Donlin Gold Draft APDES

February 13, 2018

Allan Nakanishi, PE
Alaska Department of Environmental Conservation
Division of Water, Wastewater Discharge Authorization Program
555 Cordova Street
Anchorage, AK 99501

Via email to [email protected]

Re: APDES Draft Permit AK0055867 for the Donlin Gold Project

Dear Mr. Nakanishi:

The Resource Development Council for Alaska, Inc. (RDC) is writing to urge approval of the Department of Environmental Conservation (DEC) proposed Alaska Pollutant Discharge Elimination System (APDES) Draft Permit AK0055867.

RDC is a statewide business association comprised of individuals and companies from Alaska’s oil and gas, mining, forest products, tourism and fisheries industries. RDC’s membership includes Alaska Native Corporations, local communities, organized labor, and industry support firms. RDC’s purpose is to encourage a strong, diversified private sector in Alaska and expand the state’s economic base through the responsible development of our natural resources.

RDC supports DEC’s approval of the APDES permit to Donlin Gold. The permit authorizes and sets appropriate conditions on the discharge of pollutants from this facility to waters of the United States. The permit ensures protection of water quality and human health, places limits on the types and amounts of pollutants that can be discharged from the facility and outlines best management practices to which the facility must adhere. 

As stated in the APDES permit, the authorized discharge of treated wastewater to Crooked Creek will result from a net positive water balance thus necessitating the need to discharge excess water. According to the permit, the proper treatments will be in place, and there will be no mixing zone. 

Further, Donlin Gold will monitor the treated water, and reports will be reviewed by DEC and available to the public.

In regards to the Donlin Gold project, the potential benefits of future production are significant, not only to the rural communities in the areas around the project, but also to the descendants and shareholders of Alaska Native corporations, as well as benefits that will be realized through jobs and other opportunities.

Through the exploration stages, Donlin has shown a strong commitment to local hire and for supporting communities and cultures in the region. A project like this truly is a rare opportunity to improve the local economy where few other opportunities exist.

If developed, RDC believes the project will be done in a way that creates opportunity for local employment and economic growth, while protecting the subsistence resources and culture of the region, and the environment.

We appreciate the opportunity to comment on this important part of Alaska’s rigorous permitting process that has already permitted the six large mines under the review of NEPA and the scientifically-based process which includes over 60 major state and federal permits and authorizations. Alaska’s existing mines are operating to the highest standards and in harmony with our renewable resources. Donlin’s project description demonstrates an understanding of environmental concerns, and features vigorous environmental management principles.

In conclusion, RDC urges the DEC to approve thisAPDES permit in a timely manner. As our state faces a fiscal crisis, it is also imperative projects be allowed to go through Alaska’s well-vetted permitting process without unnecessary delay, and show investors that Alaska is “open for business.”

Thank you again for the opportunity to comment on this important issue.


Resource Development Council for Alaska, Inc.