Ministry Review of the Springpole Gold Project environmental assessment

Summary of our review

Who

First Mining Gold Corp. (FMG or proponent)

What

FMG is undertaking an EA of the Springpole Gold Project (the project). The project involves the development, construction, operation and closure of an open pit gold and silver mine and any associated facilities and ancillary activities.

The project would include several components, such as:

• open pit mine and related infrastructure
• dikes to isolate the open pit in a dewatered basin of Springpole Lake
• surficial soil stockpile
• ore stockpiles
• on-site ore process plant and process plant complex
• co-disposal facility for tailings and mine rock
• water management systems and treatment facilities
• treated effluent discharge
• fish habitat development area
• accommodations complex and other on-site buildings
• fuel and chemicals storage and management
• solid waste management (transport off-site)
• on-site domestic sewage management
• aggregate operations
• two-lane all-season gravel access road
• airstrip (co-located with the mine access road)
• 230-kilovolt overhead transmission line

When

The formal EA submission date was November 8, 2024. The comment period for the EA ended on January 17, 2025; however, extensions to that deadline were provided by the ministry on a case-by-case basis.

The EA was amended by FMG to address certain comments received during the EA review period, and an amended EA was submitted to the ministry on June 8, 2026.

Where

Approximately 110 kilometres (km) northeast of the Municipality of Red Lake, District of Kenora, Ontario.

Why

The purpose of the proposed project is to extract ore by open pit mining for processing on site to produce doré bars (semi-pure products of gold and silver that will be transported off site for eventual use) to meet global demands for gold and silver.

As part of the EA process, FMG considered and compared the benefits and effects of a range of alternative methods for carrying out the proposed project, per requirements of the approved amended terms of reference (ToR) for the EA.

Conclusions

The Ministry of the Environment, Conservation and Parks (ministry or MECP) concluded that FMG has prepared the amended EA in accordance with the approved amended ToR and the requirements of the EAA. The ministry is satisfied that FMG used a clear and logical decision-making process to determine how the preferred project was selected from the alternative methods considered.

The ministry is proposing conditions, supported by government technical reviewers that also responds to Indigenous community concerns, be imposed if the amended EA is approved, so that FMG carries out the project as outlined in the EA and so that Indigenous communities, the public, government agencies, and stakeholders with an interest in the proposed project would continue to be consulted. Other standard conditions of approval are also recommended for the implementation of the project.

1. Environmental assessment process

The EAA sets out a proponent-driven planning process designed to incorporate the consideration of the environment into decision-making by assessing the effects of a project on the environment. In Ontario, the EAA sets out the general contents for the preparation of a comprehensive EA, as well as the ministry’s evaluation process. For those projects subject to the EAA, approval under the EAA is required before those projects can proceed.

Proponents are required to address a wide range of potential effects on the natural, social, cultural, and economic environments to assist in the protection, conservation, and wise management of the environment. The EA helps decision-makers to determine, on the basis of the environmental effects, if a project should proceed, and if so, how the potential environmental effects can be managed.

An EA may:

• identify a problem or opportunity
• consider alternative ways of addressing the problem or opportunity
• evaluate the environmental effects of the alternatives
• select a preferred project from the alternatives

A proponent must consider actions to avoid, reduce and mitigate potential environmental effects. In preparing the EA, a proponent completes various studies and consults with interested stakeholders, including staff from government agencies, known as the government review team (GRT), the public and potentially affected Indigenous communities to evaluate the alternatives and select the preferred project or the preferred method to implement a project. If a project is approved, a proponent is required to monitor the project to demonstrate compliance with the standards, regulations and conditions of the EAA approval.

Pursuant to the transition provisions under the February 22, 2024, EAA amendments, if a proponent has given a ToR to the ministry under subsection 6(1) of the previous EAA in respect of a project and no decision has been made under the previous EAA, the project is now deemed to be a Part II.3 project (comprehensive EA project). As this is the case for this project, pursuant to these transition provisions, the proposed project is deemed to be a Part II.3 project.

The proposed project is subject to federal impact assessment requirements under the Canadian Environmental Assessment Act, 2012. The ministry is coordinating with the Impact Assessment Agency of Canada (IAAC) on provincial and federal requirements. This has allowed the proponent to submit one set of documentation to satisfy requirements under both acts.

1.1 Voluntary agreement

On April 18, 2018, the former Minister of the Environment and Climate Change (now referred to as the Minister of the Environment, Conservation and Parks) entered into a voluntary agreement with FMG to make the project subject to the requirements of the EAA.

The proposed project was not originally subject to comprehensive EA requirements (previously referred to as an individual EA); however, certain components of the project would have been subject to the requirements of a number of Class EA documents. It was recognized by FMG that the completion of a comprehensive EA would provide for a single, coordinated process that would improve transparency and clarity. For this and other reasons (for example, public interest and feedback received by FMG during early engagement), FMG requested that the project be made subject to a comprehensive EA.

1.2 Terms of reference

Completing the EA process involves 2 separate steps – the ToR and the EA. On November 8, 2021, the Minister of the Environment, Conservation and Parks (minister) approved the ToR for the project. The ToR sets out how FMG would prepare the EA, which includes:

• a description of the purpose and rationale for the proposed project
• how specific alternative methods would be identified and assessed for components of the proposed project
• evaluating potential environmental effects (both positive and negative)
• mitigation measures
• a consultation plan for obtaining input from Indigenous communities, GRT and the public

1.3 Environmental assessment

After receiving the minister’s approval for the ToR, FMG proceeded to prepare the EA for the proposed project, in accordance with the approved ToR and the requirements of the EAA.

FMG initiated consultation on the EA with a notice of commencement in fall 2021 and has continued to consult on the project, including during the preparation of the draft EA.

On November 8, 2024, FMG submitted the final EA to the ministry, commencing a 10-week EA submission comment period, which ended on January 17, 2025. In accordance with the requirements of Ontario Regulation 616/98: Deadlines, a 7-week formal review and comment period is required for the EA; however, given the comprehensive nature of the EA and the timing of the submission, FMG requested the longer review period. During the ministry-led EA comment period, the ministry received requests from Indigenous communities for extensions to the comment period deadline. The ministry considered all extension requests received and granted extensions pursuant to section 17.11(3) of the EAA to allow additional time, as needed, for the review of the EA. The ministry also accepted any comments submitted after the comment period deadline and allowed additional time for the issue resolution process stage to be completed prior to the publication of the ministry review.

The ministry received comments from the GRT, Indigenous communities and other interested persons about the EA, which were shared with FMG for response. As part of the issues resolution process, FMG provided additional information in its responses to comments, amended its EA to address certain comments, carried out further field work, submitted supplemental reports, and made additional commitments to address concerns that were raised. Meetings were held between the ministry, FMG, and the GRT and/or Indigenous communities, as needed, to try to resolve outstanding comments and address the concerns that were raised. This is discussed further in subsequent sections of this review.

The amended EA and a complete list of commitments were submitted to the ministry on June 8, 2026, and June 9, 2026, respectively.

Tables 1 to 3 in appendix B of this review provides all comments the ministry received on the final EA, responses by FMG and supplemental information submitted.

All comments sent to the ministry by the end of the ministry review comment period, FMGs and responses, including the amended EA and supplemental information submitted by FMG will be considered by the minister before a decision is made.

1.4 Ministry review

The EAA requires the ministry to prepare a review of the EA. The review sets out the ministry’s evaluation of the EA, including whether the EA has been prepared in accordance with the approved ToR, meets the requirements of the EAA, and whether the evaluation in the EA is sufficient to allow the minister to make a decision about the proposed project.

The ministry review comment period provides an opportunity for the public and Indigenous communities to see how their comments on the EA and the proposed project have been considered. Refer to section 5 of this review for next steps.

2. Purpose and description of the proposed project

FMG is proposing the Springpole Gold project which involves the development, construction, operation and closure of an open pit gold and silver mine and any associated and ancillary activities.

The purpose of the proposed project is to extract ore by open pit mining for processing on site to produce doré bars (semi-pure products of gold and silver that will be transported off site for eventual use) to meet global demands for gold and silver. According to the amended EA, the proposed project would provide a return on investment for the proponent while supporting local employment and the regional economy. Additional information about the purpose and the opportunity provided by the proposed project can be found in Section  1.3 of the amended EA Report. 

Located in the District of Kenora, approximately 110 km northeast of Red Lake, the proposed project would have a total footprint of approximately 1,365 hectares (ha) including the mine site area (867 ha), the mine access road and transmission line. The proposed location for the project is within Treaty 9 with portions of the potential transmission route within Treaty 3 boundaries. Reserve lands with the closest proximity to the Springpole site are Cat Lake First Nation (40 km away) and Slate Falls Nation (45 km away). Reserve lands of Lac Seul First Nation, Wabauskang First Nation, Mishkeegogamang First Nation, Pikangikum First Nation and Ojibway Nation of Saugeen are all within a 120 km to 170 km range from the Springpole site.

Please refer to figure 1.2-1, available in section 1.2 of the EA, for a map displaying the project’s location.

The project includes the following components and activities:

• open pit mine and related infrastructure
• east and west dikes to isolate the open pit in a dewatered basin of Springpole Lake
• surficial soil stockpile
• ore stockpiles
• on-site ore process plant and process plant complex
• co-disposal facility for tailings and mine rock
• water management and treatment facilities (i.e., ditches, berms, pumps, water storage ponds including a central water storage pond, effluent treatment plant)
• treated effluent discharge point
• fish habitat development area
• accommodations complex and other on-site buildings / infrastructure
• fuel and chemicals storage and management
• solid waste management (transport off-site)
• on-site domestic sewage management
• aggregate operations
• two-lane all-season gravel access road (approximately 18-kilometre (km))
• airstrip (approximately 1,000 metres (m), co-located with the mine access road)
• 230-kilovolt overhead transmission line (approximately 93 km, which would tie in to the existing Wataynikaneyap Line)

Please refer to figures 1.4-1 and 1.4-2, available in section 1.4 of the EA, for figures which depict the project components, including the proposed transmission line and access road.

FMG is planning to develop the proposed project over a 3-year construction period. Once operating, the open pit mine would have a mine life of approximately 10 years. Reclamation of disturbed areas will occur during operation, where feasible, and where doing so does not interfere with daily operations. Progressively reclaiming facilities and site features, where practicable, supports the timely restoration of disturbed area for ecological and other practical uses, in addition to reducing the amount of work and time required at final closure. Following the end of operations, final decommissioning and closure of the site would occur over a 5-year period. Post-closure environmental monitoring is expected following decommissioning and closure of the site.

The open pit is expected to be 321 m deep. To develop the main open pit, a basin of Springpole Lake would be isolated and dewatered in advance of mining operations. This process is explained in more detail in section 5.7.1 of the amended EA.

Over its lifetime, the mine is expected to generate approximately 101 million tonnes (Mt) of ore, 20.4 Mt of overburden, 292 Mt of mine rock and 78 million cubic metres of tailings. FMG is proposing to store tailings and mine rock in a co-disposal facility, which would consist of 2 cells. Non-acid generating (NAG) tailings would be co-managed with potentially acid generating (PAG) mine rock in the north cell of the co-disposal facility, while conventional PAG slurry tailings would be kept saturated in the south cell of the co-disposal facility to mitigate acid rock drainage potential. More information about water management and treatment facilities for the proposed project can be found in section 5.12 of the amended EA.

2.1 Preferred alternative

During the preparation of the voluntary agreement, FMG determined that the development of an open pit mine is the only viable alternative that will address the opportunity identified. In accordance with the approved ToR, and pursuant to section 17.4(2)(c) of the EAA, the EA was focused to exclude a detailed assessment of 'alternatives to' the project. The alternatives evaluated in the EA are:

• proceed with the project as planned
• delay the project until circumstances are more favourable
• the do nothing alternative

The preferred alternative was to proceed with the project as planned.

Section 4.3 of the amended EA discusses a comparison of proceeding with the project against the do nothing alternative to support identifying the advantages and disadvantages of proceeding with the project. FMG determined that the alternative of not proceeding with the project does not meet the purpose of the project or opportunity identified. However, as required by the approved ToR and requirements of the EAA, the do nothing alternative was carried forward to be used for comparison during the assessment of alternative methods for the proposed project, as it represents the existing baseline environmental conditions.

The alternative methods assessed for implementing individual project components included alternatives to dike locations, mine rock and tailings storage, water management, ore processing, power supply, access roads, waste management, and mine closure. The assessment was informed by engineering studies, baseline environmental data, and consultation with Indigenous communities, government agencies, and the public, and identified advantages and disadvantages to determine rankings (preferred, partially preferred, not preferred). Preferred alternatives were chosen to minimize environmental disturbance, reduce risk, and for technical and economic feasibility. Some preferred alternative methods include optimized dike locations to minimize fish habitat loss and construction impacts, co-disposal of mine rock and tailings in a centralized facility, and connection to the provincial power grid.

2.2 Summary of potential environmental effects and mitigation measures

The EA describes the existing environment that may be impacted by the effects of the project. Valued components (VC) were identified and assessed in the context of the natural, social, economic, cultural and bult environments. The full description of potential effects on each component is provided in section 6 of the amended EA, and the accompanying technical appendices.

Proposed mitigation measures are described in each section specific to the VC considered in section 6 of the amended EA. Construction and operation environmental management plans are outlined in section 5 of that document. Section 12 of the EA describes the follow-up and monitoring plan frameworks and FMG submitted a consolidated list of the commitments found throughout the EA, including those in section 12 and other sections. These mitigation and monitoring commitments are intended to prevent or reduce the potential negative effects to the environment during construction and operation activities associated with the proposed project.

A summary of key potential environmental effects and mitigation measures, as stated in the EA, is provided below:

Potential effects on water, fish and fish habitat: Impacts to water from changes to groundwater and surface water quantity and quality, including altered drainage patterns, temporary increases in suspended solids, and changes in water chemistry associated with dewatering, mine contact water, effluent discharge, and seepage from mine facilities. Potential effects on fish and fish habitat include habitat loss, alteration of aquatic habitat, and changes in water quality during construction, operations, and closure.

Mitigation measures:

• integrated site water management system to treat, and reuse contact water
• dedicated effluent treatment plant prior to discharge, in accordance with regulatory requirements
• design of stormwater and containment infrastructure to manage flood events and prevent uncontrolled discharges
• controlled dewatering and refilling of the open pit basin, with monitoring to maintain water levels within natural variation
• development of a fish habitat compensation and offsetting plan, including creation and enhancement of aquatic habitat
• ongoing surface water and groundwater monitoring, with adaptive management

Potential effects on wildlife and species at risk: Impacts to wildlife, including habitat loss, sensory disturbance, displacement and changes in movement patterns, changes to predator-prey dynamics and increased mortality risks. Effects are predicted for birds, bats and large mammals, including species at risk such as caribou, wolverine, eastern whip-poor-will, lesser yellowlegs, short-eared owl, little brown and northern myotis.

Mitigation measures:

• minimization of project footprint and use of existing disturbed areas where practicable
• timing restrictions on clearing and construction activities to avoid sensitive periods (for example, breeding or calving)
• development and implementation of wildlife and species at risk mitigation and monitoring plans
• progressive reclamation and habitat restoration to re-establish terrestrial habitat
• ongoing wildlife monitoring to verify effects and effectiveness of mitigation, with adaptive management

Potential effects on vegetation and wetlands: Impacts to vegetation and wetlands, such as vegetation loss, soil erosion and compaction and groundwater flow changes. Disturbances from the removal of vegetation and wetlands for mine infrastructure, access roads, transmission line corridors, and ancillary facilities may result in temporary or permanent loss of plant communities, including wetlands, and changes to local drainage and soil stability.

Mitigation measures:

• avoidance of sensitive vegetation communities where feasible through project siting and design
• salvage and storage of organic soils and overburden for use in reclamation
• progressive reclamation and revegetation using native species to restore disturbed areas
• wetland avoidance, minimization, and compensation measures where disturbance cannot be avoided
• monitoring of revegetation success and corrective actions if needed

Potential effects on air quality and noise: Impacts to atmospheric conditions, including emissions, dust, noise and vibrations during the site preparation, construction, and operation of the project may result in localized air quality and noise effects. Air quality effects, including dust and emissions, are expected to be greatest during peak operations (years 3 to 4), while noise effects may occur throughout all project phases, with open pit blasting representing the primary noise source during operations.

Mitigation measures:

• implementation of a dust management plan, including water spraying, dust suppressants, speed limits, and progressive reclamation
• use of modern, well-maintained equipment and emission control technologies
• optimization of project design, including a compact layout and reduced haul distances
• controlled blasting practices and avoidance of blasting under unfavorable meteorological conditions
• ongoing air quality monitoring to verify compliance

Potential effects on land and resource use, and infrastructure: Impact to land and resource use and local infrastructure and services, including forestry, tourism operations, outfitting, trapping, and mineral exploration, primarily through land disturbance, altered access, increased traffic, and sensory disturbance. Outdoor recreation activities such as fishing, hunting, boating, and camping may experience disruptions in access during construction and operations. Increased workforce presence and project-related traffic may also place additional demands on local and regional infrastructure and services, including roads, waste management facilities, emergency services, and community services, particularly during peak construction periods.

