Northern Road Link Project

Attachment Please do not harm wildlife

• Northern Road Link Project
• Author: Nicole Corrado
• Reference number: 131
• Submitted: 2024-01-29 - 3:05 PM
• Project phase: Impact Statement
• This project will likely harm wildlife and therefore should not go forth.  Please do not use animal testing for pollution monitoring.  https://www.change.org/p/stop-testing-sewer-water-on-laboratory-fishPlease only use non lethal ways to live with geese, beavers, and other wildlife.  Develop a Living With Coyotes program with the animal welfare organization Coyote Watch Canada.  www.coyotewatchcanada.com (https://www.coyotewatchcanada.com/) Please only use non lethal ways to manage wildlife.  There are humane, non lethal ways to deal with beavers.  Here's a great resource.  https://thefurbearers.com/downloads/PDFs/Beaver%20Book%20-%202019-10-08%20The%20Fur-Bearers.pdf?fbclid=IwAR1fP2wOYQKbWREX0E5QzYBhZLf9VjwMov3p37Vh8ToW1-NeQvAoVATZhEg%0A%0A https://www.humanesociety.org/resources/humanely-scare-away-canada-geese https://www.canadageese.org/nlcontrol.html https://www.peta.org/wp-content/uploads/2021/06/humane-goose-control-pdf.pdf https://www.humanesociety.org/resources/what-do-about-canada-geese This company makes non lethal products. https://margosupplies.com/ca-en/ Nicole Corrado  

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Attachment THE WIINDIGO NORTHERN ROAD LINK

• Northern Road Link Project
• Author: Osgoode Hall Law School
• Reference number: 130
• Submitted: 2023-12-19 - 3:55 PM
• Project phase: Impact Statement
• *PDF of comment with proper formatting uploaded together with this intext comment.    Re: Northern Road Link Project Environmental Law with Professor Scott 25 November 2023 Cece Boissoneau, RN, JD Candidate   THE WIINDIGO NORTHERN LINK   The proposed road, “The Northern Link”, is an all-season road that will connect a remote mining region to the provincial highway system. This road and the industrial work camp, or “man camp”, that will be built once the mine is in operation, presents major risks to Indigenous women and girls whose Nations have homelands in the region. In this comment, I will outline those risks by examining the concept of the “Wiindigo” in Anishinaabe law. In conclusion, the proposed road is infrastructure that has a consuming energy not only on the land but the women and girls who inhabit it. The Northern Link will bring with it man camps that present as Wiindigo spirit energy consuming the health and well-being of the Annishnaabe women and girls who live there. Opening Summary: Extractive industries often introduce young, male and temporary workers who come from outside the region, outside the community.1 This context manifests as “man camps” being set up. These camps pose human security threats to vulnerable women in the region.2 The United Nations has identified these outside workers lead to an increase in sexual violence.3 Crime rates against women escalate.4 Woman in such regions have voiced that they feel less secure and vulnerable to violence and intimidation.5 Evidence shows an increase in sexual exploitation ...
• Attachment included
• Re: Northern Road Link Project Environmental Law with Professor Scott 25 November 2023 Cece Boissoneau, RN, JD Candidate THE WIINDIGO NORTHERN ROAD LINK The proposed road, “The Northern Link”, is an all-season road that will connect a remote mining region to the provincial highway system. This road and the industrial work camp, or “man camp”, that will be built once the mine is in operation, presents major risks to Indigenous women and girls whose Nations have homelands in the region. In this comment, I will outline those risks by examining the concept of the “Wiindigo” in Anishinaabe law. In conclusion, the proposed road is infrastructure that has a consuming energy not only on the land but the women and girls who inhabit it. The Northern Link will bring with it man camps that present as Wiindigo spirit energy consuming the health and well-being of the Annishnaabe women and girls who live there. Opening Summary: Extractive industries often introduce young, male and temporary workers who come from outside the region, outside the community.1 This context manifests as “man camps” being set up. These camps pose human security threats to vulnerable women in the region.2 The United Nations has identified these outside workers lead to an increase in sexual violence.3 Crime rates against women escalate.4 Woman in such regions have voiced that they feel less secure and 1 Digging for Rights: How Can International Human Rights Law Better Protect Indigenous Women from Extractive Industries? Sarah Morales. Canadian Journal of Women and the Law, Volume 31, Number 1, 2019, pp. 58-89 (Article) Published by University of Toronto Press 2 Digging for Rights 3 Digging for Rights 4 ...

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Attachment Submission from MFFN

• Northern Road Link Project
• Author: Administrator on behalf of Marten Falls First Nation
• Reference number: 109
• Submitted: 2023-08-10 - 11:49 AM
• Project phase: Planning
• Participation notice: Public Notice - Comments Invited on the Draft Tailored Impact Statement Guidelines and Public Participation Plan
• Please see the attached submission
• Attachment included
• Enclosure 1: Summary of Information on Potential for Impacts on Marten Falls First Nation from the Northern Road Link Project As of May 23, 2023 Page 1 of 6 This draft document was prepared by the Impact Assessment Agency of Canada (the Agency) to set out the Agency’s preliminary understanding of the potential for impacts on Marten Falls First Nation, due to the Northern Road Link Project (the Project). The Agency is seeking to learn about direct impacts the Project could have on the exercise of Marten Falls First Nation’s Aboriginal and Treaty rights. There are prompting questions in this document, which the Agency hopes could guide your input to the Agency. The Tailored Impact Statement Guidelines for the Project will identify the valued components that the Proponent will be required to study during the preparation of its Impact Statement. As additional information about impacts of the Project that are specific to Marten Falls First Nation are shared with the Agency throughout the impact assessment process, this document will be updated, and will inform the Proponent’s studies and the impact assessment. The Proposed Project Marten Falls First Nation and Webequie First Nation (the Proponent) is proposing the construction and operation, including maintenance, of an all-season multi-use public highway approximately 117 km to 164 km in length. The highway would connect the proposed Webequie Supply Road to the proposed Marten Falls Community Access Road. The highway would become part of a future all-season road network connecting mineral development activities in the Ring of Fire area to the provincial highway network system at or near Nakina, Ontario. Summary of ...

