July 20, 1999
The Honorable Christine Stewart
Minister of the Environment
28th Floor, 10 Wellington Street
Hull, Quebec K1A OH3
Dear Madame Minister:
Re: Comprehensive Study Review, Diavik Diamonds Project
Attached is a submission from MiningWatch Canada, which represents our considered response to the Comprehensive Study Review. In our opinion, the Study is incomplete, biased toward the proponent and fails in its duty to protect the environment, and further, fails in its fiduciary responsibility to First Nations.
We ask you to reject the study and establish a Joint Panel Review based on the Voisey’s Bay precedent. Further, we support the Dogrib and Lutsel K’e First Nations in their concerns about the project and their wish for a panel review. This is a clear indication of outstanding significant public concern with the project and we believe that you have no choice but to refer the Diavik project to a panel review.
We make this request on the basis of the following concerns:
- Inadequate assessment of the cumulative effects of mineral exploration and development to the environment of the Slave Geological Province, including uncertainties surrounding the effects on caribou and water
- Inadequate recognition and consideration by the Responsible Authorities for governance issues and Aboriginal rights in the project area and of federal fiduciary obligations to Aboriginal peoples
- Inadequate assessment of the full social costs of the project
- Inadequate assessment of the full economic costs of the project
- Lack of consideration of responsibility for the costs of closure, bankruptcy or abandonment of the project
- Flawed process and outstanding public concern
- Undue reliance on the integrity and authority of the project proponent
Thank you for your consideration,
Yours truly,
Joan Kuyek, National Co-ordinator