Mining 2030 Unearthing Ontario's Potential

MINING 2030: Unearthing Ontario’s Potential

Table of Contents About the Ontario Chamber’s Mining Initiative ......................................................... 2 Introduction ................................................................................................................ 3 The Strategic Pillars of Mining in Ontario.........................................................................................3

Challenges............................................................................................................................................4

Mining in Ontario......................................................................................................... 5 Indigenous Partnership ............................................................................................... 7 Environmental Collaboration .............................................................................................................8 Benefit Agreements ............................................................................................................................8 Equity Partnerships .............................................................................................................................9

Supporting More Partnerships ....................................................................................................... 10 Clear Process for Engagement ....................................................................................................... 11

Fiscal Regime ............................................................................................................12 Flow-Through Shares ....................................................................................................................... 12 Exploration Support ......................................................................................................................... 14 Supporting Project Financing ......................................................................................................... 15

Regulatory Reform ....................................................................................................17 Regulatory Reform Urgency Across Canada ................................................................................ 17 Ontario’s Current System................................................................................................................. 18 Legislative Progress in Ontario ....................................................................................................... 20

Energy .......................................................................................................................23 Energy Use on Mines and Electrification ...................................................................................... 23 Volatile and Increasing Energy Costs ............................................................................................ 24 Northern Energy Advantage Program ........................................................................................... 26

Workforce, Community, and Infrastructure ..............................................................27 Road Infrastructure ........................................................................................................................... 28 Social Infrastructure ......................................................................................................................... 28 Immigration ....................................................................................................................................... 29 Indigenous Employment ................................................................................................................. 30

Public Education & Marketing Mining Careers............................................................................. 31

Summary of Recommendations ................................................................................33 Conclusion.................................................................................................................34 Addendum: Potential Economic Impact of Regulatory Reform ................................35 Appendix A: Methodology ............................................................................................................. 43 Appendix B: Limitations .................................................................................................................. 45

References ................................................................................................................47

About the Ontario Chamber’s Mining Initiative The Ontario Chamber of Commerce (OCC) convened a Mining Policy Council in January 2025 to identify the policy and regulatory conditions necessary to capitalize on the mining sector’s opportunity and ensure its sustainable growth.

With thanks to lead author Patrick Beatty, and contributions from other members of the OCC team, including Ali Nasser Virji, Simran Singh, Sharan Khela, Andrea Carmona, Michael Thede and Jeff Law.

In the next five years, Ontario must ensure it has the workers, capital, energy transmission and distribution, infrastructure, and social licence from communities necessary to accelerate mining exploration, development and production – all preconditions for success in one of the world’s most strategically important industries.

The contents of this report do not necessarily reflect the opinions of individual members of the Mining Policy Council, their organizations, or any other contributors that may have participated in its drafting.

Throughout 2025, the OCC engaged the council in broad discussions about Ontario’s mining sector and the best ways to enable its growth. This report is the product of those discussions. The OCC thanks the founding members of the council for their input into this report, their vision, and their ongoing commitment to inclusive, sustainable prosperity: • Andre Leite (Co-chair), Vice-President, Operations (Ontario), Agnico Eagle Limited

Where attributed to PwC, the data and figures presented in this report are drawn from analyses included in the addendum. They are subject to the assumptions, definitions, methodologies, and limitations applicable to the analysis therein. Readers encouraged to consult the addendum for the complete description of scope, assumptions, and limitations.

This report focuses on the upstream stages of Ontario’s mining value chain, from exploration to production, where targeted action can unearth opportunities for growth.

• Marla Tremblay (Co-chair), Executive Director, MineConnect Supply and Services Association • Alastair Rhoades, Head of Corporate Development, Green Technology Metals • Brad Ryder, Director, Government Relations, Agnico Eagle Limited • Charla Robinson, President, Thunder Bay Chamber of Commerce • Daniel Bornstein, Partner, Business Law, McCarthy Tétrault LLP • Giancarlo Drennan, Vice-President, Practice Lead (Ontario), Sussex Strategy • Keitha Robson, Chief Administrative Officer, Timmins Chamber of Commerce • Krista Maydew, Vice-President, External Affairs, IAMGOLD • Marie Litalien, President and Chief Executive Officer, Greater Sudbury Chamber of Commerce • Michael McMillan, Partner and Managing Director, PRA Communications • Priya Tandon, President, Ontario Mining Association • Rebecca Thompson, Vice-President, Public Affairs, Alamos Gold • Sydney Oakes, Director, Indigenous Relations and Public Affairs, Canada Nickel Company

The OCC also thanks PwC Canada for their support as a lead research contributor: • Mikaela McQuade, Partner, Economics & Policy • Gemma Stanton-Hagan, Director, Economics & Policy

Photo: PENDA Productions Inc. “Alamos Gold YD & IG”, 2025, via www.pendaproductions.com

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Introduction Mining touches the lives of Ontarians every day, yet most have never seen it up close.

While mines are typically located far from public view, their products play significant roles in everyday life. When someone turns on the lights, cooks a meal, rides in a vehicle, or uses a mobile phone, they benefit from mining products. On any given day, an Ontarian has likely interacted with mining products hundreds of times without realizing it.

Simply put, mining products are building blocks of nearly every part of modern life.

Mining has taken on new urgency within an uncertain and evolving geopolitical climate.

As global tensions rise, supply chains fracture, and governments pursue ambitious net-zero targets, secure access to responsibly sourced minerals and metals has become a strategic imperative. In Ontario, mining has emerged as one of the province’s most strategic assets. It can drive economic growth and achieve objectives central to climate action, national security, and reconciliation with Indigenous Peoples.

The Strategic Pillars of Mining in Ontario The mining sector is already a major economic driver and job creator across the province but now, more than ever, amid increasing geopolitical uncertainty, strategic investments in mining are needed to fuel our economy.

Mining sustains well-paying jobs in remote and rural areas that often lack access to broader economic opportunity, with mining companies and the industries that support them serving as anchor employers in these communities.

Global decarbonization depends on ensuring a secure and affordable supply chain for mining products.

A recent report by the Energy Transitions Commission highlights that substantive investments and rapid mining expansion are critical to meeting global demand for the inputs required for a net-zero economy.1 The products from mining are critical inputs into electric vehicles, non-emitting electricity generation (wind, solar, and nuclear), the power grid, transmission, energy storage, and many other energy efficiency and emission reduction technologies.

This reflects significant evolution in the decade since the OCC published Beneath the Surface: Uncovering the Economic Potential of Ontario’s Ring of Fire.

As the International Energy Agency (IEA) notes, until the mid-2010s, the energy sector represented a small part of demand for critical minerals. Today, clean technologies are the fastest-growing segment of demand for critical minerals globally.2 This trend is only expected

to accelerate as the green transition proceeds and governments rethink how we power, transport, and manufacture to achieve global targets for a net-zero economy by 2050.

Mining is also indispensable for North American security.

Critical minerals are essential components of modern defence systems, including jet engines, missiles, aircraft, drones, lasers, targeting systems, radar, communications devices, and many other defence applications. In 2024, the North Atlantic Treaty Organization (NATO) released a list of 12 defence-critical raw materials that were essential for security, nearly half of which are produced

by Ontario mines.3 Securing the supply of these materials has become more pressing for governments as geopolitical events have caused increasing strain on international supply chains.

Many of these critical minerals are currently found in countries that are neither democratic nor NATO allies and cannot be relied upon for a secure supply. The U.S. Department of Defense is already investing directly into Ontario to support the development of these resources and the North American supply chain, while the Canadian government now counts investment in mineral mining and infrastructure as part of its revised defence spending targets.4 This reflects a growing recognition that mining is not only an economic driver but also a strategic pillar of national security.

Mining 2030: Unearthing Ontario’s Potential | 3

Mining is an important pathway to advancing reconciliation with Indigenous peoples, nations and communities. Today, the mining industry is the largest private sector employer of Indigenous people across Canada.5 Mining is among the few major economic activities in the rural and northern areas where many Indigenous communities are located, representing a generational opportunity for economic reconciliation.

Indigenous communities are at the frontline of mining developments and stand to share in the prosperity from increasing mining investment. Mining companies and all orders of government are working together to ensure that Indigenous Peoples are partners in both the industry’s development and its ongoing operations.

Challenges Ontario’s mining companies are among the best in the world. They have a long history of safe, socially responsible operations that serve as a model for how the industry should operate. However, the mining sector faces significant headwinds. Costs are increasing; overlapping regulatory structures create unnecessary complexity; and regulatory approaches to consultation with Indigenous communities can be inconsistent and inefficient. As the mining workforce ages, the talent pipeline may not be sufficient to support required sector expansion and development. Attracting this talent is further complicated by a persistent gap in the physical and social infrastructure needed for healthy mining communities. Collectively, these issues compound and present barriers to attracting and actioning the investments necessary to get new mines up and running, and to keep existing mines operating in the province.

Ontario has faced challenges of this scale before. In the 1960s, the province made ambitious investments in nuclear power despite political controversy, long timelines, and high costs. Today, nuclear power supplies more than half of Ontario’s electricity and has become a competitive advantage for business. This history demonstrates that bold, forward-looking policy and investment decisions can secure long-term prosperity.

Mining now demands the same level of ambition. This report provides a detailed look at the current state of mining in Ontario, and a roadmap to unearth the sector’s full potential. The chapters that follow discuss five pressing policy areas critical to this mission: • Partnerships with Indigenous people, businesses and communities • Fiscal tools and incentives • A competitive regulatory environment • An affordable and secure energy supply • A sustainable workforce, anchored in resilient communities Together, they provide actionable recommendations for how Ontario can make mining a driver of inclusive, sustainable prosperity for decades to come.

Ontario has the resources, expertise, and global market opportunity to lead in the next generation of mining.

What is needed now is the ambition to act and a clear commitment to creating the right policy and regulatory environment to unlock this potential. Quantitative modelling conducted by PwC as a research contributor indicates that more efficient regulatory and permitting processes could unlock substantial additional economic value for Ontario’s mining sector. These improvements could support an estimated $1-$2.2 billion in additional annual GDP, based on an illustrative range of efficiency improvements and assumptions that could enable one to two additional mines to reach construction each year, highlighting the scale of the economic opportunity. 6 But to unearth this potential, several conditions have to fall into place — including workforce, capital, energy, infrastructure, and social license — for Ontario to build producing mining assets by 2030 and seize this once-in-a-generation opportunity.

Photo: IAMGOLD Côté Gold Mine

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Chapter 01

Mining in Ontario Mining is one of Ontario’s foundational industries, contributing $23.8B to provincial GDP in 2023 (of which $15.7B came directly from minerals and metals production) and anchoring over 36 active mines, with more than 30 mines planned or under development.7 Global competition for secure and responsibly sourced minerals is intensifying, and Ontario’s mineral wealth positions it to play a critical role.

Photo: PENDA Productions Inc. “Alamos Gold YD & IG”, 2025, via www.pendaproductions.com

Recognizing this importance, governments have elevated mining to the centre of national and provincial policy discussions. The federal government’s Critical Minerals Strategy, released in 2022, frames mining as a “generational opportunity for Canada” and positions it as essential for economic growth, reconciliation with Indigenous Peoples, climate action, and international security.8 Ontario’s own Critical Minerals Strategy, launched the same year, commits to making the province a “reliable global supplier of responsibly sourced critical minerals.” Together, these strategies reflect a broad consensus that domestic mining must grow into a pillar of the global supply chain.

Ontario has the resources and ability to achieve that goal. Toronto is the world leader in global mining finance. The TSX and TSXV list roughly 40 per cent of the world’s publicly traded mining companies, and over the past five years have accounted for 47 per cent of all global mining financings and 32 percent of all mining equity capital raised.9 The province is rich in minerals and metals and has a vast geology that accommodates significant mining output. Currently, Ontario produces gold, nickel, copper, zinc, cobalt, iron, platinum group metals, salt, construction materials, and other industrial/ manufacturing minerals. The province has the potential to expand to other minerals such as lithium, graphite, rare earth elements, and chromite.

Among these commodities, gold has been, by far, the most significant to date. Of Ontario’s 36 active mines, half of them produce gold, accounting for more than 50 per cent of the value of the province’s mining production. Ontario produces more than 40 per cent of Canada’s gold and 3 per cent of all gold produced globally.10 That gold serves many purposes, including in electronics and industrial uses, as well as a main source of wealth reserves internationally. Gold acts as an economic hedge, helping Ontario navigate and de-risk through geopolitical and market uncertainty. Gold mines have also played a first-mover role in developing Ontario’s mining industry.

Gold mines have helped to install infrastructure, develop the labour force, and support the mining contractor ecosystem, reducing the barriers for other Ontario mines. Gold is Canada’s second largest export, and, notably, the only export in the top five that is not primarily exported to the United States.

At a time when trade diversification is front and centre in the national debate, gold is one of Canada’s few export-ready solutions and the leading component of Ontario’s mining success story.

Although gold will continue to be a cornerstone of Ontario’s mining economy, critical minerals have emerged as another area of strategic importance. There is no one definitive list globally of what constitutes a critical mineral. At the federal level, the designation is tied to a threat to a mineral’s supply chain and a reasonable prospect of the mineral being produced by Canada. It must also be deemed essential to Canada’s economic or national security, required for the transition to a sustainable lowcarbon and digital economy, or position Canada as a strategic partner within global supply chains.11

Chapter 01. Mining in Ontario

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Ontario deems a mineral critical if it has exploration or development potential in the province; strategic importance to the economy; applications that support the transition to a low-carbon economy; or global market demand.12 Ontario already produces eight of 34 federal critical minerals and 10 of 33 provincial critical minerals. One globally significant area of development is the Sudbury basin, which has been a long-term source of mining activity with major deposits of nickel, copper, gold, platinum, and silver.13 Yet, the province has the potential to produce more. Ontario’s Ring of Fire, a critical mineral resource-rich area located in the James Bay Lowlands region of Northern Ontario, represents its greatest opportunity. With deposits of seven critical minerals, from chromite to nickel to cobalt; the provincial government is advancing opportunities for mining development there. Other jurisdictions are already racing ahead with subsidies and regulatory reforms, and Ontario cannot afford to lag if it wants to secure its place in the global supply chain.

The challenge is that mining is a long lead-time activity. It can take many years to establish a new mine, and Canada’s supply is already falling behind demand. From exploration and evaluation through construction, consultation, and permitting, the process can take anywhere from 15 to 25 years before production begins.14 Mining is also cyclical. When prices are high, investment increases, but projects can be challenging to finance when prices fall. Yet we cannot afford to wait for the next price cycle. These commodities are needed now, and long timelines mean new mines often miss the financing window while still in development.

The Life of a Mine Community Engagement & Environmental Permitting

EXPLORATION

EVALUATION

5-10 YEARS INVESTMENT OF

5 YEARS INVESTMENT OF

Gathering data about potential mineral deposits and acquiring the rights to harvest those deposits.

Geological, technical and environmental analyses, plus community input.

Financing and governmentapproved closure plan must be secured.

$1-5M

$ 0.5-100M

CONSTRUCTION AND EARLY PRODUCTION

COMMERCIAL PRODUCTION

CLOSURE AND RECLAMATION

5-10 YEARS INVESTMENT OF

10-20+ YEARS

2 YEARS INTO PERPETUITY INVESTMENT OF

$ 750-1500M

Building of roads, environmental management systems, employee housing, processing and other facilities after investments, permits and approvals are obtained.

