Lake Manitoba and Lake St. Martin Outlet Channels Project

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Attachment Fisher River Cree Nation - Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Fisher River Cree Nation
  • Reference number: 289
  • Submitted: 2024-06-18 - 12:52 PM
  • See the attached submission / Veuillez consulter la pièce ci-jointe   
  • Attachment included
  • <Signature removed> <Signature removed> <Signature removed> <Signature removed>
  • Attachment included
  • DRAFT Chief and Council Briefing Note DATE: MAY 8, 2024 SUBJECT: COMMENTS ON IMPACT ASSESSMENT AGENCY CANADA’S ENVIRONMENTAL ASSESSMENT REPORT FOR THE LMOC-LSMOC PROJECT ASSESSMENT REPORT EXCERPT Executive Summary In reviewing the potential environmental effects of the Project, the Agency also considered factors such as effects of potential accidents and malfunctions, extreme and periodic weather events, and cumulative effects in conjunction with other past, present, and reasonably foreseeable projects or physical activities. FISHER RIVER CREE NATION COMMENTS The cumulative effects assessments (CEA) are inadequate as noted by Fisher River Cree Nation (FRCN) numerous times. It is clear from the definition in the act and EIS guidelines that for any Valued Component (VC) that is assessed, the CEA must consider the past present and reasonably foreseeable future effects of other projects and activities regardless of the degree of potential effects of the Project alone. This has not been done by the Proponent. FRCN recommends that a condition of the federal authorization include a requirement for the Proponent to do a proper cumulative effects assessment in consultation with Chief and Council of FRCN. ASSESSMENT REPORT EXCERPT The Agency is of the view that, after taking into account the implementation of the key mitigation measures identified in this draft EA Report in relation to section 5 of CEAA 2012, the Project is likely to cause direct and cumulative significant adverse environmental effects on: • Indigenous peoples’ current use of lands and resources for traditional purposes, including from loss or alteration of access, effects to the availability ...
  • Attachment included
  • Chief and Council Submission DATE: MAY 8, 2024 SUBJECT: COMMENTS ON IAAC’S ENVIRONMENT ACT AUTHORIZATION CONDITIONS Chief and Council of the Fisher River Cree Nation are pleased to submit comments on the Impact Assessment Agency of Canada’s (the Agency’s) draft report of proposed conditions of federal environmental authorization. For ease of reference, FRCN has copied relevant sections of the Agency’s report and provided comments after each. EA AUTHORIZATION CONDITIONS – SECTIONS FROM REPORT 1 DEFINITIONS 1.24 Indigenous groups means …… 1.35 Proponent means Manitoba Transportation and Infrastructure and its successors or assigns. 1.43 Wetland means land that is saturated with water long enough to promote wetland or aquatic processes as indicated by poorly drained soils, hydrophytic vegetation and various kinds of biological activity which are adapted to a wet environment and as further defined in the Canadian Wetland Classification System. FISHER RIVER CREE NATION COMMENTS: Definition of Indigenous groups: FRCN would prefer “Indigenous nations” in place of “Indigenous groups”. Groups may refer to an ad hoc organization or group comprised of more than 50% Indigenous people. Furthermore, an Indigenous Nation has different rights and interests than those of a “group”. Definition of Proponent: The conditions in this document apply to the proponent i.e. Manitoba Transportation and Infrastructure (MTI). In this project, MTI is the Proponent but also an arm of government or the Crown. This should be explained in the preamble and made clear that the Proponent is also representing the Crown, and must therefore uphold the Honour of the Crown in its ...
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Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Interlake Reserves Tribal Council
  • Reference number: 285
  • Submitted: 2024-05-17
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • <Original signed by>
  • Attachment included
  • Interlake Reserves Tribal Council 1 Comment Table for the Draft Environmental Assessment Report (“the Report”) for the Lake Manitoba Lake St. Martin Outlets Channels Project (“the Project”) Please note, that all the requested changes and conditions do not constitute the IRTC’s support for the Project’s approval. These changes are requested with the intention of protecting our rights, interests, and the environment to the best of our ability; however, we strongly oppose the Project as it poses a severe risk to our rights, interests, environment, and the future of our communities. Review of draft Conditions document We have implemented a standardized means of review and revision. Suggested text deletions are identified using a strikethrough (strikethrough), and suggested textual additions are bolded (bolded). Item Sect., Pg. Topic Comment/ Issue Requested Change or Addition 1 1 2 General The temporal scope used in the EA focusses only on the construction period, not the long-term operation of the channels that will never be abandoned and restored to their original condition (IAAC states that the Project will operate “in perpetuity” on page 10). The IRTC rejects this approach to both temporal and spatial scope. As a result of the Project operating “in perpetuity”, all monitoring, reporting, follow-up, adaptive management, and compliance enforcement initiatives and conditions must be extended for the life of the Project (in perpetuity). This includes the explicit provision of funding of Indigenous programs, including monitoring and guardianship initiatives, for the entire life of the Project (in perpetuity). Please adjust language in all relevant conditions to reflect this ...
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Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Little Saskatchewan First Nation
  • Reference number: 286
  • Submitted: 2024-05-17
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • Little Saskatchewan First Nation 1 Table 2: Comment Table for the Draft Environmental Assessment Report (“Draft Report”) for the Lake Manitoba Lake St. Martin Outlets Channels Project (“the Project”) Please note, that all the requested changes and conditions do not constitute LSFN’s support for the Project’s approval. These changes are requested with the intention of protecting our rights, interests, and the environment to the best of our ability; however, we strongly oppose the Project as it poses a severe risk to our rights, interests, environment, and the future of our communities. The contents of this document are entirely without prejudice to our position that this project must not be allowed to proceed. # Section, page(s) Comment/ Issue Requested Change or Addition 1 General IAAC is maintaining the role of the EAC as the primary mechanism for Indigenous engagement if the Project is approved, but LSFN has repeatedly stated that the EAC as described is an unacceptable avenue for Project engagement activities. While the stated mitigations are an improvement on the structure of the EAC, there is so much bad history and distrust that the EAC itself needs to be dropped and a new structure needs to be developed. The issues with the EAC, which have been repeatedly shared with the Proponent across numerous reviews and letters, are myriad, and include but are not limited to the following: • The EAC is embedded with top-down processes, controlled by the Proponent and which allows for no meaningful decision- making on the part of Indigenous committee members • The terms of the EAC do not allow member Nations to contract their own outside consultants to assist in the review of ...
