Donlin Gold Project Chapter 2: Alternatives Final Environmental Impact Statement CHAPTER 2: ALTERNATIVES 2.1 REGULATORY SETTING FOR ALTERNATIVES ANALYSIS The Council on Environmental Quality’s (CEQ’s) regulations describe the alternatives section as the “heart of an Environmental Impact Statement (EIS)” and require exploration and evaluation of all reasonable alternatives (40 Code of Federal Regulations [CFR] 1502.14). CEQ further defines reasonable alternatives as “those that are practical or feasible from the technical and economic standpoint and using common sense” (CEQ 1981). National Environmental Policy Act (NEPA) implementation procedures for the United States Army Corps of Engineers (the Corps) describe reasonable alternatives as those that are feasible, and then further specify that such feasibility must focus on the accomplishment of the underlying Purpose and Need (33 CFR Part 325, Appendix B). The Corps will follow the Clean Water Act (CWA) Section 404(b)(1) Guidelines (40 CFR Part 230) when evaluating the permit application from Donlin Gold, LLC (Donlin Gold). The 404(b)(1) Guidelines require examination of practicable alternatives to the proposed discharge (or action) and other factual determinations. An alternative is considered practicable “if it is available and capable of being done after taking into consideration cost, existing technology, and logistics in light of overall project purposes” (40 CFR 230.10). The Guidelines require that the least environmentally damaging practicable alternative (LEDPA) be determined for permit consideration. The Section 404(b)(1) guidelines (Corps 2009) also require the determination of whether a project is water dependent. Water dependent means that the project by its very nature requires access, proximity to, or siting within a special aquatic site1 to fulfill its “basic purpose.” If a project is determined not to be water dependent, the guidelines state that: “…practicable alternatives that do not involve special aquatic sites are presumed to be available, unless clearly demonstrated otherwise;” and “…all practicable alternatives to the proposed discharge which do not involve a discharge into a special aquatic site are presumed to have less adverse impact on the aquatic ecosystem, unless clearly demonstrated otherwise” (40 CFR 230.10(a)(3). The Corps has determined that the basic purpose of the Applicant’s discharge of dredged or fill material is to extract and process gold. Extraction and processing of gold in and of itself does not require access, proximity to, or siting within, a special aquatic site to fulfill its “basic purpose.” Therefore, the Corps has found that the project is not water dependent. Both the CEQ and the Corps NEPA implementation procedures require consideration of a No Action Alternative; for a Corps EIS this alternative would preclude any construction that would require a Corps permit (33 CFR Part 325, Appendix B). The No Action Alternative (Alternative 1) is described in Section 2.3.1. Donlin Gold’s proposed mine development project is Alternative 2 and is described in Section 2.3.2. 1 “Special aquatic sites” as described in 40 CFR Part 230, Subpart E include wetlands, sanctuaries and refuges, mud flats, vegetated shallows, coral reefs, riffle and pool complexes. April 2018 P a g e | 2-1 Donlin Gold Project Chapter 2: Alternatives Final Environmental Impact Statement Over 300 alternative options were developed and screened to satisfy NEPA requirements; satisfy the Corps Public Interest Review (33 CFR 320.4(a)); assure compliance with the requirements of the 404(b)(1) Guidelines; and to enable federal, state, and cooperating entities the ability to make permitting decisions if and where necessary (Appendix C). These options were systematically examined to determine the reasonable alternatives to include in the Draft EIS. Alternatives carried forward for detailed study are presented in Sections 2.3.1 through 2.3.7. CEQ regulations also require a brief discussion of the reasons for eliminating alternatives that were considered but not carried forward for detailed study. Alternatives that were considered but eliminated are presented in Section 2.4. 