Marathon Palladium Project

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Attachment Genpgm permitting

  • Marathon Palladium Project
  • Author: Sam Bawab
  • Reference number: 1330
  • Submitted: 2022-11-13 - 10:45 AM
  • I would like to say that I am very impressed at the way Genpgm and the first nations groups are interacting together. Genpgm on their part have demonstrated their respect for the First Nations right to the land and its resources. BN on their part demonstrated that they are for progress as long as its done in an environmentally responsible manner,that protects the environment and wildlife equally. I hope that this level of corroboration continues as the project progresses ( should permits be granted) I would like to thanks  BN and Genpgm for keeping the public informed about the discussions that are happening to ensure a smooth relationship when it comes to this project.   Hoping to see favorable results on next week's vote and the decision that will be rendered by both the federal and provincial governments.   Thank you Sam Bawab

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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 Potential Conditions under the Canadian Environmental Assessment Act, 2012

  • Marathon Palladium Project
  • Author: Administrator on behalf of Pays Plat First Nation
  • Reference number: 1323
  • Submitted: 2022-10-24 - 3:31 PM
  • Project phase: Decision making
  • Please see the attached document.
  • Attachment included
  • Potential conditions under the Canadian Environmental Assessment Act, 2012 The Impact Assessment Agency of Canada is contemplating the following potential conditions in relation to the Marathon Palladium Project (the Designated Project) located in Ontario for recommendation to the Minister of Environment and Climate Change (the Minister) for inclusion in a Decision Statement issued under the Canadian Environmental Assessment Act, 2012. If the Minister decides that the carrying out of the Designated Project is unlikely to cause significant adverse environmental effects as defined under subsections 5(1) and 5(2), or if the Minister decides that the Designated Project is likely to cause significant adverse environmental effects and the Governor in Council decides such effects are justified in the circumstances, the Designated Project would be allowed to proceed, and any conditions established by the Minister under the Canadian Environmental Assessment Act, 2012 would become legally binding. Pursuant to section 184 of the Impact Assessment Act, a Decision Statement issued by the Minister under subsection 54(1) of the Canadian Environmental Assessment Act, 2012 is deemed to be a Decision Statement issued under subsection 65(1) of the Impact Assessment Act, other than for the purposes of section 70. 1 Definitions Agency means the Impact Assessment Agency of Canada. Baseline means the environmental conditions prior to initiating construction of the Designated Project. Construction means the phase of the Designated Project during which the Proponent undertakes the site preparation, building or installation of any components of the Designated Project, including periods during ...
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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 Métis Nation of Ontario Region 2 Comments on Potential Conditions for the Marathon Palladium Project under the Canadian Environmental Assessment Act, 2012

  • Marathon Palladium Project
  • Author: Administrator on behalf of Métis Nation of Ontario
  • Reference number: 1324
  • Submitted: 2022-10-23 - 12:07 PM
  • Project phase: Decision making
  • Please see the attached document.
  • Attachment included
  • Métis Nation of Ontario Region 2 Comments on Potential Conditions for the Marathon Palladium Project under the Canadian Environmental Assessment Act, 2012 The Métis Nation of Ontario is undertaking continued discussions with the Crown Consultation Team and the Marathon Palladium Project Proponent, GenPGM. This review is to offer suggestions in relation to potential conditions with the spirit of those ongoing discussion in mind. The Métis Nation of Ontario, through their ongoing work on the Crown Consultation and Accommodation Report has identified that the Project is likely to cause significant adverse effects on Métis rights and interests. The Métis Nation of Ontario continues to state that the effects of the metal ore in the Project are currently unregulated and has the potential to cause extensive environmental contamination and significant public health problems (Ravindra et al., 2004, Sci. Total Environ., 5;318(1-3):1-43. doi: 10.1016/S0048-9697(03)00372-3; World Health Organization: Environmental Health Criteria 125 Platinum, 226 Palladium). These impacts can be assessed and mitigated with government regulation and statistically significant baseline studies with continued monitoring and testing in humans, Métis VECs, and the environment (animal tissues, plants, fungi, lichen, soil, air, and water). Early detection of environmental and public health impacts are crucial to the public and Indigenous Groups and are the responsibility of the Federal and Ontario governments and the Proponent. The Métis Nation of Ontario has a positive working relationship with GenPGM and believes with the collaboration of the Crown such effects will be properly monitored and mitigated. Having sufficient ...
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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 From the Ministry of Citizenship and Multiculturalism of Ontario to the Impact Assessment Agency of Canada RE: Potential Federal Environmental Assessment Conditions - Document Reference Number: 1305