Production of minerals and metals that make modern life a reality, supplying downstream processing and boosting sectors across the economy.

Exploration often continues, adding to existing reserves.

$ 1-500M

Mining operations are decommissioned responsibly and the land is returned to a natural or economically usable state.

30+ years There is no one easy solution to advance mining in Ontario. The mining system is holistic and requires several interconnected parts to function well. The challenges for one type of mine can also vary significantly from those of another based on geological conditions, engineering and mining method. What gold mining needs to succeed can diverge from what a palladium or nickel mine may require. Likewise, the challenges facing major mining companies with multiple operating mines are often distinct from those of smaller, junior mining companies looking to establish their first mines in the province.

Unearthing the mining sector’s full potential will not be easy. However, the decisions made today — in partnership with Indigenous communities — will set the province up to be the leader in responsibly sourced mining for generations to come.

Chapter 01. Mining in Ontario

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Chapter 02

Indigenous Partnership Mining companies are often at the forefront of Indigenous economic reconciliation in Ontario. Most operate in remote regions of the province where many Indigenous communities are located, and where mining often represents the main source of economic activity. In these areas, mining is the largest private-sector employer of Indigenous people. Over the past two years, Indigenous workers have accounted for an average of 12 per cent of Ontario’s mining workforce – four times the provincial average.15

While mining companies and Indigenous communities are sometimes perceived to be at odds, the reality is that successful partnerships are far more frequent and less often reported. Mining is a major driver of social and economic benefits for Indigenous people, with the potential to become an even larger driver of economic reconciliation. This potential can only be realized when industry, government, and Indigenous communities work together as genuine partners at every stage of resource development. Industry and government, in particular, are responsible for ensuring that consultation and accommodation processes are meaningful, respectful, and effective.

Indigenous Peoples are not stakeholders; they are rights holders whose unique legal status is protected under Section 35 of the Constitution Act, 1982, with the Duty to Consult grounded in Canadian case law and informed by the federal United Nations Declaration on the Rights of Indigenous Peoples Act, which guides interpretation but does not replace existing legal duties.

The duty to consult and, where appropriate, accommodate, is triggered when the Crown is contemplating conduct that could have an adverse impact on section 35 Aboriginal or treaty rights. This duty rests with the Crown and cannot be delegated; however, the procedural aspects of consultation and accommodation often fall to mining companies, which are then responsible for pursuing transparent engagement with Indigenous communities. Similarly, the principle of Free, Prior, and Informed Consent (FPIC), embedded into Article 32 of the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP), is understood as a duty to seek consent, rather than conveying a veto in the Canadian context, and offers companies a framework to build certainty, reduce risk, and establish durable partnerships by ensuring communities are meaningfully engaged as projects move ahead.

Beyond legal frameworks, Indigenous traditions such as the Anishinaabe treaty principles of Respect, Responsibility, Reciprocity, and Renewal (4Rs) provide practical guidance for building lasting relationships. By applying these principles, companies can: • Engage communities early in project planning • Respect traditional territories • Implement sustainable practices and inclusive hiring • Maintain transparency and accountability • Invest in communities in ways that support shared prosperity Together, these frameworks can guide mining companies in advancing reconciliation, while creating conditions for more efficient project approvals and resilient ongoing operations.

Chapter 02. Indigenous Partnership

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Environmental Collaboration For mining companies, early engagement, consultation, and collaboration with Indigenous communities extends beyond a legal imperative or operational consideration; it can often improve environmental outcomes, business performance and community benefit. Indigenous peoples are deeply connected to the environment and serve as the original stewards of the land. Mining companies gain from Indigenous Traditional Knowledge and expertise, which can make projects more responsible while supporting conservation initiatives and local biodiversity. Indigenous communities also often play an active role in environmental monitoring and wildlife management, helping projects reduce their impact on Ontario’s natural landscape.

Case Study: Environmental and Socio-Economic Management at Côté Gold Mine � IAMGOLD’s Côté Gold Mine is located within Treaty 9 Territory and the Traditional Territories of Mattagami First Nation and Flying Post First Nation. � Working together has been a central tenet of the relationship between the company and the two communities. Water and fish habitat were identified early by the communities as critical to community well-being and culture. Having community environmental monitors embedded within the site’s environmental team and active participation by both communities in an Environmental Management Committee add incredible value to our efforts to minimize, reduce and offset environmental impacts. Some of the initiatives undertaken include supporting the efforts of Mattagami’s Fish Hatchery to strengthen walleye populations in Mattagami Lake and collaborating on the development of offsetting measures to compensate for fish habitat loss during mine construction.

A new lake, Oshki Lake (meaning ‘new’ or ‘young’ in Ojibwe) was created as one such offset, and the company supported a community-led process of naming the lake, marking a significant step in IAMGOLD’s commitment to environmental stewardship and reconciliation. � Together, the company and the two communities co-developed a Socio-economic Management and Monitoring Plan (SEMMP) to track and manage social and economic conditions throughout construction, operations, and closure. The plan covers employment, training, business opportunities, community health, infrastructure, transportation, and Indigenous land use and culture. A joint committee with representatives from IAMGOLD and both communities meets quarterly to review data and progress.

Benefit Agreements While a longstanding practice, partnerships between Indigenous communities and mining companies have grown significantly over the last several decades.

Today, there are more than 140 active agreements between mining companies and Indigenous partners in Ontario. Acknowledging that any such partnerships do not substitute the Crown’s Duty to Consult or Accommodate, they provide an avenue through which prosperity can be shared with Indigenous communities impacted by, or who have an interest in, a mining project. These can take several forms, the most common being an Impact Benefit Agreement (IBA), an agreement between the mining company and an impacted nation that shares the economic and social benefits of a mining project.

Chapter 02. Indigenous Partnership

Photo: IAMGOLD Côté Gold Mine

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Each IBA is tailored to reflect the priorities of the nation and the specifics of the project. A standard IBA typically includes some form of revenue and/or profit sharing; employment and training opportunities; environmental and cultural considerations; and supply chain participation. IBAs can be a major source of own-source revenue and capacity building for Indigenous Peoples and can also be a form of economic reconciliation in mining.

Beyond direct payments, IBAs help to build Indigenous businesses, develop community infrastructure, and train the next generation of Indigenous workers to participate in the natural resources sector. These agreements have begun to bring real change and improve living standards across many communities in Ontario.

Case Study: Benefits Sharing in Action - Agnico Eagle � Headquartered in Toronto, Agnico Eagle is the third largest gold producer globally, employing more than 4,000 Ontarians. � To date, Agnico Eagle has 11 agreements with Indigenous Nations in Ontario. These agreements include payments to communities, Indigenous employment and training, and procurement opportunities. These IBAs, along with the nine other agreements Agnico holds across Canada, make it the country’s largest participant in benefits sharing. For example, Agnico’s Ontario division spent $594M with Indigenous suppliers in 2024. � Agnico Eagle’s IBAs have led to strong partnerships with communities and meaningful participation from Indigenous Peoples in its projects. For instance, close to 22 per cent of the workforce at Agnico’s Detour Lake Mine identify as Indigenous.

Equity Partnerships Equity partnership is another model for Indigenous economic participation. In this model, Indigenous communities invest in the project (and associated infrastructure) and become part owners. Given the high upfront cost of a mine, these types of agreements have been less common in Ontario. However, federal and provincial governments have taken action to help support communities wishing to buy into projects by establishing Indigenous loan guarantees.

Some communities prefer equity stakes over IBAs. Others opt for a combination of both. While there is no one-sizefits-all solution for economic benefits, mining companies and Nations have been innovative in finding ways to tailor their agreements to the communities they are engaging with. Notably, such partnerships can create opportunities for Indigenous Peoples in leadership or governance positions and can ensure recurring revenue for Indigenous communities over the long term.

Beyond mutual economic benefits, equity partnerships create important intangible outcomes. Through ownership, Indigenous communities gain a genuine seat at the decision-making table, greater agency over how projects are developed, and stronger representation in governance. For mining companies, these partnerships foster deeper trust, more transparent communication, and shared accountability. Over time, this strengthens relationships in ways that reduce conflict, ease consultation, and accelerate project planning and approvals through a developed shared interest.

Case Study: Direct Indigenous Investment into the Crawford Nickel Project � Canada Nickel Company is developing the Crawford Nickel Project in Ontario. The company has engaged extensively with Indigenous communities in the area, resulting in several innovative partnerships. � Taykwa Tagamou Nation (TTN) invested $20 million of its own capital in a Convertible Note that will be convertible into 16.67 million Canada Nickel common shares, representing an 8.4% interest in the Company at the time of signing, based on the Company’s issued and outstanding share capital. The agreement also provides the community with membership on the company’s board of directors. This is the largest ever known direct investment into a critical minerals mining project by a First Nation in Canada. � Canada Nickel also signed equity agreements with Wabun Tribal Council (representing Mattagami, Matachewan, and Flying Post First Nations) to develop and construct supporting infrastructure for the project. This includes the realignment of 25.7 km of Highway 655, a temporary overpass, and a 25.2 km railway line linking Crawford to the Ontario Northland Railway. � These agreements were co-developed with the First Nations individually to reflect their long-term economic aspirations, while providing mutual benefit to the company for operational and construction requirements, ensuring meaningful participation and sustained revenue opportunities.

Chapter 02. Indigenous Partnership

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Supporting More Partnerships These models demonstrate both the potential and the requirements of meaningful Indigenous partnerships. However, they also highlight the significant challenges and complexities of consultations and partnership negotiations. Consulting with communities as part of the permitting and approval process is time and resource-intensive due to overlapping, inconsistent and often unclear government requirements.

While it is reasonable that a typical project would require consultation with multiple communities, provincial and federal laws and regulations can have conflicting requirements related to specific communities; there is also inconsistency between the requirements of different provincial ministries. The cost of these processes typically includes capacity funding to support each community conducting an environmental assessment.

Additionally, proponents will often cover the legal fees to negotiate and review equity or benefits agreements.

Collectively, these costs can reflect millions in up-front expenses for proponents before a mine is operational and earning revenue – a particularly acute challenge for junior mining companies that lack revenuegenerating projects to offset such costs. As essential components of project development, both upfront and ongoing partnership costs should be treated as standard operating expenses and reflected in Ontario’s mining tax regime. Changes to help companies manage these costs would enable more economic benefits for communities while de-risking projects for investors.

Recommendation

Ontario should remove ambiguity around administrative and communitybuilding expenses by ensuring that both upfront and ongoing partnership costs are eligible for Mining Tax treatment.

For Indigenous communities involved, reviewing development activity proposals and negotiating contracts is equally time and resourceintensive. Communities receive many applications to review, but do not always have the capacity and resources to participate meaningfully. Mining is also just one of their many priorities. This can lead to significant delays for projects as communities grapple with the volume of applications and the complexity required to review each one in detail.

The Ontario government recognized this problem by committing $70M over four years to the Indigenous Participation Fund “to improve capacity for Indigenous communities and organizations… to participate in regulatory processes related to mineral exploration and mine development.”16 This funding is a welcome contribution that should support the ability of Indigenous communities to fully participate in project reviews and permitting, encourage greater IBA execution, and improve timelines for consultations.

Chapter 02. Indigenous Partnership

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Clear Process for Engagement Industry stakeholders frequently raise concerns about inconsistent government rules for Indigenous consultation and accommodation. Mining companies act in good faith to ensure the highest standard of engagement, but often face conflicting guidance from government and rules that can change mid-process. For example, proponents often receive conflicting lists of impacted Indigenous communities from different federal and provincial ministries.

This misalignment on which communities need to be consulted causes significant logistical and financial complications for mining companies. Companies have also experienced new communities being added to their list while they are already in the process of negotiating IBAs. In some cases, government officials have added communities near the end of the consultation process, effectively resetting the clock on consultation and adding significant time to a permit approval. These barriers not only cause challenges for mining companies but also put pressure on the capacity of Indigenous communities.

To improve timelines for critical mineral development, process certainty for mining companies is essential. Urgent reform is needed to ensure clear guidance to mining proponents on Indigenous consultation. The guidance should contain just one list detailing which communities need to be engaged and what degree of consultation or engagement is required. The Ontario government is already improving the regulatory process through its “One Project, One Process (1P1P)” framework for designated projects (discussed in further detail in the regulatory section of this report). Improving coordination within government and between levels of government for all mine projects should be part of that reform.

of its consultation activities, and the ACO provides an ‘adequacy decision’ that determines whether the process met the required standards.18 A single consultation list, accompanied by clear direction on the required level of consultation, would significantly improve today’s fragmented and inconsistent approach to consultation, benefiting both proponents and participants. Since this could affect how Indigenous rights are interpreted, any such reform must involve robust consultation and accommodation with Ontario’s Indigenous communities. However, if handled correctly, a clearer process for engagement would both improve Indigenous consultation and strengthen Indigenous rights.

Recommendation

Ontario should ensure that mining proponents are provided with a single consultation list and clear direction on the required level of engagement.

This would require alignment across legal branches of government with authority vested in a single point of contact to make final determinations of affected communities and consultation adequacy.

Ontario should further ensure that it coordinates with the federal government to align requirements between levels of government.

Mining in Ontario can only reach its full potential by improving the process for consulting with Indigenous Peoples in the province. Mining is a generational opportunity for many Indigenous communities, and we must ensure that the right tools are in place to enable their participation in the industry’s development, operations, and future.

Alberta, for example, launched an Aboriginal Consultation Office (ACO) in 2013. The ACO serves as the central point of contact for industry on Indigenous consultation.17 Ahead of any consultation, project proponents submit an assessment request to the ACO, which triggers a pre-consultation assessment.

This process determines whether consultation is required, and if so, identifies the affected Indigenous communities and the required level of engagement — streamlined, standard, or extensive—depending on the level of impact on the community. Once the process is complete, the proponent submits a detailed log Chapter 02. Indigenous Partnership

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Chapter 03

Fiscal Regime Fiscal policy is a tool governments use to influence mining investment decisions at two key stages: before a mine is built, and once it is operational. A well-designed fiscal regime can encourage companies to open new mines or sustain existing operations. Mining, in particular, faces increased fiscal risk due to the large up-front capital required, low success rate from exploration, and highly volatile commodity prices.

Operating mines pay both federal and provincial corporate and mining taxes. Compared to British Columbia and Quebec, Ontario’s tax regime for operating mines is recognized as a clear competitive advantage. Ontario mines benefit from a lower headline mining tax rate relative to other provinces, the absence of a minimum mining tax, and a profit-based tax structure.19 Although it can be difficult to compare broader tax regimes, Ontario’s overall tax burden for operating mines is competitive with other Canadian provinces.

Despite a favourable tax regime for operating mines, many companies in Ontario struggle to advance projects from exploration into development and operation. To begin exploration, a company must first acquire mineral rights from the province through mining claims and, where required, secure exploration permits. Only after proving a viable deposit can a company apply for a mining lease, which grants the right to develop and operate a mine. It often takes multiple exploration programs, spanning several permits and claim areas, before a viable mineral deposit is found. Companies typically absorb the full cost of exploration activities long before there is any prospect of return.20 This leads to

underinvestment in exploration, which results in fewer new mines.

