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2022 Environmental Performance

Consistent with our permit requirements and the corporate policies of NOVAGOLD and Donlin Gold LLC, a high level of environmental performance continued to be maintained at the project site in 2022. The project 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. All this data is managed through the EMS, including tracking and ensuring completion of any action items.

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Compliance, Spills, Waste Management, and Reclamation

In 2022, there were no instances of significant non-compliance with any permit requirements and Donlin Gold has never been cited or fined for any non-compliance with environmental regulations, standards, or permit requirements related to effects on the environment. At the Donlin Gold project site in 2022, approximately 0.23 tonnes of hazardous waste were generated and sent to a permitted off-site disposal facility.

Approximately 576 tonnes of non-hazardous waste were produced, about 0.74 tonnes were recycled, 559 tonnes were disposed in a state-permitted on-site landfill and the remainder was disposed of in a state- permitted on-site incinerator. There was a significant increase in waste produced from 2021, in part due to the expanded 2022 drill program undertaken at the Donlin Gold project site. More significantly, over the preceding 10 years, large volumes of excess materials had spoiled due to the passage of time, and had to be disposed of properly. Near the end of the 2021 field season, Donlin Gold LLC received permits for the new on-site landfill and a new, higher capacity incinerator.

While initial disposal of excess site material began in 2021, these efforts accelerated significantly in 2022 facilitating a widespread, environmentally beneficial clean-up of the site. With the clean-up work complete and a reduced field program in 2023, much lower waste volumes are anticipated. In addition, in 2023, we will continue to look for ways to increase the level of recycling at the site.

As a development stage company, NOVAGOLD did not have any operating mines or other industrial operations in 2022. Therefore, the company, including the Donlin Gold project did not generate any tailings, waste rock, or any other processing waste or wastewater in 2022.

Per state permit requirements, Donlin Gold stabilized all the 2022 drill sites and associated drill access roads after work was completed in those areas. A total of 8.2 acres was reclaimed.

The Donlin Gold project uses diesel, Jet A aviation fuel, gasoline, and propane for camp operations and minimal quantities of hazardous chemicals. Strict protocols are in place for secure transportation and management of these substances. NOVAGOLD sets annual environmental targets relating to spills at project sites. In 2022, the company successfully achieved its goal of no spills to water and no spills of 10 gallons or more to land at any of its offices or projects. There were no spills that rose to the level of being immediately reportable to government agencies. Consistent with Donlin Gold LLC policies, all spills were fully remediated to leave no trace on or below the ground surface.

Power Generation and Emissions

Due to Donlin Gold’s remote location, on-site diesel- fired power generation and heaters are used to support current project site activities. In 2022, Donlin Gold’s Scope 1 GHG emissions totaled approximately 2,633 metric tonnes of C02 equivalent (C02-eq), an increase from approximately 1,084 metric tonnes of C02-eq produced in 2021. This is mainly the result of a much larger drill program completed during the 2022 field season. No Scope 2 emissions were recorded for Donlin Gold since the site is remote and not connected to the electrical grid. Annual changes are expected to continue to fluctuate based on the different levels of fieldwork and camp activities at the Donlin Gold project site, which vary depending on priorities established each year by the Donlin Gold LLC Board. With much less drilling and other activities planned to take place in 2023, it is expected that GHG emissions will significantly decrease from those recorded in 2022. Overall, given the annual variability and consistently low emissions levels, it is neither appropriate nor material to set GHG emissions targets for Donlin Gold at this stage of the project. Even with the larger drill programs, the relatively low levels of site activity in 2022 – including power generation – yielded again virtually no emissions of other air pollutants, including sulfur oxides, nitrogen oxides, mercury, and total particulate matter of less than 10 micrograms diameter per cubic meter. The NOVAGOLD offices in Salt Lake City and Vancouver get all of their electricity from the grid system and, therefore, generate Scope 2 emissions. The combined Scope 2 emissions from these offices in 2022 were approximately 27 metric tonnes of C02-eq, compared to 34 metric tonnes of C02-eq in 2021.

Baseline Environment Conditions Studies and Mitigation

In 2022, Donlin Gold LLC continued its long-term aquatic monitoring program for the Crooked Creek watershed where the project site is located. This included characterizing baseline surface water quality, fish distribution and spawning, and estimation of fish, macroinvertebrates, and periphyton populations. In 2022, we also continued sampling of sediment and fish tissue quality to further define pre-mining conditions.

