Agreement with timeline extension request + Recommendations

To: The Impact Assessment Agency of Canada
Subject: Extension Request for Webequie Supply Road Project

Keepers of the Circle is operated by the Temiskaming Native Women’s Support Group, we are Indigenous Family Learning Center in Kirkland Lake and Temiskaming Shores. Our mandate is to maintain quality programing for Indigenous children, women, and families through implementing various projects such as, employment training, healthcare, childcare and more. Our organization works closely with our partner the AnanauKatiget Tumingit Regional Inuit Women's Association (ATRIWA) to raise capacity for Indigenous women, girls and gender diverse persons in Northern Labrador as well as in Northern Ontario to participate in Impact Assessments.

While Indigenous Peoples are frequently regarded as key partners in project assessments, Indigenous women’s concerns and aspirations regarding industrial projects have historically been marginalized, as have the opportunities and benefits from such developments. Indigenous women, girls and gender diverse persons are frequently made invisible in impact assessment processes and their systematic exclusion has contributed to the significantly higher rate of gendered violence, poverty, and homelessness experienced. These trends are explained further in national publications such as the Final Report of the National Inquiry into Missing and Murdered Indigenous Women and Girls.  Our project aims to help remediate intergenerational impacts of colonization that contribute to systems that have oppressed and marginalized Indigenous women from decision-making processes that affect their wellbeing and economic security. Our organizations explicitly requests that steps are being taken to ensure that Indigenous women, girls, and gender diverse people are being included in decision making for this project and that their input is being thoroughly considered with tangible, measured mitigation of impacts. We would like to ensure that surrounding First Nation communities and urban Indigenous people have been sufficiently informed in advance of project developments and are given support and time to provide input.

We would like to express agreement with the extension request overall as there is a marked need to conduct further data collection, analysis, and consultation activities in the study area. The Webequie Supply Road Project has incorporated a variety of engagement methods in their planned work activities utilizing live-streaming and posting all project engagements on public forums which gives all of the membership an opportunity to watch and listen in if they can access the technology, have internet and cannot make in person meetings. The parameters of consultation continue to rely heavily on media and virtual platforms, despite a significant technology access gap for many households in remote access communities across Northern Ontario. There are significant gaps in the level of community interest in engaging in consultation activities with WSR or the ministry, and we wonder if this is related to calls of nations impacted by the proposed Ring of Fire development in which WSR will facilitate. This is demonstrated in the IKLRU program status report which indicated increased community interest in participation in information sharing, however several nations continue to be unresponsive to participation in consultation efforts by the project proponent in the IK program.

The efforts to incorporate a GBA+ lens in considering project impacts remain vague. Mitigation efforts will utilize aggregated data, literature review to discover both risk and positive impacts are standard practice. What remains unclear is the key informant’s portion of the focus group sessions that would inform project considerations in GBA+. Though these interviews and focus groups play an important role in capturing information, focus groups consisted of C&C, band staff, social services, and Elders as well as ‘other community members’ this other category must include Indigenous women, youth and 2SLGBTQ people to be sufficiently representative of the target demographic of inquiry. It is not sufficient to only collect third party observations to the lived realities and concerns of impacted peoples, more work needs to be done speaking to community women directly, and ensuring they have the space and platform in which to share, though we applaud WSR for the 8 women focus group that has been conducted thus far and look forward to learning more about additional insights and workshops conducted. Community consultations must take place in person, with increasing frequency during the timeline extension to ensure that the target consultation parameters are satisfied.

There are continued calls for more scrutiny and scientific rigor into the implications of the road for habitat fragmentation, casualties of wildlife and disturbance from construction activities, and overall risk of continued planned developments utilizing this road including traffic from large vehicles and related risks associated with it. We are eager to review WSR planned mitigation measures to community feedback, with particular regards to GHG emissions and habitat destruction mitigation. Having wildlife corridors to ensure that animal crossing casualties can me minimized would be a crucial component in respecting the natural environment.

We submit these comments respectfully and with great interested in the planned activities for engagement and development now and in future.

The Invitation to Voices Project Team