Thank you.
Good afternoon, Mr. Chair and members of the parliamentary standing committee. Thank you for the opportunity to provide testimony today on this important legislation.
I'm here today as president of the Yukon Chamber of Mines, as well as in my position as the executive vice-president and chief operating officer of Alexco Resource Corp. With me today, aIso representing the Chamber of Mines and our industry, is Mr. Samson Hartland, who is a director of the chamber, and Mr. Ron Light, vice-president of the chamber and general manager of Capstone's Minto mine.
Let me begin by saying that the Yukon Chamber of Mines and the mining industry in the Yukon support a robust environmental assessment process. Our comments today reflect our belief that the proposed amendments to the Yukon Environmental and Socio-economic Assessment Act will improve the areas of most concern to our industry with respect to the YESAA process.
I would like to address two important proposed sections in this bill that we feel will have the most benefit to mine operators and developers, namely project reassessment, proposed section 49.1, and timelines, proposed section 56.
Let me first start with Alexco's experience in the YESAA process and how it relates to our operations in the Keno Hill silver district. Alexco is a public Canadian mining company. Our primary asset is the Keno Hill silver district located in the traditional territory of the First Nation of Na-Cho Nyäk Dun.
To speak first on project reassessment, the nature of almost all mining districts and operations is that mine plans and ore bodies will change once they go into production according to changes in commodity prices, exploration results, and other cost and operating variables. These changes are generally consistent with current operations, such as an extension of the timeline for the operation of existing facilities or the expansion of current facilities. But under the current YESAA legislation, even if new activities are very similar in nature, new assessments are generally required.
ln the case of Alexco and Keno Hill, we have undergone the YESAA process 10 times over a variety of activities in the past eight years, for activities that are very similar in nature yet have already been assessed. For example, Alexco recently underwent a YESAA designated office assessment for the addition of another similar narrow-vein ore body sitting directly adjacent to and beneath our existing milling facility, a facility that had already been in operation for three years and was in full compliance with all operating permits and licences.
Despite this, the use of the mill for a further period beyond five years was included as part of the assessment for a new underground mine adjacent to the mill, along with the assessment for a new dry stack expansion tailings facility, a facility that had already operated successfully for the past three years.
We have also been required to go back through the entire environmental assessment process, simply to maintain a care and maintenance water licence, to extend the operating period of water treatment facilities from five years to 10 years. These facilities had again successfully operated for several years, but the simple extension of plant operating time required a new assessment.
Similar examples of project reassessment have been experienced at other operating and development projects in the Yukon, including Capstone's Minto mine and Golden Predator's Brewery Creek mine. These are clear examples in which a reasonable decision body could have easily determined that these are not material changes to a project and should not require an additional assessment of the project, and they underscore the importance of proposed section 49.1, project reassessment.
With respect to timelines, we support time limits that include both the adequacy and assessment stages of the YESAA process. Over the past five years, Alexco has undergone a YESAA process four times, specifically for mine development and mine operation purposes.
The adequacy review period of the YESAA process for our latest mine addition has increased fourfold compared with the time required to assess the first new mine and mill in the district. Meanwhile, the overall time required to complete the YESAA process from beginning to end has systematically increased by approximately two and a half times. Currently, the adequacy stage is not included in binding timelines, and our experience has been that this period continues to grow in length and that the adequacy period is used to conduct the assessment outside of the designated timelines.
The current uncertainty in reassessments and continued extensions of the time required for a YESAA assessment have a negative impact upon our ability to efficiently plan and operate our business. By extension, it impairs the competitiveness of Yukon, as a jurisdiction, to assert certainty in mine development and production processes and to attract scarce investment capital.
Finally, Mr. Chair, let me make some remarks on the broader context of the mining community in the Yukon. Nearly all mining operations are developed in a series of phases. In our experience as well as that of other operators and developers in the Yukon, YESAA is not conducive to or aligned with the normal mine operating requirements of sites that are already in operation. At some stage, all current and future mines will undergo normal changes in operations, and the inclusion of these amendments will be important to all current and future operators.
I thank you for your time. I would like to turn over the balance of our allotted time to Mr. Samson Hartland.