October 18, 2017…

October 18, 2017

MNDM
933 Ramsey Lake Rd, Level B6
Sudbury, ON
P3E 6B5

Attention: ROY DENOMME, PROJECT LEAD MNDM MINING ACT MODERNIZATION

Subject: COMMENTS FOR SUBBMISION TO THE GOVERNMENT ENVIRONMENTAL REGISTRY
EBR RIGISTRY NUMBER 013-1387

This letter serves as a submission of comments regarding the Mining Act Modernization roll out and new Regulations under the proposed technical changes to the Mining Act in Bill 39, “the Aggregate Resources and Mining Act Modernization”. These comments are not final, and Goldcorp reserves the right to make additional comments as we consider them, or in response to any reply from MNDM, we may receive. The Comments will be posted on the EBR website, and will be emailed directly to Roy Denomme and MNDM.

Please review the comments enclosed in the table below. Should you wish to discuss these issues and comments, our teams are more than happy to set up a time and date. My email and phone numbers are noted above.

Kind Regards,

Christine Saari
Information, Contracts, Land Manager Canada and USA
Goldcorp Canada Ltd.
130 Adelaide St W, #3201
Toronto, ON M5H 3P5

GOLDCORP CONCERNS AROUND THE ROLL OUT OF MINING ACT MODERNIZATION
MNDMIssueRecommendation
PRE-CONVERSION
MNDM posted new pre-conversion dates on October 5, 2017This leaves little time for industry to react to the changes, considering all budgets and work have been planned around the Nov 1 2017 datesMore time is required to get work done.

Jan 9 2018 Pre-Conversion period beginsOriginally, MNDM proposed Nov 1 2017 as the start of Pre-Conversion period. Industry has prepared budgets, groundwork, permits and claim renewals around this date. Moving the pre conversion date puts at risk of lapsing from November 1, 2017 up to Jan 9, 2018. Provide for an extension of time for the due dates on claims coming due from November 1 up to Jan 9, 2018 to ensure that they do not lapse. All other aspects of the January 9th pre-conversion activities could remain the same so that it coincides with delivery of MLAS and regs

Business stops Jan 9, 2018 for MNDMWork programs and Business in general does not stop for industry
What if acquisitions and dispositions of land assets occur during the pre-conversion process?
MappingWhat Spatial Data will be available to industry during the Pre-Conversion/Staking Hiatus Period?Industry requires access to spatial data for mapping purposes.

CLAIMs informationWill CLAIMS INFORMATION be available for download during Pre-ConversionIndustry requires access to client reports and claim information for audit purposes and work planning.

Conversion guideNo specific date was mentioned in the latest bulletinPlease provide specific date Conversion guide will be available.

Client Training MLASNo specific date or locations were mentioned in the latest bulletinIndustry requires sufficient notice to be able to make travel plans, provide resources for training. (For example, 1 month notice.)

LAUNCH STAGE 1 (Feb 7th to April 9th 2018

CBR - Claim Boundary ReportsIn addition to legacy and boundary claims, will Industry be required to submit Claim Boundary Reports for those ownerships with varying % ownerships?Industry requires the capacity to renew claims where they are contiguous regardless of the percentage of ownership. We can now without complication.

LAUNCH STAGE 2 APRIL 10, 2018
MLAS will only recognize claims held by the same holder(s) if the claim holder and percentages are exactly the same, and if a company owns claims in differing percentages the system will see this as 2 individual holdersGoldcorp owns many properties with varying percentages in most mining divisions in Ontario and comprise a larger area of contiguity. If we are not able to transfer credit from the varying percentage ownerships as we can do so now, then we will be limited to how and what we can renew. What is the solution to this issue? For Example: In the Ball Twp., we have three claims that we recently staked in the name of Goldcorp Inc (87.45%) and Goldcorp Canada Ltd (12.55%). These claims are contiguous to a larger claim package staked in the name of Goldcorp Inc (72%) and Goldcorp Canada Ltd (28%). We can transfer credits to any of these current claims because we have contiguity and meet the current legislative requirements. Will we be able to transfer credit from the 72/28% claims to the 87.45/12.55% claims?Industry requires the capacity to renew claims where they are contiguous regardless of the percentage of ownership. We can now without complication.

Patents not currently in the MNDM Mining Land Tax Registry will not be eligible to file work upon without prior registrationIf a company purchases a Patented piece of land that was not originally issued as mining land that PIN will not be in the Mining Land Tax registry. It can take a very long time to affect transfers of land particularly if surface rights are acquired along with the mining rights due to Planning act consent, and the length of time these processes take. How is a company going to work on the lands to keep them in good standing?Industry requires the ability to perform work on patents during the time it takes for the transaction/transfer/purchase is registered on title so that Industry can renew any contiguous mining cell claims.

Bringing Claim cells to leaseIt can take more than one year to bring a claim to lease, and once the lease is issued by MNDM/MNRF, it can take Land Titles many months to actually register the lease and provide the new PIN number. How is industry supposed to do work on leases during this transition time since the lease would not be registered at MNDM under the Mining Land Tax registry? We would be unable to file any work done until that lease was identified in the MNDM Mining Land Tax registry.Industry requires the ability to perform work on Leases during the time it takes for the issuance by the province, when it is registered on title so that Industry can renew any contiguous mining cell claims.

DATA REQUIREMENTS POST CONVERSIONIndustry requires data as soon as it is available, so that we can update our internal land management systems.

NEED ABILITY TO DOWNLOAD SPATIAL INFORMATION

NEED ABILTIY FOR CLIENTREPORTS, AND CLAIM INFORMATION

WILL THERE BE NEW NUMBERS FOR "G" NUMBERS?

When will data be available to allow clients time to revamp internal land management systems to comply with go live expectations at MNDM?

[Original Comment ID: 211184]