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Attachment BN Letter to IAAC: Consultations with GenPGM on Potential Federal EA Conditions

  • Marathon Palladium Project
  • Author: Administrator on behalf of Biigtigong Nishnaabeg First Nation
  • Reference number: 1328
  • Submitted: 2022-10-28 - 9:25 AM
  • Project phase: Decision making
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • Please see the attached submission
  • Attachment included
  • A I. RI KIT !GONG NISI INAAREG Via E-Mail - IAAC.Conditions.AEIC@iaac-aeic.gc.ca Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Ottawa, ON K1A 0H3 October 26, 2022 Re: Consultations with Generation PGM Inc. on the Potential Draft Federal Environmental Assessment (EA) Conditions for the Marathon Palladium Project (Ref No. 54755) To Whom It May Concern, Generation PGM Inc, (GenPGM) has consulted Biigtigong Nishnaabeg on the contents of GenPGM's submissions regarding the potential draft federal environmental assessment conditions for the Marathon Palladium Project. Biigtigong Nishnaabeg accepts that the recommendations of GenPGM with respect to the timing of actions and deliverables advanced by GenPGM in their proposed changes to the conditions, in particular, as set out in conditions 5.2, 5.3, and 6.4.3, would be protective of Biigtigong Nishnaabeg's interests in its unceded, unsurrendered and exclusive Aboriginal Title territory. Biigtigong Nishnaabeg also confirms its comfort with the revised comments on condition 6.4, recently submitted by GenPGM, wherein GenPGM commits to the development of the air quality follow-up program as soon as possible, and in any event not later than 3 months following the commencement of construction. Miigwe Chief Duncan Michano Biigtigong Nishnaabeg BIIGTIGONG NISHNAABEG <Original signed by> <contact information removed> <email address removed>

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Attachment From Generation PGM Inc. re: Comments on Potential Conditions

  • Marathon Palladium Project
  • Author: Administrator on behalf of Generation PGM Inc.
  • Reference number: 1329
  • Submitted: 2022-10-27 - 7:14 PM
  • Project phase: Decision making
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • Please see the attached submission
  • Attachment included
  • GENERATIONPGM ____________________________________________________________________________________ Generation PGM Inc. TSX: GENM First Canadian Place, 100 King Street West, Suite 7010 www.genmining.com P.O. Box 70, Toronto, ON M5X 1B1 Tel: 416-640-0280 October 27, 2022 Via E-Mai l - IAAC.Condit ions.AEIC@iaac-aeic.gc.ca Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Ottawa, ON K1A 0H3 To Whom it May Concern: Re: Generation PGM ("GenPGM") Marathon Palladium Project ("Project") GenPGM Comments on Draft Conditions Further to our letter of October 23, 2022, to the Impact Assessment Agency of Canada ("IAAC") regarding our comments on the potential federal environmental assessment conditions for the Project (the "Draft Conditions"), we are writing to inform you that after further consultation and consideration, we wish to revise our comment in respect of Condition 6.4 to replace the references to 8 months with 3 months, as follows: The Proponent shall immediately initiate the development of a follow-up program to verify the accuracy of the environmental assessment and to determine the effectiveness of the mitigation measures as it pertains to the adverse environmental effects on the health of Indigenous Peoples caused by changes to air quality. The Proponent shall develop this follow-up program, as soon as possible, and in any event not later than 83 months following the commencement of construction, and in consultation with Biigtigong ...
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Attachment Environment and Climate Change Canada's Comments on Potential Conditions for Marathon Palladium Project

  • Marathon Palladium Project
  • Author: Administrator on behalf of Environment and Climate Change Canada
  • Reference number: 1326
  • Submitted: 2022-10-26 - 11:14 AM
  • Project phase: Decision making
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • Please see the attached submission
  • Attachment included
  • Marathon Palladium Project ECCC’s Review of the Draft Potential Conditions Page 1 of 5 TABLE 1: PROPOSED EXPERT COMMENTS ON POTENTIAL CONDITIONS TO INCLUDE IN SUBMISSION TO IAAC, OCTOBER 21, 2022 Issue # Reference to Draft Condition Draft Condition (Original) Comment Draft Condition ECCC - 01 1.2.5 Offsetting plan means “offsetting plan” as described in Schedule 1 of the Authorizations Concerning Fish and Fish Habitat Protection Regulations and “compensation plan” as described in subsection 27.1 of the Metal and Diamond Mining Effluent Regulations. Correcting reference to section 27.1 Offsetting plan means “offsetting plan” as described in Schedule 1 of the Authorizations Concerning Fish and Fish Habitat Protection Regulations and “compensation plan” as described in section 27.1 of the Metal and Diamond Mining Effluent Regulations. ECCC - 02 3.2.6 limit seepage from the process solids management facility by: The condition may give the impression the Government of Canada (GOC) is allowing/agreeing to “some” seepage and has given approval for the seepage control/limitation measures proposed, which could increase the legal risk of officially induced error given ECCC’s enforcement role for the MDMER. The alternative wording suggested by ECCC may reduce this legal risk. undertake seepage control at the process solids management facility by: ECCC - 03 3.3 The Proponent shall comply with the Metal and Diamond Mining Effluent Regulations and the pollution prevention provisions of the Fisheries Act; Recommend remove condition 3.3. Legislative and regulatory requirements will need to be met regardless of being included as a condition. n/a ECCC - 04 3.4 The ...
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Attachment Generation PGM Inc. Comments on Draft Conditions - Marathon Palladium Project

