Environmental Registry…

Environmental Registry Response by Sault and District Prospectors Association

“A proposal for amendments to Ontario Regulation 308/12 Exploration Plans and Exploration Permits, and amendments to the “Provincial Standards for Early Exploration.”

Provincial Standards for Early Exploration

1. Clarification of language in the Provincial Standards and standardization of terminology with other legislation:

• “contained”

• “water body”

2. Enhancing environmental standards to which early exploration activities are held including:

• Establishment of standard buffers around water bodies (30m)

• Addition of drilling fluid standards similar to other jurisdictions

3. Requiring mobilization and demobilization notices pre-post execution of early exploration work

Response:

1. MNDM should proceed with caution on the definitions proposed for Provincial Standards as there are definitions in other legislation. There have been expressions of concern by the mineral exploration industry that MNDM may be over regulating.

2. The mineral exploration industry has significant concerns regarding the 30 metre buffer around water bodies. Restriction within a 30 meter buffer would limit basic exploration such as stream sediment and water geochemistry sampling, geological mapping and prospecting.

There is significant concern that a 30 metre buffer in certain areas of the Province would eliminate access to mineral exploration on many islands in areas with high mineral potential. The question was raised as to why there would be concern for a 30 metre buffer for prescribed activities when there is the ability to drill 100 metres on to a lake.

Mineral exploration industry has suggested that the provincial standards be specific regarding certain prescribed activities such as “no mechanized stripping of a certain amount within 30 metres”. Or if you are doing this type of activity “these measures must be put in place and upon completion of the prescribed activity”.

There is concern regarding the drilling fluid standards; would they be similar to standards in other jurisdictions?

3. The mineral exploration industry has great concern regarding the mobilization and demobilization notices. The requirement for notices should be on a case by case basis and applied specifically to higher impact prescribed activities.

There is concern regarding who will be responsible to notify the communities or surface rights owners. One recommendation is to have an online, simple solution through the MNDM web site, or email notification to MNDM. The MNDM would then be responsible to notify communities and surface rights owners.

There is concern that a mobilization/demobilization notification system is another layer of permitting, which could be resolved by adding terms and conditions to a Permit.

There is concern that this will be an extra burden for Prospectors in areas with good infrastructure where exploration activities may take place throughout the year, and the proponent has multiple projects. Notification should not be required every time a property is accessed. It is also difficult to determine exactly when a prospector will begin and end exploration, as it may be year-round.

Notification of mobilization and demobilization would be more applicable to remote access locations where a remote camp is required.

[Original Comment ID: 194577]