![]() OLL SIX SITES PROPOSED FOR TIMMINS DISTRICT June 28, 2001 Ministry of Natural Resources Highway 101 East Timmins, Ontario P0N 1H0 Attn: Mr. Joel Holder, District Planner Dear Mr. Holder: RE: OLL SIX SITES PROPOSED FOR TIMMINS DISTRICT Thank you for advising the Porcupine Prospectors and Developers Association (“PPDA”) of six sites within the Timmins District which are under boundary refinement consultation as part the OLL Land Use Strategy. The PPDA is a not for profit organization with the objective of representing and furthering the interests of the exploration industry and the individual prospector in the Porcupine District of Northeastern Ontario. We concern ourselves with issues affecting our members and work to maintain a strong exploration industry today, in order to ensure that new mines will be found tomorrow. The six sites proposed by your offices for boundary review are extremely important to our members and the northern communities they live in. Designation of these six sites as either Provincial Parks, additions to Provincial Parks (three areas) or Conservation Reserves (three areas) will negatively impact upon several of our members and the northern communities in which we all live. We note that the Ministry of Natural Resources has through your offices issued a “Fact Sheet” for each of the six proposed Provincial Parks/Additions and Conservation Areas. The assumption would be that the “Fact Sheets” have some practical value. We assume you designed them to avail to those persons interested, a complete synopsis of pertinent and truthful facts. Instead we find that you have blatantly disregarded significant information, omitted important and valuable land titles, dismissed the economic significance of current activities to northern communities, and proposed actions in direct contradiction to the good intentions and efforts of both the current Federal and Provincial governments to assist northern communities. Your Total Disregard for Bedrock Significance: We find it astounding that although the MNR details the type and age of the trees, etc., your “Fact Sheet” does not acknowledge the bedrock that underlies the proposed OLL sites. It is not as if your Ministry did not have free access to geological information through the Resident Geologist Offices of MNDM. It is however, evident the MNR chose to omit that data from their GAP analysis. One of the six sites proposed for the Timmins District is designed to “preserve” a surface geological feature at the proposed MacMurchy Township End Moraine Provincial Park (Nature Reserve Class). An “end moraine” is a geological term defined as a “ridge-like accumulation of drift along the margin of a valley glacier or ice sheet”. Did the MNR fear prospecting activity or the northern residence would endanger the end moraine? How ironic it is that this area is also labeled on your maps as “Sulfide Creek”, and that the entire township is staked as tight as a drum. More importantly, one of the proposed areas encompasses a section of potentially significant Precambrian bedrock containing important geological structures and an enclosing volcanic-sedimentary assemblage. This area is the Tatachikapika River Plain Conservation Reserve (Denton, Thorneloe and adjacent Twps). It lies west of the community of Timmins and covers a portion of the Porcupine-Destor Fault Zone (“PDFZ”). The PDFZ is recognized worldwide as a major, prominent, geological feature extending from west of Timmins, Ontario well into Québec and is spatially associated with a number of significant gold deposits in the Abitibi. These include such premier, world-class orebodies as the Hollinger, McIntyre, Dome, Holloway and Holt-McDermott to name just a few. The PDFZ and its sub-parallel structures are associated with better than 95 percent of the 70+ million ounces of gold produced in Porcupine Mining District alone. How can the MNR have disregarded such geological significant information? Why would anyone in his right mind wish to cover such land with Provincial Parks and Conservation areas? The proposed Dana Jowsey Provincial Park Addition (Keefer, Sewell and adjacent Twps) lies north of the projected PDFZ but may include favorable sub-parallel structures found along strike. It should be remembered here that gold mineralization is not confined to the PDFZ directly nor to the associated volcanic lithologies. As an example of this one may note that the Balmoral and Bras D’Or deposits, which occur east of Val D’Or and along a splay structure associated with the Larder Lake-Cadillac Fault Zone (“LCFZ”), occur within an intrusive batholith. The LCFZ is similar to the PDFZ and is another world known structure associated with the gold mineralization located at famous mining camps at Kirkland Lake through Larder Lake and onto Val D’Or, Québec. The MNR’s disregard of the significance of the Precambrian bedrock also extends to other areas such as the Night Hawk Shoreline Bluffs Conservation Reserve. This area is covered with overburden but is underlain by Precambrian volcanic rocks which are favorable for volcanic-associated