Springpole Gold Project

Project summary

First Mining Gold is proposing to build, operate and eventually decommission an open pit gold and silver mine and ore processing facility approximately 110 kilometres northeast of the Municipality of Red Lake. The mine is estimated to have a 12-year production life.

Major components of the proposed project include:

• an open pit mine
• water management systems and treatment facilities
• accommodations and camp
• an ore processing plant
• an ore stockpile
• a mill feed storage area
• a crushing plant
• buildings and maintenance shops
• mine rock areas
• a tailings management facility
• auxiliary infrastructure
• coffer dams and dewatering infrastructure
• an offsite transmission line and infrastructure to connect to grid power
• an all-season access road

Learn more on the Springpole Gold Project website.

Proponent

First Mining Gold

Location

Approximately 110 kilometres northeast of the Municipality of Red Lake

Project type

Mining

Reference number

18041

Contact

Jenny Archibald, Environmental Assessment Branch

• Tel: 416-262-1221
• Toll-free: 1-800-461-6290
• jenny.archibald@ontario.ca

Project history

Terms of Reference: approved
Date submitted: August 21, 2020
Expiry of public comment period: October 5, 2020
Decision date: November 8, 2021

Voluntary agreement: signed
Signature date: April 18, 2018

Terms of Reference

Ontario is committed to an environmental assessment process that is open, transparent and ensures undertakings are planned and built in a way that protects our environment.

First Mining Gold has agreed to follow an environmental assessment process for the Springpole Gold Project. This assessment will look at how the mine and any associated infrastructure could impact the environment.

The assessment process starts with a work plan—called the Terms of Reference—that outlines how the assessment will be completed, including studies and consultation plans.

On November 8, 2021, the Minister of the Environment, Conservation and Parks approved, with amendments, First Mining Gold’s amended Terms of Reference for the preparation of their proposed Springpole Gold Project, an open pit gold and silver mine and associated activities.

The minister added some amendments to the Terms of Reference to:

• increase First Mining Gold’s commitments to consultation with Indigenous communities, government agencies and interested persons during the environmental assessment process
• clarify alternative methods that should be examined and the assessment methodology that would be used by First Mining Gold to complete its environmental assessment
• identify other permits and approvals that may be required for the undertaking following the environmental assessment

The approved Terms of Reference sets out in detail the requirements for the preparation of First Mining Gold’s environmental assessment. First Mining Gold may now proceed with preparing its environmental assessment in accordance with the approved Terms of Reference.

This project is also subject to requirements of the Canadian Environmental Assessment Act, 2012. First Mining Gold has expressed an interest in working with federal and provincial agencies to coordinate the federal and provincial assessment processes, where possible.

Notice of approval

Environmental Assessment Act subsection 6(4) approval of Terms of Reference for the preparation of an environmental assessment.

Proponent: First Mining Gold Corp.

Terms of Reference: Springpole Gold Project Environmental Assessment

Undertaking: The development, construction, operation and closure of an open pit gold and silver mine, and associated facilities and ancillary activities

EA file number: 18041

As provided for by subsection 6(4) of the Environmental Assessment Act, R.S.O. 1990, c.E.18 (“the Act”), the proposed Terms of Reference submitted for approval to the Ministry of the Environment, Conservation and Parks on August 21, 2020 and revised through the submission of an amended Terms of Reference by First Mining Gold Corp. dated April 29, 2021, is hereby approved with the amendments which I consider necessary, all of which are set out in this notice.

Pursuant to subsection 6.1(1) of the Environmental Assessment Act, any environmental assessment for the above-noted undertaking, submitted to the Ministry of the Environment, Conservation and Parks (MECP) pursuant to subsection 6.2(1) of the Environmental Assessment Act, must be prepared in accordance with the approved Terms of Reference.

