From:		Justin Himmelright
Sent:		08/11/2007 5:35:26 PM
To:		Tawanis Testart
CC:		
BCC:		
Subject:	Comments to draft workplan

Hi Tawanis,

See below the Selwyn comments to the draft workplan.

Regards,

Justin Himmelright

Pg.2 2nd para. Revise to read

Selwyn proposes a mineral exploration project with with up to 100 drill sites and 10 km of new trails in the NWT near the Yukon border. This work is planned to be carried out over a 5 year time period from the date of issuance of a Land Use Permit.  The company has substantial interests in the Yukon, running a mineral exploration project there.  The project in the Yukon includes 2 camps, each with 50 person capacity.  Each camp is serviced by an airstrip and there is an access road connecting the two camps.    These operations were subject to Environmental Assessment and fully permitted in accordance with relevant Yukon legislation and regulations.  This includes permits related to waste management from the works.  The infrastructure already permitted and developed in the Yukon will be used to support extending the drilling program to areas of interest in the NWT. 

 

Pg 3, 2nd para.

Comment: Company prefers that once this process and timeline has been established that little or no variance be implemented unless a clear need is demonstrated.   All parties involved should have the benefit of certainty in the process.  Mid-process changes can create difficulties for process participants.  If changes to the process are deemed necessary, Selwyn requests that any decision to revise the process be made in consultation with the parties.  Adequate notice and supporting reasoning for the change are required in order for us all to prepare and plan accordingly.  

Pg 3, bullet 2

Re “Clearing of timber…” – The terrain of the area is alpine and sub-alpine. Clearing of timber is not likely to be a significant factor.

P3, bullet 3

Change to read:  

Transportation to sites from camps, by helicopters quads, and CATs, of personnel and equipment

Pg 4. Comments on Scope of Assessment 

The Company notes that many of the points given in this section are expressed as conclusions of the scoping session and requests that greater clarification be provided that identifies these statements as issues raised by community members and not the conclusions of the MVEIRB.  Also, some statements are general in nature and more specifics on the exact nature of the concern would be appreciated.

Bullet 2, Socioeconomics:  “there is a lack of meaningful between local communities and the developer.”  The Company notes that the Sahtu Land and Water Board staff accepted the Land Use Permit application, including information on community consultation, as complete.

Bullet 2, Socioeconomics. “the exploration activities occur within Sahtu lands but supply and manpower needs are drawn wholly from the Yukon”

Selwyn’s current supplies and manpower needs are drawn largely from the Yukon but that is because all of our permits and activity are occurring in the Yukon.  If we have permits to do work in the NWT it opens up the opportunity for us to start drawing people and resources from the NWT.  We fully intend to involve Sahtu workers and contractors in this work once it is permitted.

Bullet 4, Establishment of Park

“The primary reason for the referral of this project was the interest by Parks Canada in creating a park in this area. This interest is supported by the local people, who are concerned that development in the area may threaten the development of the region as a National Park. There is concern that development may compromise the ecological integrity of the area. This conflict over land use is a major issue in this EA.”

The primary reason for referral is not the interests of Parks Canada but rather the interests of the Tulita District Land Corporation.  It is the TDLC though the SSI that referred this project to EA, not Parks Canada.  As the Company understands it, the TDLC has taken this step out of concerns regarding consultation and because it requires more information about our proposed exploration activity since they are currently considering the desires of Parks Canada to convert the area to National Park status.

There is not a conflict over land use at this time; rather there is a potential conflict between possible future land use designations and the long standing mineral tenure that exists in the area.

Comments on Timeline

Considering that additional time is required for permits to be issued following completion of the EA, Selwyn notes that this timeline will result in permits being issued no earlier than late October 2008. This will very likely preclude any work being done in the NWT until 2009 since mineral exploration is a seasonal summer activity. 

Selwyn notes that he permitting for all the infrastructure development and exploration work currently under way on the Yukon side of the border took less than 30 days to complete.  It is quite a contrast when an application to carry out what is a very minor scale of work in comparison takes more than a year.  Management experience in Nunavut suggests that 6 months is adequate to receive the 3 permits that are required to complete projects of a similar scale in that jurisdiction.  

The long timeline limits the Company’s ability to address socio-economic concerns; no NWT permits means little opportunity for jobs for NWT residents and few opportunities for NWT contractors.  

Selwyn encourages the MVEIRB to review the scale and scope of this EA and make revisions necessary to bring it in line with surrounding jurisdictions.    Having permits in place to initiate exploration work in 2008 will allow the company to more actively engage employees and contractors from the region and for socio-economic benefits to flow to the region in the 2008 exploration season.  The Company will be doing its best to address all of its responsibilities in the process in as quick a timeline as possible.

 

 

 

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