Managing environmental risks of mining critical minerals in Canada

The report identifies three critical environmental challenges for Canada's mining sector: inadequate mine closure and reclamation, the risk of tailings dam failures, and the cumulative impact of infrastructure on biodiversity. It highlights a legacy of abandoned mines and the 'bankruptcy loophole' that allows companies to avoid cleanup costs. The document compares various Voluntary Sustainability Initiatives (VSIs) and regulatory frameworks, noting Quebec's leadership in financial assurance and British Columbia's Cumulative Effects Framework. It argues that mitigating these risks is a precondition for securing the community support and investor confidence necessary to scale up critical mineral production for the clean energy transition.

• Canada faces a significant legacy of environmental liabilities, with at least 10,000 abandoned mines that leave governments responsible for billions of dollars in cleanup costs.
• Gaps in Canadian bankruptcy law have historically allowed mining companies to prioritize secured creditors over environmental cleanup, shifting the financial burden to the public. While the 2019 Supreme Court Redwater ruling requires bankrupt companies to prioritize cleanup costs, the lack of mandatory upfront financial resources remains a challenge.
• Quebec is identified as a global leader in financial assurance for mine closure, having mandated hard and liquid surety for future closure since 2013, including requiring 50 per cent of estimated restoration costs upfront before mining begins.
• Tailings dam failures represent a major environmental and financial risk; Canada has 122 active tailings facilities, 28 of which are ranked as extreme or high risk. The report notes that 'upstream' dam designs are the cheapest but most prone to failure.
• Climate change increases the risk of tailings disasters in mountainous regions, such as British Columbia's Golden Triangle, where glacial retreat leaves destabilized rock that can compromise the integrity of tailings dams.
• Mining development in Northern Ontario's Ring of Fire region threatens one of the world's largest intact peatlands. Experts warn that disturbing this area could release enough greenhouse gases to offset the emissions reductions achieved by the clean technologies the minerals would support.
• The report argues that biodiversity impacts are often poorly managed because they are assessed on a site-by-site basis rather than through a cumulative lens. British Columbia's Cumulative Effects Framework (CEF) is cited as a best-practice model for landscape-level scrutiny.
• Voluntary Sustainability Initiatives (VSIs) like the Initiative for Responsible Mining Assurance (IRMA) often set higher standards than national laws, such as requiring public closure plans and monitoring for at least 25 years after a mine closes.
• The federal government's Impact Assessment Act provides tools for regional and strategic assessments to manage cumulative effects, but these remain underutilized, with only two regional assessments out of 38 active assessments as of April 2025.

APA

Pollon, C., & Al-Aini, E. (n.d.). Managing environmental risks of mining critical minerals in Canada. Canadian Climate Institute. https://climateinstitute.ca/wp-content/uploads/2025/05/Critical-minerals-environmental-risk.pdf

Chicago

Pollon, Christopher, and Eyab Al-Aini. Managing environmental risks of mining critical minerals in Canada. Canadian Climate Institute, n.d. https://climateinstitute.ca/wp-content/uploads/2025/05/Critical-minerals-environmental-risk.pdf.

Wikipedia

{{cite report |last1=Pollon |first1=Christopher |last2=Al-Aini |first2=Eyab |title=Managing environmental risks of mining critical minerals in Canada |publisher=Canadian Climate Institute |url=https://climateinstitute.ca/wp-content/uploads/2025/05/Critical-minerals-environmental-risk.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{pollonndmanaging, author = {Pollon, Christopher and Al-Aini, Eyab}, title = {{Managing environmental risks of mining critical minerals in Canada}}, institution = {Canadian Climate Institute}, url = {https://climateinstitute.ca/wp-content/uploads/2025/05/Critical-minerals-environmental-risk.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }