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Sustainability

Environment

NOVAGOLD recognizes environmental management as a corporate priority. Our employees, as well as Donlin Gold employees and contractors, care about preserving the environment for future generations while also providing for safe, responsible, and profitable operations for the benefit of employees, shareholders, and communities. We set and maintain standards of excellence for environmental performance at all our office and project locations. In this regard, the NOVAGOLD Environmental Policy sets out a statement of principles for all stages of a project: exploration, development, operation, and closure. Part of this commitment means preserving the local community’s way of life: Donlin Gold is dedicated to protecting subsistence rights on the waters and lands that surround the project and honoring the traditions of Alaska Native culture practiced by our employees and neighbors.

NOVAGOLD’s current environmental performance relates almost entirely to activities at the Donlin Gold project. It is our duty to support a project development plan that considers full life-of-mine risks and opportunities – from exploration through to construction, operation, and finally closure and reclamation. Dialogue with local communities and our Alaska Native partners, who offered generations of traditional knowledge about the local environment, began early in the project’s history. Donlin Gold used this information to help guide the location, layout, and design of the project infrastructure to avoid sensitive and culturally important habitats and landscapes; this information was included in the Donlin Gold Final Environmental Impact Statement (FEIS), with project adjustments informed by engagement with Y-K region stakeholders.

An extensive environmental baseline-study program has been ongoing since 1996 to provide a foundation for responsible development. Resources and topics in the baseline-study program include air quality, fish and other aquatic resources, geotechnical conditions, hydrology/ground and surface water quality and quantity, land use, mercury, public health, socioeconomics, sediment quality, subsistence, vegetation, wetlands, and wildlife. Data from these studies have been used in the planning and design of the mine, and to establish environmental conditions prior to project development. All of this data has been submitted to regulatory agencies as part of the FEIS and permitting processes.

Figure 1 - Environment Environmental Tech, Gerald Beans

The Donlin Gold project team has been collecting background data for a fish protection plan with the understanding that protecting fish starts with protecting water. The project has been designed for no uncontrolled discharge of mine-contacted water. Any water that comes in contact with mine facilities would be used in the milling process to the maximum extent practicable or treated and discharged according to stringent permit standards. Also of importance to stakeholders is the traffic plan for the river barges needed to transport fuel and other supplies to the site. Many of these materials will be transported up the Kuskokwim River during the open water shipping season, between June and October. Following completion of geotechnical and planning work, a comprehensive tailings management plan will be finalized. Donlin Gold is committed to the design, construction, operation, and closure of a tailings storage facility that will meet the requirements of the Global Industry Standard for Tailings Management as well as exceed design specifications of the State of Alaska’s Dam Safety Program. The Donlin Gold tailings storage facility will be fully lined, and the main dam will be constructed using the Downstream Method, globally considered to be the most stable design for tailings storage.

The potential environmental effects of the proposed mine project were detailed and evaluated as part of the National Environmental Policy Act process. The FEIS was issued in August 2018 and not only includes the potential effects of the project on climate change, but also the potential effects of climate change on the project itself; these risks are considered and have been incorporated in the project design. The effects of climate change, including the impacts of extreme weather conditions and melting permafrost, are incorporated into all permitting submissions, as well as design engineering and operational and closure planning. Further, the FEIS considered biodiversity by evaluating in detail the potential project effects on local, regional, and statewide flora and fauna populations, including important and sensitive species. The analysis specifically addressed how the ecosystem may change over time due to climate change. The project plan and permits include extensive biodiversity monitoring and mitigation requirements that will be fully implemented as Donlin Gold moves to project construction and operation. Finally, a reclamation and closure plan for the proposed mine project has already been developed and approved by the State of Alaska to ensure that, when mining activity ceases, the mine is closed, and the land is reclaimed and restored. As required by state law and consistent with leading practice, this plan will be reviewed and updated periodically throughout operations.

Figure 2 - Environment Statistics

At Donlin Gold’s current development stage, the site’s existing potential for environmental impacts is based on a site camp of generally fewer than 100 employees and contractors, as was the case in 2020, at peak occupancy. Donlin Gold does not generate operational process waste or wastewater, produce tailings nor waste rock, or use any cyanide. All runoff from field activities, including drill sites, is managed to protect water quality under state permit requirements. All sanitary wastewater from the camp is treated prior to disposal. Therefore, current activities pose very low risk to the environment.

