Compensatory Mitigation: What is it?

If you haven’t heard, the Alaska Mental Health Trust Authority (AMHTA) announced on December 17, 2018 that it finalized its first conservation agreement with Donlin Gold, LLC to enter into a long-term deed restriction agreement to preserve just under 2,000 acres of Trust wetlands near Tyonek for wetland compensatory mitigation of 2,800 acres of disturbed wetlands in the Middle Kuskokwim. As a part of this agreement, Donlin Gold paid the Trust $200,000 upfront for the ability to purchase a deed restriction in the future and will continue to pay $20,000 per year over the next 10 years to maintain this mitigation option until the mine is officially under construction. If the mine comes into fruition, Donlin will pay the Trust $1.3 million to secure 1,933 acres Trust’s existing wetlands and limit surface development of the wetlands as compensatory mitigation for 99 years. All earnings with the agreement will be used to support programs that serve Alaska Mental Health Trust beneficiaries.

So what is compensatory mitigation?

The EPA and U.S. Army Corps of Engineers (USACE) revised the definition of Compensatory Mitigation in 2008 as “…the restoration (re-establishment or rehabilitation), establishment (creation), enhancement, and/or preservation of wetlands, streams, and other aquatic resources to offset unavoidable adverse impacts of development after all appropriate and practicable avoidance and minimization efforts have been achieved.”

Meaning that compensatory mitigation allows for companies that are irreversibly changing or adversely affecting the environment on their site to protect, restore, or enhance wetlands or other aquatic environments in other locations to make up for lost habitat and environmental resources.

Generally, there are three types of compensatory mitigation:

• Mitigation Banks – A site, or suite of sites, where resources (e.g., wetlands, streams, riparian areas) are restored, established, enhanced, and/or preserved for the purpose of providing compensatory mitigation for impacts authorized by Department of the Army permits. In general, a mitigation bank sells compensatory mitigation credits to permittees whose obligation to provide compensatory mitigation is then transferred to the mitigation bank sponsor. The operation and use of a mitigation bank are governed by a mitigation banking instrument.
• In-lieu fee programs – Defined as a program involving the restoration, establishment, enhancement, and/or preservation of aquatic resources through funds paid to a governmental or non-profit natural resources management entity to satisfy compensatory mitigation requirements for DA permits.
• Permittee-Responsible Mitigation – This is an aquatic resource restoration (reestablishment or rehabilitation), establishment (creation), enhancement, and/or preservation activity undertaken by the permittee (or an authorized agent or contractor) to provide compensatory mitigation for which the permittee retains full responsibility. (This is what Donlin Gold is currently pursuing with AMHTA)

In comparison to the lower 48 with only 5.2% of its surface area classified as wetlands, Alaska’s wetlands occupy 43.3 % of the state’s surface area. This creates a unique challenge for development in Alaska which is most likely why Donlin Gold is pursuing this avenue for mitigation efforts. Donlin Gold did explore other options to directly impact the Middle Kuskokwim, but those options were not selected as their final mitigation plan.

Wetlands in the United States (USGS)

If you’re interested in learning more about compensatory mitigation in Alaska, the EPA and USACE signed and released a Memorandum of Agreement on June 15, 2018 which gave guidance on flexibilities for compensatory mitigation in the state of Alaska including the following six principles:

1. Avoiding wetlands may not be practicable where there is a high proportion of land in a watershed or region which is jurisdictional wetlands;
2. Restoring, enhancing, or establishing wetlands for compensatory mitigation may not be practicable due to limited availability of sites and/or technical or logistical limitations;
3. Compensatory mitigation options over a larger watershed scale may be appropriate given that compensation options are frequently limited at a smaller watershed scale;
4. Where a large proportion of land is under public ownership, compensatory mitigation opportunities may be available on public land;
5. Out-of-kind compensatory mitigation may be appropriate when it better serves the aquatic resource needs of the watershed; and
6. Applying a less rigorous permit review for small projects with minor environmental impacts is consistent with the Section 404 program regulations.

You can find the memorandum document on EPA’s website.

