Summary Report on Public Consultations in Fermont and Sept-Îles


Report on Public Consultations, February 21 and 23, 2023

Proposed Authorization for the Bloom Lake Mine Project Under the Metal and Diamond Mine Effluent Regulations (MDMER)

Project to Increase the Storage Capacity for Tailings and Waste Rock at the Bloom Lake Iron Mine

 March 17, 2023


Minerai de fer Québec (MFQ) is seeking to increase the storage capacity for tailings and waste rock near the Bloom Lake mine site. The mine is located close to Fermont, Quebec. This project is subject to separate provincial and federal regulatory processes. The process described in this report concerns the federal level.

The Fisheries Act prohibits the deposit of deleterious substances in waters frequented by fish, unless authorized by regulations. This proposed authorization requires an amendment to Schedule 2 of the Metal and Diamond Mining Effluent Regulations (MDMER). The approval, if granted, would result in the water bodies in question being listed in Schedule 2 of the regulations as “Tailings Impoundment Areas.”

To comply with the requirements and obtain authorization, notably a proponent must create and put in place a fish habitat compensation plan that meets all the criteria in section 27.1 of the MDMER. The proponent must first consider alternatives for mine waste management and show that the preferred option is the best one based on environmental, technical, economic and socio-economic criteria. This analysis must be performed in accordance with the Guidelines for the Assessment of Alternatives for Mine Waste Disposal created by Environment and Climate Change Canada (ECCC). ECCC then assesses the analysis.

Different parties have been involved in the regulatory process for the project. They will be introduced at greater length in later sections. ECCC is responsible for the enforcement and compliance of the MDMER. The fish habitat compensation plan submitted by the proponent to ECCC under section 27.1 of the MDMER, is assessed by Fisheries and Oceans Canada (DFO). DFO then provides expert advice to ECCC.

After assessing the compensation plan based on its Policy for Applying Measures to Offset Adverse Effects on Fish and Fish Habitat Under the Fisheries Act, DFO gives  ECCC  a recommendation on the adequacy of the plan, in order to proceed with consultations. ECCC then undertakes the next stage of the regulatory process by coordinating the public consultations. Canadians and Indigenous nations were invited to participate in order to get informed and share their comments and concerns.

For the Bloom Lake project, ECCC asked Boreala Management, an external third party specialized in facilitation, to provide support in the various stages of the public consultations. They took charge of:

Consultation process

The two public sessions took place in Fermont on February 21, 2023 (7:30 to 9:30 p.m.) and in Sept-Îles on February 23, 2023 (5:30 to 8:30 p.m.). The session in Fermont was only held  in person. The session in Sept-Îles could be attended either in person or remotely via an MS Teams link. The sessions were designed to facilitate access to as many participants as possible.

The purpose of the consultations was to solicit participants’ comments and questions on the reports presented by Minerai de fer Québec (the proponent). These documents were the assessment of alternatives report and the fish habitat compensation plan (FHCP), the latter serving as the main focus. Until April 3,2023, participants could also email their comments and questions via a page on the Government of Canada website. Consultations will also be organized with the different Indigenous nations affected by the expansion project or the compensation measures. However, these last two components of the consultation process are not included in this report.


A number of stakeholders made presentations at the consultation sessions and answered questions and addressed comments from the public:

These stakeholders performed different roles during the consultations. ECCC supervised the overall consultation process and presented the applicable regulations. DFO presented its mandate and its conclusions on the compensation plan submitted under section 27.1 of the MDMER.  MFQ was responsible for presenting the assessment of alternatives report and the FHCP. These three stakeholders were also responsible for giving details on and responses to comments and questions from participants. Given the collaborative and complementary nature of the approach taken, the responses provided in this document are a summary of all interventions.

Participants at the sessions included:

A total of 15 people attended the session in Fermont. The Sept-Îles session had 12 virtual participants and 32 in-person attendees. See Appendix 1 for a complete list of the participating groups.

Main findings and comments from the sessions

Participants raised several points during the public consultations. The areas addressed can be divided into four categories:


This section outlines the points raised about the regulatory framework in the context of the project to increase tailings and waste rock storage capacity for the Bloom Lake mine. This includes the process to assess the compensation measures, as well as their implementation and monitoring.

