From: Christopher O'Brien [chrisnt@mac.com]
Sent: January 8, 2009 10:14 AM
To: lpayette@nirb.ca
Cc: nwtadmin@cpaws.org
Subject: Uravan Garry Lake Project, NIRB File 08EN037

Follow Up Flag: Follow up
Flag Status: Red

Dear Ms. Payette,

I am writing to voice my concern about the impact of the expansion of uranium exploration in the core Beverly caribou calving ground, and in particular, the Uravan Garry Lake Project.

In November the Beverly and Qamanirjuaq Caribou Management Board (BQCMB) called for increased protection of the Beverly herd after members learned from the Government of the Northwest Territories that the herd appears to have decreased significantly in size.

Evidence presented at the BQCMB’s meeting in Winnipeg showed that the numbers of adult female caribou (cows) seen on the Beverly calving ground during June systematic reconnaissance surveys dropped from 5,737 in 1994 to 93 in 2008, and that very few calves were seen during the
2008 survey – only 15 calves for every 100 cows. In comparison, usually about 80 calves for every 100 cows are seen on the calving grounds of healthy barren-ground caribou herds near the peak of calving, as was the case with the Bathurst herd in June 2008.

I suggest that NIRB should not allow activities that will cause additional stress to the Beverly herd while the population is in such a vulnerable state. This means that mineral exploration should not be allowed on the Beverly caribou calving ground.

I don't think it is enough for NIRB to claim, as is standard mining industry practice, that exploration activities have a very small footprint and can be carried out at times of the year when caribou not present. The fact is that if economically viable deposits of uranium or any other mineral are found within the calving ground, companies will demand that they be allowed to develop such deposits, as is their right under the existing (but to my mind environmentally disastrous) laws. 
Surely it is best simply not to allow exploration within a calving ground in the first place.

I believe that if the caribou herds of Nunavut are to be adequately protected in the long term, then the only logical approach for government to take is not to allow industrial development of any kind within a calving ground. The risks of such activities are simply too great, especially when a herd like the Beverly is already significantly stressed by other changing ecological conditions such as climate change.

I recommend that NIRB should refuse Uravan's application, and that a policy be developed by the Government of Nunavut that no industrial development activities be allowed to occur within caribou calving grounds.

Yours sincerely,
Chris O'Brien
Yellowknife