Suncor Base Mine Extension Project

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Attachment From Smith's Landing First Nation to Suncor Energy Inc re: Consultation on the Suncor Base Mine Extension Project

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Smith's Landing First Nation
  • Reference number: 158
  • Submitted: 2022-07-21 - 5:32 PM
  • Project phase: Impact Statement
  • Please see attached document
  • Attachment included
  • July 21, 2022 Suncor Energy Inc. P.O. Box 2844 150 - 6 Avenue S.W. Calgary, Alberta Canada T2P 3E3 P.O. Box 4015 Main Mailroom Tar Island Fort McMurray, Alberta Canada T9H 3E3 RE: Smith’s Landing First Nation Consultation on Suncor’s Base Mine Extension Project Dear Tracey Stephen, I write on behalf of Smith’s Landing First Nation (SLFN) to express our ongoing concerns about the level and quality of engagement that Suncor Energy Inc. (Suncor) is providing to SLFN for the proposed Suncor Base Mine Extension Project (Project). Thus far, the technical engagement sessions have proven to be less than meaningful with little to no consideration by Suncor of the information and concerns raised by SLFN. Below we outline SLFN’s concerns about the trajectory of the technical engagement sessions with Suncor and proposed next steps. Background Information SLFN is a signatory of Treaty No. 8 and are the descendants of the traditional Dënésułıné of the South Slave region. SLFN territory expands from northern Alberta, including Wood Buffalo National Park (WBNP), northern Saskatchewan, northern Manitoba, the Northwest Territories (NWT) and southern Nunavut. Members of SLFN hold a strong connection to their territory and continue to actively use the land, waters and resources to sustain their cultural way of life. We, the Tthebatthı Dënésułıné, have been sovereign since time immemorial. Together, we will continue our journey in harmony with the environment to sustain a healthy and self-sufficient lifestyle for future generations. To honour our Creator and ancestors, we will protect and nurture the integrity of our Dëné Ch’anié. Suncor has proposed a large-scale expansion ...

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Attachment From Fort McKay First Nation re: Traditional Land Use Study for the Suncor Base Mine Extension Project

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Fort McKay First Nation
  • Reference number: 156
  • Submitted: 2022-06-30
  • Project phase: Impact Statement
  • Please see attached document
  • Attachment included
  • FORT MCKAY FIRST NATION TRADITIONAL LAND USE STUDY Regarding Suncor Energy Inc.’s Proposed Base Mine Expansion Project Submitted to Fort McKay First Nation: June 12, 2019 i Limitations and Terms of Use This Traditional Land Use Study (TLUS) report was prepared by Kwusen Research & Media under the direction of the Fort McKay Sustainability Department (FMSD). All intellectual property rights to traditional knowledge presented in this report are held by the Fort McKay First Nation. The results and recommendations in this report are intended for use by Suncor Energy Inc. and their consultants for the Environmental Impact Assessment to be completed for the Base Mine Expansion (BMX) Project to be considered by provincial regulators. Research results contained herein are specific to the BMX Project and are not intended to be used by any other parties or for any other purposes, unless agreed to by Fort McKay. This report is not suitable or intended to be used in the assessment of any other projects or in the assessment of any other existing or future developments in Fort McKay First Nation’s Traditional Territory, unless agreed to by Fort McKay. Any use, reliance, or decisions made by third parties on the basis of this report are not condoned by the report authors and are the sole responsibility of such third parties. This report was written without prejudice to Fort McKay First Nation’s Treaty Rights, Aboriginal Rights, and/or other interests. ii CREDITS Project Director: Ryan Abel Manager – Regulatory & Technical, Fort McKay Sustainability Department Report Authors: Towagh ...

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Attachment From Lakeland Métis Community Association re: Comments on the Suncor Base Mine Extension Project

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Lakeland Métis Community Association
  • Reference number: 155
  • Submitted: 2022-05-11
  • Project phase: Impact Assessment
  • Please see attached document
  • Attachment included
  • &*/il,r'?il.k Lakeland Metis Community Association May 1t,2022 Sent Via Email Attention: Claudette Bois Crown Consultation Lead, Crown Consultation Operations Division Impact Assessment Agency of Canada - Government of Canada RE: Lakeland M6tis Community Association - Potential Effects of the Suncor Base Mine Extension Project Canadian Impact Assessment Registry File No.: 80521 Dear Ms. Bois, At our recent teleconference meetings on Tuesday March 1,2022 and March 29,2022,you indicated that you would like to get a sense of how Lakeland M6tis Community Association (LMCA) is potentially affected by the Suncor Base Mine Extension Project (the Project). It is still early in the impact assessment process and LMCA has yet to conduct any Project- specific baseline studies to fully identif!, assess and mitigate any potential effects to our members' rights, traditional uses of the Project area, or socioeconomic wellbeing. Further, we have only recently received a draft list of the Valued Components of the Environmental Impact Assessment from the Proponent (at a workshop with all potentially- affected communities on April 19.2022). However, we would like to take this opportunity to put on the public record a brief discussion of how LMCA is potentially impacted by the proposed Project based on LMCA's community history, what we already know about our members' socioeconomic conditions and the unique way in which M6tis rights are exercised in the Athabasca River valley where the Proiect is located. Background Information on Lakeland M6tis Community Association LMCA is one of the founding members of the newly formed Alberta M6tis Federation. LMCA represents the interests of approximately 80 M6tis community members, most of ...

