Kawerak, Inc. (Kawerak) submits these comments in response to the Alaska Department of Natural Resources’ (DNR) Notice to the Public and Request for Information related to the activities set forth in the Alaska Multi-Agency Application for Permits to Mine in Alaska (APMA) for Suction Dredge & Reclamation in the Nome Mining District, near the community of Solomon, in Case No. F20242875 (Application). The Application sets forth IPOP, LLC’s (IPOP) proposal to operate a cutter head suction dredge on state mining claims in the Bonanza Channel located within Safety Sound near the Village of Solomon. Yet the content of IPOP’s
Application already violates Federal and State subsistence requirements, and altogether fails to establish how the Project will serve the public interest. On these and other grounds, Kawerak strenuously opposes the Application, and asks that DNR deny the same. In a related proceeding, the U.S. Army Corps of Engineers (USACE, or Corps) arbitra1ily reversed its earlier denial of r PO P’s application to dredge under Section 404 of the Clean Water Act (CWA), and offered individual pennit #POA-2018-00123 (Corps Penn it) to IPOP to dredge and dispose of material in U.S. waters approximately 25 miles east of Nome, Alaska, in the
Bonanza Channel.
The Corps Pennit-which was issued without renewed public notice or comment-is included as an Attachment to IPOP’s Application. In the six years that have passed since !POP submitted its initial application materials to relevant Federal and State authorities, Kawerak has developed a consistent record of opposition to the Project on both State and Federal stages. Our comments on the Application specifically concern the adverse effects to subsistence activities and to the public interest that would occur as a result of the activities desctibed in the Application (which incorporates the Corps Permit by reference), and which run afoul of State and Federal law. We are especially alarmed by the “avoidable adverse effects” occasioned by IPOP’s proposed activity, which adverse effects are acknowledged by IPOP and the Corps. In sum, the Application disregards demonstrated negative impacts and cumulative damage to Tribal cultural and subsistence resources, the environment, wetlands, historic
properties, fish and wildlife, water supply and quality, and welfare of the people. Both the Corps Permit and the Application rely on the unsupported assertions ofIPOP, which do not overcome—-and often do not even address-substantive issues of Federal or State law, or acknowledged adverse impacts to the area. Indeed, Federal and State laws prohibit the issuance of a permit that would de-prioritize the subsistence needs of rural Alaskans and result in yet undetermined adverse impacts to water quality and wildlife.
Kawerak adopts in full and incorporates by reference its April 9, 2018 comments on IPOP’s APMA permit application; its May 24, 2021 Comments to USACE regarding IPOP’s Corps Permit application, its Joint Correspondence of April 12, 2024 alongside the Village of Solomon, Solomon Native Corporation, Bering Straits Native Corporation, Sitnasuak Native Corporation, and Norton Sound Economic Development Corporation; and its Public Comment and Request for Public Hearing submitted in response to Draft Alaska Pollutant Discharge Elimination System (APDES) Permit No. AK0062295 issued by the Department of
Environmental Conservation.
Read more in the full comment letter: https://kawerak.org/download/kawerak-ipop-comments-july-30-2024/?tmstv=1722452205
