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A letter to Premier Dalton McGuinty

From Kate Maddigan

Dear Mr. McGuinty,

Re: Uranium mining, the free entry system, and Declaration Order MNDM-3/3

I sent a letter to you dated November 6, 2007, in which I expressed concerns over uranium mining near Sharbot Lake, Ontario, and my support for a moratorium on uranium exploration and mining. I’m happy to report that as a result, there has been correspondence between myself and the ministers of MNR and MOE who were cc’d on that original letter. I was very pleased with their kind responses and explanations of their role in this matter.

I must say however that in all the correspondence with these ministers, there remains some outstanding questions that have not been answered. Their letters did not address my concerns with respect to a moratorium on uranium exploration and mining, or the question of the free entry system. For your convenience, I have included the questions I posed from my January 23, 2008 letter to John Gerretsen, Minister for the Environment contained in two passages below, in italics:

…given there is little reason why uranium mining should continue in Ontario, and especially given that this activity is in apparent direct conflict with the [Ministry of Environment’s] own vision of a “clean and safe air, land and water that contributes to healthy communities, ecological protection and sustainable development for present and future generations,” will the Ministry of Environment and the Government of Ontario support a total moratorium on uranium exploration and mining in Ontario immediately?

And the following:

Ontario’s Mining Act and the system of free entry allow miners privileges and rights to enter, occupy and use private lands in search of subsurface minerals, in some parts of Ontario. The activities often involve tree cutting, dredging, trenching, and road building on the property, wrecking the surface lands, quite understandably against landowners’ wishes. Aside from the actual problems with uranium mining itself, it is this system of free entry that is causing many of the problems with uranium mining in Ontario today. I am sure that this government - and any reasonable person - would agree that this archaic system should be written out of the Ontario Mining Act. Will your government amend the Ontario Mining Act to no longer allow a free entry system?

I would like to know the position of the premier with respect to these two questions in italics above, please.

I would also like to state that the public have very legitimate concerns over this matter, and the responses I received not only did not answer my questions, but they seemed designed to confuse the reader, rather than assist in understanding how the government is taking responsibility for uranium mining and the free entry system. The responses included a litany of responsibilities of this and that ministry, and of various legislation, regulations, and guidelines, all of which are not protecting Ontario communities from the ills of uranium exploration and mining and the free entry system, as I provided examples for in my previous letter.

Your ministries have made lofty commitments to sustainable development in their letters; however I have seen little evidence that these are nothing more than empty statements. All I have seen are “business plans” for these ministries which do not appear to be based on sustainability principles, and do not make reference to earths ecological limits. If I were to believe that Ontario were serious about sustainability, these ministries would have strategies for sustainable development, and Ontario would have overall strategy linking these ministries. Without an overarching, “big picture” strategy to guide the prioritization and implementation of the ministries’ “business plans” such as they are, and without a comprehensive set of goals, measurable targets, timelines, or coherent plan for actually achieving sustainable development in Ontario as a whole, these plans are doomed to failure with their piecemeal, hodgepodge approach. This makes Ontario a laggard when it comes to sustainable development, and uranium mining will continue without any examination of how it may or may not contribute to the sustainability of this province.

I’m sure that it was not the intent of you or your ministers to attempt to confuse me in their letters; however it was because several ministries are involved in managing uranium exploration and mining that I addressed my original letter to you, the premier. Surely the premier must have an idea of what the overall direction of the Ontario government is in this matter of uranium mining and the free entry system, and can provide an integrated response that is cohesive, rather than piece-meal, ad hoc, and scattered?

Further, the Ontario government’s “Declaration Order MNDM-3/3,” which exempts the granting (or renewal) of mining claims and licences on Crown land from the environmental assessment (EA) process, ensures that many mines will not undergo an EA. Considering this, I hardly think it proper that the Ministry of the Environment refer to the Ontario EA Act at all, as they did in their letter to me. I agree with author Andrew Nikiforuk that EAs have become “a cynical, irrational, and highly discretionary process in Canada…a labyrinth of political intrigue, bureaucratic vagueness and legal wrangling that neither saves money nor guarantees prudent resource use,” and this Declaration proves it.

There are serious and long-lasting consequences for Ontario with the social and environmental impacts of uranium mining at all stages – prospecting, exploration, development, operations, and closure. All mining activity should be subject to individual environmental assessments. It’s absolutely unacceptable that there has been an extension to the Declaration Order MNDM-3/3 without proper public consultation and a posting to the EBR Registry.

When will there be public consultation and a posting to the EBR Registry concerning the extensions of the Declaration Order MNDM-3/3?

Thank you very much in advance for your timely response to this letter.

Sincerely,

Kate Maddigan


c. Donna Dillman

Mining Watch Canada

Michael Gravelle
Minister of Northern Development and Mines

Donna Cansfield
Minister of Natural Resources

Margarett Best
Minister of Health Promotion

John Gerretsen
Minister for the Environment

Randy Hillier, MPP
Lanark--Frontenac--Lennox and Addington