CPAWS Manitoba Position on Critical Minerals

mining stock image
May 1, 2024

CPAWS Manitoba recognizes that there is a strong demand for critical minerals to support the green energy transition. 

Resource development cannot come at the expense of our communities, lands, and waters.

As Premier Wab Kinew stated in February 2024: “in order for Manitobans to be healthy now and for generations into the future, we have to protect a clean, safe and healthy environment.”

“We are prepared to develop mining opportunities in Manitoba, but it has to be done in the right way,” Premier Kinew added. “It has to be done in a way that minimizes the risk to the health of humans and the safety of the environment.”

Here are CPAWS Manitoba’s key recommendations for what needs to be included in Manitoba’s upcoming critical minerals strategy.

Context and Commitments: 

The science is clear that Manitoba and the world face dual and interconnected climate and biodiversity crises. The need to work towards a more equitable, carbon-neutral, nature-positive world has been widely recognized as essential for the future of humanity.

The provincial government has made important commitments to address these threats by achieving net zero by 2050 and by protecting 30% of Manitoba’s lands and waters by 2030. 

Delivering on these goals and targets will require a whole-of-government approach with all parts of government aligning their policies and investments with these goals. 

Do Mining Right: Recommendations for Manitoba’s Upcoming Critical Minerals Strategy 

  • Land use planning should be completed before decisions are made on mineral development that could undermine Manitoba’s nature goals. 
    • Mining exploration and development must be undertaken in the context of protecting 30% of Manitoba by 2030. 
    • All protected areas candidates, including Indigenous Protected and Conserved Area initiative study areas, Areas of Special Interest, and other proposed conservation designations should be withdrawn from mining claims and exploration until the respective conservation planning processes are complete.
    • Land use planning should ensure the full range of ecological, economic, social and cultural values are recognized and valued in decision-making. 
    • Land use planning provides certainty to industry about where and how they can operate.
  • High-carbon landscapes should be identified and protected from development which would result in significant emissions.
    • Projected GHG reductions from clean technologies will not offset the resulting GHG emissions should these high-carbon landscapes be developed and would also irreversibly damage these environmentally significant ecosystems, undermining the government’s biodiversity conservation commitment.

  • The development of any new mining project must be approached with attention to the broad and cumulative impacts on biodiversity, climate change and water systems.
    • Environmental impact assessments must go beyond the project boundaries using tools such as regional and cumulative assessments. 
    • Assessments should include potential impacts on stored carbon and carbon sequestration potential resulting from landscape change. 
    • Assessment should establish scientific baselines of regional conditions against which no-net loss mitigation hierarchy projects will be measured.

  • A fair and equitable partnership process must be established for engaging with Indigenous communities on their lands which goes beyond their right to free, prior and informed consent.
    • Indigenous communities with ancestral ties to lands proposed for development must be included as joint decision-makers at every stage of the process, from first access and claim staking to mine restoration.
    • Benefits and revenues generated from critical mineral development should be shared with Indigenous communities in a just and equitable manner which respects and upholds their inherent and constitutional rights. 
  • Make the most of the resources and energy we use.
    • Apply a whole-of-government approach to: reduce overall demand for new materials; increase the reuse and recycling of existing materials; and improve energy efficiency.
    • Prioritize the recovery of minerals from tailings and the potential for reopening old mines.
    • Prioritize the development of projects near existing infrastructure in order to reduce the need for new roads, hydro corridors and other linear disturbances.
      Minimize the impact of new linear disturbances and infrastructure built to support new mining operations.
    • Low-carbon sources of energy (geothermal, solar, wind, hydro, run-of-river) must be used to power all mining operations. 
    • Costs for new infrastructure to service mining operations should be borne by the company, not by taxpayers.

  • Manitoba must ensure the mining industry is held to the highest possible standards and that entities are held accountable for their actions. 
    • Regular reviews of government regulatory frameworks and inspection and enforcement actions must be conducted to ensure best practices are maintained and to avoid conditions conducive to regulatory capture. 
    • Clear boundaries must be maintained between government staff charged with regulating the industry and those charged with promoting the industry. Promotion of the industry and regulation of the industry should be housed in separate departments.
    • Regular inspections and technical reviews should be conducted to ensure standards and codes are followed. Appropriate fines and penalties should be assigned to ensure the economic incentive is weighted toward compliance.
    • At a minimum, all new projects must be certified by the Initiative for Responsible Mining Assurance as complying with best practices on an ongoing basis. 
    • Regular monitoring and mitigation of environmental impacts – ideally through Indigenous Guardians programs – should be a required cost of operating a mine in Manitoba. 
    • Mining entities should be required to achieve no-net loss to regional biodiversity and ecosystem services by applying the mitigation hierarchy throughout the mine life cycle. 
    • Mining entities should be required to ensure mine waste structures are appropriately and safely designed, operated, maintained, and closed.
  • A mine closure plan and funds to cover clean-up costs must be secured prior to the commencement of mining operations so that these costs are not borne by the public. 

 View the PDF of our position paper

Reference Documents:

Principles for a Green Energy Transition (2023) Canadian Environmental Law Association, in partnership with CPAWS Manitoba and 13 other organizations.

First Nations Critical Mining Strategy (2024) BC First Nations Energy and Mining Council.

Mining Policy Framework (2023) Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development.

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