B.C. Ministry of Environment does Clandestine ‘Audit’ of Cariboo Placer Miners

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2010 Placer Mining Audit

July & August 2010

Conducted by
Ministry of Environment Ecosystem staff

Executive Summary

An audit of placer mining operations in the Cariboo Region was undertaken by Ecosystems staff from the Ministry of Environment (now MFLNRO) during the summer of 2010. The study was initiated in response to a substantial increase in the number of placer Notices of Work being received by government, and concern over potential environmental impacts associated with this industry. During the audit, a sample of twenty-six placer tenures were inspected and assessed for compliance with submitted Notice of Works. The audit sample was distributed throughout much of the area of placer activity in the region, within the major watersheds of the Cottonwood and Quesnel Rivers, encompassing ten watershed basins with both anadromous salmon and resident trout populations. Parameters assessed during inspections related to potential habitat impacts and specifically included: vicinity of works to watercourses and areas designated as Critical Fish Habitat; size and extent of disturbance areas; disturbance to designated wildlife habitat and unglate winter range areas; operations in Old Growth Management Areas; and adequacy of reclamation.

Of the twenty-three active tenures inspected, 74% were found to be in non-compliance with their Notices of Work. The results of this audit highlight the risk of aquatic, fish, and riparian habitat impacts, occurring in high value fisheries watersheds with inherent hydrological sensitivity. Works within the 10m placer riparian reserve setback were observed at more that half (57%) of the active tenures, while unauthorized in stream works had occurred at 43% of tenures, and evidence of waste water discharge into water bodies was observed at 30% of the tenures. Inadequate reclamation and unreported disturbance areas on placer mine tenures were also key findings of the audit. The audit revealed that placer Notices of Work did not accurately reflect the works that were undertaken on the ground, and that the size and types of disturbance associated with placer mining are much greater than perceived or reported.

Recommendations are made for regionally stepping up compliance and enforcement on placer mine operations; implementing regional environmental protection standards through the placer mine permitting process; locally developing basic guidance information on acceptable practices for dissemination to placer miners active in this area; renewal of the Horsefly River Watershed placer No-staking Reserve; and development of provincial environmental protection standards specific to the placer mining industry.

1.0 Introduction

Placer mining is the process of recovering unconsolidated mineral ores (most commonly fine gold) found in sand, gravel, and loose earth. In contrast to hard rock mining, which requires fracturing of bedrock to recover embedded ores, placer mining occurs in areas of alluvial deposits where water has historically eroded, deposited and reshaped minerals in loose or unconsolidated deposits. Hence by its very nature, placer mining is associated with historic or modern streams and rivers which have carried these precious minerals in their bedload.

In the Cariboo region, small and large scale placer mining has continued since the time of the gold rush, with the amount of resources dedicated to the industry generally proportional to the relative price of gold at any given time. The nature of the typical Cariboo placer operation has been influenced by increased utilization of mechanized equipment (backhoes, excavators, etc) which allows even the smallest one man placer operations to uncover increasingly larger areas and process considerable volumes of material in a season. Changes in policy and regulations have also impacted placer operations over time, as the laws regulating work in and around water courses and fish habitat have become more stringent. For instance dredging and sniping (section dredging) of river and stream beds, a common practice in placer mining not so long ago, is now considered an unacceptable practice in fish bearing waters .

Placer mining activity is not evenly distributed throughout the province but is concentrated in a relatively small number of areas of BC. The level of placer activity in the Cariboo region east of Quesnel is unprecedented in any other region of the province (see Appendix 1. Map 1). This concentration of placer mine activity is focused along rivers and creeks which also provide some of our highest value salmon and trout fisheries, including the Quesnel River, Cariboo River, Cottonwood River, Little Swift River, Lightning Creek, Willow River, Antler Creek, Bowron River and others (Appendix 1. Map 2). This concentration of placer activity also happens to be strongly correlated with areas which have been identified as Critical Fish Habitat through the Cariboo-Chilcotin Land Use Planning (CCLUP) implementation process and are now designated as such under a Land Act Order which protects the riparian areas from forest harvesting (see Appendix 1. Map 3) .

In addition to being highly sensitive watersheds for both resident and anadromous fish species, the Quesnel and Cottonwood watershed units have the highest hydrology hazard scores in the Cariboo Region, rated as part of Fisheries Sensitive Watershed assessments currently underway (Youds, personal communication, May 4, 2011). The CCLUP set a target to “manage the Cariboo (and Horsefly) and Cottonwood River Watersheds for hydrologic stability through watershed assessment, restoration work and monitoring programs” (Government of British Columbia, 1995). The Horsefly, Bowron, Quesnel, Cottonwood and Cariboo Rivers were all targeted in the CCLUP to be managed for salmon stocks through riparian area protection and controls on the rate of harvest.

