WCS Canada's Response to Yukon's Resource Road Regulation Discussion May 2023
Thank you for the opportunity to provide input on the Proposed Resource Roads Regulations. The following comments have been prepared in response to the online survey as part of the public engagement process. While we feel that the permitting and access control measures are adequate to address concerns around road safety, liability, wildlife and the environment, there are some concerns outlined in these comments.
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WCS Canada Response to Yukon Government New Minerals Legislation Discussion Paper May 2023
We offer strong support for Yukon Government’s initiative to replace existing mineral legislations and associated processes. We appreciate the recognition that these laws are too outdated to be fit for purpose and require substantial revision. We strongly assert that new mineral legislation must: recognize and be compliant with the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) and Canada’s United Nations Declaration on the Rights of Indigenous Peoples Act; explicitly recognize that the spirit and intent of the Umbrella Final Agreement includes Indigenous co-governance of all non-private lands in the territory; and, that mineral resources found on or under land that is not privately owned are common property belonging to all Yukon citizens.
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WCS Canada Comments on Yukon's Proposed Changes to Forest Resources Act and Regulations April 2023
The Act and associated Regulations are important legislative tools for ensuring stewardship of ecological, cultural, and other values associated with Yukon’s boreal forests. The Act and Regulations are critical in ensuring forest planning, management, and timber harvest operations avoid significant impacts to Yukon’s forest ecosystems and biodiversity, and associated cultural, social, and ecosystem values, in addition to providing for Yukoners’ wood products needs.
Outlined below are our major ‘likes’ of the proposed changes, and what we think is still missing and would improve stewardship of Yukon’s forest resources for current and future generations.
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WCS Canada comments on Ontario Mining Act 2023-04-14
Our overarching concern regarding these proposed changes to the Mining Act is that they
weaken requirements for mining companies and reduce oversight, which effectively transfers
the burden of the financial, environmental, and social risks of mining activities to local
communities and the public at large. We contend that these changes will lead to erosion of
public confidence in the mining process and increase public resistance to mining based on the
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burden of risks. Consequently, these changes will ultimately fail in their stated purpose to build
mines more efficiently and in a timely manner.
We recommend, therefore, that all four proposed set of changes be withdrawn and
reconsidered.
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WCS Canada comments on Critical Minerals Strategy to Natural Resources Canada - September 2022
A Critical Minerals (CM) strategy is one important step and welcomed, given the need for Canada to strengthen supply chains to support the energy transition from fossil fuels to renewable energy sources to address climate commitments. In its present form, however, the draft strategy and accompanying discussion questions are oriented around a relatively narrow and short-term economic growth perspective, rather than one that emphasizes sustainability in the full sense of the word, i.e., including ecological and social dimensions. It also fails to adequately consider the impact on Indigenous communities and the need to respect and support Indigenous sovereignty in impacted regions. Describing critical minerals as a
'generational opportunity', the strategy does not adequately cover impacts on current and future generations if the extraction of critical minerals does not deliberately consider social, environmental, and long-term economic costs.
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