Submitted comments re: Flag…

Submitted comments re:
Flag Resources (1985) Limited- Mineral exploration permit
Instrument type: Mineral exploration permit
ERO number 019-0593
Ministry reference number PR-19-000237

Submitted by:
Friends of Temagami, Earthroots, Northwatch, Sudbury Naturalists Club, Coalition for a Liveable Sudbury
- Members of the Wolf Lake Coalition Steering Committee

Comments
Twenty years ago, the provincial government made a commitment to protect Wolf Lake old growth forest. In 1999, the province committed to bring Wolf Lake into the Chiniguchi Waterway Provincial Park as existing mining leases and claims lapsed. On March 13th 2012, the Minister of Natural Resources announced that the Forest Reserve status would remain for Wolf Lake, and that the land would be protected once the claims and leases lapsed. If this commitment had been met, Wolf Lake would now be a protected and properly managed park. However, Mining leases were extended to 2033 later in 2012 in the heart of the old growth area and Wolf Lake itself. Wolf Lake Coalition supports the inclusion of Wolf Lake old growth forest within the Chiniguchi Waterway Provincial Park. We submit that the best course of action would be to move forward on steps to accomplish this goal, and that this area is not suitable for mining exploration.

However, given the current active mining leases, we submit the following comments regarding Flag Resources’ mineral exploration permit at Wolf Lake. Please note that the 30 day comment period has been insufficient time to gather all the relevant information.

• The application should be thoroughly reviewed to ensure adequate information has been provided to make a decision.
• No new work should be permitted until damage and debris from past work at those sites by Flag Resources are cleaned up and reclaimed properly. A recent site visit confirmed that debris and waste remains.
• 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) specify that work be permitted only at the proposed site, and not elsewhere within the lease or in adjacent claims; (b) require winter operations only (e.g Dec, 21- March 31) and require access across the frozen lake (from the ATV trail at the SW corner of Wolf Lake) which would avoid the old trail, which is steep (severe erosion is a problem on this trail, and conditions were not monitored or fulfilled when this access trail was put it in the 1990’s); (c) require that damage and material from past or current exploration activities be cleaned up.
• Clarity is needed on the status of Flag Resources, who hold the mining lease, and who is applying to undertake this mining exploration activity. The names given on the application are listed as management and directors for Inventus, who have claims in the adjacent area.

Thank you for this opportunity to comment, and to continue the conversation throughout the process.