Numerous riparian, fish habitat and hydrologic assessments have been carried out for these watersheds and placer mining is commonly identified as having an extensive and significant impact on the stream systems. In An Inventory of the Watershed Conditions Affecting Risks to Fish Habitat in the Cottonwood, Cariboo and Horsefly Watersheds (Chapman Geoscience Ltd. & Dobson Engineering Ltd., 1997, p.iv, x) a key finding common among these three watersheds was that,

“Where placer mining had occurred, stream channels have been disturbed resulting in increased sediment supply that overwhelmed the potential effects from other land use activities. Channel re-stabilization was observed and the supply of coarse sediment was reduced at locations where mining had been abandoned.”

It was also noted that “Channel disturbances from placer mining activity are common in many tributary channels of the Cariboo River system…If fish habitat is to be improved in these systems many stream channels will require rehabilitation. Unless there is a change in the way that placer mining is undertaken, any channel rehabilitation will be unsuccessful.”

2.0 Background

Over the past five years, as the market value of gold has soared, there has been a dramatic increase in  the number of placer Notice’s of Work being referred to Ministry of Environment  (MoE)1in the Cariboo region.  In the past, MoE Ecosystems staff reviewed and commented on individual placer  Notice’s of Work (NoW’s),  providing written recommendations to Ministry of Energy Mines and Petroleum Resources within 30 days.

With desktop mapping available for identifying habitat values and land use planning information, as well as orthophotomosaic imagery (such as on Google Earth) it has become increasingly possible to carry out a relatively thorough office review of NoW’s without actually field visiting the sites. Field visits to placer operations have generally been undertaken in an ad hoc manner and for a variety of reasons including: to verify habitat values or potential impacts identified in the office review; in response to questions raised by placer miners or MEMPR; in response to external complaints; incidentally in the course of field visits related to other duties; or in the course of investigations.

With the increased number of placer referrals being received by Ecosystems staff in the Cariboo region it became apparent in 2010 that Ecosystems staff lacked the capacity to continue with individual reviews.


1Prior to autumn 2010, Ecosystems staff were part of Ministry of Environment and Mines Inspectors were with the Ministry of Energy, Mines and Petroleum Resources; now all staff are part of the Ministry of Forests, Lands and Natural Resource Operations

In deliberating on how best to assess and address the level of environmental risks associated with placer operations the following issues were taken into account:

1.        Although considerable time was being taken by Ecosystems staff in review and comment on placer NoW’s we were uncertain whether our recommendations were being passed on to proponents or incorporated into permit conditions. Furthermore we had little indication of whether our review was actually influencing operations, reducing environmental impacts or improving the protection of identified habitat values.

2.        Individual review of placer NoW’s generally resulted in commonly identified habitat values and a number of commonly made recommendations related to environmental risks and deficiencies with the NoW’s.

3.        There were no government endorsed best management practices specific to placer operations and legislation in British Columbia . The Handbook for Mineral Exploration (Energy and Mines, 2009), though an excellent resource on mineral exploration best practices, is a very detailed and extensive reference document, but not tailored for, or entirely applicable to placer mining.

4.        Placer operations are specifically exempted from exploration activities as defined in Part 9 of the Health, Safety and Reclamation Code. Hence, this section of the Code which provides the mine regulations for many of the important environmental aspects of mining activities including, riparian setbacks, soil conservation; terrain stability, water management, and reclamation does not apply to placer mining.

5.        A Memorandum of Understanding (MoU) was established in 1997 between the provincial ministries responsible for mining, forestry and environment with respect to placer mining activities in riparian ecosystems intend to “form an interim agreement for management of placer activities, until replaced by a placer mining regulation under the Mines Act” (Employment and Investment,1997). As yet a placer mining regulation has not replaced this MoU and it remains the only endorsed source of guidance for regulating placer operations in riparian areas. The MoU establishes for placer operations a 10m setback from the high-water mark of rivers streams, lakes or wetlands. A clause in the MoU allows for a modification of the 10 metre setback if jointly agreed to for site-specific areas with aquatic protection concerns. Although this clause exists, there are several examples in the Cariboo Region where a larger reserve was requested but declined.

6.        Although placer mining often requires authorization for harvesting timber from areas to be mined, the rules which apply to other holders of forest tenures including commitments to uphold land use plan objectives are not applied for placer mining activities. Consequently areas designated under FRPA or Land Act orders as ungulate winter ranges, riparian management zones, wildlife habitat areas, old growth management areas, and critical fish habitat are often not managed accordingly for placer mining.

7.        A placer mine No Staking Reserve established over the Horsefly River Watershed in 1988 was up for review and consideration was being given to removing the reserve. The reserve was originally established recognizing the temperature and hydrologic sensitivity of the watershed which provides one of the most significant salmonid fisheries in the province.

