This proposal is presented…

This proposal is presented as having been formulated based on feedback received from industry, but without feedback from Aboriginal groups (the duty to consult) or environmental organizations. All three are important to creating a fair, equitable, and responsible plan moving forward.

Please explain the purpose of replacing the requirement to “improve” the land with a requirement that the condition of the land be “comparable to or better than” it was before the recovery activity?

The proposal gives extraordinary rights to the Minister, giving him/her the former decision-making authorities of the Director of Mine Rehabilitation, and providing him/her with authority to exercise any power or function of the Director of Exploration. What then, is the purpose of retaining the statutory role of the Director of Exploration if his/her powers can be overridden?

Without the statutory role of the Director of Rehabilitation, what kind of alternate rehabilitation measures and post-closure land uses will the Minister be permitted to allow industry? Are these measures outlined in detail in the proposed legislation? Can the Minister make these decisions without upholding the duty to consult Aboriginal treaty signees, or to override environmental legislation?

I am opposed to any measures that invest so many powers in one person. While more time-consuming, vetting issues with all stakeholders is the responsible and democratic way to proceed.