  • Marathon Palladium Project
  • Author: On behalf of Generation PGM Inc.
  • Reference number: 1321
  • Submitted: 2022-10-23 - 10:01 PM
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • Please see attached Generation PGM Inc. comments on the potential conditions for the Marathon Palladium Project (CIAR #1305), for filing.
  • Attachment included
  • GENERATIONPGM ____________________________________________________________________________________ Generation PGM Inc. TSX: GENM First Canadian Place, 100 King Street West, Suite 7010 www.genmining.com P.O. Box 70, Toronto, ON M5X 1B1 Tel: 416-640-0280 October 23, 2022 Via E-Mai l - IAAC.Condit ions.AEIC@iaac -aeic.gc.ca Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Ottawa, ON K1A 0H3 To Whom it May Concern: Re: Generation PGM ("GenPGM") Marathon Palladium Project ("Project") GenPGM Comments on Draft Conditions On September 22, 2022, the Impact Assessment Agency of Canada ("IAAC") filed potential federal environmental assessment conditions for the Project (the "Draft Conditions") and invited GenPGM and participants to comment within 30 days (CIAR #1305). Please find enclosed GenPGM's comments on the Draft Conditions. GenPGM has carefully reviewed each of the Draft Conditions against its construction schedule. Based on our review, certain Draft Conditions, as drafted, could delay commencement of construction for the Project, if approved, by up to 20 months from March 2023 to approximately November 2024. Such a lengthy delay could impair our ability to finance and construct the Project. As outlined in GenPGM's comments on the Draft Conditions, GenPGM respectfully requests amendments to Draft Conditions 5.2, 5.3, 6.4 and 6.4.3 to ensure the viability of the Project, as well as consideration of GenPGM's other comments on the Draft Conditions. If you have any questions or concerns, please do not hesitate to contact the undersigned. Yours truly, GENERATION PGM INC. Jamie Levy President, Chief Executive Officer and Director Encl. ...
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Attachment MiningWatch comments on Marathon Palladium proposed conditions

  • Marathon Palladium Project
  • Author: Administrator on behalf of MiningWatch Canada
  • Reference number: 1325
  • Submitted: 2022-10-23 - 8:47 PM
  • Project phase: Decision making
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • Please see the attached submission
  • Attachment included
  • October 23, 2022 Impact Assessment Agency of Canada Joint Panel Review of the proposed Marathon Palladium Project IAAC.Conditions.AEIC@iaac-aeic.gc.ca re: Draft federal environmental assessment conditions for the Marathon Palladium Project Thank you for this opportunity to comment on the Proposed Federal Environmental Assessment Conditions for the Marathon Palladium Mine. We are disappointed that conditions for approval are being proposed when the Panel Report clearly states that there will be significant negative environmental effects, and does not address the reliability of projected benefits that would allow those effects to be deemed “justifiable under the circumstances.” It is even more concerning that the Proposed Conditions do not describe any mechanisms to ensure compliance and implementation beyond recognising the Proponent’s obligation to obey existing laws and regulations. At the same time, there are no requirements placed on regulatory agencies to enforce those laws and regulations, nor any conditions describing what measures those agencies would need to take to ensure they have the capacity and ability to undertake the necessary monitoring and enforcement. The Panel Report also identifies a number of areas where the proponent had failed to demonstrate its ability to safely pursue the project, for example, to reliably identify non-potentially acid generating and non-metal leaching materials1 and therefore to describe appropriate management regimes, or to correctly identify travel times for groundwater contamination.2 The notion that such issues can and should be resolved as they arise is a violation of the precautionary principle and a crucial misunderstanding and ...

Attachment Biigtigong Nishnaabeg Comments on Draft EA Conditions Marathon Palladium Project

  • Marathon Palladium Project
  • Author: On behalf of Biigtigong Nishnaabeg
  • Reference number: 1320
  • Submitted: 2022-10-23 - 7:42 PM
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • Enclosed please find Biigtigong Nishnaabeg's comments on the potential federal environmental assessment (EA) conditions for the Marathon Palladium Project.   
  • Attachment included
  • BIIGTIGONG NISHNAABEG Comments on the Potential Federal EA Conditions for the Marathon Palladium Project Ref. No. 54755 1 BIIGTIGONG NISHNAABEG Comments on the Potential Federal EA Conditions for the Marathon Palladium Project (Reference Number 54755) October 23, 2022 BIIGTIGONG NISHNAABEG Comments on the Potential Federal EA Conditions for the Marathon Palladium Project Ref. No. 54755 2 Contents Introduction to Biigtigong Nishnaabeg ..................................................................................................... 2 The Proposed Project ................................................................................................................................ 3 Significant Adverse Effects on Biigtigong Nishnaabeg .............................................................................. 3 Comments on the Proposed Federal Environmental Assessment Conditions ......................................... 3 Concerns with Lack of Conditions to Address all Panel Recommendations ........................................... 10 Conclusion ............................................................................................................................................... 14 Introduction to Biigtigong Nishnaabeg Biigtigong Nishnaabeg is a progressive and prosperous Nation. Its people have lived, worked and existed on the lands off the shores of Chi-gamig (Lake Superior) and the inlands of the northern superior region since time immemorial. Biigtigong Nishnaabeg is not a signatory to the Robinson Superior Treaty of 1850 and has filed a claim for Aboriginal Title in the Ontario Superior ...
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Attachment Concerned re adverse environmental effects

  • Marathon Palladium Project
  • Author: Robin Heron
  • Reference number: 1319
  • Submitted: 2022-10-23 - 10:00 AM
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • I don't support the current proposed mine proceeding because of the Joint Review Panel's report, which states that the mine will cause adverse environmental effects despite the mitigation measures being proposed. I am specifically concerned about the planned discharges to Biigtig Ziibi during mine closure.  I also don't believe the mine (in its curent proposal) should proceed due to the Panel's statement that there will be significant adverse enviironmental and cumulative effects on Biigtigong Nishnaabeg's current use of lands and resources for traditional purposes, physical and cultural heritage, and health and socio-economic conditions. I am also concerned about the panel's expectation that the mine will cause adverse impacts on Lake Sturgeon habitat in Biggtig Ziibi,Little Brown Myotis,Northern Myotis,Woodland Caribou Habitat and Connectivity (Significant) and Eastern Whip-Poor-Will. While I do not recommend that the project proceed (given the known adverse impacts which cannot be mitigated), if the project does proceed, there needs to be a neutral third-party oversight committee to hold the proponent accountable to the mitigations identified in agreements with Biigtigong, and in the environmental assessment.   

