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VALUE-ENHANCING STRATEGY: NEXT STEPS
Projects with solid economic fundamentals – such as Donlin Gold, we believe – have diverse and multiple nancing options, all of which will be evaluated. Assets like these are needed to sustain an industry where production is falling. The new mines coming into production simply will not be su cient to replace current reserves, let alone provide growth.
Preparation of the EIS is the most time-consuming aspect of the were issued by the state in draft form for public comment in mid-
NEPA process and, in large part, drives the overall permitting
timeline for Donlin Gold. It’s a process that involves multiple public comment opportunities. The Corps, the project’s lead federal permitting agency, completed and distributed the preliminary nal EIS in July for review by the cooperating agencies. The cooperating agencies completed their review and submitted their input to the Corps on schedule in mid-September.
The Corps completed revisions to the EIS and anticipates publishing the nal EIS in early 2018; it expects to issue its ROD in the second half of the year. A thorough scoping process at the start of
the EIS identi ed the issues of primary concern to residents of the Y-K region and the cooperating agencies. Based on that input, the Corps developed a robust process for evaluating and selecting alternatives to Donlin Gold’s proposed action for evaluation in the EIS. Public input during the six-month draft EIS comment period provided additional information that generated further revisions to the project and the EIS analysis. For example, Donlin Gold is proposing to reroute a portion of the natural gas pipeline away from the Iditarod National Historic Trail. In addition, Donlin Gold has held meetings with communities along the Kuskokwim River to establish a barging communications plan intended to reduce potential con icts with inhabitants of the villages along the river who use it for subsistence and transportation.
While the federal NEPA process receives the most attention, Donlin Gold must obtain more than 100 permits, most of which are issued by the State of Alaska. As the NEPA process has progressed, Donlin Gold also has submitted applications for important state permits, for example the air pollution control permit (Prevention of Signi cant Deterioration) which was issued in June 2017, and the water discharge and integrated waste management permits. The latter two
December. Permitting a project like Donlin Gold is demanding – as it should be – and the hard work of our team is producing results
as the permit processes advance concurrently toward decisions in 2018. The Corps is committed to the EIS schedule, and NOVAGOLD is doing everything it can to support that process. The Corps’ team is an accomplished group made up of the right people to successfully coordinate the Corps’ e orts with the cooperating agencies.
Between the Corps’ ling of the nal EIS and the ROD, many
other activities will unfold. The Corps needs to write the ROD and the permit, assuming the decision is made to issue one, and then send the permit to the state, which in turn has to document that it complies with state water quality standards. For a project like Donlin Gold, the ROD itself is a fairly involved document, and would take into account any comments received on the nal EIS and on our permit application. With the ROD, the Corps prepares a Clean Water Act 404 (b)(1) analysis, often an extensive document that shows why the permitted project would have the least-damaging practicable e ect on the environment (compared to other project options). Finally, they need to complete other required consultations that started during the EIS process, including compliance with the National Historic Preservation Act, Endangered Species Act, and Magnuson-Stevens Fishery Conservation and Management Act (which protects essential sh habitat), all of which require other agency concurrence.
We believe that the risk of delay, for example from environmental litigation, is small. Should there be any interruptions, however, we
are prepared to work through them and to keep the process moving forward. With an asset that has a life of mine of approximately 27 years, NOVAGOLD maintains a long-term view while taking a methodical approach to ensure that each step is completed properly – even
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