The federal government has released a new Draft Supplemental Environmental Impact Statement for the proposed Donlin Gold Mine, and the findings deserve close attention.
The new analysis looks at what could happen if substantially more mine waste were released from Donlin’s proposed tailings storage facility than federal agencies considered when the project was originally approved.
Under the scenarios analyzed by the U.S. Army Corps of Engineers, a larger tailings dam failure could result in loss of life, displacement, long-term contamination, generational impacts to fish, significant restrictions on subsistence, and conditions that could make the Village of Crooked Creek uninhabitable.
The public has until October 23, 2026 to comment.
But before getting into what the new study says, it is important to recognize why this review is happening at all.
What does the new Donlin review actually study?
The Draft SEIS is not a completely new environmental review of the Donlin project.
Instead, it responds specifically to the court ruling requiring the federal government to examine larger tailings releases than the approximately 0.5 percent release evaluated in the original 2018 analysis.
The new review examines scenarios involving releases identified as approximately 5.4 percent, 13.3 percent, and 27 percent of the tailings facility.
The Army Corps describes a tailings dam failure as extremely unlikely. But risk is not only about the likelihood of something happening. It is also about the consequences if it does.
Crooked Creek could become uninhabitable
Crooked Creek is approximately 10 miles downstream from the proposed mine. Under the 5.4 percent scenario, the federal analysis describes inundation and burial of boat ramps, parts of the airstrip, the bridge, access roads, and shoreline residences. It also identifies potential displacement and loss of life.
Under the 13.3 percent scenario, tailings could accumulate 3 to 30 feet deep in some areas and the analysis says it is likely that Crooked Creek would no longer be habitable.
Under the 27 percent scenario, the analysis describes 10 to 30 feet of tailings deposition, full inundation of the community airstrip, and again concludes that the village could become uninhabitable.
These are scenarios, not predictions that a failure will occur.
But when a federal environmental analysis identifies the possibility that an Alaska community could become uninhabitable, that deserves more than a footnote and more technical analysis.
Ninety minutes is not an evacuation plan
Under the 27 percent scenario, the modeled front of the release would reach Crooked Creek in approximately 90 minutes. The peak would arrive approximately 110 minutes after the failure.
At the same time, the scenario anticipates impacts to roads, river access, residences, and complete inundation of the community’s airstrip. An estimated arrival time is not the same thing as demonstrating that everyone could safely evacuate.
The public deserves to know:
- How quickly would a failure be detected?
- How would residents be notified?
- Where would people go?
- How would elders, children, people with disabilities, or people without immediate transportation evacuate?
- What happens if the airstrip or river access becomes unusable?
Those questions should be answered before federal agencies decide whether to reaffirm the project’s approvals.
Water impacts could continue for decades
The analysis also makes clear that contamination would not necessarily disappear when floodwaters receded. Deposited tailings could continue releasing contaminants for years or decades.
For the largest scenario, the Draft SEIS states that chemical releases could continue for several decades even with extensive cleanup efforts.The analysis also identifies concerns about Crooked Creek’s groundwater source protection area.
That makes drinking water protection, long-term monitoring, cleanup responsibility, and funding critical parts of this decision.
Fish impacts could last generations
For communities along the Kuskokwim, fish are not just an environmental resource. They are food, culture, economy, connection, and a foundation of life throughout the watershed.
Under the 13.3 percent spill scenario, the federal analysis says effects on local fish populations could last longer than a decade and become generational.
Under the 27 percent scenario, the Draft SEIS describes impacts to salmon migration, the loss or reduction of multiple year classes of fish, and areas where cleanup may not be feasible.
Most significantly, the federal analysis says fish populations in Crooked Creek may never return to pre-disturbance numbers, even with reintroduction efforts.
That finding deserves serious consideration in a watershed where communities are already experiencing salmon declines and fishing restrictions.
Subsistence impacts are about much more than contamination
The Draft SEIS recognizes that a large spill could affect much more than whether fish or wildlife are safe to eat.
It identifies possible damage to:
- Boats
- Fish wheels
- Smokehouses
- Drying racks
- Fishing and hunting access
- Fish and wildlife populations
- Berries and other plants
The analysis also recognizes that these impacts would occur while communities are already dealing with declining salmon returns, fishing restrictions, caribou declines, and increasing pressure on families to substitute expensive store-bought foods.
