To Minister of Environment on Ring of Fire Project


October 15, 2012

The Honourable Peter Kent
Minister of Environment Canada
Les Terrasses de la Chaudière
10 Wellington Street, 28th Floor
Gatineau, QC K1A 0H3

Dear Minister Kent,

We have recently formed a new group in Thunder Bay, Citizens United for a Sustainable Planet. Our vision is a commitment to “engaged communities, a healthy environment, social and ecological justice, and a participatory democracy.” Our mission is to “create public awareness and engage citizens everywhere to require our governments and economic institutions to act in the best interests of ecological resilience and social justice.”

We are writing to support Matawa First Nations call for a Joint Review Panel Environmental Assessment, rather than the currently designated Comprehensive Study, for the Cliffs Chromite Project. A Joint Review Panel EA will provide a more comprehensive, participatory and transparent process and will fully engage First Nation communities who stand to be deeply impacted by these developments. We agree with Chief Peter Moonias of Neskantaga First Nation, who said: “The proper way to consult the First Nations is to have community consultation. Involve the community people, in their own language where they can really understand what they’re talking about, and where they can really express their concerns about the land issues and the knowledge that they have on the land itself.” We fully support Matawa and Mushkegowuk First Nations’ call that the details of the review process, including panel representation, be negotiated and agreed upon WITH them, NOT on their behalf.

The four federal agencies with major responsibilities for maintaining a sustainable environment—Environment Canada with responsibility for CEPA and environmental assessments, Fisheries and Oceans with responsibility for fish habitat, Natural Resources Canada with responsibility for explosives and Transport Canada with responsibility for navigable waters—must consider the immediate and long-term, cumulative impacts of all proposed development in this region, including impacts on James Bay First Nation communities. It would be a failure of the EA process to limit the scope to of the EA to just the Cliffs Chromite project.

As a non-governmental organization, we would like the opportunity to participate in full public hearings, so that we can raise our own concerns about the development occurring in the Ring of Fire area. There are a number of significant issues surrounding the proposed Ring of Fire development, including:

  • the manner in which these initial developments will open up the region to additional developments and the cumulative effects of such developments;
  • meeting the infrastructure needs of remote First Nations communities;
  • providing meaningful economic development opportunities for First Nations and northern communities;
  • the impacts on Aboriginal rights and sacred sites such as burial grounds;
  • water management in an area with as much or more water as dry land;
    the impacts on fish habitats and populations;
  • the impacts on woodland caribou; and
  • the impacts on boreal forest ecosystems.

In September 2011, your Ministry stated that “if built, [the Ring of Fire] would be the first large chromite mine in North America and that chromite and other mineral deposits discovered in the Ring of Fire cover an expansive land base in northern Ontario… Given that the project is sited in the upper reaches of several major watersheds which outlet to the highly sensitive and ecologically important James Bay and Hudson Bay coastal ecosystems, the potential for cumulative effects to occur outside of the project area also needs to be considered.” Your Ministry was therefore “of the opinion that a regional environmental assessment process that considered the interconnectivity and the cumulative impact of currently proposed and anticipated future developments within and connecting to the Ring of Fire would be an appropriate approach.” The current Comprehensive Study underway is entirely insufficient to meet the advice of your Ministry.

We think it is incumbent upon the federal government to uphold its constitutional responsibility to act in both the best interests of the environment and of First Nations by first ensuring the ecological integrity of the region is sustained and by compelling the Province of Ontario to develop mechanisms with First Nations in the Ring of Fire region to ensure that those communities benefit from economic development, do not bear the brunt of environmental impacts, and are able to exercise what First Nations describe as their responsibility to look after their unique and ecologically sensitive lands, with water such an important part of the landscape.

We, the members of Citizens United for a Sustainable Planet wish to formally request that you move the Cliffs Chromite project from a Comprehensive Study to a full Joint Review Panel for the purposes of an Environmental Assessment with a significant emphasis placed therein on a cumulative impact assessment for the entire region.


Peggy Smith, on behalf of
Citizens United for a Sustainable Planet
Thunder Bay

Raymond Ferris, Matawa Ring of Fire Co-ordinator
Paul Capon, Matawa Policy Analyst
Sarah Cockerton, Matawa Environmental Programs Co-ordinator
David Paul Achneepineskum, CEO, Matawa First Nations
Christine Kaszycki, Provincial Ring of Fire Co-ordinator