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Attachment Green Initiative

  • Marathon Palladium Project
  • Author: A. Lewis
  • Reference number: 1318
  • Submitted: 2022-10-23 - 1:51 AM
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • I have been following this project for the last 2.5 years and believe this project should be approved for the following reasons: Reconciliation & Economic Opportunity This becomes a once in a lifetime opportunity for BN, GenPGM & Canada to work together to achieve reconciliation through job training for BN and also any other first nations affiliated with the project. This will bring employment & economic prosperity for BN and the Town of Marathon. With the global green initiative being implemented and the need for critical minerals to make this plan succeed, in the timelines set by Canada and other nations, action must be taken swiftly in an environmentally responsible way.   Environment and Mitigation  The joint review panel has addressed concerns about the project pertaining to species at risk and water contamination.  I believe BN, GenPGM, the Town of Marathon, as well as the government can form an oversight committee through the lifetime of the project to address any future environmental risk and implement a course of action to rectify any concerns; however, this oversight committee should not impede the speed required for the green initiative and/or the project to build on a timely manner unless unforeseen situations arise which can have devastating adverse affect.  Every interaction that humans have with the environment, has an affect that can cause a negative impact even though our intentions are for the greater good (i.e farmlands for growing foods, housing for shelter, as well as mining for minerals required for everyday living). We need to strike a balance between inaction and our environmental ...

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Attachment From Northwatch re: Comments on Potential Conditions for the Project

  • Marathon Palladium Project
  • Author: Administrator on behalf of Northwatch
  • Reference number: 1331
  • Submitted: 2022-10-23
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • Please see the attached submission
  • Attachment included
  • Box 282, North Bay ON P1B 8H2 | 705 497 0373 | northwatch@northwatch.org | www.northwatch.org October 23, 2022 Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Ottawa, Ontario K1A 0H3 Email: IAAC.Conditions.AEIC@iaac-aeic.gc.ca IAA Reference Number 54755 Re. Northwatch Comments on Potential Conditions for the Marathon Palladium Project On September 22, 2022 the Impact Assessment Agency of Canada (the Agency) announced a 31 day comment period on potential federal environmental assessment conditions for the Marathon Palladium Project, a proposed open-pit palladium mine about 10 kilometres from Marathon, Ontario, indicating that final federal conditions would become legally-binding for the proponent if the Minister of Environment and Climate Change issues a decision statement indicating the project may proceed.Northwatch is a public interest organization concerned with environmental protection and social development in northeastern Ontario. Founded in 1988 to provide a representative regional voice in environmental decision-making and to address regional concerns with respect to energy, waste, mining and forestry related activities and initiatives, we have a long term and consistent interest in the mining sequence and its social and environmental costs and benefits, including mineral exploration, mine development, operation and closure, and metals processing. Northwatch has had an active interest in the Marathon PGM project since approximately 2001, when Northwatch first assembled an inventory of mining activities and issues in the Lake Superior basin and has participated in the environmental assessment of the Marathon Platinum Group ...
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Attachment Community Benefits Agreement strengthened by meaningful Oversight committee

  • Marathon Palladium Project
  • Author: Sarah Newbery snewbery1
  • Reference number: 1316
  • Submitted: 2022-10-22 - 3:49 PM
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • I presented to the panel on the importance of having a robust community benefits agreement and those comments are reflected in part in the following: Recommendation 82: GenPGM should provide sufficient financial support to fund key community services or organizations in support of fitness and recreational programs for workers. These programs should be carried out in existing facilities. Recommendation 83: The Proponent should work with the Town of Marathon to establish an oversight committee comprising local and regional citizens that would have access to Project reporting and regular Project updates. GenPGM should work with the Town to identify an agreed level of funding to support the operation of the committee. A community benefits agreement would not only establish proponent funded tangible benefits beyond short term employment, but would also provide a mechanism through which the proponent's commitments to minimize impact on the environment can be monitored and the proponent can be held accountable to the community(s) of the area.  Based on evidence presented to the panel, it is clear that historically, environmental monitoring by gov't agencies has not been frequent enough to be meaningful.  A community benefits agreement that includes environmental measures accountability is critical to the future economic success of this region.  To be effective however, a legally binding community benefits agreement cannot be overseen solely by the municipality and the proponent, but rather must have an arms-length oversight committee which includes expertise in domains of the agreement as well as ...
  • Attachment included
  • Local Citizens Need a Community Benefits Agreement and an Independent Oversight Committee Dr. Sarah Newbery Local Physician, * Northern Ontario School of Medicine On Behalf of Cit izens for Responsible Industry in Northwestern Ontario Miigwetch to Biigtigong Anishinaabek for sharing their unceded traditional territory with us today. 1 What is Possible? • Effective network of government agencies, c it izens, business people, academic institutions, and non-government organizations working together to build a project that benefits al l stakeholders, over the long term to ensure optimized benefits DURING project while also ensuring future benefits from land/water/resources are not eroded. • Holistic/systems thinking that includes cumulative impacts • Clear, measurable goals Town of Marathon from Picnic Hill 2 What is a Community Benefits Agreement? • A signed, legally enforceable agreement, having clear monitoring and enforcement mechanisms; • Specific to a particular project (rather than an institutional policy); • An inclusive, collaborative and accountable process of leveraging a development project towards achieving a broader range of policy objectives such as equity, poverty reduction, environmental sustainability and local economic development; • A CBA details in writing the specific benefits that a community will receive from a given development project. These benefits might include equitable hiring practices, funding for training, neighbourhood improvements, support for social enterprises, etc.; • There is substantial community involvement in all phases of the CBA. 3 Where is this Currently Happening? • Indigenous communities throughout Canada and the US • Sti l lwater in ...
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Attachment independent oversight committee members must have proven skills, knowledge, experience in environmental issues

