DONLIN GOLD LLC 2525 C St., Suite 450 Anchorage, AK 99503 T: (888) 225-7590 or (907) 273-0200 FAST-41 Initiation Notice (FIN) Donlin Gold Project – Supplemental Environmental Impact Statement – October 10, 2025 1 STATEMENT OF PURPOSES AND OBJECTIVES OF THE PROJECT Donlin Gold LLC (Donlin Gold) is owned by NOVAGOLD Resources Alaska, Inc.—a wholly owned subsidiary of NOVAGOLD Resources Inc.—and Donlin Gold Holdings LLC – a company wholly owned by investment funds managed by Paulson Advisers LLC (“Paulson”). Donlin Gold has proposed the development of a gold mine in southwest Alaska. The resource area for the mine spans lands selected by Calista Corporation (Calista) and The Kuskokwim Corporation (TKC) as part of the Alaska Native Claims Settlement Act (ANCSA), with Calista having specifically chosen these lands for their mineral potential. Calista serves as the regional Alaska Native corporation for the Yukon–Kuskokwim (YK) region and owns all subsurface mineral rights and a portion of the surface lands, while TKC, representing several Native villages in the Middle Kuskokwim River area, holds the remaining surface lands. Donlin Gold operates under agreements with both Native corporations, ensuring responsible stewardship throughout the mine’s development. The ‘Project’ encompasses the construction of an open-pit mine, a 316-mile natural gas pipeline originating from Cook Inlet, a natural gas-fired power plant, advanced processing facilities, designated waste management areas, and the necessary transportation infrastructure to support year-round operations. This comprehensive development plan is designed to balance economic progress with environmental responsibility, bringing significant opportunities to the region. According to the most recent Technical Report published in 202111, Donlin Gold has estimated Proven and Probable Mineral Reserves of approximately 34 million ounces of gold. Gold remains a vital commodity, serving as both a global currency and a strategic resource with established international markets. Notably, it has been listed under Executive Order 14241, "Immediate Measures to Increase American Mineral Production," highlighting its significance for national and economic security and the need to reduce American reliance on foreign sources. The primary purpose of the Project is to profitably extract gold and enable Calista and TKC to maximize economic returns for their shareholders, while contributing to the worldwide demand for this essential mineral. The Project will also provide economic benefits to a region of Alaska that lacks financial opportunity. The YK region, where the Project is located, is a remote part of Alaska where more than 26,000 1 https://wp-novagold-2024.s3.ca-central-1.amazonaws.com/media/2024/05/Technical-Report- Donlin-Gold-2021.pdf residents rely heavily on subsistence lifestyles that include hunting, fishing, and gathering of foods for survival, and pay exorbitant costs for utilities, fuel, and regular household goods. Bethel is the largest of the 48 communities in the region with 7,000 residents, while other local communities vary in size from less than 100 to 1,000 residents. Between 2012 and 2016, at least 29 percent of all residents (excluding Bethel residents) lived below the poverty line, and some subregions’ poverty rates were as high as 39 percent (Agnew::Beck Consulting, 2018). Royalty payments to Calista alone are estimated at $1.5 billion ($55.4 million annually) over the 27-year mine life, and there will be many other economic and social benefits to Calista and TKC shareholders (USACE, 2018). Donlin Gold received all necessary federal pre-construction authorizations in 2018 following preparation of an Environmental Impact Statement (EIS) under the National Environmental Policy Act (NEPA). As a result of litigation in the United States District Court for the District of Alaska, the U.S. Army Corps of Engineers (USACE) and the Bureau of Land Management (BLM) are now preparing a supplemental analysis to analyze a larger tailings spill. 