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Attachment Whitefish Lake First Nation - Suncor Base Mine Extension Project Questionnaire Responses

  • Suncor Base Mine Extension Project
  • Author: MLT Aikins LLP submitted by Amyn Lalji
  • Reference number: 148
  • Submitted: 2021-07-27 - 5:07 PM
  • Project phase: Impact Statement
  • Please see attached correspondence that we submit on behalf of Whitefish Lake First Nation.
  • Attachment included
  • Impact Assessment Agency of Canada July 23, 2021 Page 1 of 5 Attachment 1: Guiding Questions Suncor Base Mine Extension Project Canadian Impact Assessment Registry File No.: 80521 Indigenous Group: Whitefish Lake First Nation Contact Name: Fabian Grey Telephone: Address: Fax: Email: consultation@whitefishadmin.ca Potential Effects and Impacts 1. Please identify any effects of the Project that are of concern to your community. Also please identify any effects that you are aware of that are not listed in the initial project description. Note: Information on effects and direct and incidental effects as well as effects within federal jurisdiction are defined in section 2 of IAA1. Whitefish Lake First Nation (“Whitefish”) is a signatory to Treaty No. 8 territory. However, the land impacted by the Suncor Base Mine Extension Project (the “Project”) was not only used historically by members of our Nation – it continues to be used by members today to exercise our Aboriginal and Treaty rights. Our Nation has members currently living near Wandering River, south of Fort McMurray. These members engage in traditional and cultural practices in the area, including hunting, trapping, and gathering. Additionally, other Whitefish members often frequent the Project area in order to hunt. The cumulative impact of extensive development and resource extraction projects such as this current Project are of utmost concern to Whitefish. This cumulative impact has already resulted in significant changes to the Project area, leaving Whitefish members living in this area with no alternative but to move further away. Activities such as these have impacted our use of the land for cultural and ...

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Attachment From the Impact Assessment Agency of Canada to Martin Olszynski re: Response to Comments on Tailored Impact Statement Guidelines (see Reference #144)

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Impact Assessment Agency of Canada
  • Reference number: 145
  • Submitted: 2021-06-02
  • Project phase: Impact Statement
  • Please see attached document
  • Attachment included
  • From: Suncor Base Mine Extension Project (IAAC/AEIC) <iaac.BaseMine-MineBase.aeic@canada.ca> Sent: June 2, 2021 1:22 PM To: Martin Olszynski <email address removed> Cc: Suncor Base Mine Extension Project (IAAC/AEIC) <iaac.BaseMine-MineBase.aeic@canada.ca> Subject: RE: Suncor Base Mine Extension - Commencement of the Impact Assessment - Projet d'agrandissement de la mine Base de Suncor - Début de l'évaluation d'impact Good day Mr. Olszynski. Thank you for your comments regarding the Final Tailored Impact Statement Guidelines (TISG) for the Suncor Base Mine Expansion project. I would like to assure you that your submission was given thorough consideration. I recognize however that there are fewer explicit references to adaptive management in the final version of the TISG. These changes were made at the advice of our specialists at the Agency. The Agency is updating its guidance on adaptive management to further elaborate on its meaning in the context of Impact Assessment. Until this guidance is finalized, the Agency will apply the existing definition and guidance for adaptive management to the Suncor Base Mine Expansion project. The Agency’s existing guidance can be found at Adaptive Management Measures under the Canadian Environmental Assessment Act - Canada.ca. The Agency’s current practice with adaptive management is still captured in Section 16 of the TISG (Follow-up Programs). It is not referred to as adaptive management in the TISG as the term is expected to be redefined in the Agency’s guidance that is under development. The Agency will be consulting with experts on the draft, including those with whom we previously engaged in spring 2020. As well, the TISG are not the only, or ...

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Attachment From Martin Olszynski to the Impact Assessment Agency of Canada re: Comments on Tailored Impact Statement Guidelines

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Martin Olszynski
  • Reference number: 144
  • Submitted: 2021-06-01
  • Project phase: Impact Statement
  • Please see attached document
  • Attachment included
  • From: Martin Olszynski <email address removed> Sent: June 1, 2021 9:17 AM To: Pineau, Maryse (IAAC/AEIC) <email address removed>; Suncor Base Mine Extension Project (IAAC/AEIC) <iaac.BaseMine-MineBase.aeic@canada.ca> Subject: Re: Suncor Base Mine Extension - Commencement of the Impact Assessment - Projet d'agrandissement de la mine Base de Suncor - Début de l'évaluation d'impact Good morning, I was disappointed to see that the finalized Tailored Impact Statement Guidelines do not reflect any of the evidence-based recommendations reflected in my submission re: adaptive management (available here: https://iaac- aeic.gc.ca/050/evaluations/proj/80521/contributions/id/53951). Indeed, there are actually fewer references to adaptive management in the finalized Guidelines as compared to the earlier draft. Neither version contains a clear definition of adaptive management to ensure a common understanding between the proponent, regulators, Indigenous peoples, and other stakeholders in terms of what adaptive management requires. The Supreme Court of Canada has stressed the importance of transparency and justification in the administration of statutory regimes such as the IAA (see Canada (Minister of Citizenship and Immigration) v. Vavilov, 2019 SCC 65 at para 14). Consequently, it is incumbent on the Agency to explain how it arrived at its approach to adaptive management in the finalized Guidelines considering the evidentiary record before it. I look forward to hearing from you, Martin Z. Olszynski Associate Professor, Faculty of Law University of Calgary, 2500 University Drive NW Calgary AB, T2N 1N4 Office: MFH 3346 <contact information removed> ...

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Attachment From Fort McKay First Nation to the Impact Assessment Agency of Canada re: Comment on Tailored Impact Statement Guidelines (see Reference #121)

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Fort McKay First Nation
  • Reference number: 136
  • Submitted: 2021-05-25
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • Please see attached document
  • Attachment included
  • 1 V.8 – May 2021 Guidance for Odour Impact Assessments and Odour Management for Proposed Oil Sands Projects on Fort McKay’s Traditional Territories (Draft- 2021) Guidance Document Overview and Summary Oil sands development related odours have been, and continue to be, a major issue for, and of concern to, the Community of Fort McKay. The assessment of the potential odour impacts of proposed oil sands projects on Fort McKay’s Traditional Territories both singly, and in combination with other approved and planned projects, is therefore an important component of project EIAs and/or applications. The Fort McKay Sustainability Department (FMSD), in its review of project applications, has identified what it considers are significant deficiencies with certain elements of the odour impact assessments (OIAs) that are part of a proposed project’s EIA and/or application. This Guidance Document has been prepared to provide oil sands developers with guidance on the FMSD’s expectations regarding OIAs for proposed projects on Fort McKay’s Traditional Territories. The following is a summary of the specific recommendations/requests in the Guidance Document. The technical basis and rationale for recommendations/requests are outlined in the body of the Guidance Document. Odorants Assessed in OIAs: In their assessment of potential project and cumulative development impacts on odours, the proponents of proposed oil sands projects on Fort McKay’s Traditional Territories include, but not necessarily be limited to, the odorants listed in Table 1. Odour Thresholds used in OIAs: 1. Proponents of proposed oil sands projects on Fort McKay’s Traditional Territories use whenever possible ...

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Attachment From Indigenous Services Canada to the Impact Assessment Agency of Canada re: Comments on Tailored Impact Statement Guidelines (see Reference #102)

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Indigenous Services Canada
  • Reference number: 135
  • Submitted: 2021-05-19
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • Please see attached document
  • Attachment included
  • Suncor Tailored Impact Statement Guidelines - Disposition Table Response requested by: May 18th, 2021 Department/Agency: Indigenous Services Canada IA Contact: [Debra Nkusi] Telephone: <contact information removed> Email: <email address removed> Comment # Section Page # Issue (i.e. rationale, including if critical or recommended, project- specific or general) Suggested edit (show original text with track changes) 1 3.2 Project Location 5 Note: ISC is currently working to add lands to reserve in the region. Distance of the project components to any federal lands and the location of any federal lands within the regional study area, including lands in a reserve or lands to be added to a reserve, within the meaning of subsection 2(1) of the Indian Act; 2 3.4 Project Components and Activities 6 Please revise the 5th bullet point under “The Impact Statement must” in order to include the rights of Indigenous peoples. Highlight activities that involve periods of increased disturbance to environmental, health, social and economic conditions or impacts on Indigenous peoples and the rights of Indigenous Peoples. 3 3.4 Project Components and Activities 6 Additional information is required in the 6th bullet point under “The Impact Statement must” pertaining to key cultural or archaeological sites. Include maps of key project components, boundaries of the proposed site with geographic coordinates of major existing infrastructure, proponent lands, and leased properties or lands, adjacent resource boundaries, jurisdictional boundaries adjacent land uses, key cultural and important environmental features. 4 3.4 Project Components and Activities 7 ISC ...

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Attachment From Mikisew Cree First Nation to the Impact Assessment Agency of Canada re: Comment on the draft Tailored Impact Statement Guidelines (see Reference #111)

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Mikisew Cree First Nation
  • Reference number: 134
  • Submitted: 2021-05-17
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • Please see attached documents
  • Attachment included
  • 1 Suncor’s BMX TISG Project Section Section Title Comments Recommendations 1.1 Introduction: Factors to be Considered in the Impact Assessment Proponents often propose to use a number of mitigation measures for upland and wetland plant communities, even though the effectiveness of some of the techniques is not supported by scientific evidence and/or Indigenous knowledge. It is important that any mitigation measures a proponent proposes are not only technically and economically feasible, but supported by scientific evidence and/or Indigenous knowledge. This requirement should be explicitly stated in the TISG whenever there is a discussion of mitigation measures (this includes the residual effects and cumulative effects sections). Scientific evidence should include studies published in peer- reviewed literature, and/or data from other projects in the region that is substantive enough to show clear evidence supporting the proposed mitigation measure. Indigenous knowledge, especially with respect to berries and other vegetation consumed or used by Indigenous communities, should come from the local community that will be affected by the development. Please revise the guidelines as follows: “The Guidelines correspond to factors listed in subsection 22(1) of the Act and prescribe that the impact assessment of a designated project must take into account: (b) mitigation measures that are technically and economically feasible and that would mitigate any adverse effects of the designated project, as demonstrated by scientific evidence, from peer-reviewed journals and/or data from other projects in the region, and/or local indigenous knowledge, when available;” 2.2 Proponent Information: ...
  • Attachment included
  • Transport Canada Navigational Study of the Lower Athabasca River – Outcomes and Technical Review Prepared for: Athabasca Chipewyan First Nation Industry Relations Corporation - Fort McMurray, Alberta Mikisew Cree First Nation Government and Industry Relations - Fort McMurray, Alberta Prepared by: Dr. Martin Carver, PEng/PGeo, PAg, (BC) PGeo (AB) AEA Project #404-21 February 4, 2020 Aqua Environmental Associates Nelson, BC CANADA TEL: (250) 354-7563 E-MAIL: aqua@netidea.com mailto:aqua@netidea.com Transport Canada Athabasca River Navigation Study – Review & Implications; Feb 4, 2020 2/26 Aqua Environmental Associates EXECUTIVE SUMMARY In 2014, Transport Canada (TC) initiated a four-phase study to establish a navigation profile of the lower Athabasca River between Fort McMurray and Embarras, south of Fort Chipewyan, and use this information to identify potential impacts of oilsands water withdrawals on navigation of this river. TC had become aware that users of the lower Athabasca River were experiencing poor navigability during periods of low flow. Given the interaction between mainstem water surface elevations and channel bathymetry, if water surface elevation is sufficiently altered by water withdrawals then navigation can be impeded leading to a reduced ability to use the river as a travel corridor and lost access to areas important in the exercise of traditional-use activities. To exercise its legal responsibilities for protecting the navigability of listed Canadian waterways, TC decided to undertake a four-phase navigation study on the mainstem of the lower Athabasca ...

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Attachment From Lakeland Métis Community to the Impact Assessment Agency of Canada re: Comment on the draft Tailored Impact Statement Guidelines

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Lakeland Métis Community
  • Reference number: 132
  • Submitted: 2021-05-10
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • Please see attached document
  • Attachment included
  • May 7, 2021 Lakeland Métis Community COMMENTS ON THE DRAFT TAILORED IMPACT STATEMENT GUIDELINES FOR THE SUNCOR BASE MINE EXTENSION PROJECT Lakeland Métis Community – Comments on the draft Tailored Impact Statement Guidelines for Suncor Base Mine Extension 1 Comment # Section ID and Title Sub-section; Page # TISG Requirement(s) Comments and Recommendations 01 3 Project Description 3.4 Project Components and Activities p. 6 Include maps of key project components, boundaries of the proposed site with geographic coordinates, major existing infrastructure, proponent lands, and leased properties or lands, adjacent resource lease boundaries, adjacent land uses and any important environmental features. LMC recommends that maps should also include any important cultural areas identified by Indigenous groups if not subject to confidentiality. 02 3 Project Description 3.4 Project Components and Activities Gap in requirements for engagement on project activities and components. LMC notes that a requirement in the Agency’s template TISG was not included in this section: “Evidence that input from diverse subgroups was sought through engagement activities to identify potential effects or other concerns and issues must be provided. The information must be sufficient to provide an analysis regarding the project’s impacts in the context of potential interaction between VCs" (IAAC 2020, TISG Template p.10) LMC requests that this statement be included in section 3.4. 03 3 Project Description 3.5 Workforce Requirements p.7 Gap concerning Indigenous workforce data LMC is concerned that direction is not included concerning information related to data on the ...

Attachment Comments on Base Mine Extension draft, Tailored Impact Statement

  • Suncor Base Mine Extension Project
  • Author: Ian Peace
  • Reference number: 125
  • Submitted: 2021-05-08 - 1:45 AM
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • see attached document
  • Attachment included
  • Ian Peace Salt Spring Island, BC Email: airtime@agt.net May 7, 2021 Impact Assessment Agency of Canada 160 Elgin Street Ottawa, ON Re: Suncor Base Mine Extension Project – Public Comment on the Draft Tailored Impact Statement Guidelines To Whom It May Concern: Please accept the following comments on the draft Tailored Impact Statement Guidelines (draft Guidelines) for Suncor’s Base Mine Extension Project (BMX). General and detailed comments follow a brief description of my knowledge of the topic. Field experience with Oil and gas exploration informed my First Nations Consultation work in the oil sands region. Consultation work provided opportunities to live in Fort McMurray and Fort Chipewyan for which, I remain grateful. These activities sparked my interest in oil sand developments, which triggered research. In 2006, I earned a BA in Anthropology at University of Calgary. In 2019, I wrote a thesis, “Oil Sand Tailings Water in the Athabasca River,” which completed my MSc Environment and Management at Royal Roads University. General Comments: a background for detailed comments My comments follow from the tension between Suncor’s unspecified claims to recycle almost all the water diverted from the Athabasca River (AR) and specific information that contradicts these claims. A large measure of Suncor’s stewardship in the mineable oils sands region depends on their claim to recycle Oil Sands Process-Affected Water (OSPW). Over the past two decades, Suncor’s Sustainability Reports claim that 75 – 88% of the water required to drive the Clark Hot Water Process (CHWP) “is recycled tailings water” (Suncor Energy Inc., 2012, p. 13; Suncor Energy Inc., ...

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Attachment Smith's Landing First Nation Comments on the Draft Indigenous and Engagement Partnership Plan dated February 26, 2021

  • Suncor Base Mine Extension Project
  • Author: Smith's Landing First Nation submitted by Becky Kostka
  • Reference number: 124
  • Submitted: 2021-05-07 - 7:42 PM
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • See attached letter
  • Attachment included
  • Page 1 of 3 May 7, 2021 VIA REGISTRY WEBSITE Impact Assessment Agency of Canada Suncor Base Mine Extension Project 160 Elgin Street, 22nd Floor, Ottawa ON K1A 0H3 Dear Sir or Madame: Re: Smith’s Landing First Nation Comments on the Draft Indigenous and Engagement Partnership Plan dated February 26, 2021 I am writing in response to the Impact Assessment Agency of Canada’s (the “Agency”) request for comments on the draft Indigenous and Engagement Partnership Plan dated February 26, 2021 (the “Plan”). The Agency has taken a step in the right direction by providing more a transparent and open process for consultation on the proposed Suncor Base Mine Extension Project (the “Project”) as outlined in the draft Plan. We submit our comments below for the Agency’s consideration for improving the Plan to ensure meaningful consultation, and where appropriate, accommodation of potentially affected Indigenous groups, such as Smith’s Landing First Nation (“SLFN”). Comments on Draft Plan 1. Impact Assessment Agency of Canada’s objectives (section 3, page 4 to 5) SLFN recommends the following amendments (in red and underlined) to this section to ensure that the Crown upholds its duty to consult on the proposed Project: • Conduct adequate Crown consultation on the potential positive and adverse effects (direct, indirect, cumulative, residual and incidental) of the Project and adverse impacts of the Project on the exercise of Aboriginal and/or Treaty rights of the Indigenous peoples of Canada recognized and affirmed in section 35 of the Constitution Act, 1982 (Aboriginal or Treaty rights); • Meaningfully engage with Indigenous communities throughout the impact assessment process ...

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Attachment Smith's Landing First Nation Comments on the Draft Tailored Impact Statement Guidelines dated February 26, 2021

  • Suncor Base Mine Extension Project
  • Author: Smith's Landing First Nation submitted by Becky Kostka
  • Reference number: 123
  • Submitted: 2021-05-07 - 7:39 PM
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • See attached letter
  • Attachment included
  • Page 1 of 8 May 7, 2021 VIA REGISTRY WEBSITE Impact Assessment Agency of Canada Suncor Base Mine Extension Project 160 Elgin Street, 22nd Floor, Ottawa ON K1A 0H3 Dear Sir or Madame: Re: Smith’s Landing First Nation Comments on the Draft Tailored Impact Statement Guidelines dated February 26, 2021 I write on behalf of Smith’s Landing First Nation (“SLFN”) in response to the Impact Assessment Agency of Canada’s (the “Agency”) request for feedback on the draft Tailored Impact Statement Guidelines dated February 26, 20211 (the “Guidelines”). SLFN wishes to participate in the Planning Phase by providing comments on the Guidelines to ensure that Suncor Energy Inc. (the “Proponent” or “Suncor”) has a comprehensive foundation for preparing the Impact Statement which will consider and assess potential impact of the Suncor Base Mine Extension Project (“Project”) on the environment and Aboriginal and Treaty rights. Unfortunately, SLFN’s comments are limited in nature because the funding provided by the Agency was not enough to conduct a detailed review of all components of the Guidelines. Please find our comments below for your review and consideration. Comments on Guidelines 1. Regulatory framework (section 3.3) The Agency requires the Proponent to identify legislation and other regulatory approvals that are applicable to the Project at the federal, provincial, regional and municipal levels.2 We request that the Agency revise this section to list the specific legislation and require the Proponent to complete a concordance table indicating how the applicable legislation were considered rather than leaving identification at the discretion of the Proponent. 1 Impact ...

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Attachment From Fort Chipewyan Métis Association Local 125 to the Impact Assessment Agency of Canada re: Comment on the draft Tailored Impact Statement Guidelines

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Fort Chipewyan Métis Association Local 125
  • Reference number: 128
  • Submitted: 2021-05-07
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • Please see attached document
  • Attachment included
  • Suncor Base Mine Extension Project D R A F T T A I L O R E D I M P A C T S T A T E M E N T G U I D E L I N E S P U R S U AN T T O T H E I M P A C T A S S E S S M E N T A C T February 23, 2021 DRAFT FOR PUBLIC COMMENT I M P A C T A S S E S S M E N T A G E N C Y O F C A N A D A T A I L O R E D I M P A C T S T A T E M E N T G U I D E L I N E S - S U N C O R B A S E M I N E E X T E N S I O N P R O J E C T i Contents List of Abbreviations and Acronyms ................................................................................................ iv 1. Introduction ............................................................................................................................... 1 1.1. Factors to be considered in the Impact Assessment ...................................................................... 2 2. Proponent information ............................................................................................................. 43 2.1. The proponent ............................................................................................................................. 43 2.2. Qualifications of individuals preparing the Impact Statement .......................................................... 4 3. Project description .................................................................................................................... 4 3.1. Project overview ............................................................................................................................ 4 3.2. Project location ...

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Attachment From Suncor Energy Inc to the Impact Assessment Agency of Canada re: Comment on the draft Tailored Impact Statement Guidelines (see Reference #122)

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Suncor Energy Inc
  • Reference number: 131
  • Submitted: 2021-05-07
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • Please see attached document
  • Attachment included
  • Suncor Energy Inc 2844-150 6th Ave SW Calgary AB T2P 3E3 www.suncor.com May 7, 2021 Via Email Only: iaac.BaseMine-MineBase.aeic@canada.ca Impact Assessment Agency of Canada 22nd Floor, Place Bell 160 Elgin Street Ottawa, ON K1A 0H3 Re: Suncor Comments on Draft Tailored Impact Statement Guidelines Suncor Energy Inc (Suncor) has reviewed the draft Tailored Impact Statement Guidelines (Draft TISG) for the Base Mine Extension Project1 (Project) developed by the Impact Assessment Agency of Canada (IAAC) and released for public comment on February 26, 2021. Suncor’s comments on the Draft TISG consist of this letter, outlining key ways in which Suncor believes the Draft TISG should be improved, and technical comments that are in the attached Appendix. Suncor appreciates the opportunity to provide these comments and to better understand input from communities and government agencies on the Draft TISG. Summary: Key ways in which Suncor believes the Draft TISG should be improved fall into five areas: (i) proportional engagement (ii) impact statement validation (iii) alternatives assessment (iv) valued components (v) human health and social conditions. Proportional Engagement Suncor will consult with all Indigenous groups identified in the Draft Indigenous Engagement and Partnership Plan 2 . However, the Draft TISG do not adequately recognize that some Indigenous groups will be impacted more than others and as a result will require more engagement. Specifically, requirements in the Draft TISG for engagement with Indigenous groups are rooted in the Crown’s duty to consult and, if appropriate, accommodate Indigenous groups. The content of this duty varies with ...

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Attachment From Natural Resources Canada to the Impact Assessment Agency of Canada re: Comment on the draft Tailored Impact Statement Guidelines and Permitting Plan

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Natural Resources Canada
  • Reference number: 117
  • Submitted: 2021-05-07
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • Please see attached document
  • Attachment included
  • May 7, 2021 CIAR File No.: 80521 Chelsea Fedrau Project Manager, Prairie and Northern Region Impact Assessment Agency of Canada Re: Request for Federal Authority Advice on the Draft Tailored Impact Statement Guidelines and the Draft Permitting Plan for the Suncor Base Mine Extension Project On February 26th, the Impact Assessment Agency of Canada (the Agency) requested that Natural Resources Canada (NRCan) review the draft Tailored Impact Statement Guidelines (TISG) and draft Permitting Plan for the proposed Suncor Base Mine Extension Project (the Project) near Fort McMurray, Alberta. NRCan has conducted its review pursuant to section 23(a) of the Impact Assessment Act, as a federal authority in possession of specialist or expert information or knowledge with respect to a designated project. Background on NRCan’s review can be found in the Appendix below, and suggested revisions to the TISG can be found in tracked changes in the document entitled NRCan Final Revisions – Suncor BMX – TISG (May 2021). If you have any questions, please contact me via e-mail at or by phone at . Thank you, Walker Smith Environmental Assessment Officer Office of the Chief Scientist cc: John Clarke – Director, Environmental Assessment <Original signed by> <email address removed> <email address removed> <contact information removed> Page 2 of 4 Appendix: Natural Resources Canada’s Background Information Regarding the Review of the Tailored Impact Statement Guidelines and Permitting Plan Context: Natural Resources Canada (NRCan) seeks to enhance the responsible ...

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Attachment From Athabasca Chipewyan First Nation to the Impact Assessment Agency of Canada re: Comment on the draft Tailored Impact Statement Guidelines

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Athabasca Chipewyan First Nation
  • Reference number: 120
  • Submitted: 2021-05-07
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • Please see attached document
  • Attachment included
  • -7 .f.4f.C.T1 ACFN ATHABASCA CHIPEWYAN FIRST NATION I www.acfn.com May 7, 2021 Suncor Base Mine Extension Project Impact Assessment Agency of Canada (IAAC) 160 Elgin St, 22nd Floor Ottawa, Ontario K1A 0H3 via email: IAAC.BaseMine-MineBase.AEIC@canada.ca Ms. Chelsea Fedrau Project Manager, Prairie and Northern Region Impact Assessment Agency of Canada 9700 Jasper Avenue, Suite 1145 Edmonton, Alberta T5J 4C3 Dear Ms. Fedrau, Re: Suncor Base Mine Extension (BMX) - Draft Tailored Impact Statement Guidelines (TISG) The Athabasca Chipewyan First Nation (“ACFN”) Dene Lands and Resource Development (“DLRM”) has reviewed the Draft TISG issued by the Impact Assessment Agency of Canada (IAAC) for the Suncor BMX Project. We are writing to submit our comments on the TISG to IAAC, as well as inform IAAC of the review process established between Suncor and ACFN. Earlier this year, DLRM reviewed Suncor’s BMX Project Information and identified ACFN’s anticipated impacts of the Project on the ability of ACFN members to exercise their Aboriginal and Treaty rights. In doing so, DLRM also identified whether the anticipated impacts on ACFN were (a) direct Project impacts, or (b) indirect, cumulative, regional impacts. Consistent with the long-term bilateral process that ACFN and Suncor have established, direct impacts of the Project and appropriate mitigation are being discussed with Suncor, whereas anticipated indirect, cumulative effects will be brought forward to Canada and Alberta for mitigation and management by the appropriate responsible authority(ies). This is the context for the following comments submitted by ACFN on IAAC’s ...

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Attachment From Willow Lake Métis Nation to the Impact Assessment Agency of Canada re: Comment on the draft Tailored Impact Statement Guidelines

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Willow Lake Métis Nation
  • Reference number: 118
  • Submitted: 2021-05-07
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • Please see attached document
  • Attachment included
  • Willow Lake Métis Nation May 7, 2021 Impact Assessment Agency Canada Consultation Operations Division 160 Elgin St., 22nd Floor Ottawa, ON K1A 0H3 Attention: Ms. Claudette Bois Re: Suncor Base Mine Extension Project - Tailored Impact Statement Guidelines and Indigenous Engagement and Partnership Plan Willow Lake Métis Nation (WLM) is providing these comments to the Impact Assessment Agency of Canada (IAAC) regarding the Suncor Basemine Extension Project (the Project) Tailored Impact Statement Guidelines (TISG) and Indigenous Engagement and Partnership Plan (IEPP). WLM would like to acknowledge Suncor and IAAC’s support in this process, as well as our appreciation for recognition of the Nation’s section 35 rights. Suncor is already a valued partner to WLM, and the Nation intends to work with Suncor throughout this regulatory process regarding Project-specific impacts, mitigation, and follow up in the spirit of our existing agreement. The Project is located within WLM’s traditional territory and based on review of the TISG, WLM recommends the inclusion of the following valued components related to the biophysical environment in the Project impact assessment: • Surface water and groundwater • Wildlife and wildlife habitat, specifically including moose, caribou, deer, game birds such as grouse and duck, and species at risk • Air quality and emissions • Fish and fish habitat • Climate change Regarding Indigenous Nations and peoples, WLM supports the assessment of the following values: • Land Use, Treaty and Aboriginal/Indigenous Rights, and Culture • Health <contact information removed> • Social • Economic WLM also strongly supports the ...

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Attachment From Driftpile Cree Nation to the Impact Assessment Agency of Canada re: Comment on the draft Tailored Impact Statement Guidelines and Indigenous Engagement and Partnership Plan

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Driftpile Cree Nation
  • Reference number: 119
  • Submitted: 2021-05-07
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • Please see attached document
  • Attachment included
  • Driftpile Cree Nation Suncor Base Mine Extension Project May 7, 2021 Impact Assessment Agency of Canada 160 Elgin St, 22nd Floor Ottawa, Ontario K1A 0H3 Telephone: 343-549-5813 IAAC.BaseMine-MineBase.AEIC@canada.ca Re: Suncor Base Mine Extension – DRAFT Tailored Impact Statement Guidelines and Indigenous Engagement Plan The proposed Suncor Base Mine Extension (“the Project”) falls within the Traditional Territory of Driftpile Cree Nation (DCN) including our Treaty No. 8 to which Driftpile was a founding signatory. Our ancestors and present-day community members have lived in harmony with these lands and waters since time beyond memory. These lands have provided us with everything that we need to sustain our life, culture, and spirit. We therefore have a sacred duty to protect the environment and act as stewards, so that it may continue to sustain the wildlife, plants and other creatures which depend on it. We use the lands in the immediate vicinity of the Project to exercise our Aboriginal and Treaty Rights. It is for this reason that we are participating in the Impact Assessment for this Project. We have prepared the comments below on the draft Tailored Impact Statement Guidelines (TISG) and the draft Indigenous Engagement and Partnership Plan (IEPP). These are being submitted to the Impact Assessment Agency of Canada (IAAC, or “the Agency”) so that they can be carefully incorporated into the final versions of these documents. The requested changes are necessary to ensure that impacts to DCN’s Aboriginal and Treaty rights are understood, mitigated and avoided. It will also result in an improved process for all those involved. We are willing to meet with the IAAC and discuss ...

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Attachment From Chard Métis Nation to the Impact Assessment Agency of Canada re: Comment on the draft Indigenous Engagement and Partnership Plan and Public Participation Plan

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Chard Métis Nation
  • Reference number: 126
  • Submitted: 2021-05-07
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • Please see attached document
  • Attachment included
  • May 6th, 2021 Impact Assessment Agency of Canada 22nd Floor, Place Bell 160 Elgin Street Ottawa ON K1A OH3 IAAC.BaseMine-MineBase.AEIC@canada.ca RE: Draft Indigenous Engagement and Partnership Plan and Draft Public Participation Plan for Suncor Energy Inc.’s Proposed Base Mine Extension Project At the request of the Chard Métis Nation (CMN), I have reviewed the Impact Assessment Agency of Canada (the Agency) Draft Indigenous Engagement and Partnership Plan (IEPP) 1 and Draft Public Participation Plan (PPP) 2 for the Impact Assessment (IA) for Suncor Energy Inc’s (the Proponent) Base Mine Extension Project (the Project) issued Feb 26, 2021 (Canadian Impact Assessment Registry File No. 80521). The review of the Draft Plans is guided by the following questions: • How does the Agency intend to approach the Indigenous Engagement and Consultation process and how would this relate to the Chard Métis Nation? • How does the Agency intend to assess the Project’s potential impact to community’s traditional land use and how would this relate to Chard’s Métis culture, Aboriginal rights and traditional land and resource use? • What are some of the potential gaps in the process and procedures outlined by the Draft Plans and how might these be addressed? Information of relevance to the CMN is identified, gaps are considered and recommendations for changes to the Draft Plans are provided for each of these sections. 1Impact Assessment Agency of Canada 2021. “Draft Indigenous Engagement and Partnership Plan: Impact Assessment of the Suncor Base Mine Extension Project.” https://iaac-aeic.gc.ca/050/evaluations/document/138268 2 Impact Assessment Agency of Canada ...