Developing a mine is an inherently risky investment. Exploration is speculative, capital-intensive, and requires long lead times before revenue, making it difficult to finance without strong fiscal supports.

Before a mine can start production and generate revenue, mining companies must fund initial costs for exploration, drilling, permitting, evaluations, consultation, and royalty payments.21 These costs can be substantial and can reach up to $100M per mine, creating significant upfront risk.22 This risk is particularly acute for junior mining companies without other mines generating revenue to finance new ones.

Government support during the early stages of mining is a strategic, long-term investment in Ontario’s economic future. Exploration is the lifeblood of mining. Mines that successfully move from exploration to production generate decades of well-paying jobs, attract sustained investment, and provide stable tax revenue, while helping to insulate Ontario’s economy from global supply chain shocks.

Flow-Through Shares Flow-through shares (FTS) are a financing tool that junior mining companies use to raise money for exploration. Normally, companies can deduct exploration expenses from taxable income to reduce the amount of tax they owe, but since junior mining firms typically do not have other operating mines that are producing revenue, these deductions go unused.

Chapter 03. Fiscal Regime

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By implementing FTS, the federal government has helped to address this issue while creating a new incentive for investors. Under this scheme, a junior mining company spends money on eligible exploration work and then passes on (or “flows through”) the tax deductions to investors, who can apply them against their own taxable income. Eligible exploration includes activities such as geological mapping, geochemical or geophysical surveys, exploratory drilling, and other preliminary fieldwork to locate and evaluate mineral deposits. Investors claim the tax deductions the company would have received, reducing the investor’s effective cost well below their original investment, while providing the mining company with upfront capital for costly exploration.

One limitation of the FTS regime is that many essential activities are not eligible under the Canadian Exploration Expense (CEE) rules. This has excluded a significant portion of exploration expenses required to establish mineral reserves and make critical mine development decisions.

Such expenses include many technical studies needed to advance a mine, such as engineering, economic and feasibility studies. This restriction limits the ability to advance many discoveries from preliminary resource estimates to proven, mineable reserves.23 Recommendation

The federal government should expand flow-through share (FTS) eligibility for the Canadian Exploration Expense (CEE) by including the costs of technical studies.

Case Study: Costs Associated with Establishing a New Mine in Ontario � Green Technology Metals (GT1) is advancing the Seymour mining project near the Township of Armstrong, Ontario. The project aims to be the first lithium mine in the province. � The Seymour project is designed as a low-impact, low-capital, short-life (less than 10-year mine life) open pit operation. Seymour will produce spodumene concentrate for conversion into battery-grade lithium hydroxide, a critical input for electric vehicles and energy storage systems. � Since 2021, GT1has spent close to $63M in development costs across exploration, technical studies, Indigenous engagement, royalty payments, and regulatory permitting. This upfront spending excludes the project’s acquisition costs. The costs are broken down in the table below.

Cost

Spend

Description

Exploration and Camps

$47,461,000

Fieldwork, drilling, assays, site infrastructure, permits and associated exploration expenses.

Technical Studies and Mine design

$8,172,000

Technical studies, metallurgical test work feasibility studies, engineering design, and related technical work.

Indigenous engagement, royalties, technical reviews & community capacity

$3,617,000

Meetings with Chief and Council, consultation travel, third-party technical reviews, capacity funding, mine development plan amendments, payments, and funding provided to communities to support review of the project.

Regulatory permitting and baseline studies

$3,726,000

Environmental registry filings, studies to support permits, and regulatory applications.

Total to Date (2021–Present)

$62,976,000

� The Seymour project underscores the capital-intensive, lengthy and complex process required to open a new lithium mine in Ontario. Tens of millions of dollars in upfront investment are required before construction can begin. While GT1 has made substantial progress (including securing strategic offtakes, advancing technical studies, and maintaining strong Indigenous partnerships), the experience illustrates how permitting complexity, consultation requirements, and regulatory delays can strain the capacity of junior companies. These challenges are particularly notable in the pre-construction phase, when projects carry high costs and risks without generating revenue.

Chapter 03. Fiscal Regime

Mining 2030: Unearthing Ontario’s Potential | 13

Exploration Support Many governments offer direct supports to incentivize and reduce the risk of exploration activity.

For example, British Columbia and Quebec have refundable exploration tax credits. Quebec provides a refundable tax credit of up to 38.75 per cent of eligible exploration expenses, while B.C. offers a 20 per cent refundable credit, rising to 30 per cent in remote regions.24 B.C. and Quebec’s credits can be stacked with the federal FTS program, meaning an investor can benefit from the provincial refundable tax credit and the federal FTS deduction on the same eligible exploration expense. These measures give companies direct, predictable support even when they have no taxable income, making them highly attractive for early-stage explorers.

Ontario, by contrast, relies on the Ontario Junior Exploration Program (OJEP), which provides targeted grants to support early-stage exploration. Currently, under the OJEP, a project can receive up to $200,000 per year, per application, for exploration costs on a single project.

However, drilling, assay, and site development costs at the advanced exploration stage are significantly higher. While helpful, OJEP does not provide the broad, predictable support available elsewhere. Ontario does provide a five per cent Ontario Focused Flow-Through Share (OFFTS) credit that stacks with the federal FTS rules. While this measure offers some additional benefit for investors, it is modest compared to the refundable credits available in Quebec and B.C. This leaves Ontario at a competitive disadvantage in attracting exploration capital.

Introducing an exploration tax credit would make Ontario the most competitive fiscal regime in Canada and support increased investment into developing new mines.

Recommendation

Ontario should introduce an exploration tax credit that is stackable with the federal flow-through share rules to support more exploration activity and the development of new mines.

Photo: IAMGOLD Côté Gold Mine

Chapter 03. Fiscal Regime

Mining 2030: Unearthing Ontario’s Potential | 14

Supporting Project Financing Beyond exploration, companies can also face significant challenges in financing mining projects due to highly volatile critical mineral pricing and global market manipulation. Mining companies are price takers with no ability to control mineral prices. To secure financing, companies need to give potential investors a forecast of its rate of return and when they will be able to recoup their investment. This can be difficult for critical mineral projects because the markets for many such minerals are still immature, with opaque and unstandardized pricing.25 To compound the challenge, the critical minerals market is dominated by a few countries that use their market power to control prices, deter investment and drive out competition. For example, China and Russia have weaponized control over several parts of the critical minerals supply chain to deprive other countries of critical minerals.26 In other cases, China has reportedly oversupplied the market to depress prices of critical minerals and make new mines in democratic countries uneconomic.27 China’s ability to heavily subsidize parts of the mineral supply chain to maintain market control has caused substantial volatility in critical mineral and rare earth prices. Market price volatility continues to be a major challenge for many junior critical mineral mining companies trying to establish new mines in Ontario. Even currently operating critical mineral mines face difficulties financing expansion projects to increase or sustain operations.

Governments have used several policy tools to support development and share risks for strategically important markets, such as mining. Equity investments are the most direct way for governments to support project financing. As direct investors, governments can provide capital for strategic projects that the private sector will not.28 This tool is already being used in mining for critical minerals, exemplified by the U.S. taking equity stakes in MP Materials, which operates the nation’s only rare-earth mine, and in two British Columbia mining companies.29 The U.S. has also coinvested $35M with the Canadian federal government into the Mactung mine in the Northwest Territories, which contains one of the largest tungsten deposits on earth.30 Australia recently invested $50M in the Kathleen Valley lithium project through its government-owned National Reconstruction Fund Corporation.31 Australia has also been considering price floors for critical minerals to provide broader support for domestic production.32 Domestically, Quebec recently made multiple equity investments through (totalling $965M) into the Nemaska lithium mine.33 The federal government has signalled it is moving in this direction with the announcement of a $2B Critical Minerals Sovereign Fund.34 Another tool available for governments is the use of offtake agreements where the government gives a project a contract to purchase their product for a set period. This tool was used extensively when uranium became a critical national resource for the United States.35 Today, offtake agreements are used to develop critical mineral stockpiles, where a government purchases, stores and saves critical minerals to prepare for supply chain shortage. Japan and South Korea have used this approach, and it is currently being pursued by the United States, the E.U., Australia, and India.

These policy tools are among many actions countries are pursuing to support domestic production of critical minerals. While they all involve public dollars, the additional cost has been dubbed a ‘non-China premium’ to guarantee some domestic supply and prevent China from controlling the market.36 The G7 is actively considering how to give these critical mineral and rare earth element markets more certainty through some form of price floor.37 Overall, these types of policy mechanisms should be considered temporary measures that must be directly targeted to critical minerals facing significant price volatility.

Chapter 03. Fiscal Regime

Mining 2030: Unearthing Ontario’s Potential | 15

For Canada, a contract for differences (CfD) mechanism has been raised as another potential response. In energy markets, a CfD sets a price floor for a commodity, such as a critical mineral, that the company will be able to receive. If the price of the commodity falls below that price floor, the counterparty (in this case, the government) would top up the price to guarantee a minimum rate of return. A CfD also sets a price ceiling, which the company would pay the counterparty if prices rise higher than expected. This mechanism provides price stability and shields companies from major price swings, resulting in risk-sharing between the counterparty and the company. In this case, the company would have a guaranteed minimum rate of return and would share the upside with the government should prices rise unexpectedly. The U.K. government has been the largest user of CfD contracts in the power sector, and they have been the government’s “main mechanism for supporting low carbon generation.”38 This type of solution for mining would allow companies to finance their projects, as it would give lenders greater certainty about a project‘s rate of return.

Recommendation

The Ontario and federal governments should explore options, such as contracts for difference, to provide greater long-term price certainty for some critical minerals identified in the province’s Critical Minerals Strategy.

Ontario already has a competitive advantage in its operating mine tax regime, with lower rates and a profit-based structure compared to other provinces. Strengthening exploration incentives and ensuring projects can be financed with reliable access to capital would make Ontario unmatched in Canada. Aligning fiscal policy with the realities of modern exploration and production would reduce risk, attract investment, and drive sustained growth, reinforcing Ontario as Canada’s leading destination for mineral development.

Photo: IAMGOLD Côté Gold Mine

Chapter 03. Fiscal Regime

Mining 2030: Unearthing Ontario’s Potential | 16

Chapter 04

Regulatory Reform Opening a new mine in Ontario can take up to 15 years or longer.39 Exploration, prospecting and project development understandably take time. However, government processes – notably environmental assessments, permits, approvals and the consultation associated with them – are key contributors to prolonged timelines.

Project proponents must navigate long, complicated, and often duplicative regulatory processes that risk frustrating the provincial government’s goal to advance and accelerate critical mineral development. Regulatory delays increase risk for mining sector participants and are frequently cited as the most significant barrier to mining investment.40 By reforming the regulatory system, Ontario can support new mine development while simultaneously improving consultation, enhancing environmental protection, and increasing investor confidence.

Photo: PENDA Productions Inc. “Alamos Gold YD & IG”, 2025, via www.pendaproductions.com

Based on modelling conducted by PwC as a research contributor, bringing Ontario’s permitting timelines closer to leading jurisdictions could enable roughly one to two additional mines to reach construction or operation each year. These improvements could support an estimated $1-$2.2 billion in additional annual GDP, create approximately 4,000-8,500 jobs, and generate corresponding increases in provincial tax revenues. Combined incremental revenues for Ontario’s government from personal income tax, sales tax and corporate income tax under modelled scenarios could range from $69 to $140 million, attributable to higher economic activity and employment.41 Together, these impacts highlight the potential scale of economic opportunity associated with a more predictable and efficient regulatory and permitting system.

Regulatory Reform Urgency Across Canada Ontario is not the only jurisdiction in need of regulatory reform. Governments across Canada have recognized that significant reform is necessary to get projects built. In the past year: • The Government of Canada passed the Building Canada Act, which aims to streamline federal regulatory processes for large scale developments, like those in energy, natural resources, and infrastructure projects of national interest. The Act establishes a new Major Projects Office that will serve as a one-stop shop for federal environmental assessment, permitting, Indigenous consultation, and financing for designated projects. Its overarching goal is to simplify and streamline regulatory processes and to work with provinces to reduce decision timelines from five years to two years, while preserving environmental protections and Indigenous rights.42 • British Columbia passed legislation that exempts specific energy projects from provincial environmental assessments to expedite development. Notably, it introduced a ‘single-window permitting process’.43 Instead of navigating approvals through multiple government agencies, proponents will submit their applications to a single body, the B.C. Energy Regulator, responsible for all provincial permits for energy projects.44 More recently, British Columbia introduced additional legislative measures to expedite permitting and approvals for infrastructure projects designated as “provincially significant”.45 Chapter 04. Regulatory Reform

Mining 2030: Unearthing Ontario’s Potential | 17

• Nova Scotia recently implemented significant reforms to regulatory structures for energy and mining, intended to help projects to start sooner and face fewer delays.46 The reforms included streamlining key approvals (generally covering environmental assessments, water and industrial applications) and establishing a specialized provincial review team and plain language documents to increase transparency and predictability. Of note, Nova Scotia’s approval process for mines is largely streamlined to include three key approvals: an environmental assessment (EA), a water approval, and one Industrial Approval that covers construction, operation, reclamation, and decommissioning.47 Taken together, these reforms show a clear trend across Canada: governments are moving toward single-window models and faster approval timelines to get projects built while upholding environmental protections and commitments to Indigenous Peoples.

Ontario’s Current System While designed to ensure strong oversight, Ontario’s current regulatory framework can present a significant barrier for mining project proponents, impacting its competitiveness and ability to attract investment.

For any given mine, a proponent must navigate a long list of complex federal and provincial regulations, spanning multiple government departments, with often-conflicting consultation requirements and frequent regulatory redundancy. For a new mine, proponents work with up to five different provincial ministries for permits, including Energy and Mines; Environment, Conservation and Parks; Natural Resources; Transportation; and Citizenship and Multiculturalism. At the federal level, proponents often must also seek approval from the departments of Fisheries and Oceans Canada; Natural Resources, Environment and Climate Change; and Transport Canada. As a result, proponents frequently receive inconsistent guidance within the same level of government as they navigate engagement across teams, ministries, and departments. This creates avoidable complexity, duplication, and inconsistency throughout the process, often leading to years of delay.

Those opening or operating a mine are subject to over 80 different permit types throughout the life of the mine, including up to 27 federal permits and 53 provincial permits. Each permit brings its own conditions that include monitoring, reporting, compliance and consultation obligations. Given the lengthy lead time to make a mine operational, many permits must be updated regularly. This means new applications and approvals, even in cases where these projects’ updates would serve to reduce a mine’s environmental impact. In practice, a mine’s operator may submit hundreds of permit applications throughout the lifecycle of a single mine. Understandably, this adds considerable cost and delay, adding risk for both companies and investors.

All stakeholders understand the province’s obligation to ensure mining projects are responsibly developed, with environmental impact managed and reduced as much as possible. This is what an environmental assessment is supposed to do: evaluate the potential environmental, social, and health impacts of a proposed mining project before it proceeds. However, Ontario’s process for environmental assessment (EA) does not effectively meet this goal and presents another significant challenge for mine development.