Mitigation measures:

• project design and timing management to minimize overlap and interference with commercial and recreational land uses and operations
• ongoing engagement and communication with commercial operators and land users to identify concerns and implement practical mitigation measures
• traffic management and road safety measures, including worker transportation strategies and controlled site access to reduce effects on public road infrastructure
• coordination with municipal and regional service providers to manage demands on infrastructure and services, including emergency response capacity
• progressive reclamation and restoration of disturbed areas following closure
• monitoring and adaptive management to confirm effects and refine mitigation measures as needed

Potential effects on traditional land and resource use: Impacts to traditional land and resource use, including hunting, fishing, trapping, plant harvesting, travel, and the use of culturally and spiritually important areas, primarily due to land disturbance, altered access, and sensory disturbance. Potential effects also include the disturbance or alteration of archaeological sites and cultural heritage landscapes, particularly in areas associated with waterbodies and historic travel routes.

Mitigation measures:

• project design refinements to avoid or minimize disturbance to areas of known traditional land use, archaeological resources, and cultural heritage features where feasible
• ongoing engagement and consultation with Indigenous communities, including the incorporation of Indigenous knowledge and traditional land and resource use information into project planning and mitigation
• avoidance, protection, or management measures for identified archaeological sites, built heritage resources, and cultural heritage landscapes
• implementation of chance find protocols to make sure that any previously unidentified archaeological or cultural heritage resources encountered during construction are appropriately assessed and managed
• monitoring and adaptive management, including Indigenous participation, to verify effects and refine mitigation measures over the life of the project

Potential positive effects of the project include:

• increased employment opportunities, particularly for Indigenous communities
• increased education, training and skills development, and learning opportunities
• increased local and regional labour income and business opportunities through mine-related employment, contributing to broader local and provincial economic growth, including higher employment and government revenues
• infrastructure enhancements beneficial to the region including an all-season access road, transmission line and airstrip, improving the movement of people, goods and services
• contracting opportunities for Indigenous and non-Indigenous businesses
• advances critical mineral development supporting access to and extraction of valuable mineral resources (for example, gold and silver), contributing to economic growth and supply of valuable commodities

A summary of the overall advantages and disadvantages of the project is provided in section 15 of the EA. The EA concludes that the effects are acceptable, based on an assessment against all of the criteria and with the application of mitigation measures.

3. Results of the ministry review

The ministry review provides an analysis of the EA. The ministry review is not intended to summarize nor present the information found in the EA. For information on the proponent’s decision-making process, refer to the EA itself. The EA and supporting documentation outline the EA planning process and demonstrate how a proponent selected the preferred project and made the final decision.

3.1 Conformance with ToR and EAA

3.1.1 Ministry analysis

Appendix A provides the ministry’s analysis of the EA against the requirements of the approved ToR and the EAA. It documents how each requirement has been addressed, identifies any gaps or follow-up needs, and describes how these were addressed by FMG.

In response to comments received from government reviewers and Indigenous communities, FMG made amendments to the EA. These updates clarified methodologies, strengthened the supporting rationale, addressed inconsistencies, and incorporated additional information and commitments identified through the review and issues resolution process. The ministry concluded that the amended EA is consistent with the approved ToR and meets the requirements of the EAA.

While the ministry is generally satisfied with the amended EA, it identified areas requiring additional information or future work to fully support transitioning to permitting, including hydrogeological studies, fish habitat calculations, species at risk mitigation and monitoring plans, archaeological assessments, and continued consultation with Indigenous communities. Additional information requirements are proposed to be addressed through the proponent’s commitments and conditions of approval under consideration by the ministry. Refer to section 3.1.2 of this ministry review for further details.

Indigenous community consultation

On April 25, 2018, the ministry delegated the procedural aspects of consultation to FMG for the project. A list of Indigenous communities identified as potentially affected and/or interested in the proposed project that should be consulted for the EA process was provided to FMG. The list included:

• Cat Lake First Nation
• Lac Seul First Nation
• Slate Falls Nation
• Wabauskang First Nation
• Mishkeegogamang First Nation
• Ojibway Nation of Saugeen
• Métis Nation of Ontario Northwest Métis Council / Region 1 Consultation Committee

As indicated in the delegation letter, FMG is responsible for procedural aspects of consultation such as providing timely information to Indigenous communities about the project; responding to concerns raised; adjusting its consultation planning, project design or mitigation measures as appropriate; and keeping a record of consultation.

Summary of proponent’s consultation activities

FMG summarized its consultation activities in section 2.0 of the amended EA. FMG also provides summaries of the “influence of consultation with Indigenous communities, government and the public” in various subsections of the amended EA, where applicable. 

A record of consultation documenting consultation up to the end of June 2024 was submitted to the ministry with the final EA. At the ministry’s request, additional consultation records were submitted by FMG in June 2025, January 2026, and May 13, 2026, to supplement the record of consultation for the EA and to describe consultation up to the end of 2025.

According to the amended EA, the methods and tools that FMG used to consult during the preparation of the EA included:

• circulation of documents to the GRT, Indigenous communities and interested stakeholders for review and comment (for example, baseline studies, technical workplans, preliminary alternative assessment tables, draft EA and other information about the project and potential effects)
• use of FMGs project website to provide access to EA materials, videos and factsheets, and to facilitate public reviews of documents
• meetings with the GRT, Indigenous communities (including Chiefs and Councils), and interested stakeholders
• community information sessions, webinars and workshops to present project information and provide opportunities for input and questions
• notices of public information sessions including in local newspapers, online and via radio announcements
• circulation of project updates (for example, fact sheets, newsletters, community bulletins)
• use of plain language and translated summaries, where possible, so feedback could be provided by non-technical reviewers
• engagement of Indigenous communities in environmental baseline field studies
• development / support of traditional knowledge and traditional land use studies and information-sharing with Indigenous communities
• targeted mailouts to distribute flyers, letters and project information to residents, landowners and local land users in the project area
• the opening of a local project office in the Municipality of Sioux Lookout to increase local awareness of the project and allow in-person meetings, questions and comments
• use of social media to provide updates and information about the project and opportunities for engagement throughout the EA process
• establishing a community relations email to provide an additional forum for interested parties to contact FMG about the project
• contact lists created and maintained by FMG
• participation in public events to increase public awareness about the project and provide opportunities for questions and comments
• other GRT, Indigenous community and/or stakeholder specific communications

Following submission of the EA to the ministry, FMG continued to consult with Indigenous communities. Additional consultation records for the period of January 2025 to December 2025 were submitted to the ministry on May 13, 2026.

The ministry provided Indigenous communities, the GRT, interested stakeholders and the public an opportunity to review the EA and the project, and to submit their comments to the ministry during the 10-week ministry-led EA submission comment period. Extensions to the 10-week comment period were granted, by request, to allow additional time for the review of the EA to those who needed it. Extension requests were submitted by Mishkeegogamang First Nation, Ojibway Nation of Saugeen, Slate Falls Nation, Cat Lake First Nation and Lac Seul First Nation and the ministry accepted comments submitted after the comment period deadline. The ministry worked with the proponent to resolve outstanding issues through an iterative process, leading to the submission of an amended EA before the ministry review was published.

3.1.2 Comments received

All comments received from the GRT, public and Indigenous communities and the proponent’s responses are included in appendix B of this ministry review. A summary of the key issues raised on the final EA, responses from FMG and the ministry’s analysis, including proposed conditions under consideration by the ministry, are described in this section of the ministry review. All commitments made by FMG during the EA process can be found on the proponent’s website and these commitments form part of the EA.

Government review team comments

The GRT reviewed the EA to confirm that the information and conclusions of the EA were valid. During the EA submission comment period, the following provincial ministries provided comments:

• Ministry of Citizenship and Multiculturalism (MCM)
• Ministry of Energy and Mines (MEM)
• MECP
• Ministry of Indigenous Affairs and First Nations Economic Reconciliation (IAFNER)
• Ministry of Natural Resources (MNR)
• Ministry of Northern Economic Development and Growth (MNEDG)
• Ministry of Tourism, Culture and Gaming (MTCG)

All comments received from the GRT, and the proponent’s responses are included in appendix B of this ministry review. Key issues identified by the GRT relate to hydrogeology and water quality, caribou, fish and fish habitat, and archaeology and cultural heritage. Additional details are provided in section 3.1.3 of this ministry review.

Public and stakeholder comments

The ministry received 32 letters of support for the project, citing strong benefits for local communities, including new roads and energy infrastructure, job creation and business opportunities, training and apprenticeships for local workers, and increased regional economic strength and resilience.

Concerns were raised by local outfitters regarding potential impacts to outfitting camps, particularly the proximity of the proposed transmission line, along with a request for a minor route adjustment.

FMG advised that no visual, noise, or physical impacts to outfitting camps are anticipated from the transmission line. Construction access will be strictly controlled, access roads will be decommissioned following construction, and natural regeneration is expected to limit future access. FMG will continue to work with the outfitter and the MNR should concerns arise.

FMG also advised that the transmission line route was designed to minimize length, reduce environmental effects, and respect Indigenous land use. The route follows regulatory setbacks and has been optimized to use existing corridors where possible. FMG will continue to explore further route optimization and maintain engagement through the engineering and permitting phases.

All comments received from the public and stakeholders, and the proponent’s responses are included in appendix B of this ministry review.

Indigenous community comments

The record of consultation documents all the consultation with Indigenous communities and will be reviewed and considered by the ministry when assessing the Crown's duty to consult before the minister, with the approval of the Lieutenant Governor in Council, makes a decision about the proposed project.

Appendix C of this review provides a summary of the consultation undertaken, including Indigenous consultation.

Six Indigenous communities submitted comments on the final EA including:

• Cat Lake First Nation
• Lac Seul First Nation
• Slate Falls Nation
• Wabauskang First Nation
• Mishkeegogamang First Nation
• Ojibway Nation of Saugeen
• Métis Nation of Ontario Northwest Métis Council / Region 1 Consultation Committee

All comments received from Indigenous communities and the proponent's responses are included in appendix B of this ministry review. Key issues identified by Indigenous communities relate to hydrogeology and water quality, co-disposal facility and risk management, caribou, fish and fish habitat, archaeology and cultural heritage, Indigenous knowledge, alternatives assessment, and meaningful consultation. Additional details are provided in section 3.1.3 of this ministry review.

On June 16, 2026, Cat Lake First Nation and Lac Seul First Nation announced via a news release that they do not object to the environmental assessment approval of the project subject to the application of 35 conditions that were accepted by FMG. These conditions were informed by the Anishnaabe-Led Impact Assessment completed by the Cat Lake Nation and Lac Seul First Nation, and relate to environmental and water protections, cultural and socio-economic safeguards, economic participation and community healing. They further noted in the news release that the conditions would form part of a binding agreement with FMG.

3.1.3 Key issues raised on the EA

The issues raised on the EA by the GRT and Indigenous communities are outlined below. The identification of issues is followed by an explanation of how they were addressed by FMG, as well as the ministry’s analysis of the issues, including proposed conditions under consideration by the ministry.

Hydrogeology and water quality

The ministry’s Northern Region Technical Support Section raised concerns over identified gaps in hydrogeological characterization, subsurface flow pathways and shoreline discharge creating uncertainty in predicted groundwater transport, shoreline discharge behavior, and seepage related loading to Springpole Lake and Birch Lake. Further hydrogeological investigations and improved characterization of seepage pathways and groundwater interactions will be required to support an informed assessment of groundwater-related environmental risk associated with the co disposal facility prior to permitting.

Indigenous communities:

Cat Lake First Nation, Lac Seul First Nation, Slate Falls Nation, Wabauskang First Nation, Ojibway Nation of Saugeen and Northwest Métis Council identified potential risks associated with effluent discharge and seepage from the co-disposal facility, sharing concern that it could adversely affect water quality, including drinking water and aquatic ecosystems, with permanent impacts on treaty rights, traditional land use and connection to local waterways.

Proponent response:

FMG completed hydrogeological field work and supplemental reports to address comments received. These reports are included in appendix B.

FMG has committed to a groundwater and surface water monitoring program with sampling locations around the co-disposal facility, and as indicated by FMG, is expected to include effluent, peripheral and receiving water quality monitoring. Specific monitoring details and requirements, including methods, reporting and remedial actions will be formalized by the ministry through the terms and conditions of provincial approvals.

FMG has also committed to comparing water monitoring results against federal and provincial standards, with exceedances to be reported to the ministry, shared with Indigenous communities and investigated and addressed through adaptive management.

FMG is prepared to work with the ministry on planning next steps to support subsequent permitting.

Ministry analysis:

The ministry reviewed FMGs hydrogeological field work and supplemental reports and identified additional work that will be needed to support permitting.

The ministry may propose, for the minister’s consideration, a condition of approval that would require the proponent to complete additional hydrogeological investigations at the co-disposal facility prior to Environmental Compliance Approval (ECA) permitting to supplement information collected to date. This condition is intended to confirm that uncertainties are appropriately addressed through an understanding of subsurface conditions, verification through field investigations, assessment of contaminant transport pathways, and implementation of appropriate monitoring and contingency programs. These studies should be compiled into a report and shared with Indigenous communities for review and consultation prior to submission of the ECA applications. The report, together with documentation of consultation, should be submitted as part of the ECA applications.

Co-disposal facility and risk management

Indigenous communities:

Cat Lake First Nation, Lac Seul First Nation, Slate Falls Nation, Wabauskang First Nation, Ojibway Nation of Saugeen and Northwest Métis Council have indicated that the proximity of the co-disposal facility to Birch Lake and Springpole Lake presents a risk to groundwater and surface water quality, particularly in the event of a facility failure. Indigenous communities noted the constraints that the facility’s proximity to water has on the effectiveness of any adaptive management approaches to mitigate potential issues and effectively manage risk. Increased monitoring in the vicinity of these waterbodies is necessary to support effective risk management and early detection of potential issues.

Proponent response:

FMG notes that section 4.6 of the amended EA describes the assessment of co-disposal facility location alternatives, identifying a preferred option based on an evaluation of environmental, technical and economic considerations. FMG indicates that the preferred location balances these factors as the proximity to the project site increases operational efficiencies and therefore lowers transportation distance, reduces costs, and decreases air and greenhouse gas emissions. The assessment found that this alternative had the least impact on wetlands and is not expected to adversely affect wetland connectivity. Amendments to the EA were made to improve the clarity and transparency of the alternative assessment for the co-disposal facility.

FMG has committed to establishing environmental committees with opportunities for Indigenous participation throughout the construction, operation, and closure phases of the project. Committees will support ongoing engagement, integration of Indigenous knowledge, and collaborative review of environmental monitoring, management plans, and adaptive mitigation measures.  

FMG has also committed to develop and implement measures to support safe operations and risk management, including procedures, training, expert review of tailings and water management infrastructure, and will collaboratively develop an emergency response plan prior to construction, to be refined through the permitting process, for prompt protection of the environment, including areas used for traditional land use.

Ministry analysis:

The ministry is generally satisfied with the efforts made by the proponent to address comments received regarding the co-disposal facility and risk management. Detailed investigations and analysis will be undertaken during closure planning and the permitting phase. Water quantity monitoring requirements will be established through provincial approvals including ECAs and permits to take water.

The ministry may propose, for the minister’s consideration, a condition of approval to reinforce the proponent’s commitment to establish environmental committees with interested Indigenous communities. The environmental committees would provide a forum for ongoing consultation and engagement during construction, operation, and decommissioning of the project on areas of interest to each Indigenous community. The proponent would be required to bring forward all relevant environmental management and monitoring plans, reports, permit and approval applications, and related documentation to the environmental committees for review and consultation. The environmental committees would provide a forum to review plans and reports; share and assess environmental information (including advance notice of activities, and information related to the environmental safety and co-disposal facility integrity); validate EA predictions and mitigation effectiveness; support adaptive management; incorporate Indigenous knowledge and community monitoring; and develop communications to address environmental quality and support continued land use.

The ministry may also propose, for the Minister’s consideration, a condition of approval that would require the proponent to develop an emergency response plan prior to construction and to refine it during the permitting process, construction, operation, and decommissioning, incorporating opportunities for collaboration with Indigenous communities. The purpose of the emergency response plan will be to facilitate prompt and efficient response actions for addressing emergencies; identify responsibilities and reporting procedures for emergencies; provide protocols to follow should an emergency occur; and provide information on available resources, facilities and trained personal in the event of an emergency.

