Permitting and Licensing Fission’s PLS High-Grade Uranium Mining Project
Just last week, Fission submitted the draft Environmental Impact Statement (“EIS”) for the PLS project to the Saskatchewan Ministry of Environment (“SK-ENV”). Reaching this stage is an exceptional development milestone and is a testament to the quality and viability of the project. It is also significant in terms of our timeline to production. As such, I wanted to share my thoughts on why this milestone is so important and why Fission is well positioned as we move through the permitting and licensing phase. I will do so by answering the key questions we’ve received from shareholders since we announced the EIS submission.
Why the use of the word “Draft” in our EIS documents submission? Why not submit a final EIS?
The short answer is that an EIS is not final until deemed complete following the ministry’s technical review, which is why the EIS review process for all projects begins with the submittal of a draft EIS. It is worth noting here that the EIS is not a single, simple document. It is the culmination of the Environmental Impact Assessment process (“EIA”) and contains years of environmental studies and analysis, consultations with multiple rights holders and stakeholders, and detailed plans for how a company will manage and/or mitigate any potential impact on the environment.
Once the draft EIS has been received, Saskatchewan’s SK-ENV begins its technical review. Typically, after conducting an initial review, the SK-ENV will respond with questions or requests for additional information or clarification to address potential deficiencies in the submission. The company must then respond with the appropriate information. This may lead to further information requests, or it may be sufficient for the SK-ENV to continue its review. Once the SK-ENV is finished its technical review, the EIS and the technical review comments will be made publicly available for a 30 to 60 day response period, after which there will be a ministerial decision.
How long does it take for EIS approval?
When it comes to mining and processing ore, uranium is unique because you must account for the radioactivity. Canada, and specifically the Province of Saskatchewan, has strict but fair permitting and licensing procedures that are the key to our country’s 70+ year track record of safe and efficient uranium production. The EIS review phase is a key part of those procedures, and the exact turnaround time varies depending upon the project, upon the quality and comprehensiveness of the EIS submission, and upon the exact EIS review and approval path (more on that in the next question).
This is where a company needs people who have a deep experience in permitting, constructing, and operating uranium mines, and I cannot stress enough how vital it is that the bulk of our team’s experience lies in the uranium sector and in particular in the jurisdiction where we will operate. Without that experience, gaps in a company’s EIS can result in significant delays during the review process. So, while the timeline for a ministerial decision can vary a great deal, based on our team’s competence and extensive uranium experience, we are optimistic for a positive ministerial decision from the province later this year.
Why doesn’t Fission require a Federal-level review and approval for its EIS?
I want to address this question early on because our development level peers – NexGen Energy and Denison Mines – have also submitted draft EIS documents for their advanced projects. Both peers are progressing under the Canadian Environmental Assessment Act of 2012 (CEAA, 2012) and are required to complete separate Provincial and Federal EIS approvals before they can move to the licensing stage. In contrast, Fission is able to progress via the Impact Assessment Act of 2019, which removed significant duplication of review processes present in the previous regulations.
We can be certain of the Province-only review process because, in 2022, the Impact Assessment Agency of Canada reviewed Fission’s PLS project and issued a ruling stating that under the current Impact Assessment Act of 2019, PLS did not require a Federal impact assessment. The core reasons for this determination are:
- PLS development of Triple R does not meet the physical activities regulations criteria that trigger a Federal review as Fission’s proposed mining and mill capacity is well below 2,500 tonnes per day “TPD” ,
- The PLS project’s activities are well covered by existing legislation,
- There is a strong federal regulator, the CNSC, and
- PLS will undergo a provincial EIA.
This doesn’t mean that Fission’s PLS project is not regulated by the Federal Government. Every single uranium project in Canada is regulated by the Canadian Nuclear Safety Commission (“CNSC”) via the licensing process, which commences after the EIS has been approved. The CNSC will also participate in the review of the provincial EIS and ensure that federally required components are completed. This means that we do not have two separate EIS approval processes running at the same time, as would be the case under the previous system, and that is a great advantage when it comes to timelines.
Why is it such a big advantage to only need the Provincial EIS approval rather than a dual Provincial and Federal level reviews, and is there any disadvantage?
In short, it has the potential to considerably reduce the time taken to move through this crucial stage because we don’t have to duplicate our efforts. It also costs less because we are not paying cost recovery fees to the Impact Assessment Agency. Having just one EIS approval is also consistent with comments from both levels of government that there should be a one-project, one-EIS process wherever feasible, and also, as the Province is the lead for assessing our EIS, the CNSC is more heavily involved once we are able to move into the licensing stage.
When a company receives official EIS approval, what comes next?
After a positive EIS ministerial decision has been acquired, a uranium developer has to apply for all of the required federal and provincial permits and licenses. Much of the preparatory work for the licenses and permits is done parallel to the EIS process with the understanding that no licenses or permits can be issued until there is a positive EIS outcome. Mine and mill construction can only commence once the Province and the CNSC have processed and issued the relevant licenses and permits.
To conclude, I’m extremely pleased with Fission’s rate of advancement during this stage of development. Our permitting and licensing team will continue to work closely with the Province and the CNSC to obtain everything required for construction and eventual production, and in the meantime, our engineers are hard at work as we near the end of the Front End Engineering Design and approach the start of Detailed Engineering.
Further Questions
Please reach out to us through email, phone, or by direct message on social media if you would like further information. I have more media interviews coming up during which I will be happy to address additional questions. I also encourage you to follow our Twitter account for the latest updates, interview clips, and more.
Ross McElroy,
President & CEO of Fission Uranium
