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Marten Falls Community Access Road Project

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Attachment Eabametoong First Nation Comments re MFCAR Draft Assessment Report

Marten Falls Community Access Road Project
Author: Administrator on behalf of Eabametoong First Nation
Reference number: 272
Submitted: 2026-07-13 - 7:40 AM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
See the attached submission / Veuillez consulter la pièce jointe
Attachment included
July 6, 2026 Impact Assessment Agency of Canada Marten Falls Community Access Road Project 600-55 York Street Toronto, Ontario M5J 1R7 Delivered via email: MartenFalls@iaac-aeic.gc.ca. RE: Comments regarding the Marten Falls Community Access Road (“MFCAR” or “Project”) Draft Impact Assessment Report (“Draft Report”) (IAAC Reference No. IAC-IA-00075 / Project No. 80184) On behalf of Eabametoong First Nation, I write in response to the Impact Assessment Agency of Canada’s (“IAAC”) Report regarding the MFCAR Impact Statement. As a neighbouring First Nation who stands to be significantly and permanently affected by the Project, we urge IAAC to better assess and explain its findings and conclusions with respect to the Project’s impacts on our inherent, Aboriginal, and Treaty rights prior to a final decision. 1. Overview Eabametoong has participated throughout the MFCAR impact assessment process and has submitted comments in response to both the draft and final versions of the proponent's Impact Statement. However, the assessment of the Project’s impacts to our Aboriginal and Treaty rights and interests has been deeply flawed due to inaccurate assumptions about our Area of Interest, and delayed responses to our concerns. As emphasized in our comments to the proponent dated December 15, 2025, the Draft Impact Statement and draft Aboriginal and Treaty Rights and Interests Report (“ATRI Report”) were based on the false premise that the Taashikaywin Land Use Plan area represented the entirety of our Area of Interest. In fact, Eabametoong’s Area of Interest / Territory overlaps significantly with the MFCAR Construction Disturbance Area, Local Disturbance Area, Regional ...

Attachment Mushkegowuk Council Comments on IAAC’s draft Impact Assessment Report

Marten Falls Community Access Road Project
Author: Administrator on behalf of Mushkegowuk Council
Reference number: 274
Submitted: 2026-07-07 - 8:07 AM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
See the attached submission / Veuillez consulter la pièce jointe
Attachment included
IAAC Review of the MFFN-CAR PDF Page # Document Quote Mushkegowuk Comment PDF Page 4 Effects on fish and fish habitat Mushkegowuk Council disagrees that the effect on fish and fish habitat will be low. We believe that the increased access to new populations of fishes will result in a significant increase in the fishing pressure. This has been witnessed in many other jurisdictions that are now seeing their fish populations shift to smaller average sizes or reduced in number. This can result from being outcompeted by introduced species, suffering an increase in predation as young-of-year due to species like the round goby being preying on the game fish fry or habitat loss due to invasive crayfish activity. PDF Page 5 Effects on current use of lands and resources for traditional purposes by Indigenous Peoples - Residual effects and cumulative effects to which the project contributes are likely to be significant to a low extent Mushkegowuk Council believes that the increased access to area lands and increased mobility provided by the project roads for the Marten Falls populace will have a very significant effect. Particularly concerning is the effect this will have on the far easier hunting for caribou that will result from the project. PDF Page 32 The proponent has also committed to maintaining hydrological flows through the peatlands by installing equalization culverts and the floating road design. Mushkegowuk Council does not believe that equalization culverts will perfectly mimic the hydrology currently in the peatlands and is particularly concerned that during the melting and spring freshet the culverts will be frozen and water unable to flow. This has been previously observed in ...

Attachment Fort Albany First Nation - comments on draft MFCAR IA report

Marten Falls Community Access Road Project
Author: Administrator on behalf of Fort Albany First Nation
Reference number: 273
Submitted: 2026-07-06 - 10:19 PM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
See the attached submission / Veuillez consulter la pièce jointe
Attachment included
1 July 6, 2026 Via email: martenfalls@iaac-aeic.gc.ca Impact Assessment Agency of Canada Ontario Region 600 – 55 York Street Toronto, ON M5J 1R7 Attn: Caitlin Cafaro, Senior Consultation Analyst, Ontario Region Dear Ms. Cafaro: Re: Fort Albany First Nation’s Comments on the Draft Impact Assessment Report for the Marten Falls Community Access Road Project Fort Albany First Nation (“FAFN”) submits this letter in response to the Impact Assessment Agency of Canada’s (“IAAC”) Draft Impact Assessment Report (“Draft IA Report”) and Draft Potential Conditions for the Marten Falls Community Access Road Project (“the Project” or “MFCAR”) released for public comment on June 2, 2026. This submission includes the following appendices: ● Appendix A – FAFN Technical Comments on the Proponent and IAAC Responses Comments; ● Appendix B – FAFN Comments on Marten Falls Community Access Road Aboriginal and / or Treaty Rights and Interests (“ATRI”) ; and ● Appendix C – FAFN Targeted Rights Impact Assessment (“Targeted RIA”) for the Marten Falls Community Access Road Project. The attached materials provide further detail regarding FAFN’s concerns and should be read together with this letter. We also expect that these comments will be read in the context of our other submissions throughout this process. We have received the comments submitted by Attawapiskat First Nation on June 26, 2026. We share their serious concerns about the deficiencies in the process and substance of this impact 2 assessment (“IA”) and the Draft IA Report, and we endorse and adopt their comments in supplement to those in this letter. FAFN has consistently raised concerns regarding ...

Attachment Marten Falls Community Access Road Project – Comments on Draft IA Report

Marten Falls Community Access Road Project
Author: Ecojustice
Reference number: 268
Submitted: 2026-07-06 - 6:03 PM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
To whom it may concern, Please find attached a PDF document containing Ecojustice's comments regarding the Marten Falls Community Access Road Project Draft IA Report. Sincerely, Reid Gomme
Attachment included
1 Lindsay Beck & Reid Gomme 1910-777 Bay Street, PO Box 106 Toronto, Ontario M5G 2C8 Tel: 416-368-7533 ext. 551 Fax: 416-363-2746 Email: lbeck@ecojustice.ca, rgomme@ecojustice.ca File No.: 0002312 July 6, 2026 Sent via portal To Whom it May Concern: Re: Marten Falls Community Access Road Project – Comments on Draft IA Report Ecojustice, Canada’s largest environmental law charity, submits the following comments on the draft Impact Assessment Report and proposed conditions for the Marten Falls Community Access Road (MFCAR) project (Draft IA Report). Our primary submission is with respect to the IAAC’s June 11, 2025, letter of direction, which confined the scope of the remaining federal assessment of the MFCAR to three issues: fish and fish habitat, migratory birds, and impacts on Indigenous Peoples, citing reliance on provincial oversight mechanisms for all other matters.1 This scope is narrower than required by the legal definition of adverse effects within a federal jurisdiction, and narrower than what a project of the MFCAR’s scope demands, particularly given that (i) the project cuts through pristine and ecologically sensitive terrain; and (ii) it is one part of a much larger road network planned for the region, to support not only community access but mining and other industrial development. Under the amended Impact Assessment Act, “adverse effects within federal jurisdiction” include non-negligible adverse changes to fish and fish habitat and to migratory birds.2 Peatland hydrology changes caused by floating road construction can alter downstream fish habitat. Cumulative habitat disturbance across the project footprint can ...

Attachment The Friends of the Attawapiskat River Comments on the Marten Falls Community Access Road Draft Impact Assessment Report and Potential Conditions

Marten Falls Community Access Road Project
Author: Administrator on behalf of Friends of the Attawapiskat River
Reference number: 275
Submitted: 2026-07-06 - 5:36 PM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
See the attached submission / Veuillez consulter la pièce jointe
Attachment included
Comments from the Friends of the Attawapiskat River on the Draft Impact Assessment Report and Potential Conditions for the Marten Falls Community Access Road Project (IAAC Reference No. 80184) July 6, 2026 TO Marten Falls Community Access Road Project Impact Assessment Agency of Canada 600-55 York Street Toronto, Ontario M5J 1R7 martenfalls@iaac-aeic.gc.ca FROM Michel Koostachin, Founder Friends of the Attawapiskat River Friends of the Attawapiskat River PO Box 49, Reserve 91A, Attawapiskat, ON P01 1A0 friendsoftheattawapiskat@gmail.com | friendsoftheattawapiskatriver.ca TABLE OF CONTENTS I. ABOUT US..........................................................................................................................................3 II. SUMMARY OF CONCERNS................................................................................................................. 3 III. COMMENTS ON THE DRAFT IMPACT ASSESSMENT REPORT AND POTENTIAL CONDITIONS............... 5 a. The IA Report fails to address concerns of project splitting to the detriment of understanding cumulative effects................................................................................................................................. 5 b. The IA Report fails to assess the MFCAR’s enabling function, eroding comprehensive understandings of impacts to areas of federal jurisdiction.................................................................... 6 i. Fish and fish habitat..................................................................................................................... 7 ii. Species at risk – ...

Attachment Ginoogaming First Nation Comments on Marten Falls Community Access Road Impact Assessment Report and Conditions

Marten Falls Community Access Road Project
Author: Administrator on behalf of Ginoogaming First Nation
Reference number: 267
Submitted: 2026-07-06 - 4:58 PM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
See the attached submission.
Attachment included
Ginoogaming First Nation 101 Poplar Cres., Ginoogaming First Nation P.O. Box 89 Longlac, Ontario P0T 2A0 P. 807.876.2242; F. 807.876.2495 www.ginoogamingfn.ca To: Marten Falls Community Access Road Project Impact Assessment Agency of Canada 600-55 York Street Toronto, Ontario M5J 1R7 Telephone: 416-952-1576 Email: martenfalls@iaac-aeic.gc.ca Re: Ginoogaming First Nation Comments on the Marten Falls Community Access Road Draft Impact Assessment Report and Conditions of Approval I’m writing to express Ginoogaming First Nation’s serious concerns about the Marten Falls Community Access Road Project (MFCAR; the Project). GFN sees the MFCAR Project holistically and recognizes its clear intention to access mineral resources in the Ring of Fire as stated frequently by senior public officials. As we have consistently stated verbally and on the written record, GFN does not support development related to the Ring of Fire without our consent. We will only provide our consent if we secure accommodation measures that are commensurate with the scale and severity of the anticipated impacts to GFN’s Treaty and Aboriginal rights and interests from the development of the entire Ring of Fire road network and associated mining development. We insist that these accommodation discussions commence immediately. Our Nation will consider all options to ensure that our Treaty and Aboriginal rights and interests are honoured by the Crown. GFN homelands extend throughout the entirety of the RoF road network. Our people have lived in this region since time immemorial. GFN citizens exercise their rights, have Tazhiikaywinin, conduct ceremony, harvest food and medicines, and care for ...

Attachment Wildlife Conservation Society (WCS) Canada Comments on the MFCAR draft Impact Assessment Report

Marten Falls Community Access Road Project
Author: Wildlife Conservation Society Canada
Reference number: 266
Submitted: 2026-07-06 - 4:11 PM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
Thank you for the opportunity to comment. Please accept our comments on the Marten Falls Community Access Road (MFCAR) draft Impact Assessment Report.
Attachment included
WCS Canada – Ontario Northern Boreal Program Phone: (807) 285-9125 10 Cumberland St N Email: wcscanada@wcs.org Thunder Bay, ON, P7A 4K9 Canada Web: www.wcscanada.org July 6, 2026 To: Impact Assessment Agency of Canada via the Canadian Impact Assessment Registry (https://iaac-aeic.gc.ca/050/evaluations/proj/80184) Re: Comments on the Marten Falls Community Access Road Project Draft Impact Assessment Report Dear Impact Assessment Agency of Canada, Please accept our comments on the draft Impact Assessment Report for the Marten Falls Community Access Road (the Project) in northern Ontario. We thank you for the opportunity to contribute to the process in our capacity as conservation scientists with Wildlife Conservation Society (WCS) Canada with expertise in research and policy relevant to species and ecosystems to inform conservation decisions. Our comments focus on evaluating how the draft Impact Assessment Report has considered available information to characterize residual and cumulative effects and make significance determinations. In our view, there are several key deficiencies that affect the reliability of the assessment’s conclusions as they relate to unresolved information gaps presented in the Project’s Impact Statement. WCS Canada has ...

Attachment Aroland First Nation- Comments on MFCAR Draft IAR and proposed conditions

Marten Falls Community Access Road Project
Author: Administrator on behalf of Aroland First Nation
Reference number: 270
Submitted: 2026-07-06 - 2:59 PM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
See the attached submission / Veuillez consulter la pièce jointe
Attachment included
Delivered by Email Re: Review of Draft IAR and draft potential conditions under Section 64 of the Impact Assessment Act July 6, 2026 Dear Caitlin Cafaro, Aroland First Nation ("AFN") has reviewed the draft Impact Assessment Report (IAR) and Proposed Conditions for the Marten Falls Community Access Road (MFCAR) Project. We appreciate the opportunity to provide our comments and have enclosed our detailed review for consideration. AFN supports the development and approval of the MFCAR Project for the purpose of community access. However, this support is limited to the MFCAR as a community access road and does not extend to industrial development in the Ring of Fire, including mining or other future developments. AFN maintains that any such development must proceed only following meaningful consultation at the deepest level with accommodation sufficient to address all our reasonable concerns, comprehensive and coordinated assessment, and with AFN's free, prior, and informed consent, consistent with our governance authority and decision-making responsibilities over our lands. AFN also expects that future decisions be informed by the outcomes of the Regional Assessment once completed. This standard of consultation, accommodation and consent is grounded in: • The requirements of UNDRIP and the federal UNDRIP Act which the courts are finding does necessitate fuller engagement to get or seek consent, given the provisions in UNDRIP about the right of indigenous peoples to exercise free, prior and informed consent (or withhold it) in respect of developments on or to their lands (see Gitxaala v BC 2025 BCCA and Kebaowek First Nation v Canadian Nuclear Safety Commission 2025 FC 319). ...

Attachment Constance Lake First Nation Comments on Marten Falls Community Access Road Impact Assessment Report and Conditions

Marten Falls Community Access Road Project
Author: Administrator on behalf of Constance Lake First Nation
Reference number: 265
Submitted: 2026-07-06 - 11:27 AM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
See the attached submission.
Attachment included
Comments on Marten Falls Community Access Road Impact Assessment Report and Conditions of Approval July 6, 2026 Submitted by: Constance Lake First Nation Constance Lake First Nation – Comments on MFCAR Draft Federal IA Conditions | 2 Regulatory and Procedural Context The Marten Falls First Nation Community Access Road (MFCAR) is a proposed all-season road intended to connect the remote community of Marten Falls First Nation (MFFN; the Proponent) to Ontario’s provincial highway network. Located in the James Bay Lowlands region of northern Ontario, MFFN is currently accessible only by air and a seasonal winter road. The planned access road would span approximately 184 kilometers from the northern terminus of Painter Lake Road, north of Aroland and Nakina, to the MFFN community at the confluence of the Albany and Ogoki Rivers. The MFCAR is located on the Homelands of Constance Lake First Nation (CLFN), where we have long maintained cultural ties and exercised our rights. As part of our engagement on the MFCAR, CLFN submitted comments and recommendations on the Environmental Assessment /Impact Statement (EA/IS) to the Proponent and to Provincial and Federal regulators. Responses were provided in writing by the Proponent and the Ontario Ministry of Environment, Conservation and Parks (MECP) in March 2026 which we subsequently responded to on April 9, 2026. The Impact Assessment Agency of Canada (IAAC) provided responses to CLFN’s comments on the EA/IS comments on May 21, 2026, shortly before releasing the draft Conditions of Approval and draft Impact Assessment (IA) Report for the Project. MECP have concluded that the Provincial Environmental Assessment (EA) meets the ...

Attachment Geogrid design support

Marten Falls Community Access Road Project
Author: MACCAFERRI CANADA LTD
Reference number: 264
Submitted: 2026-07-06 - 11:25 AM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
Our company manufactures high-tensile-strength geogrids and has operations across Canada. We have supplied materials and engineering support for numerous infrastructure projects nationwide and provide design assistance for geogrid-reinforced applications. We would appreciate knowing which geotechnical consultant will be responsible for the geotechnical design of this project so that we can provide technical input and share information on our geogrid solutions. We would welcome the opportunity to collaborate with the design team and contribute to the evaluation of cost-effective and technically sound ground improvement alternatives. Jose Fernandez j.fernandez@maccaferri.com

Attachment Limestone cliff and Sacred water nnorth of Aroland

Marten Falls Community Access Road Project
Author: Elaine Gurney
Reference number: 263
Submitted: 2026-07-04 - 6:52 PM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
Hello to start-I am not Indigenous and I believe the First Nations should be able to use the lands they care for . This is not about that. This is a letter written from my heart. I had met David and Ida Megan-the caretakers for that quadrant of land many years ago. I was drawn to the water site from Toronto. David and ida treated me as family . I was allowed to stay at the site on my own. I made the offerings to the little people on the cliff when Ida could not. She told me that the site had been used for time immemorial as a meeting place where everyone observed the peace. Ojibway,Cree,Oji-Cree and people from further north* she did not have the English word or them would all be allowed to gather the Healing water. As someone who does not know anyone from the community, I do not know if this has been shared before,and it is a hard thing for me to do,considering how the place was a semi secret place.Although people from Mobert and Thunder Bay and Nakina (that I personally saw) gathered the water from the spring. So many Elders have passed. It is a sin to put this road thru there.It would be like putting a road through Lourdes. If this is considered giving away secrets ,that is sad-because without this being said -there would be no hope for this unique place. Thank you, Elaine Gurney 124 16th St. Etobicoke M8V3K1 Cultural Heritage Value (CHV) Submission Spring–Pond–Limestone Peace Site, North of Aroland 1. Location and Physical Description The site is located north of Aroland First Nation within a quiet, ...

Attachment Response to June 3, 2026 Release of the Draft Impact Assessment Report and Potential Conditions for the Marten Falls Community Access Road Project

Marten Falls Community Access Road Project
Author: Marten Falls First Nation
Reference number: 262
Submitted: 2026-07-03 - 4:34 PM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
Please see attached.
Attachment included
MARTEN FALLS FIRST NATION #65 Ogoki Post, Ontario P0T 2L0 Tel: (807)349-2509 Fax: (807)349-2511 July 3, 2026 Impact Assessment Agency of Canada Attention: Nicholas Wawryk Re: Response to June 3, 2026 Release of the Draft Impact Assessment Report and Potential Conditions for the Marten Falls Community Access Road Project Dear Mr. Wawryk: On behalf of the Council and membership of Marten Falls First Nation (MFFN), I am writing to provide our comments on the draft Impact Assessment Report and potential conditions of federal approval which the Agency released on June 4, 2026 and updated on June 22, 2026. MFFN has four basic comments: First, the draft IAR should be amended to address UNDRIP from the perspective of MFFN providing its free, prior and informed consent to this Project as the most impacted Indigenous people. Second, the draft IAR and many draft conditions of federal approval should be amended to focus on effects which are not within Ontario’s authority to assess and regulate so that the IAR for this integrated impact assessment process is not duplicative. Third, for effects not within Ontario’s authority, the draft IAR should be amended to provide a Nation-by-Nation description of First Nation rights and interests likely to be affected by this Project. Fourth, for effects not within Ontario’s authority, the draft IAR should be amended to provide additional details - effect by effect - on the Agency's new approach to assessing the significance of adverse effects and determining the extent of significant effects. (1) The draft IAR should be amended to address UNDRIP and the UNDA from the perspective of MFFN providing its free, prior and ...

Attachment Comment Submission on behalf of Weenusk First Nation on Draft MFCAR Report

Marten Falls Community Access Road Project
Author: Administrator on behalf of Weenusk First Nation
Reference number: 271
Submitted: 2026-07-03 - 4:22 PM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
See the attached submission / Veuillez consulter la pièce jointe
Attachment included
1 July 3, 2026 Delivered via Email Impact Assessment Agency of Canada Marten Falls Community Access Road Project 600-55 York Street Toronto, Ontario M5J 1R7 Email: martenfalls@iaac-aeic.gc.ca RE: Marten Falls Community Access Road (MFCAR) Draft Impact Assessment Report (dated May 2026) Review To whom it may concern, As elected Chief of Weenusk First Nation (“Weenusk”), I write to you on behalf of my Nation. As part of Weenusk’s consultation regarding the Marten Falls Community Access Road (“MFCAR” or the “Project”), my responsibility as Chief is to protect my Nation’s Section 35 rights. We, as a Nation, are signatories to Treaty No. 9 and hold rights throughout this treaty area. We have completed a review of the Draft Impact Assessment (IA) Report (“draft IA report”) for the MFCAR. This letter provides a summary of comments and issues identified by Weenusk. Ontario Plans to Accelerate Construction of the MFCAR In our comments on the Final Environmental Assessment/Impact Statement (EA/IS), we noted our concern regarding the accelerated construction and consultation timing. We expressed concern that the accelerated construction schedule for the MFCAR may undermine the purpose of the environmental assessment process and the Crown’s duty to consult. We felt that the approach meant that consultation and engagement may not meaningfully inform project decisions. Further, we raised that the EA/IS includes commitments for additional consultation to complete components of the assessment and to develop construction and operations monitoring plans; however, the EA/IS does not provide clear timelines, work plans, or a defined approach to ensuring Indigenous participation. Given ...

Attachment Attawapiskat First Nation Comments on the Draft Impact Assessment Report and Potential Conditions

Marten Falls Community Access Road Project
Author: Administrator on behalf of Attawapiskat First Nation
Reference number: 269
Submitted: 2026-06-26 - 12:06 PM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
See the attached submission / Veuillez consulter la pièce jointe
Attachment included
June 26, 2026 SENT BY EMAIL Loraine Cox and Caitlin Cafaro Team Leaders, Ontario Region Impact Assessment Agency of Canada (IAAC) loraine.cox@iaac-aeic.gc.ca caitlin.cafaro@iaac-aeic.gc.ca martenfalls@iaac-aeic.gc.ca Dorothy Moszynski and Simon Zhao Special Project Officers Environmental Assessment Branch Ontario Ministry of the Environment, Conservation and Parks (MECP) dorothy.moszynski@ontario.ca simon.zhao@ontario.ca Dear Ms. Cox, Ms. Cafaro, Ms. Moszynski, and Mr. Zhao, Re: Attawapiskat First Nation’s comments on the Marten Falls Community Access Road Ministry Review and draft Impact Assessment Report We are writing in response to a June 26, 2026 deadline to provide comments on the Marten Falls Community Access Road (MFFN CAR) Ministry Review (Ontario) and a July 6, 2026 deadline to provide comments on the draft Impact Assessment Report (Canada). The regulatory review process for the MFFN CAR, at both federal and provincial levels, has been nothing short of a rubber-stamping exercise. At every stage we have raised concerns over the impact of this proposed frontier-opening project to our inherent and Treaty rights, and our entire Way of Life as Kattawapiskak people. Instead of engaging with us in a meaningful way your regulatory teams tried to placate us with by saying that you have provided funding, that you are happy to accept our comments, that everything is being done according to legislative requirements, and that there will be additional opportunities to comment at future stages of the regulatory timeline. While we were busy preparing one letter after another detailing our concerns, with no meaningful responses from either Crown government, the proponent proceeded ...

Attachment Nibinamik First Nation’s Comments on Ontario’s Ministry Review and the Impact Assessment Agency of Canada’s Draft Impact Assessment Report for the Marten Falls Community Access Road

Marten Falls Community Access Road Project
Author: Administrator on behalf of Nibinamik First Nation
Reference number: 276
Submitted: 2026-06-19 - 3:34 PM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
See the attached submission / Veuillez consulter la pièce jointe
Attachment included
NIBINAMIK FIRST NATION General Delivery Summer Beaver, Ontario P0T 3B0 Tel: (807) 593-2131 Fax: (807) 593-2270 June 19, 2026 VIA EMAIL Ministry of the Environment, Conservation and Parks Environmental Assessment Branch Special Project Officers 135 St. Clair Avenue West, 1st Floor Toronto, ON M4V 1P5 kathleen.oneill@ontario.ca dorothy.moszynski@ontario.ca simon.zhao@ontario.ca Attention: Kathleen O’Neill, Dorothy Moszynski, and Simon Zhao Impact Assessment Agency of Canada Ontario Region 600-55 York Street Toronto ON M5J 1R7 martenfalls@iaac-aeic.gc.ca caitlin.cafaro@iaac-aeic.gc.ca Attention: Caitlin Cafaro RE: Nibinamik First Nation’s Comments on Ontario’s Ministry Review and IAAC’s Draft Impact Assessment Report for the Marten Falls Community Access Road Nibinamik First Nation (“Nibinamik”) is writing in response to the Government of Ontario’s (“Ontario”) and the Impact Assessment Agency of Canada’s (“IAAC” or “Canada”) requests for comment on Ontario’s Ministry Review Report (“Ontario Report”) and IAAC’s Draft Impact Assessment Report (“IAAC Report”) (together “Government Reports”) for the Marten Falls Community Access Road (“MFCAR”). Nibinamik continues to support Marten Falls First Nation’s (“Marten Falls” or the “Proponent”) desire to build an all-season road to connect its community to the provincial highway system. Nibinamik shares this desire and is interested in exploring opportunities to build our own all-season road. However, as we have expressed numerous times, Nibinamik has serious concerns with Ontario’s and Canada’s efforts to expedite the assessment and construction of the MFCAR, as well 2 ...

Attachment Public comment – Draft IA Report (Marten Falls Community Access Road): basal reinforcement / “heavy geogrid” design basis

Marten Falls Community Access Road Project
Author: Geoquest Canada
Reference number: 261
Submitted: 2026-06-16 - 2:30 PM
Project phase: Impact Assessment
Participation notice: Public notice - Public comments invited on the draft Impact Assessment Report and potential conditions
We are a manufacturer of high-tensile-strength geogrids and have reviewed the floating-road design described in the Draft Impact Assessment Report. The report states that the permeable rock embankment over peatland would be “supported with reinforcing material such as heavy geogrid” to help it settle without clogging. We respectfully submit that the geotechnical basis for this reinforcement is not characterized in the report, and that this matters both to structural safety and to the environmental claim that the floating road will maintain peatland hydrology. We request that the proponent clarify the following: Function and terminology 1. “Heavy geogrid” is not a defined engineering term. What is the specified characteristic ultimate tensile strength (kN/m), polymer type, and structure (uniaxial / biaxial / triaxial) of the proposed reinforcement? 2. The report attributes a “prevent clogging / allow settlement” function to the geogrid. As clogging prevention is a separation/filtration function (a geotextile role) and geogrids primarily provide tensile reinforcement, can the proponent confirm which geosynthetic provides which function, and whether a separation geotextile is included in addition to the geogrid? Reinforcement design basis 3. To which design standard will the basal reinforcement be designed (e.g., BS 8006-1:2010, FHWA geosynthetic design guidance, TAC/MTO muskeg practice)? The codes cited in the report (CSA S6:25, Ontario Roadside Design Manual, Structural Manual) do not govern geosynthetic basal reinforcement. 4. Is a single layer or multiple layers of reinforcement proposed, and on what basis (total required tensile capacity, ...

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Date modified:: 2019-03-01

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