Critical Minerals Framework…

Critical Minerals
Framework Discussion Paper

Background
On March 10th, 2021, the Ministry of Energy, Northern Development and Mines (MENDM) released a discussion paper for pubic consultation to help the ministry develop Ontario’s first-ever critical minerals strategy. The period of public consultation began March 10th and will be open until May 9th, 2021 (60 days).

This document was written by the Timmins Economic Development Corporation (TEDC) to provide direct feedback for the consultation process of the Ontario Critical Minerals Framework Discussion Paper.

The comments made herein reflect key positions that should be considered when developing Ontario’s critical minerals strategy.

About the TEDC
The TEDC is the economic development team for the City of Timmins. Its role is to facilitate economic and social activity that supports job creation, diversifies the economy and improves quality of life.
Timmins has been historically known as one of the most prolific and top tier locations for exploration and mining activity. Because of this, the mineral exploration industry has become one of the TEDC’s primary areas of focus. Its staff works to generate awareness pertaining to the numerous exploration opportunities in Timmins and the surrounding area. Additionally, TEDC staff provide direct support to exploration companies interested in, or currently operating in Timmins. The TEDC acts as a concierge service when working with these companies. Whether it be funders, municipal departments, provincial or federal ministries, its team will bring all parties to the table to address current and future business development needs to find the best solutions for the company.
Discussion Questions

Objectives for Developing Ontario’s Critical Minerals Strategy

1. Will these objectives support achieving Ontario’s vision?

At this time the objectives identified in this paper are too broad to be able to comment on if they will support Ontario in achieving its vision. However, it can be assumed that some of these objectives will assist Ontario as long as the actionable items undertaken to achieve these objectives are realistic. Further objectives should be considered and detail on actionable items would be desirable to comment on.

2. Are there any other elements that need to be considered in the objectives?

Yes, the following should be considered:
• Further research that is needed to promote and generate awareness on critical minerals and rare earth elements are available in Ontario;
o For example: research projects by the Ontario Geological Survey (OGS) or community based exploration projects like “Discover Abitibi” which was previously completed in Timmins would help gain momentum and exploration investment.
• Dedicated investment attraction efforts will also need to be undertaken to generate awareness to investors regarding the availability and potential of critical minerals and rare earth elements;
• The condition of transportation based infrastructure, especially in all areas of Northern Ontario;
• The high costs associated with electricity in Ontario;
• The cost of transitioning to a low carbon (green) economy;
• The actual viability and reliability of new (green) technologies in this industry, especially in all areas of Northern Ontario where the climate is much colder;
• The labour market forecasts for the resource development and mining industries, especially in Northern Ontario.

3. What are some actions Ontario could consider to achieve these objectives?

The following are some actions that Ontario could consider to achieve these objectives:
• Increase research activities in Ontario with respect to critical minerals and rare earth elements;
• Fund community based exploration projects in Northeastern, Northwestern and Far North, Ontario;
• Provide dollars to the OGS and partner with the federal geological survey to conduct additional research in target areas of the province;
• Proactively share research results from the Ontario Geological Survey (OGS) with municipalities, economic development organizations and other industry based entities;
• Partner with local economic development agencies to help with investment attraction and help design value propositions that can be utilized for investment attraction;
• Promote and generate awareness on what critical minerals and rare earth elements are available in all areas of Ontario;
• Develop, or assist in developing, a lead generation strategy to target both domestic and foreign direct investment;
o This can be a function of the Ministry of Economic Development, Job Creation and Trade (MEDJCT).
• Increase Ontario’s Flow Through Share Tax to competitive levels;
• Increase Ontario’s Flow Through Share Tax for Indigenous owned Joint Ventures;
• Incentivize the cost of electricity in Ontario for certain organizations at various levels of the value/supply-chain;
• Incentivize the transition and adoption of new (green) technologies in the industry.

Key areas of focus for a critical mineral strategy

1. What opportunities do you see for indigenous communities participating in resource development?

There are many opportunities for Indigenous communities that participate in resource development. Specifically, Indigenous communities have the opportunity to take more of an active role throughout the entire process of resource development including resource sharing. These communities can promote and directly support the creation of new Indigenous owned businesses and Joint Ventures. In doing-so, Indigenous communities would have direct ownership in resource development, have additional influence and decision making capabilities, and become a more pronounced stakeholder throughout the process. These opportunities would allow for the realization of tangible benefits including: revenue generation, job creation, capacity building through education and training, and the diversification of a community’s economy. Furthermore, there is also the opportunity to establish consistent and equitable partnerships between Indigenous communities and key stakeholders involved in the resource development industry. The varying degree and nature of Impact Benefit Agreements, Resource Development Agreements, and Exploration Agreements make it difficult on government, mining companies and other parties to establish mutually beneficial relationships. Therefore, the development of a template or standard by which Indigenous communities and other key stakeholders can establish partnerships would be key.