  • Marathon Palladium Project
  • Author: Administrator on behalf of Ministry of Citizenship and Multiculturalism of Ontario
  • Reference number: 1322
  • Submitted: 2022-10-21 - 8:57 AM
  • Project phase: Decision making
  • Please see the attached document.
  • Attachment included
  • Please see the attachment to view the content.
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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 Closing remarks

  • Marathon Palladium Project
  • Author: Sam Bawab
  • Reference number: 1288
  • Submitted: 2022-05-18 - 11:24 AM
  • Today was very brief with only four presenters. I thought BN first nation's seemed to be satisfied with the talks during the discussions related to undertaking #31. The mayor of Marathon said it well when he stated that Marathon and BIIGTIGONG NISHNAABEG were the main parties affected by this project.  Then came Jamie Kneen. I found his presentation very vague, misleading and confusing.  Kneen's remarks suggested that he is an environmental and financial expert. Also suggested he is an oil,diesel and all mineral financial analyst. Where Genm got an expert for each of those areas and discussed at length the solutions,benefits and means to having a sound operation backing it all up with their extensive knowledge and past experience, kneen seems to suggest that he commands more knowledge and experience that all of Genms experts put together.  Kneen then decides to ignore feasibility studies and all the hard work that goes into them and accused Genm of either being incompetent in completing the mine or that they will simply  sell it. Those are unsubstantiated direct accusations of the mental capabilities of Genm management.  Kneen then reiterates the ridiculous notion that every study completed by Genm does not "Adequately' represents this or thar. H e did so without stating what that "Adequate " threshold is. Kneen further represented his Jack of all trades claims  by saying the project will either go bust in five years or be so successful that they might sneak in and mine other deposits under the radar of the law. As I stated in a previous extensive reply to this argument kneen you are contradicting yourself . Your options ...

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Attachment Day 16

  • Marathon Palladium Project
  • Author: Houssam Bawab
  • Reference number: 1237
  • Submitted: 2022-04-05 - 10:32 PM
  • Day 16 was filled with presentations from  Biigtigong Nishnaabeg (BN)and rightfully so as they are the closest First Nation's Group to the project. ( approx 9 km) Most of the presentations today taught us about the past;,present and future of BN. The importance of culture, rituals and sacred lands were also presented. I found those presentations very meaningful and educational. Towards the end of the day 2 presenters took the podium at the BN communication site and shared their organization's findings. I found the presentations at some points to be misleading,inaccurate and lacking statistics.  One of the presenters showed a map with a new road on it ( they failed to mention thar the road does not exist and was indeed penciled in)  Only when one of the panel members  specifically asked about the road did the presenter acknowledge that at this time the road is non existence.Furthermore the road is one of the option routes that were presented as a relief for the deadhorse area. No definite location has been decided on by the involved parties and the road may ir may not be built in 10 years. The presenter failed to mention all the routes that were discussed for a road as a form of mitigating the concern.   The second presentation spoke to the impact of the project on  4 different areas of the BN way of life. Before i share my opinion, I would like to acknowledge that these ways of life and the lands used to practice them on rightfully belong to BN. Having said that I  found it strange that every topic the presenter spoke off suggested thar the project will have an impact on an already stressed situation. They did not ...

