To access the Mactung mining site, North American Tungsten plans to build a new 30-kilometre road through key wildlife habitat.
The upgrading of a 11-kilometre-long existing road located 15 kilometres north of the Macmillan Pass aerodrome would allow access to the mining site and have comparatively very little impact on wildlife
The impact of the planned new road on wildlife would be enormous and hence unacceptable.
Right on the planned route of the new road, the proponent identifies a mineral lick that is heavily used by sheep, and moose year round, and by caribou from spring to winter.
The highest fall and winter moose density in the whole wildlife study area of about 1,200 square kilometres has been recorded at that precise mineral lick (2.4 to four animals per square kilometre).
Nevertheless, the proponent intends to build a road right through or beside this mineral lick (the map provided by North American Tungsten is not precise enough to figure out exactly where the road will be in relation to the mineral lick, but in the best case it will be in the immediate vicinity).
As most people are aware, mineral licks are critical for wildlife survival and if animals are displaced or unable to access it will directly affect the welfare of a wildlife population.
If wildlife is not prevented from accessing this vital resource, it will nevertheless be exposed to the disturbance resulting from the construction of this road and the subsequent traffic.
This will predictably create stress to the animals, causing them to flee, which can directly influence winter survival.
Studies have proven that burning the calories needed to run during critical food shortage periods and under extreme low temperatures can actually cause animals to perish during the winter.
By upgrading and using the existing road, these problems would be entirely avoided.
The proponent identifies 10 potential grizzly bear dens in the immediate vicinity of the projected new road to the minesite. Two of them are located right at the valley bottom, where the new road is planned.
Grizzly bears do not den randomly, but congregate in denning areas that offer the best survival chances in terms of exposure (usually oriented southward) soils and early spring resources.
Bears will abandon a den in the vicinity of human activity.
Destroying a critical bear denning area Ã because that is the very effect that this new road will have Ã and displacing a whole bear population form their winter range is not an acceptable outcome of this project.
Hunting pressure results from a newly created access road to the backcountry. North American Tungsten Corporation seems aware that creating new roads into intact wilderness will expose wildlife to added hunting pressure.
The company points out it will use an existing exploration road and that it is only adding about 15 kilometres of new road to gain access to their mine and not allow hunting on that part of the road during the mining operations.
Therefore, they claim the impact will be small.
The proponent also plans on decommissioning the “new” part of the new road once the mining is done, but mentions the existing road will have to remain public afterwards, according to Yukon legislation.
First, if one examines the proposal it appears the first part of the new road will follow the same valley than the existing exploration road but not at all the same route.
The existing road is halfway up the side slope of the valley. The proponent plans on staying at the bottom of the valley.
This fact results from the very map the proponent produced in its proposal. In reality, the proponent is building whole new road that will double the present road. And we are told that this new road is there to stay.
Once a road is build in a narrow mountain valley bottom there is no way to render it inaccessible to ATVs and other such vehicles.
The proponent mentions numerous times they will seed the road with native vegetation. I am not aware of a nursery in Canada the sells dwarf birch, alpine fire or lichen.
On the other hand, in the climatic conditions of the Mackenzie Mountains, it takes hundreds of years for a disturbed area to regain its vegetation cover.
Seeding a few plants will absolutely not prevent motorized hunters from accessing the area. Once built, this road is there to stay because, in real life, the unfortunate truth is that this type of road is never decommissioned.
The area is used by the Redstone caribou herd. The last count of these caribou is more than 20 years old and very approximate when it comes to the size of the herd (between 5,000 and 10,000 animals).
In fact, the health of this herd as of today is totally unknown and so is the amount of animals harvested.
Having been in the area on several occasions during hunting season, I can only say that the harvest is extremely heavy and I am afraid that it has already reached an unsustainable level.
As areas in the south of the Yukon are depleted of game Ã a testimony to wildlife management in the Yukon. Hunters (native and non-natives alike) converge to areas that still have game left. This can only result over harvest and shortage of game for the population of Ross River that relies on it for its survival.
In that context, it can hardly get worse than creating a new 30-kilometre road that leads right to a mineral lick used by every animal in the wider area Ã and this in the absence of any harvest monitoring and/or restriction.
The ease of killing animals at such a site will predictably result in population decline.
For all these reasons, I urge YESAB to recommend that the construction of this access road be not allowed.
I also urge North American Tungsten to modify its proposal in order to use the existing road.
During its presentation in Ross River on the 9th of November, the representatives of the company insisted on the fact that it is a socially and environmentally responsible company, and this is truly the time to prove that claim.
It appears that the main reason given by the proponent to discard the option of using the existing road is that it would involve negotiations with the Sahtu First Nation of the Northwest Territories, since the existing road is located in land that is part of their comprehensive land claim agreement.
This would result in a more lengthy process than building a new road in the Yukon, according to North American Tungsten.
In that regard, I would like to remind the proponent that he benefits from free access to Yukon mineral resources for its own enrichment, but that he is going to operate on the historical land of the Ross River First Nation.
The proponent must be aware that a large part of the Ross River population shares the concerns expressed in this letter and this should create a moral obligation to make the extra effort to respond to these concerns in a satisfactory way.
As for myself, I am not a member of the Ross River Dene Council, but I am a taxpayer in Canada and in that regard, I would also like to remind the proponent the taxpayers in Yukon and Canada are subsidizing its mining operation through the gift of a massive investment of $70 million into the upgrading of the North Canol Road, entirely funded by public money.
I would wish that, with that in mind, the proponent would also feel a moral obligation to respond to the request in this submission and modify its project as requested.