Comment
The mapping on this application is far better than previous submissions from Flag Resources. It is clear where the activities will occur, and where they abut protected areas.
However, missing from the map is an indication of how the sites will be accessed. Whether it be by new road construction or new trial construction, this needs to be presented to the public before the application proceeds.
As you know, Wolf Lake is a very heavily used recreational lake, as well as a globally significant ecological area. While we hope the drill sites will be small, getting there is likely to create significant damage to the land due to the thin soils, rutting, and removal of vegetation.
There are only three options for accessing the two proposed working sites on the east shore of Wolf Lake.
1) Winter access by crossing the lake.
2) Use of the road built by Inventus in 2018 that comes from the east to a small lake, southeast of the proposal.
3) Building a new road from the north.
The proponent has repeatedly rejected the idea of water crossings, which leaves only the possibility of creating new roads and trails.
As you can easily see on the attached map, the very steep topography will prohibit trails from being created without extreme measures. Any new road construction or new trial construction needs to be presented to the public before the application proceeds, along with a restoration plan.
The two work sites near Jess Lake were previously accessed by a trail that crosses the Chiniguchi River (not shown on the map), and by winter crossing of the lake. How will they be accessed now?
1) Winter access by crossing the lake and using one or more of the four existing trails on the south shore of Wolf Lake that were previously used by Flag Resources
2) Use of the road built by Inventus in 2018 that comes from the east to a small lake, southeast of the proposal.
3) Building an entirely new road.
The proponent has repeatedly rejected the idea of water crossings, which leaves only the possibility of creating new roads and trails. So how will these sites be accessed? Whether it be by new road construction or new trial construction, this needs to be presented to the public before the application proceeds.
Due to the rough topography of the existing trail, rutting and runoff occurred in several places, especially around Jess Lake. How will this be mitigated with new disturbance?
Concerns about motorized access:
1) Already there is a major travel route bisecting the Old Growth Forest.
2) In the mid-1990s Flag was given a work permit to create a trail on the west side of the lake. Conditions for this trail were not met. Major erosion occurred, continued access by ATVs increase the damage to the land every year. We do not want to see this repeated!
3) Flag Recourses also created a drill trail to access Jess Lake to allow year round access to the site.
4) Previous to that, Flag created four separate trails from the south shore of Wolf Lake to access Jess Lake and Cobalt Hill.
The company needs to reconsider the traditional exploration access to the proposed sites, as further fragmentation due to roads and trails cannot be justified.
Flag resources historic workings in the Jess Lake area left heavy cables, barrels, oily debris, uncapped drill holes with flowing water, and other drilling detritus on site. Will the new work undertake to remove and restore these areas? This application is proceeding under the guise of Flag Resources; therefore it is reasonable to require restoration of damage previously committed.
Line cutting usually has minimal long term impact on the social and ecological values, especially if it is conducted in winter. Given the nature of the ecological sensitivities of the area, it is important to not cut any trees greater than 10 cm diameter. Due to harsh growing conditions in some areas, these small trees can be very old.
In summary, while the footprint of drilling operations can be small, the unintended fallout from creating new roads and trails is large. Given the uncertainty of where the drilling will occur, and how they will get there, this application should be withdrawn until these things are known.
It was very good to see the Ministry’s information sheets that describe the proposed activities to help those of us who are not prospectors to understand the terminology and requirements. Given the sensitivity of the Wolf Lake area, it will come as no surprise that many people will be watching once operations begin.
Supporting documents
Submitted September 9, 2020 7:03 PM
Comment on
Mark Hall - Mineral exploration permit
ERO number
019-2230
Comment ID
48372
Commenting on behalf of
Comment status