In the spring of 2010, MoE made a decision to cease individual review of placer NoW’s. To support this initiative we collated all of the mapped habitat values that we typically considered in review of placer NoW’s and compiled a compendium of our comments. We used these to formulate a guidance letter addressed to MEMPR, outlining our recommendations for protection of habitat values related to mapped attributes, with an explanation that we would no longer be individually responding on placer NoW referrals (Appendix 2. Letter to MEMPR). We also outlined our intention to reallocate available staffing resources to field inspection of placer operations. This report summarizes the placer mine monitoring audit that we undertook during the summer of 2010.

3.0 Methods

Inspections of a sample of placer mines were undertaken by Cariboo region MoE staff, Michelle Arcand and Joanne McLeod, from July 7 to September 9, 2010. We were accompanied on inspections at different times by Conservation Officer Service staff, the Ecosystems Section Head, Williams Lake Indian Band staff, and DFO officers and habitat staff. Selection of the sample was non-random. Placer tenures associated with high fish and wildlife habitat values or which appeared to have large areas of surface disturbance were prioritized for site inspections. In order to maximize the number of sites and watersheds visited, effort was made to cluster site inspections along a particular road network during any given field day, and also to visit sites from a variety of geographic locations over the course of the season. Hence not all placer sites visited were rated as high priority and it was beyond the scope of our resources to inspect every site that we prioritized as a high potential for impacts.

Advance notice of inspections was not given to tenure holders, [emphasis added. Webmin.] but when we arrived at mine sites we always made any personnel on site aware of our presence and intentions. At each inspection, we made an effort to view the entire area of the claim where works were identified in the NoW, as well as any other areas of apparent disturbance. We compared what we observed on site to what was reported in the referred NoW.

During inspections we measured the distance of works (disturbance) from watercourses; we looked for potential discharge or diversion of watercourses; we identified potential impacts to fish and wildlife habitat; and we looked for evidence of reclamation and soil conservation. We did not attempt to assess timber volumes removed, or look at health and safety compliance, as these issues were outside the scope of this audit.  Inspection results for each site were recorded on an individual field form developed for the audit (Appendix 3).

4.0 Results

Throughout the 2010 calendar year Ministry of Environment received one hundred and thirty-five NoW referrals for placer operations within the Cariboo region. During our audit we inspected twenty-six placer mine sites.There were no works initiated at three of the inspected sites. Results of the audit for all of the placer sites are summarized in Table 1.

•    Seventeen (74%) of the placer operations inspected were not in compliance with their NoW; meaning that some aspect of the reporting on their NoW was inaccurate.

•    Of the six operations that were considered to be in compliance with their NoW’s, one lacked a fish screen on their pump, so was out of compliance with DFO’s fish screening directive.

•    Two of the operating placer mines were working without an approved NoW permit from MEMPR.

4.1 Riparian, stream and fish habitat related results

Placer tenures were inspected in the following watersheds: Willow River, Ketcham Creek, Big Valley Creek, Summit Creek, Antler Creek, Swift River, Cottonwood River, Lightning Creek, Cariboo River, and Quesnel River (upstream of Quesnelle Forks). All of these watersheds provide habitat for both anadromous salmon and resident fish populations.

•    Thirteen inspected placer operations had works within the 10m riparian setback reserve.

•    At ten sites instream works had occurred.  Unauthorized instream works included: excavated stream beds; division of natural streams into constructed channels to settling ponds; roads constructed through seasonal streams and floodplains; filling in stream channels and recontouring sites hence eradicating the natural channel and dispersing stream flow; excavating and /or dumping material in wet lands and beaver ponds.

•    At eight placer sites there was discharge of wastewater from mine operations into a watercourse.

•    In two cases fish were observed in mine settling ponds.

•    Ten of the audited placer tenures were in areas identified as Critical Fish Habitat under the CCLUP and Land Act Order; one of these tenures was not active.  Six sites inspected with identified Critical Fish Habitat had works occurring less than 30m from the high water mark. And at four of these sites with Critical Fish Habitat, operators were working less than 10m from the associated stream. In one of these cases the mine permit specifically required a minimum riparian setback of 30m.

4.2 Reclamation, disturbance areas and Old Growth Management Areas

•    Only one of the placer tenures (4%) had adequate reclamation consistent with that reported in the NoW.

•    Thirteen of the placer sites (7%) had little or no reclamation observed, and the extent of the disturbance was notably more extensive than indicated on the NoW.

•    It was commonly stated on the placer NoW’s that reclamation would be concurrent with mining or would be conducted at the end of the season, however this was not observed to be occurring.
•    Ten placer tenures (43%) had disturbance areas ranging from 2.5 hectares to over 28 hectares; while 13 tenures had disturbance areas of approximately 1ha or less.

