Comment Letter on the Proposed Changes to the Kuskokwim Area Plan

March 29, 2019

Southcentral Regional Land Office
550 West 7th Avenue, Suite 900C
Anchorage, AK 99501

Via email to: [email protected]

Re: Proposed changes to the Kuskokwim Area Plan and Donlin Gold LLC Land Use Authorizations from Department of Natural Resources

To Whom It May Concern:

The Resource Development Council for Alaska, Inc. (RDC) is writing in support of the proposed changes to the Kuskokwim Area Plan. The Land Use Authorizations for the Donlin Gold, LLC (Donlin) project would allow for a submerged lands lease for a port, a private road easement, an airstrip, a fiber optic cable from Cook Inlet to the project site along the proposed natural gas pipeline route, and materials sites on State lands for road construction. 

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 to grant the land use authorizations for the proposed Donlin Gold project site. The authorization would benefit the State by generating revenues from use of state lands, lands that have very little revenue potential otherwise. All of the land uses proposed would generate significant direct and indirect revenues for the State.

The gas pipeline would 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 pipeline, or use power generated from its natural gas at a later date. The same goes for a fiber optic cable that would run alongside the pipeline. If communities choose to tie into it, it would 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 cleaner, superior energy source than other options and offers a better delivery method.

Further, approval would give Donlin access to the project site while avoiding direct impacts to the village of Crooked Creek. A 27-mile road and port are planned to eliminate project traffic from the community by building a new port on lands owned by The Kuskokwim Corporation and Calista Corporation near Jungjuk Creek.

In addition, a Kuskokwim River port lease is needed to allow construction of a dock face to provide safe, reliable handling of materials and fuel. 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%.

Lastly, the airstrip location was selected to provide safe and reliable access for transporting crews to and from the mine site, and the proposed road easement is a private access road for public safety reasons to avoid accidents between industrial mine traffic and light vehicle use. 

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 27 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 proposed changes to the Kuskokwim Area Plan, and the Land Use Authorizations for the Donlin project. Thank you for the opportunity to comment on this important project.