EBR 012-8179…

EBR 012-8179

I have been the representative of the Federation of Ontario Cottagers Associations (FOCA) on the Minister’s Mining Act Advisory Committee (MMAAC)since 2008. I was a member of the sub-committee that developed the original recommendations for the regulations governing exploration plans and permits. I am responding as a private citizen and I anticipate that FOCA will also file a response to this posting. Proposed Regulation Changes When the regulations were implemented 2012 there was a major omission at the last stage before approval in that there was no provision for the Ministry (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. The proposed regulation change to Section 18 of Regulation 308/12 finally proposes to implement the broadened discretion which has been requested by all ENGO members of MMAAC and supported by all MMAAC members on several occasions since it was omitted in 2012. I support this proposed change in the strongest possible terms. I would hope that the final wording will make clear the discretion will apply when issues are raised by the public or by public interest groups or when major environmental concerns are identified. As well I also support the implementation of all of the other proposed regulation changes on the posting. Proposed Changes to Provincial Standards I also support the proposed changes to the provincial standards and in particular point #3 concerning pre and post mobilization notices. Although I believe that the proposal is intended to address concerns from First Nations it must be expanded 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. I believe that individual property owners have a right to full information and notification of exploration work on a similar basis as First Nations are provided that information. 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. Thanks you for the opportunity to respond to these proposals.

[Original Comment ID: 195015]