As referred to in the…

As referred to in the submission by Friends of Temagami, Earthroots, Northwatch, Sudbury Naturalists Club, Coalition for a Liveable Sudbury, and Members of the Wolf Lake Coalition Steering Committee, these proposed sites all contain 300-year old growth pines, which provide a critical ecosystem that sustains Ontario's dwindling biodiversity. This is not just about damaging legacy canoe routes and campsites, which should be protected, but is much more serious: this area provides crucial habitat and protection for numerous at-risk species of plants and animals. The stakes are very high.

The magazine article referenced below (see pages 32-35) presents facts and research about the critical biodiversity found in the Wolf Lake area that needs immediate protection. The Province of Ontario needs to be held accountable for their commitment to the United Nations target to protect at least 17 percent of terrestrial and inland water areas and 10 percent of coastal and marine areas by 2020.

Flag Resources also has a lousy track record of improper process and reporting, environmental mismanagement, and breaking public trust: the company was delisted by the BC and Alberta stock exchanges for failing to meet public reporting requirements and its co-founding president was banned from being an officer or director of any publicly-traded corporation.

As such, before this application is granted, I urgently request the following due diligence be conducted, as per the letter submitted by Friends of Temagami, Earthroots, Northwatch, Sudbury Naturalists Club, Coalition for a Liveable Sudbury, and Members of the Wolf Lake Coalition Steering Committee:
• The application should be thoroughly reviewed to ensure adequate information has been provided to make a decision. For example, how and when is access proposed for the two new work sites, where there are no existing trails or roads?
• No new work should be permitted until damage and debris from past work by Flag Resources are cleaned up and reclaimed properly. Historic workings in the Jess Lake area left heavy cables, barrels, oily debris, and other drilling detritus on site.
• Flag Resources has a poor record of stewardship during mining exploration at this site and nearby areas. For example, oil spills, rutting of soils (including streambeds) by movement of heavy machinery, and abandoned equipment and refuse have been observed. We are concerned that it is possible this may be repeated and that roads and trails may not conform to what is permitted, that impacted areas may not be properly cleaned and restored, and that activities, including wastewater management, may not be handled properly. We are also not confident that the capacity exists to monitor and enforce conditions, since enforcement has not happened in the past.
• If this application is approved, conditions should be included to minimize damage, including: (a) prohibit removal of trees greater than 10cm dbh (these small trees can be very old due to local growing conditions); (b) specify where work is permitted (excluding the most sensitive areas and favoured campsite, and not permitting work elsewhere within the lease or in adjacent claims); (c) require winter operations only (e.g Dec, 21- March 31) and require access across the frozen lake (to avoid creating new trails/roads or exacerbating past damage and erosion on trails and creek crossings) ; (d) require that damage and material from past or current exploration activities be cleaned up.
• Clarity is needed on the status and viability of Flag Resources.
• Consultation is required with Wahnapite First Nation. Communication is also expected with the Wolf Lake Coalition.