Minister's Response – PADCOM Potash Solution Mining Project

Physical Activities

Potash and Agri Development Corporation of Manitoba (PADCOM) Ltd. (the Proponent) is proposing the construction and operation of the PADCOM Potash Solution Mining Project (the physical activities) for the extraction and processing of potash. As proposed, the physical activities would be located in the hamlet of Harrowby, approximately 16 kilometres west of Russell, Manitoba, and include a potash processing facility with a centrifuge and dryer. Potash would be mined using hot brine injected and extracted via production wells. The physical activities would have a surface footprint of approximately one hectare and an underground pipeline loop that extends approximately 1,600 metres horizontally to access the potash, and will produce up to 250,000 tonnes of potash per year with an expected life of 60 to 100 years.

Information Considered

Pursuant to section 9 of the Impact Assessment Act (the IAA), I, Steven Guilbeault, Minister of Environment and Climate Change Canada, considered the potential for the physical activities to cause adverse effects within federal jurisdiction; adverse direct or incidental effects; public concerns related to these effects; as well as adverse impacts on the Aboriginal and Treaty rights of the Indigenous peoples of Canada.

In forming my opinion, I took into account the analysis prepared by the Impact Assessment Agency of Canada, which included consideration of correspondence received from the requester, Indigenous groups, and the public; comments submitted to the province of Manitoba from the public and provincial Technical Advisory Committee during the provincial environmental assessment process; and information provided by the Proponent, federal authorities, and the province of Manitoba.


The physical activities do not warrant designation.


I am of the opinion that the physical activities do not warrant designation for the following reasons:

  • The physical activities are small in scale and located on previously disturbed land. Their potential to cause adverse effects within federal jurisdiction is limited.
  • Any potential adverse effects within federal jurisdiction, and related concerns, are expected to be managed by Manitoba's legislative mechanisms and through compliance with relevant federal legislation.
  • Provincial legislative mechanisms include:
    • the provincial environmental assessment and licensing process under Manitoba's The Environment Act, which includes enforceable licence conditions to mitigate potential environmental effects for all stages of the development;
    • other provincial legislation, as applicable, such as The Endangered Species and Ecosystem Act, The Oil and Gas Act, The Heritage Resources Act, and The Water Rights Act; and
    • that the provincial Crown will address impacts to Aboriginal and Treaty rights that may result from provincial approvals for the physical activities.
  • Federal legislative mechanisms include:
    • the Fisheries Act in relation to any potential effects to fish and fish habitat; the Migratory Birds Convention Act, 1994, in relation to any potential effects to migratory birds; and the Species at Risk Act in relation to any potential effects to species at risk and their critical habitat; and
    • other federal legislation that may apply such as the Canadian Environmental Protection Act, 1999.
  • Carrying out of the physical activities is not expected to result in adverse direct or incidental effects. No federal authority is expected to exercise a power or perform a duty or function that could permit the carrying out of the physical activities or provide financial assistance to any person for the purpose of enabling the physical activities to be carried out.

Document Reference Number: 3

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