Donlin Gold Compensatory Mitigation Plan Comments Submitted!

The Final Environmental Impact Statement (FEIS) for Donlin Gold was released on April 27, 2018. An additional commenting period was opened for the updated Compensatory Mitigation Plan (CMP) of the FEIS, located in Appendices J and M of the FEIS. The CMP addresses how Donlin Gold plans to mitigate short- and long-term temporary disturbances and permanent disturbances to wetlands, riparian areas, and streams in the Mine, Pipeline, and Transportation Areas. These comments were due by May 29, 2018.After reviewing the updated CMP, Georgetown submitted comments that will be reviewed and addressed with other comments submitted by the public. We appreciate the ability to voice our concerns and receive meaningful responses from U.S. Army Corps of Engineers (USACE) as the Kuskokwim and other areas should be developed properly to avoid unnecessarily damaging the environment.As a summary, most of the comments submitted by Georgetown were in support of requiring stricter language, additional research, and further explanation of Donlin Gold's decisions for compensatory mitigation.

• We expressed the need for stricter language for Donlin Gold's timeline to remediate disturbed sites. In the updated CMP, timelines were suggested with the phrasing "as soon as practicable," which we felt should be addressed to ensure remediation will occur in a timely manner.
• The updated CMP also included plans for remediating old placer mines by removing berms and revegetating to realign the water channels. Georgetown was concerned about the mineralogy of the sediments by historical and requested additional and requested additional studies be completed on sediments of the historical placer mines and berms.
• Georgetown requested stricter requirements for revegetation to take necessary actions to limit invasive plants during revegetation and measure successful revegetation on remediated berms and tailings. Georgetown also requested additional studies of subsistence fish species for metals and other contaminants in the remediated area.
• Georgetown expressed concerns about the viability of the Chuitna wetland preservation option for compensatory mitigation plan. Protecting the wetlands of Alaska is very important to preserve the natural filtration process for water quality as well as limiting impacts of natural resource extraction or other human activities. However, Donlin Gold's plan for preserving wetlands in the Chuitna watershed is a point of concern for Georgetown. This does not impeded future mining operations from permitting and operating upstream and may still impact the watershed. Water quality testing was requested by Georgetown to be included in the CMP for the Chuitna preservation plan to develop a baseline in case of future natural resource extraction in the area.
• More information on the Fuller Creek watershed preservation was requested to explain why the preservation plan, located in the Middle Kuskokwim Region, was rejected.

This is a summary of the thoughts and concerns submitted by Georgetown as comments to USACE for the Donlin Gold Compensatory Mitigation Plan. If you are interested in reading a full version of our comments, please email me and I can send you a copy. As this process continues to move forward, I will do my best to keep you informed, and please don't hesitate to send me any questions you may have.

Meredith Wittemeredith.witte@georgetowntc.comPC: Donlin Gold  June 7, 2018