While not originally designed to regulate mining, Ontario’s EA has evolved to do just that. Proponents can voluntarily opt into the province’s EA process for their entire project. However, this pathway does not deliver tangible improvements and has become a source of delay. Rather, it has evolved into an overly complex study that assesses every aspect of a project, from cumulative, social, health and economic impacts to public participation. Regardless, proponents must also to apply for several overlapping environmental approvals to move their project forward, each tied to specific mining site activities, covering areas from granting disposition of Crown resources to constructing power generation or transmission facilities. These are referred to as “class EAs” and each brings with it an element of consultation.

Chapter 04. Regulatory Reform

Mining 2030: Unearthing Ontario’s Potential | 18

The current system forces companies to make a difficult choice: either opt for a provincial EA process not equipped for mining projects or navigate a web of disconnected class EAs that duplicate reviews for related permits. The problem is compounded by the fact that consultation activities conducted as part of an EA or class EAs are treated as entirely separate from the consultation requirements under the permitting review process, forcing them to repeat the same consultations. The federal Impact Assessment Act (IAA) environmental assessment process operates independently of the provincial process, with substantial overlap but little coordination; this creates yet another layer of duplication for mining projects that are subject to the act. The result is a system that is inefficient, complex, and poorly aligned with the needs of regulators, communities, and project developers.

Ontario must prioritize reducing duplication and redundancy in its regulatory system. This does not mean diluting environmental oversight; in fact, breaking down approvals processes into so many permits can result in worse regulatory oversight in two key ways.

First, it means that the environmental and social impacts from a mining project are considered in a fragmented and siloed manner. Any form of development will have trade-offs that society deems acceptable for a project to proceed. However, by considering the impacts of projects through a patchwork of unconnected permits and approvals, the government, stakeholders, and Indigenous communities cannot consider the total impact of a project, weakening environmental oversight.

Second, stakeholders and Indigenous communities get inundated with consultation requests for the same project. Currently, proponents have an obligation to consult with multiple Indigenous communities and stakeholders for most of their permit applications. Given that some mines have multiple communities with whom they need to consult for any project, this can lead to significant consultation obligations. For example, in discussion with the Ontario Chamber, one proponent reported having more than 10 Indigenous communities to consult with during the approval of a single mining project, requiring hundreds of individual engagements. Each community could have several dozen consultations. This is not only very complex and resource-intensive for proponents, but it can be daunting and lead to ‘consultation fatigue’ for communities. With Indigenous communities often struggling with their capacity to participate fully in the mining economy, breaking project approvals into so many individual permits may exacerbate the problem and reduce the prospects of oversight and meaningful consultation.48 Alberta provides a useful case study. In 2012, the province passed the Responsible Energy Development Act (REDA), which created the Alberta Energy Regulator (AER). The AER serves as a single regulatory authority responsible for the entire lifecycle of energy resource projects (including oil sands mining). REDA consolidated responsibilities that had previously been spread across multiple ministries, such as those dealing with environment, public lands, and water, into one regulator. This one-window model reduced duplication, clarified accountability, and offered proponents a more predictable and coordinated process. For example, oil sands mining projects undergo both the provincial environmental impact assessment (EIA) process and Alberta’s Environmental Protection and Enhancement Act (EPEA) approval through the AER. The EPEA approval is the main project permit and covers construction, operation, decommissioning, and reclamation. While REDA applies specifically to energy projects rather than hard-rock mining, it provides a helpful example for how Ontario can move from a patchwork of permits and agencies toward an integrated regulatory framework.

Chapter 04. Regulatory Reform

Mining 2030: Unearthing Ontario’s Potential | 19

Legislative Progress in Ontario Recognizing the challenges with the current regulatory regime, Ontario has announced an ambitious plan to reform the system. The Protect Ontario by Unleashing the Economy Act (“Bill 5”) aims to streamline “approval processes for mining and critical infrastructure projects to achieve outcomes that fuel our economy while also creating jobs and protecting the strategic national mineral supply chain.”49 Bill 5 amends several acts that affect the environmental assessment and permitting of major projects with the intention of reducing government review times on projects to two years. As part of this initiative, in October 2025, Energy and Mines Minister Stephen Lecce announced the ‘One Project, One Process’ (1P1P) framework for mining approvals for designated projects to simplify the regulatory process and provide proponents more certainty, while reducing permitting timelines by 50 per cent. The 1P1P framework will have mining regulatory applications for designated projects go through the Ministry of Energy and Mines (MEM), which will act as the ‘one window’ for project applications, saving proponents from navigating multiple departments.

For these designated projects, MEM would appoint a primary contact who would serve as a concierge for proponents to navigate approval processes.

The industry broadly supports the government objectives from Bill 5 to streamline regulations, simplify the regulatory process, and speed up decision timelines. These changes should be made in close consultation and collaboration with Indigenous communities across the province to ensure their rights are upheld, and to build public support and trust in the new regulatory regime.

The challenge is that the 1P1P only applies to designated projects. While a good first step, we need a system that reduces permitting timelines for all mining companies operating in Ontario, including to de-risk new development at established mines, and to ensure business continuity and environmental compliance. As Ontario works to reform its regulatory regime, the following principles should guide implementation: 1. One Window: Project proponents should have one main government point of contact 1

for any application process. Industry strongly agrees that MEM should be the main point of contact for the industry, with responsibility to oversee all permitting requirements.

2. Concierge Approach: Each project should have a representative at MEM who would 2 act as a ‘concierge’ to help proponents navigate the permitting, approvals, and consultation process from start to finish.

3.

3 Streamline Permits: Mining permitting should be consolidated into one comprehensive site-wide permit. This permit would include construction, operations, decommissioning, and reclamation. With one process for each mining application, stakeholders could consider all of a mine’s impacts. Ontario should coordinate with the federal government to reduce duplication, and where appropriate, substitute for any federal environmental assessment.

4. Build Ministry Capacity: The government should establish a recruitment and training 4

program within MEM to hire and upskill mining subject matter experts. It should partner with post-secondary institutions and mining-related organizations to develop specialized programs in mining regulation and Indigenous consultation. This additional capacity would help reduce regulatory bottlenecks and ensure consistency of approach.

Given the change in culture required to speed up government review timelines, the government should also invest in organizational change training for ministry staff.

Chapter 04. Regulatory Reform

Mining 2030: Unearthing Ontario’s Potential | 20

5. Centralized Digital Permitting Platform: A unified digital platform for submitting 5 and tracking mining project applications should be developed to integrate all regulatory requirements. This platform would help keep all parties accountable to timelines and significantly simplify the existing disjointed system.

6. Deadlines: To ensure timely decisions, the government should mandate a firm 6

deadline of two years to reach permitting decisions for new mining projects. Similarly, government needs to establish fixed decision timelines for permits and amendments that impact operating mines.

A more innovative regulatory system is one of the most important steps Ontario can take to unlock mining development in the province. Changes around the margin won’t be enough; the province needs a fundamental retooling of how mines are assessed and permitted.

Structural reform will signal to investors that Ontario is open for business. At the same time, a modernized regime will also deliver stronger environmental oversight, more meaningful Indigenous consultation, and the certainty needed to build the next generation of mines.

Photo: PENDA Productions Inc. “Alamos Gold YD & IG”, 2025, via www.pendaproductions.com

Chapter 04. Regulatory Reform

Mining 2030: Unearthing Ontario’s Potential | 21

Case Study: IAMGOLD’s Côté Gold Mine Overview IAMGOLD Corporation is a Canadian gold producer headquartered in Toronto, Ontario. Established in 1990, the company has built a diversified portfolio of mining operations and exploration projects across North America and West Africa.

What is the Côté Gold Mine The Côté Gold Mine, situated in the Chester and Yeo Townships within the District of Sudbury, represents a significant investment in Ontario’s resource sector and a benchmark for modern, responsible mining. Operationally, the mine achieved its first gold pour on March 31, 2024, and entered commercial production on August 1, 2024. During the early stages of project development, agreements were negotiated with Mattagami First Nation, Flying Post First Nation, and the Métis Nation of Ontario. These Indigenous relationships are central to the mine’s development strategy and focus on responsible, innovative and accountable mining.

Despite serving as a replicable model for how large-scale resource projects could be responsibly developed in alignment with reconciliation, sustainability, and economic growth, Côté Gold faced significant challenges and bureaucratic delays related to environmental assessment (EA), permitting, and consultation processes.

Environmental Assessment (EA) Process The Côté Gold project offers a revealing case study of the challenges embedded in Ontario’s EA framework for mining developments. The project was subject to a federal EA process, and the company also opted into the provincial EA process. Each EA involved extensive consultation with Indigenous communities and coordination across multiple government agencies. Despite aiming for thorough oversight, both jurisdictions’ EA processes operated in silos. Bureaucratic challenges also led to a nine-month delay in the provincial EA decision.

This lack of coordination led to duplicative reporting requirements, especially with the ongoing annual environmental reporting requirements under both jurisdictions, conflicting timelines, a lack of harmonization, and administrative inefficiencies that slowed progress and strained resources.

Permitting Challenges The Côté Gold project faced a daunting permitting process in Ontario, requiring over 195 distinct permits and approvals to facilitate construction and move into operations after EA completion. These permits covered everything from water use and land disturbance to emissions, infrastructure, and waste management. While such requirements are standard for industrial projects, the sheer volume and complexity of approvals created substantial delays and inefficiencies. Each permit was treated as a new environmental effect, triggering consultation for activities that had previously been assessed.

Indigenous Consultations Due to the absence of a streamlined and harmonized EA process, IAMGOLD was required to conduct Indigenous consultations both provincially and federally, with each department and agency having its own expectations and timelines. The company had to consult multiple times with each community on an individual permit by permit basis, which delayed the project and risked straining their relationships with the Indigenous communities.

Federally, IAMGOLD was given guidance to consult with four Indigenous communities, and provincially, they were directed to consult with 13. These shifting expectations, combined with leadership changes and evolving rights-based positions, made coordination difficult. Federal agencies were more hands-on, attending consultations and assessing completeness directly, whereas provincial bodies lacked technical capacity and often delayed decisions.

Conclusion The development experience of the Côté Gold mine underscores the urgent need for a more streamlined and coordinated approach to mining regulation in Ontario. From navigating overlapping EAs to securing over 195 permits, many of which were low-risk and duplicative, the project faced significant delays and administrative burdens that were not rooted in environmental protection but in regulatory inefficiency. Better coordination, clearer expectations, and improved support for Indigenous communities are needed to ensure consultation is both effective and efficient.

Chapter 04. Regulatory Reform

Photos: IAMGOLD Côté Gold Mine

Mining 2030: Unearthing Ontario’s Potential | 22

Chapter 05

Energy Energy is one of the largest expenses for most Ontario mines, accounting for 15 to 30 per cent of total costs.50 As a result, maintaining stable and affordable access to energy is fundamental to mining competitiveness.

Ontario’s clean electricity system is a major competitive advantage, with one of the cleanest grids in the world and the vast majority of power generated from emissions-free sources. This provides the opportunity for Ontario businesses to operate with a much lower carbon footprint than international competitors that rely on more carbon-intensive grids. Policies that encourage and support mines in shifting from higher-cost, higher-emitting energy sources to electricity will reduce operating costs while cutting emissions.

Photo: PENDA Productions Inc. “Alamos Gold YD & IG”, 2025, via www.pendaproductions.com

Energy Use on Mines and Electrification A mining operation typically uses multiple sources of energy. Many Ontario mines are remote, located far from northern transmission lines and other key infrastructure, which makes it difficult and expensive to connect to the grid. Consequently, these mines operate off-grid and use alternative energy sources. Even mines located closer to a grid connection will still use natural gas, diesel, or propane due to the high initial cost to replace equipment to electrify and the need to power distant parts of a large mine site.

While these energy sources are critical for mining, electrifying mining operations, where possible, can help reduce both costs and emissions. While many mines have looked to electrify their operations, it can be prohibitively expensive to replace equipment and retool operations.

Considerations include the cost and performance of the equipment upgrade, the mine’s access to the grid, and the company’s forecast of provincial electricity prices over the life of the new equipment. Volatile and increasing electricity prices will undermine the business case to electrify the mine, and discourage investment.

Case Study: Partnering with Indigenous Communities to Electrify � Alamos Gold has partnered with the Batchewana First Nation to build a new $70M, 115 kV transmission line in Northern Ontario. � The line will connect to Alamos Gold’s Island Gold District mine, supporting electrification for the Phase 3+ expansion and reducing reliance on diesel generators. � Batchewana First Nation will retain long-term ownership and operation, positioning the community as a regional leader in clean energy development. � Once operational in 2026, the project will cut the mine’s emissions intensity to 70% below the industry average, with a further 29% reduction targeted by 2027. � The project also delivers regional benefits, including construction and maintenance jobs, enhanced energy reliability in Algoma District, and long-term Indigenous-led economic growth.

Chapter 05. Energy

Mining 2030: Unearthing Ontario’s Potential | 23

Case Study: Ontario Electrification in Mining � Agnico Eagle’s Macassa Mine operates one of Ontario’s best-documented underground Battery Electric Vehicle (BEV) fleets, including 22 battery-electric scoops and 6 battery-electric trucks such as the Artisan Z50, with measured ventilation and heat benefits underground. � IAMGOLD’s Côté mine is a new, grid-connected open-pit operation with autonomous haulage. The mine will be installing new electric-powered dewatering pumps and mobile lighting towers. The electric upgrades at site will eliminate an estimated 7,500 tonnes of carbon dioxide equivalent (CO e) emissions in 2030 by switching from diesel-driven equipment to electricity from the grid.

2

� Alamos Gold’s Young-Davidson mine has deployed battery-electric utility vehicles from Ontario manufacturer Miller Technology, deploying Battery Electric Vehicles into daily underground support work.

Volatile and Increasing Energy Costs Industry looks for energy price stability and predictability. However, Ontario’s electricity model exposes power consumers to more price fluctuations, and costs are expected to rise over the next decade.

The province’s grid operator, the Independent Electricity System Operator (IESO), must continuously balance electricity generation and demand in real time. When there is a mismatch between supply and demand, the grid can experience instability that may lead to brownouts or system failure.

Natural gas is the main source of flexibility that helps balance generation across Ontario’s grid.

One advantage of natural gas generation is that it can ramp up or down quickly to meet changes in power demand. There are few other options to balance the grid in the short to medium term. As natural gas plants are often the last form of generation to be called upon, they set the marginal price for electricity. In practice, this means that gas prices greatly impact Ontario’s overall electricity costs.51 If global events, such as Russia’s war on Ukraine, limit gas availability and cause price spikes, major power consumers can face price volatility. As shown by Figure 1, global natural gas prices have been volatile in recent years, exposing large power consumers to significant fluctuations on their energy bills.

Figure 1 - Global Quarterly Natural Gas Price Index, Jan 2020 to Oct 2025 Price Index (2016=100) 800 700 600 500 400 300 200 100 0

Chapter 05. Energy

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Mining 2030: Unearthing Ontario’s Potential | 24

Ontario’s power prices are also projected to rise sharply. The provincial government’s Integrated Energy Plan sets ambitious targets to expand grid capacity and bring new generation assets online to meet growing demand. With electricity demand expected to increase by 75 per cent by 2050, major investment in new generation is both essential and already underway.52 However, these investments, combined with rising demand and the temporary loss of supply, will also put upward pressure on medium-term prices.