2 PROJECT DESCRIPTION 2.1 GENERAL LOCATION, AND GEOSPATIAL INFORMATION The proposed mine site is located 277 miles northwest of Anchorage, 145 miles northeast of Bethel, and 10 miles north of the village of Crooked Creek at, 62.031369 Longitude, -158.232248 Longitude. Major supporting components would extend far beyond the mine site, including a 316-mile natural gas pipeline running from the west side of Cook Inlet to the mine to provide power, port facilities on the Kuskokwim River in Bethel and near Jungjuk Creek for barging freight and fuel, and a 30-mile access road connecting the Jungjuk port to the mine site. The supporting Project components overlay lands owned by Alaska Native corporations (Calista, TKC, and Cook Inlet Region, Inc.), the State of Alaska, and Federal lands managed by the BLM. 2.2 PROJECT DESCRIPTION The Project includes three primary components: the mine site, the natural gas pipeline, and the transportation corridor. Construction is anticipated to take 3–4-years, followed by 27 years of operation. The mine site will include an open pit, facilities for storing waste rock and tailings, a power plant, and other essential infrastructure. Operations are planned to run year-round, utilizing conventional truck-and-shovel methods with both bulk and selective mining techniques. On average, the project aims to process 422,000 tons of material per day, generating an estimated 3 billion tons of waste rock, which will either be stored in the waste rock facility or used for backfilling part of the final pit. At full capacity, the open pit is expected to reach about 1,653 feet deep, one mile wide, and 2.2 miles long. The mill site and processing plant will handle approximately 59,000 tons per day, featuring a gyratory crusher, semi-autogenous grinding and ball mills, followed by flotation, concentration, pressure oxidation, and carbon-in-leach circuits. Gold will be extracted using conventional carbon stripping and electrolytic recovery, producing doré bars for offsite refining. Production is estimated to be approximately 1 million ounces of gold annually over the 27-year mine life. Advanced mercury abatement controls will be placed on all major thermal equipment, including the autoclave, carbon kiln, electrowinning cells, gold furnaces, and retort. Tailings from processing will be contained in a fully lined storage facility covering 2,351 acres, capable of storing up to 335,000 acre-feet of material (USACE, 2018). The mine site is in an area with virtually no existing infrastructure. The project plan, therefore, includes a 227 MW gas-fired power plant located at the mine site, and a 14-inch diameter, 316-mile- long natural gas pipeline from the existing Beluga pipeline in west Cook Inlet to the mine site. The pipeline would be almost entirely buried except in two sections where the line crosses two major faults and includes one single compressor station near its origin. The total surface exposure of the pipeline is less than one-half of a mile. The Project would be the largest single consumer in southcentral Alaska, taking about 11 billion cubic feet of natural gas per year. The transportation corridor uses marine, river, and overland transport. Mining supplies and diesel fuel will be barged from West Coast ports to a new port in Bethel, then transferred to river barges heading to the Jungjuk port 202 miles upstream. A 30-mile road will connect the upriver port to the mine site, with additional plans for an airstrip and camp facilities (USACE, 2018). 2.3 ENVIRONMENTAL, CULTURAL, AND HISTORIC RESOURCES 2.3.1 Environmental Resources Donlin Gold has collected a wide range of environmental data to support the permitting of all Project components over more than two decades. This includes more than 10 years of baseline biomonitoring and more than 20 years of baseline water quality data in the Crooked Creek drainage where the mine site is located. These data collection focus on identifying fish species distribution and relative abundance and describes aquatic invertebrate and periphyton communities. The Crooked Creek drainage (from its origin at the junction of Donlin and Flat Creeks to its mouth at the confluence with the Kuskokwim River) habitat has been mapped to determine returning salmon and spawning distribution numbers (OtterTail, 2009 and OtterTail, 2014). Additionally, numerous hydrologic studies have been conducted to establish flow and water quality conditions for surface and groundwater modeling. Further data collection has included comprehensive climate, air quality, soils, wetlands, vegetation, and wildlife studies, as well as additional aquatic resource and hydrology studies in the project infrastructure areas. 