This comment is from the…

This comment is from the Northwestern Ontario Prospectors Association (NWOPA); it is submitted without registration so as not to be ascribed to any member of the Association or its Directors.

The most negative comment received as a result of circulating the request for comment focused on the limit of assessment credit "Where the claim holder’s own labour is claimed for assessment work credits". The policy goes on to state that "the claim holder’s labour costs must not exceed the costs they would have reasonably paid for a contractor to perform the same work to a maximum of $350 per day. The assessment work submission must include receipts that support expenses claimed such as food and lodging, if applicable, and the costs associated with the transportation of persons within Ontario during the same period of time the work was performed."

The costs that most claim holders pay for a contractor to prospect a mining claim is, in our view, significantly greater than $350 per day; we are informed that rates of $550 per day and higher are more representative of such rates in the current environment.

To extend the argument, consider the situation where a contractor undertakes prospecting on the mining claim held by an entity other than themselves, at a rate in excess of the policy limit. The "contractor" then performs the same prospecting work on a contiguous claim which is registered in their name. This same person (or persons) would, under the proposed policy, be entitled to significantly less assessment work credit for their "sweat equity" than for the same work performed under contract. This is neither fair, just nor reasonable.

Also, in our opinion, this policy biases prospecting and exploration in favour of having prospectors work for corporate entities rather than as entrepreneurs. It removes incentive for true, grassroots prospecting. Grassroots prospecting has generated a high proportion, if not a majority, of the exploration targets being pursued today. Encouraging a diminishing of grassroots prospecting is not in the long-term interests of prospectors, the exploration industry nor Ontario's long-term, sustainable supply of critical minerals.

The bias against grassroots prospecting also creates a barrier to members of Indigenous communities who might be trying to enter the prospecting profession. When the then Ministry of Northern Development and Mines delivered a program of teaching the skills of prospecting in Indigenous settlements, it became apparent that prospecting was a skill which was highly compatible with traditional Indigenous activities on the land. It meshed very well with the historic entrepreneurial spirit of a hunter-gatherer society. The proposed policy of limited respect for “sweat equity” would, instead, push Indigenous prospectors into an employee–employer relationship with exploration companies; this is the antithesis of good policy in Indigenous relations and reconciliation.

How to improve the proposed policy's deplorable limitation on self-starters in prospecting? — Introduce a mechanism that recognizes a more realistic and reasonable value for assessment work credits available to the entrepreneurial prospector. We suggest a process whereby the Minister annually survey, from assessment work reports, the rates that are paid to prospectors under contract to third parties. The weighted average of such real costs should be published and form the rate at which "the claim holder’s own labour is claimed for assessment work credits". This rate should be in place for one year from the fixed, annual publication date of the average from the survey data. Alternatively, the rate should increase by a percentage amount equal to the cost-of-living increase calculated for a number of Ontario programs such as civil service pensions where this amount is greater than the average from the survey data.