by Dave Cannon
As I’m writing this I’m thinking ahead a week or two, and back to just over a year ago. It won’t be long and the smelt will enter the mouth of the Kuskokwim and migrate past the lower river villages on their way to the spawning grounds near the two Kalskag villages.
I’m reflecting back to the 27th of April of last year when the Donlin Gold Final Environmental Impact Statement (FEIS) was released that was the culmination of six years of studies conducted by the Corps of Engineers (COE). Following its release, I, and others, expected to be able to comment on the entire document – specifically on whether or not the FEIS addressed our comments from the Draft Environmental Impact Statement (DEIS). In my case, my concerns focused on the likely impacts to smelt.
But there was a surprise with the study’s release. Instead of being able to comment on its entirety – including the concerns specified in the DEIS that may not had been adequately addressed – we were only able to comment on the mitigation portion…something that the public had not seen before. We only had 30-days to comment on the seemingly foreign material; all of which were in two appendices totaling over 900-pages.
Apparently, commenting on the mitigation plan was a futile effort, the Record of Decision (ROD) was released in mid-August with no changes to the FEIS.
If these acronyms and terms are confusing – you’re right. Both the DEIS and FEIS (and the plethora of documents that were associated with each of those) were chock-full of acronyms and technical jargon; sometimes too much for even those of us trained in the sciences. Those physical documents were massive, each containing thousands of pages and standing over a foot tall!
Quite troubling was that most people were expected to access much of that information via the internet. It goes without saying that many of the files were large and took much bandwidth to download. But how reliable is the internet in most villages? I spent time in McGrath last summer and couldn’t even access my E-mail.
Yet the folks at Donlin Gold have always touted the public involvement process noting how many villages officially participated. The reality is, however, that half of the tribes listed as Cooperating Agencies actually had meaningful input; Napaimute, Chuathbaluk, and Knik were able to effectively participate only because they had access to technical expertise.
The six-year process was so complicated and onerous that it was only toward the end of the process that several lower and upper river villages realized what impacts the mine and associated activities could have. When they requested Government to Government relations with the COE, they were refused.
I specifically asked the COE shortly after the FEIS was released if anyone was going to come out to the Kuskokwim and explain what was in the complex document … and their short answer was, “No”.
But now let’s go back a few more years to the release of the 7,000-page Draft Environmental Impact Statement in 2015. The COE held numerous meetings throughout the region asking for public input to be considered in the draft document. However, when it was released – there was no one to explain the highly technical jargon that it contained. It was so technical and cumbersome that residents (and scientific experts) asked for additional time to digest everything; consequently, the Corps granted an additional 30-days for comments on the contents of the DEIS.
At this later stage in the process, the COE was now looking for substantive comments dealing with specific topics, not comments like, “Yes, I’m for the mine”, or, “I’m opposed to the mine”.
Although I was highly involved in the process up until that time, I struggled keeping up with everything. I, like many people, had been to countless COE, Donlin Gold, and Kuskokwim Corporation meetings where everything from the EIS process, Donlin’s design plans, and the likely formation of a borough were discussed. It was a lot to comprehend.
During that time, I worked for the Kuskokwim River Watershed Council and thought about the lack of meaningful information that was being presented at these meetings, knowing people needed to be more informed about the project’s trade-offs. So, I took it upon myself to go out to as many villages as possible and give presentations titled Understanding the Donlin Gold DEIS & Writing Effective Comments.
I planned to point out where in the draft document many of the concerns local residents brought up during the scoping period were, and whether or not they might be adequately addressed. One concern I highlighted related to our smelt, which I’ll soon discuss.
I made up numerous copies of the Power Point presentation on CD’s and passed some out at the 2016 Alaska Forum on the Environment; some Donlin Gold employees asked for a copy and I didn’t hesitate in providing one. Soon after that, Donlin folks complained to the COE that I was stirring up opposition. Fortunately, the COE determined that there was nothing inappropriate about the information I was providing.
Why would Donlin be troubled about people expressing concerns over the mine’s activities on the environment and our subsistence resources? It’s evident if you go back to a report prepared for NovaGold in 2006 that states that, “Significant public response during the Project’s permitting phase could alter the permitting timeline.”
Is it any wonder then why Donlin Gold has spent hundreds of thousands of dollars “ensuring” us that the mine will be done in an environmentally responsible manner?
This is but ONE example of many times over a 15-year period that the Donlin folks have assured us that there will be no impacts to subsistence resources; it’s from a recent opinion piece by Donlin’s Project Manager that appeared in this paper: 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.
It’s hard to counteract the amount of money that Donlin Gold has spent on pro-propaganda.
Almost from day one, the mine’s proponents have downplayed the tradeoffs that you and I will have to contend with should the mine be built.
This all brings me to the next couple of weeks when the smelt will be arriving in the Kuskokwim. I, and others, submitted comments regarding our concerns for impacts to the smelt from the increased barging that will occur if the mine were to proceed. Those concerns brought up in the DEIS were not addressed in the FEIS … they weren’t even mentioned in the Mitigation Measures in Appendices J & M.
Here’s why the smelt concerns were not addressed. Although the DEIS (and FEIS) stated: The propeller scour of passing tug traffic in such locations could have resulted in detectable incidents of injury or mortality to incubating fish eggs or population-level effects depending on the tug’s horsepower rating and engine speed. Because of the 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.
Yet, the Corps of Engineers approved the following monitoring plan developed by Donlin Gold for smelt: Donlin Gold would develop and implement a rainbow smelt monitoring program to establish additional baseline data for a better understanding of the species’ occurrence and the character, use, and distribution of spawning habitat along the Kuskokwim River. Survey methodology would likely include documenting sex ratio and age structure of the population and if possible, fecundity of females. Initially, surveys would be conducted annually to document the age structure of the rainbow smelt population and further document spawning patterns. Once an adequate baseline is established, regular sampling would be used to monitor for changes to existing patterns. The frequency of surveys over the long-term would depend on previous results and whether the data indicate a potential shift.
If rainbow smelt population changes are observed over a defined time period, additional work would need to be undertaken to investigate the reason for those changes. If observed changes were attributed to project-related activities, Donlin Gold would implement an assessment of measures available to address or mitigate those activities.
But there’s a problem with that. I’ve talked to researchers who’ve studied smelt and other similar species, and it’s extremely difficult to accurately quantify them in such a large system as the Kuskokwim. Think of the difficulty biologists have at determining a precise drainage-wide abundance estimate for the various species of salmon. Biologists use confidence intervals to indicate how accurate certain measurements are, and the confidence intervals for the amount of smelt returning each year would be too large to give anyone confidence that population trends over time were being affected by any one influence.
Definitively attributing an impact from a “project related activity” would be next to impossible. Furthermore, the time that it would take to attribute such an impact, plus the additional work to undertake a further investigation, could result in a population level impact that may be irreversible since barging would continue throughout the life of the project.
It was my recommendation for both the DEIS and FEIS to cease the barging activities for the Donlin project while the smelt eggs were developing on the river bottom (for about three weeks). Yes, barges have navigated the river for years and the smelt run is still strong, but the tug/barge combinations – and the amount of traffic – that will support the Donlin project are much larger and powerful than anything seen before.
To me, that is the ONLY way to ensure that there will be no harm done to the smelt population as a result of the operation of the mine.
Dave Cannon is a resident of Aniak, AK.