If you have any comments on Donlin Gold or want to learn more please reach out to our Environmental Department at Meredith.witte@georgetowntc.com or at 907.274.2196. We will do our best to keep everyone informed on Donlin Gold’s progress.

M Witte 
01/09/2019

Featured image by Donlin Gold

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Citizen Science, No Lab Coat Required

Ever since I’ve moved to Alaska, people have told me, “Just wait, the summer makes it worth it.” In response to this, I have to say:

1. 

   Made it to Exit Glacier!

   I have loved every Alaskan season I’ve experienced so far, winter being one of my favorites.

2. This summer has been AMAZING!

The weather has been beautiful this summer and I have spent every minute possible enjoying it. One of the most unique things I did this summer was take part in a Citizen Science Partnership. To explain, I have a personal goal of visiting all 60 National Parks and this summer while I was visiting Kenai Fjords National Park to hike Exit Glacier, I came across this little sign post…

On the trail to Exit Glacier PC: Larry Perez

This is a Picture Post, it is an eight-sided platform that you use to take pictures of an area in multiple directions to give an idea of what the environment looks like on a certain day. You upload the pictures to Picture Post using the link provided by the sign and the pictures are used to document the local conditions of the Picture Post during the year.

These are the pictures I took from the Picture Post.

The Picture Post for Exit Glacier has been in place since 2016. By uploading my pictures, I was participating in a Citizen Science program to track the greenery, atmospheric conditions, and weather on the Kenai Peninsula. It was fast and fun to see the pictures I posted along with all the pictures posted by other enthusiasts.

So how can you get involved?

There are lots of Citizen Science opportunities in Alaska, here are a couple of projects you can get involved with:

1. Winterberry  – UAF Scientists are researching how berries and flowers are impacted by climate change, help them out! 
2. Alaska Hare Project – ADF&G wants to know more about Alaskan hares, have you seen any?
3. LEO (Local Environmental Observer) Network – ANTHC has developed the LEO Network to record and track changes in the local environment, download the app on your phone today!

There are lots of Citizen Science projects out there, go find one that focuses on a cause that’s important to you and get started! If you are interested and want help finding a project to work on, contact the Environmental Department at meredith.witte@georgetowntc.com. We’d be happy to help!

M. Witte
09/18/2018

Salmon Watch on the Kuskokwim

As the weather is warming up and the salmon start heading upriver to spawn in the Kuskokwim, Georgetown and other communities are in conservation mode to protect the Chinook and other salmon species for today and future generations. If you are interested in learning about other ways to support the salmon, check out the LEO Network.

The LEO Network is a powerful tool developed by Alaska Native Tribal Health Consortium (ANTHC) as a platform to share information and raise awareness about the climate and environmental change. LEO includes observations from around the world and you can contribute too!

Here is how LEO works:

• Observe something out of the ordinary:

-Salmon aren’t running when they should be or large numbers of salmon running
-Salmon have parasites or looks strange
-Salmon are showing up in fish weirs, but not in nets
-Or other out of the ordinary experiences (e.g. extreme weather, unusual animals, etc.)

• Report it! There are several options:

-Sign up with LEO Network and report it online or through your phone’s LEO app  (currently supported for iPhones, will update if added to Google Play). 
-Write up what you saw, include pictures (if possible), and email them to me at meredith.witte@georgetowntc.com so I can help you report it.
-Post it to Georgetown’s Facebook Page so we can see it and with your permission, notify the LEO Network.

• LEO Network officials review the post and reach out to experts to explain the observation.

-LEO reaches out to ADF&G, fish biologists, professors at universities, or other subject matter experts to find out more information about the reported observation.

• LEO shares information to observer and publically with observer network to document and increase awareness about event.

If you are interested, here are some examples of salmon observations from the past:

Kitchivik River – Photo by Mike Brubaker

Toby Anungazuk Jr. writes: The permafrost is thawing on the river banks and has caused a lot of erosion since about 2007. The bank has collapsed causing the channel to be blocked with dirt and small islands of plants. The water is much dirtier then it usually is. It used to be clear and you could see the fish. In 2007 the water was usually the color of tea. Now it is more often like coffee. The salmon is late coming into the river this year. There are also fewer salmon. I am wondering if they are waiting for the water to clear before they come into the river. We are monitoring river conditions using a Hobo logger so hopefully, we will have good data soon. We are also concerned about the water used by camps for drinking and by people who haul water from the river for their home use. There are a lot more big willow now in the river and also a lot more beaver.