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Attachment Day 14

  • Marathon Palladium Project
  • Author: Sam Bawab
  • Reference number: 1214
  • Submitted: 2022-04-02 - 2:55 PM
  • The topic was about cumulative affects of the project. GenPgm started the day with a presentation that was backed up by slides and quotes from the EIS. The first presenter spoke about how in their expert opinion GenPgm experts did not adequately study different species of birds ( habitat,mating and rehabitating due to project). The claim is that GenPgm used a one fit all mentality. They said that one fit all does not includes all bird species. ( I didn't know we can read birds minds) Then they proceded to say that their is not enough data to know exactly how all the species act. Well by their admission data is lacking then logically a one fit all scenario should suffice l. Then came the environmental group ( Crino). They had 4 main points. A) They spoke about other projects in the area how they can overlap with the marathon project thus causing more damage. ( note the closest project is 18 km away). GenPgm did a study on that topic and presented their findings in the EIS. B) the lumber producer in the area has violated the environmental act some 479  times give or take and were only fined 400k dollars. ( thank you for this fun fact but what does that have to do with GenPgm, I didn't make the connection) I feel like I'm repeating myself. Just because the lumber company committed violations does not equal to GenPgm doing the same. ( simple Arithmetics) C) I never understood how those presenters can make some of the statements they do. The presenter said that GenPgm has not adequately done their job. How do they know that infact its the case. How can you bluntly accuse experts in the field of not knowing what they are doing ...

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Attachment Support for Generation's Marathon Project

  • Marathon Palladium Project
  • Author: Administrator on behalf of Tyler Davis
  • Reference number: 1218
  • Submitted: 2022-04-02
  • Project phase: Public Hearing
  • Good Afternoon, My name is Tyler Davis. I have owned and operated a business here in Marathon, Ontario since December of 2010. Born and raised in Marathon, I am proud to be able to contribute to the local economy while giving back to the community that I call home. Like most communities in rural Northern Ontario, Marathon has seen it's fair share of challenges over the past 20 years. If not for the Barrick-Hemlo Gold Mine, we would not enjoy the quality of life that we do today. We are a mining community and we rely on this industry to keep our community afloat. Generation Mining's Marathon Palladium project is crucial to our future. This project would benefit the entire North Shore in so many ways, not limited to the following; provide direct employment for people from Marathon and other north shore communities including area First Nations provide spin-off employment through the establishment of new businesses provide a much needed boost to existing businesses (more people = more business) provide further educational opportunities for local youth (more students = more course options) more users for existing recreational facilities/groups and opportunities for new activities/options The bottom line is that more people in our community is better for the community. The ripple effects touch all aspects of our quality of life. We have the infrastructure and we have the facilities. We have also shown that we can effectively and safely host large groups of construction workers, as per the successful completion of Valard's East-West tie project here in Marathon.  I truly believe that our local leaders, and the leadership ...

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Attachment map of current contamination sites in Marathon

  • Marathon Palladium Project
  • Author: Administrator on behalf of Teri Burgess
  • Reference number: 1219
  • Submitted: 2022-04-01
  • Project phase: Public Hearing
  • Hello Jason I hope that you are well. One local person who listened to today's proceedings said that the panel was looking for information about contamination sites in Marathon. Sarah Newbery passed on the attached map from her work with the drinking water/ground water group. Also, Ted Schintz passed this along: I snowshoe past that site several times every winter.  There are many other chemicals besides mercury buried there. Some of the chemicals are in a decent concrete structure that very much looks like a basement, with a floor and walls.  Many other chemicals were buried in steel drums.  I have heard about another dump site located near a school yard, as well. Someone appears to be monitoring the mercury Dump site still.  Brush was cleared from the sides of the trails to monitoring wells last summer.  When the ownership of the mill went from an American owner to Kruger and Tembec, the site was not included in the sale.  It stayed with the American owner. The site is at UTM:  16U 547336 E 5394000 N. Ted   From her groundwater work, Sarah Newbery also made this note below: The other piece element that I have been thinking about but have not yet had a chance to put my fingers on is that the secondary water source for Marathon should the ground water in town become contaminated was going to be the aquifer that is at the bottom of the ski hill.  I am not sure the degree to which the Bigtiig River is connected to that (surface water/groundwater connections) but if there is contamination of that source of water by outflow of contaminated water from the ...
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Attachment Day 12

