2018-07-20
The Honourable Greg Rickford
Minister of Energy, Northern Development and Mines
34 G King Street
Dryden ON
P8N 1B3
Dear Minister Rickford,
RE: Mining permitting system and the Ring of Fire
On behalf of the Greater Sudbury Chamber of Commerce and Greater Sudbury’s business community, I am writing to you regarding mining regulations in Ontario and their impact on the development of the Ring of Fire.
The Ring of Fire project in Northern Ontario has the potential to produce considerable wealth for the province, with estimates of well over $60 billion and the creation of more than 5,500 jobs. Ontario is a global leader in the mining industry and developing the Ring of Fire is essential to maintaining our competitive edge and promoting economic development in Northern Ontario.
The former Liberal government committed $1 billion to building an all-season road to the Ring of Fire. It is our understanding that discussions with the Matawa communities are progressing and that the environmental assessments for the road are underway. We are encouraged by this progress and urge your government to continue with this work.
In addition to developing this road, however, the Government of Ontario must create policy conditions that are conducive to investments in the Ring of Fire and that will allow the further development of the project. The current policy framework has caused delays with the Ring of Fire and other mining projects that have produced real opportunity costs for project proponents, workers, and communities.
To prevent further delays with the Ring of Fire, the provincial government must conduct a comprehensive review of the mine permitting system and engage in extensive consultations with industry stakeholders with the aim of:
- improving the system’s transparency, and
- reducing regulatory uncertainties.
Ontario’s mining sector competes not only against international jurisdictions but also against other Canadian provinces. To attract investment to the Ring of Fire and other mining projects, Ontario’s regulatory transparency must be competitive with other Canadian provinces as well as international competitors. According to a 2016 Fraser Institute report, more than 70 per cent of mining industry representatives in Saskatchewan said that regulatory transparency was an incentive for growth, while in Ontario only 5 per cent said the same. When investors do not understand what the regulations are or how they are applied, it discourages investment and hamstrings economic growth. The government must work to improve that industry perception; conducting a consultation-heavy review of Ontario’s mine permits system will lead to improved trust in the mechanics of the system and support the development of the Ring of Fire and other projects.
In addition, we encourage the government to reduce regulatory uncertainties in the system. Industry remains uncertain about the approval process for mining permits and the length of time the process can take. That same Fraser Institute report indicated that Ontario’s industry was far less confident that it would receive mining permits in a reasonable amount of time than were the industries in either Saskatchewan or Manitoba. What is more, the majority of industry representatives indicated that the length of time to get a permit in Ontario has increased over the last ten years. These are worrisome indicators for the future of Ontario’s mining industry. If investors are not confident in Ontario’s regulatory framework, it is less likely they will consider investing in our economy.
To address these issues, we urge the Government of Ontario to conduct a thorough review of the province’s mine permitting system to improve transparency and reduce regulatory uncertainties. This review ought to begin with the findings of the province’s own Red Tape Challenge report on mining, which highlighted a number of opportunities for regulatory improvement, including streamlining mine permit applications, harmonizing with other jurisdictions, and using industry standards to develop new regulations. In addition to using these findings, however, the government should re-engage the industry through stakeholder consultations so that they may fully participate in reform of the regulatory system. Such an initiative will drastically improve industry confidence in Ontario’s economic future, improve our competitive edge versus competitor jurisdictions, and ultimately lead to the development of new mining projects.
On behalf of Greater Sudbury’s business community, thank you for the opportunity to provide our thoughts on mining regulations in Ontario and we look forward to a constructive dialogue on the topic. We look forward to your response at your earliest opportunity.
Yours truly,
Debbi M. Nicholson
PRESIDENT & CEO
cc Doug Ford, Premier of Ontario
Vic Fedeli, Minister of Finance
Jamie West, MPP Sudbury
France Gélinas, MPP Nickel Belt
Ontario Chamber of Commerce