Article by
David Hunter
,
Nalin Sahni
and George McKibbon (McKibbon Wakefield
Inc.)
Many of our mining clients do not appreciate the role of the
Ministry of Natural Resources ("MNR") and the regulation
of Crown land through the Public Lands Act. While licenses
for advanced prospecting and mine development are secured through
the Mining Act, this is not the case with other critical
infrastructure. Miners need to manage the requirements of the
Public Lands Act that cover the approval of new access
roads, electricity generation sites, transmission lines, and other
infrastructure indispensible for developing mining operations on
Crown land.
Common areas of governmental regulation that miners deal with
such as securities, mining and environmental law have well worn
rules contained in statutes, regulations or highly prescriptive
guidance documents. This is not the case with the MNR and the
Public Lands Act. The MNR relies far more on setting broad
policy directions