Reasons

• The amendments in this Notice of Approval contain enhanced requirements for First Mining Gold Corp. to consult Indigenous communities, government agencies and interested persons with respect to key steps in the environmental assessment process. With these amendments, the approved Terms of Reference will ensure that the environmental assessment is completed using a comprehensive public, Indigenous and government agency consultation process that is open and transparent;
• The approved Terms of Reference provides adequate rationale for focusing the environmental assessment;
• The amendments in this Notice of Approval include additional requirements for First Mining Gold Corp. to consider certain alternatives for components of the undertaking including the “do nothing” alternative, as well as requirements to conduct its assessment of alternative methods to ensure that the potential effects, mitigation and management measures, advantages and disadvantages of each alternative are assessed. With these amendments, the approved Terms of Reference provides an appropriate level of detail to confirm that the completed environmental assessment should contain the sufficient level of detail to accurately assess the environmental effects of alternative methods and the proposed undertaking;
• I am satisfied that an environmental assessment prepared in accordance with the approved amended Terms of Reference will be consistent with the purpose of the Act and the public interest; and,
• There are no outstanding issues that have not been incorporated into the approved Terms of Reference and amendments, or that cannot be addressed through the preparation of the environmental assessment.

Amendments

To the extent that there is any conflict between the requirements outlined in the approved Terms of Reference and the amendments below, it is the amendments below that will take precedence.

1. Consideration of the “do nothing” alternative

To ensure that First Mining Gold Corp. adequately considers the “do nothing” alternative in its environmental assessment with respect to the assessment of alternative methods and the proposed undertaking, Section 5.2.1 – Identification of Alternatives in the Terms of Reference is amended to include the following:

In its environmental assessment, First Mining Gold Corp. will identify and assess a “do nothing” alternative.

The “do nothing” alternative will be considered in the context of a benchmark against which the potential effects of alternative methods will be evaluated and compared to determine the advantages and disadvantages of the alternatives.

The “do nothing” alternative will also be compared against the project to assess the overall advantages and disadvantages of proceeding with the preferred undertaking.

2. Alternative methods and assessment methodology

To clarify the proposed methodology presented in the Terms of Reference for the assessment of alternative methods for carrying out the undertaking, the Terms of Reference is amended to include the following:

2.1 Replace second sentence of Section 5 – Description and Rationale for Alternatives in the Terms of Reference with the following text:

In accordance with MECP’s Code of Practice: Preparing and Reviewing Terms of Reference for Environmental Assessments in Ontario (January 2014), a reasonable range of alternatives will be identified in the environmental assessment, based on consideration of the following questions, and a comparative evaluation will be completed per the methodology described in the sections below to assess each of the alternative methods […]

2.2 Replace first paragraph of Section 5.1.1 – Performance Objectives with the following text:

The assessment of alternative methods will be carried out to identify and evaluate potential environmental effects, advantages, and disadvantages of each alternative method of carrying out the Project, including measures to mitigate potential adverse effects and net effects. A comparative evaluation of a reasonable range of alternative methods will be conducted, and the advantages and disadvantages of each method will be assessed within the environmental assessment based on performance objectives, evaluation criteria and indicators, to define the preferred alternative.

2.3 The first two paragraphs of Section 5.1.2 – Evaluation Criteria and Indicators are amended to read:

Proposed criteria and indicators for the assessment of alternatives are described in the subsections that follow. These preliminary criteria and indicators presented in this ToR will be refined/modified through the EA process, following further analysis and to incorporate input from government agencies (including MECP), the various stakeholders and Indigenous communities. First Mining Gold Corp. will describe in its summary of consultations how comments and concerns were considered and, in the event that input is not incorporated in the EA process, First Mining Gold Corp. will provide justification for its decision.

Potential data sources for the assessment of alternatives indicators are provided below. Further data sources will be added during EA development with justification, if it is determined in consultation with government agencies that they are required to adequately assess the alternative methods.

2.4 Section 5.1.3 – Identification of the Preferred Alternative is amended to remove the following text:

Using this method, and with the knowledge that all performance objectives are essential to the decision process; an alternative is rejected if it attains an unacceptable rating for any single performance objective.

