Hello, This proposal is not…

Hello,

This proposal is not really in plain language... I don't know if I fully understand what is being proposed.
For example, in one paragraph, it says, "Currently, ..., the ministry allows mining claimholders to sell materials extracted for the purposes of testing, and retain proceeds to the extent of eligible cost recovery, without first filing a mine production closure plan." In the next paragraph, it says, "The ministry is proposing to amend the Mining Act to allow lessees, licensees and owners of mining lands to sell and retain the proceeds from materials extracted for the purposes of testing without the requirement for a mine production closure plan being filed." To me, who is not an industry insider, it sounds like you are proposing something that already exists. Maybe the main change is that you're proposing to extend the allowances that exists for claimholders to lessees, licencees, and land owners. If that is the case, why not just say so? Later on, it says, "When materials are being extracted, an advanced exploration closure plan or exploration permit/plan is required. However, small-scale testing activities (sampling) fall under the definition of mine production if the intention is to later sell the tested minerals (which can be done in an effort to offset the costs of the testing).".. this seems to contradict what was said above. Summary: this is a confusing proposal!

Based on type of tenure, claims have the least rights and therefore the least responsibilities on their lands. Therefore, the government is progressively less responsible for licensed, leased, and owned lands. Taking that into account (and ignoring the question of whether the government takes environmental responsibility of mining claim environmental impacts), it is not clear to me that releasing the mining land holders from their responsibilities is the responsible choice for the public good.

This proposal sounds like it's trying to convince me of something.... but it's not entirely sure of the argument it's making.

Finally, what is to stop people from doing a whole lot of testing (more than they would normally do), and coming out on top, then just moving on? If this proposal is suggesting that a closure plan is not necessary for the sale of samples for testing from all forms of mining land, shouldn't there at very least be clear boundaries on the amount of testing that is reasonable before a closure plan is, in fact, necessary due to environmental impacts of testing? Environmental impacts include ecological, economic, social... SOME sort of rehabilitation plan should be required, if not a "mine closure plan", if trees are being taken down, large equipment is brought in, and drilling and blasting are occurring on public lands, effectively removing the use of those lands for other activities. This should be the case ESPECIALLY if mining does not move forward after testing, so that the lands can be rehabilitated sooner and enjoyed for other uses. This proposal is using reverse logic that revolves around benefits to individuals (exploratory mining companies are usually very small entities), instead of the public good, which is the government's actual job.

It is the government's responsibility to ensure that private individuals and companies aiming for eventual profit put in the necessary investment money into the economy and towards government policies that ensure that the public good is accounted for. If that investment money is a rehabilitation plan or a mine closure plan, so be it. I am much less interested in saving/making those people money than I am in making sure that public lands are taken care of responsibly, for everyone and the environment.

Thanks for reading.