Notice of Material Changes…

Notice of Material Changes are submitted to ensure the crown performs their duty to consult with First Nations, this is a constitutional obligation. Proposed activities and proposed changes need to be assessed by the Crown not by the mining companies to ensure the crown duty to consult is not triggered. There is no definition of minor site alterations, this will leave too much interpretation and lead to violations of the Crowns constitutional obligations. This is not reconciliation.

Will the government be reviewing the certifications? Will the government be reporting people who claim to be qualified persons but are not to their respective associations? Removing Ministry technical review seems like a step backward. Public servants (technical reviewers) have no conflict of interest and ensure that closure plans meet the legislation. Qualified persons will be paid by the mining company, which is a conflict of interest, especially if there is no government review of the certifications provided and no compliance tools to punish individuals or companies that are not truthful.

Is it appropriate for the Minister (politician)to be making decisions on whether a mine or drilling program should take place? Are mining companies and exploration companies contributing to the Minister’s campaign? It seems like a direct conflict of interest. When a politician is advocating for industry and at the same time has taken over the role of a regulator and public servant when he empowers himself as the decision maker removing the Director from that role and assigning it to himself. How would the Minister comply with ONTARIO REGULATION 381/07? Is it even possible when the checks and balance that comes with a non-elected senior public servant being a regulatory decision maker is eliminated and both the political and public servant role is played by the same person?