The province is currently accepting public comment as it creates a regional initiative to capitalise on the growing push to access and produce critical metals.

With an earmarked C$6 million (US$4.3M)  investment, the province aims to grow BC's exploration and mining sector while meeting its greenhouse gas emission reduction targets.

Citing the indispensability of critical metals for daily life, the province put out a discussion paper and a call for public comment on the development of a provincial strategy.

"British Columbia is committed to achieving its legislated climate goals, in alignment with the CleanBC Roadmap to 2030, and to making the transition to lower carbon economies - but this transition cannot occur without critical minerals, which are required in the transportation, electrification, renewable energy generation and storage and technology sectors," the paper read.

Independent from the C$38 billion national Critical Metals Strategy, which lists 31 metals and minerals of strategic importance, BC's planned strategy has raised questions from some about the critical metals designation, the potential toll of mining expansion and the actual value a critical metals strategy will provide residents.

Importance of transparency

Some of these questions were raised in June when The Northern Confluence - a regional environmental- advocacy group, released a report entitled Critical Minerals: A Critical Look.

In it, the author, Nikki Skuce, pointed to the ambiguity in the term critical metals and called for specificity in terms of designation and production plans.

Mining Magazine reached out to Skuce following the province's announcement to find out if the Northern Confluence would be submitting recommendations during the provincial submission call.

Using some of the points in the discussion paper, Skuce plans to submit a five-page submission ahead of the November 5, 2023 deadline.

In an email, Skuce noted that while the paper uses the term critical minerals and stresses the need to develop a strategy, it fails to explain which minerals it deems critical or why the province needs a specific plan.

"The paper points out that other countries and regions have identified many different minerals based on supply chain access, geography, and geopolitical considerations, "among other considerations" - but then fails to highlight what BCs are or how they are going to decide," she wrote. "It is important that BC is transparent and clear about what it ends up prioritising and why."

Deeming criticality

For Skuce, any critical metals strategy must prioritise metals needed for decarbonisation ahead of any others.

"The focus of BC's "critical minerals" strategy should be on minerals needed for the energy transition (to get off fossil fuels). BC mostly mines coal, gold and copper. Given the biodiversity crisis and extent of cumulative impacts, mines for the energy transition, if consent is achieved and environmental risks minimised, should be prioritised over new gold and coal mines," she said.

In the June report, The Northern Confluence, criticised the critical metals push as being "devoid of imagination," and Skuce reiterated this sentiment.

"The [discussion] paper is also based on the assumption that we can mine our way out of the climate crisis when we need broader solutions to reduce consumption to meet our climate goals," she said.

 Instead, Skuce and Northern Confluence would like more emphasis on minimising consumption and reusing the existing metals.

"While there's recognition in the paper about needing to look at the whole value chain, there's no area of focus on the need to reuse/recycle/re-mine as part of the strategy," she said. "I think focusing on brownfield sites and opportunities to reduce, re-use, recycle, repair are a "critical" part of the whole energy transition."

Indigenous input

Skuce also questions the legality of the proposed strategy.

Despite calling for input into advancing recognition and reconciliation with Indigenous Peoples, as Skuce pointed out, there are legal requirements that must be fulfilled in relation to Indigenous sovereignty before a mining strategy can even be discussed.

While referencing the recent Gitxaała v. British Columbia, BC Supreme Court ruling, Skuce explained it is clear that BC needs to incorporate free, prior and informed consent (FPIC) before granting mineral claims in the province within the next 18 months.

"In addition, Indigenous-led land use planning is creating Indigenous Protected and Conserved Areas (IPCAs) as well as no-go zones for mining activity," she said. "The province (and mining companies) need to respect that not all of the over 75% of BC's land base currently open for mining and mineral exploration will be for critical or other minerals and that FPIC is ongoing and needs to be achieved throughout the mining process (exploration, permitting, EA, operation, closure, reclamation)."

In the discussion paper, the province did acknowledge that the First Nations Energy and Mining Council is developing a First Nations Critical Minerals Strategy, independent of the national and provincial initiatives.

"BC and First Nations may consider aligning their strategies in 2024," it read.

Regardless, Skuce stressed the need for FPIC ahead of new mines or expansions and a robust mechanism to gauge the risk and reward balance.

 "There is lots about the economic benefits of mining and exploration and potential to "capitalise" on the critical mineral potential without any acknowledgement of costs, risks or legacy sites," she said.

Despite her scepticism regarding critical metals strategies, Skuce did commend the number of organisations that have been brought together to consider the strategy.

"It does highlight the interconnectedness of various policy priorities, including DRIPA, Mineral Tenure Act modernisation, CleanBC, Biodiversity targets, etc.," she said. "This is a good thing - to see this strategy within broader land-use commitments."

More broadly, Skuce hopes her submission, the report, and the advocacy work The Northern Confluence has achieved is reflected in how BC defines ‘transition' or ‘critical' minerals.

"[And that the strategy] includes opportunities to reduce demand for raw materials by re-using and recycling, as well as re-mining tailings; and that it connects with other BC priorities around MTA modernisation, aligning with DRIPA, biodiversity protection and land-use planning."