Please see the following direction from the Chief Permitting Officer:
There has been a recent update made to the Regional Mine Reclamation Bond Calculator Guidance Document (the Guidance). The change surrounds the requisite level of reclamation effort required on existing roads that are used by proponents to access exploration sites and it provides additional clarity on the intent of the Guidance.
In summary, Mines Inspectors still have the discretion to require additional reclamation where there are extenuating circumstances that warrant this, and where there is a clear rationale for doing so. However, the default course of action will be to ensure that roads are left in the condition they are found, while managing any site-specific water management, erosion, or stability concerns.
More specifically
The April 2018 version of the Guidance included the following paragraph on page 9:
Figure 1 indicates that deactivation as defined in Part 9.10.1(6) of the HSRC may be an acceptable level of road closure and release from reclamation obligations only in situations where it involves a main access route that connects to other resource values and is expected to be used after current authorization or project is completed and other extenuating circumstances or risks do not apply.
The March 2021 version of the Guidance includes the updated paragraph on page 9 as follows:
Figure 1 indicates that deactivation as defined in Part 9.10.1(6) of the HSRC may be an acceptable level of road closure and release from reclamation obligations in some situations. Deactivation needs to be properly scaled according the level of risk and the expected future use of the road. For historical or non-status roads that are used by other non-industrial users, they should be left “as is” as much as possible while managing any specific water management or stability concerns.
In addition, the changes in red below have been made to the relevant text in Figure 1:
Deactivate only to level needed to ensure road stability and erosion control (as per Part 9.10.1(6) or Part 10 of Code) and without rendering the road impassable.
View the updated document.