  • Marathon Palladium Project
  • Author: 858899966
  • Reference number: 1315
  • Submitted: 2022-10-22 - 11:26 AM
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • To Whom it May Concern: I hope this note finds you well. I am writing with my own personal views today, not as a member of an organization. In response to proposed conditions 12,13,14 145137E.pdf (iaac-aeic.gc.ca) (https://iaac-aeic.gc.ca/050/documents/p54755/145137E.pdf) It is of the utmost importance that an effective independent oversight committee be established for the life of this project, not just regarding the construction and closure. In addition to members from the Marathon municipal government and the Biigtigong government, the committee must have members with a proven interest in and knowledge of environmental issues. The Marathon Municipal government does not have a track record of being concerned about environmental issues. For example, faced with an increase cost to the recycling program in (approximately) 2020, the Marathon municipal government simply cancelled the entire household recycling program. All recyclables in the waste stream would have to go to landfill. After it had been cancelled, citizens expressed their concern about the cancellation of the program. It was only in response to concerns voiced by citizens that the town investigated whether a new deal could be reached to continue household recycling in the town of Marathon. In fact, the new deal resulted in a more extensive recycling program than the previous program. The chief of Biigtigong has a financial interest in this project. Members of the independent oversight committee must have no political nor financial stake in the project. These members may be affiliated with a ...

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Attachment Benefit of mine opening in Marathon

  • Marathon Palladium Project
  • Author: Major Machine Works
  • Reference number: 1314
  • Submitted: 2022-10-21 - 9:44 PM
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • As a local businessman for the past 10 years providing services mainly for the mining sector I have employed 10 to15 employees in Marathon. I have worked closely with Barrick Hemlo providing machine work and welding, also equipment manufacturering. I have always supported apprenticeship programs in my business model.  I simply want to say as a long time employer in Marathon, I believe the benefits of approving the Generation mine project will benefit my business and the employment of 10 to 15 employees, as well as the benefit it will bring to the community as a whole.  Please except my comments as a long time business owner as positive, I believe this will bring long term stability to my business and of course the community and the region.  I Sylvain Dunn owner of Mayor Machine Works appreciate the opportunity to submit comments and look forward to a favourable outcome to EA process. Thank You  Sylvain Dunn   

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Attachment Effective Oversight

  • Marathon Palladium Project
  • Author: Ted Schintz
  • Reference number: 1313
  • Submitted: 2022-10-21 - 5:52 PM
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • I agree with the administration of my town, Marathon, that we ought to strive to be "responsible stewards of our future and ensure that economic and social sustainability for our grandchildren and future generations are at the fore, while at the same time we are respecting the lands which we live upon."  Federal and provincial governments struggle to oversee the environmental performance of mines, mills and industry, generally.  Let's support the government and citizens with an independent oversight committee. A pulp mill just a short distance up the shore of the world's biggest lake is notorious for polluting the lake.  Let's do better with this project.  Let's be leaders by setting up an oversight committee that can ensure robust oversight. When the pulp mill in my town closed, I (like the other employees) was left with a small part of my expected pension.  Again, governments struggle to provide effective oversight with regards to the behavior of companies.  Let's put in place some guardrails at the start of this project.

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Attachment Health Canada's comments on the potential EA conditions for the Marathon Palladium Project

  • Marathon Palladium Project
  • Author: Administrator on behalf of Health Canada
  • Reference number: 1327
  • Submitted: 2022-10-21 - 4:37 PM
  • Project phase: Decision making
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • Please see the attached submission
  • Attachment included
  • Health Canada recommends the following additions (green) and deletions (red) to Condition 6.5: 6.5 The Proponent shall develop, prior to construction and in consultation with Biigtigong Nishnaabeg, other Indigenous groups, Health Canada, Ontario Ministry of the Environment, Conservation and Parks, and other relevant authorities, a follow-up program to verify the accuracy of the environmental assessment and determine the effectiveness of the mitigation measures as it pertains to adverse environmental effects of the Designated Project on the health of Indigenous Peoples caused by changes in concentrations of contaminants of potential concern in country food, including vegetation, fungi, and fish and other wildlife. The Proponent shall seek consensus with Biigtigong Nishnaabeg on the content of the follow-up program and its implementation, and shall implement the follow-up program during all phases of the Designated Project. In doing so, the Proponent shall: 6.5.1 determine, in consultation with Indigenous groups, the species to monitor (including vegetation, fungi, and fish and other wildlife used as country food); 6.5.2 monitor, prior to construction selected contaminants of potential concern listed in Table 5-1 and Table 5-13 of the Human Health Risk Assessment, Appendix D10 of the Environmental Impact Statement addendum (Canadian Impact Assessment Registry Reference Number 54755, Document Number 727), including methylmercury in the tissue of fish identified in condition 6.5.1 for the country food species identified in condition 6.5.1, including but not limited to: 6.5.2.1 mercury and other metals in all identified species; 6.5.2.2 methylmercury in the tissue of fish; and 6.5.2.3 ...
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Attachment Independent oversight committee

  • Marathon Palladium Project
  • Author: Jonathan Kelly
  • Reference number: 1312
  • Submitted: 2022-10-19 - 10:46 AM
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • I'm not opposed to the mine but have not at all been convinced that it's an environmentally sound plan.  Kevin Morin's geohydrology findings are extremely concerning.  At present, I'm not confident that the mine is in the best long-term interests of the town and the province does not enforce penalties for environmental violations adequately.  To give some semblance of accountability for a company that will pack up and walk away in about a decade (leaving the land worse than they found it by any standard), an independent oversight committee is critical.  This committee (as put forth in the review process) needs to have members who are not involved in any level or form of government in order to be truly independent, and there must be guaranteed funding for the committee (from the mine) for the life of the project.  Simply trusting that the mine will operate in the best long-term interests of our town can't be our plan. 