  • Attachment included
  • Little Saskatchewan First Nation 1 Table 1. Conditions Table for the Draft Environmental Assessment Report for the Lake Manitoba Lake St. Martin Outlets Channels Project – LSFN Comments Please note, that all the requested changes and conditions do not constitute LSFN’s support for the Project’s approval. These changes are requested with the intention of protecting our rights, interests, and the environment to the best of our ability; however, we strongly oppose the Project as it poses a severe risk to our rights, interests, environment, and the future of our communities. The contents of this document are entirely without prejudice to our position that this project must not be allowed to proceed. We have implemented a standardized means of review and revision. Suggested text deletions are identified using a strikethrough (strikethrough), and suggested textual additions are bolded (bolded). Item Sect., Pg. Topic Comment/ Issue Requested Change or Addition 1 1 2 General The temporal scope used in the EA focusses only on the construction period, not the long-term operation of the channels that will never be abandoned and restored to their original condition (IAAC states that the Project will operate “in perpetuity” on page 10). LSFN rejects this approach to both temporal and spatial scope. As a result of the Project operating “in perpetuity”, all monitoring, reporting, follow-up, adaptive management, and compliance enforcement initiatives and conditions must be extended for the life of the Project (in perpetuity). This includes the explicit provision of funding of Indigenous programs, including monitoring and guardianship initiatives, for the entire life of the Project (in ...
  • Attachment included
  • Little Saskatchewan First Nation May 8, 2024 SENT BY EMAIL Sean Carriere, Regional Director Prairie and Northern Region, Impact Assessment Agency of Canada Canada Place, Suite 1145, 9700 Jasper Avenue Edmonton, Alberta T5J 4C3 Email: sean.carriere@iaac-aeic.gc.ca, lakemanitoba-lakest.martin@iaac-aeic.gc.ca. Re: Little Saskatchewan First Nation Review of the draft Environmental Assessment Report for the Lake Manitoba and Lake St. Martin Outlet Channels Project Dear Mr. Carriere, We, the leadership of Little Saskatchewan First Nation (LSFN), are writing to you today to share our comments on the Impact Assessment Agency of Canada’s (IAAC or “the Agency”) draft Environmental Assessment Report (“the Draft Report”) for the Lake Manitoba and Lake St. Martin Outlet Channels Project (“the Project”) as well as of the draft conditions that will be recommended to the Minister of Environment and Climate Change (“the Minister”). Attached to this letter, you will find two tables: • Table 1 provides our detailed review of the proposed conditions (“the Conditions Comment Table”). • Table 2 provides our detailed comments on key areas of concern and interest contained in the Draft Report (“the Draft Report Comment Table”). We ask that you give all these materials sincere consideration and incorporate these findings into the final draft of the Report and recommended conditions. We look forward to meeting with the Agency to discuss how to implement our suggestions and resolve our outstanding concerns. If the Agency elects to not include some or all of our proposed conditions and mitigations in ...
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Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Pinaymootang First Nation
  • Reference number: 279
  • Submitted: 2024-05-16 - 2:27 PM
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • 1 Attachment 2: Comment Table for the Draft Environmental Assessment Report (“the Report”) for the Lake Manitoba Lake St. Martin Outlets Channels Project (“the Project”) Please note, that all the requested changes and conditions do not constitute SBOFN or PFN support for the Project’s approval. These changes are requested with the intention of protecting our rights, interests, and the environment to the best of our ability; however, we strongly oppose the Project as it poses a severe risk to our rights, interests, environment, and the future of our communities. The contents of this document are entirely without prejudice to our position that this project must not be allowed to proceed. # Section, page(s) Comment/ Issue Requested Change or Addition 1 1.2.2, p. 3 In Table 1 Value Components Identified, the list provided of First Nations who will be impacted by the Project with reserves on federals lands is incomplete. Many Nations are missing, including SBOFN. We recognize that the Project area falls on the federal lands / reserves listed in the table, however the environmental effects of the Project will be felt on reserves up- and downstream, and in the surrounding areas. The impacts will not be limited to the RAA. IAAC to add the following to this section: 1) Expand the list of potentially impacted Nations to ensure the environmental effects on reserve lands outside of the Project location are also acknowledged, considered, and protected. It is important to acknowledge all the First Nations who may be impacted by the Project (should it proceed) to ensure consultation and engagement is adequate, and to ensure that all Nations are respectfully involved in Project planning and ...
  • Attachment included
  • 1 Attachment 1. Conditions Table for the Draft Environmental Assessment Report for the Lake Manitoba Lake St. Martin Outlets Channels Project – PFN Comments Please note, that all the requested changes and conditions do not constitute PFN’s support for the Project’s approval. These changes are requested with the intention of protecting our rights, interests, and the environment to the best of our ability; however, we strongly oppose the Project as it poses a severe risk to our rights, interests, environment, and the future of our communities. The contents of this document are entirely without prejudice to our position that this project must not be allowed to proceed. We have implemented a standardized means of review and revision. Suggested text deletions are identified using a strikethrough (strikethrough), and suggested textual additions are bolded (bolded). Item Sect., Pg. Topic Comment/ Issue Requested Change or Addition 1 2.1, p. 4 General The intention of this condition is well received; however, as currently written it is not enforceable, measurable, or trackable. Concrete direction for MTI is required that includes language for commitments to work with PFN and IAAC to measure how it is meeting the conditions. Throughout the EA process, the Proponent has not integrated nor considered the knowledge and input that we provided and has taken an approach that disregards the precautionary principle. Additionally, "sustainable development" is not defined here, and First Nations, Manitoba Transportation and Infrastructure (MTI, “the Proponent”) and the federal government all have different perspectives on what this means. To PFN it is not sustainable to sacrifice the use of a ...