•    Soil conservation for reclamation was only recorded at three of the dies visited, though this parameter was not consistently recorded on the field form.    ‘
•    Eleven of the 26 tenures (42%) overlapped with areas designated as Old Growth Management Areas (OGMA’s). One of these tenures was not active. In five of the active tenures with OGMA’s the disturbance recorded was quite small (<1ha each) or outside the OGMA, but the other four had disturbed areas ranging from 3 ha to 28 ha.

•    The invasive plant species knapweed was identified in disturbed areas at one of the tenures.

4.3 Wildlife Habitat Areas and Ungulate Winter Ranges

•    Three of the 26 tenures (12%) were identified as overlapping with Wildlife Habitat Areas (WHA’s) or Ungulate Winter Ranges (UWR’s).

•    Two tenures overlapped with designated Mule Deer Winter Ranges (MDWR). One of these tenures did not have placer works within the winter range; in the one tenure with works within the MDWR the reclamation of placer mining disturbance was inadequate.

•    Two tenures overlapped with no-harvest WHA’s designated for mountain caribou. Only one tenure overlapping with a caribou WHA was active, and there was no activity in that area of the claim.

4.4 Non-compliance results

•    We forwarded by email the results of inspections and issue of non-compliance to MEMPR for fourteen of the placer sites.

•    We received responses and were notified of follow-up action by MEMPR in regard to five of these inspections.

•    MEMPR follow-up actions included stop work orders, letters of reprimand, reclamation orders, and orders to undertake other site specific remediation action including removal of fish from settling ponds and engineering reports for settling pond stability. To our knowledge these actions were taken based on our reported inspections results, not on inspections undertaken by the mines inspectors.

5.0 Discussion

In a large proportion of the inspected placer sites the submitted NoW’s did not accurately reflect the works that were undertaken on the ground.  Seventy-four percent of the audited active tnures were not in compliance with their submitted NoW. These results suggest disregard or indifference among the audited placer operators with regard to NoW reporting requirements. These results indicate that individual office review and comment by MoE staff was not an effective means of assessing potential impacts from these operations .

Based on the results of this audit the highest risk of environmental impacts associated with placer operations in the Cariboo is to aquatic, fish, and riparian habitats. This is not entirely surprising given the inherent association between placer deposits and watercourses. To fully appreciate the gravity of these threats, the values provided by healthy riparian areas and areas designated as Critical Fish Habitat need to be recognized.

Riparian zones are a complex, dynamic interface between aquatic and terrestrial environments involved in the transfer of water, sediment, nutrients, organic matter, and heat both vertically and horizontally over different time scales.  Riparian zones are particularly sensitive to disturbance and they support many highly valued resources. Healthy riparian areas have high species richness; provide wildlife habitat and travel corridors, as well as supporting aquatic ecosystems through several functions.  Riparian vegetation contributes to bank stability, influences factors that contribute to microclimate such as air temperature, solar radiation and wind speed. It maintains water quality by intercepting sediment and nutrients, regulates water temperatures, and contributes organic matter that provides the primary form of energy for stream food webs (Pike et al, 2010)

Critical Fish Habitat areas are designated areas of exceptional habitat determined by regional fisheries experts to have particular value for spawning or rearing of anadromous salmon, kokanee, bull trout and rainbow trout (Hoffos, personal communication, April 22, 2011) These areas have been identified as requiring additional riparian protection for maintenance of water quality, base flows, channel morphology, stream temperature and organic inputs. Areas designated as Critical Fish Habitat include specific watercourses adjacent to main channels within floodplains, as well as backchannels, oxbows, wetlands, and ground water sources connected to the main watercourse, which provide exceptional habitat for juvenile salmonids (Integrated Land Management Bureau, 2007)).

The audit results show a low rate of compliance (43%) with the 10m placer riparian setback reserve. At more than half of the placer operations inspected (57%) works had been conducted within 10m of the high water mark of a stream. These works included: removal of riparian vegetation; blading of trails; deposit of excavated materials; and road and camp construction. On some tenures these infringements into the riparian reserve area extended along several hundred meters of stream bank, significantly and permanently altering the structure and function of the riparian corridor within the mine area. It generally appeared that the 10m setback boundary was recognized by operators but that they were often tempted to push the limits.  Rather than the 10m reserve being considered by operators as a minimum setback it appears to be used as a target to aim for (and not always met).

The high incidence of unauthorized in-stream works on ten of the twenty-three active placer tenures (43%) is also of high concern, particularly given that every one of these tenure holders specifically checked off NO in Section 9 of their NOW application where it asks Are you proposing changes in or about a stream (bridges, culverts, pipelines, dams, stream diversions, etc)? A though it was apparent in some cases that instream and riparian works have occurred historically at these sites, this does not justify or lessen the impacts of undertaking such works under current conditions and regulations.

