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Sustainability

Environmental Principles and Policies

NOVAGOLD recognizes environmental management as a corporate priority. Our board and our employees, as well as Donlin Gold LLC’s 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, our environmental policy sets out a statement of principles for all stages of a project.

"For more than two decades, the Donlin Gold LLC team has been conducting a wide range of environmental studies to evaluate the possible impacts of the activities required to construct and operate the mine. Much of this data collection has been undertaken by Alaska Native Corporation shareholders and Alaska Tribal members from the Y-K region employed by Donlin Gold LLC. Data from these ongoing scientific studies is being used in the project design process to establish high-quality environmental practices before a construction decision is made. Careful, thoughtful, inclusive planning will provide for the protection of the natural, cultural, and subsistence resources."

Ron Rimelman
Vice President of Environment,
Health, Safety, and Sustainability
NOVAGOLD RESOURCES INC.

Administrative assistant Ellie Wright at the Donlin Gold project site office.
Administrative assistant Ellie Wright at the Donlin Gold project site office

NOVAGOLD’s environmental performance measurement primarily relates to activities at the Donlin Gold project site in Alaska. Detailed operating and monitoring plans and policies have been established for and implemented at the Donlin Gold project site for ongoing activities 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. Donlin Gold LLC is dedicated to protecting the subsistence culture that relies on the water and lands surrounding the project, as well as honoring the traditions of Alaska Native culture practiced by our employees and neighbors.

Donlin Gold tracks and manages its annual energy use, greenhouse gas (GHG) emissions, and water use. As a non-producing mining company with very limited operations, however, these levels are very small. Establishing targets related to the reduction of water use or carbon emissions is challenging and generally immaterial due to the project’s stage of development. Exploration work at the project site varies from year to year; hence both power generation and water use vary on an annual basis. In 2021, there was a seasonal drill program; for much of the summer months, the camp was occupied by approximately 100 employees and contractors. In the winter months, the camp is typically closed and all activity ceases. This contrasts with the future mine construction stage, which will require approximately 2,000 workers over a period of several years, and then production, which will require fewer employees but will necessitate year-round large-scale extraction and processing activity that is energy- and water-intensive. During 2022, in collaboration with Donlin Gold LLC and Barrick Gold, NOVAGOLD plans to develop a detailed climate change policy that will be focused on addressing climate change in all aspects of the Donlin Gold project design, including consideration of emissions goals and targets. In the policy, NOVAGOLD will include an impact scenario that refers to 1.5–2°C limits in its project’s climate change disclosure. NOVAGOLD’s GHG emissions targets will be clearly aligned with this principle.

As reported in NOVAGOLD’s climate change submission to the Carbon Disclosure Project (CDP) in July 2021, the company’s climate change disclosure presents and describes multiple scenarios for the potential impact of climate-related risks and opportunities on its business. These will be refined and addressed in 2022 as part of developing our climate change policy.

The Donlin Gold project’s water use from 2020 was provided in NOVAGOLD’s inaugural CDP Water Security filing in July 2021 and this information will be provided in 2022. During peak summer months in 2021, the camp had a workforce of 100 to support the drill program and conduct other site activities. All runoff from field activities, including drill sites, is managed to protect water quality under state permit requirements. The project’s domestic water supply is provided by groundwater wells, while sanitary wastewater from the camp is treated in a leach field where it is recycled to the subsurface. Current water and waste management activities pose very low risk to the environment.

A wide-ranging environmental baseline-study program has been ongoing since 1996 to provide a foundation for 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 conducting 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. 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 issuance of the Clean Water Act Section 404 permit, for which it determined that the project plan was the least environmentally damaging practicable alternative.

As examples of scientific work, aquatic resource background data has consistently been collected over the years to better understand how to protect fish and water.

* See more information about different tailings storage facility designs at https://donlingold.com/environment/tailings-management-plan/.

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. 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 to project construction and operation. 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, natural condition. The plan includes requirements to achieve specific levels of revegetation. It also strives to limit long-term water management requirements, e.g. 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 periodically throughout operations (at a minimum, every
five years).

One of the primary risks to the project related to environmental impacts involves 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 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, 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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