In the Crooked Creek watershed, Donlin Gold LLC began planning the initial work on a fish habitat restoration project in 2021. The project seeks to restore stream and pond habitat and fish populations in areas adversely affected by historic placer mining activities. Both resident fish and coho salmon habitat are being created and enhanced. In 2022, full scale restoration work was started, and the project is expected to be completed in 2023. Donlin Gold will then monitor success, make further modifications as needed, and use the information to guide additional fish habitat restoration in other affected areas in the watershed. Initial observations suggest the project will be highly successful in creating important pond habitat, which is currently limited in the Crooked Creek watershed.

Also in 2022, Donlin Gold LLC continued studies in the Middle Kuskokwim River to further define potential future barging effects on rainbow smelt. Rainbow smelt are an important subsistence species for some villages. Over the past decade, Donlin Gold defined the locations and timing of rainbow smelt spawning and migration. This was the first study of its kind in the Y-K region, and the work was supplemented further in 2022. Donlin Gold LLC also performed updated hydrodynamic surveys in the river to map shallow areas where rainbow smelt eggs could be disturbed by barging. This information will be used to refine the impact assessment and, in collaboration with local subsistence users, consider the need for mitigation, where appropriate.

During 2023, Donlin Gold LLC and NOVAGOLD will pursue new partnerships for additional off-site biodiversity enhancement and protection projects around the project site and throughout the Kuskokwim River watershed.

Water Use

Donlin Gold used approximately 550,000 gallons of ground water to support camp operations during 2022. This reflects the larger field programs in 2022 and reflected a slight increase compared to 2021 (approximately 445,000 gallons), but it is still very low for facilities associated with the mining industry. Like the low but variable GHG emissions, water use at the project site changes on an annual basis depending on camp needs such as domestic supply, core cutting, and washdowns. With decreased field activity in 2023 and a shorter field season compared to 2022, we expect that the camp water use volume could decrease and remain at relatively low volumes. The project site is in a remote part of western Alaska where water scarcity is not a concern. In addition, all water withdrawals and uses are authorized by the State of Alaska. The permitting process provides for protection of other local water uses, including ensuring no adverse impacts to streams and aquatic life. Finally, as noted previously, the plans for the full-scale mine operation maximize re-use to limit water supply needs.

NOVAGOLD’s offices in Vancouver and Salt Lake City combined used approximately 100,000 gallons of water in 2022, all drawn from municipal water systems and largely recycled back to the environment (minus minimal losses for personal consumption). Between the Donlin Gold project and NOVAGOLD about 650,000 gallons of water were used in 2022, a slight increase from 2021. Essentially all water used was recycled to the environment.

Donlin Gold Environmental Statistics

  2022 2021 2020
Metric tonnes of CO2 in greenhouse gas emissions 2,633 1,084 1,565
Gallons of water used to support camp operations 550,000 445,000 184,000
Fines for environmental non-compliance None None None
Hazardous material spills to water or >10 gallons to land None None None
Pounds of household hazardous and electronic waste removed from Y-K villages 134,000 180,000 45,000

Regional Environmental Initiatives

Beyond our project site activities, we engage in regional efforts to improve environmental conditions. NOVAGOLD and Donlin Gold LLC supported the 2022 Clean-Up Green-Up program, which runs annually throughout the summer and aims to collect and dispose of trash from the tundra, roads, public areas and beaches in the Y-K region that accumulates during the winter months. This year, 54 Tribal community partners participated in the event. Hazardous waste management is a major community concern in the Y-K region because there are no safe, authorized sites for long-term management and disposal of these wastes generated in the communities. Donlin Gold LLC, along with the Association of Village Council Presidents (AVCP), the Native Village of Napaimute, and other community and Tribal partners, held the fifth successful “In It for the Long Haul” backhaul project in summer 2022, removing approximately 134,000 pounds of hazardous materials – such as fluorescent tubes, used oil, ethylene glycol, paint, household chemicals, lead acid batteries, and electronic waste – from 26 villages throughout the Y-K region. Over the last five years, nearly 425,000 pounds of waste has been removed that would otherwise end up in landfills, in waterways, or in other areas that could be harmful to local communities.

Donlin Gold LLC is also working with TKC, the State of Alaska, and the Alaska Native Tribal Health Consortium to upgrade water and sewer services in Middle Kuskokwim area communities. In addition, Donlin Gold LLC began working with AVCP to train local residents in conducting water quality testing throughout the Kuskokwim River watershed in 2022.

Each of these regional efforts will continue in 2023, including participation of additional villages and regional partners.

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