The discharge of wastewater from 35% of the active placer operations is also cause for concern particularly given that in Section 10 of the NoW it specifically asks: Is your operation planned for zero discharge, and all of these tenure holders checked off YES. Furthermore, the NoW explicitly defines  that zero discharge means no water is released back into a stream either through a pipe, an overflow, by pumping, or by visible seepage through an impoundment.

These results are of even higher concern considering that 43% of the active tenures inspected in the audit occupied areas designated as Critical Fish Habitat. Although many of the areas occupied by placer tenures may have been mined in the past, the recurring disturbance to riparian areas and watercourses precludes the natural recovery of historically impacted streams, and diminishes their potential to provide fish and wildlife habitat components and ecosystem services.

At two operations fish were observed in settling ponds and at two more placer sites settling ponds were connected with fish bearing streams making it highly likely that fish would be present in these as well. Instances of fish inhabiting placer mine ponds are not particularly unusual as fish have been noted in placer ponds at several other operations within the region in recent years. The presence of fish in settling ponds indicates a lack of understanding among placer operators in regard to fish habitat and fish passage. There appears to be a lack of understanding or acceptance within the placer mining community that areas of seasonal inundation provide important fish habitat.

Inadequate reclamation and unreported disturbance areas on placer mine tenures were also key findings of the audit. It was not possible to thoroughly assess reclamation of the current years work on tenures where the NoW indicated it was to occur at the end of the season. However the recurrent trend was that previously disturbed areas including trenches, test pits, access trails/ roads/ and settling ponds were not adequately reclaimed. Large (sometimes massive) unreclaimed piles of coarse rock and gravel were common at the larger placer operations. We also found that there was often ongoing or new disturbance in areas recorded on NoW’s as previously reclaimed. Similarly it was common for exploration work, sampling, and trail clearing to occur in areas where it was not reported on the NoW. Often these unreported works were undertaken in areas of high environmental sensitivity such as riparian areas, ephemeral stream beds, wetlands, or along steep slopes.

A lack of topsoil conservation was noted at several placer sites, though this was not specifically assessed during all inspections. Without organic matter and nutrients from conserved soil, reclamation of denuded and excavated tracts of land will be ineffective and revegetation will takes decades longer. The cumulative impacts of large disturbance areas associated with unreclaimed placer operations and a lack of topsoil conservation, present a long term loss of wildlife habitat and potential chronic sediment sources. This is of particular concern in areas where specific habitat values have been identified such as in UWR’s, WHA’s, and critical fish habitat.

A placer inspection in the Likely area was conducted by Fisheries and Oceans Canada and Ministry of Environment in 2001 with results reported by Fisheries and Oceans Canada to MEMPR and MoE (see Appendix 4). Similar issues raised in that inspection were also identified in the 2010 audit; including unauthorized in-stream works, works within fish habitat, discharge to water courses, large disturbance areas, and encroachment into the 10 metre riparian reserve. The 2001 inspection also noted many claims lacked any or effective reclamation. In comparing the results of our 2010 audit inspections with the Fisheries and Oceans Canada 2001 inspections and 1995 file information we noted a recurrence of the same compliance issues at the same placer sites and among the same operators.

•    At one site removal of riparian vegetation and encroachment within the 10m. riparian reserve continued to occur under the same operator in 1995, 2001 and 2010 (Fisheries and Oceans Canada, 1995a)

•    A separate proponent had been warned by Fisheries and Oceans Canada about working within the 10m riparian reserve in 1995 (Fisheries and Oceans,1995b) and yet was found to be operating equipment within 5 metres of the Cariboo River in 2010 and created a skid trail within 10 metres of the river for a distance of 75 metres.

•    At this same site, Fisheries and Oceans Canada had requested a 50 metre setback in 2001 (Pow, e-mail communication, January31, 2002), and Ministry of Environment had requested a 50 metre setback in 2010 (Ludwig, e-mail communication, March 23, 2010), and both requests were turned gown by MEMPR.

•    At another site, the proponent was warned about removing riparian vegetation and operating within the 10 metre riparian reserve in 2001, yet had excavated a wetland in 2010.

•    On another site the proponent had gained access to a settling pond in 2001 and again in 2010 (Fisheries and Oceans Canada, 2001).

6.0 Conclusions and Recommendations

Placer mining is often considered a low priority, low risk industry due to what has been cited as a very small environmental footprint associated with these “Ma and Pop” operations. Within the Cariboo region, this is not an accurate assessment of the placer mining industry. The results of this audit provide evidence that placer mining in the Cariboo region is often undertaken in high value riparian areas and that environmental risks are considerable. The potential cumulative effects on aquatic resources are particularly concerning, especially where placer mines interface with large, salmon bearing waters such as the Cariboo, Quesnel and Swift Rivers. Furthermore, the size and types of disturbance associated with placer mining are greater than perceived or reported.

