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Environmental Programs

A wide-ranging environmental baseline-study program has been ongoing since 1996 to provide a foundation for permitting and responsible development. Resources and topics in the baseline-study program have included air quality, fish and other aquatic resources, geotechnical conditions, ground and surface water quality and quantity, land use, mercury, public health, socioeconomics, sediment quality, subsistence, vegetation, wetlands, and wildlife. Beyond collecting baseline scientific data, we have had extensive dialogue with local communities and our Alaska Native Corporation partners, who offer generations of traditional ecological knowledge (TEK) about the local environment. Donlin Gold LLC has used this information and the multiple years of environmental baseline data to locate and design the mine and associated infrastructure in a way that avoids or minimizes potential impacts to sensitive and culturally important habitats and locales.

Group photo of locals

This information was included in the Donlin Gold Final Environmental Impact Statement (FEIS), completed in 2018, and we continue to update our understanding of baseline conditions, including TEK, through our ongoing studies. It was also considered by the U.S. Army Corps of Engineers in the issuance of the Clean Water Act Section 404 permit, which determined that the project plan was the least environmentally damaging practicable alternative. NOVAGOLD supports a project development plan for Donlin Gold that considers risks and opportunities in all phases: exploration, development, operation, closure, and reclamation.

The Donlin Gold project has been designed for no uncontrolled discharge of mine-contacted water. Any water that contacts mine facilities would be used in the milling process to the maximum extent practicable or treated and discharged according to stringent permit standards.

Many of the mine supplies will be transported up the Kuskokwim River by barge during the open water shipping season between June and October. A detailed barging plan has been developed with input from communities on the river which ensures protection of aquatic resources and limits impacts to subsistence fishing activities.

Following completion of geotechnical and planning work, a comprehensive tailings management plan will be finalized. Donlin Gold LLC is committed to the design, construction, operation, and closure of a tailings storage facility that meets the requirements of the Global Industry Standard for Tailings Management (GISTM) as well as meeting or exceeding 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 and safe design for tailings storage*. Dry closure of the tailings storage facility will significantly reduce long-term water management requirements and greatly limit failure potential.

The potential environmental effects of the proposed mine project were detailed and evaluated as part of the National Environmental Policy Act (NEPA) process. The FEIS includes the potential effects of the project on climate change, and the potential effects of climate change on the project itself; these risks are considered and integrated in the project design. The effects of climate change, including the impacts of extreme weather conditions and melting permafrost, are incorporated into permitting submissions, as well as design engineering and operational and closure planning.

* See more information about the tailings storage facility design here.

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 the Donlin Gold project moves into construction and operation.

Aerial landscape

Finally, a reclamation and closure plan for the proposed mine has already been developed and approved by the State of Alaska to ensure that, when mining activity ceases, the mine is properly closed, and the land is reclaimed to a stable, healthy condition. The plan includes requirements to achieve specific levels of revegetation. It also strives to limit long-term water management requirements (e.g., by dry closure of the tailings storage facility). Where water management and treatment are required, the plan ensures compliance with all applicable water quality standards to protect aquatic resources and human health. As required by state law and consistent with leading practices, this plan will be reviewed and updated in 2023 and periodically throughout operations (at a minimum, every five years).

One of the primary risks to the project related to environmental impacts involves changes to governmental policies, regulations, and permitting requirements. We would expect that the imposition of international treaties or U.S. federal, state, and/or local laws or regulations pertaining to mandatory reductions in energy consumption or GHG emissions could increase the project development and operating costs, and even affect the overall feasibility of any mining project subject to the jurisdiction of such regulations.

As we move toward updating the feasibility study and ultimately project construction and operation, we will continue to monitor and, where possible, anticipate and plan for such developments, especially in evaluating energy generation and use, pipeline construction, and GHG emissions.

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