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Attachment From McMurray Métis to the Impact Assessment Agency of Canada re: Comment on the draft Tailored Impact Statement Guidelines

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Fort McMurray Métis Local Council 1935
  • Reference number: 127
  • Submitted: 2021-05-07
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • Please see attached document
  • Attachment included
  • SUNCOR BASEMINE EXTENSION TAILORED IMPACT STATEMENT GUIDELINES COMMENTS FROM THE MCMURRAY MÉTIS MÉTIS NATION OF ALBERTA ASSOCIATION – FORT MCMURRAY MÉTIS LOCAL COUNCIL 1935 MAY 4, 2020 <contact information removed> Métis Nation of Alberta Association Fort McMurray Local Council 1935 Page 1 of 6 Base Mine Extension Consultation and Engagement This memo letter is provided to supplement the direct comments provided in our accompanying document. Consultation and Engagement Suncor and the McMurray Métis have entered into a consultation and engagement plan process with Suncor on this Project. In the event that the project is approved, the consulation and engagement plan provides for ongoing consultation and engagement between the McMurray Métis and Suncor in relation to the Proposed Project Applications. As such, consultation and engagement planning will occur annually for the life of the Project application process and, if approved, through project construction, mining operations, mine development planning, environmental monitoring, and reclamation. McMurray Métis and Crown Consultation We understand that the Project been designated for Federal review. Given this, McMurray Métis expects to be fully engaged in Crown Consultation for the life cycle of the BMX impact assessment process with both Alberta and Canada. Furthermore, McMurray Metis assert that the Crown has a duty to enter into a bilateral consultation agreement with McMurray Métis in relation to Impacts to Section 35 Rights emanated from the Project. In particular, the McMurray Métis is interested in discussing how Impacts to section 35 rights may be mitigated or accommodated by the ...

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Attachment From Fort McKay First Nation to the Impact Assessment Agency of Canada re: Comment on the draft Tailored Impact Statement Guidelines

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Fort McKay First Nation
  • Reference number: 121
  • Submitted: 2021-05-07
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • Please see attached document
  • Attachment included
  • 001198-0001.0001 00667155 1 May 7, 2021 Charles Gauthier, Senior Consultation Lead, Crown Consultation Operations Division, Impact Assessment Agency of Canada 160 Elgin Street, 24th Floor Ottawa, Ontario K1A 0H3 Email: IAAC.BaseMine-MineBase.AEIC@canada.ca Dear Madame or Sir, RE: Fort McKay First Nation comments on Suncor Base Mine Extension (BMX) Project Draft Tailored Impact Assessment Guidelines (TISGs) – Project Reference #80521 On behalf of the Fort McKay First Nation (Fort McKay), we are writing to you regarding the Suncor Base Mine Extension (BMX) Project Draft Tailored Impact Assessment Guidelines (TISGs). The Project is located at Townships 90, 91, 92, and Ranges 10, 11 W4M and is within Fort McKay’s Traditional Territory: • At approximately 21 kilometres south of the residential community of Fort McKay at Reserve 174; • At approximately 70 km southeast of Fort McKay First Nation’s sacred Moose Lake Reserves (174A&174B); and • Intersects Registered Fur Management Area #587, which is a trapline held by a Fort McKay First Nation member. Traplines have been areas of intensive use for the exercise of treaty rights and traditional land use for Fort McKay families; and • Intersecting the Project Development Area there are at least documented at least 81 documented traditional use sites and another 51 within 2 km around the PDA. These sites represent many traditional uses and values including but not limited to access, trails, camping, plant and wildlife habitat, trapping, hunting, fishing, and gathering areas for medicine, food and spiritual purposes and cultural transmission, place names, and historic resources. The ...

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Attachment From Environment and Climate Change Canada to the Impact Assessment Agency of Canada re: Comment on the draft Tailored Impact Statement Guidelines

  • Suncor Base Mine Extension Project
  • Author: Administrator on behalf of Environment and Climate Change Canada
  • Reference number: 129
  • Submitted: 2021-05-07
  • Project phase: Planning
  • Participation notice: Public Notice - Suncor Base Mine Extension Project - Comment Period on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan
  • Please see attached document
  • Attachment included
  • May 7, 2021 Via email: Chelsea Fedrau Impact Assessment Agency of Canada 1145-9700 Jasper Avenue , Edmonton, AB T5J 4C3 Dear Chelsea Fedrau, Re: Review of Draft Tailored Impact Statement Guidelines (d/TISG) and Draft Permitting Plan during public comment – Suncor Base Mine Extension Project (BMX) Environment and Climate Change Canada (ECCC) is providing comments on the draft Tailored Impact Statement Guidelines (d/TISG) and the draft Permitting Plan for the Suncor Base Mine Extension Project as requested by the Impact Assessment Agency of Canada’s (IAAC or “Agency”) February 26, 2021 email. Comments have been provided on the February 26 version of the d/TISG posted to the Registry for public comment. ECCC has reviewed the Draft Permitting Plan and have no comments at this time. Our advice is based on ECCC’s mandate in the context of the Species at Risk Act (SARA), the Migratory Birds Convention Act 1994 (MBCA), pollution prevention provisions of the Fisheries Act, and the Canadian Environmental Protection Act 1999 (CEPA). ECCC File: 4194-10-3/6327 CIAR Reference: 80521 Environmental Protection Operations Directorate Prairie & Northern Region 9250 49 Street , Edmonton, AB T6B 1K5 <email address removed> Please contact Gillian Brown at if you need more information. Sincerely, Margaret Fairbairn A/ Regional Director Environmental Protection Operations Directorate cc: Jody Small, Head, EA South, EPOD, ECCC Gillian Brown, Senior EA Officer, EPOD, ECCC Attachments: SuncorBMX-DraftTISGpostedFeb262021-ECCCCommentsFinal <contact information removed> <Original signed by> Suncor Base Mine Extension ...

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