The IESO forecasts that the average marginal energy price (Ontario Zonal Price) will increase by more than 160 percent within the next two to three years. This surge will be driven primarily by growing demand and the temporary loss of generation capacity during the refurbishment of the Pickering Nuclear Generating Station. To maintain system reliability, the lost output from Pickering will need to be backfilled by natural gas until the refurbished units and new generation projects come online in the 2030s. Until then, operators will face both higher prices and greater volatility, which will affect how they plan and invest.

Ontario’s existing industrial electricity frameworks, such as the Industrial Conservation Initiative (ICI) and Interruptible Rate Pilot (IRP), are designed to reduce power costs by managing the Global Adjustment (GA) component of electricity costs for large consumers. The GA represents the portion of electricity pricing that recovers the fixed costs of generation and conservation programs, including payments to nuclear, hydro, and contracted renewable facilities. These programs help stabilize system costs by reducing GA exposure for eligible consumers, but do not shield large users from increases in the market-based portion of electricity pricing.

Additionally, as the price of electricity goes up, the GA decreases, which minimizes the potential benefits from these programs. As a result, industrial customers will remain vulnerable to fluctuations in the hourly energy price. Likewise, none of the province’s electricity rate mitigation programs are designed to offset increases in cost outside of the GA. According to the Association of Major Power Consumers (AMPCO), if unaddressed, many industrial consumers, such as mines, could experience overall electricity cost increases of 25 to 50 per cent between 2026-2030. These increases will occur at an already challenging time for Ontario’s economy and mining sector. Notwithstanding increased volatility and shifting commodity price dynamics, the total cost of Ontario’s electricity system is poised for substantial increases over the coming years.

As Ontario aspires to grow its mining economy, it must address this combination of energy supply scarcity, price volatility and rising costs, which the province’s current industrial frameworks are not designed to manage. Addressing the policy gap and the increasing vulnerability of industrial consumers will require dedicated engagement with industry in the next year.

Recommendation

The Ontario government should consider all available options, including rate mitigation, to protect the province’s industrial foundation from the impacts of rising and more volatile electricity prices over the next decade.

Chapter 05. Energy

Mining 2030: Unearthing Ontario’s Potential | 25

Northern Energy Advantage Program The Ontario government has taken several measures to mitigate some of the price exposure for mining companies. Its main policy tool is the Northern Energy Advantage Program (NEAP).

The NEAP was established in 2022 and replaced the Northern Industrial Electricity Rate Program (NIER). NIER was a program launched in 2010 to help large industrial electricity customers offset high electricity costs. Widely used by mining companies in the North, the program set a $20 per megawatt-hour discount on electricity costs for eligible large consumers.

Mining companies were very supportive of the NIER and the administrative updates to the program as it transitioned to the NEAP. The NEAP removed the company cap of $20 million, allowing mining companies to gain more value from the program. The program also introduced the investor class, aiming to support participants making transformational investments. While both additions were positive for the industry, the $20 per megawatt-hour discount has remained constant for 15 years, and not adjusted for inflation or rising electricity costs. In 2010, this discount represented a significant savings. Today, due to inflation and rising electricity costs, it covers a far smaller share of a company’s power bill. The NEAP program is up for renewal in 2027, and the discussions on the design of the program will begin in 2026.

Recommendation

The Ontario government should index the Northern Energy Advantage Program to the Consumer Price Index (CPI) and extend the program term beyond five years to give rate relief for mines and provide business certainty over the next decade.

Energy is a key driver of competitiveness for Ontario’s mining sector. Clean, reliable, and affordable power is essential to the industry’s long-term success. Price volatility threatens Ontario’s position as a leading mining jurisdiction and risks slowing decarbonization initiatives.

By implementing these targeted measures, Ontario can secure its position as a global leader in low-cost, low-carbon, responsible mining.

Photo: PENDA Productions Inc. “Alamos Gold YD & IG”, 2025, via www.pendaproductions.com

Chapter 05. Energy

Mining 2030: Unearthing Ontario’s Potential | 26

Chapter 06

Workforce, Community, and Infrastructure One of the biggest risks to Ontario’s mining sector is the shortage of skilled labour. The sector directly employs approximately 22,000 people, but the demand for employees is growing as the existing workforce ages and retirements increase.53 Companies report persistent difficulty recruiting the workers needed to maintain current operations, with anxiety surrounding the long-term sustainability of their labour needs.

Industry assessments project Canada’s most in-demand mining roles include engineers, electricians, millwrights, technologists, data specialists, and geologists. These positions require long training pipelines and continuous upskilling.54 Without broad coordinated action to address this issue soon, labour demands will severely limit Ontario’s mining potential.

Mining is a leading employer in Ontario’s north, representing more than a third of all jobs.55 However, many mining employees are recruited from outside the region. To attract workers from urban areas, companies often rely on ‘fly-in fly-out’ (FIFO) programs, where employees rotate in for two or three weeks before returning home. These have opened additional pools of potential employees, and many candidates like them because they can take well-paying mining jobs without uprooting their families or losing access to urban amenities.

With mining companies across the spectrum pursuing models that suit their unique needs and those of their employees, FIFO programs have emerged as a critical part of the industry’s strategy.

For some more remote mines, they may be the only option. For others, these programs can be difficult to sustain. For northern communities, the programs can impact tax contributions and local economic spin-offs. The challenge has been made worse by reduced airline service following the COVID-19 pandemic. Fewer flights operating at capacity have created real bottlenecks for getting workers to sites, impacting reliability and challenging efficiency.

Where possible, companies augment FIFO programs by striving to find local employees or encourage employees to relocate to communities near the mines. Attracting and cultivating a local workforce helps build healthy and sustainable communities, contributes to the local tax base, and improves retention. However, relocation remains difficult. Many northern communities lack sufficient housing, schools, robust health services, and other social infrastructure. Coupled with lingering perceptions of mining as a transient or high-risk career, these deficits hinder efforts to attract and retain families. Addressing workforce shortages, therefore, requires not just training programs but coordinated investment in the social and community infrastructure that makes relocation viable. For its part, the Government of Ontario recently expanded the Building Ontario Fund’s mandate, recognizing these enabling infrastructure investments will be integral for industry development.56

Chapter 06. Workforce, Community, and Infrastructure

Mining 2030: Unearthing Ontario’s Potential | 27

Road Infrastructure Reliable road infrastructure is critical to the success of Ontario’s mining sector, yet many northern highways require significant investment. Northern Ontario’s mining sector depends on reliable north–south and east–west transportation corridors that connect communities, workers, and supply chains to markets in southern Ontario and beyond.

Highway 69 is the key gateway that links the Greater Toronto Area to Sudbury, the region’s largest mining hub, before joining Highway 17 as part of the Trans-Canada Highway. Highway 144 provides another critical connection, linking Sudbury directly to Timmins and serving as a lifeline for mining operations. Both highways are essential to the movement of people, equipment, and materials. However, these highways’ current two-lane designs cause frequent closures, accidents, and delays that increase costs and can disrupt just-in-time mining supply chains.

Poor road conditions also create a significant barrier to workforce movement. Concerns about getting to work smoothly and safely on these roads are frequently cited as reasons to avoid mining careers. Safety concerns and unpredictable travel times raise risks for those commuting long distances between northern communities and mine sites.57 Long stretches without reliable cellphone coverage heighten public safety risks, leaving workers unable to call for help in the event of an accident. Upgrading these highways would increase safety, reduce fatalities, and ensure more reliable access for employees. In turn, this would support better workforce access, stronger economic outcomes for the province, and greater resilience across Ontario’s transportation network.

Highway connectivity across northern Ontario must form an essential component of a broader economic corridor strategy that enhances growth and insulates the province from transportation disruptions. Highways that serve as key arteries for mining communities — such as Highways 69, 144, 11, and 17 — should be prioritized in transportation planning. Most of these investments are highlighted in Connecting the North, the draft transportation plan for northern Ontario. The plan should be further developed to create a true economic corridor.58 Federal and provincial investment in these routes would not only unlock the north’s resource potential but also strengthen the long-term sustainability of northern communities and improve Ontario’s competitiveness in the global mining economy.

Recommendation

The Ontario government should invest in key roads, including Highways 69, 144, 11, and 17, that serve northern communities and mines and connect them to markets across the province and beyond.

Social Infrastructure Infrastructure gaps extend beyond just physical infrastructure. Constraints in social infrastructure – such as health care, childcare and housing – are persistent barriers to recruiting and retaining mining workers. With so many mining communities in northern and remote regions, they often lack the essential services needed to support families and sustain long-term settlement.

Northern Ontario faces significant gaps in healthcare, childcare, and digital connectivity. The Ontario Medical Association reports that there are more than 350 unfilled physician vacancies in northern Ontario, including more than 200 family doctors.59 These shortages pose a problem for companies looking to attract more workers to move to northern communities with their families.

The lack of childcare options has a negative impact on the ability of women to join the mining workforce, which reduces the ability of mining companies to improve the diversity of their workforces and limits the overall labour pool. Expansions to Ontario’s Learn and Stay program, which covers a health workers’ education in exchange for service in northern communities, is a promising step. Still, more work is needed to provide northern mining communities with care comparable to the rest of the province.

Chapter 06. Workforce, Community, and Infrastructure

Mining 2030: Unearthing Ontario’s Potential | 28

Housing availability similarly poses a barrier to more people relocating to mining communities. While housing costs are typically lower than in southern Ontario, the supply of houses and available rentals remains limited.60 The existing housing stock is also older than in other parts of the province and often needs to be updated to accommodate incoming mining employees. With over 70 per cent of housing in towns like Timmins and Thunder Bay built before 1980, many units require upgrades.61 High construction costs – driven by remoteness, labour shortages, and material costs – deter new development, resulting in a persistent shortfall of modern, familyready housing.62 These housing pressures are even more pronounced for many First Nations communities, where efforts to build new homes are often delayed by the long Addition-to-Reserve (ATR) process needed for expanding community land bases. These delays limit the availability of on-reserve housing for members seeking to return home for mining-related employment opportunities.

Other jurisdictions have addressed similar challenges. In the last decade, Quebec encountered comparable problems with the development of northern communities and, in response, introduced Plan Nord, a major coordinated 25-year investment plan to build both physical and social infrastructure to support northern economic development. The plan invested heavily in building out both physical infrastructure (e.g., roads, ports, airports, and telecommunications) and social infrastructure, with more than $382M for housing, healthcare, and education.63 The plan also earmarked funds to invest in the cultural vitality of northern communities for libraries, recreational facilities, and arts programs. Ontario should match this degree of ambition to meet the needs of northern communities and unlock the level of economic development they have outlined in their long-term mining plans.

Recommendation

Ontario should build on existing northern economic development plans, such as the Growth Plan for Northern Ontario and the Northern Ontario Heritage Fund, by creating a bold, long-term strategic framework. This could draw inspiration from Quebec’s Plan Nord. Any plan must integrate physical, social, and community infrastructure, ensure coordinated investment, and match scale and ambition to the demands of mining-led growth in the North.

Immigration Immigration is a critical lever to address labour shortages in Ontario’s mining sector, helping to stabilize the workforce, support project development, and strengthen northern and rural communities. The challenge is that most newcomers settle in urban centres within the Greater Toronto Area (GTA) for better access to services and established cultural communities. Between 2000 and 2018, the GTA accounted for between 74 and 84 per cent of Ontario’s total immigration annually – a trend that continues today.64 Targeted programs, however, can shift this dynamic. The federal Rural and Northern Immigration Pilot (RNIP) has been a notable success, empowering smaller and more remote communities to have a direct role in selecting immigration candidates who matched their labour market needs. The program has improved retention rates, filled critical shortages, and encouraged stronger integration of newcomers into local economies. The program was celebrated by the rural communities that used it, and the federal government is making it a permanent part of Canada’s immigration strategy.

Recommendation

Ensure the Ontario Immigrant Nominee Program supports northern labour market needs by expanding regional allocation streams. Building on Ontario government pilots such as REDI (Regional Economic Development through Immigration) and the Employer Job Offer (Northern Ontario Stream), the province should commit to a predictable and scaled pathway.

Chapter 06. Workforce, Community, and Infrastructure

Mining 2030: Unearthing Ontario’s Potential | 29

Indigenous Employment Training and employing Indigenous workers is a major priority for the mining industry. Indigenous people are Canada’s fastest-growing demographic and live near many mining operations. Their full participation in the sector is both a crucial labour solution and a pathway to economic reconciliation, as called for by Canada’s Truth and Reconciliation Commission Call to Action 92. This presents a significant opportunity for mining companies to tap into this large and growing labour force while driving economic reconciliation. Achieving greater Indigenous employment will require substantial action from both industry and government to support Indigenous participation in mining projects.

Indigenous employment in mining takes two forms: direct employment on mining projects and procurement from Indigenous businesses. As the Ontario Chamber noted in a recent report with the Canadian Council for Indigenous Business, procurement is especially powerful because nearly 89 per cent of Indigenous businesses hire at least one local Indigenous worker, meaning supply chain engagement directly translates into community jobs.65 Indigenous businesses support mining across a wide range of areas, including project management, remote lodging, electrical services, environmental monitoring, engineering, and many other key mining activities.66 To foster greater Indigenous procurement, mining companies should engage with local Indigenous-owned businesses about their longterm investment plans, well before launching Requests for Proposals.

This would give Indigenous entrepreneurs time to prepare bids and ramp up production activity, if necessary, to meet the demand.

Direct roles on mining projects is the other critical form of Indigenous employment. Over 2023 and 2024, Indigenous peoples represented 12 per cent of Ontario’s mining workforce, well above the three per cent provincial average across industries.67 Yet, Indigenous peoples still face many obstacles to gaining employment in the sector.

One major impediment is the lack of relevant education and training opportunities for potential Indigenous employees. Most mining jobs require at least a high school diploma or a General Education Development (GED), which is a barrier for many Indigenous peoples.68

Case Study: Côté Mine and Indigenous Businesses � IAMGOLD engaged with Indigenous businesses to build their Côté Gold mine project located in the Chester and Yeo Townships, District of Sudbury.

By collaborating with Indigenous communities early in the project’s development, First Nation partners were able to create economic development entities to support business development and economic growth for their communities: Mattagami AKI LP and Flying Post First Nation Limited Partnership. � AKI Caron, a partnership between Mattagami AKI and Caron Equipment, is a noteworthy example of a community business engaged in supporting the mine’s environmental efforts.

AKI Caron provides various construction and earth-moving services at Côté Gold and was an instrumental contractor involved in the earthworks aspects of the development of Oshki Lake (meaning ‘new’ or ‘young’ in Ojibwe) and the Mollie River realignment. � The company continues to expand its services and works with other contractors to build capacity for larger projects. At the peak of Côté Gold’s construction, AKI Caron employed 23 Mattagami members.

Mining companies should also implement good inclusion practices and promote Indigenous cultural awareness across their organizations.

Strengthening partnerships with Indigenous training institutions, apprenticeship programs, and northern colleges could help bridge these gaps and ensure a sustained pipeline of skilled Indigenous workers.

Recommendation

Ontario should build upon the successes of the Indigenous Economic Development Fund and support Indigenous businesses and communities in learning about the procurement supply chain RFP processes. Local mining and supply and service companies should engage early with Indigenous businesses to share their long-term investment plans, specifically identifying opportunities to improve Indigenous participation in procurement.

