"September 30, 2010 Peel Watershed Planning Commission Government of Yukon P.O. Box 2703 Whitehorse, Yukon Y1A 2C6 Submitted online via http://www.peelconsultation.ca/Discussions/General.aspx Re: Areas Proposed to be Withdrawn from New Oil and Gas and Mineral Development On behalf of the 300 corporate and 4,000 individual members of the Association for Mineral Exploration British Columbia (AME BC), I welcome the opportunity to comment on the Recommended Peel Watershed Regional Land Use Plan. Even though AME BC is clearly a BC based association, we have many members that live in Yukon and/or are actively exploring for mineral deposits in Yukon. As such, AME BC has serious concerns regarding the recommendations of the Plan, primarily due to the proposed removal of 80% of lands open to new mineral or oil and gas activities. Removing such a vast area will negatively affect the mineral exploration and development sector both in Yukon and throughout the rest of Canada, including your neighbours in BC. AME BC works with governments, communities, and stakeholders to maintain access to land for mineral exploration that benefits everyone. Minerals are a hidden resource. Our association believes that the unknown value of mineral potential should be properly evaluated and should always form part of an informed discussion about land access and use. The proposed restrictions in the Plan pose several challenges for our members. AME BC is particularly concerned that the amount of land that may be closed to claim staking in Yukon will increase from 14.5% to 25.8% if the recommendations in the Plan are adopted and that an area the size of Nova Scotia will be removed from staking in the Peel watershed. There are at minimum 219 known mineral occurrences and 13 known mineral deposits in the Peel watershed that are currently underexplored. Although the Plan protects existing mining claims in Special Management Areas (SMAs) and allows new mineral claims in Integrated Management Areas, the conditions of operation and removal of new surface access in SMAs as proposed will render the majority of these claims unworkable. The Plan suggests alternatives to ground and airstrip access for industrial development; however, the reality of the industry is that should a mineral deposit proceed to development, ground access will be required to transport materials and people to and from the mine site, particularly if no new airstrips are permitted. Furthermore, the proposed ban on uranium development throughout the Plan area is based on subjective public opinion, and is not based in science. Mineral claim holders that are no longer able to work their claims due to restrictions of either an access or mineral nature will seek compensation from government, and the issue of compensation must be considered fairly in any land use planning exercise that restricts or bans activity. AME BC supports and promotes a safe, modern, environmentally responsible mineral exploration and mine development sector that co-exists with other land uses. We support land use plans that engage First Nations, communities, and stakeholders and build certainty on where mineral exploration and mine development can occur. Given that there are six land use plans to follow the Peel Watershed Planning process in Yukon and considering the removal of 16 out of 21 Landscape Management Units from new mineral exploration and mine development in the Peel plan, we are very concerned that this plan does not accommodate all stakeholders and may set a precedent for exceedingly high levels of protection in Yukon. If principles in the Recommended Peel Watershed Regional Land Use Plan are carried over to other regions in Yukon, these could threaten the sustainability of the mineral exploration and development industry, which now contributes $200 million annually to the Yukon economy after years of struggling to re-establish itself in such a high mineral potential jurisdiction. Land use planning can build certainty for First Nations, communities, and stakeholders, but such planning should be balanced with the federal and territorial legislation already in place to ensure the integrity of the Peel watershed. Furthermore, should a mineral exploration project proceed to development, the Yukon Environmental and Socio-economic Assessment Board is legislated to review projects and ensure that they proceed in a socially, environmentally, and economically responsible manner. AME BC proposes that integrated land management, that allows both ground and air access, should take precedence in the plan and that the large majority of the Peel watershed should remain open to mineral exploration and potentially mining. Thank you for your serious consideration of AME BC’s recommendation to continue to allow new mineral exploration and mine development, and required access, throughout Yukon’s Peel watershed. Sincerely, Gavin C. Dirom President & Chief Executive Officer Association for Mineral Exploration British Columbia cc: Yukon Chamber of Mines AME BC Board of Directors"