by Grant Fairbanks
Donlin is not ready or capable to build a safe mine at this time. Their proposed gold mine would be the largest of this type in the world. After reading over 5000 pages of the Donlin Environmental Impact Statement from the Corp of Engineers, after reading hundreds of pages of testimony and comments addressing the technical and scientific analysis of this proposed mine it is evident that it is too soon to issue any permits for this mine.
This mine has been labeled as a “Perpetually Polluting” mine. Meaning that there will always be some type of pollution coming from the facility once it is operating and possibly even before it operates. Any discharge into the air, water table or streams different from the baseline or naturally occurring environment at the proposed mine site will cause some type of harm.
Just regulated and/or permitted discharges to the air or Crooked Creek will cause harm to the areas animals, fish, water and air.
The public needs additional time to read, study and comment on any changes to the EIS from our comments and those of 3rd party scientists and professionals whom have submitted very technical papers. We are not at a time or place to accept a Final Environmental Impact Statement.
There are too many design questions in the mine plan that have not been addressed or proven to work using pilot plants or modeling.
The U.S. Department of the Interior has concerns pertaining to ground water data supplied by Donlin and it is evident that more studies must be done and that better models need to be constructed to prove Donlin’s proposed facility will work as implied. There are questions about post closure contaminant transported in the groundwater flow from the pit to local streams.
After reading the comments from the U.S. Environmental Protection Agency (EPA) about their concerns of the Donlin mine I feel we need to see what corrective plan the mine has before we are presented with the Final EIS.
The EPA noted that a Health Impact Assessment was not included in the Donlin EIS and that the public first must know about the health risks from this mine before a Final EIS is issued. The EPA is also concerned with elevated mercury and arsenic concentrations in local water and sediment. They are concerned about premature mine closure and how that would affect financial assurances for closure and reclamation.
If the trust fund for closure, reclamation and perpetual water treatment is not large enough for any foreseeable problems then the land owners, Calista and the Kuskokwim Corp, the State of Alaska and the Federal Government will have to pay. We must all make sure the Alaska Department of Natural Resources, when establishing this financial trust fund have public meetings and be totally transparent.
In discussions around the area many people have thought that at least 2 billion dollars be on deposit before mining starts and invested in the most secure financial vehicle possible. There have been too many mines built and when the time came for cleanup the money was not sufficient to do the job.
The two biggest problems with this proposed mine in my humble view are air transported pollution to the surrounding area and then there is the big fat elephant in the room, water and hydrology.
Technical papers by world renown hydrologists state that there are too many unanswered questions and too many uncertainties with the Donlin plan and the EIS. Donlin’s water or hydrology models need much more work before they can offer us a safer mine. We must not accept this mine at this time and with their untested modeling.
As stated in a technical paper, “a primary impact of this proposed mine is the impacts mine dewatering and pit lake formation could have on the stream flow of Crooked Creek valley.”
The Federal Corp of Engineers, the lead permitting agency for this mine, plans on presenting a final EIS very soon but we the people of the Kuskokwim must demand to see all the corrections and alternatives proposed and then we must be able to comment on these items.
We are not ready for a final plan at this time. Where are all the other permits needed for this mine? Should not we see the other 96 permits that Donlin says they need? Something smells and it’s not the dead fish yet.