2.3.2 Cultural and Historic Resources For millennia, the people of the YK Region have maintained a deep connection to the land and waters, valuing subsistence, stewardship, and the intergenerational transmission of traditional knowledge. This enduring presence is reflected in their respect for the environment and the cultural significance they attach to the region’s resources. Placer mining in the Crooked Creek drainage dates to as early as 1909 when gold was first discovered approximately 4 miles north of the Donlin Gold deposit in Snow Gulch. The deposit produced an estimated 8,238 ounces, most of which was recovered by Spencer the Lyman family in the 1980s (mindat.org, 2025). As a result of these generations of sustained habitation and development, the region today contains a wealth of cultural and historic properties dispersed throughout the landscape. Potential Project effects on cultural resources were analyzed in detail in the previous NEPA review described in Section 4.2. In recognition of the cultural importance of the Kuskokwim River for subsistence uses and travel, Donlin Gold signed a Programmatic Agreement (PA) with USACE, BLM, the Advisory Council on Historical Preservation, and the Alaska State Historic Preservation Officer to, “resolve known and potential adverse effects of the Project on historic properties pursuant to 36 C.F.R.§ 800.14(b).” The PA also required development of a Cultural Resource Management Plan to, “…protect manage and, where feasible, preserve the areas historic properties and other cultural resources that may warrant consideration and protection from adverse project effects.” Phase I (surveys) and Phase II (evaluation reports and eligibility recommendations) have been completed for most of the proposed project area of potential effects (APE). To date, there are 49 known cultural resources within the APE, 21 of which are either eligible for registration with the National Register of Historic Places (NRHP) or will be treated as such for the purposes of Section 106 (USACE, et al., 2018). Donlin will conduct Phase III excavation and data recovery of known NRHP sites within the APE. Donlin Gold has proactively protected and preserved cultural resources with neighboring communities. This effort has included the repatriation of remains in collaboration with the Cooked Creek Traditional Council and generation of lithic casts from excavated artifacts found at a local cultural site. The lithic casts were developed and delivered to Crooked Creek’s Johnnie John School to be used as teaching tools. 3 PROJECT SPONSOR’S TECHNICAL AND FINANCIAL ABILITY TO CONSTRUCT THE PROPOSED PROJECT 3.1 TECHNICAL EXPERTISE Donlin Gold has the technical expertise and operational experience required to advance the development and long-term operation of the Donlin Gold Project. Our team includes seasoned professionals with demonstrated success in complex mining environments, including engineering, environmental management, logistics, and remote infrastructure development. Our owners also bring some of the most experienced mining professionals in the businesses having led development and operation of several of the largest open gold mines in the world. NOVAGOLD’s President and Chief Executive Officer, Mr. Greg Lang, has over 35 years of diverse experience in the mining industry, including time as President of Barrick Gold North America, a wholly-owned subsidiary of Barrick Gold Corporation, and Homestake Mining Company prior to that. NOVAGOLD’s Chief Operating Officer, Mr. Richard Williams, has spent over 30 years with Barrick Gold developing and operating major mines. He is a highly knowledgeable and experienced leader in autoclave technology which is planned to be used to process ores at Donlin Gold. Most recently, he served as Project Director of the Pueblo Viejo project in the Dominican Republic. In addition to our in-house capabilities, we maintain strong partnerships with industry experts and contractors, and we have the organizational capacity to recruit and retain the specialized technical talent necessary to support the project’s evolving needs. This depth of capability helps us to execute the project safely, efficiently, and in accordance with all regulatory and environmental requirements. 