Caribou

The ministry’s Species at Risk Branch identified concerns regarding potential impacts to species at risk that were protected under Ontario’s former Endangered Species Act, 2007 (ESA).  On March  30, 2026, the Species Conservation Act, 2025 (SCA) and several implementing regulations came into force and the ESA was repealed. Boreal Caribou are listed on the Protected Species in Ontario List under the SCA. As such, any person engaging an activity that results or is likely to result in killing or harming Boreal Caribou or damaging or destroying its habitat must register before proceeding, unless the activity is prescribed as requiring a permit or is excepted from the requirements to register or obtain a permit.

Significant consideration has been given to boreal caribou, given the importance of the established nursery habitat in that area of Birch-Springpole Lakes which supports successful calving and rearing for multiple individuals. The ministry noted that FMGs conclusion of limited or insignificant effects relies substantially on mitigation, offsetting, and monitoring measures that are not yet finalized, and requested more detailed mitigation plans, including specific caribou habitat offsetting measures.

Indigenous communities:

Cat Lake First Nation, Lac Seul First Nation, Slate Falls Nation, Mishkeegogamang First Nation, Ojibway Nation of Saugeen, and the Northwest Métis Council raised concerns regarding boreal caribou habitat loss and associated long-term disturbance that may result from the project, increasing predator access and sensory disruption. The concern expressed was that if these impacts go unmitigated, they could create a risk of population decline and potential risk of loss of caribou from the local area (for example, within 10 km of the mine site).

Proponent response:

FMG completed a supplementary technical memorandum that provided additional information on proposed mitigation, restoration, and monitoring plans to address potential impacts on boreal caribou. This memorandum is included in appendix B of this ministry review.

FMG has committed to the following actions to mitigate adverse effects on boreal caribou:

• minimize the disturbance footprint and contribution to cumulative disturbance and habitat loss at the range scale
• minimize habitat changes and fragmentation to maintain the function and connectivity of sub range habitat features
• minimize the density of linear features to avoid increases in predator efficiency and access
• reduce habitat and sensory disturbance near high use areas, including calving, nursery, and seasonal concentration areas
• avoid activities that increase boreal caribou mortality risk, including vehicle collisions and opportunities for hunting

FMG also noted the EA incorporates progressive, enhanced on site restoration designed to re-establish mature coniferous refuge habitat and avoid vegetation types that could locally increase moose presence and predation risk to boreal caribou from shared predators (wolf, bear) that could periodically or seasonally occur and use current or future refuge habitat.

Ministry analysis:

The ministry reviewed FMGs supplementary technical memorandum and the ministry acknowledges the difficulty of developing detailed, species specific mitigation and offsetting plans prior to construction and operational planning. These plans will continue to be important as FMGs conclusion that impacts to species at risk and their habitats will be insignificant, relies on the future development of these plans.

The ministry may propose, for the minister’s consideration, a condition of approval that would require the proponent to develop detailed mitigation, offsetting, and monitoring plans for all species at risk. These plans would be developed in consultation with Indigenous communities through environmental committees or other means, established with each Indigenous community, if interested, and the ministry, prior to the commencement of activities that result or are likely to result in killing or harming boreal caribou or damaging or destroying its habitat at each phase of the project (early works, construction, operation and decommissioning) at the project site.

Fish and fish habitat

MNR identified potential effects on fish and fish habitat including habitat loss, alteration of aquatic habitat and changes in water quality during construction, operations and closure.

MNR expressed concerns about fish habitat availability associated with the removal of optimal habitat in Springpole Lake, including the ability of lake trout populations to persist following the loss of optimal habitat within the deep North Basin of Springpole Lake.

MNR also raised concerns about the location of the open pit and its proximity to Birch Lake, with only a minimal (approximately 20 metre) buffer.  The EA had limited information to assess whether this buffer is adequate from a geotechnical and hydrological perspective. Limited information was provided on whether the buffer materials and underlying bedrock conditions could maintain stable pit slopes, limit seepage, and prevent groundwater interaction with Birch Lake or the development of a hydraulic connection under anticipated conditions (for example, blasting, dewatering, and variable pore pressures). Such interactions could alter lake water levels and hydrology, potentially affecting fish habitat through changes to shoreline conditions and the overall stability of the Birch Lake aquatic ecosystem.

Indigenous communities:

Cat Lake First Naton, Lac Seul First Nation, Slate Falls Nation, Mishkeegogamang First Nation, Ojibway Nation of Saugeen and Northwest Métis Council expressed concern about the scale of fish habitat loss and the broader implications for aquatic ecosystems, noting that areas of habitat are expected to be affected and that avoidance measures appear limited. Concerns extended to fish removal and relocation, with requests from Indigenous communities for clearer methods, alignment with spawning periods and monitoring to confirm effectiveness.

These communities highlighted concerns about water quality risks and potential impacts on fish habitat particularly with respect to long-term and post-closure outcomes. Indigenous communities indicated low confidence in closure and long-term results, with concerns that the proposed plans lack measurable criteria and evidence that fish habitat can be successfully restored or maintained over time.

These communities indicated a lack of meaningful Indigenous participation in planning and decision-making phases, particularly related to the fish habitat and offset compensation plan and expressed the importance of robust monitoring and adaptive management, including Indigenous-led programs. Indigenous communities called for more transparent and collaborative processes with stronger integration of Indigenous involvement in assessing impacts and designing mitigation measures.

Proponent response:

FMG provided a technical memorandum with additional information on dissolved oxygen and temperature conditions in Springpole Lake, including monitoring and adaptive management, in response to comments received MNR regarding fish and fish habitat. This memorandum is included in appendix B.

Additionally, FMG indicates they will implement a follow-up and monitoring plan to verify the construction, performance, and effectiveness of fish habitat offsetting and compensation measures. Monitoring will be conducted in accordance with regulatory requirements and will address key indicators such as water quality, benthic invertebrates, and fish populations, including species presence. FMG states that sampling stations will be located and developed in consultation with regulatory agencies and Indigenous communities. FMG will also complete additional quantitative analyses of fish habitat under both impact and restoration scenarios.

FMG has committed to offer continued engagement with Indigenous communities on the fish habitat and offset compensation plan, throughout the permitting process, including opportunities for review and input. FMG also committed to the involvement of providing the erosion and sediment control plan to Indigenous communities for review prior to construction. FMG stated that they will continue to work with regulators throughout the EA process, and during permitting to demonstrate that potential effects to fish and fish habitat are addressed.

Ministry analysis:

MNR has identified the need for additional information on fish and fish habitat, during the permitting process, under the Lakes and Rivers Improvement Act (LRIA). The additional information that FMG has committed to providing includes final calculations of the total volumes of optimal and usable habitat distribution, as well as the total optimal and usable habitat that will remain in Springpole Lake during mine operation.

To further support MNRs findings, the ministry may propose a condition of approval, for the minister’s consideration, that will require FMG to provide detailed information demonstrating that the proposed aeration contingency measure will be effective and feasible to implement, as part of the LRIA application process. Aeration refers to the addition of oxygen to the water (example, by pumping air) to help maintain suitable water quality conditions for fish in the remaining deep basins of Springpole Lake. This measure is intended to protect lake trout, which require cold, well-oxygenated water to survive. FMGs description of how the aeration system will function in practice will be used to provide reassurance that the long-term lake trout population productivity can be maintained.

The ministry may propose a condition of approval, for the minister’s consideration, that would require engagement with Indigenous communities on fish habitat monitoring and offset compensation plan continue through environmental committees or other means, established with each Indigenous community, if interested.

The ministry may also propose a condition of approval, for the minister’s consideration, that would require FMG to provide additional assessment of the potential seepage or outflow risk between the open pit and Birch Lake, and where such risk exists, to develop and implement a mitigation and monitoring plan to address impacts on Birch Lake water levels.

Archaeology and cultural heritage

Archaeology resources (terrestrial and marine):

MCM raised concerns related to the archaeological assessments (AA) undertaken for the project. MCM indicated that the work may have been completed in a segmented manner and recommended that a comprehensive stage 1 AA be carried out for the entire project area by a licensed archaeologist as early as possible during detailed design and prior to any ground disturbing activities.

MCM advised MECP that the proposed in-water works, including effluent discharge and construction and dewatering activities in Springpole Lake may result in impacts to marine archaeological resources. MCM recommended that these project components be screened using the ministry’s criteria for evaluating marine archaeological potential and further, should it be determined that the project areas meet the criteria for marine archaeological potential, that a marine AA be carried out by a licensed archaeologist as early as possible during detailed design and prior to any ground disturbances for the dewatering of the open pit basin of Springpole Lake (including the construction of the two dikes) and for the installation of the effluent treatment plant discharge line.

Indigenous communities:

Cat Lake First Naton, Lac Seul First Nation and Slate Falls Nation have expressed concerns related to the sufficiency of technical cultural heritage studies undertaken for the project, as they relate to potential impacts to archaeological resources and cultural heritage landscapes. These communities have raised concerns related to the AAs undertaken for the project including the limited scope of fieldwork, limited extent of background research, lack of opportunity to provide input, and insufficient assessment of areas of archaeological potential. These communities have also expressed concerns related to the assessment of impacts to marine archaeological resources.
 

Marten portage (CHR-1)

The Marten Portage was determined to meet the criteria for a cultural heritage value or interest under the Ontario Heritage Act. The cultural heritage evaluation report prepared for the portage route recommended that a heritage impact assessment (HIA) be prepared for CHR-1. MCM recommended that the HIA be completed by a qualified professional as early as possible during detailed design and prior to any ground disturbing activities in that area. Furthermore, MCM recommended that the report should be provided to the ministry and to Indigenous communities, as well as any other interested parties, for review and comment. Any feedback should be incorporated into the report.

Indigenous communities:

Cat Lake First Nation, Lac Seul First Nation and Slate Falls Nation have raised concerns related to the proposed removal of the Marten portage, a cultural heritage landscape (CHR-1) which was determined to meet the criteria for cultural heritage value or interest under the Ontario Heritage Act. The cultural heritage evaluation report prepared for the portage route recommended that a HIA be prepared for CHR-1.

Proponent response:

In response to the comments received, FMG amended the EA to improve clarity and incorporate corrections identified by MCM.

FMG has committed to engaging a qualified person to prepare a heritage impact assessment (HIA) for the Marten portage as early as possible during detailed design prior to any ground disturbing activities in that area and to follow the recommendations of the HIA. The HIA will be submitted for review and comment to MCM, Indigenous communities and any interested parties. In addition, FMG has committed to establishing an alternate portage route to maintain access between Springpole Lake and Birch Lake until post closure when portage routes can be re-established.

FMG has committed to undertaking a stage 2 AA of the transmission line route (areas recommended in the stage 1 AA) prior to ground disturbing activities and will follow the resulting recommendations of the assessment, while providing opportunities for engagement by Indigenous communities during the stage 2 AA. In addition, FMG has committed to the implementation of a chance find procedure and to follow the requirements of the Ontario Heritage Act, should previously undocumented archaeological resources be discovered during construction or operation. FMG indicates this will be supported by employee training to recognize and appropriately respond to the discovery of previously undocumented archaeological resources.

FMG has committed to carry out a marine AA by a licensed archaeologist as early as possible during detailed design and prior to any ground disturbing activities associated with the dewatering of the open pit basin of Springpole Lake (including the construction of the two dikes) or installation of the effluent discharge line.

Ministry analysis:

The ministry is generally satisfied with the efforts made by the proponent to address comments received regarding archaeology and cultural heritage. However, to address comments from Indigenous communities as well as MCM, the ministry may propose, for the minister’s consideration, a condition of approval for a comprehensive stage 1 AA for the entire project area to be compiled by a licensed archaeologist as early as possible during detailed design and prior to any ground disturbing activities. The licensed archaeologist would be required to engage Indigenous communities during the stage 1 AA and provide the AA report for review and comment, and to incorporate any feedback into the report. Indigenous engagement must occur before the report is submitted to MCM for review.   

The ministry may also propose, for the minister’s consideration, a condition of approval that would require the HIA for the Marten portage to be undertaken by a qualified professional as early as possible during detailed design and prior to any ground disturbing activities in that area. The condition would require that the HIA be provided to MCM, Indigenous communities, and any other interested parties for their review and comment, and that any feedback be incorporated into the report. 

The ministry may also propose, for the minister’s consideration, a condition of approval that the effluent discharge location and the project area for the 2 dikes/dewatering be screened using MCMs criteria for evaluating marine archaeological potential checklist. If it is determined that the project areas meet the criteria for marine archaeological potential, a marine AA shall be undertaken by a licensed marine archaeologist as early as possible during detailed design and prior to any ground disturbing activities for the dewatering of the open pit basin of Springpole Lake (including the construction of the town dikes) and for the installation of the effluent treatment plant discharge line. The licensed archaeologist would be required to consult with Indigenous communities in the process, and to provide them with the marine AA for their review and comment and incorporate any feedback into the report.

Indigenous knowledge

Indigenous communities:

Cat Lake First Naton, Lac Seul First Nation, Slate Falls Nation, Mishkeegogamang First Nation, Ojibway Nation of Saugeen and Northwest Métis Council raised concerns that Indigenous knowledge is either absent from, or not meaningfully integrated int, the EA as well as broader concerns regarding potential impacts on Aboriginal and treaty rights.

Proponent response:

FMG indicated they reviewed Indigenous knowledge studies shared by Indigenous communities throughout the EA process and incorporated relevant information into the EA, consistent with how the information was provided and permitted to be used. The EA integrates this information across valued components and assessment sections, demonstrating where Indigenous knowledge informed the analysis and conclusions.

FMG provided specific examples of how Indigenous Knowledge was considered in the EA, include the including:

• changes to baseline studies including additional water monitoring locations 75 km downstream, additional study to determine fish presence, additional study to assess baseline ecological health conditions, additional study on birds and habitat of importance, additional study and investigation on groundwater including hydraulic conductivity, and several additional geochemical tests
• implementation of a caribou telemetry program to collar and collect data from 50 individual caribou
• supplemental analysis of geochemistry, groundwater, surface water and air quality to further demonstrate the effectiveness of environmental protection measures
• the addition of key commitments related to country foods monitoring, environmental monitoring roles, and committees
• the development of the mine access road management plan including the provision for a gatehouse to monitor road usage and provide access to Indigenous land users and the use of signage along the Wenasaga Road advising of the road ahead being closed to public use
• expedited refilling of the open pit basin to restore fish habitat in a timely manner at closure
• development of the fish habitat offsetting measures
• the relocation of the treated effluent discharge location and associated waterline to a location closer to the mine site to avoid discharge directly to the southeast arm of Springpole Lake
• routing of the transmission line whereby 57 km of the transmission line was relocated
• development of the water management and treatment system including perimeter contact water and seepage collection ditching, containment ponds and water treatment technology effective for removal of metals and other parameters at a scale suitable for the project
• co-located the mine access road with the transmission line to reduce linear corridors
• consideration of plant and wildlife species of interest to Indigenous communities in the assessment (for example, blueberry, wild rice, moose)

FMG also provided support for some Indigenous communities to carry out their own consultation processes on the project, which were community-led and carried out by the communities and their advisors with the funding from FMG.

Ministry analysis:

The ministry acknowledges that Indigenous knowledge was incorporated into the EA through ongoing dialogue, collaborative engagement, and iterative review opportunities. Indigenous communities were supported with funding and opportunities to conduct their own Indigenous knowledge studies and shared non-confidential information with the proponent, which informed baseline study methodologies, valued components, criteria and indicators, alternatives assessment, mitigation measures, monitoring plans, and broader project planning decisions. Engagement methods such as workshops, community information sessions, and participation in baseline field studies and environmental monitoring, which resulted in project modifications and enhanced environmental protections that were influenced by Indigenous perspectives and aligned with community priorities.

The ministry is generally satisfied that the efforts to collect Indigenous knowledge and input from Indigenous communities to assess potential impacts of the project on Aboriginal and treaty rights were completed in accordance with the ToR and EAA requirements. To support ongoing consultation with Indigenous communities, the ministry may propose, for the minister’s consideration, a condition of approval that would require the proponent to meet with interested Indigenous communities through an environmental committee before submitting final permit or approval applications and discuss how Indigenous knowledge will be considered in each application. Should the minister choose to approve the project and include this condition, the proponent would be required to consider and, where appropriate, address community comments by revising applications prior to submission. In addition, following engagement, the proponent would also have to provide written explanations outlining how Indigenous input and Indigenous knowledge were incorporated into the final permitting materials.

Alternatives assessment and meaningful consultation

Indigenous communities:

Cat Lake First Naton, Lac Seul First Nation and Slate Falls Nation raised concerns that they were not meaningfully consulted on the alternatives assessment and on key items such as siting decisions about critical project components. These Indigenous communities also raised concerns about providing free, prior and informed consent before decisions are made.

