000, in context with the Crooked Creek average escapement of 59 Chinook.  This gives a range of less than one tenth of one percent that Crooked Creek Chinook contribute to the overall Chinook escapement goal for the Kuskokwim: even lower than what is reported in the EFH assessment. Hopefully the previous point serves to illustrate that using only abundance estimates in such a broad context should not be the only factor considered when evaluating impacts to fisheries, for all the reasons previously discussed.

In the EFH assessment the mention of the removal of beaver dams from Crooked Creek as mitigation, page 44 is not only short-sided, but illustrates a lack of understanding by the authors preparing the assessment regarding salmon/beaver/riverine ecology. It is recommend prior to any type of stream manipulation proposed as mitigation that a limiting factor analysis of spawning, rearing, and overwintering habitat be conducted for each species of salmon found in Crooked Creek.

Cumulative Effects Assessment

As stated on page 4-1 of the cumulative effects assessment:

“the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such actions” (40 CFR 1508.7).”

The cumulative effects assessment in the DEIS does not adequately address active mining claims near the proposed project, Figure 1, and considered them to be small scale placer mining operation or exploration activity. Approximately 100 sq miles of active claims occur along a 100 mile long, by 20 mile wide corridor extending from the proposed mine site to Takotna: including active Donlin claims in the George River watershed, less than 50 miles to the NE.

Future development of these claims either by Donlin or some other Claimant is a reasonably foreseeable future action, or possibly even a connected action if the infrastructure developed by Donlin for the proposed mine is utilized in anyway. A revised assessment should be conducted that is inclusive of the potential development of these claims and to what degree the Donlin project would/ or would not facilitate their development.


The DEIS present two assessments of the impacts to subsistence; the ACOE assessment with a conclusion of only minor impacts, and the BLM 810 analysis which concludes that there will be significant restrictions to subsistence uses. The DEIS fails to provide any explanation of, or discussion on the two contradictory findings. The result is that the DEIS does not allow the reviewer to make a “reasoned choice” among alternative.

Figure 1. Active mining claims near the proposed Donlin Project.  See attachment for a pdf version of this post and reference section.



NVN Comments on the Draft Donlin Environmental Impact Statement – Part 1:

To Whom It May Concern:
This is the first part of a two part statement the Native Village of Napaimute will be submitting. This part is based on long term observations of the changes in the region, our concern over the current direction we are heading and our vision for a better future for our young People.
Part two will be more science based and address in more detail some specific environmental concerns we have regarding the Project.
Part 1:
We have been involved with the development of the Donlin Creek Project since its inception all those years ago. Throughout this long process we have strived to maintain a balanced view point on all of the issues surrounding this potential large-scale natural resource development coming to our region. We have made trips to open-pit mines both at our own expense and at the invitation of Donlin’s developers. We have attended dozens of Donlin-related meetings throughout the years and visited the Project Site several times.
Nobody ever mentions that there is already a large open-pit gold mine operating in Alaska, on a tributary of the Chena River which flows right through Alaska’s second largest city – Fairbanks, which flows into the Tanana, which flows into the mighty Yukon. The Fort Knox mine has safely operated for two decades and is barely noticeable. We understand that there are significant differences between Ft. Knox and what a Donlin Creek open pit mine would be, but still it demonstrates how large scale resource development can be done with little or no noticeable impact to the environment at this time.
After years of involvement with the development of the Donlin Project, with the public release of the Donlin EIS it is has been some what frustrating to watch all the “Johnny-Come-Latelys” jump on the band wagon in opposition to the Project. Many of them have no true understanding of the issues – especially the environmental ones.
Much of the most vocal & eloquent opposition comes in fact from relatively wealthy people with good jobs and fine homes with very limited experience in the region beyond their residences in Bethel..
Many of them have no vision for our future – the future of the region.
They have no understanding of what it’s like to be a twenty-something young man living in a village in the middle of winter with little to no opportunity for anything except a dope pipe or a bottle of R & R whiskey. No jobs, no money for gas and good equipment to go out hunting or trapping. The illegal sale of alcohol and drugs is probably the second biggest factor in the quasi-economy of our region after government spending.
Where is our region going to be in 20 years or 50 years without some true economic development?
Our population is growing at third world country levels. Over half of our People are under the age of 25 and this percentage is growing. We have people in their 30’s that are grandparents already! What are we going to have for all these young People?
More over-capacity prisons, more over-flowing cemeteries?
People have been complaining about their subsistence way of life being threatened by the development of Donlin Creek. Let us tell you that in a lifetime of traveling up and down this River and as people that still travel up and down it more than most – the country is empty. Especially the Middle and Upper Kuskokwim – the part of our region that would be most effected by the development of Donlin Creek.
There is no one out there anymore – not on an extended basis like they used to. There is still a lot of subsistence activity going on but most of it consists of short day trips close to home. The modes of transportation, tools, and equipment we have in these modern times has made subsistence hunting, fishing, and gathering so much easier. Oh, but they also take more money! And once you’ve completed your seasonal rounds of subsistence activities with vastly more effectiveness and efficiency than it took in traditional times – what do you do with all that spare time?
What are our young People going to have without some major economic development? Not everyone can work for YKHC, AVCP, or the school districts. And they’ll have no money to go hunting, fishing, trapping, or gathering. So they continue to rely increasingly on public assistance programs. Public assistance is becoming an integral part of our Region’s culture. It is also an enabler/enhancer of our more negative social aspects: unwed mothers becoming pregnant over and over again so they can get more assistance, fathers with no responsibility, free money for alcohol and drugs (yes people have figured out how to use public assistance for this), significant health problems and obesity from all the junk food that is bought with public assistance money, high crime, suicide, the list goes on and on.
But if you ask any young person along the River today what they want most. Their answer isn’t subsistence. It’s a JOB! Give a young person a job – an opportunity – and you change their life.
With opportunity, a young person can be even more true Native – independent, self-sufficient, have more pride and self-esteem, be more of a Nukalpiaq (good hunter/provider) – the very core of our culture in this region.
Instead of being poor and dependent on government support. The definition of being Native is becoming more and more confused with the definition of poverty.
We may not want Donlin Creek but we need it. We can’t go on like this – all we’re doing is creating a big ghetto with millions of acres of empty unused country around it.
Allow for the development of just a few thousand acres to bring economic benefit to the greater Region – there will still be vast areas of untouched land and water that can be enjoyed by the People as they hunt, gather, and fish for food while at the same time having the economic means to do it even more effectively. And there will still be vast areas of land and water that will NEVER feel the impacts (negative or positive) of an open pit mine on a small tributary of the Middle Kuskokwim. Some People who live hundreds of miles from Donlin talk like everything about their lives will be ruined. We bet they won’t even notice a thing much like the People living along the Yukon aren’t even aware of the Ft. Knox mine far away on a distant tributary.
Regarding the specific issues covered in the Draft EIS:
Barge traffic: not an issue. Our administrator grew up on barges on the Kuskokwim River and was a captain for 10 years. The River is a big place. A couple of barges a day is nothing. People forget the immense amount of barge traffic we had in the 1980’s when the State was flush with oil money and splashed it all over our region paying for the construction of new schools, multi-purpose buildings, clinics, fire stations, and just about any other thing a community asked for. In addition to the greater volume of freight/fuel barge traffic there was also a viable commercial fishery going on in the 1980’s that included significant large vessel traffic – especially in the Lower River. With several fish processors operating in Bethel and 800 commercial fisherman there was a lot of large vessel activity on the River. Somewhere we have a picture of 14 freight barges, large fish processing ships, Japanese tramp steamers, and assorted tenders lined up in front of Bethel at one time. There was also a constant stream of barges hauling hauling gravel from the middle to lower Kuskokwim. Up until recently every rock on every road, runway, and building foundation pad in the lower River came down by barge from the Kalskag- Aniak area. Sometimes these barges were drafting as much as 10 feet!
The best thing though would be the implementation of those LNG trucks – just a better alternative in so many ways – including reduced barge traffic – since the public perception is that this a big issue in this Donlin EIS process.
The Port Site: We’ve always favored the Birch Tree Crossing Alternative for several reasons.
  1. The River from Birch Tree downstream to Bethel is relatively easy for barges to navigate at just about any River level. Upstream of Birch Tree there are several tricky spots which have more potential for barging problems.
  2. The other reason we’ve favored Birch Tree is because in almost any year you can have a safe, reliable ice road from Bethel to Birch Tree. Even in a mild winter like the one we’re experiencing now you get get 60-90 days of ice road trucking – this could be an important transportation alternative if summer River conditions are extreme and limiting. A safe, maintained ice road would also bring great economic/social benefit to the People of the region.
  3. We also like the idea of the 80 mile road from Birch Tree to Donlin – the first major road in our region that could be a real asset when the mine closes. The road would also open up other mineralized areas for development and perhaps even provide a transportation connection to the Yukon River someday.
  4. The road might also have the potential to serve as the route for any extension of the natural gas pipeline to the rest of the region.
Dry Stack Tailings – we prefer this alternative. Any process that further reduces the amount of water that needs to be monitored and treated “in perpetuity” and reduces risk to the watershed has to be a good thing.
Natural Gas Pipeline – not an issue – already a well established practice throughout the world – including Alaska – with the added benefit of the potential to extend and supply natural gas to the lower Kuskokwim and beyond.
Air Quality – mercury emissions have been one of our greater environmental concerns, it seems to have been addressed, but those entities responsible for issuing permits for the Project must ensure that it is.
Hazardous Materials and Waste Management: the transport and handling of hazardous materials isn’t an issue – there are well-developed almost universal safety systems in place for this issue. Many toxic, hazardous materials are safely transported throughout our State in general and Region in particular everyday. On a tour of the Golden Sunlight Ore Processing Facility in Montana years ago our administrator stuck his hand in the cyanide solution. His hand still works just fine today.
Water Quality – this is perhaps the biggest concern for everyone who lives along the River. It seems to have been addressed adequately but we would like a clearer more understandable plan for treatment of water in “perpetuity” including financial planning to support this on going work. We don’t ever want to worry that our River is polluted and that its not safe to eat what we get from it.
We think it would be good to be able to demonstrate what the true effects would be in the unlikelihood of a catastrophic release of contaminated water into the Kuskokwim. Over the years we have observed man-made and natural contaminations of the River and see how quickly they are diluted and their effects flushed out in a relatively short period of time.
It’s ironic that no one says much about a sewer lagoon in Bethel that is being used at seven times the capacity it was designed for being discharged regularly into the Kuskokwim River. Where’s the water quality there?
The Kuskokwim River is a large river with a lot of water moving through the watershed. Crooked Creek isn’t even the half way point of the Kuskokwim’s length. There would still be over half of the River’s water coming down uncontaminated to further dilute the already quickly disseminated contaminated water.
This may be over simplifying it but in our minds it would be like releasing 1,000,000 gallons of dry powdered red Kool Aid into the River at Crooked Creek. How long would the water stay red downstream? It might hurt a few fish in the immediate area for a short time, but a majority of of the main stem of the Kuskokwim would feel minimal effects if any at all. And again there would be vast areas of the watershed that would have no negative effects.
The other issues identified and analyzed aren’t worth spending too much more time discussing. Things like marine mammals, bald eagles, wetlands etc. Again look at our region as whole – it’s a vast area – most of it will never be touched by natural resource development and will remain as it has throughout the millennia.
Our region has been famous for opposing natural resource development yet always open to more low-risk/no-risk government spending. In the 1970’s and 80’s regional leaders opposed oil & gas exploration. Now they would welcome it!
Another example of our region’s strong resistance to change that we remember is when they were first proposing to use a hovercraft to deliver mail and freight from Bethel to our outlying villages. There was great opposition to this. Many People publicly spoke against the use of the hovercraft fearing that it would scare away fish and game and damage other subsistence resources.
Now the hovercraft is an accepted part of everyday life in the Lower Kuskokwim. No harm done.
There are risks associated with the development of Donlin Creek into a world class open pit gold mine, but great efforts have been taken in the planning for this Project to minimize these risks. And yes, there will be a relatively small area of the Kuskokwim Watershed that will never be the same, but this is a risk and a limited change in the natural environment that we need to take – for the economic, social, and even cultural future of our young People.
Thank you.