  • Marathon Palladium Project
  • Author: Sibip submitted by Sam Bawab
  • Reference number: 1203
  • Submitted: 2022-03-30 - 9:12 PM
  • The day started with GenPgm as a team flawlessly presenting. In their presentation I believe they covered all the concern presented on day 11. The first presenter spoke about the possibility of accidents at the project. To demonstrate this they used an example of a mine that's no where near the proposed mine. According to the presenter the mine leaked tailing material into the surrounding water when a basin broke due to what they said was a weak foundation. They never presented any facts about the incident. For example when was the mine built  what did the EIS look like compared to GenPgm or what material was used and how long did it take for the incident to occur. I don't think anyone can condemn GenPgm by bringing up another mine. ( you can't punish a son for a mistake a father committed). In the sprit of fairness I think the presenter should have included an example of a mine that did not have such an incident. Later they described " the severe" adverse impact on the populations living in close proximity to the mine.Those included having to move a bit further down the body of water to catch their fish. On a personal level people were extremely concerned about the incident and some even had anxiety or depression.  Furthermore they suggested that there should be a third party organization that shadows GenPgm while they preform there monitoring. I say who will monitor the 3rd party.  I do appreciate the personal effects on the people in the example but I don't think it has any relevance here  Furthermore if someone comes in with the mentality that anything that may go wrong will go wrong, then it follows that humans should sieze all ...

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Attachment Day 11

  • Marathon Palladium Project
  • Author: Sam Bawab
  • Reference number: 1200
  • Submitted: 2022-03-29 - 11:42 PM
  • Day 11 was very interesting. This has become a learning process for me.  When a person or a group is trying to help and not just object they usually share their concerns and offer what to them would be an acceptable solution. Some might go further and point out some positives that the proponent has shown. Some of today's presenters asked questions of GenPgm. Even though Pgm answered their question clearly they proceded to ask the same question again with a different format. Others suggested that they don't agree with some of GenPgm's findings. I find that offensive on two parts . Either the presenters think that the experts don't know how to their job or that GenPgm is making up results to their advantage ( which is illegal). Some presenters argued about the adverse reaction of Pgm on human health. They stated that Canada does not currently have a limit as not enough data is available.  If  GenPgm is not required to do this by law why bring  it up?  Furthermore any figure that GenPgm comes up with will be useless as there are no parameters in Canada as stayed by the presenters. Finally no specifics to the adverse reaction were given. So the severity of the impact is unknown. It was stated that  mercury levels at all bodies of waters have exceeded the recommended levels. As a result the water is not suitable for 15 year olds or younger and women of child bearing age. I don't understood the concern since the water and fish tissue is already contaminated. It is my understanding that GenPgm has reported minimum levels of mercury as a direct impact of the project. Logically then I would assume that with the information provided its ...

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Attachment Day 8 & 9

  • Marathon Palladium Project
  • Author: Sibip submitted by Sam Bawab
  • Reference number: 1170
  • Submitted: 2022-03-24 - 7:06 AM
  • Day 8 started off by finishing the discussion in regards to fishery and protection of existing plants shrubs ect while discussing how invasive plants will be dealt with. I thought that most of the talks were fruitful and everyone seemed to be in agreement that sufficient work is planned to keep things under control. That included 2 species of birds that mate approximately 1 month before the start of mating season of April 15. The hearings hit a snag when multiple government agencies displayed critical concerns over a dwindling Boreal Caribou population.  The government has a program in place that aims at increasing the population to the point were they are able to self sustain. I believe the main concern was the ease of connectivity that the Caribou would have during production, operation and closure.  GenPgm said that during their study period there were no Caribou observed in the area of concern. To me that is a good response if it was followed by  how the area would be monitored and what steps would be taken if infact they spotted a Caribou in the future. The ECCC said that the information provided was not sufficient and asked GenPgm for more clarity. Just when things looked like this is gonna be a major issue a member of the panel asked about an example of 30to1 reforestation which suggests 30000 hecters to the 1000 heaters used by GenPgm. The answer to that by ECCC seemed to show a way to remedy this problem by relocating infrastructure or by improving connectivity.  GenPgm was issued a few undertakings which I believe they will use the opportunity to clear this issue.  Noise disturbance was another concern. It is believed ...

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