The Federation of Ontario…

The Federation of Ontario Cottagers’ Associations (FOCA) has been represented on the Minister’s Mining Act Advisory Committee (MMAAC) since 2008, and actively involved in the sub-committee that developed the original recommendations for the regulations governing exploration plans and permits. FOCA represents 50,000 property owners across rural Ontario.

Below are FOCA’s comments regarding the proposed regulations changes contemplated in this EBR Posting #012-8179.

When the regulations were implemented in 2012 there was a major omission, in that there was no provision for the Ministry (the Minister, or the Director) to have discretion to bump an Exploration Plan up to an Exploration Permit on the basis of issues identified by the public. The discretion was limited to issues raised by First Nations. Without discretion there is no way for the Ministry to impose terms and conditions on a work plan except if it is a First Nations’ issue.

FOCA strongly supports the proposed regulation change to Section 18 of Regulation 308/12 which implements the broadened discretion which has been requested by all ENGO members of MMAAC and supported by all MMAAC members on several occasions since 2012. FOCA recommends that the discretion include the ability to require a permit where there are issues of environmental significance and/or broad public concern.

Proposed Changes to Provincial Standards FOCA also supports the proposed changes to the provincial standards and in particular point #3 concerning pre- and post-mobilization notices, though we recommend the notice provisions be expanded beyond notices to First Nations and to also apply to the general public. While most exploration activity is some distance from settled areas, there are exceptions where the work can be close to or immediately adjoining private residential property or communities. FOCA believes that individual property owners have a right to full information and notification of exploration work, and that the statement should be expanded to ensure that specific notice be given to adjoining and nearby landowners and more general information provided to the communities which may be impacted.

Respectfully,

Terry Rees
Executive Director

[Original Comment ID: 195057]