Resubmission of comments on the Upper Beaver Project

Greetings,

Based on the conditions set out by the Impact Assessment Act, it appears obvious that an Impact Assessment must take place. This project has a proposed ore production capacity between 4,000-10,000 tonnes per day, and the diversion of 90,000,000 m³ of water per year. This represents a significant impact to the regional environment, as well as the surrounding watershed. These impacts must not be underestimated, and we believe that the Impact Assessment Agency has a responsibility to fully examine all impacts of this proposed project through an Impact Assessment Process.

Temagami First Nation (TFN) would like to clarify that although our traditional territory is not within the project area, our close proximity means that there is a likely impact to the watersheds which flow through our traditional territory of n’Daki Menan.

One concern we would like to see addressed is clarifying if members of a local First Nation have participated in the archaeological assessments which were conducted. First Nations being directly involved in the work which publicly reveals their own history is an invaluable step towards reconciliation which cannot be overlooked.

We also seek clarification on how local First Nations groups will be involved in the aquatic habitat replacement process. Having conducted our own Use and Occupancy Study, we would be able to provide guidance and recommendations at a later point.

TFN has examined the cumulative effects within the confines of our own territory, and would be interested to know what the Impact Assessment Agency guidance on this matter will be.

Regarding impacts to migratory birds, studies will be required outlining which species are in the area, if any Species at Risk are in close proximity to the project area, and what measures will be implemented to ensure minimal disturbance (for example, distance and timing buffers).

In short, it is our opinion that the Impact Assessment Agency of Canada should consider the very serious consequences that will occur should a project of this nature move forwards. The draining of York Lake must not be considered lightly. Temagami First Nation/Teme-Augama Anishnabai have experienced, and are still experiencing the devastating impacts that mining leaves in its wake.

We understand that these comments will be posted publicly in the IAA registry.

Thank you,