YCS comments on draft Resource Access Road Framework

RESOURCE ACCESS ROAD FRAMEWORK<strong>YCS</strong> <strong>comments</strong> on draft Resource Access Road FrameworkSept. 11, 2012OverviewThank you for the opportunity to comment on the draft Resource Access Roads Framework.<strong>YCS</strong> supports the concept of having a Framework to guide decisions about the developmentand management of resource roads.However, the draft Framework does not place enough emphasis on the environment or socioeconomicvalues like First Nation traditional activities, traplines, and tourism. We understandthat with the present state of technology, overland access is necessary for the economicexploitation of most non-renewable resources. While it is important to develop Yukon’s nonrenewableresources as sustainably as possible, it must be acknowledged that there is almostno other industrial activity with wide spread effects as significant as those which roads produce.This framework should ideally produce a decision making matrix regarding whether eachproposed overland access is socially and environmentally acceptable, and then, who should payfor it. As written, this framework does not achieve this goal.Recommendation: The Framework should produce a decision making matrix regardingwhether overland access is socially and environmentally acceptable, and if so, who should payfor it.GoalsThe first goal of the draft Framework is “to ensure resource developers have transportationinfrastructure to access resources”. As stated, this goal presupposes the entire process.Instead, the Framework should include the possibility that transportation infrastructure is notalways appropriate, rather than being a mechanism to ensure it happens. The Frameworkshould provide a way to decide whether a resource road should be built, and if so, whethergovernment should help pay for the road.Recommendations:- Change the first bullet to read: “Resource developers have transportation infrastructureto access resources if appropriate.”- Include another principle: “Resource Access Roads will not necessarily be permitted.Government shall consider the negative effects of hinterland access on the environment,non-consumptive and renewable resources equally to the positive economic effects of

The criteria listed in this section should be questions that are asked as part of consultations, notcriteria to determine whether consultation should occur.Recommendations:- This section needs to state that government shall make every effort to include publicparticipation in decisions relating to new resource access or upgrading existing roads.- The public consultation criteria bullets in this section need to be changed to issues totake into account during consultations. To this list should be added “Possibility andseverity of environmental and socio-economic impacts.”Processes: New Roads<strong>YCS</strong> supports the statement in paragraph 2 that “new road construction will be managed toensure that new public use roads are not created.” This is very important since many of theenvironmental impacts from roads result from public use of them for hunting and fishing.We also support the statement in the same paragraph: “Unless otherwise determined by YG, allnew roads will be decommissioned upon completion of the project.” However <strong>YCS</strong> would like tosee more clarity about under which circumstances a resource road would not bedecommissioned. The only good reason for not decommissioning resource roads would be ifthere is another immanent project that would use the road.An important issue that has not been addressed in the draft Framework is the issue of miningcompanies staking claims end to end in a long line to make it possible to build a road that istechnically on their claims. The Framework needs to explicitly state that this practise is notallowed, as it has the potential to circumvent the Framework.