2. What are the barriers that Indigenous communities face in participating in resource development?

Indigenous communities may face a number of barriers with respect to participating in resource development. Barriers may be associated with the overall awareness and understanding of resource development itself. Without knowing of, or understanding, the resource development process it becomes difficult to participate in the industry. Therefore, the barriers can be directly attributed to an Indigenous community’s actual capacity and capabilities. There also may be barriers associated with the fact that education levels are lower in these communities. These levels need to be increased so that Indigenous peoples can begin to take on more leadership roles within the resource development process, including when mines develop. Additionally, there may be other barriers associated with resource development concerning operators recognizing and incorporating Indigenous beliefs and values within process. Indigenous community’s value all lands, especially their traditional territories, and their views and opinions must be respected when conducting resource based activities. Finally, there may also be barriers associated with a resource development company’s willingness to work more collaboratively with Indigenous communities in allowing them to have more decision making capabilities or hands-on involvement throughout the process. There could be a negative stigma from previous experiences or difficult relationships that exacerbate any potential involvement.

3. What supports might assist Indigenous communities with taking advantage of the many opportunities of a critical minerals strategy?

There are a number of supports that would assist Indigenous communities with taking advantage of the opportunities of a critical minerals strategy. They could include: generating awareness and an understanding of resource development and critical minerals through enhanced education, training, consultation and collaboration. Additionally, supports could be in the form of programming or incentives to stimulate participation within the industry.

It could be incentives to start new businesses or joint ventures, or even an enhanced Flow Through Share Tax for Indigenous Joint Ventures to the levels that are seen in Quebec. Furthermore, companies operating in the resource development industry (including mines) could assist Indigenous communities with business start-ups and other opportunities through direct financial assistance, training, Joint Ventures, or even mentorship.

4. What kind of initiatives or partnerships could create more opportunities for participation in critical minerals projects and the supply chain?

There are a number of different initiatives or partnerships that could create more opportunities for participation in critical minerals projects and the supply chain. One initiative or partnership could be through various forms of mentorship between industry operators and various levels of government with Indigenous communities. Mentorship could help foster a culture of awareness and understanding of resource development. Additionally, mentorship opportunities could open the door for Indigenous peoples to explore and experience first-hand the variety of job opportunities that are available in that industry. This would highlight potential career paths and hopefully influence Indigenous people to consider pursuing employment in this industry.

Developing an Ontario Critical Minerals List

1. Are there other considerations or factors that Ontario should take into account when developing a critical minerals list for Ontario?

Yes, Ontario should consider its position with respect to the entire value and supply chains surrounding resource development. The Province has the opportunity to develop all facets of the value and supply chains to position itself as a leader in critical minerals. Therefore, Ontario should consider identifying and addressing gaps or challenges faced by the entire industry. Additionally, Ontario should consider working more closely and collaboratively with local and regional economic development agencies and key industry stakeholders as these entities have a thorough understanding of their respective communities or areas. Furthermore, Ontario should consider the fact that the presence of critical minerals and rare earth metals are not uniformly present throughout the Province. Therefore, policy development should take this into consideration with policy and strategy that is uniquely and finely tuned these jurisdictions.

2. Are there other minerals in Ontario that should be added to the list because they are considered “critical”, or that should be removed from the list?

All minerals of value to the “green” economy should be added to the list.

3. How can Ontario leverage its critical minerals list to demonstrate to the global investing community that the province is ready to supply the world with critical minerals?

There are a number of ways that Ontario can leverage its critical minerals list to demonstrate to the global investing community that the province is ready to supply the world with critical minerals. One way would be to work more collaboratively with economic development agencies by sharing key information (i.e. which minerals are located in a certain area and where they are located) so it can be included within value propositions and shared with potential investors. Additionally, Ontario could take a more proactive approach in advertising its critical minerals by sponsoring or employing a “booth” at key mineral or mining conferences and events (i.e. PDAC), similar to other Canadian provinces. Ontario could easily market the critical minerals list as well as the location and availability of these minerals within the province at these key events.

Additionally, the government can also leverage its critical minerals list by demonstrating commitment and its level of seriousness by supporting key critical mineral projects and developing key program designed to support the industry.

Enhancing investment in mineral exploration and development

1. What else could Ontario do to promote the exploration for and development of critical minerals in order to enhance investment?

To promote the exploration for and development of critical minerals in order to enhance investment, Ontario could invest in projects similar to Discover Abitibi with communities with known resources. Organizations like FedNor and the NOHFC could aid in funding this community led research as it will stimulate investment into critical minerals and rare earth elements in these communities. Additionally, the OGS could publish, actively promote, and share its research findings to stimulate and attract investment.

2. What else could Ontario do to prepare communities to be ready for, and actively participate in, exploration and development of critical minerals?

The Ontario government could do a number of things to prepare communities to be ready to actively participate in the exploration and development of critical minerals. Specifically, Ontario could begin to actively engage communities with known resources and begin to educate and consult with the Province on the importance of resource development as a means of transitioning to the green economy. Additionally, Ontario should consider looking at lowering the cost of electricity since high costs are a deterrent to investment and overall operations throughout the entire mineral development value (supply) chain. For example: battery manufacturers require a lot of power in their operations, and the cost of electricity is typically a key investment driver.

