Suncor Base Mine Extension Project

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 Comment removed by Administrator due to administrative purposes

• Suncor Base Mine Extension Project
• Author: Administrator on behalf of Suncor Energy Inc
• Reference number: 122
• 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

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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Attachment From Ian Peace to the Impact Assessment Agency of Canada re: Comment on the draft Tailored Impact Statement Guidelines (see Reference #125)

• Suncor Base Mine Extension Project
• Author: Administrator on behalf of Ian Peace
• Reference number: 130
• 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
• Ian Peace Salt Spring Island, BC Email: 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., 2019, p. 86). In ...

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Attachment Comment removed by Administrator due to administrative purposes

• Suncor Base Mine Extension Project
• Author: Mikisew Cree First Nation submitted by Charlotte Collington
• Reference number: 111
• Submitted: 2021-05-06 - 8:09 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

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

• Suncor Base Mine Extension Project
• Author: Administrator on behalf of Employment and Social Development Canada
• Reference number: 110
• Submitted: 2021-05-06
• 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
• Tailored Impact Statement Guidelines - Disposition Table Response requested by: April 7, 2021 Department/Agency: Employment, Social Development Canada IA Contact: Eric Lalonde, Policy Analyst Telephone: <contact information removed> Email: <email address removed> Section Issue (i.e. rationale, including if critical or recommended, project-specific or general) Suggested edit (show original text with Track Changes) 11.1 Baseline Conditions  Recommend specifying the working conditions to be described  Recommend clarifying what is to be described in regards to training. Education level is mentioned and an aggregate level of on the job training for the the study area’s workforce would not likely be available. Describe the workforce in the study area, including the availability of skilled and unskilled workers, education level, existing working conditions, wages and average salary range, full-time and part-time employment, training, and gender gaps in wages and qualifications for skilled trades. If the project’s labour force is anticipated to draw beyond the regional labour force, describe the same information for areas (regions or provinces) with potential labour supply. 11.2.1 Training  Recommend that the text specify a focus on developing the local, regional, and Indigenous workforce. Original: Describe local and regional workforce development and training plans including those specific for Indigenous people. Amended: Describe plans for developing and training the local and regional workforce including specific plans for Indigenous people. 11.2.2 Employment  Recommend clarifying that local skills and labour shortages alone ...

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Attachment From Little Red River Cree Nation to the Impact Assessment Agency of Canada re: Comment on the draft Indigenous Engagement and Partnership Plan

• Suncor Base Mine Extension Project
• Author: Administrator on behalf of Little Red River Cree Nation
• Reference number: 115
• Submitted: 2021-05-06
• 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
• Draft Indigenous Engagement and Partnership Plan I M P A C T A S S E S S M E N T O F T H E 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 February 26, 2021 DRAFT VERSION 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 D R A F T I N D I G E N O U S E N G A G E M E N T A N D P A R T N E R S H I P P L A N – D R A F T V E R S I O N 2 Contents Draft Indigenous Engagement and Partnership Plan ....................................... 1 Indigenous Engagement and Partnership Plan ........................................................... 3 1. Introduction ..................................................................................................... 3 2. Description of the proposed Project ................................................................ 4 3. Objectives of Indigenous engagement and partnership .................................. 4 4. Indigenous communities ................................................................................. 6 5. Engagement and consultation tools, and methods ......................................... 8 6. Distinction between the Review Panel and the Crown Consultation Operations Team ............................................................................................ 9 7. Engagement and consultation approach ...................................................... 10 8. Participant Funding ....................................................................................... 17 9. Federal Agencies’ roles and responsibilities ................................................. 17 10. How to submit comments ...

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Attachment From Little Red River Cree Nation to the Impact Assessment Agency of Canada re: Comment on the Detailed Project Description Summary

• Suncor Base Mine Extension Project
• Author: Administrator on behalf of Little Red River Cree Nation
• Reference number: 114
• Submitted: 2021-05-06
• 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
• Notes for development of a LRRCN Project Detailed Impact Assessment Statement 4 April, 2021 LRRCN TAILORED IMPACT STATEMENT-SUNCOR BASE MINE EXTENSION From review of Detailed Project Description Summary document, July, 2020 Following a review of the Detailed Project Description Summary for the Suncor Base Mine Extension Project, I compiled a list of the matters which LRRCN Lands could address in relation to this project’s potential for positive or negative impacts on the LRRCN. In these Notes, I have used an asteric * to identify matters which are related to the Nations desire/opportunity to use FMU F 23 for provision of ecosystem services. I note that Suncor is committed to working with Indigenous communities (among others) to seek approval for this Project, while caring for each other and the earth, with a view to the long-term interests of Canada and its Peoples (pg 1). I note that Suncor will concurrently be pursuing paths to reduce emissions…and sequester carbon in ways that produce net benefits (pg 1). These statements are relevant to the intent and objective of the LRRCN to seek an agreement with Canada, the government of Alberta, and Suncor, for conversion of the Nation’s forest tenure-FMU F 23- into a First Nation Forest Conservation Management Area (i.e, an area-based forest tenure, managed under the provisions of a provincial Forest Management Agreement between Little Red River Askee and AA & F, setting out the provincial regime under which Little Red River Forestry Ltd. would be responsible for some agreed-upon combination of growth, sustainable harvest and regrowth of timber, which is compatible with provision of some list of environmental ...

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Attachment From Fisheries and Oceans 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 Fisheries and Oceans Canada
• Reference number: 112
• Submitted: 2021-05-05
• 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
• 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 26, 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 1. Introduction ............................................................................................................................... 1 1.1. Factors to be considered in the Impact Assessment ...................................................................... 2 2. Proponent information ............................................................................................................... 3 2.1. The proponent ............................................................................................................................... 3 2.2. Qualifications of individuals preparing the Impact Statement .......................................................... 4 3. Project description .................................................................................................................... 4 3.1. Project overview ............................................................................................................................ 4 3.2. Project location ............................................................................................................................. 4 3.3. Regulatory framework ...
• Attachment included
• Tailored Impact Statement Guidelines - Disposition Table Response requested by: April 7, 2021 Department/Agency: Fisheries and Oceans Canada IA Contact: Laura Phalen Telephone: <contact information removed> Email: <email address removed> *prefer email over phone Section / Page Issue (i.e. rationale, including if critical or recommended, project-specific or general) Suggested edit (show original text with Track Changes) 3.2, page 5 Recommended, general: Suggested language is more technically applicable to the subject matter.  all permanent, and intermittent, or ephemeraltemporary waterbodies and watersheds potentially affected by the project; 7.1, page 17 Recommended, general: It is common to see baseline sampling programs that are not well linked to the ability to verify predictions made in the effects assessment or post-impact data collection (ie monitoring program). It is critical that proponents are aware from the start of project planning that these links should be considered before deciding on data collection programs or modelling approaches.  clearly describe the study design, including how use of existing data, and data collected for the project will inform the effects assessment and monitoring programs;  include baseline data collected in a way that makes analyses, extrapolations and reliable predictions possible. The collated data should make it possible to carry out analyses to estimate pre-project baseline conditions, predict impacts, assess and compare post- project conditions, all at the scale of the project, and the local and regional assessment areas;  provide detailed descriptions of data sources and data ...

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Attachment From Métis Nation of Alberta - Region 1 to the Impact Assessment Agency of Canada re: comments on draft Tailored Impact Statement Guidelines, Indigenous Engagement and Partnership Plan, and Public Participation Plan

• Suncor Base Mine Extension Project
• Author: Administrator on behalf of Métis Nation of Alberta - Region 1
• Reference number: 109
• Submitted: 2021-05-05
• 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
• April 30th 2021 Impact Assessment Agency of Canada 22nd Floor, Place Bell 160 Elgin Street Ottawa ON K1A OH3 IAAC.BaseMine-MineBase.AEIC@canada.ca RE: Suncor Base Mine Extension Project On behalf of Metis Nation of Alberta Region 1, please find the following comments in response to the Draft Tailored Impact Statement Guidelines, Draft Indigenous Engagement and Participation Plan, and the Draft Public Participation Plan for the proposed Suncor Base Mine Extension Project (Canadian Impact Assessment Registry File No:. 80521). After reviewing the draft documents, several oversights were found consistently, throughout all the documents reviewed, in relation to both the language and content presented. The comments provided within this letter have been presented in general terms to address the consistent omissions found, as well as in table format to speak to specific areas and language within each document. General comments reflect missing language regarding Section 35 and Treaty rights and the inconsistent use of terms for defining Indigenous peoples, appropriate determination of adequacy within the processes, the need for mechanisms to mitigate conflict and ensure meaningful consideration of Indigenous contributions, the contextualization of baseline measurements, and commitment for on-going monitoring and collaboration for end-of-project activities such as reclamation. Specific comments related to the documents and their respective sections, and recommended language considerations have been attached in table format. The language used in the comment submission that references "the Agency" refers to the Impact Assessment Agency of Canada, and "the Proponent" refers to Suncor Energy Inc. ...

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