The Wolf Lake region of…

ERO number

019-2230

Comment ID

47888

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

The Wolf Lake region of Sudbury is home to one of the worlds oldest contiguous stands of old-growth red pine. This region is of immense recreational, ecological, and scientific value and should be protected from exploration activities. Three of the four sites on the exploration applications (019-0593 & 019-2230) fall on campsites favored by those who use the area recreationally and all four sites are home to significant numbers of old growth red pine. In 1999 The Government of Ontario committed to absorb the Wolf Lake Forest Reserve into the Chiniguchi Waterway Provincial Park as existing claims expired. In 2012 the MNR and MNDM broke this promise and despite not meeting criteria for lease renewal the leases were extended for a period of 21 years.

This proposal includes mechanized stripping, pitting and trenching, and line cutting and the permit would allow for mechanized drilling to occur as well. These activities will cause unacceptable damage to the health of the ecosystem, adding to the still evident impacts of prior exploration that have already not been cleaned up properly. This damage would include increased erosion and habitat fragmentation from access development, damage to creekbeds and shorelines from this erosion, damage to old growth vegetation and understory, compaction of soils from heavy equipment traffic, and damage from blasting and excavation of pits.

I support the recommendations of the Wolf Lake Coalition, copied here:
"• The application should be thoroughly reviewed to ensure adequate information has been
provided to make a decision. For example, how and when is access proposed for the two new
work sites, where there are no existing trails or roads?
• No new work should be permitted until damage and debris from past work by Flag Resources
are cleaned up and reclaimed properly. Historic workings in the Jess Lake area left heavy cables,
barrels, oily debris, and other drilling detritus on site.
• Flag Resources has a poor record of stewardship during mining exploration at this site and
nearby areas. For example, oil spills, rutting of soils (including streambeds) by movement of
heavy machinery, and abandoned equipment and refuse have been observed. We are
concerned that it is possible this may be repeated and that roads and trails may not conform to
what is permitted, that impacted areas may not be properly cleaned and restored, and that
activities, including wastewater management, may not be handled properly. We are also not
confident that the capacity exists to monitor and enforce conditions, since enforcement has not
happened in the past.
• If this application is approved, conditions should be included to minimize damage, including: (a)
prohibit removal of trees greater than 10cm dbh (these small trees can be very old due to local
growing conditions); (b) specify where work is permitted (excluding the most sensitive areas and
favoured campsite, and not permitting work elsewhere within the lease or in adjacent claims);
(c) require winter operations only (e.g Dec, 21- March 31) and require access across the frozen
lake (to avoid creating new trails/roads or exacerbating past damage and erosion on trails and
creek crossings); (d) require that damage and material from past or current exploration activities
be cleaned up.
• Clarity is needed on the status and viability of Flag Resources.
• Consultation is required with Wahnapite First Nation. Communication is also expected with the
Wolf Lake Coalition.
• MNRF should be included in setting, monitoring and enforcing conditions, especially related to
trails. E.g. The proposed water crossing is within the regulated Chiniguchi Waterway Provincial
Park."