These communities also expressed concerns regarding uncertainty about the conditions or mechanisms that would allow for the relocation or modification of key project components following EA approval and expressed a desire for ongoing, meaningful consultation following the EA decision, including during the permitting process.

Proponent response:

FMG indicates Indigenous communities were consulted on the alternatives assessment and provided opportunities for communities to review and comment on alternative methods, criteria and indicators (that is, draft EA review, meetings/workshops, Indigenous knowledge studies). 

For example, an Indigenous community requested that the treated effluent discharge location and associated infrastructure be relocated closer to the mine site to reduce the overall project footprint and avoid placing infrastructure and discharge points in the southeast arm of Springpole Lake. Relocating the discharge to Birch Lake could reduce infrastructure related effects and better avoid proximity to traditional land use areas.

FMG has committed to support optimizing the treated effluent discharge location during detailed design and permitting to avoid discharge to the southeast arm of Springpole Lake and relocate the discharge closer to the mine site, with discharge to Birch Lake. Relocating the discharge would eliminate the need for approximately 8 km of pipeline infrastructure. This also includes undertaking additional data collection as required for permitting and refining the discharge location through detailed engineering, informed by regulatory input and ongoing consultation with Indigenous communities.

Ministry analysis:

During the review of the EA, the ministry requested clarification from the proponent regarding certain rankings and conclusions for the alternatives assessment, to demonstrate the decision-making process that the proponent followed was clear and transparent. Due to concerns raised by Indigenous communities regarding the proponent’s consultation for the alternatives assessments, the ministry also asked for additional information and documentation from the proponent about how it consulted on this component of the EA process.

In response to the ministry’s comments, FMG amended the EA to revise the rankings and provided further rationale to define the rankings.  FMG also provided additional information in response to ministry comments on how it consulted with Indigenous communities during the alternatives assessment, which is documented in appendix B, table 1.

The ministry is satisfied that a reasonable range of alternative methods were described in the amended EA and evaluated using a broad range of environmental criteria and indicators. The ministry is satisfied that the proponent adequately consulted on the selection of alternatives.  

To support the Indigenous community request to relocate the treated effluent discharge location and associated infrastructure, the ministry may propose, for the minister’s consideration, a condition of approval that would require additional assessment of an alternative effluent discharge location, including further baseline data collection in Birch Lake and additional consultation with relevant government agencies and Indigenous communities, to inform any potential changes to the discharge location.

The ministry may also propose, for the minister’s consideration, a condition of approval regarding an amending procedure. This condition would set out the requirements the proponent must meet, including Indigenous consultation, if changes to any project components are proposed. This type of condition is standard practice and has been applied in previous EA approvals.

With respect to comments received regarding the recognition of the principles of free, prior and informed consent, it is the federal government that has the lead role in working with Indigenous communities and organizations on how to address Indigenous communities’ requests for recognition of these principles in alignment with the United Nations Declaration on the Rights of Indigenous Peoples within Canada.

The ministry recognizes that it has a constitutional duty to consult and, if appropriate, accommodate Indigenous communities with respect to potential adverse impacts to established or credibly asserted Aboriginal or treaty rights from the proposed project. This means that Indigenous communities must be provided with reasonable consultation opportunities throughout the process. The ministry notes that FMG has conducted an extensive consultation program, which followed ToR and EAA requirements, as summarized in appendix C of this ministry review. The ministry has also offered to meet with interested communities to discuss their concerns.

Following the ministry review comment period, the ministry will be considering all comments received during the comment periods and the proponent’s responses, and this information will form an important part of the minister’s decision on the project.

3.2 Conclusions of the EA process

The ministry found that FMG followed a logical and transparent decision-making process to select the preferred methods for carrying out the proposed project and considered the benefits and effects of the range of alternative methods for the project components.

In its EA, FMG considered the appropriate balance of environmental, social, cultural heritage and economic effects. Project components were selected to best meet the project’s purpose and objectives, including the efficient recovery of ore, while minimizing the overall environmental footprint and incorporating technologies and best management practices to address environmental effects.

The ministry is satisfied that the assessment considered the broad definition of the environment, the advantages and disadvantages of proceeding with each of the alternatives, and the potential effects after mitigation (net effects).

The ministry is satisfied that the process used to identify, consider, and evaluate alternatives was consistent with the amended ToR and the EAA. Further, the ministry is of the view that commitments made by FMG, together with proposed conditions of approval under consideration by the ministry requiring additional baseline information collection and assessment prior to permitting, will provide sufficient information to support the transition to permitting and before project implementation.

Refer to appendix A of this review for the ministry’s analysis of how the EA has met the requirements of the EAA and the approved ToR.

3.2.1 Monitoring and commitments

FMG provided a follow-up and monitoring framework in section 12 of the amended EA, which discussed objectives and proposed methods for monitoring several components, including:

• air quality
• noise and vibration emissions
• greenhouse gas emissions
• groundwater
• hydrology and surface water quality
• fish and fish habitat
• vegetation communities and wetlands
• wildlife, wildlife habitat
• species at risk, and
• built heritage resources and cultural landscapes

FMG has committed to developing monitoring plans, noting further monitoring details would be developed during permitting.

FMG committed to developing environmental management plans to effectively implement mitigation measures identified for the proposed project and to support construction, operation and decommissioning / closure phases of the project.

On June 9, 2026, FMG submitted a complete list of commitments from the amended EA to the ministry, which will support compliance monitoring.

4. Summary of the ministry review

The ministry review has explained the ministry’s analysis of the EA, and the following is a summary of this analysis:

• The ministry is satisfied that the amended EA has met the requirements of the ToR and the EAA.
• The ministry is satisfied that FMG has provided sufficient opportunities for the GRT, the public and Indigenous communities to provide input into the amended EA. The results of the consultations have also been clearly documented in the consultation record provided in the amended EA.
• The ministry is satisfied with FMGs responses to the comments submitted by the GRT, the public and Indigenous communities. Where more information is required and identified by Indigenous communities and government technical reviewers, FMGs commitments, together with the ministry’s proposed conditions of approval, under consideration by the ministry, will enable the collection and submission of adequate information to address outstanding issues prior to project implementation.
• FMG amended the EA to demonstrate it used a clear and logical decision-making process to determine the preferred project in accordance with the approved ToR.
• The ministry has enough information about the potential environmental effects as documented in appendix A to enable a decision to be made about the proposed project. Proposed conditions of approval will provide for the verification of environmental effects prior to permitting and support a determination of the feasibility of mitigation measures.

4.1 Proposed conditions of approval

If the project is given approval to proceed under the EAA, the ministry may propose several conditions that would, if imposed, address comments received on the final EA. These proposed conditions of approval under consideration by the ministry are described in section 3.1.2 of this ministry review and include:

• completion of additional hydrogeological investigations at the co-disposal facility prior to ECA permitting to supplement information collected to date
• establishment of environmental committees with interested Indigenous communities to provide a forum for ongoing consultation and engagement during construction, operation, and decommissioning of the project on areas of interest to each Indigenous community
• development of an emergency response plan prior to construction and to refine it during the permitting process, construction, operation, and decommissioning, incorporating opportunities for collaboration with Indigenous communities
• development of detailed mitigation, offsetting, and monitoring plans for all species at risk, in consultation with Indigenous communities through Environmental Committees or other means, established with each Indigenous community, if interested, and the ministry, prior to the commencement of activities that results or is likely to result in killing or harming Boreal Caribou or damaging or destroying its habitat at each phase of the project (early works, construction, operation and decommissioning) at the project site
• demonstration of a clear and detailed understanding of the feasibility and effectiveness of the proposed aeration contingency measure as part of LRIA application process which will be used to confirm that the long-term lake trout population productivity is maintained
• Engagement with Indigenous communities on fish habitat monitoring and an offset compensation plan to continue through environmental committees or other means, established with each Indigenous community, if interested
• assessment of potential seepage or outflow risk between the open pit and Birch Lake and, where risks are identified, develop and implement a mitigation and monitoring plan
• completion of a comprehensive stage 1 AA for the entire project area by a licensed archaeologist as early as possible during detailed design and prior to any ground disturbing activities
• Completion of a HIA for the Marten portage by a qualified professional as early as possible during detailed design and prior to any ground disturbing activities in that area
• Screening of the effluent discharge location and the project area for the two dikes/dewatering activities using MCM’s criteria for evaluating marine archaeological potential check-list. If it is determined that the project areas meet the criteria for marine archaeological potential, a marine AA shall be undertaken by a licensed marine archaeologist as early as possible during detailed design and prior to any ground disturbing activities for the dewatering of the open pit basin of Springpole Lake (including the construction of the two dikes) and for the installation of the effluent treatment plant discharge line
• consultation with interested Indigenous communities through environmental committees before submitting final permit or approval applications and discuss how Indigenous knowledge will be considered in final permit or approval applications
• completion of an additional assessment of an alternative effluent discharge location, including further baseline data collection in Birch Lake and additional consultation with relevant government agencies and Indigenous communities, to inform any potential changes to the discharge location

Other standard conditions are also proposed. These conditions include:

• documentation requirements for the public record
• development of an amending procedure
• annual compliance reporting
• preparation of a complaints protocol to respond to all complaints received

Additional conditions may be considered and proposed prior to a decision being made on the project.

5. What happens now?

This review is available for a 5-week comment period. During this time, all interested parties, including the public and Indigenous communities, can submit comments to the ministry about the proposed project, the amended EA and/or the ministry review. At this time, anyone can make a written request that the Minister refer either all or part of the EA to the Ontario Land Tribunal for a hearing if their environmental concerns have not been considered.

When making a decision, the minister will consider the purpose of the EAA, the ToR, the EA, the ministry review, the comments submitted during the EA and ministry review comment periods and any other matters the minister may consider relevant.

The minister will make one of the following decisions, with the approval of the Lieutenant Governor in Council:

• give approval to proceed with the project
• give approval to proceed with the project subject to conditions
• refuse to give approval to proceed with the project

Prior to making that decision, the minister may also:

• refer the application (which consists of the ToR and EA), or a matter that relates to the application, to the Ontario Land Tribunal for a hearing and decision
• refer matters in connection with the project to mediation

5.1 Additional approval requirements

If approval is given under the EAA, FMG would still need to obtain other permits and approvals to design, construct, operate and decommission this project. Section 11 of the amended EA lists the additional provincial and federal approvals that may be required.

5.1 Modifying / amending the proposed project

Given the large scale and complexity of the project, and commitments to ongoing monitoring and consultation, it is anticipated that there could potentially be proposed changes to the design and implementation of the project. The process to make changes to the project, if required, will be set out in an amending condition of approval proposed by the ministry and referenced in the section 3.1.2 of this ministry review.

Making a submission

A 5-week public review period ending July 31^st, 2026, will follow publication of the ministry review. During this time, any interested parties can make submissions about the proposed project, the EA, or the ministry review.

Should you wish to make a submission, please send it electronically to antonia.testa@ontario.ca and address it to:

Kathleen O’Neill, Director
Environmental Assessment Branch
Ministry of the Environment, Conservation and Parks
Re: Springpole Gold Project Environmental Assessment
Attention: Antonia Testa, Special Project Officer

Appendix A: Environmental Assessment Act

Requirements in Ontario Regulation 53/24: General and Transitional Matters

Summary of the EA

Ontario Regulation 53/24: section 4.(1)(a)

EA should contain a brief summary of the EA organized in accordance with the matters set out in subsection 17.6 (2) of the Act.

Analysis of the EA

The amended EA submission included an executive summary (entitled environmental impact statement / environmental assessment summary) organized in accordance with the matters set out in subsection 17.6(2) of the EAA.

1. List of proponent-led studies

Ontario Regulation 53/24: section 4.(1) (b)

EA should contain a list of studies and reports which are under the control of the proponent and which were done in connection with the project or matters related to the project.

Analysis of the EA

Baseline studies and reports under the control of the proponent and undertaken in connection with the EA are listed in section 3.0 of the amended EA Report (entitled "environmental setting"), in table 3.3-1 (entitled "list of baseline studies").

2. List of additional studies

Ontario Regulation 53/24: section 4.(1)(c)

EA should contain a list of studies and reports done in connection with the project or matters related to the project of which the proponent is aware and that are not under the control of the proponent.

Analysis of the EA

The list of studies and reports in table 3.3-1 (entitled list of baseline studies) in section 3.0 of the amended EA Report includes some studies and reports undertaken in connection with the proposed project and the EA that were not under the control of the proponent (for example, traditional knowledge, traditional land Use and socioeconomic baseline studies undertaken by Indigenous communities).

Other sections of the amended EA Report also contain lists of data sources, references and works cited, where applicable.

3. Maps

Ontario Regulation 53/24: section 4.(1) (d), 4.(2), 4.(3)

If the EA is for a project with a fixed location, at least 2 well-marked, legible and reproducible maps showing the location of the project and the area to be affected by it.

Of the maps referred to above, one shall be a simplified base map suitable for reproduction in any notices that may be published and the other may include more detail such as a 1:10,000 scale Ontario base map.

The maps referred to may show alternative proposals.

Analysis of the EA

Figure 1.1-2 (entitled “project location”) in section 1.2 of the amended EA report shows the location of the proposed project.

Figure 1.4-1 (entitled "EIS/EA site plan") and figure 1.4-2 (entitled "EIS/EA extended site plan") in section 1.4 of the amended EA report show the proposed site plan and layout of the proposed project, including the preferred locations for various project components. Figure 1.4-2 shows the preferred routes for the mine access road and the transmission line. Additional maps are included in section 5.0 of the amended EA report (entitled project description) showing more detailed plans and cross-sections for project components.

Figure 3.3-1 (entitled baseline investigation area) in section 3.3.2 of the amended EA report shows the overall study area for the EA. Sections 6.2 to 6.26 of the amended EA report include additional information about the study areas used for the effects assessments of valued components identified by the proponent for the EA with accompanying maps specific to those assessments.

Section 4.0 of the amended EA report (entitled alternatives assessment) includes additional maps identifying the locations of alternative methods assessed for the EA.

The maps in the amended EA report are full-page and legible.

Problem / opportunities

1. Identify an existing problem or opportunity and purpose of the project:

Environmental Assessment Act section 17.4 (2) (c) and section 17.6 (2) (a)

The EA should contain a brief explanation of the problem or opportunity that prompted the proposed activity.

If a specific project has been identified provide a brief description.

Analysis of the EA

Section 1.3 of the amended EA report (entitled purpose of the project and project justification) discusses the purpose and justification for the proposed project, including the opportunity prompting the proposed activity. According to the amended EA report, the purpose of the proposed project is to extract ore by open pit mining for processing on-site to produce doré bars (semi-pure products of gold and silver that will be transported off-site). The amended EA report states the project is being proposed to meet global demands for gold and silver and to provide a return on investment, while supporting local employment and the regional economy.

Section 5.0 of the amended EA report (entitled project description) describes the preferred project design. The proposed project includes the following key components:

• open pit mine and related infrastructure
• dikes to isolate the open pit in a dewatered basin of Springpole Lake
• surficial soil stockpile
• ore stockpiles
• on-site ore process plant and process plant complex
• co-disposal facility for tailings and mine rock
• water management and treatment facilities
• treated effluent discharge
• fish habitat development area
• accommodations complex and other on-site buildings
• fuel and chemicals storage and management
• solid waste management (transport off-site)
• on-site domestic sewage management
• aggregate operations
• 2-lane all-season gravel access road
• airstrip (co-located with the mine access road)
• 230-kilovolt overhead transmission line

During the construction phase, a basin of Springpole Lake would be isolated, using dikes, and dewatered to allow for development of the open pit. The open pit would be refilled during the decommissioning and closure phase of the proposed project, and once water quality meets all regulatory requirements, the reclaimed basin would be reconnected to Springpole Lake.

According to the amended EA Report, the open pit is planned to be mined over approximately 10 years. Ore from the open pit would be processed on-site at approximately 30,000 tonnes per day. Mine rock and tailings would be stored in a co-disposal facility with a north cell for thickened non-acid generating tailings and mine rock, and a smaller south cell for conventional slurry tailings deposition.

Alternatives

1. Description and statement of the rationale for the alternatives to:

Environmental Assessment Act section 17.4 (2)(c) and section 17.6 (2) (b)(iii)

Alternatives to represent functionally different ways of addressing the problem or opportunity.

A reasonable range of alternatives to should be identified and evaluated. The proponent should be able to justify that it has considered a reasonable range of alternatives.

The do nothing 'alternative to' should be included in the evaluation and will represent the benchmark situation.

Analysis of the EA

During the preparation of the voluntary agreement and the ToR for the EA, the proponent determined that open pit mining is the only feasible option for the project when compared to underground mining or a combination of open pit and underground mining.

