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Mr. Jamie R. Hyslop
U.S. Army Corps of Engineer
Alaska District CEPOA-RD-Hyslop
P.O. Box 6989
JBER, AK 99506-0898
Via E-mail: POA.donlingoldeis@usace.army.mil

Re: Donlin Gold Compensatory Mitigation Plan

Dear Mr. Hyslop,

Thank you for the opportunity to comment on the Donlin Gold proposed Compensatory Mitigation Plan. These comments are submitted on behalf of Earthworks, Earthjustice, Northern Alaska Environmental Center and Cook Inletkeeper.

Cook Inletkeeper is a community-based nonprofit organization formed in 1995 by concerned Alaskans to protect the Cook Inlet watershed and the life it sustains. Northern Alaska Environmental Center is an Alaska-based conservation organization dedicated to protecting the land, waters and wildlife of Interior and Arctic Alaska for current and future generations to use and enjoy. Earthworks is a national non-profit organization dedicated to protecting communities and the environment against the adverse effects of mining, while promoting sustainable solutions. Earthjustice is a non-profit environmental law firm wielding the power of law and the strength of partnership to preserve the wild, to fight for healthy communities and to advance clean energy for a health climate.

In general, we are concerned that the proposed Compensatory Mitigation Plan lacks sufficient information to determine whether wetland losses will be adequately compensated by the proposed mitigations. As a result, Donlin should be required to provide additional information, and apply for a new Section 404 permit. The CMP and final mitigation plans should be re-noticed, with a public comment period in accordance with the 2008 Mitigation Rule. Please see the attached technical comments for more detail.


Bonnie Gestring
Northwest Program Director Earthworks

Tom Waldo
Staff Attorney Earthjustice

Lachlan Gillespie
Clean Water and Mining Program Director Northern Alaska Environmental Center

Bob Shavelson
Inletkeeper and Advocacy Director Cook Inletkeeper

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