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Mine du lac Bloom

Montreal, April 3, 2023

Bloom Lake Iron Mine Tailings Facility Expansion Project
Environment and Climate Change Canada
Mining Section, Mining and Processing Division
351, boulevard Saint-Joseph, 11th floor
Gatineau QC K1A 0H3


Subject: Bloom Lake Iron Mine Tailings Facility Expansion Project

Dear,


Hereby, Emergency Water and Fondation Rivières wish to communicate to you their concerns and requests regarding the notice of Amendments to the Regulations respecting effluent from metal mines and diamond mines for the Bloom Lake project.

For several years now, our organizations and our numerous partners – whether we are talking about citizen and environmental organizations, communities or committed individuals – have been following the expansion of the Bloom Lake mine tailings park. carefully. Our participation in the Public Hearing Office on the Environment (BAPE) and the analyzes of this body allowed the BAPE to reject, unequivocally, the proposal from Ore Fer Québec in 2021. Among the arguments having led to this rejection, we will note the obvious possibility of using one or other of the gigantic pits dug by the developer to store the waste that their excavation generates. In the popular mind, this is common sense. In the minds of analysts consulted during previous efforts, this is the responsibility of the promoter. In the spirit of the economic analyzes that have been carried out, this is a technically and economically feasible solution. It is really only in the mind of the promoter himself that this solution remains impossible to envisage for purely economic and, as we will demonstrate below, purely speculative reasons.

We would not be, today, sending you this umpteenth memorandum concerning this disastrous project if the provincial government had done its homework, had assumed its role as defender of the territory against poorly developed projects and had followed the recommendation of the BAPE encouraging him to demand that the developer go back to the drawing board to develop a better solution that does not unnecessarily sacrifice eight lakes, including one of 88 hectares. However, the provincial government gave in to the promoter's economic argument and, to do so, ignored the opinions of experts in favor of opinions poorly supported by civil servants and consultants defending particular interests more than the environment that we are preparing to sacrifice. This government is also hiding behind the appearance of a consultative process involving the population and the various stakeholders concerned, but our analyzes reveal that several elements point in the direction of downright flawed analysis and decision-making processes. We will support these points below.

Since this disastrous decision by the Quebec government to accept this negligent, poorly planned, poorly managed, poorly oriented, poorly supervised and unnecessarily destructive project, Eau Secours and Fondation Rivières, in particular – but also with the unwavering support of many of its allies .es – have initiated steps to analyze the decision rendered to identify serious shortcomings in the evaluation processes of this project. These steps also made it possible to identify how much the reason
to be of the solution adopted is poorly supported, how incomplete the analysis submitted is, how much the government authorities, both federal and provincial, at one time or another, have been able to demonstrate laxity and how much there is no urgency to move forward with such a rushed and misdirected solution. We will therefore try, here, to demonstrate the particular and highly disturbing history which characterizes the development of the Bloom Lake mine. We will continue with the shortcomings observed at the level of project analysis and decision-making process. We will then end with the obvious lack of valid reasons justifying the unnecessary sacrifice of these lakes.

A few additional points will support all of our approaches and reflections. Eau Secours' past report, submitted to the BAPE held in 2020, is available in the Appendix to this report. There is also, following it, a non-exhaustive press review reporting on the precariousness of water in Quebec as elsewhere in the world and illustrating how water is not this infinite resource which can be used as needed. seems to us – contrary to certain preconceived ideas wanting
that it is infinite and infinitely renewable. Finally, also in the appendix, is attached a text written by Raymond Lemieux, journalist, and reporting the dubious process governing the analysis and decision-making concerning the development of this iron mine.

In summary, our main demands

  • Refuse the promoter's request to sacrifice lakes for the storage of its mining waste;
  • Require the proponent to develop and apply an alternative solution to the storage of its mining waste without sacrificing any lake, as well as serious scenarios for backfilling the pits in order to limit the impact of waste storage as much as possible out of these pits;
  • Grant additional time to civil society to submit documentation and opinions, with the stated objective of allowing the completion of procedures initiated by the organizations Fondation Rivières and Eau Secours with the provincial Ministry of Natural Resources and Forests. This information that our organizations hope to be able to obtain through access to information will, for their part, be transmitted to you without delay as soon as we obtain it;
  • Take into account the laxity in assessments and authorizations from which the various owners of the Bloom Lake mine have historically benefited;
  • Take into account the gaps identified in the analyzes from which the various expansion projects of the Bloom Lake mine benefited, facilitating their acceptance.

Photo: Bloom Lake Mine, BBA Consultants

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