In accordance with the approved amended ToR, the voluntary agreement for the EA and the rationales provided by the proponent during the preparation of those documents, an assessment of alternatives to the proposed project was not required for the EA. The proponent did, however, include an assessment (in section 4.3 of the amended EA report) of options to proceed with the proposed project in the near term, delay the proposed project until circumstances are more favourable or abandon the project (do nothing). Proceeding with the project in the near term was selected as the preferred option in the amended EA report.

The proponent determined that the do nothing alternative does not meet the purpose of the proposed project; however, as required by the approved amended ToR, it was carried forward to be used for comparison during the assessment of alternative methods for the proposed project, as it represents the existing baseline environmental conditions.

The ministry reviewed the EA report and the amendments submitted by the proponent, and suggested the proponent clarify the EAA requirements for the proposed project — with respect to assessment of alternatives to the project and the do nothing. The proponent did accept MECPs recommendation and amended the EA to clarify EAA requirements.

2. Description and statement of the rationale for the alternative methods

Environmental Assessment Act section 17.6(2)(b)(ii)

Alternative methods include a description of different ways of implementing the preferred alternative to.

A reasonable range of alternative methods should be identified and outlined.

While this is an assessment which is focused on alternative methods, the "do nothing" 'alternative to' should be included in the evaluation and will represent the "benchmark" situation.

Analysis of the EA

Section 4.0 of the amended EA report (entitled alternatives assessment) describes the proponent’s evaluation of alternative methods for components of the proposed project.  The proponent amended this section in response to ministry comments to provide more clarification on the rationale for each alternative method assessed in the EA.

Based on the methodology described in the approved amended ToR and section 4.1 of the amended EA report (entitled alternatives assessment approach), the proponent identified a reasonable range of alternatives for project components, where available, based on a set of initial questions / considerations.

The proponent assessed alternatives methods for the following project components:

• east and west dike locations in Springpole Lake
• mine rock and tailings storage locations / methods / technologies / strategies
• ore storage locations
• effluent treatment
• water supply
• site water management
• treated effluent discharge locations
• mine access road routes
• workforce transportation
• domestic sewage management
• solid waste management
• power supply
• transmission line routes
• explosives handling and storage
• mine closure activities

Where viable alternatives were not identified for project components, the proponent provided information in the amended EA report regarding the lack of viable alternatives and provided a rationale.

Through the issues resolution process, the ministry heard concerns from Indigenous communities about the proponent’s consultation regarding the alternatives assessments, including on decisions related to the selection of alternatives. The ministry asked the proponent for additional information and documentation regarding how Indigenous communities were consulted for this component of the EA process. The proponent provided this additional information as part of the ministry’s issues resolution process documented in appendix B, table 1 of this review. 

The ministry is satisfied that a reasonable range of alternative methods were described in the amended EA report. The ministry is satisfied that the proponent adequately consulted on the selection of alternatives.

Evaluation 

Description of the environment for the project and alternatives

Environmental Assessment Act section 17.4(2)(c) and section 17.6(2)(c)(i)

Proponents must consider the broad definition of the environment including the natural, biophysical, social, economic, built and cultural conditions.

The EA must provide a description of the existing environmental conditions in the study area.

The EA must identify those elements of the environment that may be reasonably expected to be affected, either directly or indirectly, by the proposed project and/or the alternatives.

Analysis of the EA

A preliminary description of the existing environment was provided in section 6.0 of the approved amended ToR for the EA (entitled "description of existing environment"). This section of the approved amended ToR included a commitment for the proponent to provide a more detailed description of the environment in the EA report.

Section 3.0 of the amended EA report (entitled "environmental setting") describes the existing environment, providing a description of the geographic area in relation to the proposed project. The amended EA report notes this section focuses on what potentially interacts with the proposed project and the alternatives considered for the project components. The section provides a description of existing conditions related to the natural, social, cultural, economic and built environments, and uses the baseline investigation area (refined overall EA study area) presented in figure 3.3-1, which is available in section 3.3.2 of the amended EA report.

Additional information regarding baseline environmental conditions is provided throughout section 6.0 of the amended EA report (entitled "effects assessment") to support the assessment of potential effects for each identified valued component. The spatial boundaries (study areas) specific to each valued component are described in the relevant subsections. Environmental baseline reports with more detailed information are provided in the appendices to the amended EA report (appendices G to U).

The environmental components described in section 3.0 of the amended EA report are:

• section 3.4.1 — meteorology and climate
• section 3.4.2 — air quality
• section 3.4.3 — sound and vibration
• section 3.4.4 — geology and physiography
• section 3.4.5 — hydrogeology
• section 3.4.6 — hydrology
• section 3.4.7 — surface water
• section 3.4.8 — aquatic resources
• section 3.4.9 — vegetation communities and wetlands
• section 3.4.10 — wildlife and wildlife habitat
• section 3.4.11 — socioeconomics
• section 3.4.12 — light
• section 3.4.13 — visual aesthetics
• section 3.4.14 — traditional land use
• section 3.4.15 — archaeological resources
• section 3.4.16 — built heritage resources and cultural heritage landscapes

The environmental components (or valued components selected by the proponent for the effects assessment for the preferred project) described in section 6.0 of the amended EA report are:

• section 6.2 — air quality
• section 6.3 — noise and vibration
• section 6.4 — greenhouse gas emissions
• section 6.5 — groundwater
• section 6.6 — Birch Lake system
• section 6.7 — Springpole Lake, north basin system
• section 6.8 — Springpole Lake, southeast arm system
• section 6.9 — local inland waterbodies
• section 6.10 — fish and fish habitat
• section 6.11 — vegetation communities and wetlands
• section 6.12 — wildlife and wildlife habitat
• section 6.13 — boreal caribou
• section 6.14 — wolverine
• section 6.15 — bats
• section 6.16 — species at risk birds
• section 6.17 — commercial land and resource use
• section 6.18 — outdoor recreation
• section 6.19 — local and regional economy
• section 6.20 — local and regional infrastructure and services
• section 6.21 — traditional land and resource use
• section 6.22 — archaeology
• section 6.23 — built heritage resources and cultural heritage landscapes
• section 6.24 — human and ecological health
• section 6.25 — federal considerations
• section 6.26 — effects on Indigenous peoples

The ministry is satisfied that a broad definition of the environment was considered and descriptions of the existing environmental conditions in the study area(s) were provided.

Through the issues resolution process, the ministry received comments regarding the description of the existing environment for the EA:

• The ministry’s Northern Region Technical Support Section requested additional geological and geophysical assessment of the area within and adjacent to the proposed co-disposal facility footprint at the project site. This information is needed to demonstrate an understanding of geological structures and hydraulic properties in that area, and to support reliable prediction and monitoring of groundwater flow. The proponent completed additional geological drilling in the fall of 2024 and a field program in 2025; however, the ministry reviewed the proponent’s supplemental reports and confirmed additional information is necessary to support an informed assessment of environmental risks. Therefore, the ministry is proposing conditions of approval requiring the proponent to complete additional hydrogeological field investigations prior to permitting.
• MCM recommended additional marine archaeological assessment work be carried out to inform the existing baseline conditions at the final effluent discharge location and the north basin of Springpole Lake. The proponent has committed to undertaking further assessment. The ministry is also proposing a condition of approval requiring the proponent to complete a marine archaeological assessment by a licensed archaeologist. The condition of approval would also require the proponent to consult with Indigenous communities prior to the submission of the assessment to MCM.
• MECPs Environmental Assessment Branch was copied on correspondence from Cold Lake First Nations (CLFN) and LSFN to MCM in November 2025, including the Kita-Ki-Nan archaeology and cultural heritage review report which raised concerns with archaeological work conducted for the EA. In response, the ministry is proposing a condition of approval that would require the proponent to undertake a new stage 1 archaeological assessment for the proposed project by a licensed archaeologist. The condition of approval would also require the proponent to consult with Indigenous communities prior to the submission of the assessment to MCM.
• Through the issues resolution process for the EA, the proponent committed to undertaking additional baseline studies in Birch Lake to support a potential change to the location of the treated effluent discharge in response to comments from CLFN. To build on this commitment, the ministry is proposing a condition of approval that would require the proponent to complete an assessment to support the potential change of the effluent discharge location to Birch Lake.  The condition of approval would also require the proponent to consult with Indigenous communities during the assessment process.
• MECPs Species at Risk Branch recommended a condition of approval for the proponent to develop detailed mitigation, offsetting, and monitoring plans for all species at risk. These plans would be developed in collaboration with Indigenous communities and MECPs Species at Risk Branch prior to the commencement of any activities at the project site.
• MNR recommended conditions of approval for the proponent to provided additional information to demonstrate the feasibility and effectiveness of proposed aeration contingency measures, define transmission line access and maintenance activities, and an assessment of the potential seepage or outflow between the open pit and Birch Lake, and where risk exists, develop and implement a mitigation and monitoring plan to address impacts.

The ministry is satisfied that the amended EA report, along with the proponent’s commitments and potential conditions for the collection of further information about baseline conditions, provide for a description of the environment that will be affected or might reasonably be expected to be affected, directly or indirectly, by the project and the alternative methods assessed by the proponent.

2. Description of the potential environmental effects

Environmental Assessment Act section 17.4(2)(c) and section 17.6(2)(c)(ii)

Both positive and negative environmental effects should be discussed.

The EA must identify methods and studies used to analyze the potential environmental effects. The methods used are contingent on the type of project.

Impact assessment methods and criteria used during the evaluation should be identified.

The methods chosen must be clear, traceable and replicable so that interested parties can understand the analysis and logic used throughout the EA.

Analysis of the EA

Description of potential effects from the alternative methods

Section 4.0 of the amended EA report (entitled “alternatives assessment”) identifies potential effects from the alternative methods assessed by the proponent for components of the project. The assessments include potential effects at different stages (construction, operations and closure).

The approach and methods used by the proponent to identify potential effects from the alternative methods are described in section 4.1 of the amended EA report (entitled “alternatives assessment approach”). The proponent followed the methodology outlined in the approved amended ToR, which required a comparative evaluation of viable alternative methods of carrying out the proposed project based on performance objectives, evaluation criteria, and indicators to define the preferred alternatives for the components of the project.

The performance objectives, evaluation criteria and indicators chosen by the proponent relate to the natural, social, economic, cultural and built environments, as well as technical performance (including cost) and amenability to reclamation. The ministry reviewed the EA report submitted by the proponent, and found that clear rationales for the selection of final criteria and indicators for the alternatives assessments were not provided. The ministry also found that there were inconsistencies in the criteria and indicators described in the alternative methods assessment methodology and those used in the assessment tables in section 4.0 of the amended EA report. The ministry requested additional information and amendments from the proponent to address these comments. The proponent amended this section in response to ministry comments to provide clear rationales for the selection of the criteria and indicators, as well as corrected the inconsistencies identified by the ministry.

The proponent’s alternatives assessments identified high-level potential effects, advantages and disadvantages of each alternative method. The alternative methods were considered with the application of mitigation measures for potential environmental effects. The “do nothing” alternative was also presented as the environmental baseline condition / benchmark for comparison.

As required by the approved amended ToR, the results of the assessments were recorded in tables with ranking conclusions for each criterion. The proponent described, in the EA report (prior to amendments), some modifications to its ranking approach and descriptions from what was described in the approved amended ToR.

For each performance objective, the results were summarized, and a ranking for each performance objective was made for each alternative method. An overall assessment was completed by the proponent, considering the results for all performance objectives, and an overall ranking and statement of suitability was provided for each alternative method. Explanations for which alternatives were selected to be carried forward into the proposed project design were provided.

The ministry reviewed the EA report submitted by the proponent, and asked for clarification from the proponent regarding certain rankings and conclusions for the alternatives assessment, so that the decision-making process that the proponent followed is clear and transparent.

Due to concerns raised by Indigenous communities regarding the proponent’s consultation for this component of the EA and the alternatives assessments, the ministry also asked for additional information and documentation from the proponent about how it consulted on this component of the EA process.

In response to the ministry’s comments, the proponent amended the EA to revise the rankings and provided further rationale to define the rankings.  The proponent also provided additional information in response to ministry comments on how it consulted with Indigenous communities during the alternatives assessment, which is documented in appendix B, table 1.

The ministry is satisfied that the proponent evaluated the alternative methods using a broad range of environmental criteria and indicators.

The ministry is satisfied that the proponent followed a clear and logical decision process to select the preferred alternatives consistent with the EAA and the approved amended ToR. Per the ministry’s Code of Practice for Preparing and Reviewing Environmental Assessments in Ontario (EA Code of Practice), the results of the alternatives assessments are transparent and traceable such that anyone with the same information could reach the same conclusion without additional assumptions.

Description of potential effects from the preferred project

Section 6.0 of the amended EA report (entitled "effects assessment") includes subsections describing the potential effects from the preferred project design on each valued component selected by the proponent for the effects assessment. The approach and methodology for the effects assessment are described in section 6.1 of the amended EA report (entitled “effects assessment approach”).

In accordance with the methods described in the approved amended ToR, valued components were selected by the proponent for the biophysical (natural) environment and the human (social, economic, cultural and built) environment. For each valued component, criteria and indicators were selected to identify potential effects. Rationales were provided in the corresponding subsections explaining why criteria were selected for the effects assessments.

The proponent identified pathways to potential effects based on interactions between project components / activities and the valued components for the phases of the proposed project (construction, operations and decommissioning / closure). The potential effects that would be caused or might reasonably be expected to be caused by the proposed project were then further analyzed by the proponent in the effects assessment for each valued component. The potential effects included both direct and indirect effects, and negative and positive effects.

Mitigation measures were identified by the proponent, and potential net effects (after the application of mitigation) were described for each valued component. Analytical methods and tools used for these assessments (for example, laboratory tests, modelling, statistical analyses) are described, along with key assumptions made. The proponent characterized net effects, and provided a determination of significance for each potential adverse residual effect using attributes that it selected, including ecological / social context, magnitude, extent, duration, frequency, reversibility, and timing.

Net adverse effects were identified by the proponent for the valued components listed below; however, the proponent’s assessments of significance concluded that no significant adverse environmental effects are predicted.

• air quality
• noise
• greenhouse gas emissions
• groundwater
• surface water (Birch Lake, Springpole Lake north basin, and Springpole Lake southeast arm systems)
• vegetation communities and wetlands
• wildlife and wildlife habitat
• species at risk (boreal caribou, wolverine, bats, birds)
• commercial land and resource use
• local and regional infrastructure and services
• traditional land and resource use
• Indigenous peoples

Section 15.0 of the amended EA report (entitled “effects assessment summary tables”) includes tables summarizing potential effects, mitigation measures, net effects and the proponent’s significance determinations for each valued component.

Section 7.0 of the amended EA report (entitled “cumulative effects assessment”) describes the cumulative effects assessment completed by the proponent for the EA.

In accordance with the approved amended ToR, the ministry’s EA Code of Practice, and the ministry’s climate change guideline, the proponent considered the impacts of climate change on the proposed project and the impacts of the project on climate change. These assessments are documented in section 6.4 of the amended EA report (entitled “greenhouse gas emissions”), section 8.0 of the amended EA report (entitled "effects of the environment on the project"), and throughout section 4.0 of the amended EA report (entitled “alternatives assessment”). In section 4.0 alternative methods were assessed according to criteria related to greenhouse gas emissions.

The ministry reviewed the EA report submitted by the proponent, and found that certain potential effects were not described in relation to the indicators chosen for the effects assessments. The ministry also found that certain conclusions made by the proponent were not supported by sufficient rationale. The ministry asked for clarification regarding certain methods and conclusions in the EA. The proponent amended this section in response to ministry comments to provide more information on potential effects on each of the indicators for the preferred project.

Due to concerns raised by Indigenous communities regarding the proponent’s consultation and the proponent’s methodology for the effects assessments, the ministry also asked for additional information and documentation from the proponent about how it consulted on this component of the EA process.  The proponent also provided additional information in response to ministry comments on how it consulted with Indigenous communities during the alternatives assessment, which is documented in appendix B, table 1.

In addition to the amendments made to the EA and supplemental information submitted by the proponent, the ministry is proposing conditions of approval for additional hydrogeological investigations, marine and stage 1 archaeological assessments, and the assessment of Birch Lake as a potential location for treated effluent discharge to further understand the potential effects of the project prior to permitting.

The ministry is satisfied that the evaluation methods for the effects assessments in the amended EA report are clear, traceable, replicable and appropriate for a transmission line project. The ministry is satisfied that the amended EA report provides a complete and accurate description of effects that may be caused to the environment from the project and its alternatives. The ministry is satisfied that through the proposed conditions of approval, the effects of the preferred project on the environment will be well understood prior to permitting.