3. How could the Ontario Geological Survey play a greater role in supporting critical minerals exploration and development in the province?

The OGS could play a greater role in supporting critical minerals exploration and development in the Province by completing more research and actively sharing and promoting the results of community based exploration projects with economic development agencies, key stakeholders, and academic facilities. The OGS can work more collaboratively with these organizations to assist them in their direct activities in attempting to stimulate investment and support existing operations.
Regulatory Policy Reform

1. Are there any additional areas of the regulatory system that are creating barriers for critical minerals projects?

Yes, there are additional areas of the regulatory system that are creating barriers for critical minerals projects. Specifically, the entire process of resource development is incredibly lengthy and the regulatory requirements may not adequately reflect modern operational practices and the speed at which the market moves.

These timelines can make it incredibly difficult for operators to leverage high commodity prices when economically viable and beneficial for all parties involved. These timelines may be associated to a lack of internal capacity and capability. If Ontario wishes to promote resource development and the entire value (supply) chain, then it must increase its internal capacity and capability to ensure swift response times to the regulatory requirements that the industry must oblige by.

2. Are there specific areas of policy guidance that industry and partners would find beneficial?

Yes, there should be more collaboration and work with communities with respect to closure plans. If a community would like to save critical infrastructure on a specified property, it should be allowed. For example: the KIDD mine its Metsite in Timmins would like to keep infrastructure such as electricity, rail access, and natural gas, water so the property could be repurposed as an industrial park.

3. What key considerations would you want looked at in a review of bulk sample thresholds?

No comment.

4. What are some of the challenges related to advanced exploration and mine closure planning with respect to the development of critical minerals?

As noted previously, communities should have more input in the decision making process with respect to closure plans. Certain aspects of a site, such as critical infrastructure, could be repurposed for future economic development initiatives and may be seen as attractive by potential site selectors and investors.

Supply Chain and Manufacturing Opportunities

1. What are the barriers and opportunities facing the development of an Ontario-based critical minerals supply chain outside of mineral exploration and development?

Two critical barriers and opportunities facing the development of an Ontario-based critical minerals supply chain are the availability and price of power in Ontario. The Province does not have a competitive edge when it comes to the overall price of power and this is a huge deterrent for all types of large developments, especially those in the value (supply) chain of the critical minerals and resource development industries. As previously noted: manufacturers of batteries require significant amounts of power in its operations and therefore the price of power will be a huge driver for potential investment.

Ontario is also faced with an opportunity to position itself to establish, expand and benefit from secondary processing from critical minerals and rare earth elements. It is dichotomous to think of extracting Ontario’s resources only to send them outside of the Province for processing and manufacturing. Therefore, there should be strong attempt for Ontario to complete these activities “in-house” to best extent possible.

Specifically, Timmins is interested in attracting battery manufacturers that will directly utilize various critical minerals and rare earth elements. Given developments in our community; such as: Canada Nickel Company’s Crawford Nickel-Cobalt Sulphide project, Timmins is well positioned to host battery manufacturers and be a leading community in the support of the Ontario and Federal government’s transition into a more green economy. The Ontario government should consider providing assistance to Timmins in promoting its potential as an ideal location for these types of operations.

2. How can Ontario attract investment in new processing capacity needs in Ontario?

To attract investment in new processing capacity needs in Ontario, the Province can simply provide incentives to this industry for the cost of power and or lower the overall cost of power for all.

Additionally, Ontario could loosen the regulatory stipulations and restrictions surrounding alternative forms of power making it easier for businesses to utilize other (potentially cheaper) substitutes. This could include biomass, small-modular (nuclear) reactors, solar, wind, etc.

3. What key industry partners should be engaged to best position Ontario in securing new supply chain developments?

The key industry partners that should be engaged to best position Ontario in securing new supply chain developments are economic development agencies and existing operating mines. Ontario should work collaboratively with these partners as they fully understand the industry, capacity and capabilities of a community, as well as the potential opportunities that can be pursued. Additionally, there should be a mechanism for municipalities, economic development agencies, chambers of commerce (or boards of trade) to be involved with the overall process. By involving these parties through scheduled consultation, it could reduce the timelines associated with projects by decreasing the duplication of services and allow for increased awareness and education around specific projects for all parties involved.

4. Are there any missing linkages in critical minerals supply chain processes that should be included in an Ontario critical minerals strategy?

No comment.

5. Are there any best practices from other jurisdictions that could be implemented in Ontario to better attract critical minerals supply chain investments?

The Ontario government should look at best practices from its neighboring Province Quebec, as they have positioned themselves to benefit from the trends of critical mineral and rare earth element industries. Additionally, Ontario should look at the best practices of countries such as Sweden and Finland, as they have already began to harness their resources and position themselves to operate throughout various sections of the value (supply) chain, including the manufacturing of electric vehicle batteries.