The practices of placer miners observed during this audit indicate that there is significant potential for cumulative impacts to watercourses, and riparian habitat associated with placer mining in the Cariboo region.  This is particularly concerning given the extensiveness of placer mining along major salmonid producing streams in this region of the province. Potential impacts include: increased sedimentation; altered water quality; reduced contributory flows; increased water temperatures; as well as reductions in riparian vegetation providing shade, litter, invertebrate habitat and long term large woody debris contributions. Fish and aquatic habitat alterations resulting from unauthorized instream works are also of concern given the high number of these occurrences uncovered in this audit.

Currently there is very little environmental regulation for placer operations outside of specific permit conditions which are at the discretion of the permitting agency, and which are only enforceable by Mines Inspectors. Government officials not designated as Mines Inspectors do not have the authority to enter placer tenures without permission of the mine manager. The results of this audit (and the previous Fisheries and Oceans Canada inspection from 2001) indicate that placer mine compliance with NoWs is very poor and that environmental impacts are ongoing.

There must be a coordinated and cooperative approach among resource agencies to address the impacts of placer mining within the Cariboo region. The first step will be a common recognition among resource agencies that current placer mining practices have the potential to seriously impact high value habitats and important resources, and it is therefore in the public interest to improve industry practices. Provincial regulation of placer mining needs to be brought up to standards that are comparable for other permitted resource users on the land base, and are consistent with all provincial and federal legislation.

To address the current and potential impacts of placer mining it is recommended that the following measures be implemented:

1.    Develop a  coordinated interagency compliance and enforcement plan for monitoring placer tenures in regard to fish and riparian resources, wildlife habitat restoration, Water Act compliance, reclamation, soil conservation and invasive weed control.

2.    Establish authorities to enable enforcement of placer mining standards by other agencies including the Conservation Officer Service and FLNR Compliance and Enforcement staff.

3.    Ensure the standards previously provided regionally by Ministry of Environment to Mines staff in the May 26, 2010 letter (Appendix 2.) are incorporated into placer mining permit conditions.

4.    Develop simple BMPs and guidance regionally for distribution and outreach to placer miners by Mines Inspectors and compliance and enforcement staff.

5.    Apply for renewal of the placer No-Staking Reserve within the Horsefly River Watershed for a minimum of ten years.

6.    Recommend the development of provincial standards and guidelines for the placer mining industry, in conjunction with Fisheries and Oceans Canada.

6.1 References

Chapman Geoscience Ltd., Dobson Engineering Ltd. (1997) An Inventory of Watershed Conditions Affecting Risks to Fish Habitat in the Cottonwood, Cariboo and Horsefly Watersheds. Prepared for Cariboo Region Interagency Committee by Chapman Geoscience Ltd. And Dobson Engineering Ltd, November 1997. URL: https.//al00.gov bc.ca/pub/acal/public/viewReport.do?reportld=8420

Ministry of Employment and Investment (1997) Memorandum of Understanding between the Ministry of Employment and Investment, the Ministry of Forests and the Ministry of Environment, Lands and Parks respecting Placer Mining Activities in Riparian Ecosystems on Crown granted claims and tenures administered by the Ministry of Employment and Investment. July 21, 1997.

Ministry of Energy and Mines (2009) Handbook for Mineral and Coal Exploration in British Columbia :A Working Field Guide. 2008/2009 Edition. URL: http:/www.offshore-oil-and-gas.gov.bc.ca/Mining/Exploration//Pages/Handbook.aspx

Fisheries and Oceans Canada (1995a) Inspection report from, October,1995; letter November 10, 1995. File # 8450-6-5/Placer Mine, Keithley Creek.

Fisheries and Oceans Canada (1995b) File notes, reference 264926, File# 8450-6-10, Placer Mine, Cariboo River.

Fisheries and Oceans Canada (2001) Placer Mining Inspection Report, May 15, 2001. File 366386

Government of British Columbia (1995) The Cariboo-Chilcotin Land-Use Plan: 90-Day Implementation Process Final Report. February 15, 1995.

lntegrated Land Management Bureau (2007) Cariboo-Chilcotin Land Use Plan: Quesnel Sustainable Resource Management Plan. Retrieved April 28, 2011. URL:
http://www.ilmb.gov.bc.ca/slrp/srmp/north/quesnel/index .html

Newell (2011) The Canadian Encyclopedia: Gold Rushes & Cariboo Gold Rush. Retrieved April 14, 2011. URL: http://www.thecanadianencyclopedia.com/index.cfm?PgNm=TCE&Params=A1ARTA0003299