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Attachment From Fort Albany First Nation to the Impact Assessment Agency of Canada re: Comments on the Northern Road Link Project Draft Tailored Impact Statement Guidelines and Draft Indigenous Engagement and Partnership Plan

• Northern Road Link Project
• Author: Administrator on behalf of Fort Albany First Nation
• Reference number: 119
• Submitted: 2023-08-04 - 3:06 PM
• Project phase: Planning
• Participation notice: Public Notice - Comments Invited on the Draft Tailored Impact Statement Guidelines and Public Participation Plan
• Please see the attached submission. 
• Attachment included
• 1 Fort Albany First Nation Preliminary Comments on the Draft Tailored Impact Statement Guidelines for the Northern Road Link Project (June 21, 2023) August 4, 2023 ID Reference Topic Comment Assessment Methodology FAFN 001 7.1 p. 33 Baseline methodology Baseline data taken from the MFCAR and WSR assessments may be skewed from the actual baselines due to the impacts of COVID on studies. For example, did travel and social distancing restrictions impact the conduct of studies? Did environmental factors such as reduced flight traffic impact the results of studies? Did the significant negative impact on Indigenous engagement with the assessments affect the studies? Such factors must be considered and accounted for before data from these studies is used. FAFN 002 7.2 p. 38 Sources of baseline information Any data sharing between projects must comply with conditions on information-sharing and use set by First Nations, and with any relevant conditions of OCAP. Data from or about Indigenous people should not be shared between projects without the free, prior, and informed consent of the Indigenous group regarding the specific data and the specific purpose(s) for which it is shared. FAFN 003 7.6 p. 46 Mitigation and enhancement measures When proponents are permitted to use less-effective mitigation measures for economic reasons, they bear the gains while the costs are offloaded onto the environment. Proponents should be required to identify technically feasible mitigation measures that were deemed not to be “economically feasible”, and explain the likely costs and why they were not considered economically feasible. FAFN 004 7.6 p. 48 Mitigation and enhancement ...
• Attachment included
• 1 FORT ALBANY FIRST NATION Preliminary Comments on the draft Indigenous Engagement and Participation Plan for the Northern Road Link Project (June 21, 2023) August 4, 2023 ID Reference Topic Comment FAFN 001 5 and 6 General The IEPP does not identify methods to ensure that consultation is accessible to all members of Indigenous communities, including members living off reserve. It is essential that the ‘grassroots’ members are involved at an early stage in the impact assessment process. Please revise the IEPP to identify mechanisms to ensure that consultation is accessible to all members of Indigenous communities, including those living off reserve. FAFN 002 6 Table 1 p. 9 Phase 3 – Impact Assessment The IEPP identifies consensus-seeking as a key objective. However, this objective is not reflected in the engagement and consultation approach. The Agency must work with FAFN to ensure that FAFN’s issues and concerns are substantively addressed in each phase of the impact assessment process, including with respect to FAFN’s views on key documents. The Agency and FAFN must determine whether consensus has been achieved at these key points. Please revise Table 1 of the IEPP to identify how consensus-seeking will be incorporated into each phase of the impact assessment. FAFN 003 6 Table 1 p. 9 Phase 3 – Impact Assessment Under Phase 2 in Table 1, the IEPP states that Indigenous communities will submit “opinions or comments to the Agency on the proponent’s Impact Statement” and that the Agency will issue “requests to the proponent for information or studies.” There is no assurance that FAFN’s comments will be appropriately conveyed to the proponent by the Agency, ...

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Attachment From Webequie First Nation to the Impact Assessment Agency of Canada re: Comments on the Northern Road Link Project

• Northern Road Link Project
• Author: Administrator on behalf of Webequie First Nation
• Reference number: 110
• Submitted: 2023-07-28 - 6:44 PM
• Project phase: Planning
• Participation notice: Public Notice - Comments Invited on the Draft Tailored Impact Statement Guidelines and Public Participation Plan
• Please see the attached submission
• Attachment included
• Enclosure 4b: Summary of Information on Potential for Impacts on Webequie First Nation from the Northern Road Link Project As of May 23, 2023 Page 1 of 6 This draft document was prepared by the Impact Assessment Agency of Canada (the Agency) to set out the Agency’s preliminary understanding of the potential for impacts on Webequie First Nation, due to the Northern Road Link Project (the Project). The Agency is seeking to learn about direct impacts the Project could have on the exercise of Webequie First Nation’s Aboriginal and Treaty rights. There are prompting questions in this document, which the Agency hopes could guide your input to the Agency. The Tailored Impact Statement Guidelines for the Project will identify the valued components that the Proponent will be required to study during the preparation of its Impact Statement. As additional information about impacts of the Project that are specific to Webequie First Nation are shared with the Agency throughout the impact assessment process, this document will be updated, and will inform the Proponent’s studies and the impact assessment. The Proposed Project Marten Falls First Nation and Webequie First Nation (the Proponent) is proposing the construction and operation, including maintenance, of an all-season multi-use public highway approximately 117 km to 164 km in length. The highway would connect the proposed Webequie Supply Road to the proposed Marten Falls Community Access Road. The highway would become part of a future all-season road network connecting mineral development activities in the Ring of Fire area to the provincial highway network system at or near Nakina, Ontario. Summary of Information ...