Participants took issue with the regulatory framework governing the overall process. It should be noted that the process at the provincial level was also challenged. The provincial process, however, which includes the publication of the report from the Bureau d’audiences publiques sur l’environnement (BAPE) was completed prior to the federal one. Consequently, participants requested clarifications on the changes that were made to the compensation plan since the publication of BAPE’s report.

Some participants said that not enough time was allotted for the proponent to give a detailed presentation on the fish habitat compensation plan.Footnote 1  For example, participants wondered about project phases and implementation schedules, as well as timelines. MFQ emphasized, among other things, the 53% reduction in the area impacted (in hectares) relative to the initial mine plan. The analyses and plans available onlineFootnote 2  also give more detail on the specific studies and projects to be undertaken.

One participant shared concern about the objectivity of data collection, which is done by specialized firms hired and paid by the proponent to analyze the project. He evoked the appearance of a conflict of interest from the outset, regardless of the firm retained or the proponent involved. The suggestion was made that measures be put in place to better ensure the absence of bias by the specialized firms required to produce these expert reports.

The WSP representative emphasized the company’s rigorous processes and work ethic. Furthermore, DFO stressed that the data submitted were analyzed by its experts, based on all the knowledge and information sources available. This included site visits to:

ECCC added that the tools it has in place to analyze the alternatives integrate objective measurements to manage the subjectivity inherent in all decision-making.

Both economic and ecological concerns were raised over the selection of the sites for the compensation plans. It was stated that many sites are located at a significant distance from the Fermont region. Although, this was the area directly impacted by the project. The stakeholders explained that the high concentration of mining projects in the region resulted in a high density of offsetting projects. Consequently, a wide range of suitable sites were identified in the Fermont region and elsewhere in Quebec. In the end, sites were chosen that maximized the positive effects on fish habitat as a whole.

A one-to-one ratio between the project’s impacts on fish habitat and the effects of the offsetting measures cannot be measured in this context. Therefore, questions were asked on the weighting method used to assess the value of the various compensation measures. At the same time, clarifications were requested on the method used to determine the total monetary amounts required. This includes amounts for implementing adequate measures to offset the loss of water bodies and on the use of the financial guarantee. Some of the discussion also focused on ensuring that these amounts were not a way of avoiding monitoring activities and compensating for the losses.

DFO explained that the requirement to supply a financial guarantee was a precautionary measure. It would only be used if the proponent did not implement the compensation measures as agreed, or if the objectives of these measures were not achieved. In addition, the amount of the guarantee was determined based on the costs of implementing compensation measures deemed suitable and sufficient. The aim is to offset the impacts on fish habitat resulting from the disposal of tailings and waste rock. The estimation of monetary amounts and the validation of the proportionality of the compensatory measures in relation to the loss of fish habitat conducted by DFO, are carried out according to various parameters and data. Some of them are provided by the proponent and others through research and analysis conducted by DFO. Therefore, the required compensation measures are identified prior to determining the monetary amounts required to implement them.

Concerns were also raised about the development and construction of spawning grounds. The fragility of such infrastructures in the medium or long term was mentioned. One  issue was the monitoring process to ensure the adequate functioning and longevity of this infrastructure.

Another concern related to the measures considered if the objectives were not met. Similarly, some participants shared concerns about the duration of monitoring after the mine ceases operations. They asked for details on the number of years that monitoring activities would be carried out by the proponent to ensure that the compensation measures are functioning properly in line with the objectives. They also requested clarifications on the process used by DFO to monitor the implementation of the compensation plan. The arrangements for remedial measures and potential penalties, if required, were also discussed, for cases where deadlines were not met.

First, DFO explained that it would conduct compliance monitoring based on the reports submitted by the proponent. As well, there will be on-site monitoring to ensure that the objectives were satisfactorily achieved. Additional monitoring or supplemental compensation measures could be required. Moreover, the development of spawning grounds must take into account the movement of a watercourse. It must also be based on an approach aimed at sustaining the spawning ground created. The location of the watercourse, and the spawning ground in it, are two key criteria that can be used to improve longevity.

A question was asked about whether the tailings had been analyzed to allow the remaining mineral content in the tailings to be determined. Those results could ensure more transparency on the tailings to be deposited at the new storage site. WSP explained that the analysis showed the presence of silica particles with very few metals, indicating that the process was mechanical.

Lastly, some participants requested access to detailed maps showing the locations of the projects or the plans provided by the proponent. MFQ explained that this information was available online on the ECCC website, in various reports that the Department has made public. The link to these documents is in Appendix 2 of this report.

