I was surprised to see appointed Department of Natural Resources Commissioner Corri Feige’s op-ed regarding the Donlin Gold project that appeared in many newspapers. I must ask, if DNR were to deny a similar project, would the commissioner have written such a thing explaining the reasons? So, why this, and why now?
I take issue to several of Ms. Feige’s statements, especially the assurances of protections to water quality and fisheries resources.
I’m a fish biologist and have lived in the Kuskokwim drainage for 20 years and attended countless Donlin meetings hosted by the Army Corps of Engineers, DNR, Calista and The Kuskokwim Corp., as well as by Donlin officials themselves. I not only followed the environmental impact statement process from beginning to end, I formally participated in it. From the time I started following the progression of the project’s exploration and development in 2002, I’ve observed how the potential environmental impacts have continually been whitewashed by proponents of the mine. It now appears that some of those concerns have been similarly brushed aside by permitting agencies.
Commissioner Feige stated: “Alaskans often ask how we can protect the environment … and especially about long-term, post-closure water management. Our ... commitment to addressing these requirements has grown significantly in recent decades.”
She didn’t mention that the state has never before permitted a mine designed with a pit lake two miles long and 1,800 feet deep, filled with toxic wastewater, that will require water treatment in perpetuity. What about human and mechanical failures? Don’t forget, this project is off the road system. Perpetuity is forever.
I question this statement by Ms. Feige: “Donlin Gold has never shied away from tackling difficult questions, often going beyond legal and regulatory requirements.”
Donlin Gold didn’t go beyond the requirements in addressing the impacts of a substantial failure of the eventual 470-foot-tall tailings dam; they only considered a 0.5 percent material release. This excerpt is from a scoping letter that DG submitted to the Corps in 2013: “Some participants at the scoping meetings stated that the EIS needs to address catastrophic failures such as pipeline breaks or dam failures ... we encourage the Corps to give due consideration to those impacts which are foreseeable and essential to the consideration of alternatives versus those which are remote and highly speculative ... we know of no other EISs that evaluated impacts due to a tailings dam failure, and we think that scenario should not be evaluated in the Donlin Gold EIS.”
That letter was written shortly before two catastrophic tailings dam failures – the Mount Polley Mine in British Columbia and the Brazilian mine in Mariana that killed 17 people — both relatively new projects. Recently, a third dam failed in Brazil, killing many people. Unfortunately for the residents of the Kuskokwim region, the Corps of Engineers did not require an adequate assessment of such catastrophic failures.
I also find this statement by Ms. Feige questionable: “I’ve also seen the extensive and meaningful public outreach throughout the Yukon-Kuskokwim region by Donlin Gold and the agencies.”
From my experiences after visiting more than a dozen Kuskokwim villages, local residents feel they haven’t been adequately kept informed about the project. Prior to the final environmental impact statement being released, I contacted the Corps of Engineers’ project manager and asked if anyone from his agency would be coming to the region and explaining the contents of a document that stands more than a foot high and is filled with technical jargon. Because it was so voluminous and expensive to print, people were expected to download the materials online. However, the internet in most villages is too slow to effectively do that. The project manager informed me that there were no such plans.
Lastly, Donlin Gold won’t take measures to ensure no impacts to the smelt population of the Kuskokwim, and the Corps of Engineers won’t require them to do so.
The final environmental impact statement determined that a “medium to high level of injury or mortality” could occur to incubating eggs during years of low water: “Because of the narrow width and relatively shallow depth across this particular channel segment, it is unlikely that impacts to incubating rainbow smelt eggs could have been avoided by altering the line of travel of barge traffic.”
The mitigation plan in the final EIS is woefully inadequate to protect the smelt. The Kuskokwim River has experienced low water during five of the past 10 years. If Donlin Gold, the state and the Corps of Engineers were sincere about “ensuring” no impacts to the smelt, those 3,000-horsepower tug-barge tows would cease for a one-month period from the time the smelt reach the spawning grounds to the time the juveniles safely migrate out.
Dave Cannon moved to Bethel in 1998 to be the fish biologist with the Yukon Delta National Wildlife Refuge, and then moved to Aniak in 2002 to work with the Kuskokwim Native Association and Native Village of Napaimute. He currently works for the Kuskokwim River Watershed Council.
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