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Attachment From Weenusk First Nation to the Impact Assessment Agency of Canada re: Comments on the Northern Road Link Project Draft Tailored Impact Statement Guidelines and Draft Indigenous Engagement and Partnership Plan (Second Submission)

• Northern Road Link Project
• Author: Administrator on behalf of Weenusk First Nation
• Reference number: 120
• Submitted: 2023-07-28 - 2:45 PM
• Project phase: Planning
• Participation notice: Public Notice - Comments Invited on the Draft Tailored Impact Statement Guidelines and Public Participation Plan
• Please see attached submission
• Attachment included
• Weenusk First Nation Comments for Northern Road Link Tailored Impact Statement Guidelines (Draft Version) # Section Details Comment 1. 2.2 Qualifications of individuals preparing the Impact Statement Page 9 “The Agency also expects proponents to demonstrate scientific integrity in their preparation and delivery of the Impact Statement by...” The TISG should be revised to ensure ‘scientific integrity’ refers to both western science and western scientific methods, as well as Indigenous knowledge, Indigenous science, and Indigenous scientific methods. Suggested rewording: “The Agency also expects proponents to demonstrate scientific integrity (both western and Indigenous) in their preparation and delivery of Impact Statements by…” 2. 3.5 Project activities Page 14 “This will also include an appendix of all the proposed mitigation and follow-up program measures to address adverse effects and potential impacts on the rights of Indigenous peoples.” Mitigation and follow-up programs must be developed in partnership with Weenusk First Nation. This can ensure mitigation and follow-up programs do not result in unintended additional impacts to Indigenous rights and interests. If programs or remediation, etc. are required, Weenusk First Nation should be included in these processes and given the opportunity to support. Suggested rewording: This will also include an appendix of all the collaboratively developed proposed mitigation and follow-up program measures to address adverse effects and potential impacts on the rights of Indigenous peoples. # Section Details Comment 3. 3.5.1 Site preparation and construction Pages 14-15 “Anticipated activities ...

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Attachment From Weenusk First Nation to the Impact Assessment Agency of Canada re: Comments on the Northern Road Link Project Draft Tailored Impact Statement Guidelines and Draft Indigenous Engagement and Partnership Plan (First Submission)

• Northern Road Link Project
• Author: Administrator on behalf of Weenusk First Nation
• Reference number: 115
• Submitted: 2023-07-27 - 3:13 PM
• Project phase: Planning
• Participation notice: Public Notice - Comments Invited on the Draft Tailored Impact Statement Guidelines and Public Participation Plan
• Please see the attached submission 
• Attachment included
• <Original signed by>

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Attachment From Nibinamik First Nation to the Impact Assessment Agency of Canada re: Comments on the Northern Road Link Project Draft Tailored Impact Statement Guidelines

• Northern Road Link Project
• Author: Administrator on behalf of Nibinamik First Nation
• Reference number: 112
• Submitted: 2023-07-24 - 4:59 PM
• Project phase: Planning
• Participation notice: Public Notice - Comments Invited on the Draft Tailored Impact Statement Guidelines and Public Participation Plan
• Please see the attached submission
• Attachment included
• July 24, 2023 VIA EMAIL Caitlin Cafaro Crown Consultation Coordinator Impact Assessment Agency of Canada 600-55 York Street, Toronto, ON M5J 1R7 NorthernRoad-RouteDuNord@iaac-aeic.gc.ca Maryse Sciberas, Project Analyst, Impact Assessment Agency of Canada 600-55 York Street, Toronto, ON M5J 1R7 Attn: Caitlin Cafaro & Maryse Sciberas Re: Preliminary Comments from Nibinamik First Nation on the Draft Tailored Impact Statement Guidelines and Plans the Northern Road Link Project We are legal counsel for Nibinamik First Nation (“Nibinamik”) in relation to the Northern Road Link project (the “NRL” or the “Project”). We are writing to provide a preliminary response to the Impact Assessment Agency of Canada’s (“Canada’s”) request for Nibinamik’s comments on the draft Tailored Impact Statement Guidelines and related draft plans posted on Canada’s website (collectively, the “Draft Guidelines”).1 We want to first emphasize that these comments are preliminary in nature. They do not reflect or encompass Nibinamik’s final or full views on the Draft Guidelines or the Project itself. In particular, Nibinamik continues to face challenges related to addressing COVID-19, as well as other community social and infrastructure pressures that have meant they have not yet been able to meet with land-users, Elders, or other traditional knowledge holders about the Draft Guidelines. We trust that Canada will understand this and that no final decisions regarding the Draft Guidelines will be made until meaningful consultation can occur. With that said, Nibinamik understands that Canada has requested comments within 30 days,2 and is therefore sharing the following preliminary comments for ...

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Attachment From Kashechewan First Nation to the Impact Assessment Agency of Canada re: Comments on the Northern Road Link Project Draft Tailored Impact Statement Guidelines and Draft Indigenous Engagement and Partnership Plan

• Northern Road Link Project
• Author: Administrator on behalf of Kashechewan First Nation
• Reference number: 121
• Submitted: 2023-07-24 - 1:06 PM
• Project phase: Planning
• Participation notice: Public Notice - Comments Invited on the Draft Tailored Impact Statement Guidelines and Public Participation Plan
• Please see the attached submission. 
• Attachment included
• Delivered by Email Impact Assessment Agency of Canada Email: NorthernRoad-RouteDuNord@iaac-aeic.gc.ca July 24, 2023 To Whom it May Concern, RE: Review and Comment on the Draft Tailored Impact Statement Guidelines and Draft Indigenous Engagement Partnership Plan I am writing as the elected Chief of Kashechewan First Nation (“KFN”). This letter is sent on behalf of myself, the Council, and Nation members of KFN. As Chief of my Nation, it is my duty to protect our Section 35 rights which can be exercised throughout Treaty 9, of which we are signatories. Further, as you are aware, the Northern Road Link Project is located within the James Bay Lowlands which is an extensive peatland complex that is one of the world’s most important carbon sinks. Due to this, our involvement in this impact assessment process is critical to ensure the ongoing protection and maintenance of this critical area. To this end we have review the Tailored Impact Statement Guidelines (“TISG”) and the Indigenous Engagement and Partnership Plan (“IEPP”) which are meant to provide the proponent(s) with direction and requirements for the preparation of an Impact Statement and outline the opportunities and methods of Crown engagement and consultation with Kashechewan First Nation. Our review is compiled in table form for the TISG to ensure specific comments are related to specific sections. Comments on the IEPP are contained within this cover letter, below. Comments on the IEPP The IEPP does not contain any reference to a co-led process for the Northern Road Link impact assessment. Kashechewan First Nation is heavily involved in the Regional Assessment for the Ring of Fire Area and is a strong proponent of ...

