by Dave Cannon
By now you might have heard about the recent mine tailings dam collapse in Brazil that killed 58 people with hundreds still missing.
You may, or may not, be aware of the recent Op-Ed about the Donlin Gold Mine by the new Commissioner of DNR – Corri Feige – that appeared in several papers around the state. In her Op-Ed, she more or less gave several assurances that the State’s approval of the mine would guarantee few, if any, impacts to the environment here in the Kuskokwim.
Commissioner Feige states: “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 doesn’t mention that the State has never before permitted a mine designed with a pit lake two-miles long and 1,800’ deep – filled with toxic wastewater – that will require water treatment in perpetuity. What about human and mechanical failure? Don’t forget, this project is off the road system. Perpetuity is forever!
Here is what else Ms. Feige had to say. “Overall, I have been very impressed by the rigor of the baseline data collection and analyses that have been conducted for the Donlin Gold project. From tailings management to mercury and cyanide risks, to potential impacts on fish and subsistence resources, the project has undergone a high level of scrutiny. In every case, Donlin Gold has never shied away from tackling difficult questions, and has often gone above and beyond what is required by the statutes and regulations.
Donlin Gold didn’t go beyond the requirements in addressing the impacts of a substantial failure of the eventual 470’ tall tailings dam; they only considered a 0.5 % material release. This excerpt is from a scoping letter that Stan Foo, the then General Manager for Donlin Gold, submitted to the Corps of Engineers (COE) 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 scoping letter was written a year before two other catastrophic tailings dam failures – the Mount Polley Mine (MP) in British Columbia and the Brazilian mine in Mariana that killed seventeen people … both relatively new projects. Unfortunately for the residents of the Kuskokwim region, neither the COE nor the State have yet to require an adequate assessment of such catastrophic failures.
The Donlin folks, however, are quick to point out how different the planned tailings dam above Crooked Creek will be from the MP dam that collapsed in 2014. They say, “1) the Donlin dam will be anchored to bedrock rather than built on glacial silt, 2) the Donlin dam will be built with a downstream design as opposed to the upstream design for MP’s, and 3) the Donlin tailings storage facility will be lined as opposed to MP’s.” They also note that it will be designed similar to the one at Fort Knox, which they say, “easily withstood the 2002 Denali earthquake of 7.9 magnitude.”
The Fort Knox dam was less than 300 feet high at the time of the quake, but as noted, Donlin’s will be at least 470 feet high. No matter what, there are no guarantees that problems won’t arise either during the life of the mine (which is when all of the previously mentioned failures occurred) or after closure. And the tailings dam in the Kuskokwim will be around forever and ever possibly affecting future generations.
Yet another questionable statement by Ms. Feige: “I’ve also seen the extensive and meaningful public outreach throughout the Y-K region by Donlin Gold and the agencies.”
From my experiences after visiting over twelve Kuskokwim villages from Kwigillingok to McGrath, many local residents feel they haven’t been adequately kept informed about the project. Prior to the FEIS being released, I contacted the COE’s Project Manager and asked if anyone from his agency would be coming to the region and explaining the contents of a document that stands over a foot high and is filled with highly 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.
Ask yourselves this: “How many of you really know what was in the Draft or Final EIS’s?”
Is Donlin doing everything they can to minimize or eliminate impacts to the resources we rely so heavily on? Let’s look at a Letter to the Editor that appeared in the Delta Discovery last October by Andy Cole with Donlin and Andrew Guy with Calista regarding Ballot Measure #1. They started out with: “Truth is important, especially when the stakes are as high as they are with Ballot Measure 1, the salmon-habitat initiative.”
Huge companies – some of the largest in the world – often make little ones to their benefit. Here’s what they wrote: “Donlin Gold is an Alaska limited liability company created in 2007 to develop and operate the project. It is owned by NovaGold Resources Alaska Inc., an Alaska company, and Barrick Gold US Inc., a California company. Their parent companies are registered in Canada, and their shares are publicly traded on stock markets both in Canada and the U.S.”
If you look at Nova Gold’s Board of Directors, they’re from all over the world; likewise, for Barrick that recently merged with a company from across the Atlantic. The truth is, the main players involved with making the Donlin Mine decisions are not really from Alaska. What will bear that out is if one day, the Chinese aren’t part owner in this endeavor. That is something that some local miners have expressed concern to me over.
Mr. Cole and Mr. Guy wrote this: “As part of the six-year Environmental Impact Statement process, state and federal regulators kept the public comment periods open for more than nine months and held over 50 public meetings, primarily in the YK region. More than 7,500 substantive comments were received and considered.”
My response to this would be the same as above for Ms. Feige’s similar assertion. The proponents of the Donlin Mine would like everyone to think that the people of region had meaningful input into the process. But the truth is, most of the comments from local residents were disregarded (including some state and federal biologists); for example, the routing of the pipeline location in the vicinity of McGrath and Nikolai.
Don’t buy into statements like this: “Further, the compensatory mitigation to which Donlin Gold agreed will rehabilitate Crooked Creek tributaries that were affected by old placer mining done by other miners before Donlin Gold even existed, providing better fish habitat than what exists now in the tributaries that the project will affect.”
The habitat that they’re talking about was marginal fish habitat at best, even before it was impacted from past mining operations. Regarding salmon, very few salmon ever used those streams. What the mine operation will do is remove a good proportion of Crooked Creek’s water, 80-100% near that “improved habitat” area, and roughly 30 % or more down near Crooked Creek’s mouth where it enters the Kuskokwim River.
That dewatering will have a negative impact on the spawning salmon adults, but more importantly the developing eggs that are in the gravel during the winter…the most critical period. Without adequate flows, the delicate eggs could be left high and dry during the late summer or fall and easily freeze in the winter.
However, this, to me, is the most erroneous statement of Mr. Guy and Mr. Cole’s Letter to the Editor and should be a concern to all of us: “Both Calista and TKC take very seriously their responsibility to ensure that development of the Donlin Gold project is carried out in a thoughtful manner that safeguards Shareholders’ way of life and protects all resources, including salmon and rainbow smelt.”
The FEIS 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 in the FEIS is woefully inadequate to protect the smelt. Five of the last ten years the Kuskokwim River has experienced low flows during May and early June. If Donlin Gold, the State, and the COE were sincere about “ensuring” no impacts to the smelt, those 3,000 h.p. 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.
That is the truth; anything else is just a hollow promise.
Dave Cannon is a resident of Aniak, AK.