3.2 FINANCIAL CAPABILITY Donlin Gold is a limited liability company with 60/40 ownership by NOVAGOLD and Paulson, who have the financial strength and commitment necessary to support the successful construction of the Donlin Gold Project, with an estimated capital cost of approximately $7.4 billion (NovaGold Resources, Inc., 2021). Both owners have a proven track record of financing large-scale mining ventures and carry the capacity to secure additional capital through established relationships with global financial institutions, strategic partners, and equity markets. Their combined financial resources, prudent fiscal management, diverse experience in mine operations, project evaluations, project evaluations, and longstanding commitment to responsible development ensure that the project can be advanced to completion and into operations in a manner that meets all operational, environmental, and regulatory obligations. As of August 5, 2025, NOVAGOLD has a market capitalization of $2.34 billion and has shown the ability to raise significant funding, including more than $340 million invested in the project to date. Paulson was the cornerstone investor in leading the successful development and construction of the Detour Lake Mine, which, today, is Canada’s largest operating gold mine. Paulson is also the lead investor in Perpetua Resources, which is on the cusp of beginning construction of the Stibnite Gold Project in Idaho, with the support of the US Department of Defense and with financial backing from the US Export Import Bank. 4 FEDERAL FINANCING, ENVIRONMENTAL REVIEWS, AND AUTHORIZATIONS PENDING 4.1 FEDERAL FINANCING Donlin Gold does not currently have, nor has it requested, federal financing in support of the project. 4.2 ENVIRONMENTAL REVIEWS The USACE led the preparation of an EIS for the Project from 2012 to 2018. The EIS addressed the potential impacts of all project components, including the proposed mining operation, camps, airstrip, access road, two ports, and natural gas pipeline2. Following issuance of a Final EIS in April 2018, USACE and BLM issued a Joint Record of Decision (JROD) in August 2018. The USACE and BLM need now prepare a supplemental analysis pursuant to court orders by the United District Court of the District of Alaska. In September 2024, the court found that USACE and BLM violated NEPA and Section 810 of the Alaska Native Interest Lands Conservation Act by failing to consider a larger tailings spill than the tailings spill analyzed in the Final EIS. In June 2025, the court did not vacate the authorizations while the agencies remedy this error by supplementing the EIS. This Supplemental EIS would benefit from the faster, more predictable, and transparent federal permitting process with dedicated support, coordinated timelines, and high-level oversight offered by the FAST- 41 program. Separate from the EIS, the U.S. Pipeline and hazardous Materials Safety Administration (PHMSA) prepared an Environmental Assessment (EA) to evaluate issuance of a special permit for the strain- based construction of the pipeline. PHMSA issued the Final EA and Finding of No Significant Impact in June 2018. 4.3 AUTHORIZATIONS PENDING There are no authorizations under Federal law pending. USACE and BLM issued authorizations for the Project in 2018. The United States District Court for the District of Alaska did not vacate those authorizations, so those authorizations remain in effect. In addition, Donlin Gold received a Special Permit from PHMSA for the strain-based construction of the pipeline. The remaining primary authorizations under Alaska law are the State of Alaska Dam Safety Permit, and the Regulatory Commission of Alaska Certificate of Public Convenience and Necessity. Donlin Gold has already obtained from the State of Alaska numerous other authorizations. Donlin has obtained an Integrated Waste Management Permit, Reclamation Plan Approval, Alaska Pollutant Discharge Elimination System, and an Air Quality Control Construction Permit. Several Water Rights and associated Fish Habitat Permits have been obtained from the State for dewatering and other mining-related uses. A lease agreement was signed for construction and operation of the pipeline on land owned and managed by the State of Alaska. 