Chapter 06. Workforce, Community, and Infrastructure

Mining 2030: Unearthing Ontario’s Potential | 30

Public Education & Marketing Mining Careers The image of the mining industry plays a direct role in workforce development and its social licence to operate. Mining has strong and growing support from Ontarians. In a 2025 Spark Insights poll, 83 per cent of Ontarians surveyed reported that they had a favourable view of mining.69 This support has been progressively growing over the last number of years and reflects the mining industry’s efforts to increase public understanding of the industry.

While this is a strong baseline, more needs to be done to continue to build understanding and interest in mining careers, particularly among younger Ontarians. A 2023 Abacus Data poll found that Canadians under 35 view mining less favourably than other sectors.70 While respondents associated mining with good pay and benefits (65 per cent) and abundant job opportunities (58 per cent), other factors negatively impacted the overall perception of the industry. Among the top ten words associated with mining were “hard”, “dangerous”, “dirty”, and “pollution”. Only 38 per cent of those surveyed believed there were mining job opportunities in places they would want to live, and only 32 per cent felt that mining jobs had a good work-life balance. Most notably, only 22 per cent felt that mining jobs were safe. In fact, the number one reason respondents gave for not wanting to work in the industry was the belief that the jobs were “too dangerous.”

Such perceptions do not reflect the reality of mining in Ontario today. Ontario mining outperforms the provincial average on safety (lost-time injury rate of 0.70 versus 0.93 across all industries in 2023), has ambitious environmental commitments, and is central to building a net-zero economy.71 Many of the province’s critical minerals directly support Canada’s emissions-reduction goals.

Mining is also increasingly high-tech, drawing on automation, clean technology and advanced environmental practices. Yet, these realities need to be reinforced to help recruit the next generation of workers. With only 34 per cent of young Canadians surveyed responding that they would consider a career in mining, both industry and government can do more to make mining careers compelling.

Targeted campaigns that challenge and correct key misperceptions of the industry could enhance enrolment in mining-related programs. Specifically, the campaigns should educate target audiences about the industry’s significance, emphasize the safety of mining jobs, highlight the important role mining plays in a net-zero economy, and position mining jobs as high-tech careers contributing to a cleaner, safer and more prosperous future. The Abacus poll underscores the potential of this approach: after learning more about career possibilities, 65 per cent of respondents reported a more positive view of mining. This suggests that a campaign to increase understanding of the industry among the next generation can serve as a key workforce development strategy.

Chapter 06. Workforce, Community, and Infrastructure

Mining 2030: Unearthing Ontario’s Potential | 31

Recommendation

Government and industry should collaborate on a long-term, coordinated campaign to continue to build understanding and interest in mining among young Ontarians, highlighting the sector’s economic opportunity, safety record, environmental leadership, and role in Canada’s clean economy of the future.

Investing in northern Ontario will lead to tangible improvements for both the mining industry and the welfare of northern Ontarians. Through targeted investments, industry and government can make northern Ontario a destination where more people want to live, grow, and raise families.

Stronger communities will translate into more inclusive, sustainable prosperity for the province.

To achieve this, Ontario needs a coordinated strategy that mirrors the ambition of other jurisdictions: improving roads and transportation corridors to unlock economic potential; ensuring health care, housing, and childcare are at par with the rest of Ontario; attracting and retaining new Canadians and marketing mining careers; and advancing Indigenous participation in every aspect of the mining economy.

By addressing these interconnected challenges together, Ontario can secure the workforce needed for the future, strengthen social license for mining, and ensure the benefits of development flow directly to northern communities.

Chapter 06. Workforce, Community, and Infrastructure

Mining 2030: Unearthing Ontario’s Potential | 32

Summary of Recommendations 1.

Ontario should remove ambiguity around administrative and community-building expenses by ensuring that both upfront and ongoing partnership costs are eligible for Mining Tax treatment.

2.

Ontario should ensure that mining proponents are provided with a single consultation list. This would require alignment across legal branches of government with authority vested in a single point of contact to make final determinations of affected communities and consultation adequacy. Ontario should further ensure that it coordinates with the federal government to align requirements between levels of government.

3.

The federal government should expand flow-through share (FTS) eligibility for the Canadian Exploration Expense (CEE) by including the costs of technical studies.

4.

Ontario should introduce an exploration tax credit that is stackable with the federal flowthrough share rules to support more exploration activity and the development of new mines.

5.

The Ontario and federal governments should explore options, such as contracts for difference, to provide greater long-term price certainty for some critical minerals identified in the province’s Critical Minerals Strategy.

6.

Ontario’s regulatory system should reduce permitting timelines for all mining companies operating in Ontario. As Ontario works to reform its regulatory system, the following principles should guide implementation: a. One point of contact for applications; b. A ‘concierge’ within government to help proponents navigate process from end-to-end; c. Consolidated permitting into one, side-wide permit with coordination between orders of government to reduce duplication; d. Expanded capacity within government; e. A unified digital platform to submit and track applications; and f. Firm deadlines to reach decisions for both new projects and for permits and amendments impacting operating mines.

7.

The Ontario government should consider all available options, including rate mitigation, to protect the province’s industrial foundation from the impacts of rising and more volatile electricity prices over the next decade.

8.

The Ontario government should index the Northern Energy Advantage Program to the Consumer Price Index (CPI) and extend the program term beyond five years to give rate relief for mines and provide business certainty over the next decade.

9.

The Ontario government should invest in key roads, including Highways 69, 144, 11, and 17, that serve northern communities and mines and connect them to markets across the province and beyond.

10. Ontario should build on existing northern economic development plans, such as the Growth Plan for Northern Ontario and the Northern Ontario Heritage Fund, by creating a bold, long-term strategic framework. This could draw inspiration from Quebec’s Plan Nord. Any plan must integrate physical, social, and community infrastructure, ensure coordinated investment, and match scale and ambition to the demands of mining-led growth in the North.

11. Ensure the Ontario Immigrant Nominee Program supports northern labour market needs by expanding regional allocation streams. Building on Ontario government pilots such as REDI (Regional Economic Development through Immigration) and the Employer Job Offer (Northern Ontario Stream), the province should commit to a predictable and scaled pathway.

12. Ontario should build upon the successes of the Indigenous Economic Development Fund and support Indigenous businesses and communities in learning about the procurement supply chain RFP processes. Local mining and supply and service companies should engage early with Indigenous businesses to share their long-term investment plans, specifically identifying opportunities to improve Indigenous participation in procurement.

13. Government and industry should collaborate on a long-term, coordinated campaign to continue to build understanding and interest in mining among young Ontarians, highlighting the sector’s economic opportunity, safety record, environmental leadership, and role in Canada’s clean economy of the future.

Mining 2030: Unearthing Ontario’s Potential | 33

Conclusion Mining presents one of the greatest economic and social opportunities for Ontario. Mining can grow and green the economy, advance economic reconciliation with Indigenous communities, and strengthen Canada’s sovereignty in an era of geopolitical change.

Realizing this potential requires action. As this report has discussed, the challenges facing Ontario’s mining sector are interconnected and systemic. The sector needs clearer, more consistent rules for consultation and the capacity within Indigenous communities to engage meaningfully.

It needs the fiscal tools to move projects from exploration to operation; a regulatory framework that is efficient and predictable; low-cost and stable energy prices; and a skilled workforce that is sustained with investments into stronger communities.

With strong collaboration between government, industry, and Indigenous partners, mining can be a lasting driver of Ontario’s prosperity for generations to come.

Mining 2030: Unearthing Ontario’s Potential | 34

Addendum: Potential Economic Impact of Regulatory Reform

Lead research contributor

Introduction The OCC is pleased to collaborate with PwC Canada to conduct a comparative assessment of leading mining jurisdictions, including Australia, British Columbia, Quebec and Finland. Their assessment suggests that, on an illustrative basis, bringing Ontario’s permitting timelines closer to leading jurisdictions could enable roughly one to two additional mines to reach construction or operation each year.

The following provides an overview of PwC’s analysis, including the quantitative modelling and jurisdictional and operational insights derived from their assessment.

Key Pillars for Reform: PwC’s analysis identifies four critical themes where Ontario can adopt international best practices to streamline approvals while maintaining strong environmental standards and social: 1.

Interagency Coordination and Regulatory Sequencing: By centralizing coordination and reducing duplicative reviews, governments can reduce bottlenecks that increase cost and lengthen timelines for proponents.

2.

Risk-Based Approvals: Implementing tiered pathways where low-impact or routine activities proceed via notification-based approvals allow regulators to focus resources on complex or higherrisk applications.

3.

Digital Modernization: Investing in a unified digital platform for mining applications can help to increase transparency, automate compliance tasks for regulators, and promote shared decisionmaking for all stakeholders.

4.

Meaningful Indigenous Engagement: Where feasible, single, unified consultation processes can help reduce “consultation fatigue” and can help to improve predictability and certainty for both Indigenous communities and industry.

As Ontario seeks to secure its role in the global critical minerals supply chain, the insights within this addendum and the broader report serve as a call to action. PwC’s analysis shows that, if implemented, these changes could result in meaningful economic outcomes for Ontario. Modernizing our regulatory environment increases the likelihood that exploration success translates into operational mines, high-quality jobs, and healthy, sustainable mining communities across the province.

PwC’s analysis is subject to limitations described in this addendum. This analysis was produced independently. The views, conclusions, and recommendations presented in the Mining 2030 report outside of this analysis do not reflect input from PwC.

Lead research contributor

Mining 2030: Unearthing Ontario’s Potential | 36

Comparative Assessment of the Regulatory Process in Ontario’s Mining Sector To inform OCC’s recommendations, we identified leading practices from peer jurisdictions such as Western Australia, British Columbia, Quebec, and Finland. We engaged directly with global industry specialists, regulatory officials, mining companies, and consultants through interviews. This approach allowed us to go beyond published literature and capture real-world operational insights and challenges.

Our analysis focused on four key themes: interagency coordination and regulatory sequencing, risk-based approvals, digital modernization, and Indigenous engagement.

Interagency coordination and regulatory sequencing Mining projects typically require multiple approvals across ministries and, at times, federal agencies. This complexity can often lead to duplicative reviews and bottlenecks, ultimately lengthening timelines.

Lessons from leading jurisdictions Jurisdiction

Western Australia

Reforms/Initiatives

•

2023-2024: Moved from project coordinator model to a centralized coordination system enabling parallel processing of mining and environmental approvals.

•

Introduced Resources Online portal (in November 2024) for single submission and tracking. This aligns with the broader reform agenda under FastTracking Mining Approvals Strategy and Approval Response Plan, with set decision timelines and Eligible Mining Activity (EMA) pilot for low-risk activities.

•

•

Applies integrated reviews mainly to brownfield expansions, enabling all permits and environmental assessments to be processed together.

•

BC has implemented process changes to reduce formal decision points (i.e. fewer mandatory regulatory approval steps) during the lifecycle of an energy resource activity (relates to broader resource sector, not mining exclusively).

British Columbia

1 2

2018 EA Act reform: Introduced substitution agreements allowing for a single coordinated review satisfying both federal and provincial requirements.

Impacts

•

Early results directionally positive but modest; average mining proposal processing time fell from 51 to 46 business days1;

•

A report by the Department of Energy, Mines, Industry Regulation and Safety, notes that success of these reforms depends on adequate resourcing and staff continuity to meet target timeframes;

•

Clearer sequencing and better visibility for proponents; implementation still maturing.

•

Combined environmental assessment and permitting for existing mines reduced timelines by up to 60%.2

•

As a result of reducing formal decision points, there was approximately a 12% reduction in the need for pipeline amendment applications and ~30%* reduction in facility amendment applications to date.

Assessment Timeframes for Mining Environmental Applications

The 60% reduction is an example interview based insight provided by BC officials.

Lead research contributor

Mining 2030: Unearthing Ontario’s Potential | 37

Quebec

• Piloted Bureau de coordination de l’évaluation environnementale (BCEE) in 2019 to align ministry reviews and streamline permitting.

Finland

• 2023-2026 reform agenda: Aligning its permitting system to the EU Critical Raw Materials Act, to provide a single point of contact.

• In 2023, the initiative had reduced timelines for each permit in scope by an average of 43%,3 • Industry viewed it positively for improving communication, but it was eventually discontinued.

• Improved predictability; • Timelines for strategic projects decreased.4

• Introduced joint processing and integrated hearings with digital e-services and statutory timelines.

*The facility number is a rough estimate only, based on year-over-year application numbers and may be influenced by other factors.

For Ontario, targeted reforms like centralized coordination, parallel processing of approvals, and clear decision timelines could be expected to lead to significant improvements in permitting efficiency. A key benefit of this approach is that much of it can be achieved through operational changes, even within existing legislative and regulatory frameworks.

Risk-based permitting processes Adjusting the scale of regulatory review to match the size and risk profile of mining projects can reduce unnecessary administrative burden for routine or low-impact activities, while allowing regulators to focus resources on complex or higher-risk developments.

Although recent changes like the Building More Mines Act (2023) have added some flexibility by aiming to match regulations with the risks and sizes of projects, Ontario’s approach to risk-based permitting is still narrow and hasn’t been formally applied to all types of approvals.

Lessons from leading jurisdictions Jurisdiction Western Australia

South Australia

3 4

Reforms/Initiatives

Impacts

• 2025: Development of the EMA framework; low-impact or low-risk activities (i.e. minor exploration works) that meet predefined criteria, can proceed via notification-based approval instead of full assessment.

• Still in pilot phase, implementation ongoing.

• Ongoing Mining Act Review introducing tiered, risk-based approval pathways;

• Ongoing; expected to reduce bottlenecks and improve processing times.

• Streamlined approvals for low-risk exploration; clearer timelines for high-risk projects; emphasizes proportionality and transparent standards.

Interviews with Quebec officials.

Interview based insight.

Lead research contributor

Mining 2030: Unearthing Ontario’s Potential | 38

Digital permitting platforms While no jurisdiction has yet achieved a fully integrated one-stop portal, Western Australia and British Columbia are leading this digital transition.

Lessons from leading jurisdictions Jurisdiction

Reforms/Initiatives

Impacts

• Launched Resources Online (2024) - a centralized portal integrating mining and environmental approvals; Western Australia

British Columbia

• Replaced legacy systems, enabling single submission, tracking, and management across agencies; • Supports parallel processing of applications; • The proposed Shared Environmental Analytics Facility (SEAF): a platform for sharing regional environmental data that could reduce project assessment timelines by up to 34 months.

• Full impact not yet measurable as rollout continues.

• Introduced MineSpace, a unified hub for permit applications, tracking, and reporting; • In 2025, piloted AI tools to extract permit requirements and automate compliance checks.

Digital platforms are most valuable when used to drive broader alignment in approach, such as improving sequencing, and streamlined coordination and parallel processes. They can also enhance analytics and automation by enabling AI to handle compliance tasks, identify missing information, and provide current dashboards, increasing both efficiency and transparency. Additionally, these shared platforms promote informed decision-making by ensuring all stakeholders access the same data, which builds trust and simplifies communication.

Indigenous and community consultations Indigenous and community consultation remains one of the most important, complex, and time-intensive aspects of mining permitting in many jurisdictions. We understand that industry and community feedback underscores persistent challenges in balancing meaningful consultation with process efficiency and regulatory certainty. In Ontario, key issues identified by proponents include a lack of clarity on which specific communities mining companies need to consult and what constitutes adequate consultation.

