Donlin Gold and the US Army Corps of Engineers (Corps)  held a community meeting in Bethel earlier this week related to the protection of Cultural Resources that may potentially be effected by the Donlin Gold mine project, should it be permitted.  This was the second of two meetings (the first was held in Anchorage October 5).  If you weren’t able to attend these meetings, but want to know more about the process and how you can be involved in making sure cultural resources you know of are protected- this article is for you.

Take a look at the map up there and remember, Georgetown is just 34 miles from the proposed mine site, and probably less than 20 miles from sections of the proposed natural gas pipeline route.  In terms of culturally significant places, we’re talking about Georgetown’s backyard.

So, before Donlin can get its permit from the Corps, they have to be in compliance with both NEPA and the National Historic Preservation Act (NHPA) Section 106. The Corps is the lead agency for the project, and so is responsible for ensuring the completion of this process.  In order to be in compliance with Section 106, they must follow a series of steps.  We will discuss in detail the first step, and then list out the next steps.

STEP 1- Gather Information

  • Determine what the scope of their effort is, identify the Area of Potential Effects (APE), Identify historic properties and evaluate their significance.
  • Ultimately, at the end of this step, they will have a list of “Historic Properties” that they need to examine the effects of the project for

Now, after reading just two bullet points, I have a lot of questions.  Let’s answer some of them here:

What is the APE?

The APE is a geographic area or areas within which something related to the project may directly or indirectly cause changes in the character or use of historic properties.

What is the difference between direct and indirect effects?

An example of a direct effect would be if they started digging in a place where there were artifacts.  An example of an indirect effect would be if visual or auditory changes or a change of use takes place at a historic property because of the project.

What is considered “significant”?

In the October 5th meeting in Anchorage, it was said that: “Not all cultural resources are historic properties, but the reverse is true” So then what is the difference between a cultural resource and a historic property?

According to Section 106, to be “significant”, the cultural resource must be eligible for inclusion on the  National Register of Historic Places(NRHP).  In order for that to be true, the cultural resource must meet 1 or more of the following criteria:

  • Be associated with significant events/broad patterns
  • Be associated with historically significant people
  • Embody exceptional architecture or engineering qualities
  • Yield important information in history or prehistory

What kind of things are often identified as Historic Properties?

Historic Properties can include buildings, sites, structures, objects and Traditional Cultural Properties.  Their definition of a Traditional Cultural Property is a property or place that is associated with cultural practices or beliefs of a living community that are

  • rooted in the community’s history
  • important in maintaining the continuing cultural identify of that community

It was asked at one point – well what about our fish?  Our berries? 

The answer came that no- according to NHPA, plants and animals are not considered historic properties….they are protected under NEPA.

BUT- berry picking spots and hunting places, those could be included as historic properties.

After all of this is complete, the Corps must then:

STEP 2 – Determine effects of project on these Historic Properties

STEP 3- Explore Measures to Reduce Effects To the Properties

Step 4 – Reach an Agreement with the State Historic Preservation Office & Tribal Historic Preservation Office on such measures to resolve adverse effects.

All of these steps talk about “effects”.  There are three main outcomes here:

Findings of Effects can be that a) no historic properties are present, or there will be no effect on them, b) no adverse effect – project won’t significantly diminish qualities of Historic Properties, c) adverse effect – direct, indirect or cumulative effects will significantly diminish qualities that make the Historic Properties eligible

Now, of course, there has to be a paper trail.   What does that look like?

All of the information discussed above will be put into a “Cultural Resource Management Plan” and a Programmatic Agreement.  The Programmatic Agreement is a legally binding document that Donlin will have to follow if the project is permitted.

A  Draft Programmatic Agreement (with draft versions of  APE  and the Cultural Resource Management Plan) will be released in January or February of 2017.  At that point, public comment is welcome on the documents.

But that doesn’t mean you have to wait until then to offer your comments.  Public comment is welcome at any point during the process.  Until the APE is defined, it will be hard to determine whether or not cultural resources of concern to you will be impacted, but that doesn’t mean you can’t let the Corps know about them.

Comments can be provided via e-mail to Richard L Darden, Ph. D at or Jenny Blanchard, Archeologist at

Comments are welcome on the Section 106 process itself, or concerns or ideas regarding the content of the Programmatic Agreement.  They also are looking for information on historic sites, archaeological sites, or properties of traditional, religious or cultural significance that may be  within the project area and on their “significance”.  Comments can be kept confidential if that is preferred.

Stay tuned for more about the historic finds that Donlin has already made in the region.