LEO says: This observation will be forwarded to the salmon research community in Alaska with the intent of learning more about the relationships between water quality and salmon and other fish in Arctic rivers. It will also be shared with Norton Sound Health Corporation regards beaver and prevention of waterborne illness in rivers used by residents for drinking water.

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PC: C Prince

Observation: A local resident cleaning fish observed a chum salmon with pus draining from the flesh of the fish. Charles writes, the salmons backbone and meat of the fish carcass have been placed into a freezer. C. Prince, for local resident.

Alaska Department of Fish & Game Consult: Ted Meyer, State Fish Pathologist writes, “Based on the photo there appears to be a long linear-shaped abscess in the dorsal musculature of the affected chum salmon. The lesion is probably due to a bacterial infection, possibly introduced from a piercing type wound maybe caused by a predator or a gaff or spear.”

• T. Meyer, ADF&G writes, “A probable abscess renders this fish likely not fit for human consumption so it should be discarded.”

Observer Comment: Based on this for future references, should we just take pictures and discard the fish? C. PrinceResource: Alaska Department of Fish and Game, Common Diseases of Wild and Cultured Fishes in Alaska, a good reference for learning about illness in salmon provided by the, Fish Pathology Laboratory.

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Estuary up head King Cove Lagoon (Photo by Jane Mack, King Cove)

Desirae Roehl and Jane Mack write, At the end of August, my family and I drove to Whittier and were happy to see so many pink salmon in the creeks. Over the next several days, salmon abundance was brought up in numerous conversations and I noticed many family and friends posting photos and videos on Facebook. My aunt Jane Mack from King Cove snapped the associated photo and said, “there were so many humpies (pink salmon) and fish, in general, this year that they were spawning all along the beach from the Rams to the Lagoon. It was amazing to watch. The creeks were so full – I bet the oxygen levels weren’t so good for them though.” It’s not typical for the salmon to spawn along the beaches, but figure they had no choice if they were unable to fit in the creek.

LEO says: About 75 miles ENE of King Cove on the south side of the Alaska Peninsula lies Sand Point, AK. David Osterback, Captain, Commercial Fisherman, and LEO Member documented the pink salmon run for the Shumagin Islands during the summers of 2015-16. During 2015, Sand Point’s pink salmon run had an unprecedented return with numbers not seen before. The following year, 2016 it was the complete opposite, local fisherman did notice a change in the sea water temperature during 2015 as being warmer than 2016. Conversation among commercial fisherman in the Shumagin’s during 2016 mention the warmer water temperature’s are a potential factor with salmon numbers. During the 2017 salmon season in the Kachemak Bay, pink salmon were showing up in unexpected places around Homer, AK. M. Tcheripanoff

Resources: Alaska Department of Fish & Game – “Pink salmon have the shortest lifespan of all the Pacific salmon found in North America. They mature and complete their entire life cycle in two years. This predictable two-year life cycle has created genetically distinct odd-year and even-year populations of pink salmon.”

• Wildlife Notebook Series – The pink salmon (Oncorhynchus gorbuscha) also known as the “humpy” because of its very pronounced, laterally flattened hump which develops on the backs of adult males before spawning.

Olympic National Park Washington – The Salmon Life Cycle, “The anadromous life history strategy of salmon plays a key role in bringing nutrients from the ocean back into rivers and the wildlife community. Though it varies among the five species of Pacific salmon, in its simplest form, it is hatch, migrate, spawn, die.” Source: NPS February 2015.

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We work to keep you updated on what is happening along the Kuskokwim. If you are interested in getting involved or have any questions, feel free to contact me  at meredith.witte@georgetowntc.com or at 907.274.2195.