3. Description of the actions necessary to prevent, change, mitigate or remedy the environmental effects for the alternatives

Environmental Assessment Act section 17.4(2)(c) and section 17.6(2)(c)(iii)

A description of future commitments, studies and a work plan may be included as part of the actions necessary to prevent, change, mitigate or remedy environmental effects for each alternative for the ultimate purpose of comparing them.

Analysis of the EA

Section 4.0 of the amended EA report (entitled "alternatives assessment") identifies mitigation measures related to the alternative methods assessed by the proponent.

Section 6.0 of the amended EA report (entitled “effects assessment and mitigation”) includes the proponent’s descriptions of mitigation measures to prevent, eliminate or reduce negative effects from the proposed project to the valued components selected for the EA. These discussions are presented in the relevant subsections related to each valued component.

Section 15.0 of the amended EA report (entitled “effects assessment summary tables”) includes tables summarizing potential effects, mitigation measures, and net effects.

Section 12.0 of the amended EA report (entitled “follow-up and monitoring”) provides a follow-up and monitoring framework for the follow-up monitoring program that would be designed to verify the conclusions of the EA and determine the effectiveness of mitigation measures.

Section 12.0 identifies environmental management plans that the proponent commits to developing to support construction, operation and decommissioning and closure phases of the proposed project, including:

• water management plan
• domestic waste management plan
• emergency response plan
• erosion and sediment control plan
• explosives and blasting management plan
• greenhouse gas management plan
• mine rock management plan
• soil management plan
• spill prevention and response plan

The framework described in section 12.0 of the amended EA report discusses objectives and proposed methods for monitoring related to:

• air quality
• sound and vibration
• greenhouse gas emissions
• groundwater
• hydrology and surface water
• fish and fish habitat
• vegetation communities and wetlands
• wildlife and wildlife habitat
• species at risk
• built heritage resources and cultural heritage landscapes

Table 12-1 (entitled “preliminary follow-up and monitoring program”) in section 12.0 of the amended EA report provides an overview of monitoring objectives and the proponent’s preliminary approaches. Section 12.0 of the amended EA report also includes commitments related to the implementation of a complaint procedure, a dust management plan, and a blasting management plan, which would be developed during approvals and/or prior to construction.

The proponent provided a full list of EA commitments in the amended EA.

MECPs Species at Risk Branch recommended a condition of approval for the proponent to develop detailed mitigation, offsetting, and monitoring plans for all species at risk. These plans would be developed in collaboration with Indigenous communities and MECPs Species at Risk Branch prior to the commencement of any activities at the project site.

MNR recommended conditions of approval for the proponent to provide additional information to demonstrate the feasibility and effectiveness of proposed aeration contingency measures, define transmission line access and maintenance activities, and an assessment of the potential seepage or outflow between the open pit and Birch Lake, and where risk exists, develop and implement a mitigation and monitoring plan to address impacts.

4. Evaluation of advantages and disadvantages to the environment

Environmental Assessment Act section 17.4(2)(c) and section 17.6(2)(d)

The preferred alternative should be identified through this evaluation.

Analysis of the EA

Advantages and disadvantages of the alternative methods

Section 4.0 of the amended EA report (entitled “alternatives assessment”) describes the advantages and disadvantages of the alternative methods assessed by the proponent. This section includes discussions of the advantages and disadvantages that led to the proponent’s selection of preferred alternatives for project components.

The ministry reviewed the EA report submitted by the proponent, and asked for clarification regarding certain advantages and disadvantages (or key differentiating factors) identified by the proponent in the alternatives assessments. The proponent amended the EA to provide more information on advantages and disadvantages of the alternative methods.

Advantages and disadvantages of preferred project

Section 4.0 of the amended EA report also describes an assessment completed by the proponent comparing options to proceed with the proposed project in the near term, delay the proposed project until circumstances are more favourable or abandon the project (“do nothing”). This assessment identifies advantages and disadvantages of the project overall.

Benefits of the project are also discussed in other sections of the amended EA report (for example, section 1.3, entitled “purpose of the project and justification”; section 5.20, entitled “economic benefits”; and section 13.0, entitled “conclusions”).

5. Description of consultation with interested stakeholders

Environmental Assessment Act section 17.6 (2)(e)

A description of stakeholder consultation that occurred during the preparation of the EA needs be documented and should include consultation methods used, frequency of consultation, dates that events occurred, target audience, descriptions of key milestones for which stakeholders are providing input, comments received.

The EA must identify any Aboriginal consultation efforts that have been made including methods for identifying potentially interested First Nations, who was consulted, when and how consultation occurred and any comments received from First Nations.

The EA should outline conflict resolution techniques used by the proponent to resolve outstanding issues with any stakeholders. There must be clear documentation as to how issues and concerns have been addressed.

Analysis of the EA

Section 2.0 of the amended EA report (entitled “consultation”) provides a description of the proponent’s consultation with Indigenous communities, government agencies, stakeholders and the public during the preparation of the EA.

The proponent provided communications logs and supporting records in appendix D (“record of consultation”).

The ministry is satisfied that the amended EA report adequately documented the consultation undertaken for the project.

The consultation undertaken is consistent with the consultation plans provided in the approved amended ToR.

The consultation process and comments received on the EA are summarized in appendices B and C of this review.

The proponent responded to all comments received by the ministry on the EA. The proponent made amendments to address certain comments and provided additional information in its responses and supplemental reports. The ministry is satisfied with the amendments made to the EA in response to comments from the ministry.

The amended EA report includes commitments for continued consultation.

The ministry is satisfied that there were sufficient opportunities for consultation.

Selection process

1. Description and statement of the rationale for the project

Environmental Assessment Act section 17.6(2)(b)(i)

The description of the project should specify what the proponent is seeking approval for under the EAA.

The description should include information on the location, attributes, dimensions, emissions etc.

The evaluation process should identify which is the preferred project.

Analysis of the EA

Section 5.0 of the amended EA report (entitled “project description”) describes the project for which the proponent is seeking approval under the EAA. This section includes information on the proposed project phases (construction, operations and decommissioning / closure), and about the different components of the proposed project.

Descriptions of locations, attributes, and dimensions of project components are included. An EIS/EA Site Plan (figure 5.1-1) and extended site plan (figure 5.1-2) are also provided, in section 5.1 of the amended EA report.

According to section 5.0 of the amended EA report, the proposed site layout and infrastructure routing presented were developed through the assessment of alternatives presented in section 4.0 of the amended EA report.

The ministry’s Northern Region Technical Support Section requested additional geological and geophysical assessment of the area within and adjacent to the proposed co-disposal facility footprint at the project site. This information is needed to demonstrate an understanding of geological structures and hydraulic properties in that area, and to support reliable prediction and monitoring of groundwater flow. The proponent completed additional geological drilling in the fall of 2024 and a field program in 2025; however, the ministry reviewed the proponent’s supplemental reports and confirmed additional information is necessary to support an informed assessment of environmental risks. Therefore, the ministry is proposing conditions of approval requiring the proponent to complete additional hydrogeological field investigations prior to permitting.   

Through the issues resolution process for the EA, the proponent committed to undertaking additional baseline studies in Birch Lake to support a potential change to the location of the treated effluent discharge in response to comments from CLFN. To build on this commitment, the ministry is proposing a condition of approval that would require the proponent to complete an assessment to support the potential change of the effluent discharge location to Birch Lake. The condition of approval would also require the proponent to consult with Indigenous communities during the assessment process.

The ministry is satisfied that the proponent has adequately described the project in the amended EA, and any outstanding information can be obtained through the proposed conditions of approval.

Next steps and additional commitments

1. Additional ToR commitments

Outline any further commitments made by the proponent in the ToR.

Analysis of the EA

The EA must be consistent with the approved amended ToR. The proponent included appendices B-4 and B-5 with the amended EA submission, which include concordance tables listing ToR requirements / commitments and where they are addressed by the proponent in the amended EA report and supporting appendices.

2. Additional EA commitments

Outline any further commitments made by the proponent in the EA.

Analysis of the EA

The proponent provided a complete list of commitments in the amended EA.

3. Additional approvals

Outline additional approval requirements. Provide sufficient detail about the nature of the approval.

Analysis of the EA

Section 11.0 of the amended EA report (entitled “environmental approval requirements”) outlines additional federal and provincial environmental approvals anticipated to be required for the proposed project.

Anticipated federal approvals are listed in table 11.1-1, and anticipated provincial approvals are listed in table 11.2-1. The proponent does not anticipate municipal approval requirements as the proposed project is not located in an incorporated municipality.

Anticipated provincial environmental approvals include environmental compliance approvals under the Environmental Protection Act, a permit to take water under the Ontario Water Resources Act, project registration under the Species Conservation Act, and other permits and approvals from MNR, the Ministry of Transportation, MEM (that is, closure plan under the Mining Act), and the Ontario Energy Board.

Anticipated federal environmental approvals include authorizations and approvals from Fisheries and Oceans Canada, Environment and Climate Change Canada, Natural Resources Canada and Transport Canada.

Appendix B: Submissions received during the comment period

Table 1: Government review team comment summary table

To be provided with an electronic copy of this table, please contact Antonia Testa, Special Project Officer, Environmental Assessment Branch, at antonia.testa@ontario.ca, or Tel: 416-388-2524.

Table 2: Public comment summary table

To be provided with an electronic copy of this table, please contact Antonia Testa, Special Project Officer, Environmental Assessment Branch, at antonia.testa@ontario.ca, or Tel: 416-388-2524.

Table 3: Indigenous communities comment summary table

To be provided with an electronic copy of this table, please contact Antonia Testa, Special Project Officer, Environmental Assessment Branch, at antonia.testa@ontario.ca, or Tel: 416-388-2524.

Appendix C: Consultation

FMG consulted with the GRT, Indigenous communities, stakeholders and the public in preparation of the EA.

The approved amended ToR for the EA included:

• an Indigenous consultation plan
• a government consultation plan
• a public engagement plan

The approved amended ToR also included commitments for FMG to provide flexible consultation opportunities to Indigenous communities, including the development of community-specific consultation plans, if requested. ToR commitments required FMG to consult Indigenous communities about specific key components of the EA process.

On November 24, 2021, FMG published a notice of commencement for the EA in the Sioux Lookout Bulletin newspaper. The notice was distributed to the GRT, Indigenous communities and FMGs public contact list via email on December 3, 2021. 

According to the amended EA, the methods and tools that FMG used to consult during the preparation of the EA included:

• circulation of documents to the GRT, Indigenous communities and interested stakeholders for review and comment (for example, baseline studies, technical workplans, preliminary alternative assessment tables, draft EA and other information about the project and potential effects)
• use of FMGs project website to provide access to EA materials, videos and factsheets, and to facilitate public reviews of documents
• meetings with the GRT, Indigenous communities (including chiefs and councils), and interested stakeholders
• community information sessions, webinars and workshops to present project information and provide opportunities for input and questions
• notices of public information sessions including in local newspapers, online and via radio announcements
• circulation of project updates (for example, fact sheets, newsletters, community bulletins)
• use of plain language and translated summaries, where possible, to make sure feedback could be provided by non-technical reviewers
• engagement of Indigenous communities in environmental baseline field studies
• development / support of traditional knowledge and traditional land use studies and information-sharing with Indigenous communities
• targeted mailouts to distribute flyers, letters and project information to residents, landowners and local land users in the project area
• local office opened in the Municipality of Sioux Lookout to increase local awareness of the project and allow in-person meetings, questions and comments
• social media to provide updates and information about the project and opportunities for engagement throughout the EA process
• community relations email established to provide an additional forum for interested parties to contact FMG about the project
• contact lists created and maintained by FMG
• participation in public events to increase public awareness about the project and provide opportunities for questions and comments
• other GRT, Indigenous community and/or stakeholder specific communications

Per commitments set out in the approved amended ToR, FMG prepared a draft EA which was circulated in May and June 2022 to the GRT, Indigenous communities, and stakeholders for review (both electronically and in hardcopy format, where requested). The draft EA, including supporting studies and reports, was posted on FMGs website for public comment. According to the amended EA, in November 2022, a draft EA summary translated to Ojibway was also made available. FMG responded to comments provided on the draft EA and held meetings to discuss comments and responses leading up to the submission of the final EA in November 2024.

FMGs consultation activities and the comments it received in preparation of the EA are discussed in section 2.0 of the amended EA and FMG’s record of consultation. FMG also provides summaries of the “influence of consultation with Indigenous communities, government and the public” in various subsections of the amended EA, where applicable.

FMGs record of consultation

FMG summarizes its consultation for the EA process in section 2.0 of the amended EA. A record of consultation was submitted with the EA (appendix D) which included communication logs and a selection of supporting records. The record of consultation submitted with the EA in November 2024 covered to the end of June 2024.

The ministry reviewed FMG’s consultation summary and record of consultation for the EA. The ministry determined that supporting records were missing and requested that FMG submit a complete set of records to the ministry, as well as additional records for consultation that occurred after June 2024. On June 10, 2025, FMG submitted a supplemental record of consultation to the ministry (for July to December 2024). On November 13, 2025, and January 13, 2026, FMG submitted additional supporting records that were previously missing from its record of consultation.

FMG continued to consult with Indigenous communities following the submission of the EA to the ministry. FMG also held community information sessions following the ministry-led comment period on the EA. On June 10, 2025, January 13, 2026, and May 13, 2026, FMG submitted updates to its record of consultation for the periods of January to December 2025. 

Final EA distribution and consultation

Upon submission of the final EA to the ministry in November 2024, the EA was circulated by FMG for review to the GRT, Indigenous communities, and interested stakeholders. The EA was posted to the proponent website for public review.

A notice of submission of the EA was posted to FMGs website. The notice was also published on local newspaper websites such as TB News Watch, Wawatay News, the Sioux Lookout Bulletin, and Northwest Ontario NWO News Watch. A link to the notice was provided on the ministry’s ontario.ca project webpage.

FMG sent hardcopies of the EA to GRT members and Indigenous communities, where requested. Hardcopies were also sent to the Sioux Lookout Public Library and the Ear Falls Public Library for public viewing. Prior to the submission date, the ministry reached out to FMG to ask about its plans for distributing the EA to stakeholders in the area (for example, trappers). FMG was advised to work with the MNR for the mailout.

In accordance with the requirements of Ontario Regulation 616/98: Deadlines under the EAA, a 7-week formal review and comment period is required for the EA submission; however, given the comprehensive nature of the EA and the timing of the submission, FMG requested a longer review period. The ministry began its consultation on the EA submission by providing a 10-week comment period beginning on November 8, 2024, and ending on January 17, 2025.  The ministry-led comment period provided the GRT, Indigenous communities, and the public an opportunity to review the EA and submit their comments to the ministry regarding the fulfillment of the ToR requirements, the EA, and the proposed project.

In December 2024, during the public comment period on the EA, FMG issued an update to its EA submission after making changes to certain sections of the EA in response to preliminary comments from IAAC. FMG uploaded the revised documents to the project website and notified the GRT, Indigenous communities, and the public contact list by email on December 3, 2024. In the email, FMG summarized the changes, provided a link to the updated version of the EA, and offered to send hardcopies of the revised sections upon request.

During the 10-week comment period, the ministry received requests from the GRT and Indigenous communities for extensions to the comment period deadline. The ministry considered all extension requests received and granted extensions to allow additional time, as needed, for the review.

All comments received by the ministry for the EA submission were forwarded to the FMG for response.

Summaries of consultation and comments received by the ministry are provided below. All comments received by the ministry for the EA submission, along with the FMG responses, are included in tables 1 to 3 of appendix B of the ministry review.

Government review team

Consultation with the GRT — including federal, provincial and municipal governments – occurred throughout the EA process. FMGs consultation included document reviews (that is, baseline study reports, workplans, draft EA), technical meetings with the GRT and other specific communications prior to submission of the EA.

A summary of FMGs consultation with the GRT is included in sections 2.6.2 and 2.6.3 of the amended EA. Communication logs and a selection of supporting records were provided in FMGs record of consultation (appendices D-1.2 and D-1.3; and D-2.2 and D-2.3 of the EA). Tables of comments provided by the GRT on baseline study reports and the draft EA, including FMGs responses and references to where FMG considered the comments in the EA submission, are provided in appendices C-1 and C-2 of the EA.

Provincial ministries and agencies

Following the submission of the EA to the ministry, the following provincial GRT members were provided a link to the EA on FMGs website for review:

• Hydro One Networks Inc.
• Independent Electricity System Operator
• Infrastructure Ontario (IO)
• MCM
• Ministry of Economic Development, Job Creation and Trade (MEDJCT)
• MEM
• MECP
• IAFNER
• Ministry of Labour, Immigration, Training and Skills Development
• Ministry of Municipal Affairs and Housing (MMAH)
• MNR
• MNEDG
• Ministry of the Solicitor General
• MTCG
• Ministry of Transportation
• Office of the Fire Marshall (Municipality of Red Lake, Municipality of Sioux Lookout, and Township of Ear Falls)
• Ontario Energy Board
• Ontario Provincial Police

FMG held a virtual government review kick-off meeting on November 13, 2024, to provide a presentation on the layout and organization of the EA and to answer any initial questions from the GRT.

