Comment Letter on the Donlin Gas Pipeline ROW Lease

March 22, 2019

State of Alaska, Department of Natural Resources
Pipeline Coordinator’s Section
3651 Penland Parkway
Anchorage, AK 99508

Via email to: [email protected]

Re: Commissioner’s Analysis and Proposed Decision Donlin Gold’s gas pipeline right-of-way lease request, ADL 231908 

To Whom It May Concern:

The Resource Development Council for Alaska, Inc. (RDC) is writing in support of approval of the Donlin Gold, LLC (Donlin) gas pipeline right-of-way lease request. RDC supports the Commissioner’s analysis of the application that finds “Donlin to be fit, willing, and able to operate the pipeline in the manner required by Alaska Statute 38.35.100.”

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 urges the State Pipeline Coordinator’s Office (SPCO) to move forward with the right-of-way lease for the gas pipeline for the proposed Donlin Gold project site. Donlin’s application for the right-of-way lease for the natural gas pipeline from Cook Inlet to the proposed mine north of Crooked Creek will be for a 14-inch diameter, 315-mile line. RDC notes the gas pipeline will also include fiber optic cable to be built within the right-of-way under a separate authorization. 

The gas pipeline will provide a stable source of energy for the Donlin project, and has the potential to offer the same to local communities if they choose to tie into the gas pipeline at a later date. The same goes for the fiber optic cable, if communities choose to tie into it, to increase telecommunication capacity and provide other opportunities. The pipeline will bring natural gas closer to rural Alaska, and potentially offer lower cost energy options to the region and job opportunities leading to reduced out-migration. The gas pipeline is also a superior energy source than other options, and offers a better delivery method.

Construction of the pipeline, lasting two to three years, will provide jobs to Alaskans, plus ongoing security and maintenance work. For further safety measures, Donlin Gold has committed to adding four safety cabins along the trail through the Alaska Range when the pipeline is constructed as part of its project mitigation.

Donlin proposed the gas pipeline as an alternative after residents along the Kuskokwim River expressed concerns about excess barge traffic delivering diesel to the project. The pipeline will reduce expected fuel barge traffic on the river by nearly 67%.

In addition, Donlin has committed to burying nearly all of the pipeline to reduce visual impact and environmental footprint, as well as reclaiming temporary infrastructure, such as roads and landing strips. The proposed pipeline project includes designs to mitigate potential seismic disturbances at the Denali and Castle Mountain Fault crossings, and check valves about every 20 miles to protect against leaks.

Further, the footprint of the proposed pipeline is narrow as to reduce environmental impact. Permanent infrastructure of the pipeline will be minimal, and winter construction will reduce impacts to the surrounding environment and uses, including sport and subsistence hunting.

The Iditarod Trail Committee, Iditarod Sled Dog Race, the Iron Dog Race, and other users have been kept informed of the proposed project and pipeline. The route has been optimized to reduce overlap with the historic Iditarod Trail, including rerouting through the Jones River valley and the north route option near Happy River – which ultimately eliminates any co-location with the trail.

About the Donlin Gold project

The Donlin Gold project is located in a region of Alaska that experiences some of the highest unemployment and poverty rates and has very few 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.

New mining operations in the area, should they come to fruition, can be of great economic benefit to Alaska and local communities, as well as Alaska Native corporations and shareholders. The Donlin project could produce gold for over 25 years, while providing family wage jobs in a region where few other opportunities exist. 

The project, when developed, would benefit Alaska Native corporations statewide. Royalties paid to the Calista Corporation will in part be redistributed to other regional and village corporations. The Donlin project will provide responsible economic prospects for this region and for Alaska, while protecting the subsistence resources.

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

Further, Donlin Gold has engaged with the communities in the region since submitting its application in 2014.  In every public meeting in Bethel, and in many other lower Y-K communities, Yup’ik translators have been made available for stakeholders who may require translation. 


In closing, RDC supports the SPCO’s decision and urges the SPCO to move forward and approve the right-of-way lease for the Donlin Gold gas pipeline. RDC believes a pipeline to Western Alaska is much needed, and without stable energy, projects like Donlin in rural Alaska will likely not be feasible.

Thank you for the opportunity to comment on this important project.