This section is further amended to include the following:

Consideration of each alternative method will be evaluated after potential impacts have been determined and mitigation measures have been applied. Identifying any requirements associated with effectively managing the key components will be considered during the evaluation of alternative methods.

A comparative methodology will be applied at a sufficient level of detail to identify advantages and disadvantages of each alternative method. The potential effects associated with each alternative method will be compared to establish the relative advantages and disadvantages of each option.

The results will be recorded in a summary table and conclusions for each criterion will be established based on the advantages and disadvantages of the alternative methods. The preferred alternative method will be the one with the preferred balance of advantages and disadvantages. The summary table will include a clear rationale for the conclusions and decisions made regarding the selection of preferred alternatives. The evaluation process will be clear, logical and traceable, allowing anyone reviewing the EA to come to the same conclusions without any additional assumptions.

3. Consultation

3.1 To strengthen the commitments in the Terms of Reference regarding consultation with Indigenous communities and government agencies at key decision-making milestones, Section 9.1 – Consultation Overview is amended to include the following:

In its environmental assessment, First Mining Gold Corp. will ensure effective and meaningful communication and engagement through the building of trust between the Project team and Indigenous communities to enhance awareness of the Undertaking. First Mining Gold Corp. will provide flexible consultation opportunities, issues resolution and feedback to consult Indigenous communities for the following components of the environmental assessment process:

• The development of community-specific Indigenous consultation plans, if requested, for the preparation of an environmental assessment;
• The development of criteria and indicators for the assessments of alternative methods and the preferred Undertaking;
• The development of the methodology, evaluation and results of Baseline Studies;
• The development of the evaluation methodology for the assessment of alternatives and the preferred Undertaking;
• The conclusion of assessment and evaluation of alternatives (including the identification of potential effects and the development of appropriate mitigation and management measures);
• The development and implementation of Traditional Knowledge and Traditional Land Use studies;
• The assessment and evaluation of the preferred Undertaking (including the development of mitigation and monitoring measures to address any potential effects); and,
• The conclusion of the assessment and evaluation of the preferred Undertaking (including potential effects, and appropriate effects management measures).

First Mining Gold Corp. will provide opportunities for Indigenous communities to be engaged at critical decision-making points during the environmental assessment process, so that Indigenous communities may provide input on how the undertaking and its alternatives may have an impact on their rights and interest through the sharing of traditional knowledge; and, that First Mining Gold Corp. will consider and incorporate, where appropriate, traditional knowledge and traditional land use into each environmental assessment decision-making milestone.

First Mining Gold Corp. will also provide opportunities for government agencies and interested persons to be engaged at critical environmental assessment decision-making milestones, including the identification of criteria and indicators, the development of baseline studies and evaluation methodologies.

3.2 The second paragraph on page 6-39 of the Terms of Reference in Section 6.8 – Ongoing and Future Studies is amended to read:

Baseline studies for the Undertaking have been ongoing since 2011. Where necessary, First Mining Gold Corp. have identified additional studies to supplement programs in 2021. Additional studies may be identified during the course of the environmental assessment process through consultation with Indigenous communities, government agencies and interested persons; if additional studies are required through consultation with MECP, these studies will be used to further inform the environmental assessment.

Baseline study methods will be circulated for review and comment to government and Indigenous communities. Opportunities to review and provide input on the programs and results will be provided during the environmental assessment, which will be considered going forward as on-going fieldwork programs are refined into monitoring programs.

