Environmental Principles and Policies
“Donlin Gold has had an extraordinary record of ensuring a high level of environmental protection at the project site for several decades. Donlin Gold’s experienced environmental team, including field staff comprised entirely of Alaska Native employees, ensures that all permit requirements are met, and procedures are followed. All project staff receive training to ensure that protection of water, land, and biological resources is the highest priority. In 2022, our Field Environmental Coordinator, Danny Twitchell, an Alaska Native from Bethel who has been with us for more than a decade, received state-wide recognition of his outstanding environmental work from the Alaska Miners Association.”
Ron Rimelman
Vice President, Environment, Health, Safety and Sustainability
NOVAGOLD
NOVAGOLD recognizes environmental management as a corporate priority. Our Board of Directors ("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 local 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 projects.
NOVAGOLD’s environmental performance measurement primarily relates to activities at the Donlin Gold project site in Alaska. Donlin Gold LLC has always had detailed procedures that guide its environmental management activities across all site operations, and this is reflected in the strong environmental compliance track record that the site has maintained. In 2022, Donlin Gold LLC implemented an Environmental Management System (EMS) which includes the necessary processes and tools to avoid and minimize environmental impacts while ensuring compliance with all regulatory and permitting requirements.
Key components of the EMS include:
- A centralized document repository known as the Environmental Document Management System (EDMS), which holds all relevant environmental documents (e.g., permits, agency communication, reports, and plans).
- Permit requirements and other environmental obligations and incidents are recorded, catalogued, scheduled, assigned, and tracked using Intelex, a proven environmental management software solution.
- Documentation of all Standard Operational Procedures (SOPs) are regularly updated as needed.
- Experienced personnel from the environmental department team ensure that the EMS is maintained, monitored, and managed accurately.
- Third party audits are completed on an annual basis for assurance that environmental standards have been met. As scheduled, a third-party audit was conducted in 2022 and all recommendations were adopted by the project team.
In addition to minimizing environmental impacts, 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 specifically dedicated to protecting the subsistence culture that relies on the water and lands surrounding the project site, 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 minimal. 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 other GHG emissions and water use vary on an annual basis.
In 2022, Donlin Gold LLC completed its largest drill program in 15 years. During the summer months, the camp was occupied by approximately 100 employees and contractors. This contrasts with the future mine construction stage, which will require approximately 2,000 year-round workers over a period of several years, and then production, which will demand fewer employees but will require year-round extraction and processing activities that are energy- and water-intensive.
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. In 2022, we commissioned a new leach field at the camp that should serve its needs for years to come. Current camp septic wastewater and waste management activities pose very low risk to the environment, given the site is not an operating mine and did not generate any industrial waste or wastewaters in 2022.
Climate and Biodiversity Policies
During 2022, NOVAGOLD developed a formal corporate climate change policy that addresses its operations. Beyond the aspirational goal of Net Zero by 2050, the policy lays out how we will address climate change in each aspect of our current operations, which are limited and, more significantly, those projects that we will operate in the future (e.g., through construction and operation of the Donlin Gold project). This includes our impacts on climate as well as how climate-related changes could impact our operations and ensure we will be resilient in the face of such changes. In 2023, we will focus on implementing the policy, including as appropriate with Donlin Gold LLC.
NOVAGOLD also developed a corporate biodiversity policy in 2022. Protection of biodiversity is key to our ability to successfully develop our projects, including the Donlin Gold project in western Alaska where fish and wildlife resources are integral to residents’ lives. The policy expresses our dedication to defining key biological resources and ensuring that they will not be adversely affected by our operations. As a goal, we are committed to no net loss of biodiversity values, and wherever possible, enhancement of such values across the Y-K region. An important element involves soliciting input from and involvement of regional stakeholders. In 2023, we will begin to implement the biodiversity policy especially as it applies to the Donlin Gold project. Important to this effort will be to start to develop a Biodiversity Action Plan that addresses species of concern, especially salmon, and how we will protect and monitor them.
In 2022, we completed full climate change and water security disclosures to the Carbon Disclosure Project and will do so again in 2023. These included detailed information regarding risks and opportunities associated with the Donlin Gold project in each of these areas. An example of an identified risk is the potential for climate-related changes in the flows and water levels of the Kuskokwim River that the project will depend on for transportation of most supplies during construction and operations. An example of an opportunity is the integration of climate resiliency into the project plan as well as Donlin Gold’s surrounding community development initiatives.