Pike, R.G., T.E. Redding, R.D. Moore,  R.D. Winker and K.D. Bladon, editors (2010) Compendium of forest hydrology and geomorphology in British Columbia.  B.C. Ministry of Forests and Range, Forest Science Program, Victoria, B.C. and FORREX Forum for Research and Extension in Natural Resources, Kamloops, B.C. Land Manager. Handbook. 66. URL:

Appendix 1.Maps
Appendix 2. Letter to MEMPR

File:   58000-30/Mines

May 26,2010

Regional Director
Ministry of Energy, Mines and Petroleum Resources
162 Oriole Road
Kamloops BC  V 2C 4N7

Dear Joe Seguin:

As a result of decreased staffing capacity within the Cariboo Region Ecosystems Section, in conjunction with the increase in placer mine referrals that are being received at our office, we will no longer be able to review and respond to all placer NOW referrals.  We are expecting that MEMPR will continue to refer placer NOWs to our office for information purposes. It is our intention to allocate available resources this field season to monitoring and reporting out on placer activities within the region.

In order to reduce impacts to high value habitats that we consider to be at greatest risk from placer operations it is our expectation that the following minimum standards be followed:

Ungulate Winter Ranges and Wildlife Habitat Areas

Placer tenure operations located  within Wildlife Habitat Areas (including Caribou WHAs) or Ungulate Winter Ranges should conduct activities consistent with the General Wildlife Measures designated by GAR Order under FRPA. Where activities are proposed in an UWR or WHA that are not consistent with the GWMs, placer tenure holders are required to apply for an exemption from the Ministry of Environment, and should provide such an exemption to Ministry of Mines prior to issuance of a work permit.

Riparian, Old Growth, and Fish Habitat Protection

All placer mine activities must comply with the Federal Fisheries Act and the Water Act.  In stream works and works less than 10m from the high water mark of any watercourse (including seasonal streams, wetlands, lakes and rivers) should not be permitted. For water bodies which provide fish habitat, greater setback distances may be required in order to ensure compliance with the Fisheries Act.

Camps, road access, and settling ponds should be developed at least 30m from the high water mark of watercourses, to minimize long-term disturbance and impacts within riparian areas.

Areas designated as Critical Fish Habitat under the Cariboo-Chilcotin Land Use Plan have been identified in consultation with Ministry of Environment and Fisheries and Oceans Canada, as requiring additional riparian setbacks to adequately protect valuable fish habitat.  This should be reflected in the placer permit conditions for operations in these areas.  At a minimum, 30m setbacks from the high water mark should be required in these areas.

Timber harvesting should be avoided in areas identified in the CCLUP as Critical Fish Habitat or Old Growth Management Areas.  These digitally mapped layers are available through the Land and Resource Data Warehouse.

Mining activities must not result in sediment delivery into fish bearing waters, or harmful alteration, destruction, or disruption to fish habitat.  This includes sediment delivery resulting directly from mining activities, or indirectly such as from runoff erosion on undisturbed areas or roads.

Settling ponds must not be allowed to connect or discharge into natural waterbodies at any time, as this may result in fish migration into settling ponds. Where there is any indication that settling ponds have been breached or that fish may be present in settling ponds, an assessment and fish salvage conducted by appropriately qualified environmental professionals should be required prior to allowing further works.

In the absence of complete fish inventory data, streams should be considered fish bearing unless proven otherwise by an accepted methodology conducted by appropriately qualified professionals.

Stream crossings utilized for access to placer operations must be constructed and maintained consistent with the Federal Fisheries Act, the Water Act, and FRPA. The Forest Practices Code Fish Stream Crossing Guidebook
( http://www.for.gov.bc.ca/tasb/legsregs/fpc/FPCGUIDE/FishStreamCrossing/FSCGdBk.pdf ) must be utilized for best management practices regarding constuction of stream crossings. Stream crossing structures must provide for fish passage during all flow conditions. In general, only open bottomed structures should be utilized for crossing fish streams. Where stream crossings are required, a Notification for Changes In or About a Stream application must be submitted to MOE (available at
http://www.env.gm.bc.ca/wsd/water_rights/licence_application/scction9/index.html ).

Given the vicinity of many placer tenures to fish bearing lakes and streams, bald eagle and osprey nests may be present.  Bald eagle, osprey nests and any occupied bird nest are protected under the BC Wildlife Act and should not be removed or disrupted .

Site Disturbance and Reclamation

Site disturbance should be limited to the minimum area required to carry out placer activities and topsoil and organic matter should be stockpiled for reclamation.   Reclamation activities should be carried out promptly and effectively utilizing conserved topsoil to establish site stability, minimize surface erosion, and prevent sediment delivery.

Reclamation activities should include recontouring of disturbed areas similar to pre-disturbance shapes with re-establishment of natural gullies and swales so that surface drainage patterns are re-established. Compacted surfaces should be ripped to allow normal water infiltration and growth of vegetation.