Impacts of the various alternatives

Several points raised by participants during the sessions concerned the short and long-term impacts of an increase in the mine waste storage capacity. As well, the impacts of the alternatives proposed by the proponent.

Participants shared concerns about and mentioned the need to test the edibility of fish in the affected water bodies and water quality itself. WSP stated that no evaluations of the quality of fish flesh had been conducted. Furthermore, such an evaluation was not required under the regulatory process. Participants were sometimes confused about the assessment of the environmental impacts of mine waste disposal and the positive effects of the measures outlined in the compensation plan. Their concerns sometimes intersected with questions discussed in the Methodology category above.

Questions were raised with respect to potential impacts on residential development near the areas included in the compensation plan. DFO noted that the compensation measures do not, in themselves, add any specific restrictions in relation to residential development. The existing legislative and regulatory framework already protects the habitats concerned and continues to apply.

Lastly, a point was raised about the use of the open-pit mine for the disposal of mine tailings. This was one of the scenarios that was not selected in the alternatives assessment. Some participants argued that this was a more environmentally sound option. MFQ responded to this comment by stating that the province did not authorize this option. The province considers that the mine could still have mineral potential. Therefore, the disposal of mine tailings in the pit would condemn its potential.

Concerns outside the specific scope of the consultations

The fish habitat compensation plan was the main focus of the consultation sessions held in Fermont and Sept-Îles. However, some participants raised questions that went beyond the scope of the federal public consultation process. Their comments were nevertheless noted.

Eau Secours and certain participants asked questions about the process of selecting the alternative, which was approved at the provincial level. A number of points highlighted in the BAPE report were mentioned. In addition, some participants criticized the rigidity of the assessment process and criteria. It was noted that some innovative alternatives had not been examined. The participants mentioned it was because the current regulatory framework does not allow it, even if they could be relevant or have a smaller ecological footprint.

Eau Secours also questioned ECCC’s approvals process for tailings disposal. The organization pointed out that all recommendations thus far that list these water bodies as tailings impoundment areas were approved and that the process was purely administrative. ECCC explained that Treasury Board had not rejected any recommendations, because recommendations are not made until the consultations have been completed and all regulatory requirements have been met.

Eau Secours also mentioned that it had submitted an access to information request to the province to obtain documentation related to the disposal of mine tailings in the open‑pit mine. The province refused to provide this documentation. Eau Secours asked whether ECCC was aware of this explanatory document and the Department answered that it was not.

Participants at the Fermont session expressed concern about the location of a snowmobile trail in an area affected by the mine plan. A request to have access to the lake despite the change in route was made during the session. The proponent stated that access to the water bodies affected by the compensation measures would not change. However, the snowmobile trail would no longer be usable and would be relocated.

Clarifications were requested about how the production chain works, from mining to steel making, as well as its impact on the project. Participants shared concerns about the pollution created throughout the processing chain and not just that associated with mine tailings. The proponent explained the process and indicated that it had a major impact on decarbonization. The resulting iron concentrate can be used for direct reduction or electric arc furnaces. The proponent said that the reduction in carbon emissions is equivalent to taking two million cars off the road.

Some participants raised concerns regarding the avian species that occur near the affected water bodies. Participants asked questions about whether species other than fish had been studied. They also asked if they were considered in the assessment of the potential impacts of the tailings impoundment areas and the proposed compensation measures. Some participants noted that the plan focused on salmon. They stated they were worried about the avian species living near the areas covered by the compensation measures or the protection of biodiversity in general.

In summary, several participants argued that the entire ecosystem should be taken into consideration when a compensation plan is established. The elements included in the overall assessment were discussed at length. According to the participants, fish should not be the only element considered. The proponent indicated that different species living near the various sites had indeed been considered in the analyses. This led to an assessment of the feasibility and relevance of the proposed compensation measures. The existing regulatory framework must be applied as is. However, all comments outside the scope of this framework were noted.

Finally, participants asked for details on the progress of the compensation project, which is currently being discussed with the residents of Lac Daigle. Since the proponent and the residents are still in discussions, the subject could not receive further comment.

Other responses

Comments from representatives of the Band Council of the Innu Community of Uashat Mak Mani-Utenam

Two representatives of the Band Council of the Innu Community of Uashat Mak Mani-Utenam, who were present virtually at the meeting in Sept-Îles, shared comments.

