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Submission to the Public Hearings on applications by Canadian United Minerals for licences to conduct mineral exploration in Tombstone Park

Jamie Kneen Communications and Outreach Coordinator responsible for: strategic research, social media, and public engagement; our Africa program, environmental assessment, and uranium mining.

Dave Jennings
Chief, Mining Land Use and Reclamation
Mineral Resources
Department of Indian and Northern Affairs
345-300 Main Street
Whitehorse Yukon Y1A 2B5

Dear Mr. Jennings:

Re: Applications by Canadian United Minerals for licences under the Quartz Mining Act to conduct mineral exploration in Tombstone Park

This letter is a submission to the Public Hearings in regard to the above. Thank you for this opportunity to express our views on this matter. MiningWatch Canada is a non-governmental organization established in April 1999 to research and advocate for responsible mining practices in Canada and by Canadian companies abroad. Our members are other not-for-profit organizations. These are the Yukon Conservation Society, the Task Force on the Churches and Corporate Responsibility, the Innu Nation, the CAW Social Justice Fund, the Canadian Nature Federation, the Canadian Parks and Wilderness Society, Inter Pares, the Environmental Mining Council of British Columbia, Canadian Environmental Law Association, Northwatch, and the Citizens Environmental Mining Council of Newfoundland.

The applications of Canadian United Minerals for permits under the Quartz Mining Act to explore the "Horn claims" are of national significance. They attack the very basis of aboriginal title and interest. They fly in the face of commitments made by the Honourable Robert Nault to protect parks from mining. Granting these permits would represent a foolish step in terms of sustainable development and planning.

  1. Attack on aboriginal title.

    The ground that Canadian United Minerals wishes to mine has extreme cultural and traditional significance to Yukon First Nations. In a press release, dated March 24, 2000, the Trondëk Hwech'in stated: "Our history is inscribed on this land. There are two ancient villages within the Park and over 70 archaeological sites, including microblade sites dating back 8 to 10,000 years. In 1989 at the outset of TH Land Claims negotiations, we selected a good portion of this ground as a Category A Land Selection, designated R-10. R-10 was selected to protect these important lands, and included every square inch of the Horn Claim group of interest to Mr. White." In June of 1992, the Trondëk Hwech'in agreed to drop the R-10 designation in favour of a Territorial Park, "with the explicit assurance from Yukon that the land would be protected for all time as a Territorial Park".

    The section 10, schedule A of the Trondëk Hwech'in Agreement it states that the Agreement is "to protect for all time a natural area of territorial significance". The 1992 preliminary agreement included the Horn claims area, as does the Agreement of September 15, 1998. The First Nation has unequivocally stated its opposition to the exploration licences. The federal government is bound by honour and law to ensure that this land agreement is enforced.

  2. The commitments made by the Honourable Robert Nault.

    On February 28, 2000, Mr. Nault made the following stated that "Mining is not compatible with parks. We will not support mining in parks." He went on to say that miners are irresponsible for moving quickly to stake in areas that are going to be parks.

    This statement followed on many years of discussion between the mining industry, environmental, aboriginal and government representatives on the issue of protected areas, and the Tombstone range in particular. In the Tombstone area, the park boundaries were established after a sound and thorough public consultation process. Writes the Canadian Nature Federation, "mineral staking should not interfere with proper protected areas planing, public consultation processes regarding boundaries, and eventual park establishment."

  3. A foolish step in terms of sustainable development

    The proponents of this exploration permit and their supporters in the mining industry anticipate that the Horn claims exploration will reveal a rich lode of gold and even possibly uranium ore . The Yukon Prospectors Association were quoted in the Whitehorse Star November 9, 1999 saying "Mineral exploration and government research over the past 50 years have established that the Tombstone area contains rocks with some of the highest known mineral potential in the Yukon. There are known high-grade gold occurrences. Excellent potential exists for the discovery of bulk tonnage deposits — mines which could rival Faro in size and economic benefits. In addition the syenitic intrusion forming the bulk of the Tombstone Range proper contains one of the largest undeveloped uranium resources in North America, according to government geologists."

    The exploration licence requests need to be considered in light of the contribution of gold and uranium mining to future generations in the Yukon. Both gold and uranium face very uncertain markets at this time, and are entirely dependent on government manipulation of demand for their value. Both involve serious concerns with toxins and long-term legacies. All mining has an enormous ecological footprint. As Bob Aherns, former director of Strathcona Park in B.C. writes: "What harm is a ten acre mine in a park of 500,000 acres? Let me tell you about a ten acre mine in one provincial park. This requires a hydro electric power development (or power poles into the park), a tailings disposal site, mill effluent disposal sites, many roads, a camp, barge shipping and tugs on a major lake, loading out works, then a highway through the park (along water grades) all for just a starter. That ten acre hole influences 100,000 acres of the choicest part of the park."

    Gold extraction is a dangerous process that leaves behind cyanide and other toxic chemicals in its massive tailings dumps and waste rock piles. Mt. Nansen Mine and Viceroy Mine testify to the these concerns. In the North West Territories, gold mining has brought us the Giant Mine and Colomac. Gold is not even a useful mineral: 85% of all gold produced is used for jewelry.

    Uranium mining is even more destructive, polluting land and water with its radio-active tailings and waste rock piles, and requiring care forever to monitor what it leaves behind. Neither gold nor uranium mining use the land for a short period of time. The mine lasts a few years, but the damage lasts for generations.

    The Trondëk Hwech'in have wisely decided that mining is not a proper use for their lands. Why should exploration proceed, if mining is not intended to go ahead, no matter what is found? Local renewable and sustainable resource economies like tourism and fisheries can be seriously damaged by even small mines if accidents happen. The value of conserving nature and bio-diversity, protecting sacred spaces and cultural heritage is immeasurable, and beyond price.

  4. This is an issue of national importance

The granting of permits to mine in the Tombstone Territorial Park area is of national significance:

  • firstly in terms of the responsibility of the Canadian government to ensure that agreements made in good faith with First Nations are respected;
  • secondly, in terms of the Canadian government's willingness to value bio-diversity and the environment over the questionable demands of resource extraction industries for easy access to natural capital; and
  • thirdly, in terms of federal willingness to assist in the development of truly sustainable economic policies and development in Canada's north.

We urge you to refuse the application of Canadian United Minerals for exploration permits in Tombstone Territorial Park.

Yours truly,

Joan Kuyek
National co-ordinator