M Witte 06.15.2018

This observations were taken from the LEO Network with permission. Please respect the information collected and presented by crediting the observers and pictures in the observations. Featured Image Photo Credit: USFWS/ Ryan Hagerty

Donlin Gold Compensatory Mitigation Plan Comments Submitted!

The Final Environmental Impact Statement (FEIS) for Donlin Gold was released on April 27, 2018. An additional commenting period was opened for the updated Compensatory Mitigation Plan (CMP) of the FEIS, located in Appendices J and M of the FEIS. The CMP addresses how Donlin Gold plans to mitigate short- and long-term temporary disturbances and permanent disturbances to wetlands, riparian areas, and streams in the Mine, Pipeline, and Transportation Areas. These comments were due by May 29, 2018.

After reviewing the updated CMP, Georgetown submitted comments that will be reviewed and addressed with other comments submitted by the public. We appreciate the ability to voice our concerns and receive meaningful responses from U.S. Army Corps of Engineers (USACE) as the Kuskokwim and other areas should be developed properly to avoid unnecessarily damaging the environment.

As a summary, most of the comments submitted by Georgetown were in support of requiring stricter language, additional research, and further explanation of Donlin Gold’s decisions for compensatory mitigation.

• We expressed the need for stricter language for Donlin Gold’s timeline to remediate disturbed sites. In the updated CMP, timelines were suggested with the phrasing “as soon as practicable,” which we felt should be addressed to ensure remediation will occur in a timely manner.
• The updated CMP also included plans for remediating old placer mines by removing berms and revegetating to realign the water channels. Georgetown was concerned about the mineralogy of the sediments by historical and requested additional and requested additional studies be completed on sediments of the historical placer mines and berms.
• Georgetown requested stricter requirements for revegetation to take necessary actions to limit invasive plants during revegetation and measure successful revegetation on remediated berms and tailings. Georgetown also requested additional studies of subsistence fish species for metals and other contaminants in the remediated area.
• Georgetown expressed concerns about the viability of the Chuitna wetland preservation option for compensatory mitigation plan. Protecting the wetlands of Alaska is very important to preserve the natural filtration process for water quality as well as limiting impacts of natural resource extraction or other human activities. However, Donlin Gold’s plan for preserving wetlands in the Chuitna watershed is a point of concern for Georgetown. This does not impeded future mining operations from permitting and operating upstream and may still impact the watershed. Water quality testing was requested by Georgetown to be included in the CMP for the Chuitna preservation plan to develop a baseline in case of future natural resource extraction in the area.
• More information on the Fuller Creek watershed preservation was requested to explain why the preservation plan, located in the Middle Kuskokwim Region, was rejected.

This is a summary of the thoughts and concerns submitted by Georgetown as comments to USACE for the Donlin Gold Compensatory Mitigation Plan. If you are interested in reading a full version of our comments, please email me and I can send you a copy. As this process continues to move forward, I will do my best to keep you informed, and please don’t hesitate to send me any questions you may have.

Meredith Witte
meredith.witte@georgetowntc.com
PC: Donlin Gold  June 7, 2018

 

Donlin Gold Project Update: Final EIS Published

Dear Georgetown Community and Friends,

The U.S. Army Corps of Engineers has released their Final Environmental Impact Statement (EIS) for the Donlin Gold Project on April 27, 2018. To view the whole document, click here. To view the executive summary, click here.

Comments are being only accepted on the updated compensatory mitigation plan included as appendices to the final EIS document (specifically, Appendices J and M).

From USACE Special Public Notice: Comments on the compensatory mitigation plan will be accepted through a 30 day review period, beginning April 27, 2018, and ending May 29, 2018. This comment period is intended to provide those interested in or affected by this proposal an opportunity to make their concerns known prior to a decision being made by the Corps. All comments concerning the compensatory mitigation plan should be directed to: Mr. Jamie R. Hyslop, U.S. Army Corps of Engineers, Alaska District, CEPOA-RD-Hyslop, P.O. Box 6898, JBER, AK, 99506-0898; via email at: POA.donlingoldeis@usace.army.mil or; (907) 753-2670.

