Ecology Action Centre’s Position Statement on the Department of Natural Resources and Renewable’s Critical Minerals Strategy 2024

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On March 4, 2024, the Province’s Department of Natural Resources and Renewables released their Critical Minerals Strategy. This Strategy includes a list of 16 minerals found in Nova Scotia which will “help with climate change goals, are in global demand and present strategic opportunities for the Province.” 

While a swift transition to renewable energy technologies and systems is needed, Nova Scotia must ensure that this transition is just, and takes a people- and environment-centred approach. The Critical Minerals Strategy should properly reflect this.  

Below are Ecology Action Centre’s high-level recommendations for improving the Critical Minerals Strategy. These recommendations were shared with the Department while the Department was drafting the Strategy. 

Climate Change 

The Strategy draws connections to one of Nova Scotia’s commitments to reduce its contributions to climate change (the Province’s emissions reduction goal for 2030) and alludes to how the Critical Minerals Strategy will help with that. There is much more work on climate change, including by the Province, to connect to, beyond the one emission reduction goal. The Strategy could be strengthened by describing how it will contribute to the emissions reduction goal, and other commitments, in a way that aligns with the Environmental Goals and Climate Change Reduction Act (EGCRA) and other provincial targets and policies (e.g., the Our Climate, Our Future: Nova Scotia’s Climate Change Plan for Clean Growth).  

Furthermore, while the Strategy mentions “strong environmental principles” early in the document, it does not discuss environmental protections nor acknowledge that mining has considerable environmental impacts. Mining for critical minerals will create more environmental impacts – the Strategy does not discuss how those impacts will be mitigated or what environmental restriction will be observed in the Strategy.  

Crown Land Use Planning 

Many mining projects are proposed and carried out on Crown Land, but Crown land also needs to be managed for other purposes under the Crown Lands Act, including forestry, outdoor recreation, and biodiversity conservation, in addition to new uses such as wind farms, housing and green hydrogen plants and infrastructure. The problem is they are all occurring independently and with no landscape-level planning to determine where these different, and sometime conflicting uses, are best located and where some should not be located. We once again ask for, as part of the Critical Minerals Strategy, a commitment by the Province to undertake a comprehensive, spatial Crown Land Use Planning process to ensure that industrial activities are sited in areas that are appropriate without negatively impacting, or harming, other uses and values on Crown lands.  

What the Strategy Will Support 

This Strategy could support many things and does mention some potential new directions for the Department. Recycling is briefly mentioned twice. If the Strategy and the Province is serious about supporting more recycling of critical minerals in Nova Scotia, the potential to support critical mineral recycling should be elaborated upon in the Strategy. Seriously advancing critical mineral recycling, and other parts of the critical minerals value-chain, in Nova Scotia would be a step closer towards actualizing a circular economy here.  

It is stated that the Strategy is an opportunity to engage in relationship-building with Mi’kmaq organizations and Nations, however it is not clear if the Province engaged with interested Mi'kmaq groups before creating the Strategy.  Moreover, there may also be an opportunity to work on improving inclusivity in mining through the Strategy, but this deserves further discussion. For example, the Strategy should answer the following questions: How would the Strategy work on inclusivity? Will it identify gaps in the current mining industry in Nova Scotia and work with stakeholders about how these could be addressed? How will historically marginalized communities be engaged? There may be an opportunity with the Strategy to change some aspects of the mining industry to make it more inclusive. These approaches to social justice are an important part of working on climate change too. 

In addition, the Strategy also proposes to examine regulatory efficiencies. "Regulatory efficiencies" can sometimes mean making regulations and processes less stringent for companies. We should not weaken the regulations and processes already in place for the mining industry for proposed projects. If anything, regulations and processes should be stronger when it comes to protecting water and biodiversity. 

What the Strategy Will Not Support 

To be considered strategic, a strategy should not simply state what it will do or will support more of, but also be clear the directions it is not taking. The Strategy could be improved upon by describing what it will move away from – and this could be connected to climate change as well. The Strategy does not recognize that mining is one of the most polluting industries in the world, uses huge amounts of freshwater, produces significant Greenhouse Gas Emissions and destroys vast areas containing biodiversity and ecosystems. All of these exacerbate the twin crises of climate change and biodiversity loss. This Strategy should present the opportunity to move the mining industry away from these unhelpful practices. 

For example, gold is not a critical mineral and its extraction produces significant amounts of atmospheric and ground and water level pollution. We do not need open pit gold mining to continue in Nova Scotia as it is an unnecessary industry. Gold can be recycled infinitely, and there is already more than enough mined gold to meet the needs of humans. Gold is not needed for the green energy transition. The Strategy should speak to specific steps to move away from mining that is not supporting the transition to greener economies.  

Use of the Mined Minerals 

The Strategy highlights the ways in which each of the critical minerals can be used in the green energy transition. One of the criteria used to develop the list of critical minerals is that each mineral contributes to the requirements for Nova Scotia to reach our emission reduction targets, including 80% of energy produced from a renewable source by 2030, and net-zero emissions by 2050. It is important that the critical minerals mined in Nova Scotia do get used for the green energy transition rather than being sold and used for other industrial and production purposes. The Strategy should outline accountability with respect to the supply chain to ensure the critical minerals mined in the province will in fact be used for the green energy transition.  

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