Revised Final Environmental Study Report (24 MB) - Gold Canyon ...

Revised Final Environmental Study Report (24 MB) - Gold Canyon ... Revised Final Environmental Study Report (24 MB) - Gold Canyon ...

goldcanyon.ca
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06.05.2015 Views

Gold Canyon Resources Inc: Final Environmental Study Report Review March 30, 2013 Domtar 2014-2019 Forest Management map, shows that Domtar is not anticipating to harvest in the greater eastern corridor region, during 2014-2019 period. So far it is not clear to what extent Domtar will use the eastern corridor. GCU is currently seeking a 3 year exploration permit for Springpole. If continued Springpole exploration unsuccessful, the permit will terminate Springpole activity in 2016. Therefore making the assumption that GCU and Domtar will use the road during the same period is premature. Furthermore, in the event that GCU and Domtar use the eastern corridor simultaneously, another environmental assessment will have to be conducted to evaluate the cumulative impacts of dual corridor use. Recommendation: GCU be transparent with Stakeholders, First Nation community, OMNR and the public regarding the full extent of their synergistic relationship with Domtar, and identify the following; When synergistic eastern corridor use will take place down to the year; How much financial or administrative assistance Domtar is providing to GCU for eastern corridor development; Outline the road closure and rehabilitation plan in the event share use of the eastern corridor. Recommendation: GCU needs to provide detailed maps showing the 2014-2019 GCU eastern corridor and Domtar harvesting plans, identifying exact locations of where Domtar activities will take place in reference to the eastern corridor. Recommendation: GCU will need to complete a cumulative impacts assessment for the eastern corridor if both GCU and Domtar intend to use the corridor over the same period; 2014-2019. 5.11 Corridor Rehabilitation When any land is subject to industrial exploitation, leading to environmental degradation, an environmental rehabilitation plan (ERP) is required of the proponent to ensure accountability. The ERP must employ strategies to restore the environment to its original state; structure, properties, topography, texture, etc. Instances where the environmental damage is anticipated to be significant, the proponent is required to set-aside a reclamation bond” with the OMNR, to cover costs associated with project decommissioning and rehabilitation. The eastern corridor intends to destroy 645 km 2 of old growth boreal forest, crossing through known woodland caribou habitat. Despite the rather large project area, the ESR makes no direct reference to having a rehabilitation strategy or plan in place, and instead puts the responsibility onto First Nations, Domtar, Stakeholders and OMNR. 38

Gold Canyon Resources Inc: Final Environmental Study Report Review March 30, 2013 “This rehabilitation that GCU is prepared to undertake is pending input from other parties that include, but are not limited to, Cat Lake First Nation, Domtar and MNR. It is understood that some of these parties may potentially have an interest in having some or all of the road and water crossings remaining in place. This modified use of the eastern corridor would be subject to a new environmental assessment and approvals process (ESR page 49).” GCU further avoids addressing the issue of eastern corridor rehabilitation directly, by stating that: “In the event that the Springpole Gold Project becomes fully permitted and proceeds to a production phase, the rehabilitation of the access corridor would be within the scope of the Closure Plan that is filed pursuant to Part VII of the Mining Act and MNDM’s requirements regarding the financial assurance provision for the entire development (ESR page 49).” Review of Part VII of the Ontario Mining Act provides no specific recommendations for corridor rehabilitation. Given that GCU seeks to implement a road through 645 km 2 of valued forest, Stakeholders are requesting the GCU be required to place a “Reclamation Bond” for 100% of the rehabilitation costs with the OMNR. GCU must also disclose the total amount required for rehabilitation of 645 km 2 of land to Stakeholders, First Nation communities, etc. Note: According to the Springpole Preliminary Economic Assessment, roughly $20 million is planned to be set aside for Springpole mine closure and rehabilitation: No indication of how much reserved for eastern corridor rehabilitation. To date, GCU has not indicated how much it will cost to put in a seasonal road, nor the amount required to rehabilitation 645 km 2 of land. This raises serious questions of whether GCU understands how much it will cost to rehabilitate the eastern corridor, timelines associated with rehabilitation and if they even have the financial capital sufficient for the undertaking. If the eastern corridor is constructed, and GCU lacks the capital to initiate rehabilitation, tax payers will end up covering the cost! Recommendation: The OMNR require that GCU secure a reclamation bond for 100% of the costs associated with rehabilitation of the eastern corridor. Recommendation: The OMNR and GCU will disclose to Stakeholders, First Nation communities and the public the amount required to rehabilitate 645 km 2 of old growth boreal forest and woodland caribou habitat. Recommendation: GCU develop a road closure and rehabilitation plan for the eastern corridor in conjunction with Stakeholders, First Nation communities and the public, which is to be developed prior to approval of the project. 39

<strong>Gold</strong> <strong>Canyon</strong> Resources Inc: <strong>Final</strong> <strong>Environmental</strong> <strong>Study</strong> <strong>Report</strong> Review<br />

March 30, 2013<br />

Domtar 2014-2019 Forest Management map, shows that Domtar is not anticipating to<br />

harvest in the greater eastern corridor region, during 2014-2019 period. So far it is not<br />

clear to what extent Domtar will use the eastern corridor.<br />

GCU is currently seeking a 3 year exploration permit for Springpole. If continued<br />

Springpole exploration unsuccessful, the permit will terminate Springpole activity in 2016.<br />

Therefore making the assumption that GCU and Domtar will use the road during the same<br />

period is premature.<br />

Furthermore, in the event that GCU and Domtar use the eastern corridor simultaneously,<br />

another environmental assessment will have to be conducted to evaluate the cumulative<br />

impacts of dual corridor use.<br />

Recommendation: GCU be transparent with Stakeholders, First Nation community, OMNR<br />

and the public regarding the full extent of their synergistic relationship with Domtar, and<br />

identify the following;<br />

When synergistic eastern corridor use will take place down to the year;<br />

How much financial or administrative assistance Domtar is providing to GCU for<br />

eastern corridor development;<br />

Outline the road closure and rehabilitation plan in the event share use of the eastern<br />

corridor.<br />

Recommendation: GCU needs to provide detailed maps showing the 2014-2019 GCU<br />

eastern corridor and Domtar harvesting plans, identifying exact locations of where Domtar<br />

activities will take place in reference to the eastern corridor.<br />

Recommendation: GCU will need to complete a cumulative impacts assessment for the<br />

eastern corridor if both GCU and Domtar intend to use the corridor over the same period;<br />

2014-2019.<br />

5.11 Corridor Rehabilitation<br />

When any land is subject to industrial exploitation, leading to environmental degradation,<br />

an environmental rehabilitation plan (ERP) is required of the proponent to ensure<br />

accountability. The ERP must employ strategies to restore the environment to its original<br />

state; structure, properties, topography, texture, etc. Instances where the environmental<br />

damage is anticipated to be significant, the proponent is required to set-aside a reclamation<br />

bond” with the OMNR, to cover costs associated with project decommissioning and<br />

rehabilitation.<br />

The eastern corridor intends to destroy 645 km 2 of old growth boreal forest, crossing<br />

through known woodland caribou habitat. Despite the rather large project area, the ESR<br />

makes no direct reference to having a rehabilitation strategy or plan in place, and<br />

instead puts the responsibility onto First Nations, Domtar, Stakeholders and OMNR.<br />

38

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