  • Attachment included
  • May 8, 2024 SENT BY EMAIL Sean Carriere, Regional Director Prairie and Northern Region, Impact Assessment Agency of Canada Canada Place, Suite 1145, 9700 Jasper Avenue Edmonton, Alberta T5J 4C3 Email: sean.carriere@iaac-aeic.gc.ca, lakemanitoba-lakest.martin@iaac-aeic.gc.ca. Re: Pinaymootang First Nation Review of the draft Environmental Assessment Report for the Lake Manitoba and Lake St. Martin Outlet Channels Project Dear Mr. Carriere, We, the leadership of Pinaymootang First Nation (PFN), are writing to you today to share our comments on the Impact Assessment Agency of Canada’s (IAAC or “the Agency”) draft Environmental Assessment Report (“the Draft Report”) for the Lake Manitoba and Lake St. Martin Outlet Channels Project (“the Project”) as well as of the draft conditions that will be recommended to the Minister of Environment and Climate Change (“the Minister”). Attached to this letter, you will find two tables: • Table 1 provides our detailed review of the proposed conditions (“the Conditions Comment Table”). • Table 2 provides our detailed comments on key areas of concern and interest contained in the Draft Report (“the Draft Report Comment Table”). We ask that you give all these materials sincere consideration and incorporate these findings into the final draft of the Report and recommended conditions. We look forward to meeting with the Agency to discuss how to implement our suggestions and resolve our outstanding concerns. If the Agency elects to not include some or all of our proposed conditions and mitigations in the final Environmental Assessment (EA) Report ...
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Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Sandy Bay Ojibway First Nation
  • Reference number: 280
  • Submitted: 2024-05-16 - 2:26 PM
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • 1 Attachment 2: Comment Table for the Draft Environmental Assessment Report (“the Report”) for the Lake Manitoba Lake St. Martin Outlets Channels Project (“the Project”) Please note, that all the requested changes and conditions do not constitute SBOFN or PFN support for the Project’s approval. These changes are requested with the intention of protecting our rights, interests, and the environment to the best of our ability; however, we strongly oppose the Project as it poses a severe risk to our rights, interests, environment, and the future of our communities. The contents of this document are entirely without prejudice to our position that this project must not be allowed to proceed. # Section, page(s) Comment/ Issue Requested Change or Addition 1 1.2.2, p. 3 In Table 1 Value Components Identified, the list provided of First Nations who will be impacted by the Project with reserves on federals lands is incomplete. Many Nations are missing, including SBOFN. We recognize that the Project area falls on the federal lands / reserves listed in the table, however the environmental effects of the Project will be felt on reserves up- and downstream, and in the surrounding areas. The impacts will not be limited to the RAA. IAAC to add the following to this section: 1) Expand the list of potentially impacted Nations to ensure the environmental effects on reserve lands outside of the Project location are also acknowledged, considered, and protected. It is important to acknowledge all the First Nations who may be impacted by the Project (should it proceed) to ensure consultation and engagement is adequate, and to ensure that all Nations are respectfully involved in Project planning and ...
  • Attachment included
  • May 8, 2024 SENT BY EMAIL Sean Carriere, Regional Director Prairie and Northern Region, Impact Assessment Agency of Canada Canada Place, Suite 1145, 9700 Jasper Avenue Edmonton, Alberta T5J 4C3 Email: sean.carriere@iaac-aeic.gc.ca, lakemanitoba-lakest.martin@iaac-aeic.gc.ca Re: Sandy Bay Ojibway Review of the draft Environmental Assessment Report for the Lake Manitoba and Lake St. Martin Outlet Channels Project Dear Mr. Carriere, We, the leadership of Sandy Bay Ojibway First Nation (SBOFN), are writing to you today to share our comments on the Impact Assessment Agency of Canada’s (IAAC or “the Agency”) draft Environmental Assessment Report (“the Draft Report”) for the Lake Manitoba and Lake St. Martin Outlet Channels Project (“the Project”) as well as of the draft conditions that will be recommended to the Minister of Environment and Climate Change (“the Minister”). Attached to this letter, you will find two tables: 1. Table 1 provides our detailed review of the proposed conditions (“the Conditions Comment Table”). 2. Table 2 provides our detailed comments on key areas of concern and interest contained in the Draft Report (“the Draft Report Comment Table”). We ask that you give all these materials sincere consideration and incorporate these findings into the final draft of the Report and recommended conditions. We look forward to meeting with the Agency to discuss how to implement our suggestions and resolve our outstanding concerns. If the Agency elects to not include some or all of our proposed conditions and mitigations in the final Environmental Assessment (EA) Report and/or Manitoba ...
  • Attachment included
  • 1 Attachment 1. Conditions Table for the Draft Environmental Assessment Report for the Lake Manitoba Lake St. Martin Outlets Channels Project – SBOFN Comments Please note, that all the requested changes and conditions do not constitute SBOFN’s support for the Project’s approval. These changes are requested with the intention of protecting our rights, interests, and the environment to the best of our ability; however, we strongly oppose the Project as it poses a severe risk to our rights, interests, environment, and the future of our communities. The contents of this document are entirely without prejudice to our position that this project must not be allowed to proceed. We have implemented a standardized means of review and revision. Suggested text deletions are identified using a strikethrough (strikethrough), and suggested textual additions are bolded (bolded). Item Sect., Pg. Topic Comment/ Issue Requested Change or Addition 1 2.1, p. 4 General The intention of this condition is well received; however, as currently written it is not enforceable, measurable, or trackable. Concrete direction for MTI is required that includes language for commitments to work with SBOFN and IAAC to measure how it is meeting the conditions. Throughout the EA process, the Proponent has not integrated nor considered the knowledge and input that we provided and has taken an approach that disregards the precautionary principle. Additionally, "sustainable development" is not defined here, and First Nations, Manitoba Transportation and Infrastructure (MTI, “the Proponent”) and the federal government all have different perspectives on what this means. To SBOFN it is not sustainable to sacrifice the use ...