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Attachment Transport Canada Completed_Enclosure_1_-_draft_TISG_and_Permitting_Plan_-_Northern_Road_Link_Project_(002)

• Northern Road Link Project
• Author: Transport Canada
• Reference number: 102
• Submitted: 2023-07-24 - 12:59 PM
• Project phase: Planning
• Transport Canada has comments regarding the draft TISG - please see the attached/submitted document.  
• Attachment included
• CIAR #: 84331 Northern Road Link Project Page 1 of 3 Comment Form – Draft Permitting Plan and Draft Tailored Impact Statement Guidelines – Federal Review Team Northern Road Link Project Response required by: July 21, 2023 All comments should be submitted via the Submit a Comment feature available on the Project’s Canadian Impact Assessment Registry page (https://iaac-aeic.gc.ca/050/evaluations/proj/84331). Documents can be uploaded using this feature. If you have any difficulties submitting this way, please contact the Registry directly at registry-registre@iaac-aeic.gc.ca. All comments submitted using this form will be posted on the Registry website for the Project. Please note that this is your opportunity to customize the Tailored Impact Statement Guidelines. The Agency is required to issue the final Guidelines and plans no later than day 180 of the planning phase (August 20, 2023). Department/Agency: Transport Canada IA Contact: Linda Beaulieu Telephone: 416-557-5671 Email: Linda.Beaulieu@tc.gc.ca Section 1 – Draft Permitting Plan: 1. Confirm that all applicable legislative and regulatory oversight that may apply to the Project, under the authority of your department or agency, is accurately listed in the draft Permitting Plan. Insert response here: In addition to the references to the CNWA in the Permitting Plan, Transport Canada also has a regulatory role related to the Transportation of Dangerous Goods Act and the Canadian Aviation Regulations. There is a typo in the header of section 4.2.1.2, it should read: “Major Works in any navigable water” 2. Indicate whether your department or agency has identified any power that it will be unable to ...

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Attachment From Wildlife Conservation Society Canada to the Impact Assessment Agency of Canada re: Comments on the Northern Road Link Project Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan

• Northern Road Link Project
• Author: Administrator on behalf of WCS Canada
• Reference number: 114
• Submitted: 2023-07-21 - 9:37 PM
• Project phase: Planning
• Participation notice: Public Notice - Comments Invited on the Draft Tailored Impact Statement Guidelines and Public Participation Plan
• Please see the attached submission
• Attachment included
• WCS CANADA PHONE: (CAN) 416 850 9038 344 BLOOR STREET WEST, SUITE 204 FAX: 416 850 9040 TORONTO, ONTARIO, M5S 3A7, CANADA WWW.WCSCANADA.ORG July 21, 2023 Impact Assessment Agency of Canada Transmitted by email: NorthernRoad-RouteDuNord@iaac-aeic.gc.ca Re: WCS Canada comments on Draft Planning Phase Documents for the Federal Impact Assessment of the Northern Road Link Project To whom it may concern: We are providing comments on the draft Tailored Impact Statement Guidelines (TISG)1 and draft Public Participation Plan2 developed by the Impact Assessment Agency of Canada (IAAC) to support the federal impact assessment process for the Northern Road Link (NRL) project3. First and foremost, we are compelled to emphasize that the 30-day period for the draft TISG is insufficient for a review of this lengthy document. We, like any other member of the public who might wish to comment on this document, did not know when to expect its issuance; moreover, this review period falls during the summer months when many people have reduced working hours and reduced access to support services such as childcare to be able to meaningfully engage with the process. The ”tailored” aspect of the Impact Assessment Guidelines means that the direction provided by IAAC to the proponent “is based on the nature, complexity and context of the ...

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Attachment ISC Comments on Northern Road Link draft TISG and Permitting Plan

• Northern Road Link Project
• Author: Indigenous Services Canada
• Reference number: 101
• Submitted: 2023-07-21 - 5:20 PM
• Project phase: Planning
• See attachment for comments from Indigenous Services Canada.
• Attachment included
• CIAR #: 84331 Northern Road Link Project Page 1 of 5 GCDOCS # 115707637 GCDOCS # 115981190 Comment Form – Draft Permitting Plan and Draft Tailored Impact Statement Guidelines – Federal Review Team Northern Road Link Project Response required by: July 21, 2023 All comments should be submitted via the Submit a Comment feature available on the Project’s Canadian Impact Assessment Registry page (https://iaac-aeic.gc.ca/050/evaluations/proj/84331). Documents can be uploaded using this feature. If you have any difficulties submitting this way, please contact the Registry directly at registry-registre@iaac-aeic.gc.ca. All comments submitted using this form will be posted on the Registry website for the Project. Please note that this is your opportunity to customize the Tailored Impact Statement Guidelines. The Agency is required to issue the final Guidelines and plans no later than day 180 of the planning phase (August 20, 2023). Department/Agency: Indigenous Services Canada IA Contact: Julia Gregory (ISC-LED HQ) Telephone: 438-465-8693 Email: Julia.gregory@sac-isc.gc.ca Section 1 – Draft Permitting Plan: 1. Confirm that all applicable legislative and regulatory oversight that may apply to the Project, under the authority of your department or agency, is accurately listed in the draft Permitting Plan. Insert response here: The Northern Road Link Project is expected to be entirely on provincial Crown Land, therefore, Indigenous Services Canada does not have authority for permitting. Should the proponent require gravel from Indian Reserve lands during construction and operation, permitting under the Indian Act will be required, and the proponent should consult ...

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Attachment WAGE input draft TISG

• Northern Road Link Project
• Author: Women and Gender Equality Canada
• Reference number: 100
• Submitted: 2023-07-21 - 4:11 PM
• Project phase: Planning
• Women and Gender Equality Canada comments on Northern Road Link Project Draft TISG (pdf).
• Attachment included
• CIAR #: 84331 Northern Road Link Project Page 1 of 5 Comment Form – Draft Permitting Plan and Draft Tailored Impact Statement Guidelines – Federal Review Team Northern Road Link Project Response required by: July 21, 2023 All comments should be submitted via the Submit a Comment feature available on the Project’s Canadian Impact Assessment Registry page (https://iaac-aeic.gc.ca/050/evaluations/proj/84331). Documents can be uploaded using this feature. If you have any difficulties submitting this way, please contact the Registry directly at registry-registre@iaac-aeic.gc.ca. All comments submitted using this form will be posted on the Registry website for the Project. Please note that this is your opportunity to customize the Tailored Impact Statement Guidelines. The Agency is required to issue the final Guidelines and plans no later than day 180 of the planning phase (August 20, 2023). Department/Agency: Women and Gender Equality Canada (WAGE) IA Contact: Denise Gareau, Director, GBA Plus Directorate, Research, Data, and Intersectionality (RDI) Branch Telephone: 819-938-1132 Email: FEGC.EvaluationImpacts- ImpactAssessment.WAGE@fegc- wage.gc.ca Section 1 – Draft Permitting Plan: 1. Confirm that all applicable legislative and regulatory oversight that may apply to the Project, under the authority of your department or agency, is accurately listed in the draft Permitting Plan. Insert response here: WAGE does not hold any regulatory power, functions, or duties. Based on the project’s potential effects relating to women and the advancement of gender equality, the following are potential effects within federal jurisdiction on which WAGE focus: ▪ ...