massive sulfide (“VMS”) deposits rich in copper, zinc, silver, etc. Timmins is host to a World Class VMS deposit, the Kidd Creek Mine, and our citizens recognize the importance of not limiting access to favorable lands that may possibly host the next mine and provide feed for the Kidd smelter. Why does the MNR not share the concerns of northern communities? Nonetheless, if the intention in proposing the Night Hawk Shoreline Bluffs Conservation Reserve was to preserve the “Shoreline Bluffs”, why does the MNR propose the reserve extend 5,800 metres east of the Night Hawk Shoreline? Your Omission of Mining Claims: We find it very interesting that your proposed boundary maps do not indicate all types of land holdings within the proposed areas. If your concerns were that displaying all types of landholders would clutter the esthetics of the map, may I suggest that it was an intentional omission designed to minimize the interest within the area? Several of the proposed six areas contain mining claims or would have contained claims under more favorable economic times. We note that in proposing these areas the MNR have modified the original proposed boundaries to exclude patented lands. We compliment the MNR on this action; however, we remind you that all of the patented mining lands in Northern Ontario started as mining claims. The success of work on mining claims in other parts of Ontario or other legal jurisdictions may lead to applications for mining leases, and, subject to compliance with various regulations, may lead to an application to conduct mining activity in a few situations. The requirements imposed upon successful exploration on claims within proposed Parks/Reserves are unreasonable. Other jurisdictions do not impose the bizarre requirement that landowners procure title to other lands to be included into a Park/Reserve elsewhere within the jurisdiction as a prerequisite to advancing their existing mineral claims to a higher level. Furthermore, we understand that these acquired lands must be acceptable to the MNR who may refuse the proposed acquisition without any stated logical reason. The cost of such an acquisition and the public discussions that follow are too onerous for mining companies to accept. This is especially true for homegrown, Ontario-based, junior mining ventures. If the MNR wishes to propose Park and Reserves areas that either have geological potential, contain mining claims, or have historically contained claims, then the MNR should be prepared for successful exploration activities which lead to their logical conclusion as they would anywhere else. The PPDA strongly recommends that the MNR consider a flexible Park/Reserve system whereby staking and exploration activities are permitted and site boundaries change over time without penalty to the exploration community as new mines are discovered within or adjacent to OLL sites. Your Dismissal of Economic Importance to Northern Communities: Contrary to whatever revisionist history the MNR may wish to enunciate, Timmins, Kirkland Lake, Larder Lake, Cobalt, and numerous other communities throughout all of Northern Ontario owe their very existence to mining. Mining and especially mineral exploration continue to play an important economic role throughout the region, although at a reduced pace during these times of low metal values. This sector of society also offers high wages averaging $55,000-60,000 per annum. Extremely important to our northern communities is that for every job within the mining/mineral exploration industry there is spin off employment which averages of 4.5 persons. These other people are employed in various other sectors of our society from the service and hospitality industries, to the health, professional, and retail sectors. Furthermore mining and mineral exploration activities leave an extremely small footprint unlike the forestry industry. We are extremely surprised to see areas of potential interest to mineral exploration included to such a high degree within your proposed Provincial Parks and Conservation Reserves. Are you not aware that your proposed Tatachikapika River Plain Conservation Reserve was part of a recent Timmins area gold rush during 1996-98? Band-Ore Resources Ltd., an Ontario based junior mining company, discovered two new gold zones on lands to the west of the proposed Tatachikapika Conservation Reserve. This triggered a flurry of staking, survey work and drilling by Band-Ore and numerous other mining companies. This work extended onto land covered by the Tatachikapika Conservation Reserve including lands current not covered by mining claims. The direct local impact of the discovery was an injection of a minimum 6 to 10 million dollars of exploration expenditures into the local economy. The spin off factor could be estimated at another 20-30 million dollars. Numerous individuals in Timmins also invested in Band-Ore and many appreciated significant capital gains. If you doubt this I would be pleased to point out several Band-Ore “built” houses. Although no gold mine was discovered within the area during this round of