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Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Norway House Cree Nation
  • Reference number: 284
  • Submitted: 2024-05-16 - 10:01 AM
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • DRAFT EA REPORT REVIEW COMMENTS_NHCN_MAY 2024 Comments on the Draft EA Report for the LMLSMOC Project Norway House Cree Nation May 2024 The Norway House Cree Nation technical advisory team has done a preliminary review of the draft EA Report submitted by the Impact Assessment Agency of Canada for the proposed Lake Manitoba and Lake St Martin Outlet Channels Project (Project). The draft EA Report outlines a wide range of concerns that have been expressed and explored by Indigenous Nations, other communities, and federal government agencies over the likely and potential impacts that would be created by this massive landscape altering construction proposal. NHCN has concluded that there is a need for more clarification on some issues for the Minister’s benefit in order that he can fully understand the long-term consequences of his decision. In this set of comments, we will share perspectives about some of the broad issues with the federal environmental assessment process followed by comments and recommendations on sections of the draft EA Report prepared by IAAC. Some of the comments are a repetitive as they refer to specific passages of text in the EA Report which address some overlapping topics. General Comments Need for and Alternatives to the Project Given the passage of time since CEAA 2012 was replaced, we would like to see some more detail in the EA Report explaining the implications of this Project being assessed under CEAA 2012 and discussion of the Agency’s perspective on this. As we understand it, the requirement to consider the need for and alternatives to the proposed Project was reduced in CEAA 2012 compared to previous federal EA legislation and compared to the ...
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Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Poplar River First Nation
  • Reference number: 278
  • Submitted: 2024-05-16 - 10:00 AM
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • Page 1 of 3 Poplar River First Nation Poplar River, Manitoba Phone (204) 244-2267 Box 90, Negginan R0b 0Z0 Fax (204) 244-2690 May 10, 2024 To: IAAC From: Poplar River First Nation About: PRFN comments about the IAAC draft final report about the review under CEAA, conducted by IAAC for the Lake Manitoba Lake St Martin Lake Winnipeg Channel project. This memo is the cover sheet for the notes about IAAC’s final draft report from the in- community meeting in Poplar River First Nation on May 6, 2024. 1) For those interested in PRFN contributions and participation to this EIS review you can find our comments on the original EIS, our comments on the proponent’s answer to Information Requests about the project from IAAC, and other correspondence in the IAAC public registry between 2018 and 2024. 2) We would suggest reading the concerns from PRFN at the front of our comments on the Round Two Information Request answers from MTI. Those concerns are as valid and important now as then. 3) IAAC identified additional potentially affected First Nations for the list of participants early in the Channel project reviews. We feel these were important decisions. All the First Nation and Indigenous participants – with their consultants and experts – have done important work during this lengthy set of reviews. The scope and number of potential impacts increased while the potential range of those impacts also increased with these First Nations also participating. 4) Round Three Information Requests from IAAC to MTI were important repeat attempts to get answers to questions about First Nation and Indigenous communities, engagement with communities, and ...
  • Attachment included
  • Poplar River First Nation Poplar River, Manitoba Phone (204) 244-2267 Box 90, Negginan R0b 0Z0 Fax (204) 244-2690 Lake Manitoba and Lake St. Martin Outlet Channels Project Comments for The Draft Environmental Assessment (EA) Report and Potential Conditions for the Lake Manitoba and Lake St. Martin Outlet Channels Project Community Meeting & Presentation Monday 6th May 2024 Poplar River First Nation Band Hall 10:00 AM to 3:00 PM May 2024 PRFN Page 2 of 12 Outline 1. What is the Lake Manitoba Lake St Martin Outlet Channels Project 2. What is Environmental Impact Assessment 3. What is the Impact Assessment Agency of Canada 4. Finding 1: Significant Impacts on Indigenous Peoples 5. Finding 2: Significant Environmental Impacts 6. Why is Poplar River First Nation (PRFN) involved? 7. How is Poplar River First Nation involved? 8. Some concerns PRFN raised about the Channels Project: 9. IAAC Findings – Engagement with Indigenous Groups 10. IAAC Findings – Surface Water and Ground Water 11. IAAC Findings – Land, Wildlife and Plants 12. IAAC Findings – Fish and Fish Habitat 13. IAAC Findings – Physical and Cultural Heritage 14. IAAC Findings – Traditional Land and Resource Use 15. IAAC Findings – Indigenous People’s Health 16. IAAC Findings – Indigenous People’s Socio-Economic Conditions 17. Take Away Messages from IAAC Draft Assessment Report: 18. Discussion May 2024 PRFN Page 3 of 12 Lake Manitoba Lake St Martin Outlet Channels Project The Channels project is a permanent flood control system proposed by Manitoba Transportation and Infrastructure (MTI). This ...