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Attachment Proponent Comments on Draft TISGs and IEPP

• Northern Road Link Project
• Author: SNC-Lavalin Inc.
• Reference number: 99
• Submitted: 2023-07-21 - 4:03 PM
• Project phase: Planning
• Good afternoon, On behalf of the NRL Project Team, please find attached the proponent's comments on the: Draft TISG Draft IEPP The proponent would like to meet with the Agency to discuss our comments and how they may be incorporated into the final planning documents. Best regards, Lyndsey MacBride
• Attachment included
• 1 Table 1: Northern Road Link Draft Indigenous Engagement and Partnership Plan (IEPP) – Proponent Questions, Comments and Clarification Requests Item # Draft IEPP Section Requirement Question/Comment/Clarification Request 1 Section 1: Introduction To complement this IEPP, interested Indigenous communities may develop community-specific consultation plans, in collaboration with the Agency, to describe the community’s specific objectives for consultation, or any unique features of the impact assessment and consultation process pertaining to that community for the Project” Please provide clarification on the role of the proponent, if any, and how the proponent will be informed of any such community-specific consultation plans. 2 Section 2: Description of the Proposed Project The Project would become part of a future all-season road network connecting mineral development activities in the Ring of Fire area to the provincial highway system at Nakina, Ontario. This description of the Project is not consistent with the description in the Detailed Project Description (2023-05- 01). Please clarify what is meant by ‘future all-season network’. Please also ensure that the description of the Project is consistent. 3 Section 3: Objectives of Indigenous Engagement and Partnership Ensure engagement is consistent with the Government of Canada’s commitment to implement the United Nations Declaration of Rights of Indigenous Peoples (the Declaration) as a comprehensive international human rights instrument and Canada’s roadmap for reconciliation. The Declaration also emphasizes the need to work together in partnership and respect, as articulated through the principle of free, ...
• Attachment included
• 1 Table 1: Northern Road Link Draft Tailored Impact Statement Guidelines – Proponent Questions, Comments and Clarification Requests Item # Draft TISGs Section Requirement Question/Comment/Clarification Request 1 General - There are many requirements in the Draft NRL TISGs which are not included in the Marten Falls Community Access Road (MFCAR) and Webequie Supply Road (WSR) Tailored Impact Statement Guidelines (TISGs), which are both proposed all-season roads also undergoing federal impact assessments (IAs) in the region. Please provide clarification on the additional requirements for NRL compared to other road projects with similar design, locations in the same region, and assessments under the same legislation. 2 General - In the draft Northern Road Link (NRL, ‘the Project’) Tailored Impact Statement Guidelines (TISGs) there are multiple mentions of the proponent collaborating with Indigenous communities, Indigenous communities reviewing portions of the Impact Statement (IS), and Indigenous communities undertaking their own studies on potential effects to their rights which need to be incorporated into the IS to be completed by the Proponent. However, the timeline for the IS, as per guidance the Impact Assessment Agency of Canada1 (the Agency) is still anticipated to be three years. While the proponent supports fulsome and meaningful engagement, we are concerned that the level of collaboration with Indigenous communities and the incorporation Indigenous studies required by TISGs will dilate the timeline of the IS phase beyond the anticipated three years. We are also concerned that this could require significant funding and it is not clear whether the current federal funding ...

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Attachment From Ministry of Natural Resources and Forestry to the Impact Assessment Agency of Canada re: Comments on the Northern Road Link Project Draft Tailored Impact Statement Guidelines

• Northern Road Link Project
• Author: Administrator on behalf of Ministry of Natural Resources and Forestry
• Reference number: 123
• Submitted: 2023-07-21 - 3:36 PM
• Project phase: Planning
• Participation notice: Public Notice - Comments Invited on the Draft Tailored Impact Statement Guidelines and Public Participation Plan
• Hi Ely, Although MNRF did not do a formal review of the TISG for the Northern Road Link project, I did do a scoped look through the document and identified a few thoughts for IAAC’s consideration.   I honestly couldn’t find a way to submit comments without using my personal GC Key login, so I’m sending them directly to you instead. These comments are all related to the cumulative effects section (7.7).  It appears that the cumulative effects assessment (CEA) section speaks to the inclusion of various existing or future projects as part of the CEA.  I might recommend adding the following to the list on page 50-51: Rapid Lynx Fiber Optic project. Potential waterpower or other electricity generation projects that may feed power into future “power transmission projects” to service remote MATAWA communities and/or mining developments. In addition, although not explicitly identified as a future project, it could be expected that the NRL may require secondary services (gas stations, garages, electric charging stations and rest stops) located along the northern road link corridor or WSR/MF-CAR corridors.  Where these secondary service features are not considered as part of the IA/EA, and where they can be reasonably anticipated, please consider including them as part of the cumulative effects assessment. If you have any questions, please let me know. Nancy Berglund (she/her)

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Attachment From Métis Nation of Ontario to the Impact Assessment Agency of Canada re: Comments on the Northern Road Link Project Draft Tailored Impact Statement Guidelines and Draft Indigenous Engagement and Partnership Plan