5 QUALIFICATIONS FOR FAST-41 The Project qualifies as a “covered project” because: it is an activity in the United States that requires environmental review by a Federal agency involving construction of infrastructure for mining and 2 Note that the USACE issued a permit for the Bethel Port in 2025 to Knik Construction. conventional energy production (i.e., it falls within a designated sector), and it meets two of the pathways to become a Fast-41 project. The Project meets the standard pathway at 42 U.S.C. 4370m(6)(A)(i). The Project: (i) subject to NEPA; (ii) likely to require a total investment of more than $200,000,000 – it has an estimated capital cost of $7,402 million; and (iii) it does not qualify for abbreviated authorization or environmental review processes under any applicable law. To be clear, the Project does not require any further “authorizations,” as defined at 42 USC 4370m(3), since the United States District Court for the District of Alaska did not vacate the Project’s authorizations. The preparation of a supplemental analysis pursuant to a court order does, however, qualify as an “environmental review.” See 42 USC 4370m(11), (9)(B). Upon completion of the supplemental analysis, USACE and BLM will evaluate whether the current authorizations should be modified. The Standard pathway includes infrastructure projects that fall within a designated sector and meet the following criteria. In addition to meeting the criteria outlined in 42 U.S.C. 4370m(6)(A)(i)., the Donlin Gold Project clearly fulfills the requirements of item 42 U.S.C. 4370m(6)(A)(iv). as well. The Project encompasses significant mining and infrastructure components that are subject to NEPA, as previously discussed. Furthermore, the scope and complexity of the Donlin Gold Project necessitate authorizations and environmental reviews by more than two federal agencies—including USACE and BLM as well as the U.S. Environmental Protection Agency, and the U.S. Fish and Wildlife Service who were cooperating agencies for the FEIS. This multi-agency involvement and the scale of required oversight further underscore the project's eligibility under 42 U.S.C. 4370m(6)(A)(iv). Donlin Gold acknowledges that FAST-41 requires that an eligible project needs Federal authorization to begin construction. Although the Alaska District Court decision under which the remand is being addressed did not vacate the Sections 404 and 10 permits from USACE or the Right-of-Way from the BLM, the court found that the FEIS and the Alaska Native Interest Land Conservation Act (ANILCA) Section 810 evaluation were inadequate in their analysis of a tailings spill. The Court enjoined Donlin from initiating any construction under the 404 permit or BLM ROW issued under the Joint Record of Decision (JROD) without 90-days’ notice to the Court and enjoined Donlin from initiating any construction related to the tailings dam until the SEIS is completed and the Corps and BLM have reaffirmed (or taken other action) on the JROD. The tailings storage facility is an essential component of the permitted mining and processing operations, i.e., they could not move forward without the additional work; therefore, completion of the SEIS and reaffirmance of the JROD by the Corps and BLM is required prior to Donlin beginning construction on the core aspects of the project. Accordingly, the Donlin Gold project is eligible for inclusion in FAST-41. 6 REFERENCES Agnew::Beck Consulting. (2018). Yukon-Kuskokwim Region Comprehensive Economic Development Strategy 2018-2023. Anchorage, Alaska. CEQ. (2007). A Citizen's Guide to the NEPA. Washington D.C.: Council on Environmental Quality, Executive Office of the United States. Executive Office of the United States. (2025). Executive Order 14241: Immediate Measures to Increase American Mineral Production. Washington D.C.: Federal Register. mindat.org. (2025, 8 7). Snow Gulch Mine, Iditarod Mining District, Bethel Census Area, Alaska, USA. Retrieved from mindat.org: https://www.mindat.org/loc-200046.html NovaGold Resources, Inc. (2021). NI 43-101 Technical Report on the Donlin Gold Project, Alaska, USA. NovaGold Resources, Inc. OMB and CEQ. (2025). Memorandum for Heads of Executive Departments and Agencies. Washington, D.C.: Office of Management and Budget and Council on Environmental Quality. OtterTail. (2009). Instream Habitat Analysis of Crooked Creek for the Donlin Gold Project. Anchorage, Alaska: OtterTail Environmental, Inc. OtterTail. (2014). Donlin Gold Natural Gas pipeline Project 2010-2015 Aquatics Surveys. Anchorage, Alaska. USACE. (2018). Donlin Gold Project Final Environmental Impact Statement. JBER, Alaska: Department of the Army. U.S. Army Corps of Engineers. USACE and BLM. (2018). DONLIN GOLD PROJECT Joint Record of Decision and Permit Evaluation. Crooked Creek, Alaska.