The following is a copy of a letter which I have submitted to the Canadian Environmental Assessment Agency regarding the environmental assessment process underway for Cliffs Chromite Project. Cliffs is seeking to establish an chromite mine (open pit and underground) on crown lands in remote Northwestern Ontario, known as the Ring of Fire. Chromite ore will be processed on site, and then trucked several hundred kilometres to an existing rail head at Nakina, Ontario, where it will be loaded and transported to a ferrochrome production facility (smelter). Currently, Cliffs "base case" for the environmental assessment is using the Moose Mountain site, located in the City of Greater Sudbury, about 20 minutes drive outside of the community of Capreol, for the purposes of the EA, although no commitment has been made to locate the smelter there.
Cliffs has published the "Cliffs Chromite Booklet", which contains more information on the plans for this project.
Commenting on the draft CEAA Guidelines closed on November 16th. Opporutnities for addtional public input may be availalbe later in the process, once technical and other studies have been finalized by Cliffs and its consultants.
November 15, 2011
Cliffs Chromite Project
Canadian Environmental Assessment Agency
Jim Chan, Project Manager
55 St. Clair Avenue East, Suite 907
Toronto ON M5T 1M2
*Sent Via email and Regular Mail*
Re: Cliffs Chromite Project, Public Comments Invited on
Draft Environmental Impact Statement (EIS) Guidelines
I have had an opportunity to review the draft EIS Guidelines posted to the Canadian Environmental Assessment Agency (CEAA) website for the Cliffs Chromite Project. I understand that this project includes four components:
1) The mine site, intended to be located near McFauld’s Lake in that part of remote Northwestern Ontario which has lately become known as “The Ring of Fire”. The mine will extract materials from Cliffs “Black Thor” deposit;
2) The ore processing facility, which is to be located at or near the mine site;
3) An integrated transportation system to service the mine site and ore processing facility, which will include air transport features, and an all-weather roadway which will connect the mine site and ore processing facility to the railhead at Nakina (a portion of this road is already in existence);
4) A ferrochrome production facility to be located elsewhere in Northern Ontario, and for which the draft EIS assumes will be located within the geographic boundaries of the City of Greater Sudbury, at a location known as “Moose Mountain” outside of the community of Capreol (this assumption forms the “base case” for ferrochrome production facility).
I have also reviewed materials previously published by Cliffs on the internet (at: http://www.scribd.com/doc/66087132/CliffsChromite-Booklet), known as the “Cliffs Chromite Booklet” (dated February, 2011). This publication was extremely helpful in my understanding of the anticipated project and processes, although I do understand that some or all of the information contained in this publication may be out of date or otherwise not relevant to the CEAA’s environmental assessment process, as it appears that the CEAA is relying on more recent information received from Cliffs (noted in the draft Guidelines as being from May, 2011).
I wish to offer the following comments:
1. “Comprehensive Review” vs. “Joint Environmental Assessment”
The four components of this project, as outlined above, are limited in scope to what is currently being sought by a single corporation for approval from the CEAA. Specifically, the mine which is to be located to exploit Cliffs’ Black Thor deposit, is only one of several deposits of chromite in the area which are expected to be commercially viable deposits.
Further, portions of the integrated transportation system will undoubtedly provide service for accessing other deposits, both those staked by Cliffs (such as the “Big Daddy” deposit) and those of Cliffs’ competitors.
Finally, the ferrochrome production facility will also undoubtedly process ore from other deposits in the Ring of Fire, including Cliffs’ Big Daddy deposit, and perhaps those of some of Cliffs competitors as well.
Given the unique circumstance which future chromite producers in the Ring of Fire find themselves in, the environmental assessment process being contemplated by the CEAA in its draft guidelines is simply not providing the right kind of assessment, in that it will ignore the anticipated development of other deposits in the area, including Cliffs own Big Daddy deposit. Without assessing impacts from other anticipated development, the process which is laid out in the draft guidelines will not address the full range of anticipated actual impacts.
I understand that a more comprehensive process is available to the CEAA, known as the “Joint Environmental Assessment”. Given the specific situation which mining companies in the Ring of Fire find themselves in, and the clear overlap of issues, it would seem sensible for mining companies to work together and provide a truly comprehensive analysis of expected developmental impacts. A Joint Environmental Assessment would also likely save mining companies and the governments of Canada and Ontario money, as redundancies could be addressed through a single process (whereas each company may be asked to repeatedly provide the same information, for the repeated review by our governments; this is not an effective use of time and money, in my opinion).
Respectfully, I believe that the CEAA needs to provide an environmental assessment process which will capture the full range of anticipated impacts of all proposed development within and stemming from the Ring of Fire. Only a truly comprehensive process can assess anticipated impacts. Further, such a process will likely cost less in the long term. I strongly urge the CEAA to initiate a Joint Environmental Assessment for all projects within the Ring of Fire.