• Northern Road Link Project
• Author: Administrator on behalf of Métis Nation of Ontario
• Reference number: 117
• Submitted: 2023-07-21 - 3:35 PM
• Project phase: Planning
• Participation notice: Public Notice - Comments Invited on the Draft Tailored Impact Statement Guidelines and Public Participation Plan
• Thank you for providing the opportunity for the Métis Nation of Ontario to review and comment on the Draft Tailored Impact Assessment Guidelines and the Draft Indigenous Engagement and Participation Plan for the Northern Road Link Project. As you are aware, and as outlined further in the attached edits to ‘Enclosure 3’, the Métis Nation of Ontario Region 2 is not asserting Aboriginal rights within the Northern Road Link Project area at this time. Therefore, the MNO Region 2 is not fully engaging in consultation on this Project at this time. The MNO also does not have project-specific traditional knowledge and land use data for the study area, which would be needed to adequately assess potential impacts of the Project on the exercise of section 35 rights.   As such, we do not have specific comments with regards to the documents, beyond requesting continued follow-up for the next stages in the assessment. We hope that opportunities to provide feedback will continue throughout the Impact Assessment process. In particular, ongoing MNO concerns for the Project regard potential indirect impacts to traditional land use, harvesting, social and cultural practices, community well-being, cumulative effects, and climate change. Additionally, the MNO wishes to be engaged on the archaeological assessment for the Project. Continuance on these issues as well as general project updates throughout the next stages of the project assessment is of interest to the MNO.   We also note that within the IEPP, the Métis Nation of Ontario is referenced as the Indigenous community to be consulted with. In actuality, it is ...
• Attachment included
• Enclosure 1: Summary of Information on Potential for Impacts on the Métis Nation of Ontario from the Northern Road Link Project As of May 23, 2023 Page 1 of 8 This draft document was prepared by the Impact Assessment Agency of Canada (the Agency) to set out the Agency’s preliminary understanding of the potential for impacts on the Métis Nation of Ontario, due to the Northern Road Link Project (the Project). The Agency is seeking to learn about direct impacts the Project could have on the exercise of the Métis Nation of Ontario’s Aboriginal rights. There are prompting questions in this document, which the Agency hopes could guide your input to the Agency. The Tailored Impact Statement Guidelines for the Project will identify the valued components that the Proponent will be required to study during the preparation of its Impact Statement. As additional information about impacts of the Project that are specific to the Métis Nation of Ontario are shared with the Agency throughout the impact assessment process, this document will be updated, and will inform the Proponent’s studies and the impact assessment. The Proposed Project Marten Falls First Nation and Webequie First Nation (the Proponent) is proposing the construction and operation, including maintenance, of an all-season multi-use public highway approximately 117 km to 164 km in length. The highway would connect the proposed Webequie Supply Road to the proposed Marten Falls Community Access Road. The highway would become part of a future all-season road network connecting mineral development activities in the Ring of Fire area to the provincial highway network system at or near Nakina, Ontario. Summary of ...
• Attachment included
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Attachment ECCC Comments on the draft TISG and Permitting Plan

• Northern Road Link Project
• Author: Environment and Climate Change Canada
• Reference number: 98
• Submitted: 2023-07-21 - 3:25 PM
• Project phase: Planning
• Enclosure 1 - ECCC Comments on the draft TISG and Permitting Plan
• Attachment included
• CIAR #: 84331 ECCC Comments on the Draft TISG and Draft Permitting Plan – Northern Road Link Project Page 1 of 73 Comment Form – Draft Permitting Plan and Draft Tailored Impact Statement Guidelines – Federal Review Team Northern Road Link Project All comments should be submitted via the Submit a Comment feature available on the Project’s Canadian Impact Assessment Registry page (https://iaac- aeic.gc.ca/050/evaluations/proj/84331). Documents can be uploaded using this feature. If you have any difficulties submitting this way, please contact the Registry directly at registry-registre@iaac-aeic.gc.ca. All comments submitted using this form will be posted on the Registry website for the Project. Please note that this is your opportunity to customize the Tailored Impact Statement Guidelines. The Agency is required to issue the final Guidelines and plans no later than day 180 of the planning phase (August 20, 2023). Department/Agency: Environment and Climate Change Canada (ECCC) IA Contact: Venita Harry Telephone: 416-739-5863 Email: venita.harry@ec.gc.ca Section 1 – Draft Permitting Plan: 1. Confirm that all applicable legislative and regulatory oversight that may apply to the Project, under the authority of your department or agency, is accurately listed in the draft Permitting Plan. See Table 1 – ECCC Comments on Draft Permitting Plan – Northern Road Link Project on page 2. 2. Indicate whether your department or agency has identified any power that it will be unable to exercise to allow the Project to proceed, in whole or in part. For more information, please refer to subsection 17(1) of the IAA. ECCC has not identified any power that it will be unable to exercise at ...

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Attachment Comments on Draft Public Participation Plan

• Northern Road Link Project
• Author: University of Toronto Scarborough
• Reference number: 97
• Submitted: 2023-07-21 - 12:59 PM
• Project phase: Planning
• Please find attached letter.
• Attachment included
• Yukari Hori, Ph.D. Research Associate Climate Laboratory (CL@UT) Department of Physical and Environmental Sciences (DPES) University of Toronto Scarborough Campus (UTSC) 1265 Military Trail Toronto, ON M1C 1A4 July 21, 2023 Northern Road Link Project Impact Assessment Agency of Canada 500-55 York Street Toronto, ON M5J 1R7 To whom it may concern: Re: Comments on the Draft Public Participation Plan of the Northern Road Link I am writing this letter on behalf of the Climate Laboratory (CL@UT) at the Department of Physical and Environmental Sciences (DPES), University of Toronto Scarborough Campus (UTSC). The University of Toronto Climate Lab (CL@UT) https://www.utsc.utoronto.ca/people/gough/ is the research laboratory of Professor William A. Gough at UTSC. The CL@UT conducts research on climate change impacts, vulnerability, and adaptation such as climate change in the eastern Arctic, northern Canada and Canadian cities, climate change impact assessment, numerical ocean and climate modeling, air quality in southwestern Ontario, hurricanes and climate change, day to day temperature variability, climate change policy, and other topics in climatology, meteorology, and physical geography. We have reviewed the Northern Road Link Draft Public Participation Plan for consideration and participation of our interests during the impact assessment process and hope to work collaboratively with your agency. In Appendix 1 Public Participation Plan Distribution List, we acknowledge that there are only two academic institutions listed as educational institutions. Since we recognize the significance of the Northern Road Link Project ...