Responsibilities are routinely delegated to proponents, with limited central guidance or consistency across ministries, making the process unpredictable and sometimes fragmented.

Lessons learned from best practices across jurisdictions Across leading jurisdictions, several approaches to Indigenous consultation have emerged, each with its own strengths and trade-offs.

Lead research contributor

Mining 2030: Unearthing Ontario’s Potential | 39

Jurisdiction

British Columbia

Quebec

Reforms/Initiatives

Impacts

• Introduced a single, unified consultation process for brownfield (existing) sites where EA amendments and permitting are coordinated together as one process5;

• Single, unified consultation for brownfield amendments replaces 6-7 separate rounds; reducing duplication and consultation fatigue.

• For new (greenfield) projects, proponents typically complete the EA process first, and engagement remains iterative and complex, with separate consultation rounds required for EA and several additional permits.

• Requires engagement with municipalities and Indigenous communities before major exploration begins.

• Early consultation builds trust and transparency, but it can extend timelines if communities or municipalities lack staff and technical capacity.

Economic impacts PwC assessed the potential economic gains that could result if Ontario’s mining permitting process were more efficient and required less time to move from exploration to operations. We used a benchmarking approach, comparing Ontario’s performance to peer jurisdictions, using capex-to-exploration ratios and project-level data (for full details on the benchmarking methodology and peer selection, see Appendix).

The analysis focuses on how faster approvals could: • Enable more exploration projects to advance into construction and operation; and • Accelerate project timelines, creating earlier economic benefits for investors and government.

Australia was selected as the primary benchmark because it combines similar geological potential with a well-documented track record of permitting reforms and reliable, accessible data. Compared to other peer jurisdictions, Australia’s regulatory environment and commodity mix are broadly comparable to Ontario, and its permitting process is recognized for greater efficiency.

Canada’s mine development timelines are longer than global peers, averaging about 20 years from exploration to production, versus 14 years in Australia.6

Economic footprint Despite the similarities outlined above, Australia sees significantly more mines going into production relative to exploration spending. There are many reasons for this including more efficient regulatory and permitting processes, geology (grade, accessibility, size) and infrastructure access. To estimate the impact of regulatory and permitting improvements, we assumed a conservative illustrative range (5-10%) of the share of this gap that could be attributable to regulatory and permitting factors. Under these assumptions, Ontario could see roughly one to two additional mines reach construction or operation each year, even given similar exploration spending to 2024 levels (all dollar values reported here are in 2024 Canadian dollars).7

5 6 7

Insights from interview with BC government officials.

S&P Global. From 6 years to 18 years: The increasing trend of mine lead times.

Statistics Canada, S&P, PwC Analysis

Lead research contributor

Mining 2030: Unearthing Ontario’s Potential | 40

We used the REMI PI+ model, which enables the dynamic forecasting of policy and investment scenarios, to analyze the impact of this increased investment. This model estimates the impact of new investment throughout the entire Ontario economy. We used this model to translate the increases in investment expected from each regulatory and permitting efficiency scenario (closing 5% or 10% of the mining to exploration gap) into macroeconomic outcomes such as GDP. Results are reported as increases relative to the baseline level for 2026.

The 5% improvement scenario could add 4,200 jobs and add more than C$1 billion to Ontario’s annual GDP, with the largest gains in the mining sector and spillovers into the retail, professional services, and construction sectors. The 10% scenario could create over 8,500 jobs and add more than C$2.1 billion to Ontario’s GDP in a single year.

Table 1: Economic footprint summary of 5% and 10% improvement scenario in Ontario

Economic Measures Total employment (thousands)

Year-2026 (5% scenario)

Year-2026 (10% scenario)

4,211

8,533

Gross Domestic Product (GDP)

$1.07B

$2.174B

Personal Income (thousands)

$443,000

$899,000

Output

1.67B

$3.38B

Table 2: Employment impacts, by industry, of 5% and 10% improvement scenario in Ontario

Industry

Year-2026 (5% scenario)

Year-2026 (thousands) (10% scenario)

Mining and quarrying (except oil and gas)

963

1,951

Retail trade

347

702

Professional, scientific and technical services

327

664

Residential building construction

245

496

Repair construction

184

373

All other industries (total)

2,144

4,346

In addition to GDP and employment gains, the permitting efficiency scenarios generate fiscal benefits for Ontario. Under the 5% improvement scenario, personal income tax (PIT) revenues would increase by approximately $26.7 million, sales tax by $14.1 million, and corporate income tax (CIT) by $28.7 million.

The 10% scenario nearly doubles these impacts, with PIT rising to $54.1 million, sales tax to $28.5 million, and CIT to $58.1 million. These figures reflect incremental provincial tax revenues attributable to higher economic activity and employment under each of the scenarios.

Table 3: Provincial tax impacts for 5% and 10% improvement scenario in Ontario

Revenue changes

5% scenario ($ millions)

10% scenario ($ millions)

Personal Income Tax (PIT)

26.7

54.1

Sales Tax

14.1

28.5

Corporate Income Tax (CIT)

28.7

58.1

Lead research contributor

Mining 2030: Unearthing Ontario’s Potential | 41

Realizing economic benefits sooner Speeding up regulatory and permitting processes, for example to bring them more in line with Australian timelines, would mean that projects come into production sooner after discovery, even in the absence of incremental inbound investment. Businesses and governments value income today more highly than income in the future, because of the time value of money in terms of foregone investment income, debt costs, and risk. This impact is measured using net present value, which takes into account how future income is discounted compared to the present, reflected by a discount rate.

Using illustrative cash flows from public disclosures from a mine in Ontario, we calculated that reducing regulatory and permitting timelines by six years would increase the net present value of company cash flows by 63% ($173 million), and provincial tax revenues by 42% ($77.4 million).89 The ability to create jobs, attract investment, and generate tax revenues is particularly valuable in times of high economic uncertainty.

8 9

The impact for government is lower relative to the company because of a lower discount rate reflecting their lower cost of borrowing and risk from the project.

Six years is equivalent to the difference between Canadian and Australian averages, and is an illustrative value chosen to represent potential improvements for Ontario.

Lead research contributor

Mining 2030: Unearthing Ontario’s Potential | 42

Appendix A: Methodology To benchmark Ontario’s performance, PwC identified peer jurisdictions with similar geological potential but higher policy and permitting efficiency and higher capital and operating expenditure: • Fraser Institute’s Annual Survey of Mining Companies was used to compare jurisdictions across two key indicators: • Mineral Potential Index (geological attractiveness) • Policy Perception Index (regulatory attractiveness) • Jurisdictions within ±5 points of Ontario’s mineral potential score and scoring higher on policy perception were shortlisted.

Among those jurisdictions with similar commodity mixes (e.g., gold, nickel) were prioritized.

Based on data availability and comparability, Australia was selected as the primary benchmark. Although Australia’s mineral potential is somewhat higher, many aspects of the investment environment are comparable, and it is established as having historically stronger regulatory and permitting.

Data sources The following data were used: • Ontario: Statistics Canada- Capital and Repair Expenditures Survey for NAICS 212 Mining.

• Australia: Australian Bureau of Statistics - Mineral Exploration Expenditure • Project-level data: S&P Global Market Intelligence - for tracking gold project investment and operational transitions (2014–2024).

• Operating expenditure estimates: Derived from the Statistics Canada Supply–Use Tables (2021, detailed industry level) and validated against S&P Global data for active Ontario gold mines.

Analysis 1.

Calculate average annual expenditures (2014-2024): Average annual Capex and Exploration Expenditures were calculated for Ontario and Australia using 10-year trend data (2014-2024). a. Example (rounded): b. Ontario CapEx ≈ CAD 2.7 billion c. Ontario Exploration ≈ CAD 0.7 billion d. Australia CapEx ≈ CAD 33.8 billion e. Australia Exploration ≈ CAD 2.5 billion

2.

Derive capex to exploration ratio: The capex-to-exploration ratio was computed for both jurisdictions to capture how efficiently exploration spending translates into development (i.e. how many exploration projects progress to construction/operation).

3.

Estimate efficiency gap and improvement scenarios: The difference in ratios represents the relative “efficiency gap”, how much more effectively exploration spending converts into construction activity in Australia.

Two conservative improvement scenarios were modelled for Ontario; with 5% and 10% improvement.

Translate incremental capex into new mines: To contextualize investment gains, average capex per new mine was estimated at CAD $350 million, based on S&P data.

Lead research contributor

Mining 2030: Unearthing Ontario’s Potential | 43

Incremental capex from Step 3 was divided by $350 million to estimate potential new mine Scenario

5% improvement

Incremental capex ($M)

Avg. capex per active mine ($M)

Approximate no. of mines

404.84

350.0

1.2

809.67

350.0

2.3

10% improvement

Estimate associated operating expenditures: Operating expenditures per mine were benchmarked at $254 million annually, derived from Supply-Use Tables data. This value will be applied in the economic footprint model to estimate recurring annual GDP and employment impacts once additional mines are assumed to be operational.

These results indicate that modest permitting efficiency improvements (5-10%) could enable 1-2 additional mines to production, adding hundreds of millions in annual capex and opex activity.

Capex and opex were translated into economic outcomes using the REMI+ model, which enables the dynamic forecasting of policy and investment scenarios. This model estimates the impact of new investment throughout the entire Ontario economy.

NPV analysis Below we outline our methodology for assessing the Net Present Value (NPV) analysis for quantifying the financial impact of accelerating project development timelines.

Approach The NPV analysis was completed in two stages: Step 1: Establishing a baseline (status quo permitting timelines) We first identified six Ontario mining projects currently classified as Advanced Exploration in S&P Global’s database. For each project, we reviewed NI 43-101 documents for details of project cash flows.

Due to data limitations, one project (IAM Gold’s Côté gold mine) was selected as a representative casestudy approach. We developed a baseline NPV model reflecting: • Total project capex • The full Life-of-Mine cash-flow schedule • Construction period • Expected production start year • A discount rate of 8.44%, based on Damodaran’s estimated cost of capital for Canadian gold mining projects The resulting NPV represents the financial value of the project under current permitting timelines, where projects in Canada take approximately 20 years on average to advance from exploration to production (S&P Global).

Lead research contributor

Mining 2030: Unearthing Ontario’s Potential | 44

Step 2: Accelerated scenario (improved permitting timelines) S&P Global data indicate that Australia achieves exploration-to-production timelines of approximately 14 years. Based on this, we modelled an improved timeline where the project moves into production approximately six years earlier. In this accelerated scenario: • Total capex remains unchanged • Construction duration remains unchanged • Operating cash flows occur earlier • The discount rate remains at 8.44% Since revenues begin sooner, the NPV of the project increases materially due to the time value of money.

We find that by bringing production forward, increases company cash flows by 63% ($173 million).

We also estimated the impact of accelerated permitting on government fiscal revenues using the same method, including: • Mining royalties • Applicable mining taxes • Applying a 6% discount rate to reflect the approximate long-term borrowing cost We find government tax revenues to increase by 42% ($77.4 million). The impact for government is lower relative to the company because of a lower discount rate reflecting their lower cost of borrowing and risk from the project.

Limitations NI 43-101 reports vary in disclosure detail by company; only one project provided a complete financial model suitable for NPV analysis and was used as a representative mine.

We also note that not all advanced exploration projects will ultimately proceed to construction, and timelines are sensitive to metal prices, financing, and geology.

Appendix B: Limitations Our Services were performed and this Report was developed in accordance with our engagement letter dated September 22, 2025 and are subject to the terms and conditions included therein. Our role is advisory only. OCC is responsible for all management functions and decisions relating to this engagement, including establishing and maintaining internal controls, evaluating and accepting the adequacy of the scope of the Services in addressing OCC’ needs and making decisions regarding whether to proceed with recommendations. OCC is also responsible for the results achieved from using the Services or deliverables.

Receipt of new information: PwC reserves the right at its discretion to withdraw or revise this report should we receive additional information or be made aware of facts existing at the date of the report that were not known to us when we prepared this report. The findings are as of November 2025 and PwC is under no obligation to advise any person of any change or matter brought to its attention after such date, which would affect our findings.

Lead research contributor

Mining 2030: Unearthing Ontario’s Potential | 45

Reliance on third party data/information: We relied upon the completeness, accuracy and fair presentation of all the information, data, advice, opinion or representations obtained from third parties and public sources (collectively, the “Information”). We have not conducted any audit or review of the Information, nor have we sought external verification of the Information. We accept no responsibility or liability for any losses occasioned by any party as a result of our reliance on the financial and non-financial information that was provided to us or found in the public domain.

Use limitations: This report has been prepared solely for the use and benefit of, and pursuant to a client relationship exclusively with OCC. We understand that OCC may share our report with third parties. OCC can release this report to third parties only in its entirety and any commentary or interpretation in relation to this report that OCC intends to release to the public either requires PwC’s written consent or has to be clearly identified as OCC’ own interpretation of the report or OCC is required to add a link to the full report. PwC accepts no duty of care, obligation or liability, if any, suffered by OCC or any third party as a result of an interpretation made by OCC of this report.

Further, no other person or entity shall place any reliance upon the accuracy or completeness of the statements made herein. In no event shall PwC have any liability for damages, costs or losses suffered by reason of any reliance upon the contents of this report by any person other than OCC. This report and related analysis must be considered as a whole: Selecting only portions of the analysis or the factors considered by us, without considering all factors and analysis together, could create a misleading view of our findings. The preparation of our analysis is a complex process and is not necessarily susceptible to partial analysis or summary description. Any attempt to do so could lead to undue emphasis on any particular factor or analysis.

We note that significant deviations from the above listed major assumptions may result in a significant change to our analysis.

Lead research contributor

Mining 2030: Unearthing Ontario’s Potential | 46

References 1

Energy Transitions Commission. Material and Resource Requirements for the Energy Transition. July 2023.

2

International Energy Agency. The Role of Critical Minerals in Clean Energy Transitions. Paris: IEA, 2021.

3

North Atlantic Treaty Organization. “NATO Releases List of 12 Defence-Critical Raw Materials.” NATO, December 11, 2024. https://www.nato.int/cps/en/natohq/news_231765. htm

4

The Guardian, “US military announces $20 m grant to build cobalt refinery in Canada,” August 21, 2024, sec. US news; Financial Post, “Carney says Canada can hit new $110 billion NATO bill with mines,” June 24, 2025.

5

Mining Association of Canada. “Indigenous Employment, Training and Procurement.” Mining.ca. Accessed November 16, 2025. https://mining.ca/our-focus/indigenousaffairs/indigenous-employment-training-and-procurement/

6

These estimates rely on a benchmarking approach that compares Ontario to peer jurisdictions with similar geological potential and commodity mix. The modelling assumes modest improvements (5-10 per cent) in closing the “efficiency gap,” defined as the difference in how effectively exploration spending translates into capital investment, based on capex-to-exploration ratios across jurisdictions. Scenario results reflect potential economic outcomes associated with accelerating project timelines and enabling more exploration projects to advance into construction and operation.

