January 14, 2020 Submitted…

January 14, 2020

Submitted comments re:
Inventus Mining Corporation- Mineral exploration permits
Instrument type: Mineral exploration permit
ERO numbers 019-1049, 019-1050
Ministry reference numbers PR-19-000329, PR-19-000331

Submitted to:
Dave Bell
Mineral Development Office (Sudbury)
dave.bell@ontario.ca, and via the ERO on-line comment forms.

Submitted by:
Friends of Temagami, Sudbury Naturalists Club, Coalition for a Liveable Sudbury
- Members of the Wolf Lake Coalition Steering Committee

Comments
These two applications occur in sensitive areas. Exact locations are difficult to discern from the maps provided. However, it is clear that these areas border Chiniguchi Waterway Provincial Park, and impact an Enhanced Management Area between Doon and Matagamasi Lake (Crown Land Use Policy Atlas). Old growth red pine trees are present.

We are concerned about the impact of the proposed activities, which are extensive and include the use of heavy equipment such as bulldozers and skidders, line cutting, mechanized stripping, over twenty drill pads (drill casings left in place), and new trails and roads. The line cutting and stripping is especially extensive in PR-19-000329, with 5km of line cutting, and 10 stripped locations with 10,000 square metres of stripped area proposed. New roads are also proposed for this location.

Expected impacts include:
- Damage to the land
- Loss of old growth trees
- Disruption of the forest ecosystem through line cutting, stripping and new roads. Roads fragment forests. The loss of intact forest habitat is very detrimental to many forest species. These activities also contribute to erosion and impacts on water quality.
- Impact on canoe routes and portages
- Impact on Chiniguchi Waterway Provincial Park and protected areas

As submitted, the extent of these activities is too damaging to these sensitive areas. If permission for exploration is granted, more information is needed on how impacts will be mitigated and monitored. More information is also required on the requirements of the Crown Land Use Policy and how it will be respected. Greater clarity in mapping is needed showing in detail the claim boundaries, and other land use direction in these areas and adjacent areas (including park and forest reserve boundaries). As presented, it would appear that some of the line clearing and perhaps other proposed activities will trespass into the protected areas. Even if this is not the case, proximity of these activities to protected areas is of concern, because the health of these protected areas will be impacted.

These add to our concerns to impacts on Wolf Lake old growth forest from new permissions for mining exploration (PR-19-000237). Wolf Lake is the oldest known old growth red pine forest, the missing link in the Chiniguchi Waterway Provincial Park, and, as intended for Forest Reserves, will be brought into the parks system as existing mining leases and claims laps. Cumulative impacts of mining exploration on adjacent lands should not be permitted to degrade the health of this unique ecosystem, or of other protected areas.

Thank you for this opportunity to comment, and to continue the conversation throughout the process.