Navigating the Muddy Waters of Permit Applications for Mineral Exploration Projects
As we grow and expand our mineral exploration projects the need for increasing transparency of our activities becomes more prevalent and is reflected in the requirements to apply for necessary permits with various government organizations. If this is something new to you, or even when you're experienced, the task can be quite daunting but there are some strategies that are useful in most situations. First and foremost, make sure to introduce yourself, your company and your proposed project to the local mineral exploration & mining authorities prior to applying for permits, such as the BC Office of the Chief Inspector of Mines or the YT Mining Recorder's Office. They are there to assist you through the process.
Often, when faced with difficult situations, our first response is to look at the governing body to determine what they can do better. There isn't much we, as individuals, can do to influence the governing bodies in a timely matter so this post focusses on what can be done now to create high-quality permit applications.
Let's first take a look at the issues common to most applicants: feels like the goal post is always moving, have to re-send information, slow response times and often the amendment requests seem trivial or appear to be outside the scope of the project.
Moving Goal Post
It is frustrating when you've made the effort to check all the boxes only to find out that the list is getting longer. At this point it may be prudent to bring in a more experienced person, or an expert in the relevant discipline, to assist with the application. Guidelines, policies and regulations are also constantly evolving to grow and adapt with new information and societal changes so it's important to keep up-to-date on environmental and social concerns.
If you have ever done any database management you will understand that, in all likelihood, you will have to re-send information. It seems like it's a natural human trait to request information from the source, rather than search through our own filing system. Remember to be kind, send the information promptly, comment when the information was originally sent and to whom, ask if there were any issues with the information and keep detailed records of all communications with the interested parties.
Slow Response Times
Some jurisdictions do not have an online registry for communicating permit applications so a proactive approach is required. Make sure to keep in contact with the local authorities you contacted at the start of the application process to ensure a smooth transition through the various steps and agencies.
Requests Seem Trivial or Appear Outside the Scope of the Project
It is very important to bear in mind that the permit applications are not only reviewed by geologists but may also be reviewed by biologists, engineers, foresters, health care professionals, non-scientific government staff and local interest groups. Their understanding of mineral exploration activities may be limited so offering well-explained and well-thought-out permit applications, suitable for any audience, will reduce communication backlogs.
Although mineral exploration and mining have their own laws, guidelines, policies and best management practices relevant to specific mining activities, we are also bound by the regulations that govern other industries. This is to ensure that the standards and practices for all the cross-over activities in resource-based industries, such as road building and cutting down trees, are consistent for all land users.
How to Submit a High-Quality Permit Application
Review other projects' applications (if possible). Check the comments to see what they did right and wrong.
Introduce yourself, your company and your project to the local mineral exploration and mining government office.
That blank space where you describe your project or provide other information is not an indication of how much detail to provide. More often than not you will need to provide more information than the blank space allows. That blank space is, however, the perfect size for "See attached document".
Hire an expert: someone who has successfully submitted permit applications or whose background is in a relevant discipline such as wildlife biology, forestry, archaeology, engineering, health sciences, safety or social science.
Be aware of special considerations when working in certain areas such as the Great Bear Rainforest Legal Direction and Agreements zone which overlaps with part of the Golden Triangle.
Keep track of new social and environmental requirements:
Anti-Harassment Policy and Reporting
While we can't change how government agencies assess our applications in the present, we can increase efficiency with high-quality permit applications. It is important to remember that even though it seems like we are the only people working out there, we are not the only land users. Transparency is necessary to ensure the land is protected and reclaimed, to the best of our knowledge, for current and future land users and that we continually establish our social license to operate. Good luck!
About the Author:
Dr. Diana Benz has 24 years of experience working in the mineral exploration industry searching for diamonds and metals in a range of roles: from heavy minerals lab technician to till sampler, rig geologist, project manager and business owner. She has a Bachelor of Science in General Biology, a Master of Science in Earth Sciences researching diamond indicator mineral geochemistry and a Ph.D. in Natural Resources and Environmental Studies using geochemical multivariate statistical analysis techniques to interpret biogeochemical data for mineral exploration. Diana has conducted field work in Canada (BC, NWT, YT and ON) as well as in Greenland. She has also been involved, remotely through a BC-based office, on mineral exploration projects located in South America, Africa, Eurasia, Australia and the Middle East. Currently, Diana is the owner of Takom Exploration Ltd., a small geological and environmental consulting firm focused on metal exploration in BC and the Yukon.