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Attachment Town of Marathon Comments on Potentially Binding Conditions

  • Marathon Palladium Project
  • Author: Corporation of the Town of Marathon
  • Reference number: 1311
  • Submitted: 2022-10-11 - 11:08 AM
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • As community leaders, we believe that the Marathon Palladium Project has been properly studied by experts and the time for this project is now. It is important for Ontario and Canada. Let’s not be afraid of this opportunity and hide from the criticism that will come with any development project. Let us be the responsible stewards of our future and ensure that economic and social sustainability for our grandchildren and future generations are at the fore, while at the same time we are respecting the lands which we live upon. It is through this vision that Marathon supports mining.   The Town of Marathon, as a registered supporter of the Marathon Palladium Project, offers the following comments on the potential federal environmental assessment conditions:   Any final federal conditions that would become legally-binding upon the Proponent must be based on sound science and/or fact-based through value-driven data and research. Conditions that become legally-binding cannot be emotion-based concerns or arguments and must not be predicated on subjective or objective interpretations of potential outcomes. Legally-binding conditions should also not be imposed unless they pass a materiality test.   Legally-binding conditions at the federal level should not duplicate permits that are required at the provincial (Ontario) level.   If the Minister of Environment and Climate Change issues a decision statement allowing the project to proceed, legally-binding conditions should not be an impediment for the project to proceed as scheduled. Rather, the conditions and appropriate mitigation measures should proceed in parallel with project ...

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Attachment Green energy

  • Marathon Palladium Project
  • Author: Sam Bawab
  • Reference number: 1310
  • Submitted: 2022-10-05 - 5:14 PM
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • The green revolution is trying to omit harmful emissions from machinery by replacing gas with electric power. I think everyone would love for the green movement to be implemented as soon as possible.  Cars emissions account for almost 25% of co2 emissions in the environment and that is in countries that monitor and regulate emissions like Canada does. Other countries do not have the infrastructure to gather such data and inforce such rules. How do we get to the point that rids mother earth of 25% co2 and gives our children a better cleaner future? Well the main things we need are minerals to achieve those goals. If we all keep saying no to sustainable mining then the least we can do is go back to horses and carriages. We need companies like Genpgm that is managed by a very environmentally conscious management team, we need First Nation officials involved not only to ensure economic benefits but also to help keep things sustainable and the community safe. I believe that Genpgm has demonstrated that they are willing to install state of the art monitoring system and immediately rectify any unforseen events if any. This earth is hurting from all the pollution that humans bring onto it, all the trees we cut,all the cars we drive and all the factories we build. The true insult to mother nature is having a green solution and not doing whatever it takes to start healing mother earth. I see articles all the time about scientists trying to find another planet that sustains life. I believe if the same efforts are aimed at sustaining life on a planet that we already know about hint (earth) we would be able to heal this earth from centuries of ...

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Attachment Strong Objection

  • Marathon Palladium Project
  • Author: Kyla Moore
  • Reference number: 1309
  • Submitted: 2022-10-05 - 12:42 AM
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • I strongly object to the Marathon Palladium Project. According to the Marathon Palladium Project Joint Review Panel Report the Project is "likely to cause significant adverse effects, which by definition are adverse effects that cannot be fully mitigated." https://iaac-aeic.gc.ca/050/documents/p54755/144651E.pdf   I just spent the last 15 minutes reading Potential Federal Environmental Assessment Conditions https://iaac-aeic.gc.ca/050/documents/p54755/145137E.pdf. I reject this document, both despite the fact it mentions "mitigation" 68 times, AND precisely because of this fact. I will repeat the quote above "which by definition are adverse effects that cannot be fully mitigated.”    Here are some more quotes from the executive summary, which highlight my concerns: "the Project is likely to cause a significant adverse environmental effect on the hydrology of Stream 6 (Angler Creek)." "the Project is likely to cause a significant adverse cumulative effect on Lake Sturgeon habitat." "the Project, in combination with other projects and activities is likely to cause a significant adverse cumulative effect on Little Brown Myotis, Northern Myotis and Eastern Whip-poor-will." "the Project is likely to cause a significant adverse effect on critical habitat for caribou, as well as on connectivity of habitat within the Lake Superior Coastal ...

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Attachment Great day for a green future

  • Marathon Palladium Project
  • Author: Sam Bawab
  • Reference number: 1308
  • Submitted: 2022-10-04 - 11:48 AM
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • Some people submit irresponsible comments on this page. There baseless comments are a) not backed up by fact and b) is playing a dangerous game with the financial benefits with sustainableining that this project will provide to the area. Let's hear from people that have all the fact about the benefits and harms of this project.   "We are very pleased to announce that Chief and Council have approved a Community Benefit Agreement (CBA) with Generation PGM for ratification by the membership through meetings and online voting.  Please see the posters below for some preliminary information on the CBA and the ratification process. We will be releasing more information on October 8th" Social media quote link below https://www.facebook.com/100069270966868/posts/pfbid0rn723nvivUfh3Fz5Kno9Ms7B2a1aqjWAc7MxWQEUG1Hmf5aJMa2e1GwvuPqVhrHPl/   And that's how you present an argument.  Always facts over emotions.   Thank you Sam  

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Attachment Irresponsible

  • Marathon Palladium Project
  • Author: Rae-Ann St. Jean
  • Reference number: 1307
  • Submitted: 2022-10-03 - 1:51 PM
  • Participation notice: Public Notice: Public Comments Invited on Potential Conditions
  • During a time when one can no longer deny the harms being done to the climate, this project is entirely irresponsible and ignorant to what our community truly needs. The imact not only affects our communities' health and safety but adds to the negative impact of climate change around the world. We must protect this land and respect it as well as those who reside there. No amount of greenwashing will change the devastating outcome if this project proceeds 

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Attachment GBA+ lens Inclusion in Impacts Assessment

