Northwatch Comments on the Draft Agreement to conduct the Regional Assessment in the Ring of Fire Area

Reference Number

As a regional environmental non-governmental organization, Northwatch’s primary areas of interest relate to the impacts and potential impacts of Ring of Fire developments on northeastern Ontario and the lands and people of northeastern Ontario. While our primary concerns are those that impact the region of northeastern Ontario, we do have associated additional concerns and interest which are broader, geographically.

Our areas of interest with respect to Ring of Fire developments include:

  • the direct impacts of Ring of Fire project activities which are outside the McFaulds Lake (in northwestern Ontario) and have been variously announced to be intended to take place in Sudbury or Algoma districts of northeastern Ontario, namely the smelting / processing of chromium and other metals.
  • the energy demands of the project, the transportation routes and impacts, and the carbon footprint of the project
  • the downstream impacts of the project components, including the downstream impacts of the mining and smelting of the various metals to be extracted  
  • the climate / carbon impacts of the project activities, including of mineral exploration, mineral extraction, mineral processing, transportation of mine products in various states of processing, and the smelting and refining of extracted minerals
  • the recognition and realization of Indigenous authority and the ability of this project (including regional and subsequent assessments, and the carrying out of the various project activities) to further or to hinder reconciliation between non-Indigenous and Indigenous peoples and governments

There is, overall, a high level of uncertainty associated with the development and development timeline of the various components of the Ring of Fire project, including whether and when the various mineral deposits will be developed and whether and where the extracted minerals will be processed, including the chromite.

It does appear, however, that there is a high likelihood that if the chromite is ever extracted from the Ring of Fire area, a processing facility will be established in northeastern Ontario. We cite the history of two different siting processes by two different Ring of Fire proponents having both selected a site in northeastern Ontario for the then-proposed ferrochrome smelter, and the most recent proponent having considered four sites in their selection process, with three of those four sites being in northeastern Ontario (Timmins, Sudbury and Sault. Ste. Marie).  Accordingly, Northwatch has a strong expectation that with a ferrochrome smelter being part of the Ring of Fire project, the regional assessment will be scoped accordingly, and will include adequate consideration of potential impacts of the project on northeastern Ontario.

Northwatch has reviewed the Draft Agreement and provides the comments in the attached document. 

While we remain very positive about the potential to conduct a regional assessment under the Impact Assessment Act, we have some concerns and have not yet found confidence in the conduct of this particular assessment.

We note that the summary at the beginning of the Impact Assessment Act sets out specifically in section (l) that a regional assessment “provides for the assessment of cumulative effects of existing or future activities in a specific region”.

In this instance, the “region” is the region of Northern Ontario, encompassing the territories of Treaty 3, Treaty 9, Robinson-Huron Treaty Area and Robinson-Superior Treaty area, and the watersheds of Hudson’s Bay, Lake Huron and Lake Superior. The “future activities” are the activities associated with the Ring of Fire project, which includes but may not be limited to mineral exploration, the development of mines and mining infrastructure, the extraction of mineral ores and on-site processing, the transportation of those mineral products, and the off-site processing, such as the smelting of chromite or nickel or the refining of copper or gold.

In its current version, the draft Agreement to conduct the Regional Assessment in the Ring of Fire Area does not meet the requirements of the Act, in that it does not encompass the activity set of the Ring of Fire project and it does not adequately set out that the cumulative effects within the region will be given due investigation and consideration. Nor does it make clear that the “region” is the region is appropriately defined.

Given these and others concerns, we would strongly encourage the Agency to take the current set of comments into consideration and to prepare a second draft of the Agreement to conduct the Regional Assessment in the Ring of Fire Area, and to post it for a second  comment period of no less than 60 days (and longer should the comment period overlap with other culturally significant period or another peak in the effects of the COVID 19 pandemic).

In addition, we request that the Agency prepare a table setting out how they have dispositioned comments received on this first draft of the Agreement to conduct the Regional Assessment in the Ring of Fire Area. We ask this in part because we do not see our comments on regarding planning for the Regional Assessment in the Ring of Fire Area submitted as a joint letter on January 21, 2021 reflected in the draft of the Agreement to conduct the Regional Assessment in the Ring of Fire Area. We ask it also because we consider the dispositioning of comments to be good practice, and one which would demonstrate transparency and accountability on the part of the Agency in its conduct of this assessment.

Please see the attached document for our full set of comments of the draft Agreement to conduct the Regional Assessment in the Ring of Fire Area.



Submitted by
Public Notice
  • Northwatch-Commments_RoF-Draft-Agreement_Ref.80468.pdf (704 KB)
  • Comment Tags
    Air Quality Climate change Assessment Timelines / Process Wetlands
    Date Submitted
    2022-02-01 - 6:24 PM
    Date modified: