The idea of moving to a…

The idea of moving to a Qualified Person (QP) for Mine Closure is a good idea. However, your requirements for the definition for a QP needs to be to a higher standard. The naming of QP is used in many situations (NI 43-101, PGO for environmental geoscientist and Engineers of Record for tailings dam). These QP in these examples require a minimum of 5 years to as much as 10 years recommended experience in the subject matter. So the minimum QP requirement should be registered in the PEO or PGO and 5 years experience in the subject matter they are responsible for. A similar approach should be providing a QP certificate outlining the practitioner's experience as part of the submission of the closure plans. I am a QP for NI 43-101 related work and have over 25+ years of mine closure experience in Ontario and have seen too many examples in the past of poor quality work. Anther question should the QP be independent of the issuer (mining company). We want Closure Plans that are reasonable and can be achieved however if the government will not have the resources to review closure plans as before then the QP is a key role to ensure industry standards and meeting provincial (and where appropriate federal regulations/guidelines)