Conditional Filing Order –…

Conditional Filing Order – how is the Minister qualified (surface water expert, groundwater expert, geochemical scientist, engineer) to determine if a certain element of the closure plan will not have an effect of the environment and/or safety? Will the Minister be held to account if he allowed a company to move forward without meeting the legislative requirements and an environmental disaster or health and safety issues occurs. What kind of compliance tools will be used to ensure the terms and conditions of these “conditional filing order” are followed?

The proposal to allow infrastructure to remain is already accounted for in the Closure Plan process, as long as mining companies provide money for the eventual removal of the infrastructure, they aren’t forced to remove the infrastructure and they can remain in the status of inactivity forever and the crown is protected as they hold the money to remove the infrastructure if ever the company goes bankrupt. If mining companies no longer have to provide money for removal, then it will be the public that picks up the rehabilitation bill at the end when a company goes bankrupts and government let them leave infrastructure on sites with no money for clean-up.

Will the government be reviewing the certifications? Will the government be reporting people who claim to be qualified persons but are not to their respective associations? Removing Ministry technical review seems like a step backward. Public servants (technical reviewers) have no conflict of interest and ensure that closure plans meet the legislation. Qualified persons will be paid by the mining company, which is a conflict of interest, especially if there is no government review of the certifications provided and no compliance tools to punish individuals or companies that are not truthful.

Is it appropriate for the Minister (politician)to be making decisions on whether a mine or drilling program should take place? Are mining companies and exploration companies contributing to the Minister’s campaign? It seems like a direct conflict of interest. When a politician is advocating for industry and at the same time has taken over the role of a regulator and public servant when he empowers himself as the decision maker removing the Director from that role and assigning it to himself. How would the Minister comply with ONTARIO REGULATION 381/07? Is it even possible when the checks and balance that comes with a non-elected senior public servant being a regulatory decision maker is eliminated and both the political and public servant role is played by the same person?