  • Marathon Palladium Project
  • Author: Temiskaming Native Women's Support Group submitted by Alexandra Bridges
  • Reference number: 1031
  • Submitted: 2022-02-07 - 1:50 PM
  • Participation notice: Public Notice: Notice of Public Hearing for the Marathon Palladium Project (Updated January 6, 2022)
  • The Temiskaming Native Womens Support Group is contributing to the comment submissions for Marathon Palladium Project to call attention to gendered impacts of large scale industrial projects and to amplify the voices Indigenous Women and Gender diverse peoples. In regard to the Marathon Palladium Project there has been various concerns with Indigenous Womens rights to participate in the process in a meaningful way. Whether that be due to capacity issues, adequate access to technology, location, Covid19 and/or Socioeconomic Barriers. Indigenous Women and Gender Diverse people are significantly impacted with the day-to-day activities of industry. The land surrounding this specific project is sacred to the Indigenous women and gender diverse people and the important roles they carry within their culture. It is a long-standing cultural practice that Indigenous women are water keepers. This project has potential for extreme impacts on various bodies of water. There are locations where toxins coming from the Marathon Mine could enter the Lake Superior basin. Other areas of concern are Hare Creek which drains into a large area including Hare and Bamoos Lake.   The Impact Assessment Agency processes on their website to formally submit a comment are difficult to navigate for the average user. Reason for concern is that not all Indigenous women and gender diverse people have the capacity to submit a comment with their concerns and knowledge of impacts from this project. However, the ministry decision to extend the deadline for comment submissions was a good step in reconciliation. The timelines imposed by federal guidelines are strict and do not allow for enough time to process ...

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Attachment From Thunder Bay Metal Fabricators Association to the Joint Review Panel re: Comments on the Marathon Palladium Project

  • Marathon Palladium Project
  • Author: Administrator on behalf of Thunder Bay Metal Fabricators Association
  • Reference number: 1028
  • Submitted: 2022-02-03
  • Project phase: Review of the Environmental Impact Statement by a Review Panel
  • Participation notice: Public Notice: Notice of Public Hearing for the Marathon Palladium Project (Updated January 6, 2022)
  • To Whom it may Concern, We the Thunder Bay Metal Fabricators Association (TBMFA) wish to submit supporting documents for the proposed Palladium Project in Marathon. The TBMFA is an non for profit association of over 40 members from the thunder bay area offering significant capability and capacity relating to the design, manufacture, repair, and installation of a broad range of products fabricated from metal. Collectively, the member companies represent over 100,000 square feet of facilities, and a workforce of approximately 800 employees. The Association members collectively have hundreds of years of experience and expertise in providing comprehensive, time-sensitive, and cost-effective solutions to the needs of heavy industry. We support the project based on the economic gains it would offer our member firms. I will provide a written submission for a few of our member firms by Feb 25th. BR, John Jurcik President TBMFA

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Attachment From Walter Roberts to the Joint Review Panel re: Comments on the Marathon Palladium Project

  • Marathon Palladium Project
  • Author: Administrator on behalf of Walter Roberts
  • Reference number: 981
  • Submitted: 2022-01-10
  • Project phase: Review of the Environmental Impact Statement by a Review Panel
  • Participation notice: Public Notice: Notice of Public Hearing for the Marathon Palladium Project (Updated January 6, 2022)
  • When will your company be issuing out jobs..im an heavy equipment operator and i would like to get work with your company..thanks.. Walter Roberts

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Attachment From the Town of Marathon to the Joint Review Panel re: Comments on the change of start date for the Public Hearing (see Reference #974)

  • Marathon Palladium Project
  • Author: Administrator on behalf of Town of Marathon
  • Reference number: 977
  • Submitted: 2022-01-07
  • Project phase: Review of the Environmental Impact Statement by a Review Panel
  • Participation notice: Public Notice: Notice of Public Hearing for the Marathon Palladium Project (Updated January 6, 2022)
  • Please see attached document
  • Attachment included
  • Archived: Friday, January 7, 2022 3:44:11 PM From: Daryl Skworchinski Sent: Friday, January 7, 2022 9:48:46 AM To: Marathon Mine Review / Examen Mine Marathon (IAAC/AEIC) Cc: Chantal Gingras; Greg Vallance; Kelly Tsubouchi; Mayor; Ray Lake Subject: Marathon Palladium Project – Change of Start Date for the Public Hearing Sensitivity: Normal Mr. Patchell: The Town of Marathon, as one of two major stakeholders affected by this project, sends this correspondence to express our frustration with the January 5 notification that the public hearing date for this project would be changed to March 14 due to the “current public health situation in Ontario”. We fail to understand how this would have any impact on someone’s ability to prepare for the hearing. If anything, this Ontario “lockdown” situation provides more preparation time as outside of home and work activities have once again been restricted. These types of random extensions ultimately undermine the project review and public trust in the process. The Town of Marathon believes that if the Panel sees COVID-19 as an ongoing concern, then alternative logistical processes need to be put in place expeditiously. Using the pandemic situation as a continual reason to extend the public hearing dates is not acceptable. Yours truly, [Original signed by] Daryl Skworchinski ______________________________________ Daryl Skworchinski CAO/Clerk/Director of Economic Development Town of Marathon <contact information removed> mailto:marathonminereview-examenminemarathon@iaac-aeic.gc.ca

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Attachment From Terry Fox to the Joint Review Panel re: Comments on the Marathon Palladium Project

  • Marathon Palladium Project
  • Author: Administrator on behalf of Terry Fox
  • Reference number: 961
  • Submitted: 2021-12-15
  • Project phase: Review of the Environmental Impact Statement by a Review Panel
  • Participation notice: Public Notice: Notice of Public Hearing for the Marathon Palladium Project
  • This has been delayed long enough. It makes me wonder if the review panel and the Government is just a make work project to delay and continue to get paid for no reason what so ever. I have read your numerous questions to the company and if you had paid any attention to the initial report sent to the Review panel all of those were addressed. Your foolish questions are answered. Move on with the project. The town and First Nations are in agreement with the project. We need this project for the town to thrive in the future.

