Chief Ross Montour
Consultation Portfolio Chief
Ms. Brittany Diabo
Consultation Committee Technician
Mohawk Council of Kahnawà:ke

Dear Chief Montour,

Thank you for your letter dated July 29, 2020, requesting the conduct of a Regional Assessment in the St. Lawrence River area under Subsection 97(1) of the Impact Assessment Act (the Act).

Upon receipt of your request, the Impact Assessment Agency of Canada (the Agency) initiated a review taking into consideration the principles laid out in applicable guidance related to requesting such an assessment. Following careful consideration and analysis of your request, I have determined that there are potential merits of conducting such a regional assessment for various reasons, including:

  • A regional assessment could inform future project-specific federal impact assessment decisions

    There are current and foreseeable proposals for port infrastructure and other physical activities in the St. Lawrence River area that may be subject to impact assessment under the Act. A regional assessment could inform and contribute to the effectiveness and efficiency of these future assessments.

  • There is potential for effects from development within federal jurisdiction, including cumulative effects, in the region.

    Potential effects within federal jurisdiction from anticipated development include, but are not limited to, adverse effects on fish and fish habitat, wildlife listed under the Species at Risk Act and changes to the environment that could affect the Indigenous peoples of Canada.

  • There is the potential for impacts, including cumulative impacts, to the rights of Indigenous people in the region.

    Through previous and on-going project assessment processes, the Agency has heard from Indigenous groups in the area that current and proposed developments may, both individually and cumulatively, impact Indigenous rights, traditional lands and resources, socioeconomic conditions, health and community well-being.

  • There are opportunities for collaboration with jurisdictions, and for the involvement of others in the regional assessment.

    There are potential opportunities to collaborate with the Province of Quebec and to involve Indigenous groups, non-government organizations and others in the planning and conduct of a regional assessment.

  • There has been considerable public interest related to development or cumulative effects in the area.

    In addition to your request, I have received letters of support from the Grand Council of the Waban-Aki Nation, the Huron-Wendat Nation and the Montreal Port Authority for a regional assessment in the St. Lawrence River area of Quebec. Further, during consultations on recent port projects in the area, the Agency received submissions expressing concern related to development and cumulative effects, as well as support for a regional assessment in this area.

As noted above, I see potential merit in conducting a regional assessment under the Act in the St. Lawrence River area, as a means to help inform and improve the effectiveness and efficiency of future project assessments.

I am also of the view, however, that it would be beneficial to undertake further analysis and to have associated discussions with the Mohawk Council of Kahnawà:ke, the Province of Quebec and other parties to explore this further, and to help define the nature, scope, objectives and outcomes before a decision is made to move forward with a regional assessment.

As a result, I have directed Agency officials to initiate an engagement process over the coming months with federal and provincial government agencies, the Mohawk Council of Kahnawà:ke and other Indigenous groups, and other non-governmental organizations to discuss these matters. I have asked officials to provide me with the results of these discussions by spring 2021.

Thank you again for your letter and for suggesting this regional assessment, and we look forward to your on-going participation.



The Honourable Jonathan Wilkinson, P.C, M.P

Document reference number: 6

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