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Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Manitoba Wildlands
  • Reference number: 277
  • Submitted: 2024-05-16 - 9:59 AM
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • 455 – 167 Lombard Ave. Winnipeg MB Canada R3B 0T6 http://manitobawildlands.org GaileWE@icloud.com Ph: 204-944-9593 May 11, 2024 Impact Assessment Agency of Canada Re: Lake Manitoba Lake St. Martin Lake Winnipeg Channel Project Public comments on IAAC Report and Conditions Attention: Tanishka.Gupta@iaac-aeic.gc.ca Jennifer.Fitzgerald@iaac-aeic.gc.ca Allisson.Lefebvre@iaac-aeic.gc.ca lakemanitoba-lakest.martin@iaac-aeic.gc.ca This letter is a public response to the IAAC draft Environmental Assessment Report and potential conditions for the Lake Manitoba and Lake St Martin Outlet Channels Project based on our experience since before the EIS was filed for the project. I attended the Manitoba Transportation and Infrastructure (MTI) Open Houses held in Winnipeg before the MTI Environmental Impact Statement (EIS) was filed with IAAC, under CEAA. Manitoba Wildlands is not a funded participant. The Open Houses convinced me of a few things: • The technical/scientific expertise to file the EIS was not present in the room. • The MTI staff and consultants did not appear to be aware of recent EIS for other public works in Manitoba, which could assist them in the task ahead. • They also did not seem to know anything about CEAA or IAAC. • The information boards around the room looked nice but broadcast that MTI did not think any significant impacts were likely from the project, and that their very small project area was all that was needed, all that would be impacted. It is mostly the construction area. • They had left out Lake Winnipeg, the Emergency Outlet Channels, First Nations, and protected areas. • We were invited to correct the boards and write on them. However, nothing ...
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Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of York Factory First Nation
  • Reference number: 276
  • Submitted: 2024-05-16 - 9:54 AM
  • See the attached submission / Veuillez consulter la pièce ci-jointe
  • Attachment included
  • Hello Tanishka, Please see the following response to the draft Environmental Assessment (EA) Report and potential conditions for the Lake Manitoba and Lake St. Martin Outlet Channels Project, on behalf of York Factory First Nation: York Factory First Nation (YFFN) remains strongly opposed to the Project, and urges the Minister to issue a Decision Statement that would prohibit the Project from proceeding. York Factory First Nation agrees with the Agency’s assessment that “the Project is likely to cause direct and cumulative significant adverse environmental effects on the current use of lands and resources for traditional purposes by Indigenous peoples; to physical and cultural heritage; and to structures, sites, and things of historical, archaeological, paleontological, or architectural significance despite the implementation of mitigation, monitoring and follow-up measures” and believe the Proponent has not provided certainty in their assessment of the Project’s potential effects to surface water, groundwater, wetlands, vegetation, and wildlife habitat. Should the Minister allow the project to proceed with conditions, YFFN asserts that several of the proposed conditions should be strengthened: • Proposed Condition 3.19 would require the Proponent to conduct monitoring surface water and effects on fish and fish habitat in locations including Split Lake. However, Condition 3.19.1 specifies that monitoring for surface water quality is only required “at a minimum two years post commissioning” as well as “to capture seasonal variability and effects after a minimum number of outlet channel operations and a range of magnitudes of floods, including any new record floods”; YFFN requests: a) that ...
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Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Indigenous Services Canada
  • Reference number: 274
  • Submitted: 2024-05-16 - 9:53 AM
  • See the attached submission / Veuillez consulter la pièce ci-jointe
  • Attachment included
  • …/2 May 10, 2024 Jennifer Fitzgerald Project Manager, Prairie and Northern Region Impact Assessment Agency of Canada / Government of Canada Jennifer.Fitzgerald@iaac-aeic.gc.ca Dear Ms. Fitzgerald: Re: Invitation to Comment on the Draft Environmental Assessment Report and Draft Potential Federal Conditions for the Lake Manitoba and Lake St. Martin Outlet Channels Project Indigenous Services Canada (ISC) has reviewed the Draft Environmental Assessment Report (the Draft Report) and Draft Conditions for the Lake Manitoba and Lake St. Martin Outlet Channels Project (the Project), and wishes to thank the Impact Assessment Agency of Canada (the Agency) for demonstrating a commitment to taking Indigenous groups concerns and expertise seriously. ISC agrees with the Agency’s conclusions pertaining to direct and cumulative significant adverse environmental effects on Indigenous peoples’ current use of lands and resources for traditional purposes; Indigenous peoples’ physical and cultural heritage; and Indigenous peoples’ sites or things of historical, archaeological, paleontological, or architectural significance. In its mandated role to support the implementation of the United Nations Declaration on the Rights of Indigenous Peoples Act, ISC takes particular note of the fact that numerous Indigenous groups have stated strong opposition to this project. ISC provides the following comments on the Draft Report: 1. A key consideration is that while the Project is designed to manage water levels and prevent flooding of communities in the Interlake region of Manitoba, several of the Indigenous groups living in this area (the intended beneficiaries of the project) have ...
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Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Infrastructure Canada
  • Reference number: 275
  • Submitted: 2024-05-16 - 9:53 AM
  • See the attached submission / Veuillez consulter la pièce ci-jointe
  • Attachment included
  • Ottawa, Canada K1P 0B6 May 10, 2024 Jennifer Fitzgerald Project Manager, Prairie and Northern Region Impact Assessment Agency of Canada Jennifer.fitzgerald@iaac-aeic.gc.ca Dear Ms. Fitzgerald, Re: Invitation to comment on the Draft Environmental Assessment Report and Draft Potential Federal Conditions for the Lake Manitoba and Lake St. Martin Outlet Channels Project Thank you for the opportunity to comment on the draft environmental assessment report and draft potential federal conditions for the Lake Manitoba and Lake St. Martin Outlet Channels Project. At this time, INFC would like to indicate the department’s role as a relevant authority1 with respect to the potential issuance of funding for the Project. INFC requires that the Proponent submit to INFC documentation for any condition or follow up program where consultation with Indigenous groups is required, demonstrating:  the notice of the opportunity for the parties being consulted to present their views and information on the subject matter of the consultation,  sharing of all information available and relevant to the scope and the subject matter of the consultation and a reasonable period of time agreed upon with the parties being consulted to prepare their views and information,  impartial consideration of all views and information presented by the parties being consulted on the subject matter of the consultation;  discussion of opportunities for the participation of Indigenous groups in the implementation of a follow-up program, including training, the conduct of monitoring, the analysis and reporting of 1Draft Condition 1.38 Relevant authorities means federal and ...