Donlin Gold, LLC (Donlin Gold) is proposing the development of an open pit, hard rock gold mine in southwestern Alaska, about 277 miles west of Anchorage, 145 miles northeast of Bethel, and 10 miles north of the village of Crooked Creek. The proposed project would be located in an area of low-lying, well-rounded ridges on the western portion of the Kuskokwim Mountain. The proposed Donlin Gold project would require approximately three to four years to construct, with the mine life currently projected to be approximately 27 years. The mine is proposed to be a year-round, conventional “truck and shovel” operation using both bulk and selective mining methods.

Updates for Appendix J: USACE Section 10 Rivers and Harbors Act/ Section 404 Clean Water Act Permit Application and Appendix M: Compensatory Mitigation Plan from December 2017 include: 

Updated Affected Wetland and Stream Areas
1. The quantities of wetland acreage and stream length impacts were updated to reflect
the current wetlands mapping based on the Preliminary Jurisdiction Determination
report (PJD) dated December 2016 that was requested by the Corps as part of the
project review. The Corps issued a preliminary determination concurring with the
mapping dated February 27, 2017. An addendum was filed in August 2017 to include
the mapping for the pipeline North Route option. The Corps issued a preliminary
determination concurring with the addendum mapping dated October 12, 2017. The
total mapped area covered by the 2 determinations is 107,408.5 acres.

**For affected wetlands: Donlin Gold proposes two PRM projects to offset the permanent fill impacts in the Mine Area (MA), Transportation Area (TA), and Pipeline Area (PA) including:

• Restore and preserve approximately 101.7-acres of wetlands and riparian area with 8,501-linear feet (1.61-miles) of stream, and establish another 71.0-acres of  riparian preservation buffers, in historical placer mining areas in the Upper Crooked Creek watershed.
• Preserve a total of 5,888-acres, of which it is estimated 2,558-acres are wetlands and ponds, with an additional 3,330-acres of upland riparian areas, stream area, and buffers, and 228,325-linear feet (43.24-miles) of streams in the Chuitna  watershed.

This Final CMP is submitted to USACE as part of the DA Permit application.

Rerouted Pipeline around Iditarod National Historic Trail (North Route)
2. Following the submission of comments by the public and agencies on the draft EIS and
initial permit application, the pipeline route was adjusted to avoid all co-location with
the Iditarod National Historic Trail (INHT). Donlin was able to plan and propose a route
(known as the North Route option) in response to the concerns that were raised. In
addition, the project plan now includes options for reducing visual impacts at the 4
locations where the pipeline crosses the INHT. The North Route option is now
incorporated as the proposed plan in the updated DA application. The overall length of
the pipeline did not change materially.

Inclusion of a Compensatory Mitigation Plan
3. The DA application includes a Compensatory Mitigation Plan (CMP) for the updated
wetland acreage and stream length impacts. The CMP documents the extensive
evaluation that was undertaken first to identify potential mitigation opportunities
within the affected watersheds, including both restoration and preservation
opportunities. The CMP then documents the expanded search for appropriate
mitigation opportunities beyond the affected watersheds, until adequate practicable  mitigation opportunities could be identified to fulfill the values and standards of
Alaska’s wetland mitigation policy. The CMP presents a mitigation plan that offsets the
project impacts based on an acre-to-acre and foot-to-foot basis for wetlands and
streams, respectively (taken from Appendix M).

A Record of Decision on the Donlin Gold Project is expected for the final EIS and wetlands permit application later in 2018.

Georgetown Environmental Department and Tribal Council will be reviewing all documentation to determine the next course of action necessary.  If you have any comments you would like to submit to us about your concerns, please feel free to email us at meredith.witte@georgetowntc.com or call at (907)-274-2196.

 

Kuskokwim Fisheries Federal Special Action Request Hearing 04/19/2018 – Make Your Voice Heard

The information below is provided by Federal Subsistence Board from the U.S. Fish and Wildlife Service:

There will be a public hearing for Fisheries Special Action Request (FSA18-03) submitted by the Aniak Native Community scheduled on April 19, 2018 from 6:00-8:00pm.