The following provincial GRT members provided comments on the EA submission:

• MECP
• MCM
• MEM
• IAFNER
• MNR
• MNEDG
• MTCG

MEDJCT, MMAH and IO confirmed that they had no comments about the EA. The ministry did not receive responses from the remaining provincial GRT members.

FMG provided responses to the comments received from the provincial GRT. FMG also amended the EA to address certain comments from MECPs Environmental Assessment Branch and MCM. FMGs responses were reviewed by the provincial GRT, and where applicable, follow-up comments were provided to FMG for further response. Technical calls were held with the GRT, as needed, to discuss outstanding comments, FMGs responses and approaches to resolving concerns.

MEM, IAFNER, MNEDG and MTCG confirmed that FMGs responses addressed their comments, or they did not have further comments at this time. MNR, MECPs Species at Risk Branch, MECPs Northern Region Technical Support Section, MCM and MECPs Environmental Assessment Branch each confirmed its comments had been addressed or could be addressed through commitments or conditions of approval for future work prior to permitting.

Table 1, appendix B of this review provides a record of all comments received from the provincial GRT for the EA submission and FMGs responses.

Federal departments

Given the federal EA requirements for the proposed project under the Canadian Environmental Assessment Act, 2012, IAAC coordinated the review of the EA by federal authorities, including:

• Environment and Climate Change Canada
• Fisheries and Oceans Canada
• Health Canada
• Indigenous Services Canada
• Natural Resources Canada
• Transport Canada

IAAC submitted information requests to FMG regarding comments it received related to areas of federal jurisdiction. FMG responded to the information requests by providing responses and additional information directly to IAAC to support its review.

Municipalities

FMG provided a link to the final EA to the following municipalities, including municipal clerks and mayors:

• City of Dryden
• Municipality of Red Lake
• Municipality of Sioux Lookout
• Township of Ear Falls

In January and February 2025, FMG shared with the ministry, letters of support for the project, including letters from Mayor Doug Lawrance of the Municipality of Sioux Lookout, Mayor Fred Mota of the Municipality of Red Lake, and Mayor Kevin Kahoot of the Township of Ear Falls.

Indigenous community consultation

On April 25, 2018, the ministry delegated the procedural aspects of consultation to FMG for the project. A list of Indigenous communities identified as potentially affected and/or interested in the proposed project and who should be consulted for the EA process was provided to FMG. The list included:

• Cat Lake First Nation
• Lac Seul First Nation
• Métis Nation of Ontario (MNO) Northwest Métis Council / Region 1 Consultation Committee (NWOMC)
• Mishkeegogamang First Nation (MFN)
• Ojibway Nation of Saugeen (ONS)
• Pikangikum First Nation
• Slate Falls Nation
• Wabauskang First Nation

As indicated in the delegation letter, FMGs responsibilities for the procedural aspects of consultation include maintaining an accurate and up-to-date record of consultation for each individual community containing all related communications including letters / emails (outgoing and incoming), public notices, meetings (agendas, meeting minutes), and summaries of issues raised and how they were addressed.

The Indigenous communities identified above were provided opportunities by FMG to be consulted in the preparation of the EA, including:

• general project information-sharing activities (for example, sharing project updates, notices, newsletters, monthly community bulletins)
• document reviews (for example, baseline study reports, preliminary alternatives assessment tables, draft EA)
• technical review meetings with communities and their consultants
• development of traditional knowledge / traditional land use studies and information-sharing
• community information sessions and targeted meetings with communities to discuss the proposed project and the EA

FMG indicated in its EA that community-specific consultation approaches were established with Indigenous communities. Approaches remained flexible according to what the communities identified as their preferred approach to consultation throughout the EA process. FMGs consultation methods with Indigenous communities is provided in section 2.5.1 of the amended EA. A summary of FMGs consultation with Indigenous communities is included in section 2.6.1 of the amended EA. Communication logs and a selection of supporting records were provided in FMGs record of consultation (appendices D-1.1 and D-2.1). Tables of comments provided to FMG from Indigenous communities, including FMG responses, are provided in appendices C-3 to C-7. Since the submission of the EA, FMG has provided additional records to the ministry for its continued consultation. The complete record of consultation will be reviewed and considered by the ministry when assessing the Crown’s obligations to consult before making decisions about the proposed project.

Throughout the EA process, the ministry responded to correspondence from Indigenous communities, and met with Indigenous communities, when requested. On June 10 and December 8, 2021, the ministry met with the shared territory protocol nations Springpole environmental committee, including representatives from Cat Lake First Nation, Lac Seul First Nation and Slate Falls Nation, to discuss baseline report comments and the provincial EA process. In January and February 2023, the ministry sent letters to all Indigenous communities identified for consultation for the EA, extending offers to meet to discuss the provincial EA process. On April 18, 2023, the ministry met virtually with NWOMC, FMG, and IAAC, where FMG presented on the project and discussed concerns raised by NWOMC. On May 24, 2023 the ministry met virtually again with NWOMC, alongside MEM to discuss the project, the EA process and the Environmental Assessment Act and Mining Act. 

The formal submission of the EA to the ministry on November 8, 2024, marked the start of the ministry-led comment period on the EA. Prior to the formal submission date, a link was distributed by FMG to Indigenous communities providing the EA documents on FMGs website. FMG also provided hardcopies to Indigenous communities, where requested.

Ministry-led consultation activities are described in the sections below. Table 3, appendix B of the ministry review provides a record of the comments received by the ministry from Indigenous communities for the EA and FMGs responses to the comments.

Shared territory protocol nations (STPN)

In 2017, Cat Lake First Nation (CLFN), Lac Seul First Nation (LSFN) and Slate Falls Nation (SFN) entered into a shared territory protocol agreement with respect to consultation for the proposed project. The communities worked together to provide input to the EA process through the shared territory protocol nations Springpole environment committee established in 2021. In December 2023, SFN decided to move forward independently regarding consultation for the proposed project. CLFN and LSFN continued to work together for consultation. 

During the EA process, the STPN wrote to FMG on several occasions, copying the ministry, to express concerns with the proposed project and consultation. Letters were also exchanged between the STPN and Ontario ministries in 2022, 2023 and 2024 on topics related to the proposed project.

In a letter to FMG dated March 30, 2022 (copying Ontario ministries and IAAC), the STPN proposed that an Anishinaabe-led impact assessment (ALIA) of the proposed project be undertaken independent of the provincial and federal EA processes. The letter also called for a moratorium on all FMG activities on the STPNs respective lands.

In 2 letters dated September 15 and September 20, 2022, the STPN wrote to IAAC and FMG respectively (copying the ministry) regarding FMG’s extension to provide the required information and studies for the environmental assessment under the Canadian Environmental Assessment Act, 2012 (CEAA). The STPN stated that they were not consulted on the extension and raised concerns for an extension under the CEAA, stating that the Act is outdated and fails to reflect their rights, values and traditions. The STPN requested that IAAC reconsider the extension, or to allow an extension it must designate the project under the current Impact Assessment Act.

FMG responded to the STPN letter on October 11, 2022 (copying the ministry) stating that the extension to the federal assessment process intends to also allow the STPN the time required to develop its assessment process for the ALIA. FMG proposed to meet with the STPN for further discussions.

On October 13, 2022, IAAC responded to the STPN letter (copying the ministry), recognizing the lack of consultation with the STPN on the extension. IAAC proposed to meet with the STPN to discuss the goals of the ALIA and how they can be achieved under the CEAA.

On November 25, 2022, a letter was sent from the STPN Chiefs to the Ministry of Northern Development and Indigenous Affairs (copying the ministry) seeking a meeting to discuss the undertaking of the ALIA.

On January 10, 2023, the ministry sent a letter to the STPN Chiefs acknowledging the concerns raised and offering to meet with the communities to discuss their concerns, as well as how an ALIA could inform the provincial EA.

In letters to FMG and Ontario ministers dated January 19, 2023, and May 4, 2023, the STPN Chiefs requested an in-person meeting with the ministers to discuss the provincial EA process, support for the ALIA and other items. On July 5, 2023, the former Minister of the Environment, Conservation and Parks responded, acknowledging the communities’ comments and noting that the ministry’s Environmental Assessment Branch would reach out to schedule a meeting. On September 19, 2023, the ministry followed up by letter with an offer to meet, however, no response was received.

As mentioned, the relationship of the STPN changed in December 2023. The ministry’s consultation with CLFN and LSFN, and SFN respectively, is further described in separate sections below.

Cat Lake First Nation and Lac Seul First Nation

Prior to the formal submission date, the EA was circulated to CLFN and LSFN separately with a memo from the ministry requesting the communities’ review of the EA.

In a letter dated November 12, 2024, on behalf of CLFN and LSFN, the communities’ government relations coordinator confirmed receipt of the EA and provided information to the ministry, FMG, and IAAC regarding the anticipated timelines for its review pursuant to the communities Anishinaabe-led “Kita-Ki-Nan” process. On November 27, 2024, CLFN met with senior officials at the ministry, MNR, MEM and IAFNER to discuss a number of items including the Kita-Ki-Nan process and timelines for the communities’ assessment. On January 14, 2025, the ministry responded to CLFN and LSFNs letter acknowledging the timelines for CLFN and LSFNs review of the EA and noting an interest to meet with CLFN and LSFN to better understand the Kita-Ki-Nan process.

On January 31, 2025, CLFN and LSFN submitted a letter commenting on the sufficiency of the EA, based on the communities’ Kita-Ki-Nan sufficiency review. The letter identified a number of concerns and perceived gaps with respect to the EA, including limited Indigenous involvement and integration of Indigenous knowledge in the EA process, missing or incomplete information, and concerns regarding the robustness of mitigation and monitoring measures. CLFN and LSFN also questioned the assessment of environmental, social, health, economic, and cumulative effects, including the consideration of potential impacts on Indigenous rights and culture. On February 10, 2025, CLFN and LSFN submitted technical comments on the EA. Key issues raised included incomplete baseline data related to geochemistry and hydrology, lack of methodological clarity and consistency, concern regarding the co-disposal facility, and uncertainty in predicting and managing water-related impacts. Both sets of comments were sent to the ministry, IAAC and FMG directly.

Throughout March and April 2025, the ministry exchanged letters with the Kita-Ki-Nan project coordinator (on behalf of CLFN and LSFN) about the Kita-Ki-Nan process, the EA process and, the communities’ concerns with the co-disposal facility component of the project. The communities’ requested the ministry’s technical review records related to the co-disposal facility and requested to meet with the ministry for further technical discussion on this topic.

On May 7, 2025, FMG provided responses to the sufficiency and technical comments submitted by CLFN and LSFN.

On June 13 and July 8, 2025, virtual meetings were held between provincial reviewers, CLFN and LSFN technical consultants and the Kita-Ki-Nan Project Coordinator, IAAC and FMG to discuss the EA, the co-disposal facility and geochemistry.

At the June 13, 2025, meeting, CLFN and LSFN raised concerns regarding the long-term performance of the co-disposal facility, potential failure scenarios, and uncertainties related to acid generation, seepage, and the lack of comparable examples in similar environmental settings. CLFN and LSFN requested further analysis and clearer communication on these topics. CLFN and LSFN also identified insufficient inclusion of geochemistry expertise and Indigenous input and requested additional technical sessions and opportunities for Indigenous participation in monitoring and planning.

In response, FMG indicated that co-disposal facility design and water management would continue to be refined through subsequent design and permitting stages. FMG noted that monitoring approaches, effluent criteria, and any potential project modifications, including discharge locations, would be addressed through future regulatory processes, with opportunities for Indigenous community review within existing approval frameworks. Where questions could not be fully addressed during the session, particularly regarding geochemical stability, long-term performance, failure consequences, and financial assurances, FMG indicated further study, design development, and regulatory review would be required. FMG committed to providing additional technical information to continuing technical engagement with CLFN and LSFN.

At the July 8, 2025, meeting, CLFN and LSFN reiterated concerns regarding uncertainties in geochemical behaviour, sampling methodologies, acid rock drainage and metal leaching modelling, and the reliability of tailings and water quality predictions. FMG provided additional technical information in response, acknowledged the remaining information gaps and indicated they would provide follow-up materials, including further analysis and clarification of modelling assumptions. FMG also committed to ongoing engagement with CLFN and LSFN, including additional technical discussions as needed and continued consultation during testing and design refinement.

On July 21, 2025, the ministry shared provincial comments related to the co-disposal facility and seepage with CLFN and LSFN per the communities’ request.

CLFN and LSFN submitted additional information requirements for the EA to FMG on August 15, 2025, which were subsequently shared with the ministry in September 2025. These were shared with the ministry in September 2025.  Additional correspondence between the Kita-Ki-Nan Project Coordinator and the ministry clarified the intent of the submission and confirmed the communities' outstanding concerns with the proposed project. Key outstanding areas of concerns identified by CLFN and LSFN include gaps in available data and analysis, limited integration of Indigenous perspectives, uncertainty regarding potential environmental and cultural effects, and a lack of confidence in proposed mitigation, monitoring, and long‑term management approaches.

In a September 11, 2025, email exchange, the ministry requested a meeting with CLFN and LSFN to discuss the communities’ outstanding comments and to discuss next steps for the EA process but was informed that CLFN and LSFN would not meet with the ministry at that time. On October 16, 2025, the ministry sent a letter acknowledging the communities’ decision not to meet. The letter reiterated the ministry’s interest in learning about the Kita-Ki-Nan process and how it can inform the provincial EA process, and the ministry offered to remain available to meet at the communities’ convenience. Additional letters were exchanged in November and December 2025 with information about the communities' concerns and next steps for the EA process.

In August and September 2025, the ministry exchanged emails with the Kita-Ki-Nan project coordinator regarding the provision of confidential Indigenous Knowledge to the ministry for consideration in the EA process. In September 2025, CLFN and LSFN shared with the ministry a Kita-Ki-Nan archaeology and heritage memo (which was subsequently shared with MCM), and socio-economic and Indigenous knowledge reports. The ministry acknowledged receipt of the submissions and undertook a review of the documents.

In a letter to the ministry, dated November 10, 2025, CLFN and LSFN indicated their interest in continuing to participate in the provincial EA process. However, they advised that they did not have the capacity to engage at that time due to their focus on the Kita‑Ki‑Nan process, and requested information regarding anticipated timelines for the provincial EA process.

On November 14, 2025, the ministry was copied on a letter (dated October 17, 2025) from the Chief Russell and Chief Bull to the Minister of Citizenship and Multiculturalism raising concerns with the archaeological work conducted for the proposed project to-date. The Kita-Ki-Nan process report on the review of the archaeological and heritage assessment completed for the EA was shared with the letter.

FMG provided their responses to CLFN and LSFN information requirements directly to the communities on November 18 and December 10, 2025 (the ministry was made aware of the response on March 11, 2026).

On December 10, 2025, the ministry shared with CLFN and LSFN a letter responding to the November 10, 2025, letter confirming receipt of CLFN and LSFNs submissions and providing information about next steps for the provincial EA process and offering to meet with CLFN and LSFN at their convivence.

On February 23, 2026, the ministry received an email from CLFN and LSFN legal counsel requesting to meet with the ministry and MEM to discuss outstanding concerns about the co-disposal facility and water quality. The ministry acknowledged the request and confirmed they would coordinate the scheduling of the meeting. The meeting was scheduled for March 26, 2026, and included representation from MECP, MNR, MEM and CLFN and LSFN. The ministry and CLFN and LSFN continued correspondence leading up to the March 26, 2026, meeting. Prior to the meeting CLFN and LSFN shared with the ministry a meeting agenda and memo.

On March 19, 2026, CLFN and LSFN legal counsel shared in an email to the ministry and IAAC the draft extended summary for the Kita-ki-nan process for the project. The ministry responded to CLFN and LSFN, confirming receipt of the report. In the March 26, 2026, meeting, the ministry, MNR and MEM met virtually with CLFN and LSFN technical consultants and legal counsel to discuss the co-disposal facility and hydrogeological assessments and water quality for the project. The ministry’s technical specialists responded to questions related to seepage management and mitigation and discussed potential conditions to address CLFNs and LSFNs concerns. During this meeting it was decided that an additional meeting with the ministry’s Species at Risk Branch would be arranged to better address CLFN and LSFNs comments and concerns related to caribou. Correspondence continued between the ministry and CLFNs and LSFN and a meeting on caribou was scheduled for April 1, 2026.