The Bureau of Land Management’s preliminary ANILCA Section 810 analysis has also found that the project may significantly restrict subsistence uses in portions of the project area.
These are exactly the types of concerns that Mother Kuskokwim and Tribal leaders throughout the region have been raising for years.
Cleanup does not necessarily mean restoration
One of the most important findings in the new analysis concerns what would happen after a spill.
Under the 27 percent scenario, approximately 4,811 acres of wetlands could experience tailings burial and approximately 32 miles of streams could be affected by deposited tailings. The Draft SEIS says cleanup and remediation may not be feasible or effective in some areas. Wetland functions could remain impaired for decades to a century or longer, with uncertain recovery.
Now is the time to comment
The Army Corps and Bureau of Land Management have not made their final decision.
Following this review, the agencies can modify, reaffirm, or rescind existing federal approvals associated with the project.
You do not need to be an attorney, scientist, or environmental policy expert to submit a meaningful comment.
If you live along the Kuskokwim, harvest fish or wildlife, have family or cultural connections to the region, care about Alaska’s rivers, or simply believe federal agencies need to fully understand the consequences before making a decision, your perspective matters.
How to write a strong comment
A useful public comment can be only a few paragraphs.
- Start by introducing yourself and explaining your connection to the Kuskokwim River, Crooked Creek, subsistence, salmon, Alaska, or the issue.
- Then identify something in the Draft SEIS that concerns you.
- Finally, ask the agencies to take a specific action.
For example:
- Community safety: Ask the agencies to provide a realistic, scenario-specific evacuation analysis showing how residents would be notified and reach safety before roads, river access, or the airstrip become unusable.
- Fish and salmon: Ask the agencies to fully account for the possibility of generational impacts to fish populations and the fact that some populations may never return to previous levels.
- Subsistence: Ask the agencies to evaluate the spill scenarios in the context of today’s salmon declines, fishing closures, caribou restrictions, food costs, and limited alternatives available to rural households.
- Water: Ask how communities would receive safe drinking water and how long-term contamination would be monitored and treated.
- Cleanup: Ask the agencies to identify how much tailings material could realistically be removed and what would happen to contamination that cannot be recovered.
- Financial responsibility: Ask who would pay for evacuation, replacement food and water, community displacement, environmental restoration, and decades of monitoring if a major spill also makes continued mine operations economically impossible.
- Technical review: Ask the agencies to disclose the underlying technical information used to reach their conclusions and provide enough time for Tribal governments, technical experts, and communities to meaningfully review it.
How to submit your comment
Comments are due October 23, 2026.
Comments can be emailed to: donlingoldseis-record@aecom.com
Put “Donlin Gold Project” in the subject line.
Comments can also be submitted through the project website at DonlinGoldSEIS.com.
You can also participate in one of the upcoming public meetings and ANILCA Section 810 hearings:
Bethel
October 14, 2026
2:00 to 6:00 p.m.
Kuskokwim Campus, Room 118
Crooked Creek
October 15, 2026
1:30 to 3:30 p.m.
Crooked Creek Tribal Offices
Aniak
October 16, 2026
11:00 a.m. to 2:00 p.m.
Arviiq Regional Development & Training Center
Virtual
October 19, 2026
6:00 to 8:00 p.m.
Advance registration is required through the project website.
Stand with Mother Kuskokwim
This comment period represents years of work by people who refused to allow the risks to their communities to be dismissed.
Mother Kuskokwim and Tribal leaders throughout the Yukon-Kuskokwim region have continued to organize, speak out, educate decision-makers, support one another, and insist that the people who would bear the consequences of Donlin deserve to be heard.
The new federal analysis validates the seriousness of many of the concerns communities have raised.
Now the rest of us have an opportunity to listen and stand with them.
Submit a comment by October 23 and ask federal agencies to fully account for the consequences this project could have for Crooked Creek, the Kuskokwim River, salmon, subsistence, and future generations.
Learn more about Mother Kuskokwim and their work to protect the Kuskokwim River through the Mother Kuskokwim Tribal Coalition.