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Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Keewatinook Fishers of Lake Winnipeg
  • Reference number: 273
  • Submitted: 2024-05-16 - 9:52 AM
  • See the attached submission / Veuillez consulter la pièce ci-jointe
  • Attachment included
  • Keewatinook Fishers of Lake Winnipeg Inc. Draft IAAC Environmental Assessment May 2024 May 8th 2024 Minister of the Environment Impact Assessment Agency of Canada Lake Manitoba Lake St. Martin Lake Winnipeg Diversion Project RE: Review and Comments on the Draft Environmental Assessment Report Minister, First I want to thank the IAAC and it’s staff for the effort the Agency has made to accommodate the views of many people and communities that are reflected in the Draft Environmental Assessment and Conditions documents. Keewatinook is pleased to table this submission of comments to the Impact Assessment Agency of Canada. We have reviewed the Draft Environmental Assessment as requested, and discussed it with the fishers and communities that we serve. For the information of the IAAC, we have been unable to find any support for the proposed Project among Fishers, Knowledge Keepers, Elders Chiefs, Counsellors and citizen Right-holders. All say NO to the Proposed project. Here are specific key points from Keewatinook Fishers of Lake Winnipeg review of the Environmental Assessment Report Documents: 1. Section 35 Rights are referenced throughout IAAC document, and we are located in Manitoba under the NRTA in a Province that has not Affirmed our Section 35 Treaty Rights and Aboriginal Title Rights. We call upon the Minister to ensure that the Province affirms our Section 35 Treaty Rights and Aboriginal Title Rights as part of the Project Consultation. 2. Any decision by the Minister or Governor in Council regarding the Project must be compliant to Canada’s United Nations Declaration Act (UNDA) 2021. There is no consideration or ...
Report

Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Misipawistik Cree Nation
  • Reference number: 283
  • Submitted: 2024-05-16 - 9:52 AM
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • Misipawistik Cree Nation – Response to Draft Environmental Assessment Report (LMLSMOC) – May 2024 Page 1 | 13 Response to the Lake Manitoba/Lake St. Martin Outlet Channel Project: Draft Environmental Report (April 2024) Offered by Misipawistik Cree Nation Executive Summary Misipawistik Cree Nation (MCN) and its consulting team have reviewed the Draft Environmental Report on the Lake Manitoba/Lake St. Martin Outlet Channel Project (LSMLMOC) prepared by the Impact Assessment Agency of Canada (IAAC). Their responses are included throughout this report. MCN has been heavily involved in IAAC process throughout the past five years: • MCN Council, staff, fishers and consulting support team have attended every Technical Advisory Group (TAG) meeting that has been held since summer of 2019. • MCN has responded to the initial Environmental Assessment report submitted by Manitoba Infrastructure (MI or the Proponent). • MCN has responded to the subsequent three rounds of Information Request responses from MI. • MCN intentionally chose not to respond to the mitigation measured proposed by MI as we strongly believe that the science and assessment done to date regarding these mitigation strategies was faulty and incomplete. We do not believe you can create effective mitigation measures on a project that is not sound. • Internally MCN has met with the fisher community and gained their expertise and experience of the previous 2011 and 2014 temporary channels. This knowledge has been integrated into all our responses. • MCN attended the one visit by MI to MCN in late summer of 2022. This was a short few hours, most of which included a presentation that did not honestly represent the ...
Report

Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Health Canada
  • Reference number: 271
  • Submitted: 2024-05-16 - 9:51 AM
  • See the attached submission / Veuillez consulter la pièce ci-jointe
  • Attachment included
  • Environmental Health Program (EHP) Regulatory Operations and Regions Branch (ROEB) Health Canada 391 York Avenue Winnipeg, MB R3C 0P4 May 8, 2024 Jennifer Fitzgerald Impact Assessment Agency of Canada Suite 1145, 9700 Jasper Avenue Edmonton, AB T5J 4C3 Sent by email to: Jennifer.fitzgerald@iaac-aeic.gc.ca; lakemanitoba-lakest.martin@iaac-aeic.gc.ca Subject: Health Canada’s Comments on the Draft Environmental Assessment Report and Draft Potential Federal Conditions for the Lake Manitoba and Lake St. Martin Outlet Channels Project Dear Ms. Fitzgerald: Thank you for the Impact Assessment Agency of Canada’s (IAAC) April 8, 2024 invitation to comment on the Draft Environmental Assessment Report and Draft Potential Federal Conditions for the Lake Manitoba and Lake St. Martin Outlet Channels Project. Health Canada (HC) is participating in the environmental assessment review of Manitoba Transportation and Infrastructure’s (Proponent) Lake Manitoba & Lake St. Martin Outlet Channels Project as a Federal Authority under the Canadian Environmental Assessment Act, 2012. As requested, our department reviewed the characterization of potential environmental effects, key mitigation measures, monitoring, and follow-up programs, as well as those comments and views attributed to Health Canada, which in its current draft is accurately reflected in both documents with the exception of potential conditions 6.2 & 6.5.3. With regard to sections 6.2 & 6.5.3 of the Draft Potential Federal Conditions, HC noted that management and monitoring for water discharges into outside drains was limited to the Lake St Martin Outlet Channel, as identified in Figure 3C-22 of the May 2023 Update to the ...
