As an advocate for successful mineral exploration, AME is seeking member feedback on several policy developments. With your input, AME aims to work with governments in implementing existing policy and informing new policy that benefits mineral explorers.
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Canadian Exploration Expenses
AME has identified challenges with how the Canadian Revenue Agency (CRA) is assessing and auditing Canadian Exploration Expenses (CEE) that are eligible for BC Mining Flow-Through Share Income Tax Credits or the BC Mining Exploration Tax Credit. Similar challenges have also been identified by the Prospectors & Developers Association of Canada (PDAC), These include:
- Misunderstandings about the mineral exploration sector and legal (option) agreements between companies
- Different levels of expertise among auditors regarding CEE, leading to inconsistencies and situations where those being audited are training the auditors
- Speculation that audits disproportionately affect BC-based issuers.
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Some interim measures companies can take include:
- Have proper documentation that separates classes of expenses – ensure that contracts, invoices and reporting distinguish CEE from Canadian Development Expenses (CDE) and operational expenses.
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What action members can take
We are seeking input from members who have experienced challenges with the interpretation of CEE by CRA. Please share these challenges with AME so we can work with government officials to pursue possible solutions. Contact Rob Stevens at 604.630.3926 or
rstevens@amebc.ca
.
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We have heard of several examples throughout the BC interior where members are unable to access mineral tenure because of road closures without notification, or only when deactivation is imminent. We recognize that road deactivation may benefit preservation of ecological values and reduce user liability. However, given the time required to discover and assess hidden mineral resources, certainty regarding road access is fundamental to mineral exploration.
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What action members can take
Keep AME informed regarding any road closures that affect your tenure, as well as your experiences with other road users. Contact Jonathan Buchanan at 604.630.3923 or
jbuchanan@amebc.ca
.
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We urge that the province provide early notice to users when deactivation is contemplated and provide opportunities for users to collaborate and suggest alternatives to full deactivation where practical. Many users have limited resources for maintaining roads, although this infrastructure is critical to the use and enjoyment of the land. We welcome an approach that provides time and a structure for multiple parties (e.g. First Nations, mineral tenure holders, recreational users) to collaborate on approaches to road maintenance that is managed by the province. For more information and background, please read
AME’s post from July
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AME and SEG Regional Policy Form
Date
: Monday, October 21
Time:
5.30 - 7.30pm
Location:
SEG Rock Room,
#101 3424 Fulton Avenue, Smithers
Summary: The forum will provide a venue for open discussion on key issues facing mineral explorers in Northwest BC.
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Provincial Policy Developments
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Mines Act
Intentions Paper: Regulatory Excellence and Continuous Improvement in the Mining Sector
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Mineral Titles Information Update No. 38 – Permissible Activities without a
Mines Act
Permit
With input from AME and regional exploration groups throughout BC, the provincial government has released an Information Update on the scope of permissible activities that do not require filing a Notice of Work application for a
Mines Act
permit.
This document
posted on Mineral Titles Online provides specific guidance on the following:
- airborne geophysical surveying;
- baseline data acquisition, such as mapping, taking photos, and measuring water quality;
- ground geophysical surveying without the use of exposed electrodes;
- establishment of grid lines that either does not require the felling of trees or, where appropriate, a Free Use Permit to fell trees has been acquired;
- geological and geochemical (soil or rock) sampling conducted using hand-held tools;
- pitting, trenching, drilling, or channel cutting using hand-held tools.
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Water Sustainability Act – Water Use in Mineral Exploration and Small-Scale Placer Mining “What We Heard” Paper Released
In October 2018 government released an intentions paper on a proposal to regulate Water Use in Mineral Exploration and Small Scale Placer Mining proposal. Since then, government has worked to revise the proposal to address the items raised by Indigenous groups, industry representatives including AME, and other British Columbians. The Province has drafted a
What We Heard
document that summarizes the comments the received, provides additional information and outlines the revised proposal. As discussed in the paper, the province proposes a permanent allowance for water use in mineral exploration and small-scale placer mining without an authorization – including use in camps for up to 20 people, subject to prescribed restrictions.
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AME has recommended that public companies with below $100 million in revenue be exempt from new policy that would cap preferred tax treatment of employee stock options at $200,000. If accepted, this policy would continue to provide mineral exploration companies with a full suite of mechanisms for attracting and retaining skilled talent in a capital-constrained industry.
See more information
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AME has recommended that provincial reviewable project threshold criteria are applicable only for projects have the potential for adverse effects and thus should undergo an EA, and where EA will add value beyond the rigorous regulatory processes required in the Mines Act and other provincial acts and regulations.
See more information.
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