Map from Canada’s critical minerals strategy: Discussion paper, Government of Canada
Map from Canada’s critical minerals strategy: Discussion paper © Government of Canada

WCS Canada comments on Canada's Critical Minerals Strategy, to Natural Resources Canada


Justina Ray
President & Senior Scientist


Climate change Conservation planning



Perpetuating current approaches and proceeding with an “extraction first” mentality is going to have massive climate consequences.

The federal government’s draft Critical Minerals Strategy is structured around colonial ‘new frontiers’ mindset that leads to a focus on expediting extraction instead of understanding the real consequences of opening up some of the world’s last remaining ecologically intact areas and carbon-rich stores to industrial development.

Our comments on the draft strategy point to the need for a more holistic approach to determining when and where mining for these minerals may be appropriate and how Canada can ensure greater long-term benefits for local communities – particularly the Indigenous communities whose homelands will be most affected -- and society at large.

Perpetuating current approaches and proceeding with an “extraction first” mentality is going to have massive climate consequences as many of the most promising mineral deposits are located in areas that are also hugely rich in stored carbon. If mineral development results in the release of far more stored carbon than it saves through the creation of things like EV batteries or solar panels, then we will be racing backwards on climate action instead of forward. However, the federal strategy does not even address this massive climate risk and has little to say about how to also ensure globally important intact ecosystems are not deeply damaged by new resource projects.

We believe the Strategy needs to be redrafted to better reflect the trade offs inherent in opening up globally important remote areas to mining. Current planning and assessment systems are inadequate to deal with the cumulative ecological and climate consequences of a new mining rush in these areas. We see little effort, for example, to address the critical need to protect the massive amount of carbon stored in many areas being targeted for mining or even to properly account for this impact. Even a rough calculation shows that the end results of mining, particularly in peatlands, will result in increased land emissions in the name of advancing “green” solutions that could undermine the achievement of Canada’s emission reductions targets.

There is certainly a need to advance things like electric vehicles, renewable energy generation and energy storage, but a truly sustainable approach (unlike what it is in the draft strategy), would adopt a clear hierarchy of reducing demand and massively increasing reuse (e.g., recovery of minerals from waste tailings) and recycling (e.g., of consumer electronics) before embarking on ecologically and climatically high-risk new mining ventures.

Canada has a long history of focus on the exploitation of critical natural resources in the name of economic development. We should learn from our own history that the boom-and-bust cycle of poorly planned resource extraction is highly damaging to communities – human and natural. A better strategy would be to recognize and integrate the broad spectrum of globally important resources that exist in Indigenous homelands within the northern reaches of Canada into resource extraction planning. These include, but are not limited to, massive stores of carbon, critical habitat for biodiversity, cultural keystone species, copious freshwater and world-class wetlands.

Ring of Fire

Ring of Fire

More than minerals at stake



Peatlands are the world's largest terrestrial carbon store - and 25% of peatlands are in Canada.