Comments on Tailored Impact Statement Guidelines and Public Participation Plan - Marten Falls Community Access RoadWebequie supply Road

Thank you for the opportunity to comment on the Impact Assessment of the Webequie Supply Road Project and Impact Assessment of the Marten Falls Community Access Road Project.  The placement and intent of both these projects are predicated on an inevitable next phase or end-game that results in construction of a north-south or east-west all-weather access road to one or more potential mine locations within the Ring of Fire. Neither of these two projects can be adequately assessed independent of that context.  The true and consequential impacts will be the cumulative effects of the longer-term full road network and associated construction, maintenance, and subsequent use on a wide range of ecosystem functions.  A reqional environmental assessment is essential to anticipating long term effects at an adequate scale to protect economic, social and environmental interests.

The draft Tailored Environmental Assessment Guidelines for both projects require the description of location to focus on aspects of the project and its setting that are important in order to understand the potential environmental, health, social and economic effects and impacts of the project. As these two projects are proposed to be assessed independently as stand-alone projects there is great risk that the nature and scope of impacts may be inadequately identified or mitigated.  There is little indication that the environmental significance and value of the geographical setting in which the project will take place and the surrounding area is being considered at an appropriate scale. An adequate geographic scope of assessment for each project would include the same geography. This is especially true for assessment impacts on wide-ranging species at risk such as woodland caribou or wolverine.

Both these projects exist at the interface between the Boreal Shield and Hudson Bay Lowlands Ecozones. Evidence from winter distribution surveys and the movement of collared caribou suggests that the interface between the Hudson Bay Lowlands Ecozone and the Ontario Shield Ecozone is used extensively by caribou, particularly in the winter. This area represents a transition between the fire-driven ecology in the Ontario Shield and the widespread peatland complexes characteristic of the lowlands. Patterns of caribou movement demonstrate seasonal movements towards or along this transition zone. It appears to have ecological significance as both winter and summer habitat, supports calving and nursery functions, and may be important as a conduit for north-south travel, including potential connections with migratory caribou from further north. Therefore there is the very real possibility that one of the proposed projects would have impacts on woodland caribou movement, seasonal habitat selection or survival that interact with those of the other project, let alone inevitable development of other associated infrastructure. (See Berglund, N.E., G.D. Racey, K.F. Abraham, G.S. Brown, B.A. Pond, and L.R. Walton. 2014. Woodland caribou (Rangifer tarandus caribou) in the Far North of Ontario: Background information in support of land use planning., Ont. Min. Nat. Resour., Biodiversity and Monitoring Section Tech. Rpt. TR-147, Thunder Bay, Ontario. 160 pp).

There are many benefits of these two projects.  I have identified 3 major concerns that I believe need to be addressed as potential and likely impacts:

1. Proliferation of roads, aggregate pits and alteration of roadside vegetation such that distribution, movement and population dynamics of prey and predator species are altered, leading to the decline in vulnerable species such as woodland caribou.
2. Alteration in land use not related to community access to mineral exploration sites, or to southern community services resulting in altered levels of wildlife, fish or plant harvest due to increased motorized access to the terrestrial environment or increased amount and ease of success to previously limited inaccessible aquatic environments.
3. There is not much known about the vegetative response to disturbance of the productive, calcareous mineral soils that will be subject to grasses herbs and shrubs not currently common on the landscape subject to both these projects. Vectors of transport include both construction and maintenance equipment and operations.        

Public Participation Plan

Question 1. I would like to receive notice of various stages in the assessment process and have the opportunity to see maps, be involved in group discussion and hear presentations in an open-house environment in order to have meaningful input into the assessment process. I believe open house-type discussion environments are more effective than Webex type updates.  The group discussion is extremely valuable in allowing thoughtful consideration and construction of constructive comment.

Question 2. Public open houses in Thunder Bay are helpful.