exploration activity, the people within the community prospered and paid taxes. Those with new or improved housing have added to the local tax base and continue to pay taxes. All this and no mine was discovered. Again, the footprint of the exploration activity is minimal and at the end of the day, the 41 to 110-year old white cedar that are noted in the “Fact Sheet” remain standing. Of significance to this example is that the area covered by the proposed Tatachikapika Conservation Reserve contains active mining claims that are under current exploration by another local junior mining company, Explorers Alliance Corporation. Designation of the Tatachikapika River Plain Conservation Reserve may limit their ability to raise funds for further work on this area. The presence of the Conservation Reserve also questions the very possibility of a future mining operation within its limits and thereby marginalising the potential to the company of any future discovery it may achieve. Such actions also minimize the potential impact of any discovery to the local community. Why does the MNR select areas for their Parks and Conservation Reserves that either display or occur near high mineral potential areas and would by their designation inhibit the future well being of local communities? Your Direct Opposition of This Government’s Good Intentions and Actions: Two of the six areas selected for proposed Parks/Conservation Reserves lie west of Timmins and would fall within the scope of the Timmins West Project. This project is being conducted by the Precambrian Geoscience Section of the Ontario Geological Survey (“OGS”). The Timmins West Project is an important initiative of the OGS. It includes important detailed geological mapping at the 20,000 scale. The project also encompasses eight townships and will continue through till April 2005. The MNDM has received the full support of the PPDA and the entire exploration community for this initiative and we look forward to seeing the results. Why has the MNR selected areas for a Provincial Park Addition and a Conservation Reserve in the very heart of this region that has yet to be mapped? Such actions are in direct opposition to the good intentions and positive actions of this government and in particular the MNDM. MNR’s designation of these areas sends a negative message to both the exploration community and investors in Ontario junior mining companies. Also, through the diligent efforts of Reginald Blair, M.P. for Timmins-James Bay, and other Members of Parliament from Northern Ontario, FedNor monies have been directed to support a Regional Geoscience Initiative for the Timmins-Kirkland Lake area. The Ontario Minister of Northern Development and Mines and his staff should be complimented for the positive effort to assist and make this geoscience initiative both a reality and success for the communities of Northern Ontario. The Geological Survey of Canada (“GSC”) would oversee the technical aspects of the Regional Geoscience Initiative and would cooperate with the Ontario MNDM to assure the quality and success of this five million dollar program. The potential impact of the geoscience initiative is further enhanced as several exploration and mining companies have indicated that they would make contributions that would significantly increase the current public domain geoscience database. This geoscience initiative would have significant impact on the level and direction of mineral exploration activity within NE Ontario and should positively impact on the northern communities. This is in fact the reason FedNor is considering funding the program. MNR’s designation of Provincial Parks and Conservation Reserves within this region goes against the intentions of both the Federal and Provincial governments to promote mineral exploration and assist northern communities. Was MNR not aware of this proposed activity? Do you folks not read the local papers? The newspapers from Kirkland Lake, Timmins, North Bay, Sudbury, Sault Ste. Marie, etc., contained a major feature on the GSC Geoscience Initiative just last month. The Porcupine Prospectors and Developers Association kindly requests the MNR reconsider designating these Provincial Parks and Conservation Reserves at this time. Further and more complete study is required and in the face of significant new activity and results on the horizon, it would be inappropriate and contrary to the best interest of northern communities to designate these areas at present time. Respectfully submitted, PORCUPINE PROSPECTORS AND DEVELOPERS ASSOCIATION ________________________ W. Waychison P.Geol. Vice-President CC: Rt. Hon. Michael Harris, Premier Hon. Reginald Belair, M.P. Timmins-James Bay Hon. Dan Newman, M.P.P. Minister of Northern Development and Mines Hon. Gilles Bisson, M.P.P. Timmins-James Bay Andrew Tims, President, PPDA Dale Alexander, President, NPA Tony Andrews, Executive Director, PDAC Ronald Gashinski, Senior Manager, MNDM Johial Newsome, Senior Manager, MNDM Jim Ireland, Regional Manager, MNDM Dianne Corbet, District Manager, MNR Robert Galloway, Regional Manager MNR |