2. Climate Change and Greenhouse Gas Emissions
Whatever process is to be used, the draft Guidelines prepared by the CEAA appear to be deficient when it comes to the need to factor the costs of greenhouse gas emissions into the project components. Specifically, greenhouse gas emissions need to be considered as part of the “net economic and social benefit” of the project to Canada.
While section 10.2.1.2 of the Guidelines references that the EIS should include a discussion of measures to minimize the release of greenhouse gases, there is no requirement for the EIS to assess the future cost of such emissions. A per tonne levy on carbon emissions may have significant financial impacts on the Cliffs Chromite project, and indeed on all future projects located within the Ring of Fire. That there isn’t currently an established price on carbon emissions should not mean that the anticipated costs of carbon pricing aren’t considered.
Ontario’s recent election returned to power a government which campaigned on Ontario’s continued involvement in the Western Climate Initiative (WCI). The WCI is a group of provincial and state level governments in Canada and the United States which has been working together to establish a carbon emissions trading program, also known as a “cap and trade” carbon pricing system. Further, in the May 2011 federal election, more votes were cast for the candidates of parties which support carbon pricing (approximately 60%) than for political parties which have been non-committal on putting a price on carbon (approximately 40%). As such, we can fully expect that carbon pricing will be a reality at some point during the anticipated lifespan of the Cliffs Chromite project, and therefore the cost of emissions need to be evaluated.
With or without an assessment of the anticipated costs of carbon emissions, the draft guidelines do indicate in section 10.2.1.2 that the EIS shall discuss analytical techniques and relevant policies in the EA, and list and estimate greenhouse gases produced for all relevant project sources, and compare these to other mining projects. Here the CEAA should also require in the draft EIS that the EA should include projections for greenhouse gas emissions based on both the current provincial energy mix and the province’s anticipated future energy mix, over the estimated lifespan of the project. Further, the assessment of greenhouse gas emissions should be identified for each of the four project components, and be cumulative over time.
“Should” vs. “Shall”
In section 10.2.1.2 of the draft EIS guidelines the word “should” is used regarding a discussion of measures to minimize the release of greenhouse gases; this word should be replaced with the word “shall” in order to clearly require the discussion. This change will provide some certainty for Cliffs that minimization measures must be looked at.
With regards to greenhouse gas emissions, I have specific concerns regarding two components of the project, which I will address briefly, below. These issues could be built into section 10.2.1.2 of the Guidelines.
Greenhouse Gas Emissions and the Transportation System
Cliffs appears to have decided that road transport on trucks from the Black Thor deposit to the Nakina railhead will be the primary method to move ore and ore concentrate. I believe that more information is needed regarding rail transport before Cliffs can definitively identify a preference for a road network. While I do not have specific data regarding greenhouse gas emissions from trucks versus rail for the quantities of ore and concentrate to be shipped, it is my suspicion that rail transport from Black Thor to Nakina would offer lower emissions. Rail transport should be assessed as part of the EA process, as it would provide a legitimate alternative to trucking.
Further, the Moose Mountain site, which is intended to house the ferrochrome production facility, is located considerably outside of the City of Greater Sudbury’s settlement area boundary. While this may be a sensible location in order to minimize noise, odour and dust other environmental impacts on existing development, the fact is that Moose Mountain is currently only accessible by road (although a rail spur is being contemplated for the movement of goods to and from the site). As approximately 300-500 jobs are being contemplated for the ferrochrome production facility, the EA should also address the best way to minimize greenhouse gas emissions for employees who must travel to and from Moose Mountain. Specifically, the EA should address public transit routes, including busways and/or the opportunity for a light rail corridor (tramway), instead of simply requiring access to be by personal motorized vehicle, which is the current situation.
Greenhouse Gas Emissions and Energy Use
According to Cliffs, the arc furnace which is to be located at the ferrochrome production facility will use as much electricity as a city with 300,000 inhabitants uses. Given this circumstance, is there any opportunity at all for Cliffs to implement some form of carbon capture and storage, in order to minimize greenhouse gas impacts on our atmosphere? Assessing the potential for carbon capture and storage should be a requirement of the Environmental Assessment.
Further, Cliffs may wish to consider providing for green energy production on-site at both Moose Mountain and at McFauld’s lake, either through biomass, wind or solar, in order to help offset impacts on the provincial energy grid.
3. Cumulative Effects
Section 10.9.3 of the Guidelines indicates that Cliffs shall identify the sources of potential cumulative effects. Here, the Guidelines should clearly identify that one of the sources of cumulative effects is the presence of other commercially viable mineral deposits in the Ring of Fire (including chromite), both under the control of Cliffs and those not under Cliffs control. Exploitation of at least some of these deposits is likely to move forward towards development over the next 20 or so years. Infrastructure to be created through the Cliffs Chromite project will most likely also provide service to Cliffs exploitation of other deposits, as well as for Cliffs competitors, especially the use of the transportation and production infrastructure which is being contemplated by Cliffs through this EA process.