Once the disturbed sites have been regraded, soil materials salvaged prior to the construction of the site should be replaced. Applied soils should :

•    be rough and loose with many microsites (small depressions) for seeds to lodge in and germinate;
•    be keyed into the materials under the soils so that they do not slide or slump off;
•    incorporate roots, stumps and other woody debris to reduce erosion and create greater biological diversity; and
•    be revegetated promptly.

Revegetation should include grass seeding with a non-sod fanning seed mix to establish a quick ground cover, and prevent erosion and weed invasion. In addition, native trees and shrubs should be planted to establish a suitable, self-sustaining vegetation cover such as existed prior to disturbance.


For general guidance and best management practices regarding mining activities we recommend that placer operators refer to the Handbook for Mineral and Coal Exploration in British Columbia.

Yours truly,

John Youds, section head
Ecosystems Branch
Cariboo Region

Cc:    Rodger Stewart, Regional Manager, Cariboo, Thompson, Okanagan
Bruce Hupman, Ministry of Energy, Mines and Petroleum , Kamloops Region
Byron Nutton, Fisheries and Oceans, Prince George

Appendix 3. Field Inspection Form

Inspection Date: Inspection #:

Inspected by:
Placer Claim or lease#:

Road Location: UTM: 10 U

Tenure  holder:  Present at inspection: Yes    No

Identified  Values

Watercourses in vicinity :


Designated Critical fish habitat?:  Yes No

Wildlife Habitat Area:Yes    No

Ungulate Winter Range : Yes No

OGMA: Yes    No

Inspection Findings

NOW is accurate:    Yes    No

What is differing from NOW:

Area of disturbance:


Timber harvesting: Yes    No

Distance of works from watercourses:

Fish screens?:

Issues identified:

MEMPR notified:

Appendix 4. Fisheries and Oceans 20011 Inspection

and Oceans

Pacific Region
Habitat and Enhancement  Branch
Fisheries and Oceans Canada
310A-North Broadway
Williams Lake, B.C V2G 2Y7

August 14, 2002

Mr. Ken MacDonald
Inspector of Mines
Ministry of Energy and Mines Mines Branch
3990 22nd Ave
Prince George, B.C.
V2N 3A1
File No: 8450-6

Dear Mr. MacDonald:

Subject: Regulatory Action Update Request – Placer Mining Operations in the Cariboo Region

As a follow-up to the joint agency Placer Inspection which occurred in the spring and summer of 2001 Ministry of Energy and Mines provided our office with copies of “Report of Inspector of Mines” inspection forms. Each Mines Inspection Report requires that the site’s owner respond in writing how they will address the issues of concern as identified by the Mines Inspector.  Of the 9 inspection reports received, the Department of Fisheries and Oceans Canada (DFO) has specific fish and fish habitat concerns (specifically Fisheries Act sections 35(1), harmful alteration ,disruption, destruction and 36(3), deposit of a deleterious deposit) for the 5 inspected sites listed below.  We request that a written follow-up report be provided which details how each concern related to the protection of fish and fish habitat was/is being adequately addressed.

In addition, DFO continues to have concerns (based on the 2001 field monitoring inspections) associated with impacts to fish and fish habitat on the additional sites listed below (some of which were previously identified to Ministry of Energy and Mines in the winter of 2000 via a DFO report titled “Inventory 2000 of Placer Site Concerns In the Williams Lake DFO Area“).  Written comments with respect to how the Ministry of Energy and Mines will be addressing DFO concerns (specifically Sections 35(1) and 36(3) of the Fisheries Act should be provided for the sites identified in the attached table (Appendix 1). Any updates you can make to the tenure number and owner/operator information would be appreciated.

We look forward to being involved in the continued evaluation of proposed works and future remedial action items as required. If you wish to discuss proposed mitigation options, or you have any other questions, please contact the undersigned at telephone # 250-305-4018.

Sincerely yours,

Guy Scharf
Fisheries Technologist
Fisheries and Oceans Canada, Williams Lake

Cc:    Jim Michie, Conservation and Protection DFO Williams Lake
Don Lawrence, Fisheries Technologist DFO Williams Lake
Rob Dolighan, Ministry of Water, Land and Air Protection Williams Lake (via email)
Bill Klopp, Land & Water B.C. Inc Williams Lake (via email)
Andrew Anaka, Ministry of Water, Land and Air Protection Conservation Services Williams Lake (via email)

Appendix 1:

Placer Mining Sites Requiring Remedial Action to Comply

With Habitat Protection Sections of the Federal Fisheries Act


About Webmin

Male. Age 69. Married. Writer/Publisher/Musician/Builder/Gold Miner

Posted on November 19, 2012, in Mining News & Views and tagged . Bookmark the permalink. Leave a comment.

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