Letter to the Ministry of the Environment and the Fight against Climate Change: BAPE on project to expand the mining waste storage capacity of the Lac Bloom mine

Montreal, Quebec and Sept-Îles, August 10, 2020
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Mr. Benoit Charette, Minister
Ministry of the Environment and the Fight against Climate Change
Marie-Guyart Building
675 René-Lévesque Boulevard East, 30th floor
Quebec (Quebec) G1R 5V7

Subject: BAPE on project to expand the mining waste storage capacity of the Lac Bloom mine

Minister,

The undersigned hereby wish to convey to you their deepest concerns regarding the proposed expansion of mining waste storage at the Bloom Lake mine by the Australian mining company Champion Iron.

After a review of the proponent's environmental assessments, and following the first public information meeting held last July by the Bureau d'audiences publique sur l'environnement (BAPE), we judge the project, as proposed in its current form. , as unacceptable. Quebec must demand changes to the project.

Our main concern concerns the destruction of 8 lakes and dozens of waterways that the promoter proposes for the storage, in perpetuity, of 872 million tons of mining waste, while other solutions exist. We are also concerned about the risks of mining tailings spills into the environment, water contamination, identified impacts on biodiversity and
compensatory measures proposed by the promoter.

Destruction of lakes and watercourses for the storage of mining waste

The approach proposed by the proponent of filling lakes with its waste contravenes the historic approach of the Ministry of the Environment and the Fight against Climate Change (MELCC) to prohibit this type of practice in Quebec, in particular under the Directive 019 on the mining industry applied since 1989. This way of doing things also contravenes the objectives of the Quebec policy for the protection of banks, coastlines and floodplains, as well as several principles which underlie the Act respecting sustainable development of Quebec.

The proponent justifies this practice by relying on the Federal Regulations on Metal and Diamond Mining (RMMD), which opens an avenue for the destruction of watercourses for the storage of mining residues in exchange for compensatory measures for loss of fish habitat. Quebec must close this breach and clearly prohibit this type of practice on its territory, while demanding alternatives
to avoid the destruction of lakes and rivers.

Backfill open pits to reduce footprint and avoid lake destruction

The filling of mining pits and excavations with mining residues constitutes one of the best practices already implemented in other mining projects in Quebec and internationally. It makes it possible to significantly reduce the footprint of surface mining impacts and avoid the unnecessary destruction of lakes and watercourses.

However, the promoter asserts that he cannot implement partial or complete backfilling of the pit because this would compromise the economic viability of “potential” future exploitation of the pit at depth. This potential is in no way demonstrated in the promoter's technical and financial studies, nor is it part of the current project. He also states that he must leave the pits free of residue to be able to access them, at all times, in order to extract the different types of rocks and ensure “the right rock recipe” to send to the processing plant. treatment. These explanations are in no way demonstrated in current studies and are insufficient to justify the destruction of lakes. They do not meet the requirements of the law, nor do they meet industry best practices.

Quebec must set clear environmental guidelines and require the developer to backfill its tailings in open pits in order to avoid the destruction of lakes and watercourses. In addition, and only if necessary, Quebec must also require new analyzes for residue storage scenarios on sites located beyond the limit of the current mining lease, as permitted by law.

Risks of dike failure and mine tailings spills

In addition to reducing the project's footprint and avoiding the unnecessary destruction of lakes and watercourses, the complete or partial backfilling of open pits would further reduce the risks of dike ruptures and water spills. mining residues in the environment. Although the proponent claims that such a scenario is, in theory, unlikely, in practice there has been an increase in mining spills in Quebec and internationally in recent years. The most recent case that made headlines was that of the Tata Steel iron mine in 2019, located in the same region, near Shefferville, which affected several waterways. On the site of the Bloom Lake mine itself, the previous owner, Cliff Resources, has already been sentenced to criminal sanctions for a series of mining spills between
2010 and 2012, including one which affected 14 lakes and streams over kilometres.

In the environmental studies, the promoter himself describes the consequences as “considerable” in the event of dike failure and mining spills. He claims that spills could affect dozens of rivers located downstream, as well as destroy a section of national road 389, which ensures the supply of essential services to the population. Although the promoter estimates the
damage from such a rupture at nearly 67 million $ and claims to have damage coverage insurance of nearly 75 million $, such amounts remain insufficient. The damage from such ruptures can reach several hundred million. It is Quebec taxpayers who risk having to pay the price. Returning some or all of the mine tailings to the pit would significantly reduce these risks.

Wastewater treatment and protection of biodiversity

We are also concerned about the anticipated impacts of the project on water quality, wetlands and biodiversity. Quebec must require the complete treatment of mining wastewater in order to meet the strictest standards in this area, while prohibiting the dilution of wastewater in natural waters to achieve said standards. Complete or partial backfilling of the pits would also avoid the destruction of hundreds of hectares of wetlands, whose mandatory protection north of the 49th parallel was unfortunately excluded in the regulation adopted by the government in 2018.

Furthermore, let us remember that it is the duty of our governments to ensure the protection and recovery of all wildlife species at risk. In this case, four species give rise to concern: two species of birds with special status were observed in the study area (the bald eagle and the rusty blackbird), as well as the forest caribou, which is classified as “threatened” in
under federal law and as “vulnerable” under Quebec law. The migratory caribou, which is in danger of extinction, has not been taken into account in the current studies, despite the proponent confirming that it is “likely to frequent the study area”. Any biodiversity compensatory measure for the loss of habitats or wildlife species should only be used as a last resort. Quebec must first demand to avoid all possible impacts.

All in all, we reiterate our deepest concerns about the project and consider it unacceptable in its current form. We fear the dangerous precedent that could result from authorizing the destruction of dozens of lakes and rivers, when solutions exist to avoid these impacts. Quebec must demand changes to the project and must maintain its historic position of prohibiting this type of practice on its territory. Faced with these issues, and as permitted by the Environmental Quality Act, we are requesting an examination by the Bureau d'audiences publique sur l'environnement du Québec.

We thank you in advance for the attention and diligence that you will give to this and assure you, at the same time, of our full and complete collaboration for any additional information that you deem relevant to the issues of concern at this time. case.

In the hope and expectation of a follow-up to this, please accept, Mr. Minister, our respectful greetings,

Signatories: