Comment
Professionals using signature and seal for reports at the Prefeasibility and Feasibility study level are expected to work at the same level of professional expertise as those preparing the various components of Closure Plans.
NI 43-101 is one of three formal documents CSA provides to the public, along with Form 43-101F1 Technical Report (the Form) and Companion Policy 43-101CP Standards of Disclosure for Mineral Projects (CP). These documents all carry weight and together define a Qualified Person responsible for the preparation of a Technical Report and other public technical disclosure.
The definition of experience of a QP should be built on a 5 year period of work experience acquired after receiving professional registration.
PGO recommends that the Ministry of Mines apply a definition for Qualified Persons in Bill 71 regulations that is equivalent in professional standing and experience to the definitions used by other provincial regulators in Ontario (e.g. OSC and MECP O. Reg. 153/04), and that such definition include the requirement of QPs be licensed practitioners in good standing with Professional Geoscientists Ontario and Professional Engineers Ontario.
The requirements for approving closure plans should be proportional to the scope of the project. For example, closure requirements related to exploration activities (e.g. surface stripping on mining lands should not be the same as those required for a mining operation.
Supporting documents
Submitted April 23, 2023 9:40 PM
Comment on
Proposed regulatory changes to closure plan rehabilitation requirements for advanced exploration and mine production and adding an additional class of facilities to the list of such classes that are excluded from the definition of “mine”.
ERO number
019-6750
Comment ID
84069
Commenting on behalf of
Comment status