Comments in Support of Donlin Gold Preliminary Decision on EV 3-244

RDC Action Alert 


August 15, 2022

Submitted electronically via: [email protected]
DNR, DMLW, Survey Section
ATTN: Victoria Brown
550 W. 7th Ave., Ste. 650

Anchorage, AK 99501

Re:       Comments on Preliminary Decision to vacate easements requested by Donlin Gold LCC, EV 3-244

Dear Ms. Brown: 

The Resource Development Council for Alaska, Inc. (RDC) submits comments in support of Donlin Gold LLC’s (Donlin) request to vacate certain easements for the development 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 Decision (PD) on EV 3-244. 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 project 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 this easement vacation (EV) request, which began in 2015, Donlin proposes alternate access in a way that satisfies the State’s best interests by ensuring safe, continued, and permanent alternate access to public trail networks both during and after operations are concluded. In exchange for the EVs, Donlin proposes to donate easements (DEs) that meet all present and reasonably foreseeable uses for future trail development, maintain an interconnected network of public access, and are reasonably comparable in length, width, and terrain to the current trail access network. The result is improved access, including a one-mile buffer to allow for the most effective location of final routes post-reclamation.  The PD will result in higher protections for public access of the trail networks because, once recorded, the DEs will provide greater legal certainty of public access routes over private lands. 

For these reasons, RDC urges DNR to approve the PD so the project can continue to move towards successful development.