2.2 ALTERNATIVES DEVELOPMENT PROCESS In addition to the No Action and the Proposed Action alternatives, the EIS team conducted several workshops with the Cooperating Agencies, and developed a range of alternatives for analysis using a five-step process that began with issues raised during scoping (see Section 1.7). It is important to understand the terms “component,” “subcomponent,” “option,” and “alternative” when reviewing this chapter: · Component – a complete mine has several components, each necessary to allow production. For the Donlin Gold Project, there are three primary components: Mine Site, Transportation Corridor, and Pipeline. · Subcomponent – each primary component includes subcomponents; for example, the open pit and processing plant are subcomponents of the Mine Site. · Option – for each component/subcomponent there are one or more options. · Alternative – an alternative is a complete package of options that comprise a functioning mine project. In the overall Alternatives Development Process described below, consideration was given to the project’s large geographic footprint; the three different, but connected, primary components (Mine Site, Transportation Corridor, and Pipeline), and comments provided by the public, stakeholders, and agencies in scoping. Alternatives Development Process Step 1: Identify Scoping Issues and Related Project Components Step 2: Develop Screening Criteria Step 3: Identify Options to Address Concerns for Each Component & Subcomponent Step 4: Apply Screening Criteria to All Options; Develop Options to Carry Forward and Carefully Document Option Disposition Step 5: Package Options into Action Alternatives April 2018 P a g e | 2-2 Donlin Gold Project Chapter 2: Alternatives Final Environmental Impact Statement Step 1 of the alternatives development process was to identify the issues raised in scoping and then to relate them to the project components and subcomponents. Step 2 was to develop the criteria for future screening of each option. To narrow the range of options considered, criteria were organized around three screening tests: purpose and need, feasibility (including logistics), and environmental impacts. The screening criteria are more fully described in Section 2.2.1.1. In Step 3, options were identified to address concerns raised during scoping; options originating from scoping comments, Donlin Gold’s consideration of design alternatives, and the Corps’ EIS contractor, AECOM, were compiled into tables, organized by project component and subcomponent. In Step 4, screening criteria from Step 2 were applied to the options developed in Step 3. The criteria were used to screen options and to eliminate options that would not meet the Corps’ determination of Purpose and Need, that were not feasible, or that would not reduce environmental impacts over similar options. The EIS contractor completed preliminary screening, which was reviewed and refined by the Corps. Step 5 was to package the options that met all of the screening criteria into action alternatives for detailed analysis in the EIS. Options that were dismissed from further analysis are summarized in Section 2.4. The range of reasonable alternatives is described in Section 2.3.1 through Section 2.3.7. 2.2.1 SCREENING THE FULL RANGE OF ALTERNATIVES 2.2.1.1 SCREENING CRITERIA The EIS team organized screening criteria around three topic areas: purpose and need, feasibility, and environmental impacts. First, the EIS team documented and eliminated options clearly outside of the purpose and need. Each remaining option was then rated for feasibility (technical, economic and, where relevant, logistical) and environmental impacts (physical, biological, and socioeconomic). The final decision to analyze options rested with the Corps in consultation with the cooperating agencies. For any option eliminated from further analysis, the rationale for elimination is documented in Section 2.4, Alternatives Considered but Eliminated from Detailed Analysis. Alternatives Screening Process Step 1: Eliminate Options that Clearly Do Not Meet Purpose and Need Step 2: Determine if Option is Feasible · Identify Technologically Feasible and Operationally Efficient Options · Screen Technologically Feasible Options for Relative Cost Effectiveness · Where Necessary, Evaluate the Logistical Feasibility of Options Step 3: Eliminate Options that Increase Negative Environmental Impacts April 2018 P a g e | 2-3 Donlin Gold Project Chapter 2: Alternatives Final Environmental Impact Statement 2.2.1.1.1 SCREENING – PURPOSE AND NEED Three federal agencies have regulatory permitting authority for the project that will require a Record of Decision (ROD): the Corps, the Bureau of Land Management (BLM), and the Pipeline and Hazardous Materials Safety Administration (PHMSA). The Purpose and Need statements for the project are provided in Section 1.3 of the EIS. Options that did not meet the Corps’ determination of Overall Purpose and Need and NEPA Purpose and Need were not analyzed further in the EIS. Similarly, any options to the Pipeline component that fall outside the BLM or PHMSA Purpose and Need statements were dismissed. 2.2.1.1.2 SCREENING – FEASIBILITY The feasibility screening test considers technological, economic and, where relevant, logistical feasibility. Technological feasibility was evaluated to minimize the risk of an option causing