Comments in Support of Donlin Gold Preliminary Decision for ADL 236624, ADL 234025, and ADL 234035

RDC Action Alert 


August 15, 2022

Submitted electronically via: [email protected]
DNR, DMLW, Survey Section
ATTN: Stuart Greenfield
550 W. 7th Ave., Ste. 900C

Anchorage, AK 99501

Re:       Comments on Preliminary Decision for ADL 236624, ADL 234025, and ADL 234035. 

Dear Mr. Greenfield:

The Resource Development Council for Alaska, Inc. (RDC) submits comments in support of Donlin Gold LLC’s (Donlin) request for the creation, vacation, closure, and partial realignment of certain easements during the life of the Donlin Mine project. RDC encourages the State of Alaska (State) Department of Natural Resources (DNR) to adopt the analysis of its Division of Mining, Land and Water Section’s (DMLW) Preliminary Decisions (PD) referenced above addressing access to public lands during the Mine’s life. This action is necessary to ensure successful development of Donlin Mine, the safety of its operations, and the public’s safety in an active industrial site. 

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

The development and operation of the Donlin Mine will provide important economic opportunities in a region of Alaska with some of the highest unemployment and poverty rates. New mining operations in the region will have great benefit to local communities, as well as Alaska Native corporations and their shareholders, while protecting subsistence resources, the culture of the region and environment. Donlin has proven its commitment to these principles through the course of permitting this project. 

In these easement modification requests, which began in 2019 and complements application EV 3-244, Donlin proposes alternate access to ensure the public’s safe access to public lands that would otherwise be limited during the Mine’s development, operations, and reclamation. The proposed Alternative Public Access Route (APAR) is narrowly tailored to achieve this purpose and maximizes access by proposing a 100-foot wide, 24-mile long APAR to be maintained by Donlin during the life of the mine. The APAR ensures continued safe public access for local residents and communities for pedestrian, ATV, snowmachine, freight traffic, and dogsled transport vital to the region while avoiding dangerous travel through an industrial site. 

For these reasons, RDC urges DNR to approve ADL 236624, ADL 234035 and ADL 234035 to allow the project to continue to move towards successful development.