4. Draft Environmental Impact Statement / Environmental Assessment (EIS/EA) Report

To strengthen First Mining Gold Corp.’s commitments to consulting on draft environmental assessment documentation, the Terms of Reference is amended to include the following:

4.1 The fourth paragraph of Section 6.8 – Ongoing and Future Studies and the text in the corresponding commitment in Table 8.1.2 in the Terms of Reference are amended to read:

Given the current limitations imposed by the COVID‑19 pandemic, different approaches to consulting throughout the EA process may need to be considered by First Mining Gold Corp. if this is of interest to communities. First Mining Gold Corp. will continue to discuss opportunities to consult with Indigenous communities during the EA process as the pandemic vaccination process advances. These opportunities will be dependent upon the capacity and interest of the Indigenous community and may include sharing baseline reports, criteria / indicators, preliminary alternative assessments, preliminary Technical Support Documents, or portions of the environmental impact statement / environmental assessment (EIS/EA). First Mining Gold Corp. will prepare a draft EIS/EA report including supporting studies for review by interested persons, Indigenous communities and the government review team. The draft EIS/EA report will be circulated for a comment period lasting a minimum of six weeks. Notice of the comment period on the draft EIS/EA report will be provided. Comments will be considered and responses demonstrating how comments/concerns would be addressed in the final EIS/EA will be provided by First Mining Gold Corp. prior to submission of the final environmental assessment.

4.2 The first sentence of the second paragraph of Section 9.8.1 – Indigenous Consultation Plan is amended to read:

Consultation opportunities will be dependent upon the capacity and interest of the Indigenous Community and will include consultation on a draft EIS/EA, as well as potential opportunities for sharing baseline reports, criteria/indicators, preliminary alternative assessments, preliminary technical support documents in advance of the draft EIS/EA submission.

4.3 Section 5.2 – Methods of Reaching Out to Indigenous Communities in Appendix E1 – Indigenous Consultation Plan is amended to include the following bullet:

• Notice and circulation of a draft EIS/EA report for review – First Mining Gold Corp. will provide an opportunity for Indigenous communities to review and provide comments on a draft EIS/EA report. A comment period lasting a minimum of six weeks will be provided.

4.4 Section 3.1 – Methods of Reaching Out to the Public in Appendix E2 – Public Engagement Plan is amended to include the following bullet:

• Notice and circulation of a draft EIS/EA report for review – First Mining Gold Corp. will provide an opportunity for interested persons to review and provide comments on a draft EIS/EA report. A comment period lasting a minimum of six weeks will be provided.

4.5 Section 2.1 – Methods of Reaching out to Government in Appendix E3 – Government Consultation Plan is amended to include the following bullet:

• Notice and circulation of a draft EIS/EA report for review – First Mining Gold Corp. will provide an opportunity for government agencies to review and provide comments on a draft EIS/EA report. A comment period lasting a minimum of six weeks will be provided.

5. Alternative Methods for Site Access and Transmission Line Corridors

To ensure that First Mining Gold Corp. will assess a reasonable range of alternative methods for proposed all-season access road and transmission line corridors in its environmental assessment, the Terms of Reference will be amended as follows:

5.1 The second last sentence of Section 5.2.12 – Power Supply will be amended to read:

A reasonable range of power supply alternative methods will be considered and assessed in the environmental assessment, including alternatives for transmission line corridors and routings if grid power is selected as a preferred power supply.

5.2 The last sentence of Section 5.2.13 – Site Access will be amended to read:

An all-weather two-lane access road is proposed as part of the undertaking. In its environmental assessment, First Mining Gold Corp. will identify and assess a reasonable range of alternative access road locations and alignments for the proposed two-lane all-season access road to the project site, including alternative access corridors from the west and from the east. For each access road and alignment alternative, First Mining Gold Corp. will assess proposed aggregate sources, as well as any aggregate source alternatives and the potential environmental effects of extracting and transporting aggregate from any source. The assessment will include the consideration of the duration and frequency of the use of the access alternatives. Options to avoid impacts to species at risk and species at risk habitat shall be considered.

6. Noise Assessment

To ensure that off-site components of the undertaking are appropriately assessed for potential noise effects, the last paragraph of Section 6.3.6.1 – Noise in the Terms of Reference is amended to read:

In its environmental assessment, First Mining Gold Corp. will assess and include potential off-site noise sources associated with the undertaking as described in the ToR including, but not limited to, proposed access routes and transmission lines.