They pointed out that there were agreements in place with the proponent and that additional requirements had been brought to the proponent’s attention. For example, pardoning ceremonies and requests to relocate fish. One of the representatives expressed concern about the location of the compensation plans, since several sites were located outside the Nitassinan (traditional lands) of the Innu Community of Uashat Mak Mani-Utenam.

Furthermore, the representatives stated that the community’s collaboration with the proponent in this expansion project is the result of informed and freely-given consent. They also pointed out that not all mining projects are covered by such an agreement. It was mentioned that work remains to be done at the provincial level with respect to mining royalties. The royalties are not shared with the community at present. The proponent thanked the community stakeholders, stating that it would work to ensure that their relationship continues to flourish in the coming years. DFO mentioned the importance of ensuring that this relocation does not have adverse effects on and disrupt the existing balance in the watercourses and water bodies concerned. In the event that fish are to be relocated, the province will have to be consulted as well.

General comments

A number of participants in the Sept-Îles session indicated that they are not opposed to the mine expansion project. From their perspective, the main issues are the effects on ecosystems, including fish, and the project’s impacts on humans. The promoter said they have heard these comments about the human aspect of the projects. They assured participants that they would follow up on activities and that protecting the territory as a whole was important.

One participant mentioned the proponent’s potential influence on the negotiation of agreements with affected Indigenous communities. He referred to the signature of Impact Benefit Agreements (IBA), among others. Those stakeholders did not comment on the agreements as they are bilateral agreements between the communities and the proponent.

Eau Secours stated that it was concerned about the lack of options and land available for developing compensation projects. The organization mentioned that the regulations and the entire process at the federal and provincial levels should be reviewed in order to prioritize alternatives based on avoidance. MFQ pointed out that the province had not authorized the use of the open-pit mine for tailings disposal. Furthermore, the assessment of alternatives provided the opportunity to analyze options that would not affect fish habitat, including filling the open pit. However, this option was not retained, for the reasons mentioned by MFQ.

A representative of the United Steelworkers (USW) mentioned the satisfaction expressed by several USW members who are currently working at the Bloom Lake mine. He pointed out that the workers he represents are proud of working for this company. He saluted the challenging work that must be done and the effort required, amidst the complex and diverse concerns that need to be addressed in the context of mining projects. The proponent thanked the USW representative and indicated that it would continue these beneficial efforts.

Lastly, an Innu participantFootnote 3  gave a speech on his own behalf and that of his territory. He took the floor to share his story which he wanted to be heard by all. Although agreements may have been reached between the Band Council and the proponent, he himself did not benefit from an agreement related to these projects to be carried out on his traditional lands. He shared his concern about the situation and lack of attention paid to human considerations in the plans presented. The proponent noted these comments, and also undertook to contact the participant to discuss the matter further.


Most of the questions and concerns raised at the February 21 session held in Fermont focused on the methodology related to implementing the measures contained in the fish habitat compensation plan. Various questions were also about the direct and indirect impacts related to the plan and fish habitat.

Regarding the session held on February 23 in Sept-Iles, more general concerns were shared related to the steps in the process and the regulatory framework. There was also a focus on environmental effects, accompanied by comments and testimonials. The process already completed at the provincial level was also mentioned many times.

Generally, the individuals who participated in the public consultation sessions indicated that they were not opposed to the Lake Bloom mine expansion project. The discussions, questions and comments focused more on the assessment methodology and the environmental impacts. They sometimes touched on the regulatory framework, at times going beyond the specific scope of the consultations.

As mentioned in this report, it was not always possible to deal with questions concerning the provincial regulatory framework during these sessions. Therefore, the stakeholders did not respond to certain questions. However, answers were provided regarding the federal process that is underway, through complementary responses made by the different presenters. Comments and testimonials outside the scope of the process were noted by the proponent, as well as by ECCC and DFO.

Finally, various documents are available, which could provide additional details in relation to the responses summarized in this report. Specifically, they provide additional information concerning the analyses of the alternatives and the compensatory measures. The documents can be found on the Government of Canada website (see Appendix 2).

Appendix 1 — List of organizations present at the public consultation sessions

Fermont session (February 21, 2023)

Sept-Îles session (Ferry 23, 2023)

Appendix 2 — Detailed documentation available online

Several documents provided by the proponent are available on the Government of Canada’s public consultation page for this project.

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