The ministry, including representatives from the Species at Risk Branch, met virtually with CLFN and LSFN technical consultants and legal counsel on April 1, 2026 to discuss caribou. Items related to potential impacts to caribou in the Churchill boreal caribou range, including mitigation and monitoring were addressed by the ministry’s Species at Risk specialists. During this meeting, an additional meeting between the ministry, MNR and CLFN and LSFN was proposed by the ministry to discuss CLFNs and LSFNs comments and concerns on matters related to forestry management. Following the meeting, the ministry followed up with CLFN and LSFN offering to arrange a meeting to discuss forestry management with MNR. No response has yet to be received from CLFN and LSFN in regards to this meeting.

CLFN and LSFN have indicated that they are in the process of finalizing the Kita‑ki‑nan report. The Nations are expected to hold community voting on June 4, 2026. The outcome of which will inform the Nations final determination on the acceptability of impacts in the final Kita-ki-nan report and their consent decisions.

Slate Falls Nation

As mentioned, as of December 2023, SFN decided to move forward independently from the STPN regarding consultation for the proposed project and the EA. SFN is undertaking a separate Indigenous-led assessment of the proposed project (ALIA). This process has informed comments provided to FMG and the ministry for the EA.

Prior to the EA submission, SFN sent a letter to the former Minister of the Environment, Conservation and Parks (dated October 4, 2024) providing information about the ALIA process and expressing concerns about FMG’s consultation. The letter explained that the community had expected the ALIA to inform the preparation of the EA, however, that had not occurred. The letter expressed concerns that it had not received capacity support or technical information required to be meaningfully consulted and that it had not received meaningful responses from FMG to the comments provided on the draft EA. SFNs letter raised additional concerns with the proposed project and the EA process, and informed the ministry that SFN would not be able to provide comments on the EA until February 28, 2025.

On October 30, 2024, SFNs project coordinator shared with the ministry a letter from SFN to FMG requesting that FMG agree not to submit the EA document until the ALIA is completed and incorporated into the EA.

Prior to the formal submission date, the EA was circulated to SFN with a memo from the ministry requesting the community’s review of the EA. The ministry followed up by email and phone in November 2024 to confirm receipt by SFN.

On November 29, 2024, the former Minister of the Environment, Conservation and Parks responded to SFNs October 4^th letter acknowledging the challenges that SFN experienced in the EA process and the importance of the ALIA for SFN, and granting the community and extension to provide comments on the EA by February 28, 2025.

From December 2024 to February 2025, the ministry exchanged correspondence with SFN regarding SFNs offer to present an overview of its EA review process to the ministry. On February 24, 2025, a virtual meeting was held during which SFNs consultants provided an overview of its review including major comments and concerns. Key concerns raised in the presentation were related to the co-disposal facility, impacts to waterbodies, impacts to species at risk, and concerns with FMG’s consultation and integration of SFN input and knowledge in the EA.

On February 29, 2025, SFNs consultant, on behalf of SFN, submitted comments on the EA. SFN indicated that the EIS does not meet applicable requirements and does not adequately assess potential effects on the environment or on the exercise of Aboriginal and treaty rights. SFN raised concerns regarding the adequacy of consultation and engagement, the incorporation of Indigenous knowledge and the community‑based land use plan (CBLUP), and the credibility of the proponent’s assessment, mitigation measures, and project design. SFN further identified risks related to water quality, ecological integrity, cultural heritage, and cumulative effects, and expressed a lack of confidence that the project, as currently assessed, would avoid or appropriately manage adverse effects. The ministry acknowledged receipt of the comments and shared the comments with FMG for response. Over several months, FMG shared batches of responses to SFNs comments directly with the community.

From March to June 2025, the ministry exchanged emails and phone calls with SFNs Project Coordinator to set up virtual meetings to discuss SFNs comments. In a letter to the ministry, dated May 16, 2025, Chief Crane expressed concerns that SFN had not received a response from the ministry to its comments on the EA. The letter requested an opportunity to meet with the ministry to discuss the community’s concerns.

In April and May 2025, the ministry was also copied on letters exchanged between SFN and FMG about the EA, SFNs concerns and capacity funding.

On June 10, 2025, the ministry and MCM met virtually with SFNs consultants and SFNs project coordinator to discuss SFNs comments on the archaeological assessments for the EA. SFN identified gaps in archaeological work, including incomplete stage 2 assessments, missing or unverified sites, and limited consideration of culturally important areas such as historic portage routes. SFN emphasized that these areas remain significant despite limited physical evidence and raised additional concerns about downstream water quality impacts and risks associated with the co‑disposal facility. SFN indicated the project is not aligned with its CBLUP and suggested that alternative design approaches should be considered. Ministry staff noted they had not yet reviewed the proponent’s responses but welcomed the discussion and indicated openness to further technical engagement.

Following the meeting, on June 12, 2025, the ministry responded to Chief Crane’s May 16^th letter acknowledging SFNs comments on the EA, noting that a call had been held, and offering to facilitate scheduling additional calls between SFN and government reviewers to discuss the community’s comments. Additional technical meetings took place virtually on June 25, 2025, and July 15, 2025, with SFNs technical team, FMG, and provincial reviewers the ministry, MNR and MEM to discuss SFNs concerns related to the mine design, the co-disposal facility and associated systems, closure plans, and related risks and consequences. 

On December 23, 2025, SFN shared a letter (dated December 18, 2025) to the ministry and MEM asserting inadequate consultation, unresolved technical and environmental risks, and significant potential impacts on its rights. SFN emphasizes that both the proponent and Ontario have failed to respect and apply the CBLUP, including proposing development within the 2 km protection buffer without consent and ignoring commitments to integrate the CBLUP into project design. SFN argues that this failure undermines water protection, cultural values, and land use priorities central to its way of life. SFN called for alignment of the project with the CBLUP before any approval is considered and provided a list of questions for the ministry’s consideration and response. The ministry acknowledged receipt of the letter on January 7, 2026. After reviewing FMG’s responses to SFN comments, on February 19, 2026, SFN submitted a second round of comments (information requirements) with outstanding concerns.

On March 5, 2026, SFN legal counsel shared with the ministry and IAAC a letter (dated February 18, 2026) following up on SFNs letter dated December 18, 2025, and providing a set of materials regarding anticipated impacts to SFN rights. The letter included a summary of outstanding Crown engagement requirements and additional information regarding adverse impacts of the Project and provided the ALIA for consideration.

In March 2026, SFN technical consultants and legal counsel submitted supplementary materials to the ministry and IAAC including a summary report of SFN workshops related to risk reduction for the Springpole Project and copies of 2 band council resolutions regarding CBLUP. The ministry acknowledged receipt of all materials received.

On April 22, 2026, the ministry shared with SFN Chief Crane a response letter to the correspondence dated December 18, 2025, and February 18, 2026. The ministry recognized the delay in response and shared an update on the status of the EA issue resolution process including the ongoing technical reviews and engagement with FMG. The letter addressed items raised by SFN, including the ministry’s position and consideration of cumulative effects, archaeology, United Nations Declaration on the Rights of Indigenous Peoples, CBLUP, and potential accommodation measures.

The ministry confirmed receipt of the ALIA and its consideration as part of the EA process. The letter reiterated the ministry’s commitment to continued dialogue with SFN and describes the next steps in the EA process, including opportunities for further meetings, and upcoming participation by SFN during the ministry review and final comment period.

On May 15, 2026, SFN shared with MEM and the ministry a response letter to a letter shared with SFN, from MEM, on April 15, 2026, regarding the project. In the May 15, 2026 letter, SFN described unresolved issues related to the project, including unmitigated impacts to SFN rights, inconsistency with the CBLUP (including development within the 2 km buffer), and environmental and design risks, while highlighting significant information gaps and asserting that Ontario has failed to meaningfully consult or address these unresolved issues before moving toward approval. SFN provided previously posed and unresolved questions and requested formal consultation and accommodation by the ministry prior to the continuation of any assessment or decision-making processes for the project.

On May 20, 2026, the ministry shared with SFN FMG responses to the second round of comments (information requirements) from SFN.

Metis Nation of Ontario Northwest Ontario Metis Council / Region 1 Consultation Committee

Prior to the formal submission date, the EA was circulated to the NWOMC with a memo from the ministry requesting review of the EA. On November 22, 2024, the MNOs Lands, Resources and Consultations Branch confirmed receipt of the EA over the phone.

On December 5, 2024, the ministry, the NWOMC, the MNO Lands, Resources and Consultations Branch, FMG, and IAAC met virtually to discuss the provincial and federal EA processes and the NWOMCs initial review of the EA.

On December 20, 2024, the NWOMC submitted comments on the EA. NWOMCs review concluded the EA relies too heavily on biophysical analysis and does not meaningfully assess impacts on Métis rights, including broader and behavioural effects on the ability to exercise of those rights. NWOMC also raised concerns that the proposed mitigation measures are insufficient and calls for additional co-developed measures with NWOMCs involvement and consultation in decision-making, monitoring, and plan development. NWOMC also requested binding approval conditions to confirm mitigation and engagement commitments are implemented and enforceable.

FMG provided their response to NWOMCs comments on January 31, 2025.

On February 20 and 21, 2025, the ministry received letters from the Regional Councillor for the NWOMC and Chair of the v Region 1 Consultation Committee and the president of the MNO, both confirming that the NWOMC and the MNO understand the potential effects of the proposed project and the EA on the rights, interests and claims of the NWOMC and MNO citizens, acknowledge that any potential effects of the proposed on Métis section 35 Rights have been sufficiently accommodated by FMG, and consent to and support the proposed project. The ministry confirmed with the MNO Lands, Resources and Consultations Branch that the letters were intended to confirm that the NWOMC has no outstanding comments on the EA.

Mishkeegogamang First Nation

Prior to the formal submission date, the EA was circulated to MFN with a memo from the ministry requesting the community’s review of the EA. The ministry followed up in November and December 2024 by email and phone in attempt to confirm receipt by MFN.

In a letter to the ministry and IAAC, dated December 20, 2024, Chief Loon expressing concerns with timelines for the review and requesting an extension to the comment period deadline until April 30, 2025. The ministry responded on March 3, 2025, granting the extension.

MFN did not provide comments to the ministry by the extended deadline. The ministry followed up after the deadline to confirm whether MFN still planned to submit comments about the EA.

In a letter to the ministry and IAAC, dated July 28, 2025, Chief Loon explained that MFN had worked closely with FMG throughout the EA process. The letter indicated that MFN had reviewed the EA with its independent technical experts, and that comments / questions were provided directly to FMG and meetings were held between MFN and FMG to discuss various aspects of the proposed project. The letter confirmed that MFNs questions and comments on the EA had been addressed by FMG, that MFN does not need to be further engaged in the EA process, and that MFN supports development of the proposed project. The ministry confirmed receipt of the letter by email on July 30, 2025.

Ojibway Nation of Saugeen

Prior to the formal submission date, the EA was circulated to ONS with a memo from the ministry requesting the community’s review of the EA. The ministry followed up by email and phone, and on November 28, 2024, the ONS band office confirmed receipt of the EA.

Throughout December 2024 and January 2025, the ministry followed up by email and phone to confirm whether ONS planned to provide comments to the ministry, and in January 2025, emails and phone calls were exchanged between the ministry and ONSs consultant regarding the status of ONSs review and a potential request for extension to the comment period deadline. After additional follow up by the ministry in March 2025, ONSs consultant confirmed that ONS would need until April 30, 2025, to confirm funding for its review and potentially until December 31, 2025, to provide comments to the ministry on the EA.

On March 24, 2025, the ministry responded by letter granting an extension to ONS to provide comments on the EA by April 30, 2025, and offering to meet with the community to discuss it comments in the interim. On April 2, 2025, ONS consultant responded by email expressing concerns with capacity and funding for the EA review. The email requested capacity funding from Ontario. On April 28, 2025, the ministry responded by letter explaining that the procedural aspects of consultation, including bearing reasonable costs, had been delegated to First Mining Gold. The letter explained that, while no capacity funding was available from the ministry, the ministry was grateful for ONS participation in the EA process and would be available to meet with ONS to discuss consultation and comments on the EA, as well as facilitate discussions between ONS and FMG as needed.

On May 1, 2025, ONS consultant, on behalf of ONS, submitted comments on the EA. The comments were also sent directly to FMG. ONS stated that the EA reflects insufficient consultation and limited inclusion of its traditional knowledge. ONS identified gaps in baseline data, methodology, and assessment, particularly in relation to Indigenous rights, land use, and culturally important resources. ONS called for ongoing engagement, formal commitments, and active involvement in mitigation, monitoring, and future project planning.

FMG responded to ONS comments on July 15, 2025. On August 29, 2025, ONS consultant confirmed by email that ONS had no further comments at that time and that ONS was continuing to engage with FMG.

Pikangikum First Nation

Prior to the formal submission date, the EA was circulated to Pikangikum First Nation with a memo from the ministry requesting the community’s review of the EA. The ministry reached out to Pikangikum First Nation multiple times by email and phone during the EA comment period, as well as after the comment period ended, to confirm if Pikangikum First Nation would be providing comments on the EA.

In January 2025, the ministry was informed that the community had held elections, and the ministry reached out to the newly elected Chief about the EA and whether Pikangikum First Nation would be providing comments to the ministry. After additional attempts from the ministry to follow up with Pikangikum First Nation, the ministry did not receive a response.

Wabauskang First Nation

Prior to the formal submission date, the EA was circulated to Wabauskang First Nation with a memo from the ministry requesting the community’s review of the EA. On December 19, 2024, the Obaushkong Aki (Wabauskang resource office) confirmed receipt of the EA, noting the submission was being considered by Wabauskang First Nation Chief and Council.

On January 21, 2025, the Obaushkong Aki (Wabauskang resource office) provided the ministry with a statement from Wabauskang First Nation Chief and Council which stated that the community does not have land use values at the mine footprint, however, concerns with water remain. The comments raised concerns about potential impacts to water post-closure and impacts from the environment on the proposed project (for example, potential floods, forest fires, and other potential catastrophic climate events). On February 28, 2025, the ministry shared FMGs responses with Wabauskang First Nation for review.

After attempts from the ministry to follow up with Wabauskang First Nation to determine if the responses addressed Wabauskang First Nation’s concerns, the ministry did not receive a response from Wabauskang First Nation.

All comments from Indigenous communities submitted for the final EA are provided in table 3 of appendix B of this review, including FMGs responses to the comments. 

Public consultation

FMG consulted with the public by distributing public notices and newsletters, establishing a project website where EA-related documents (including the draft EA) were made available for public review, conducting in-person public information sessions and online public webinars, attending community events, and directly engaging with stakeholders and the public via targeted mail-outs and meetings with interested parties.

Public information sessions were held by FMG in:

• Municipality of Sioux Lookout (September 15, 2021; July 20, 2022; and May 31, 2023)
• Township of Ear Falls (December 16, 2021; July 19, 2022; and May 30, 2023)
• Municipality of Red Lake (November 29, 2023)
• City of Dryden (November 30, 2023)

A series of virtual public webinars were also held in October 2022 and November 2023 on various EA topics.

A summary of FMGs consultation with public stakeholders was included in section 2.6.4 of the amended EA. Communication logs and a selection of supporting records were provided in FMGs record of consultation (appendices D-1.4 and D-2.4).

During the 10-week ministry-led comment period on the EA submission, comments received by the ministry were generally supportive of the project. 32 letters of support were submitted for the proposed project during the comment period – either directly to the ministry or shared with the ministry from FMG. These include letters of support from:

• AGAT Laboratories
• Automation Now
• Bayside Geoscience
• CLAC
• Confederation College Workforce Development
• First Nation Safety and Training
• Forest Helicopters
• Fresh Market Foods
• Gear Up For Outdoors Ltd.
• GN Bio Energy
• IBEW 402
• LTL Contracting Ltd.
• Mahon Electric
• MineConnect
• Morgan Fuels
• Multicrete Contracting Inc.
• Municipality of Red Lake
• Municipality of Sioux Lookout
• NextEra Energy Canada
• NORCAT
• NorthStream Safety and Rehab
• Northern Mat & Bridge
• Northwestern Ontario Building And Construction Trades Council
• Ontario Mining Association
• Perron Contracting
• Rodren Drilling Ltd.
• Sheet Metal Workers’ International Association
• TBT Engineering Ltd.
• Thunder Bay Chambers of Commerce
• Thunder Bay Community Economic Development Commission
• Township of Ear Falls
• Veolia

One member of the public provided 2 comment submissions to the ministry during the comment period expressing concerns with the proposed project. The comments raised concerns for the proposed transmissions line’s proximity to outfitting camps and requested adjustments to parts of the corridor’s location. In their comment response, FMG did not commit to rerouting the transmission line at the requested location, however, FMG noted previous route optimizations and provided a commitment to future engagements with the outfitter as the project progresses through the engineering and processing phases.

Table 2, appendix B of this review, provides a record of the comments received from the public for the EA, including FMGs responses to the comments.