7

Ontario Mining Association. State of the Ontario Mining Sector. Toronto: OMA, March 2025. https://www.oma.on.ca/media/jy3f0tgd/oma-economic-published-march-2025final.pdf

8

Natural Resources Canada. The Canadian Critical Minerals Strategy. Ottawa: Government of Canada, December 2022. https://www.canada.ca/content/dam/nrcan-rncan/site/ critical-minerals/Critical-minerals-strategyDec09.pdf

9

Toronto Stock Exchange. “Mining Sector and Product Profile.” TSX.com. Accessed November 16, 2025. https://www.tsx.com/en/listings/listing-with-us/sector-and-productprofiles/mining

10 Ontario Mining Association, State of the Ontario Mining Sector.

11 Natural Resources Canada. The Canadian Critical Minerals Strategy.

12 Government of Ontario. Ontario’s Critical Minerals Strategy: 2022–2027. Toronto: Queen’s Printer for Ontario, March 2022. https://www.ontario.ca/files/2022-03/ndmnrfontario-critical-minerals-strategy-2022-2027-en-2022-03-22.pdf 13 Joyce Minerals. “Sudbury Mining District: History, Geology and Mineralogy.” Accessed November 16, 2025. https://djoyceminerals.com/sudbury-mining-district-historygeology-and-mineralogy/ 14 Ontario Mining Association. “Mining 101.” Accessed November 16, 2025. https://www.oma.on.ca/ontario-mining/mining-101/ 15 Ontario Mining Association, State of the Ontario Mining Sector.

16 Government of Ontario. “Province Investing $31 Billion to Support Indigenous Partnership in Critical Mineral Development.” News release, March 26, 2025. https://news. ontario.ca/en/release/1005924/province-investing-31-billion-to-support-indigenous-partnership-in-critical-mineral-development 17 Alberta Aboriginal Consultation Office. Aboriginal Consultation Office Annual Report 2021–2022. Government of Alberta, 2022. https://open.alberta.ca/dataset/2af570bede9c-4673-9d9c-926fd3b4f061/resource/8d5ac0f4-d41d-4614-b7eb-b6e8183c7bc4/download/ir-aboriginal-consultation-office-annual-report-2021-2022.pdf 18 Bórzel, Kurt, and Rob Buck. Indigenous Consultation in Alberta. Presentation to the Canadian Institute of Forestry, April 19, 2022. https://www.cif-ifc.org/wp-content/ uploads/2022/05/KurtBorzelRobBuck-20220419-Indigenous-Consultation-in-Alberta-CIF-Presentation-April-2022.pdf 19 KPMG. A Guide to Canadian Mining Taxation. KPMG International, 2023. https://kpmg.pathfactory.com/mining-tax-guide-2023 20 Okada, K., “Breakthrough Technologies for Mineral Exploration,” Minerals 12, no. 8 (2022): 945, https://www.mendeley.com/catalogue/385ff91f-99f0-3e2c-b471f3ef35f5134d/ 21 Canadian Climate Institute. Critical Path: Securing Canada’s Place in the Global Critical Minerals Race. Ottawa: Canadian Climate Institute, June 2025. https://climateinstitute. ca/wp-content/uploads/2025/06/Critical-path-Canadian-Climate-Institute.pdf 22 Ontario Mining Association, “Mining 101.”

23 Prospectors & Developers Association of Canada. Considerations & Recommendations for Federal Fall Budget 2025. Toronto: PDAC, 2025. https://cdn7.pdac.ca/web/files/ PDAC-Pre-Budget-Consultation-Fall-2025.pdf 24 Government of British Columbia. “Mining Exploration Tax Credit.” Accessed November 16, 2025. https://www2.gov.bc.ca/gov/content/taxes/income-taxes/personal/credits/ mining-exploration; Government of Québec, “Tax Measures to Support the Mining Industry.” Ministère des Finances Québec, accessed November 16, 2025. https://www. finances.gouv.qc.ca/documents/Autres/en/AUTEN_DepliantTaxMeasuresMiningIndustry.pdf 25 Canadian Climate Institute, Critical Path.

26 Lewis, James Andrew, and Gracelin Baskaran. “The Consequences of China’s New Rare Earths Export Restrictions.” Center for Strategic and International Studies (CSIS), October 9, 2024. https://www.csis.org/analysis/consequences-chinas-new-rare-earths-export-restrictions 27 Sanderson, Henry. “China Has Broken the Critical Minerals Market.” Bloomberg Opinion, September 30, 2024. https://www.bloomberg.com/opinion/articles/2024-09-30/ energy-transition-china-has-broken-the-critical-minerals-market 28 Canadian Climate Institute, Critical Path.

29 Robin Friedman, “Trump’s Mineral Megadeal Is Bypassing US Laws,” E&E News, April 29, 2024, https://www.eenews.net/articles/trumps-mineral-megadeal-is-bypassingus-laws/; Courtney Dickson, The Canadian Press. “Why the U.S. government is investing in B.C. mining companies,” CBC News, October 7, 2025, https://www.cbc.ca/news/ canada/british-columbia/u-s-government-investment-in-b-c-mining-companies-trilogy-metals-inc-lithium-americas-1.7653331 30 Pilkington, Caitrin. Canada and U.S. Department of Defence invest $35M in the Yukon’s Mactung mine. CBC News. December 17, 2024. https://www.cbc.ca/news/canada/ north/mactung-mine-fireweed-metals-us-department-defence-1.7412022 31 National Reconstruction Fund Corporation. “NRFC to Invest $50 Million in Liontown Resources’ Kathleen Valley Lithium Project.” Government of Australia, media release, August 7, 2025. https://www.nrf.gov.au/news-and-media-releases/nrfc-invest-50-million-liontown-resources-kathleen-valley-lithium-project 32 S&P Global Commodity Insights. “Floor Price Possible for Australian Critical Minerals Reserve: Resources Minister.” August 6, 2025. https://www.spglobal.com/commodityinsights/en/news-research/latest-news/metals/080625-floor-price-possible-for-australian-critical-minerals-reserve-resources-minister 33 Québec investit encore dans Nemaska Lithium Inc., portant le total à près de 1 milliard $.” Radio-Canada, September 2, 2025. https://ici.radio-canada.ca/nouvelle/2189557/ quebec-investit-nemaska-lithium-total-un-milliard 34 “Feds Pitch $2 B Fund for Critical Minerals Investments, Including Equity Stakes,” CTV News, November 4, 2025. https://www.ctvnews.ca/business/article/feds-pitch-2b-fundfor-critical-minerals-investments-including-equity-stakes/ 35 Canadian Climate Institute, Critical Path.

36 Rae, Marion. “The Non-China Premium: Why Aussie Taxpayers Will Underwrite Rare Earths.” The Energy Co., October 3, 2024. https://theenergy.co/article/the-non-chinapremium-why-aussie-taxpayers-will-underwrite-rare-earths

Mining 2030: Unearthing Ontario’s Potential | 47

37 Mason, Joseph, and Laurie Chen. “G7 Weighs Price Floors for Rare Earths to Counter China’s Dominance, Sources Say.” Reuters, September 24, 2025. https://www.reuters. com/world/china/g7-weighs-price-floors-rare-earths-counter-chinas-dominance-sources-say-2025-09-24/ 38 United Kingdom Department for Energy Security and Net Zero. “Contracts for Difference.” Accessed November 16, 2025. https://www.gov.uk/government/collections/ contracts-for-difference 39 S&P Global Market Intelligence. “Discovery to Production Averages 15.7 Years for 127 Mines.” March 2023. https://www.spglobal.com/market-intelligence/en/news-insights/ research/discovery-to-production-averages-15-7-years-for-127-mines 40 Canadian Climate Institute, Critical Path.

41 These estimates rely on a benchmarking approach that compares Ontario to peer jurisdictions with similar geological potential and commodity mix. The modelling assumes modest improvements (5-10 per cent) in closing the “efficiency gap,” defined as the difference in how effectively exploration spending translates into capital investment, based on capex-to-exploration ratios across jurisdictions. Scenario results reflect potential economic outcomes associated with accelerating project timelines and enabling more exploration projects to advance into construction and operation.)

42 Cassels Brock & Blackwell LLP. “Accelerated Project Approvals Under the Building Canada Act.” June 10, 2025. https://cassels.com/insights/accelerated-project-approvalsunder-the-building-canada-act/ 43 Government of British Columbia. “New legislation will accelerate B.C. renewable energy projects.” News release, February 6, 2025. https://news.gov.bc.ca/ releases/2025ECS0006-000100 44 Drance, Jonathan, and Rachel V. Hutton. “Permitting Reform For Renewable Energy Projects. Strikeman Elliott LLP. September 2024. https://stikeman.com/en-ca/kh/canadianenergy-law/permitting-reform-for-renewable-energy-projects 45 McMillan LLP. “B.C.’s Push to ‘Smooth the System’: How Bill 15 Impacts B.C.’s Regulatory Process.” June 9, 2025. https://mcmillan.ca/insights/publications/bcs-push-to-smooththe-system-how-bill-15-impacts-bcs-regulatory-process/ 46 Government of Nova Scotia. “New Phased Approach to Industrial Approval Process to Support Responsible, Faster Metal Development.” News release, June 13, 2025. https://news.novascotia.ca/en/2025/06/13/new-phased-approach-industrial-approval-process-support-responsible-faster-metal 47 Government of Nova Scotia. “New Phased Approach to Industrial Approval Process.”

48 Anishinabek News. “New App to Help Address High Volumes of First Nation Consultation Requests.” April 2021. https://anishinabeknews.ca/2021/04/new-app-to-helpaddress-high-volumes-of-first-nation-consultation-requests/ 49 Legislative Assembly of Ontario. Bill 5, Protect Ontario by Unleashing our Economy Act, 2025. 1st sess., 44th Parl., 2025. https://www.ola.org/en/legislative-business/bills/ parliament-44/session-1/bill-5 50 B. Bharathan, A. P. Sasmito, and S. A. Ghoreishi-Madiseh, “Analysis of Energy Consumption and Carbon Footprint from Underground Haulage with Different Power Sources in Typical Canadian Mines,” Journal of Cleaner Production 166 (2017): 21–31, https://doi.org/10.1016/j.jclepro.2017.07.233; W. Huang and Y. Chen, “The Application of High Voltage Pulses in the Mineral Processing Industry: A Review,” Powder Technology 393 (2021): 116–130, https://doi.org/10.1016/j.powtec.2021.07.003 51 Ontario Energy Board. Market Surveillance Panel: State of the Market Report 2023 (MSP39). Toronto: Ontario Energy Board, September 2024. https://www.oeb.ca/sites/ default/files/Final%20MSP39%20SotM23%20_As%20of%20Aug22.pdf 52 Government of Ontario. Energy for Generations: Ontario’s Long-Term Energy Plan. Toronto: Queen’s Printer for Ontario, June, 2025. https://www.ontario.ca/files/2025-07/ mem-energy-for-generations-en-2025-07-18.pdf 53 Ontario Mining Association, State of the Ontario Mining Sector.

54 Mining Industry Human Resources Council. National Outlook 2023. Ottawa: MiHR, March 2023. https://mihr.ca/wp-content/uploads/2023/03/Mihr-National-OutlookEN-2023.pdf 55 Ontario Mining Association and Ipsos. Ontario Labour Market Project: Final Report. Toronto: OMA and Ipsos, November 14, 2022. https://www.oma.on.ca/media/eeehkx21/ ipsos_oma-olmp-research-project_final-report_nov-14_english.pdf 56 Building Ontario Fund. “Building Ontario Fund’s Mandate Expanded to Include Critical Minerals.” Accessed November 16, 2025. https://buildingonfund.ca/building-ontariofunds-mandate-expanded-to-include-critical-minerals/ 57 Whalen, Danny. “Northern Leaders Want Highways 11 and 17 Made into 2+1 Corridors.” The Trillium, July 23, 2025. https://www.thetrillium.ca/municipalities-newsletter/ northern-leaders-want-highways-11-17-made-into-21-corridors-10984480 58 Government of Ontario. Connecting the North: Draft Transportation Plan for Northern Ontario. Toronto: Queen’s Printer for Ontario, 2025. https://www.ontario.ca/page/ connecting-north-draft-transportation-plan-northern-ontario 59 Ontario Medical Association. “Stop the Crisis: Save Rural and Northern Ontario.” Accessed November 16, 2025. https://www.oma.org/advocacy/stop-thecrisis/?shpath=/priorities/save-rural-and-northern-ontario 60 Future Skills Centre. Labour Markets in Northern Ontario 2025. Toronto: Future Skills Centre, April 2025. https://fsc-ccf.ca/wp-content/uploads/2025/04/labour-markets-innorthern-ontario-2025.pdf 61 Canada Mortgage and Housing Corporation. North at Home: Understanding Housing Conditions in Northern Ontario. Ottawa: CMHC, 2021. https://assets.cmhc-schl.gc.ca/ sites/cmhc/professional/housing-markets-data-and-research/housing-research/research-reports/housing-needs/research-insights/2021/north-home-understand-housingconditions-north-on-en.pdf 62 CMHC, North at Home.

63 Government of Québec. Plan Nord. Québec City: Ministère du Développement durable, de l’Environnement et des Parcs, 2012. https://www.environnement.gouv.qc.ca/ developpement/rio20/fiches-info-en.pdf 64 Conference Board of Canada. Immigration Beyond the GTA. Ottawa: Conference Board of Canada, 2019. https://www.conferenceboard.ca/wp-content/uploads/ woocommerce_uploads/reports/10342_ImmigrationBeyondtheGTA-RPT.pdf 65 Ontario Chamber of Commerce and Canadian Council for Indigenous Business. A Way Forward, Ontario’s Path Towards Economic Reconciliation, Equity and Inclusive Growth: Part III Procurement. Toronto, 2025. https://occ.ca/wp-content/uploads/OCC-Procurement-V6-FINAL.pdf.

66 Canadian Council for Indigenous Business. Partnerships in Procurement. Toronto: CCIB, 2016. https://www.ccib.ca/wp-content/uploads/2016/11/Partnerships-inProcurement-FullReport.pdf 67 Ontario Mining Association. State of the Ontario Mining Sector, March 2025. Toronto: OMA, March 31 2025. https://www.oma.on.ca/media/jy3f0tgd/oma-economicpublished-march-2025-final.pdf 68 Maclaine, Cameron, Melissa Lalonde and Adam Fiser. Working Together: Indigenous Recruitment and Retention in Remote Canada. Ottawa: Conference Board of Canada, 2019. https://www.conferenceboard.ca/wp-content/uploads/woocommerce_uploads/reports/10121_IndigenousEmployment-RPT.pdf 69 Mining Association of Canada. Mining & Public Opinion in Ontario: Tracking Research Results. Spring 2025. https://files.constantcontact.com/943dd4d0101/d073a5da-0f9a4015-9b85-d46a329425df.pdf 70 Mining Industry Human Resources Council. Perceptions and Interest in a Mining Sector Career. Ottawa: MiHR, October 2023. https://mihr.ca/wp-content/uploads/2023/10/ MiHR-Youth-Perceptions-Survey-Presentation-2023.pdf 71 Workplace Safety North, Making Workplaces Safe a Year in Review. (North Bay, ON: Workplace Safety North, August 26, 2024), https://www.workplacesafetynorth.ca/sites/ default/files/2024-08/Workplace_Safety_North_Annual_Report_2023-2024-08-26.pdf; Workplace Safety and Insurance Board, 2023 Annual Report (Toronto: WSIB, 2024), https://www.wsib.ca/sites/default/files/2024-09/2023_annualreport.pdf

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