Hearing Information:
Purpose:
To receive testimony on a temporary special action request received by the Federal Subsistence Board (Board). The Temporary Special Action Request FSA18-03 requests the following:

• Close Federal public waters of the Kuskokwim River drainage to the harvest of Chinook Salmon except by Federally qualified subsistence users possessing a community harvest permit between May 20, 2018 and July 1, 2018,

• Reduce the pool of eligible harvesters based on the Alaska National Interest Lands Conservation Act (ANILCA) Section 804 Subsistence User Prioritization that was implemented in 2017, and

• Establish a harvest allocation of Chinook Salmon similar to what was implemented in 2015.

Location/Details:
In Person:
Yupiit Piciryarait Cultural Center
420 Chief Eddie Hoffman Highway
Bethel, AK

Via Telephone:
Teleconference: Toll Free: (888)-455-5897
Passcode: 3344290

If you have an opinion or testimony to contribute, please attend either in person or by calling in with the number provided. When prompted, enter the passcode. Comments will be forwarded to the Board for consideration on the temporary special action request. For more information, go to https://www.doi.gov/subsistence/fisheries-special-actions.

Let your voice be heard and consider attending in person or listen in on the phone. As we approach the start of salmon season, there has been a lot of communication and work done by the communities along the Kuskokwim, the Kuskokwim River Salmon Management Working Group, the Kuskokwim River Inter-Tribal Fish Commission, the Alaska Department of Fish and Game, and U.S. Fish and Wildlife Services to create a successful and cohesive management plan for this upcoming season. This is another opportunity to express concerns or learn more about the upcoming season.

If you are interested in learning about the motions of support passed by the Kuskokwim Working Group for this season, check out the latest edition of our E-Newsletter to find out more information.

Let us know if there is any other information you want to know in preparation for the upcoming season. We work to keep you updated on what is happening along the Kuskokwim. Please feel free to contact me with any questions or concerns at meredith.witte@georgetowntc.com or at 907.274.2195.

M Witte 04.18.2018

New Faces around the Office

As we spring forward this week with Daylight Savings Time (hopefully that lost hour of sleep wasn’t too painful), we have a new member on our team here at the Georgetown Tribal Council, me! My name is Meredith Witte, and I have recently joined GTC’s office as the new Environmental Coordinator.

A little about me: I am passionate about environmental stewardship and taking a proactive stance towards ensuring a safe and environmentally healthy future in the community. I earned my B.S. and M.S. in Mining Engineering from Virginia Tech in 2014 and 2016, respectively, with a focus in environmental studies and health and safety. I currently live in Eagle River with my husband, John, and our two dogs, Rocky and Apollo (Coincidentally, they are not named after the Rocky movie). We are avid outdoor enthusiasts and have enjoyed learning about all the available winter outdoor activities including cross-country skiing, skijoring, and ice skating. From everything we’ve heard, we know the rest of the year will be just as exciting!

From left to right: Apollo, Meredith, John, and Rocky

I look forward to contributing to the Environmental Department with our planned work on protection of subsistence resources, traditional ecological knowledge, proposed and Superfund mine projects, and water quality and management initiatives. Please feel free to contact me with any questions or concerns at meredith.witte@georgetowntc.com or at 907.274.2195.

Young Adult Health Fellowship Opportunities

The National Indian Health Board is currently accepting applications for the 2018 Tribal Youth Health Policy Fellowship. If you are interested in getting involved and promoting change, check out the eligibility requirements and apply! Deadline: April 6, 2018

Here is more information:

The National Indian Health Board (NIHB) is pleased to announce that applications for the 2018 Tribal Youth Health Policy Fellowship are now open!

The National Indian Health Board’s second cohort of Fellows will consist of 12 Native youth from around the country to engage throughout the year in Indian health policy and programming efforts. The Fellows will engage in Indian health policy solutions, tell their personal story, and advocate for changes in the healthcare and public health systems important to their Tribal communities.

The Fellowship provides youth with key opportunities for relationship- and skills-building that allows them to return home feeling empowered, connected to other Native youth, and well equipped to be the next generation of advocates for Indian health.

