April 11, 2023 The wording…

Numéro du REO

019-6715

Identifiant (ID) du commentaire

83751

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire

April 11, 2023

The wording of the amendments is troublesome.

For example:

"establishing the concept of qualified persons in the Mining Act"....I would like to see this government name an environmentalist and third party expert in the mining field to be the "qualified persons".
Without a an expert who is not connected with the mining companies and/or government, the environment is left open to abuses.

"Allow the Minister to issue an order, on request from a proponent, that allows the deferral of at least one of the required elements of the closure plan".... this act has, with these words, has watered down the closure requirements of the mining company thus increasing the risk of a poorly closed mine. This act is allowing companies to start mining without a finished closure plan. Again the environment is left open to abuses.

"Eliminate the need for a Notice of Material Change for minor site alterations"....who defines "minor alteration"? Is there an environmentalist or third party expert involved here?

"Amend the definition of “rehabilitate” and the related definition of “protective measures” to support the Minister’s ability to allow an alternate use or condition or feature to remain on-site post-closure (e.g. infrastructure), and to give greater flexibility and certainty to industry by allowing alternate rehabilitation measures and post-closure land uses"....this last paragraph seems to reassure companies that their closure plans don't have to amount to much since they are given flexibility in their closure plans. again the environment is open to abusive behavior.

In closing, I would guess the vast majority of people would want a healthy environment within which to live, raise their families and grow their food. Short term gains with poor plans results in long term pains. There's always one chance to do it right.