State agencies seek comments on IPOP mining permits

The Alaska Department of Environmental Conservation and the Department of Natural Resources seek comments on the controversial proposal by IPOP LLC, a Nevada-based outfit with no mining background, to mine for gold in the Bonanza Channel and Safety Sound estuary.
The DEC permits the wastewater discharge from the proposed silt curtain containment system into the fragile estuary of Bonanza Channel.
The DNR issues land use permits, approves the plan of operations and a reclamation plan. The DNR’s public notice, which was not advertised in The Nome Nugget, the paper of record for this region, was issued on Tuesday, July 16.
The comment period started that day and will close on July 30, leaving a short window for the public to wade through hundreds of pages of technical information and to effectively comment on the permit in only two weeks.
According to the DNR’s Application for Permits to Mine in Alaska, APMA for short, IPOP plans to use a 70-foot long cutterhead dredge to cut a mining channel and to use a 10-inch suction nozzle in hopes to find gold. The average number of workers on site would be five to 15. The mining would start as soon as permits are issued, until anticipated closure in December 2028.
The proposed project would affect an area of 159.4 acres and remove about 4.5 million cubic yards of the silty sod that is creating habitat for vegetation and fish. The applicant proposes to mine in the summer months from June 1 to November 1 and operate the dredge for 20 hours daily.
IPOP proposes to set up a one-acre man camp including office and living quarters on wheels at an access trail to Bonanza Channel. They propose to haul water and have their greywater hauled off by a contractor. In addition, fuel would be stored at the man camp site.
The application materials consist of the APMA application itself and 15 attachments that include the list of equipment, plan of operations, access road creation and repair, reclamation plan and the U.S. Army Corps of Engineers 404 permit and decision document that overturned the Alaska District’s initial denial of the permit.
The DEC permit authorizes and sets conditions to discharge pollutants from the project into the waters, placing limits on the pollutants. The comment period for that permit began June 28 and will close August 5. The public notice was published once in The Nome Nugget.
The permit would authorize a 100-foot radius mixing zone and the paperwork describing the silt curtain containment system launches into pages of highly technical discussion on discharge, turbidity and effluent limits.
The DEC writes in its fact sheet document that degradation of the waters would occur but that such degradation of water quality in the Bonanza Channel would be acceptable to them as there would be economic benefit to be had by the project. Taking the applicant’s word for fact, the department writes that IPOP LLC anticipates “the contribution of substantial economic benefit to local and state economies by providing employment opportunities, annual payments to the state and business to supporting industries.”
The fact sheet states that IPOP LLC’s payroll and services bought would be “in excess of $3,000,000 per year.”
The narrative describes that IPOP would employ 40 people.
Without evidence, it claims that IPOP would spend $2.25 million in local taxes – the project is located outside of the local government and thus out of reach for local tax collection – and that it would over the five-year project life would spend $260 million in payroll and services.  
Additionally, IPOP claims – and the DEC incorporates the claim in its permit fact sheet – that IPOP shareholders would travel to Nome and contribute about $1 million to the local economy as a result of IPOP shareholder tourism.
 What the narrative does not mention is that a thriving birding tourism industry that currently exists would be negatively impacted by the project, nor the disruption to the delicate ecosystem, nor that important subsistence and cultural activities customarily done in the Safety Sound/ Bonanza Channel area would be disrupted.
  This, the DEC concludes, is worth the sacrifice for five years of assumed economic growth. “The department concludes that the operation of IPOP LLC and the operation of the wastewater treatment system and the discharges authorized by the permit demonstrate that lowering of water quality, specified by the permit, accommodates important economic development,” the DEC document says.
This attitude is echoed in the Army Corps’ 404 permit, making the concession that there will be unavoidable adverse impacts to the waters of the United States. To compensate for the loss of valuable habitat in a world-class migratory bird stopover, the permit allows IPOP to place dredged materials “in shallow water areas with the intent of creating mud flats or replaced within the dredged footprint to reestablish vegetated shallows.”
In order to offset the negative effects at Bonanza Channel, IPOP has proposed an off-site mitigation of replacing a culvert on Red Fox Road to increase fish passage.
The proposed project garnered vehement opposition from the surrounding tribal governments, Norton Sound Economic Development Corporation, Bering Straits Native Corporation and the City of Nome government. Since the project surfaced in 2018, the local response was overwhelming opposition to the proposal. The Alaska District of the U.S. Army Corps of Engineers indeed denied the permit for the project, but the applicant appealed the decision. The Pacific Ocean Division of the Army Corps surprisingly reversed the decision and granted the permit. In a letter titled “Protecting a fragile ecosystem: A unified position to protect Safety Sound and Bonanza Channel”, NSEDC, BSNC, SNC, Kawerak Inc. Solomon Native Corporation and the Village of Solomon, lodged their opposition to IPOP and asked the Congressional delegation for intervention on IPOP’s permit. The joint letter describes that the “proposed mining activity poses a significant threat to The Clean Waters Act protections for essential fish habitats, resulting in irreversible impacts on the local aquatic ecosystem and fisheries resources.”
“The Bonanza Channel provides fish and wildlife with an estuary to produce young, provides shelter from predators, and is a source of food.  There are approximately 10 Native Allotments and over 100 campsites all along the Bonanza Channel area due to its prime location for hunting, fishing, and gathering, helping to ensure food security,” the letter says. It states the fact that the region is in the midst of a salmon crisis and that further degradation of habitat would worsen the situation. “The majority of salmon that enter the Bonanza Channel and Safety Sound Estuary come through the eastern most outlet just past the Bonanza Bridge.  If IPOP is allowed to dredge and mine these waters, their operations will impact salmon migration, further exacerbating salmon declines,” the letter states.
The entities in the letter argued that the U.S. Army Corps’ Pacific Ocean Division failed to consider the opposition expressed in local testimony and comments, and ignored the original recommendations of federal agencies like the U.S. Fish and Wildlife Service and NOAA that led the Army Corps’ Alaska District to deny the permit in the first place.
Recently, the City of Nome joined the publicly voiced opposition when the Nome Common Council unanimously passed a resolution to oppose that state permits be given to IPOP for exploration or mining at Bonanza Channel.  
For the DNR permit: Written comments, questions concerning this activity or requests to view the full application packet should be directed to Charlene Bringhurst, Telephone (907) 458-6887; Fax: (907) 451-2703; email:  dnr.fbx.mining@alaska.gov. The DNR’s materials can be found online at https://aws.state.ak.us/OnlinePublicNotices/Notices/View.aspx?id=216092
For the DEC permit: The fact sheet and documents can be requested by contacting Allan Nakanishi at allan.nakanishi@alaska.gov; phone: 907-269-4028 or 555 Cordova Street, Anchorage, AK 99501.
For online copies see http://dec.alaska.gov/water/wastewater. The public notice does not specify where to send comments, but that they must be received or postmarked by August 5, 2024.