Report

Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Berens River First Nation
  • Reference number: 270
  • Submitted: 2024-05-16 - 9:50 AM
  • See the attached submission / Veuillez consulter la pièce ci-jointe
  • Attachment included
  • WWW.BERENSRIVER.CA 1 May 7, 2024 Sean Carriere Regional Director Impact Assessment Agency of Canada Via Email: lakemanitoba-lakest.martin@iaac-aeic.gc.ca Dear Mr. Carriere: Re: Lake Manitoba and Lake St. Martin Outlet Channel Project Comments on Draft Environmental Assessment Report I write on behalf of Berens River First Nation (“BRFN”) regarding the draft Environmental Assessment Report (the “Report”) in respect of the Lake Manitoba and Lake St. Martin Outlet Channel Project (the “Project”). BRFN has repeatedly raised concerns that the Project will have serious, long-term consequences on our rights, culture, and way of life. Despite our requests, the Impact Assessment Agency of Canada (the “Agency”) has yet to take the steps necessary to fully understand how the Project will affect our Treaty rights and way of life. Manitoba Transportation and Infrastructure (“MTI”) has similarly failed to meaningfully consider or address our concerns. As a result of the shortcomings in the consultation and engagement process, the draft Report cannot be relied on as a comprehensive or accurate assessment of the nature or scope of the impacts of the Project on BRFN’s rights and territory. Background BRFN is a self-governing Anishinaabe community located on the eastern shores of Lake Winnipeg in central Manitoba. We hold and exercise inherent and constitutionally protected rights, including rights guaranteed under Treaty 5. We rely on continued access to all lands and waters in the vicinity of Lake Winnipeg to exercise our rights. Preservation of our reserves and off-reserve territory is necessary to ensure our ...
Report

Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of University of Manitoba
  • Reference number: 272
  • Submitted: 2024-05-16 - 9:50 AM
  • See the attached submission / Veuillez consulter la pièce ci-jointe
  • Attachment included
  • Natural Resources Institute 220 Sinnott Building Winnipeg, Manitoba Canada R3T 2M6 T (204) 474-8373 F (204) 261-0038 E nriinfo@umanitoba.ca May 8th, 2024 SENT BY EMAIL Sean Carriere, Regional Director Prairie and Northern Region, Impact Assessment Agency of Canada Canada Place, Suite 1145, 9700 Jasper Avenue Edmonton, Alberta T5J 4C3 Email: sean.carriere@iaac-aeic.gc.ca Re: Comments on the Lake Manitoba and Lake St. Martin Outlet Channels Project Dear Mr. Carriere, The draft Environmental Assessment Report on the Lake Manitoba and Lake St. Martin Outlet Channels Project, April 2024 (EA Outlets Report), concludes, “the Agency is of the view that the Project is likely to cause significant adverse environmental effects to Indigenous peoples ’physical and cultural heritage and to structures, sites, and things of historical, archaeological, paleontological, or architectural significance.” and, “…taking into account the implementation of key mitigation measures, monitoring, and follow-up programs, the Project is likely to cause significant adverse environmental effects as defined under CEAA 2012” While the final decision is up to the Minister, the Agency surprisingly did not recommend rejection for this project despite significant adverse effects. Instead, the report recommends mitigation measures, which are not mitigation measures but adaptation measures to significant adverse effects. Despite this being the United Nations decade of Ecological Restoration more natural alternative options for flood mitigation, such as wetland restoration, were not researched. This narrow engineering view of alternatives is problematic and will create future problems as water fluctuates ...
Report

Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Environment and Climate Change Canada
  • Reference number: 268
  • Submitted: 2024-05-16
  • See the attached submission / Veuillez consulter la pièce ci-jointe
  • Attachment included
  • Environment and Climate Change Canada 1 NON CLASSIFIÉ - UNCLASSIFIED Environment and Climate Change Canada Comments on the Lake Manitoba and Lake St. Martin Outlet Channels Project - Public Comment Period on the draft Environmental Assessment Report and draft Potential Conditions under the Canadian Environmental Assessment Act, 2012 Submitted to the Impact Assessment Agency of Canada on May 8, 2024 Table 1: Comments on draft EA Report Original Text Suggested Change: new text in bold, deleted text in strikethrough Rationale/Recommendation Air Quality 7.5.3 Key Mitigation Measures N/A The Proponent shall ensure that all off-road machines meet, at a minimum, Tier 4 emission standards where technically and economically feasible, to minimize changes to air quality that may result in adverse effects to the health of Indigenous peoples or, provide a rationale for the use of any off-road machines that meet lower-tier emission standards. ECCC recommends this addition to the Agency Analysis and/or key mitigation measures, given that the Agency recognizes that “construction and operation activities may result in adverse effects to the health of Indigenous peoples through changes to air quality” in the draft EA report (section 7.5.1.3), In response to IAAC-01 (CIAR 147), the Proponent stated that they will adopt Tier 4 compliant vehicles where possible. ECCC’s final views submission (CIAR 226) stated that if Project construction does not meet Tier 4 emission standards, there may be potential residual effects to air quality due to higher NOx emissions. Hydrology Glossary Page xxii [PDF 22] “Conveyance time - The length of time water is conveyed from ...
  • Attachment included
  • Environmental Protection Operations Directorate Prairie and Northern Region Environment and Climate Change Canada 510-234 Donald Street Winnipeg, MB R3C 1M8 May 8, 2024 ECCC File: 15-MB-003 CIAR Reference: 80148 Sent via e-mail: Impact Assessment Agency of Canada lakemanitoba-lakest.martin@iaac-aeic.gc.ca Jennifer.Fitzgerald@iaac-aeic.gc.ca Valerie.Coenen@iaac-aeic.gc.ca RE: Invitation to Comment on the Draft Environmental Assessment Report and Draft Potential Federal Conditions for the Lake Manitoba and Lake St. Martin Outlet Channels Project To the Impact Assessment Agency of Canada (IAAC), Environment and Climate Change Canada (ECCC) have completed a review of IAAC’s draft Environmental Assessment Report and potential federal environmental assessment conditions for the proposed Lake Manitoba and Lake St. Martin Outlet Channels Project. We are providing comments for IAAC’s consideration. Our expert advice is based on ECCC’s mandate in the context of subsection 36(3) of the Fisheries Act (FA), the Species at Risk Act (SARA), the Migratory Birds Convention Act 1994 (MBCA), the Canadian Environmental Protection Act, 1999 (CEPA), and their relevant regulations. Please contact Orlagh O’Sullivan, Senior Environmental Assessment Officer at 431-276-4506 or Orlagh.OSullivan@ec.gc.ca if you have any questions or concerns. Sincerely, Corinna Watt A/ Regional Director, Prairie and Northern Region Attachment (1): Environment and Climate Change Canada Comments on the LMLSMOC Project – Public Comment Period on the draft Environmental Assessment Report and draft Potential Conditions under the Canadian Environmental Assessment Act, 2012 cc. Gayle ...
