The recent approval of the Coté Gold mine shows all that is wrong with the environmental assessment of gold mines in Ontario.

Located between Sudbury and Timmins near Gogama, it is only one of many new gold mines being approved in northern Ontario as the price of gold reaches an all-time high due to COVID.

 All, so far, have been found to have “no significant environmental effects”.

By the time the mine closes in 17 years or earlier, the footprint of the mine will be over 10 sq. km. (not including roads, a transmission line and downstream effects on water). The open pit will be at least 145 hectares and 550 meters deep; the 560 million tonnes of waste rock will cover 300 hectares and the tailings facility will be another 478 hectares, storing 200 million tonnes of water saturated tailings. IAMGold, the mine operator, plans to process 36,000 tonnes of ore per day, using a cyanidation process.

During construction a man camp for over 1000 workers will be constructed on site, but once operations begin, it is estimated that 350 workers will be needed.

Water will be taken from Mesomikenda Lake and discharged into Three Ducks Lake. To build the mine, Coté Lake will be dewatered and other water bodies near the mine will be redirected to create “New Lake”.

At closure, it will take at least 25 years for the open pit to fill with water and reconnect with existing water systems; the waste rock piles will be contoured. The tailings impoundment will have to be monitored forever to prevent leakage or catastrophic dam collapse.

The company also believes that there is possibility for expansion through more gold deposits nearby. The footprint could become much larger.

The Coté Gold mine underwent a federal environmental assessment under CEAA2012 that started March 2013. The federal EA was approved in April 2016. However, the company undertook a pre-feasibility study and, based on these results, changed a number of parameters for the mine. This resulted in an amended Environmental Assessment, which was approved in February 2019.

The Ministry stated in its decision:  “I have determined that the Designated Project is not likely to cause significant adverse environmental effects referred to in subsection 5(1) of the Canadian Environmental Assessment Act, 2012.”

The company volunteered to undertake a provincial EA concurrently with the federal one, to assist permitting. That decision was issued on January 19, 2017. It should be noted that the Ontario approval is for the EA that was federally approved in 2016, and is for a larger mine. The Ontario Ministry of Environment and Climate Change decision (EA-05-09-02) found that “the environmental effects of the undertaking can be appropriately prevented, changed, mitigated, or remedied.”

In both decisions, the conditions of approval deferred all decisions regarding specific requirements to the permitting stage for the project. For example:

5.5 The Proponent shall, in consultation with Indigenous groups, develop and implement a follow- up program related to the effects of changes to the environment caused by the Designated Project on harvesting, fishing, hunting or trapping activities for traditional purposes by Indigenous groups, to verify the accuracy of the environmental assessment and to determine the effectiveness of the mitigation measures implemented to address those effects. The Proponent shall implement the follow-up program during all phases of the Designated Project.

Since the ecology of the region has already been severely altered by over a century of mining in the Timmins and Sudbury areas, there are few other options for the First Nations and settler populations of the area. Flying Post and Mattagami First Nations have signed impact benefit agreements with the mining company which, they hope, will compensate for the damage and provide jobs and contracts.

However, the mine will have serious effects on the forest, water, wildlife and people in the region for decades to come. How did we get to a place where creating such massive, long-term damage to the ecosystem is the only way people can see to survive?

All this to provide gold for wealthy people in other parts of the world, and huge rewards to the major IAMGold investors.

A September 2020 report from law firm Olthius, Kleer and Townshend (OTK) compares the implementation of best practices in mining law in five different Canadian provinces and territories to a Best Practices standard developed by the Initiative for Responsible Mining Assurance (IRMA).

The report is called, Raising the Stakes: A Comparative Review of Canadian Mining Law and Responsible Mining Standards.

Ontario fails to meet the standards in every single category.

The Initiative for Responsible Mining Assurance (IRMA) standard is a leading example of international standards which was developed over 10 years engaging more than 100 organizations on how best to address environmental and social issues in mining. IRMA’s members include Anglo American, ArcelorMittal, Microsoft, Tiffany & Co., Jewellers of America, BMW, IndustriALL, United Steelworkers, First Nations Women Advocating Responsible Mining, Human Rights Watch and Earthworks.

The OTK report measures the extent to which these Canadian jurisdictions achieve best practices by comparing them to the IRMA Standard and making recommendations for improvements.

The report focuses on key elements of mining laws and policies such as: Community Engagement; Environmental Assessment; Free, Prior and Informed Consent; Biodiversity, Ecosystems and Protected Areas; Water Management; Waste Management; and, Reclamation, Closure and Security.

Although almost all Canadian jurisdictions do poorly in the comparison, Ontario is the only jurisdiction that fails the “community engagement” subsection in environmental assessment and the only jurisdiction with no environmental assessment for large mines. Ontario also allows some mining companies (like Vale) to self-assure instead of requiring reclamation bonds.