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Attachment Comments on the Draft Public Hearing Procedures from Pays Plat First Nation

  • Marathon Palladium Project
  • Author: Pinchin Ltd. submitted by Sebastian Belmar
  • Reference number: 943
  • Submitted: 2021-10-25 - 2:48 PM
  • Participation notice: Public Notice: Joint Review Panel Invites Comments on Draft Public Hearing Procedures
  • Dear Jason Patchell, Pinchin Ltd. is pleased to submit the Comments from Pays Plat First Nation on the Draft Public Hearing Procedures for their consideration by the Joint Review Panel. Yours sincerely, Sebastian Belmar
  • Attachment included
  • Please see the attachment to view the content.
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Attachment From Biigtigong Nishnaabeg First Nation to the Joint Review Panel re: Comments on the draft Public Hearing Procedures for the Marathon Palladium Project

  • Marathon Palladium Project
  • Author: Administrator on behalf of Biigtigong Nishnaabeg First Nation
  • Reference number: 945
  • Submitted: 2021-10-25
  • Project phase: Review of the Environmental Impact Statement by a Review Panel
  • Participation notice: Public Notice: Joint Review Panel Invites Comments on Draft Public Hearing Procedures
  • Please see attached document
  • Attachment included
  • October 25, 2021 Jason Patchell Co-Panel Manager, Marathon Palladium Project c/o Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor, Ottawa ON K1A 0H3 marathonminereview-examenminemarathon@iaac-aeic.gc.ca Dear Mr. Patchell, Re: Draft Hearing Procedures the Marathon Palladium Project Biigtigong Nishnaabeg First Nation would like to provide comments regarding the draft Hearing Procedures (the “Draft Procedures”) for the Marathon Palladium Project (the “Project”). The Draft Procedures correspond to document no. 933 of the public registry. Our comments may be divided into three categories: the nature of the hearings, the need for clarity regarding the definition of the term “close community” as that term is used section 2(a) of appendix “A” of the Draft Procedures, and the need for the preservation of confidentiality protocols contemplated by the Final Procedure of March 2012. Background: Biigtigong Nishnaabeg First Nation is a “participant” as that term is defined in section 1(D) of the Draft Procedures. Biigtigong Nishnaabeg is not a signatory to the Robinson Superior Treaty of 1850 and has filed a claim for Aboriginal title in the Ontario Superior Court of Justice. Biigtigong Nishnaabeg and the federal and Ontario Crowns have been in ongoing negotiations to resolve these issues since 2016. As acknowledged by the proponent, GenPGM in a joint , the Project falls within the area of Biigtigong Nishnaabeg’s exclusive Aboriginal title jurisdiction. Section 2(A) of the Draft Procedures describes the objectives of that Draft Procedures. These objectives are to allow: i. The Proponent to describe the Project and respond to concerns and questions raised by ...
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Attachment From Generation PGM to the Joint Review Panel re: Comments on the draft Public Hearing Procedures for the Marathon Palladium Project

  • Marathon Palladium Project
  • Author: Administrator on behalf of Generation PGM
  • Reference number: 942
  • Submitted: 2021-10-25
  • Project phase: Review of the Environmental Impact Statement by a Review Panel
  • Participation notice: Public Notice: Joint Review Panel Invites Comments on Draft Public Hearing Procedures
  • Please see attached document
  • Attachment included
  • GENERATIONPGM _____________________________________________________________________________________________ Generation PGM Inc. TSX: GENM First Canadian Place, 100 King Street West, Suite 7010 www.genmining.com P.O. Box 70, Toronto, ON M5X 1B1 Tel: 416-640-0280 October 25, 2021 Via E-mail Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Ottawa, ON K1A 0H3 Attention: Jason Patchell Co-Panel Manager, Marathon Palladium Project Dear Mr. Patchell: Re: Generation PGM ("GenPGM") Marathon Palladium Project ("Project") Comments on the Public Hearing Procedures We are writing further to the Joint Review Panel ("JRP" or the "Panel")'s Draft Public Hearing Procedures (the "Draft Hearing Procedures") released on September 23, 2021 (Reference No. 933). Pursuant to the JRP's Public Notice of the same date (Reference No. 934), participants were invited to provide the Panel with general comments on the Draft Hearing Procedures by October 25, 2021. Please consider this letter to be GenPGM's formal written comments on the Draft Hearing Procedures. GenPGM recognizes and acknowledges the concerns raised by various participants regarding virtual presentations, particularly involving the effect of virtual presentations on Indigenous communities (see Reference No. 938, for example). Given that COVID-19 limits the JRP's ability to ...
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Attachment From Isabel McMurray, Rose Stacey and Gwenyth Wren to the Joint Review Panel re: Comments on the draft Public Hearing Procedures for the Marathon Palladium Project

  • Marathon Palladium Project
  • Author: Administrator on behalf of Isabel McMurray, Rose Stacey and Gwenyth Wren
  • Reference number: 940
  • Submitted: 2021-10-25
  • Project phase: Review of the Environmental Impact Statement by a Review Panel
  • Participation notice: Public Notice: Joint Review Panel Invites Comments on Draft Public Hearing Procedures
  • Please see attached document
  • Attachment included
  • Jason Patchell October 25, 2021 Co-Panel Manager, Marathon Palladium Project c/o Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Ottawa ON K1A 0H3 RE: Public Notice – Marathon Palladium Project Joint Review Panel Invites Comments on Draft Public Hearing Procedures Dear Mr. Patchell: We - Isabel McMurray, Rose Stacey and Gwenyth Wren - would like to submit the following comments to the Joint Review Panel (the “Panel”) for the Marathon Palladium Project’s Draft Public Hearing Procedures (the “Draft Procedures”). As students enrolled in Environmental Law at Osgoode Hall Law School, we have reviewed the Draft Procedures and make recommendations on the following issues of concern: 1. Access issues pertaining to a virtual public hearing process; 2. The meaningful consideration and incorporation of Indigenous knowledge; and 3. The protection of confidential Indigenous knowledge. 1 PART I: ACCESS TO PUBLIC HEARINGS Public hearings are an integral part of the environmental assessment process. They give the public and communities that may be affected by the social, economic, and environmental externalities of a project the opportunity to hear from project proponents, government, experts, and other individuals or organizations with interests in the project. More importantly, they give concerned community members the opportunity to express grievances, support, and ask questions. Given the location, the potential impact on Indigenous communities, and the magnitude of the Marathon Palladium Project proposal, it is essential that the public has sufficient access to the public hearings. The current format of the public ...
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Attachment From the Ministry of Northern Development, Mines, Natural Resources and Forestry to the Joint Review Panel re: Comments on the draft Public Hearing Procedures for the Marathon Palladium Project

