MiningWatch Canada Comments on the Draft Amended Agreement to Re-establish a Joint Review Panel for the Marathon Palladium Project

Reference Number
Date Submitted
2020-10-26 12:00:00 AM

attn. Cindy Parker
Panel Manager, Review Panels Division
Marathon Palladium Project
Impact Assessment Agency of Canada

Reference Number 54755

MiningWatch Canada is very concerned about the fact that this review is being resumed after seven years, with a different proponent, as if nothing had changed in the biophysical or socio-economic environments or with the project itself. It is a clear deficiency in the legislation that allows this to take place, when the proposal should clearly be treated as a new project, albeit one that can benefit from the preparatory work was done for the previous proposal.

We note that the fifteen day comment period on the draft Amended Joint Review Panel Agreement and Terms of Reference for the Environmental Assessment and the associated Terms of Reference for the Joint Review Panel is too short, and indeed we were not able to finalise these comments before now. Apart from the pressures of the COVID-19 pandemic, reopening files and reinitiating work after nearly seven years (and on short notice) is not a trivial matter.

We note that the Joint Review Panel is being allowed significantly less time for a review that presumably will have similar scope and depth as the original review (271 days vs. 390 days). This is unacceptable, as is the idea that the proponent will not be required to submit its own environmental impact statement (EIS), but just an “addendum” to the “original EIS”.

The areas of concern will be discussed later in our comments on the draft documents but are noted here as to significant decisions that appear to have been already made, and which – if not reversed – may prove fatal to the integrity and effectiveness of this review, and of the review’s ability to gain public confidence in either its conduct or outcomes.

It is important to note that Generation Mining Inc., a junior mining company with no track record of actually building and operating a mine, is seeking to start the project assessment without having completed a project feasibility study. Given that the previous proponent’s inability to clearly commit to the viability of the project led to the suspension of the review process, and that the previous proponent was at least an established mining company, the Joint Review Panel clearly cannot begin work until proponent has completed its feasibility study. Any other course of action risks once again wasting the money, time, and effort of the Impact Assessment Agency, the Joint Review Panel itself, and significantly, public and Indigenous participants.

In this demand, we support Northwatch, as well as in the more detailed and specific comments that Northwatch has submitted in PDF format directly to the Agency. The environmental assessment process does not exist to boost proponents’ share prices by providing free publicity and the pretense that it is promoting a viable project, and in order to maintain any public credibility – not only for the environmental assessment process, but the competence of both federal and provincial governments – the review needs to be delayed to allow for meaningful public participation, but also to ensure that there really is a viable project being proposed.


Jamie Kneen,
MiningWatch Canada

Jamie Kneen, Communications & Outreach Coordinator, MiningWatch Canada
<contact information removed>

Submitted by
Administrator on behalf of MiningWatch Canada
Referral to Review Panel
Public Notice
Public Notice - Marathon Palladium Project - Public comments invited on the draft Amended Joint Review Panel Agreement and Terms of Reference
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