Consistent with our permit requirements and the corporate policies of NOVAGOLD and Donlin Gold, a very high level of environmental performance has been maintained at the project site in the past – and this continued throughout 2020. Detailed operating and monitoring plans and policies have been established for and implemented at the Donlin Gold project site that address safe drinking water and sanitary wastewater systems; stormwater management; spill prevention and control; fuel, oil, and hazardous materials management; wetlands protection; wildlife interactions; and many others. When the project site was occupied in 2020, the environmental team conducted daily inspections of all ongoing site activities as well as monitoring for potential releases to land and water. These areas include water and wastewater management, air quality, hazardous and other solid waste management, fuel storage and use (and associated spill risk), and the protection of biological resources around the site. Donlin Gold and its contractors have never been cited for any non-compliance with environmental regulations, standards, or permit requirements. All hazardous waste is strictly managed according to state and federal regulations. In 2020, Donlin Gold had no spills to water and no fuel or oil spills greater than 10 gallons (the threshold for reporting to government agencies). Per state permit requirements, Donlin Gold also stabilized and reclaimed all of the 2020 drill sites and associated drill access roads after work was completed in these areas.

Figure 2 - Environment An aerial image of the Y-K Delta, close to the village of Kongiganak, which is about 220 miles from the Donlin Gold project.

In 2020, Donlin Gold also continued studies to monitor and document environmental conditions in the project area. These included fish and wildlife studies in the Middle Kuskokwim River, such as the multi-year program to characterize rainbow smelt spawning. In this effort, Donlin Gold partnered with local residents to continue to update the species behavior under current conditions and how it is used as a locally important subsistence resource. Closer to the project site, Donlin Gold advanced fish habitat restoration plans for areas of the Crooked Creek watershed previously affected by historical placer mining. With construction planned to start in 2021, these projects will restore and reconnect stream and pond habitats that will support Coho salmon and resident fish populations in the drainage. Finally, in 2020, Donlin Gold also conducted extensive water quality monitoring and aquatic resource surveys throughout the Crooked Creek watershed.

Due to Donlin Gold’s remote location, on-site diesel-fired power generation and heaters are used to support current project site activities. In 2020, Donlin Gold’s greenhouse gas emissions totaled 1,500 metric tonnes of CO2. As the mine project moves forward – and as practicable – the use of more renewable energy sources such as wind or solar will be evaluated.

Donlin Gold used approximately 184,000 gallons of pumped ground water to support camp operations during 2020. Some additional surface water was temporarily used for drilling operations, but this water was quickly and safely returned to area streams. As previously noted, the project site is located in a remote part of western Alaska where there are few other water users and water scarcity has not been a concern. In addition, all water withdrawals and uses are authorized by the State of Alaska. This process provides for protection of other local water uses, including ensuring no adverse impacts to streams and aquatic life use.

At a broader level, hazardous waste management is a major community concern in the Y-K region because there are no safe, authorized sites in the region for long-term management and disposal. In the fall of 2020, Donlin Gold collaborated with 28 community partners, including regional and village tribal governments and Y-K region businesses, on the Donlin Gold Backhaul Hazardous Waste Removal Partnership to collect and remove approximately 45,000 pounds of household hazardous materials – such as fluorescent tubes, lead acid batteries, and electronic waste – for proper disposal. Donlin Gold was the primary funder of this endeavor, which built upon two previous disposal events. In 2019, nearly 100,000 pounds of hazardous and electronic waste was removed from 14 villages and Bethel on the Kuskokwim River and in 2018, the initial Green Star® Waste Backhaul Project removed close to 40,000 pounds of hazardous waste and materials from six Middle Kuskokwim villages. Donlin Gold is also working with TKC, the State of Alaska, and the Alaska Native Tribal Health Consortium to upgrade, as well as improve, health and safety standards of water and sewer services in Middle Kuskokwim area communities.

Applicable Corporate Policies, including Environmental Policy and Social License and Sustainable Development, can be found at https://www.novagold.com/company/governance/.

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