Tribal Youth Health Policy Fellowship
The inaugural group of Health Policy Fellows received Indian health policy, law, and advocacy training, strengthened their leadership skills, and learned how to effectively serve as future Tribal leaders and Board members.

NIHB hopes to build off the success and experiences of the first cohort of Fellows and encourage all who are eligible to apply. One of the many goals of the NIHB is to teach tribal youth about governance structures and the federal trust responsibility and we will continue to work with Tribal youth to improve the healthcare system of Indian Country.
is an excellent way to get involved and help promote changes.

Additional Information

If you have any questions please contact, Bobby Ahern at BAhern@nihb.org, or call the National Indian Health Board at (202) 507-4070.

 

Donlin Gold Project – Public Hearing This Friday, January 26

Georgetown members & friends,

A public hearing will be held on the DONLIN GOLD PROJECT  AND DONLIN GOLD WASTE MANAGEMENT PERMIT from 6:30 to 9pm at the Atwood Conference Center on January 26th, that’s this Friday!

The public hearing is intended to provide the public an opportunity to submit oral comments regarding the draft permit. Public may also submit written comments in lieu of or in addition to providing oral testimony at the hearing.

Before reviewing the permit materials please read the following considerations from the Center for Science in Public Participation:

“Perhaps the most important points to recognize in Donlin’s application and DEC’s proposed permit are:
• Water treatment is likely to be forever, and approved in 5 year increments. Never before has the state of Alaska approved a mine knowing in advance that it will need to treat mine water “forever” (“in perpetuity”). This is precedent-setting.
• The water treatment system proposed is a good one, but must be vigilantly maintained.
• There are no requirements to maintain creek water as it is.”

Donlin Gold, LLC (Donlin Gold) is proposing the development of an open pit, hard rock gold mine in southwestern Alaska, about 277 miles west of Anchorage, 145 miles northeast of Bethel, and 10 miles north of the village of Crooked Creek. The proposed project would be located in an area of low-lying, well rounded ridges on the western portion of the Kuskokwim Mountain. The proposed Donlin Gold project would require approximately three to four years to construct, with the mine life currently projected to be approximately 27 years. The mine is proposed to be a year-round, conventional “truck and shovel” operation using both bulk and selective mining methods.

The APDES permit authorizes the discharge of treated wastewater to Crooked Creek from Outfall 001. The proposed facility is expected to operate at a net positive water balance thus necessitating the need to discharge excess water. The water treatment plant (WTP) will utilize oxidation, clarification and greensand filtration, with reverse osmosis (RO) as required. The WTP will have a combined maximum design capacity of approximately 4,750 gallons per minute (gpm), with an anticipated maximum treatment rate of approximately 4,500 gpm. A mixing zone is not authorized under this permit. The WMP authorizes the disposal and storage of solid and liquid waste to the Tailings Storage Facility (TSF); Class III Camp Municipal Solid Waste Landfills; American Creek Valley waste rock facility; ACMA and Lewis mine pits; Upper and Lower Contact Water Dams, and groundwater and surface water collection, and monitoring systems within the Donlin Gold Project footprint. In addition to the disposal of wastes listed above, this permit applies to hazardous chemical storage and containment, reclamation and closure activities related to all the facilities within the area, and financial responsibility to fund reclamation, closure and post-closure activities. This permit also covers monitoring requirements for the mine pits, waste rock, and ore stockpiles, and seepage collection systems.

Additionally, this permit covers reclamation and closure activities for the TSF; ore, waste rock, and overburden stockpiles; and mine pits, including disposal to the mine pits as approved by the department. Mixing Zone: DEC does not propose a mixing zone for the discharge into Crooked Creek from the Donlin Gold Project facility. To see the draft permit and fact sheet, go to http://dec.alaska.gov/water/wastewater/public-notices. For more information, contact Allan Nakanishi at 907-269-4028 or email Allan.Nakanishi@alaska.gov regarding the draft APDES permit or Tim Pilon at 907-451-2136 or email Tim.Pilon@alaska.gov for the WMP.

Deadline for comments is February 13.