7. Commitments

To ensure that First Mining Gold Corp. has included all commitments made through the Terms of Referencereview process in its Table of Commitments in the Terms of Reference, First Mining Gold Corp. is required to update Table 8.1.1 of the Terms of Reference, in consultation with the ministry’s Environmental Assessment Branch, to include all commitments made in the Terms of Reference and Terms of Reference review process.

8. Recognition of Lakes and Rivers Improvement Act Requirements and Potential Effects to Fish and Fish Habitat

To ensure that outstanding comments from the Ministry of Northern Development, Mines, Natural Resources and Forestry are addressed, the Terms of Reference will be amended to include the following:

8.1 Table 11.2.1 – Anticipated Provincial Approvals in the Terms of Reference is amended to include:

Lakes and Rivers Improvement Act approvals for proposed dewatering, waterbody realignments and removals, and pipelines.

8.2 Section 6.3.10.1 – Fish and Fish Habitat is amended to include:

First Mining Gold Corp. will consult with the Ministry of the Environment, Conservation and Parks as well as other government agencies on baseline studies to determine the geographic extent of studies and evaluations needed to assess the potential impact of the project on fish populations and management objectives. During the environmental assessment, First Mining Gold Corp. will conduct the appropriate studies to determine the availability and viability of proposed avoidance and mitigation strategies to address any potential impacts to fisheries including studies beyond the boundary of the northern basin of Springpole Lake.

9. Alternative methods for ore processing

To ensure that First Mining Gold Corp. will assess a reasonable range of alternative methods for ore-processing in its environmental assessment, the first paragraph of Section 5.2.4 – Ore Processing in the Terms of Reference is amended to read:

On-site processing is typical for large scale, low-grade operations such as this Undertaking. Off-site processing may have substantial environmental implications related to ore transport. A reasonable range of alternatives for ore processing will be considered and assessed in the environmental assessment, including alternatives for on-site and off-site ore processing facilities.

Dated the 8^th day of November, 2021 at Toronto.

Original signed by:

Minister of the Environment, Conservation and Parks
777 Bay Street, 5^th Floor
Toronto, Ontario
M7A 2J3

Voluntary agreement

This agreement is made in triplicate, between:

• The Minister of the Environment and Climate Change (the “Minister”)
• First Mining Gold Corp., its agents, successors and assigns (the “Proponent”)

Concerning:

The Proponent proposes to develop and operate the Springpole Gold Project located in the District of Kenora, approximately 110 kilometres (km) northeast of Red Lake. This undertaking involves the development, construction, operation, and closure of an open pit gold and silver mine and any associated facilities and ancillary activities. (the “Undertaking”)

Whereas section 3.0.1 of the Environmental Assessment Act states:

A person, other than a person referred to in clause 3(a), who carries out, proposes to carry out or is the owner or person having charge, management or control of an enterprise or activity or a proposal, plan or program in respect of an enterprise or activity may enter into a written agreement with the Minister to have this Act apply to the enterprise, activity, proposal, plan or program.

Whereas the Proponent is a person, other than a person referred to in clause 3(a) of the Environmental Assessment Act, who carries out, proposes to carry out or is the owner or person having charge, management or control of an enterprise or activity or a proposal, plan or program in respect of an enterprise or activity which is described above as the Undertaking.

Whereas the Proponent who proposes to engage in the Undertaking has requested that the Environmental Assessment Act apply to the Undertaking.

The Minister and the Proponent therefore agree that the Environmental Assessment Act applies to the Undertaking.

This agreement shall take effect from the date of the last signature below and shall continue indefinitely unless terminated by the agreement of both parties, in writing.

Executed by:

Original signed by:

Chris Ballard
Minister of the Environment and Climate Change
April 18, 2018

Jeff Swinoga
President and CEO
First Mining Gold Corp.
April 11, 2018

I have the authority to bind the Corporation.