4. Water Quality and Hexavalent Chromium
The proposed ferrochrome production facility is to be located in close proximity to Lake Wanapitei, which is a drinking water source for the City of Greater Sudbury. I understand that the Guidelines emphasise the need for the EA to look at anticipated impacts of the production facility on water, and also specifically reference hexavalent chromium as a chemical compound of interest. That being said, the importance of understanding the anticipated impacts of hexavalent chromium on the Lake Wanapitei watershed can not be understated, given the lake’s importance as a drinking water source, and given the acidic nature of Sudbury’s soils. This is an extremely important issue, and Cliffs must address it seriously and comprehensively.
5. Economic and Social Benefit
The economic and social benefit of this entire project remains unclear and unknown at this time. Yet, that has not stopped publicly elected officials at all levels of government from offering their backing and support. Despite the backing of elected officials, the CEAA needs to take this matter seriously. To do so, a comprehensive analysis of costs is necessary. Without understanding the full and anticipated costs of this project, questions regarding economic and social benefit will remain unanswerable.
Regarding costs, specifically the EA should look at anticipated energy costs and the level of subsidy which Ontario taxpayers may be asked to contribute in order to make this project economically viable for Cliffs. Cliffs has already gone on the public record with claims that current electricity prices in Ontario are too high for the economic viability of a ferrochrome processing facility, and that the public should therefore subsidize their operation. Ultimately, this may or may not be a good economic approach, which is why more information regarding current and future energy costs and subsidies are required.
Cliffs should provide an economic impact analysis of the entirety of the Cliffs Chromite project, including a realistic assessment of wealth creation through direct jobs (both permanent and temporary) and indirect jobs from establishing a new industry in Ontario’s north. Ideally, this economic impact assessment should look at the full range of economic opportunities offered through anticipated development of the Ring of Fire in its entirety, so that the public can have a clear picture regarding total costs and opportunities.
The costs to the planet’s climate should also be assessed and it should be determined through the EA process whether Canadians will derive a social benefit from the Cliffs Chromite project, which is anticipated to be a significant contributor to climate changing greenhouse gases. It may be that the social benefit of not allowing this project to go forward outweighs any benefit of permitting the significant outputs of greenhouse gases into our atmosphere. Again, this issue is bigger than Cliffs Chromite project, and the CEAA really should consider the total contribution to greenhouse gas output of all anticipated Ring of Fire development.
I am frustrated that the CEAA has chosen to assess Cliffs Chromite project as a single project, disconnected from the reality of development proposals on the ground in the Ring of Fire. If ever there was an area of proposed development for which a Joint Assessment should be used by the CEAA, clearly Northwestern Ontario’s remote Ring of Fire fits the bill, as development is to be in an isolated, geographically confined area, which because of its ecology, is sensitive in nature. The Ring of Fire is located within the habitat area of Canada’s iconic woodland caribou, an endangered species which is very skittish when it comes to development. While I am glad that the draft Guidelines developed by the CEAA require the assessment of potential impacts on caribou from Cliffs Chromite project, the fact is that this assessment should be taking place on a broader scale, and it should consider the impacts from all anticipated development.
This ad hoc approach to assessing development is doing a considerable disservice to the people of Canada, and to residents of the City of Greater Sudbury in particular, who may be on the hook to finance upgrades to service a ferrochrome production facility which may ultimately be bigger in scale and used longer than anticipated to simply service ore and concentrate from Cliffs Black Thor deposit. We don’t know what we’re getting ourselves into here, and the EA process contemplated in the draft Guidelines won’t provide clarity when it comes to actual anticipated impacts. A more comprehensive process which assesses the Ring of Fire in its entirety is therefore necessary.
Another process is available to the CEAA: the Joint Environmental Assessment process. The CEAA should require a Joint EA process at this time. It is to the CEAA’s, and ultimately Canada’s shame, that our federal environmental assessment agency is deciding to pursue an ad-hoc approach when environmental sustainability and the health of Canadians could be at risk from development if it proceeds in an uncoordinated manner.
Further, Cliffs may find itself financially disadvantaged for being the first company through the door, as it were, and may have to foot the bill to answer many questions which go beyond the specifics of their project. To make the process fair for Cliffs, a Joint Environmental Assessment process would see costs shared amongst all who will benefit from resource exploitation.
I wish to be kept informed of all aspects of the CEAA’s environmental assessment process, and added to the list of those to be consulted by Cliffs throughout the process.
CEO, Sudbury Federal Green Party Association
(the opinions expressed in this blog are my own and should not be interpreted as being consistent with those of the Green Party of Canada)