  • Marathon Palladium Project
  • Author: Administrator on behalf of Ministry of Northern Development, Mines, Natural Resources and Forestry
  • Reference number: 944
  • Submitted: 2021-10-25
  • Project phase: Review of the Environmental Impact Statement by a Review Panel
  • Participation notice: Public Notice: Joint Review Panel Invites Comments on Draft Public Hearing Procedures
  • Please see attached document
  • Attachment included
  • Archived: Monday, October 25, 2021 4:03:46 PM From: McNaughton, Kimberly (NDMNRF) Sent: Monday, October 25, 2021 3:33:01 PM To: Marathon Mine Review / Examen Mine Marathon (IAAC/AEIC) Cc: Bennitt, James (MNRF) Subject: RE: comments on the draft Public Hearing Procedures Sensitivity: Normal Good afternoon, Thank you for the opportunity to review and provide comment towards the draft Public Hearing Procedures – Marathon Palladium Project. The Natural Resources and Forestry (NRF) section of Northern Development, Mines, Natural Resources and Forestry have reviewed the draft Public Hearings Procedures and provide comments as follows: 1. Section 1 Introduction In (b) or other more appropriate section in the Introduction, it may be helpful for the Panel to explain how this part of the process connects to the review of the EIS Addendum. Will those participants that provided information on the EIS Addendum need to provide this again to the Panel for it to be considered. Will the information gathered at the public hearing be added to the tech review of the EIS Addendum as the Panel carries out its work. 2. Section 4 Participating in the Public Hearing In (c) additional clarity is needed related to coordination of comments. We assume that the intention is not for governments with a regulatory mandate be required or encouraged to consolidate comments with community groups and have a single person present? 3. Appendix A. Hearing Sessions 3. Topic Specific Hearing Sessions For the second bullet in (b), further clarification is appreciated, ie is this where agencies provide information in addition to the technical comments already provided. Will any guidance be provided by the panel on subjects they ...
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Attachment From the Town of Marathon to the Joint Review Panel re: Comments on the draft Public Hearing Procedures for the Marathon Palladium Project

  • Marathon Palladium Project
  • Author: Administrator on behalf of Town of Marathon
  • Reference number: 941
  • Submitted: 2021-10-25
  • Project phase: Review of the Environmental Impact Statement by a Review Panel
  • Participation notice: Public Notice: Joint Review Panel Invites Comments on Draft Public Hearing Procedures
  • Please see attached document
  • Attachment included
  • M:\3-75 (Council)\Correspondence\Mayor\2021\let_1025.Joint Review Public Hearing Comments.doc respect. works here. The Corporation of the Town of Marathon 4 Hemlo Drive, P.O. Bag TM Marathon, Ontario P0T 2E0 www.marathon.ca OFFICE OF THE MAYOR File No. 3-75 SENT VIA EMAIL October 25, 2021 Joint Review Panel Cindy Parker, Panel Co-Manager Marathon Palladium Project Impact Assessment Agency of Canada Email: marathonminereview-examenminemarathon@iaac-aeic.gc.ca Dear Ms. Parker: These comments are in reference to the draft Public Hearing procedures .pdf document available on the Government of Canada’s website at: https://iaac-aeic.gc.ca/050/evaluations/document/141405?&culture=en-CA As the host community (along with Biigtigong Nishnaabeg) for the Marathon Palladium Project, our residents ultimately have the most to gain or lose in regards to how the Mine will affect our Town. The Town of Marathon wishes to provide our residents with the most direct, and accessible method to provide their opinions to the Joint Review Panel. As such, the Town of Marathon would like to encourage the Panel to consider holding the upcoming Public Hearing in-person in the Town of Marathon, instead of virtually. The Town proposes that an in-person public hearing would encourage more public participation and subsequently a more accurate representation of public opinion. The Town believes this hearing can be held safely in Marathon, while still adhering to mandated COVID-19 health measures. Thank you for your time in this matter and I look forward to your timely response. I can be reached at should you have any questions. Sincerely, ...
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Attachment From Indigenous Services Canada to the Joint Review Panel re: Comments on the draft Public Hearing Procedures for the Marathon Palladium Project

  • Marathon Palladium Project
  • Author: Administrator on behalf of Indigenous Services Canada
  • Reference number: 939
  • Submitted: 2021-10-20
  • Project phase: Review of the Environmental Impact Statement by a Review Panel
  • Participation notice: Public Notice: Joint Review Panel Invites Comments on Draft Public Hearing Procedures
  • Please see attached document
  • Attachment included
  • ISC: Comments on Draft Public Hearing Procedures 1 | P a g e Marathon Palladium Project: Draft Public Hearing Procedures The following comments have been provided by Indigenous Services Canada (ISC) regarding the Environmental Impact Statement (EIS) Addendum for the Marathon Palladium Project proposed by Generation Mining Limited. Manager: Name: Email: Anik Guertin (HQ) <email address removed> Project Officer(s): Name: Email: Candice Remillard-Scott (HQ) <email address removed> Jan Triska (HQ) <email address removed> Doris Odjick (RO) <email address removed> #: Page #: Section: Original: Suggested Amendment: ISC-01 3 4. (f) Participants intending to participate in the public hearing through any of the methods outlined above must register by contacting the Panel Secretariat at marathonminereview- examenminemarathon@iaac- aeic.gc.ca at least 30 calendar days in advance of the start of the public hearing. Early registration will allow for the public hearing sessions to be planned in a logical and organized manner. How will participants be notified of the public hearing date in order to register 30 days in advance of that date? Posting a notice on the IAAC website is not sufficient. The procedures document should define its efforts to inform known individuals, groups via existing e- mails, and through identified news outlets. The procedures should also identify the timeline between the notice and the due date to register so that interested parties can prepare their presentations.

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