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Attachment Natural Resources Canada's comments on the draft TISG and draft permitting plan

• Northern Road Link Project
• Author: Natural Resources Canada (NRCan)
• Reference number: 96
• Submitted: 2023-07-21 - 12:10 PM
• Project phase: Planning
• On June 21, 2023, the Impact Assessment Agency of Canada (IAAC) requested that Natural Resources Canada (NRCan) provide specialist or expert information or knowledge to support development of the Tailored Impact Statement Guidelines (TISG) and the Permitting Plan for the Northern Road Link (the Project), as per paragraph 23(a) of the Impact Assessment Act. Based on areas of our expertise, NRCan has made a few minor comments on the draft TISG and the Permitting Plan, which can be found in the attachment.
• Attachment included
• CIAR #: 84331 Northern Road Link Project Page 1 of 5 UNCLASSIFIED - NON CLASSIFIÉ CIAR File No.: 84331 July 21, 2023 Anjala Puvananathan Director, Ontario Region Impact Assessment Agency of Canada Submitted electronically: https://iaac-aeic.gc.ca/050/evaluations/proj/84331 Subject: Natural Resources Canada’s Submission of Comments on the Draft Permitting Plan and Draft Tailored Impact Statement Guidelines for the Northern Road Link Project Dear Colleague, On June 21, 2023, the Impact Assessment Agency of Canada (IAAC) requested that Natural Resources Canada (NRCan) provide specialist or expert information or knowledge to support development of the Tailored Impact Statement Guidelines (TISG) and the Permitting Plan for the Northern Road Link (the Project), as per paragraph 23(a) of the Impact Assessment Act. Based on areas of our expertise, NRCan has made a few minor comments on the draft TISG and the Permitting Plan, which can be found in Attachment 1. Should you have any questions, comments, or concerns, please contact me by email at Christina.Clarke@nrcan-rncan.gc.ca or by phone at 343-543-7619. Sincerely, Christina Clarke Team Lead Impact Assessment Division Office of the Chief Scientist cc: Peter Unger, Impact Assessment Division, Office of the Chief Scientist Attachment 1: NRCan Comments on the Draft Permitting Plan and the Draft Tailored Impact Statement Guidelines for the Northern Road Link Project ...

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Attachment MCM Comments on Draft Tailored Impact Statement Guidelines and Co-operation Plan

• Northern Road Link Project
• Author: Ministry of Citizenship and Multiculturalism (Ontario)
• Reference number: 95
• Submitted: 2023-07-21 - 11:47 AM
• Project phase: Planning
• See comment form attached.
• Attachment included
• CIAR #: 84331 Northern Road Link Project Page 1 of 6 Comment Form - Draft Tailored Impact Statement Guidelines and Draft Cooperation Plan – Provincial Review Team Northern Road Link Project Deadline: July 21, 2023 All comments should be submitted via the Submit a Comment feature available on the Project’s Canadian Impact Assessment Registry website (https://iaac-aeic.gc.ca/050/evaluations/proj/84331). Documents can be uploaded using this feature. If you have any difficulties submitting this way, please contact the Registry directly at registry-registre@iaac-aeic.gc.ca. Please note that all comments submitted using this form may be posted on the Canadian Impact Assessment Registry website for the Project. Please note that this is your opportunity to provide input to the Tailored Impact Statement Guidelines. The Agency is required to issue the final Guidelines and plans no later than day 180 of the planning phase (August 20, 2023). Ministry: Ministry of Citizenship and Multiculturalism (MCM) IA Contact: Dan Minkin, Heritage Planner, Heritage Planning Unit Karla Barboza, Team Lead, Heritage Planning Unit Telephone: 416-786-7553 (Dan) 416-660-1027 (Karla) Email: dan.minkin@ontario.ca Karla.barboza@ontario.ca Section 1 – Draft Tailored Impact Statement Guidelines: 1. Please review the draft Tailored Impact Statement Guidelines (the Guidelines) sections that are applicable to your ministry’s mandate. 2. Using the table below, given the context of the Project, please provide any comments and include your recommendation for how the final Guidelines should be adapted to address any comments. • Please indicate any corrections, additions or ...

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Attachment From Aroland First Nation to the Impact Assessment Agency of Canada re: Comments on the Northern Road Link Project Draft Tailored Impact Statement Guidelines and Draft Indigenous Engagement and Partnership Plan

• Northern Road Link Project
• Author: Administrator on behalf of Aroland First Nation
• Reference number: 116
• Submitted: 2023-07-21 - 10:55 AM
• Project phase: Planning
• Participation notice: Public Notice - Comments Invited on the Draft Tailored Impact Statement Guidelines and Public Participation Plan
• Please see the attached submission. 
• Attachment included
• SENT BY EMAIL Caitlin Cafaro, Senior Consultation Analyst Crown Consultation Coordinator Northern Road Link Project Impact Assessment Agency of Canada 500-55 York Street Toronto, ON M5J 1R7 NorthernRoad-RouteDuNord@iaac-aeic.gc.ca July 21, 2023 RE: Northern Road Link Impact Assessment Tailored Impact Statement Guidelines and Indigenous Engagement and Partnership Plan On July 21, 2023, the Impact Assessment Agency of Canada (“IAAC”) sent a letter to Aroland First Nation (“AFN”) requesting comments on the draft Indigenous Engagement and Partnership Plan (“IEPP”) and the draft Tailored Impact Statement Guidelines (“TISG”) for the Northern Road Link Project’s (“the Project”) federal Impact Assessment. In this submission, we provide our comments on the draft IEPP (see Appendix 1), followed by our review of the draft TISG (see Appendix 2), along with the following general comments on the Project and Impact Assessment process which should also be addressed in IAAC’s response and amendments to these important procedural documents. We are concerned by Ontario’s colonial approach to decision-making in the Environmental Assessment process to date, agreeing only to recognize decision-making by the small number of First Nations who will gain all-season road access from the roads projects and who have expressed their support for the related mineral development the road developments would facilitate. To be clear, AFN is not expressing opposition to all-season roads: we recognize the need and right for First Nations to be connected to the provincial highway network. However, we are deeply concerned with the ongoing absence of approaches to shared decision-making that involve AFN and all ...
• Attachment included
• Enclosure 1: Summary of Information on Potential for Impacts on Aroland First Nation from the Northern Road Link Project As of May 23, 2023 Page 1 of 6 This draft document was prepared by the Impact Assessment Agency of Canada (the Agency) to set out the Agency’s preliminary understanding of the potential for impacts on Aroland First Nation, due to the Northern Road Link Project (the Project). The Agency is seeking to learn about direct impacts the Project could have on the exercise of Aroland First Nation’s Aboriginal and Treaty rights. There are prompting questions in this document, which the Agency hopes could guide your input to the Agency. The Tailored Impact Statement Guidelines for the Project will identify the valued components that the Proponent will be required to study during the preparation of its Impact Statement. As additional information about impacts of the Project that are specific to Aroland First Nation are shared with the Agency throughout the impact assessment process, this document will be updated, and will inform the Proponent’s studies and the impact assessment. The Proposed Project Marten Falls First Nation and Webequie First Nation (the Proponent) is proposing the construction and operation, including maintenance, of an all-season multi-use public highway approximately 117 km to 164 km in length. The highway would connect the proposed Webequie Supply Road to the proposed Marten Falls Community Access Road. The highway would become part of a future all-season road network connecting mineral development activities in the Ring of Fire area to the provincial highway network system at or near Nakina, Ontario. Summary of Information Available to ...

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Attachment From Friends of Attawapiskat River to the Impact Assessment Agency of Canada re: Comments on the Northern Road Link Project Draft Tailored Impact Statement Guidelines and Draft Indigenous Engagement and Partnership Plan

• Northern Road Link Project
• Author: Administrator on behalf of Friends of Attawapiskat River
• Reference number: 118
• Submitted: 2023-07-20 - 4:48 PM
• Project phase: Planning
• Participation notice: Public Notice - Comments Invited on the Draft Tailored Impact Statement Guidelines and Public Participation Plan
• Please see the attached submission
• Attachment included
• Northern Road Link Project Impact Assessment Agency of Canada 500-55 York Street Toronto, Ontario M5J 1R7 Via email NorthernRoad-RouteDuNord@iaac-aeic.gc.ca July 20, 2023 RE: FRIENDS OF THE ATTAWAPISKAT RIVER Comments on the draft Tailored Impact Statement Guidelines and draft Indigenous Engagement and Participation Plan for the Northern Road Link Project (Ref No. 84331) We are the ancestral people of the lands where the Ring of Fire is proposed. We the Oji-cree, Ojibway, and Omushkegowuk people have lived in harmony with these lands given to us by the Creator since time immemorial. We are the Water People. The water gives us life and we take care of the water in return. This is our duty to the Creator. We are the ancestors of the Headmen who signed Treaty 9 with the Crown to peacefully share the lands. Our Natural Laws teach us to respect the land and to maintain our relationship with the Creator. Our traditional ways do not involve greed or violence to these lands, but love, harmony and an ongoing commitment to each other. We have seen what these developments and broken promises can do to our people and our lands. We were promised traditional knowledge consultation and money from the DeBeers mine, both of which were not upheld. Our tribal councils have been corrupted by greed and our communities suffer because of it. Many of our communities have not had clean drinking water for years. Our housing crisis is only getting worse which has taken a toll on our young generation, often living with no hope and in quiet desperation. We ask the government to uphold these treaty promises to our people. Money to our tribal councils does not ...

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Attachment Comments on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan for the Northern Road Link Project

• Northern Road Link Project
• Author: Municipality of Greenstone
• Reference number: 94
• Submitted: 2023-07-20 - 2:15 PM
• Project phase: Planning
• Please find attached the Municipality of Greenstone's comments on the Draft Tailored Impact Statement Guidelines and Draft Public Participation Plan for the Northern Road Link Project. 
• Attachment included
• • • • • • mailto:NorthernRoad-RouteDuNord@iaac-aeic.gc.ca •

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Attachment From Attawapiskat First Nation to the Impact Assessment Agency of Canada re: Comments on the Northern Road Link Project Draft Tailored Impact Statement Guidelines and Draft Indigenous Engagement and Partnership Plan

• Northern Road Link Project
• Author: Administrator on behalf of Attawapiskat First Nation
• Reference number: 108
• Submitted: 2023-07-20 - 2:00 PM
• Project phase: Planning
• Participation notice: Public Notice - Comments Invited on the Draft Tailored Impact Statement Guidelines and Public Participation Plan
• Please see the attached submission
• Attachment included
• July 20, 2023 SENT BY EMAIL Caitlin Cafaro Crown Consultation Coordinator Impact Assessment Agency of Canada caitlin.cafaro@iaac-aeic.gc.ca Dear Ms. Cafaro, Re: Draft Tailored Impact Statement Guidelines and Draft Indigenous Engagement and Partnership Plan for the Northern Road Link Project As per the Impact Assessment Agency of Canada’s request, Attawapiskat First Nation is providing preliminary comments on the Northern Road Link - Draft Tailored Impact Statement Guidelines (TISG) and the Draft Indigenous Engagement and Partnership Plan. Please note that submission of these comments does not signal the consent of Attawapiskat First Nation for any developments within the area commonly known as the “Ring of Fire,” including developments related to transport and resource exploitation within that area. The following is a summary of our concerns. 1. Your regulatory process for approving the Northern Road Link project does not meet the Crown’s duty to consult Attawapiskat First Nation on the impact of the Northern Road Link to our inherent and Treaty rights. Attawapiskat is being presented with a project that will open our homeland to industrial development. We believe that if this road were to be built, it would transform our lands, waters, and way of life forever. Under your current regulatory process, we are presented with a series of technical documents, on which we are expected to provide comments by a certain deadline. Given the technical nature of the documents, the comments we provide are prepared by our advisors. This process is not sufficient to gain our consent to the project. We have not had the opportunity to sit down with the Crown, our Treaty partner, to discuss ...

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