Report

Attachment Bloodvein First Nation - Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Bloodvein First Nation
  • Reference number: 264
  • Submitted: 2024-05-16
  • See the attached submission / Veuillez consulter la pièce ci-jointe
  • Attachment included
  • May 7, 2024 Sean Carriere Regional Director Impact Assessment Agency of Canada Via Email: lakemanitoba-lakest.martin@iaac-aeic.gc.ca Dear Mr. Carriere: Re: Lake Manitoba and Lake St. Martin Outlet Channel Project Comments on Draft Environmental Assessment Report I write on behalf of Bloodvein First Nation (“BFN”) regarding the draft Environmental Assessment Report (the “Report”) in respect of the Lake Manitoba and Lake St. Martin Outlet Channel Project (the “Project”). BFN has repeatedly raised concerns that the Project will have serious, long-term consequences on our rights, culture, and way of life. Despite our requests, the Impact Assessment Agency of Canada (the “Agency”) has yet to meaningfully consult with us or take the steps necessary to fully understand how the Project will affect our Treaty rights and way of life. The Project proponent, Manitoba Transportation, and Infrastructure (“MTI”) has similarly failed to consider or address our concerns. As a result of these shortcomings, the draft Report cannot be relied on as a comprehensive or accurate assessment of the nature or scope of the impacts of the Project on BFN’s rights and territory. Further details are set out below. Background mailto:lakemanitoba-lakest.martin@iaac-aeic.gc.ca BFN is a self-governing Anishinaabe community located on the eastern shores of Lake Winnipeg in central Manitoba. We hold and exercise inherent and constitutionally protected rights, including rights guaranteed under Treaty 5. We rely on continued access to all lands and waters in the vicinity of Lake Winnipeg to exercise our rights. Preservation of our territory is necessary to ensure our rights are respected ...
Report

Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Manitoba Métis Federation
  • Reference number: 282
  • Submitted: 2024-05-15 - 2:39 PM
  • See the attached submission / Veuillez consulter la pièce ci-jointe 
  • Attachment included
  • w w w . m m f . m b . c a Lake Manitoba – Lake St. Martin Outlet Channels Environmental Assessment EA Report and Draft Conditions Response Manitoba Métis Federation May 3, 2024 MMF – Lake Manitoba – Lake St. Martin Outlet Channels Environmental Assessment Report and Draft Conditions Response Contents 1.0 Introduction ....................................................................................................................................... 3 2.0 Background—The Red River Métis and the MMF ............................................................................. 5 2.1 The Red River Métis ....................................................................................................................... 5 2.2 Red River Métis’ Rights, Claims, and Interests .............................................................................. 5 3.0 Project Need and Design Considerations ........................................................................................ 11 4.0 Environmental Assessment Report and Draft Conditions ............................................................... 12 4.1 Project Overview and Description ............................................................................................... 14 4.2 Purpose of the Project and Alternative Means Assessment ....................................................... 14 4.3 Consultation and Engagement Activities ..................................................................................... 16 4.4 Predicted Changes to the Environment....................................................................................... 19 4.4.1 Surface Water ...
Report

Attachment Comments on Draft Environmental Assessment Report and Draft Potential Conditions

  • Lake Manitoba and Lake St. Martin Outlet Channels Project
  • Author: Administrator on behalf of Manitoba Transportation and Infrastructure
  • Reference number: 269
  • Submitted: 2024-05-15 - 12:15 PM
  • See the attached submission / Veuillez consulter la pièce ci-jointe
  • Attachment included
  • Lake Manitoba and Lake St. Martin Outlet Channels Project Response to the Agency's Draft Environmental Assessment Report and Potential Conditions May 8, 2024 LAKE MANITOBA AND LAKE ST. MARTIN OUTLET CHANNELS PROJECT RESPONSE TO IAAC DRAFT ENVIRONMENTAL ASSESSMENT REPORT AND POTENTIAL CONDITIONS i Table of Contents 1. INTRODUCTION ............................................................................................................ 1 2. COMMENTS ON POTENTIAL CONDITIONS ................................................................ 3 3. COMMENTS ON DRAFT ENVIRONMENTAL ASSESSMENT REPORT ......................12 4. CLOSURE .....................................................................................................................20 List of Tables Table 2.1 Comments on Potential Conditions....................................................................... 4 Table 3.1 Clarification Comments on draft Environmental Assessment Report ...................13 LAKE MANITOBA AND LAKE ST. MARTIN OUTLET CHANNELS PROJECT RESPONSE TO IAAC DRAFT ENVIRONMENTAL ASSESSMENT REPORT AND POTENTIAL CONDITIONS ii Acronyms / Abbreviations AEMP Aquatic Effects Monitoring Plan AIS aquatic invasive species the Agency Impact Assessment Agency of Canada CAMP Coordinated Aquatic Monitoring Program CEA cumulative effects assessment dEAR draft Environmental Assessment Report DRFN Dauphin River First Nation EIS Environmental Impact Statement EMO Emergency Management Organization EOC Emergency Outlet Channel FPDI First Peoples Development Inc. ha hectare HRIA Heritage Resource Impact Assessment IR Information Request IRTC Interlake Reserves Tribal Council ...
  • Attachment included
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