Impact Assessment Agency of Canada

Assessment of the Mont Sorcier Mining Project

901-1550 Estimauville Avenue

Quebec City, Quebec G1J 0C1

Telephone: 418-254-2435

montsorcier@iaac-aeic.gc.ca

Subject: Comments on the draft individualized guidelines for the impact assessment and the draft public participation plan for Voyager Metals’ Mont Sorcier mining project in Eeyou Istchee in Northern Quebec

Community and environmental groups have prepared an important report on the impacts of mining exploration activities by Nouveau Monde Graphite (NMG) in Matawinie. Following an independent community environmental monitoring campaign, the report identifies numerous cases of heavy metal concentrations in watercourses that exceed environmental protection criteria, likely attributable to exploration activities.

Our annual report provides some key impact stories from MiningWatch's work in 2024, with additional information about our financial position in 2024.

This year marked a milestone for MiningWatch. Celebrating our 25th anniversary provided an important opportunity for reflecting on the reasons MiningWatch formed when we first opened our doors in 1999, the struggles we’ve supported, the relationships we’ve built along the way, and the immense challenges that lie ahead. 

We find the Act as a whole to represent a disturbingly unaccountable and anti-democratic initiative, in that many of its provisions either bypass, undo, or override established processes, reserving decision-making authority to Ministers or Cabinet and removing those decisions from the purview of the Legislature or any other deliberative and publicly-accountable body or process.

The global steel, iron and metallurgical coal industry is emission intensive: the Canadian steel industry contributes to 2 percent of national emissions. Many emission-intensive Canadian steel mills either do not have plans in place, or are experiencing delays and a lack of clarity about the path to reaching net-zero emissions by 2050  – which is both a government and Canadian Steel Producers Association (CSPA) target.

Between 2022 and 2024, Indigenous Kuria from villages surrounding North Mara Gold Mine in Tanzania filed cases in Canada against Barrick Gold Corporation for alleged human rights abuses in and around the North Mara mine. MiningWatch Canada attended the hearings in Toronto and has prepared this report where we: 

MiningWatch Canada makes a submission to the UN Special Rapporteur on Climate Change, to inform the rapporteur’s upcoming report on “Human Rights in the Life Cycle of Renewable Energy and Critical Minerals.” 

This submission highlights several examples of human rights violations linked to mining for critical minerals, from initial claims staking to exploration, exploitation, and recycling. While our focus is on mining in Canada and the activities of Canadian mining companies abroad, these violations are common globally. 

In Canada, the National Pollutant Release Inventory (NPRI) is the means by which Canadians can access information on pollutants released into the environment from emitting companies. It helps Indigenous Nations, governments, scientists and civil society identify priorities for action to protect public health and the environment. 

Public access to the NPRI is through its web page. 

Submission to the United Nations’ Special Rapporteur on toxics and human rights, to inform the Rapporteur’s 2025 thematic report to the UN Human Rights Council.

The role of mercenaries, mercenary-related actors and private military and/or security companies (PMSCs) in the exploitation of natural resources.

Submission to the United Nations Working Group on the use of mercenaries to inform the Working Group's report to be presented to the 60th Session of the Human Rights Council in September 2025.

This submission updates and expands on MiningWatch Canada’s 2019 submission to the United Nations Working Group on the use of mercenaries with a focus on: 

On May 28, Québec’s Minister of Natural Resources and Forests, Maïté Blanchette Vézina, tabled Bill 63, an Act to amend the Mining Act and other provisions. The Coalition Québec meilleure mine (QMM) carried out an exhaustive analysis of the bill. In this brief, we present our general comments and proposed amendments. A detailed article-by-article analysis of the bill is available in the French version of this brief, originally published in September 2024 and available online.  

MiningWatch Canada launched as a pan-Canadian initiative on April 1, 1999, on the heels of a decade that saw an unprecedented global expansion of mining brought about by economic globalization. Indigenous, environmental, social justice, and labour organizations came together with different backgrounds and experiences to respond to threats posed by irresponsible mining practices in Canada and around the world.

Experts from the Environmental Law Alliance Worldwide (ELAW) say First Quantum’s Cobre Panama tailings dam is at very serious and imminent risk of failure due to internal erosion and a lack of proper monitoring. ELAW's report analyzes the Ninth Monitoring Report, presented by Minera Panama, a subsidiary of First Quantum Minerals that operates the Cobre Panama mine, in September 2024, together with other documents that were provided by the Ministry of Environment to ELAW experts who visited Panama in November 2024. 

For over a decade, MiningWatch Canada and the Canadian Network on Corporate Accountability (CNCA) have advocated for an effective and independent ombudsperson with the powers to compel documents and witness testimony, in an effort to hold Canadian companies accountable for abuse at their operations overseas. 

This year, MiningWatch gathered information on alleged violence against Kuria villagers in 2023 and 2024 carried out by police assigned to the mine. We received information on 28 cases and conducted interviews with alleged victims and family members of those who have been killed. The 28 cases include villagers who have been shot and killed, shot and survived, beaten to death, arrested and tortured, and maimed in a life-altering way through being hit by a teargas canister.

Canada and Ecuador are in their fourth round of negotiations towards a free trade agreement set to dramatically expand Canadian mining investment in the South American country.

MiningWatch Canada and the Coalition Québec Meilleure Mine hereby submit their joint comments on the Government of Canada's Emergency Order to Protect Boreal Caribou Habitat in Quebec (hereinafter, the "Federal Order") as part of the consultation process announced on June 19, 2024 and ending today.