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Great Bear Gold Project

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Attachment Stop the mine!

Great Bear Gold Project
Author: Nicole Corrado
Reference number: 100
Submitted: 2026-05-29 - 11:41 PM
Project phase: Impact Statement
Participation notice: Public notice - Comments invited on the summary of the Impact Statement
Please say NO to the Gold Project. Gold mining involves the use of cyanide, which is deadly to all life. Indigenous peoples live here. Their homes would be destroyed, and they would be subject to the toxicity of mining. The mine would also destroy the habitats of fish, birds, woodland caribou, pine martens, and plenty of other animals. During this climate emergency, we can not afford to destroy forests and wildlife habitat. Gold mining is harmful to all life, and to the planet. Forcing fish and birds to be exposed to the effluent, and cutting them up to test them for selenium and other pollutants is cruel and outdated. Canada is phasing out toxicity testing on animals. Please switch to animal free methods of testing effluent and other substances. For wild fish and birds, please stop lethal sampling and switch to humane non lethal bio monitoring like is done in humans. https://www.change.org/p/stop-testing-sewer-water-on-laboratory-fish Please do not build another gold mine. We are in the midst of a climate crisis. This proposal, which would damage and destroy the homes of black bears, caribou, birds, fish, and many animals, is terrible. And gold mines destroy all sorts of animals in laboratory testing of their effluents, and in lethal sampling of birds, fish, frogs, etc. We do not need more gold mines. Please preserve the trees at this location. Please do not build on an area that has a lot of trees, and do not build on a wetland either. Please do not harm animals with this project. Please do not use animal testing for pollution monitoring. It mentions that ...

Attachment Great Bear Gold Project – Asubpeeschoseewagong Netum Anishinabek Comments on Great Bear Gold Project Impact Statement (Reference Number 85832)

Great Bear Gold Project
Author: Asubpeeschoseewagong Netum Anishinabek
Reference number: 99
Submitted: 2026-05-29 - 4:16 PM
Project phase: Impact Statement
Participation notice: Public notice - Comments invited on the summary of the Impact Statement
Please see attached the preliminary submissions filed on behalf of Asubpeeschoseewagong Netum Anishinabek (Grassy Narrows First Nation) on the Great Bear Gold Project Impact Statement and five expert reports: - Appendix 'A' - Dr. Kevin Morin, “Great Bear Gold Project – Review of the Impact Statement (IS)”, dated May 27, 2026. - Appendix 'B' - Dr. Branfireun – Great Bear Project – Impact Statement dated May 29, 2026 - Appendix 'C' - Source Environmental Associates Inc. - Technical Memorandum: Review of the Great Bear Project Impact Statement – Preliminary Technical Review Comments, dated May 28, 2026 -Appendix 'D' - Source Environmental Associates Inc. ...
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Canadian Environmental Law Association T 416 960-2284 • 1-844-755-1420 • F 416 960-9392 • 55 University Avenue, Suite 1500 Toronto, Ontario M5J 2H7 • cela.ca May 29, 2026 VIA EMAIL AND REGISTRY Great Bear Gold Project Impact Assessment Agency of Canada 55 York Street, 6th Floor Toronto, Ontario M5J 1R7 Email: GreatBear@iaac-aeic.gc.ca Re: Great Bear Gold Project – Asubpeeschoseewagong Netum Anishinabek Comments on Great Bear Gold Project Impact Statement (Reference Number 85832) Please be advised that we are co-counsel for Asubpeeschoseewagong Netum Anishinabek (“ANA” or “Grassy Narrows First Nation”) in relation to the Great Bear Gold Project (Reference Number 85832). Our client’s preliminary comments and concerns about the Great Bear Gold Project Impact Statement are set out below. ANA will submit supplementary submissions at a later date and reserves the right to provide further comments as more information becomes available. ANA notes that this Impact Statement has been filed with the Impact Assessment Agency of Canada (“Agency”) and the impact assessment process has continued despite ANA’s repeated requests for a pause in the assessment to resolve long-standing and unresolved substantive, procedural, and consultation issues, including deficient assessment of baseline conditions, unreliable methods for predicting mercury impacts, and adverse effects on the health, well-being and constitutional rights of ANA. The Impact Statement is incomplete, inadequate, and unpersuasive. It does not adequately address the mandatory factors in s.22 of the Impact Assessment Act, SC 2019, c 28, s 1 (“IAA”), nor does it contain all of the ...
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TECHNICAL MEMORANDUM ____________________________________________________________________________ Date: May 28, 2026 To: Joseph B. Fobister, Lead Negotiator (Grassy Narrows Land Protection Team), David Sone (ANA Advisor), Jackie Esmonde (Legal Counsel) and Sydney Lang (Legal Counsel) of the ANA Advisory Team From: Fraser Riddolls (B.Sc., B.I.T.) and Emily MacMillan (MLWS, B.I.T, AAg) Subject: Additional Technical Review Comments on Fisheries, Aquatics, Migratory Birds, and HHERA - Great Bear Project Impact Statement Introduction Source Environmental Associates Inc. (Source) was retained by Asubpeeschoseewagong Netum Anishinabek (ANA) to review the Great Bear Project Impact Statement submitted in support of the proposed Great Bear Gold Project. This memorandum provides additional technical review comments from Source on fisheries and aquatic resources, fish habitat offsetting and compensation, migratory bird-related issues associated with proposed offsetting measures and selected human health and ecological risk assessment (HHERA) topics relevant to aquatic resources, traditional foods, and downstream receptors. The comments are intended to identify technical deficiencies, information gaps, uncertainties, and areas where additional assessment or clarification may be required before the potential effects of the Project can be adequately understood from ANA's review perspective. These comments supplement Source's broader technical review memorandum and focus on the following materials: • Section 8 – Analysis of Changes to Fish and Fish Habitat; • Section 9 – Analysis of Changes to Migratory Birds; • Section 15 – Cumulative Effects Assessment; • Appendix L-1 – Aquatic ...
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1 May 28, 2026 Brief opinion on the Great Bear Gold Project Impact Statement risk assessment (Appendix N) by WSP From April, 2026. I am a Principal at the firm I founded, NEK Associates LTD, and a Senior Research Scientist at the Harvard Center for Risk Analysis. I bring nearly 40 years experience to the design and implementation of human health and ecological risk assessments, focused on integrated, risk-based modeling approaches to support sustainable environmental decision making. I recently completed a series of reports and associated publications on behalf of the World Bank on exposure to methylmercury from artisanal scale gold mining. I have published peer reviewed papers on fish consumption and probabilistic risk modeling. I served on the Board of Scientific Counselors at the U.S. EPA for six years and was Chair for the last three. I am a member of the Scientific Advisors on Risk Assessment for the European Commission and serve as frequent peer reviewer under EU environmental grant programs. I served as Treasurer and President for the Society for Risk Analysis (SRA) where I am also a Fellow, and served as Treasurer and on the Board of Directors for the Society for Environmental Toxicology and Chemistry (SETAC). I received my A.B. cum laude from Harvard College, and my Sc.M. and Sc.D. from Harvard University in Environmental Science and Risk Management. Overall, this report relies on a flawed risk assessment and underlying modeling to conclude that project impacts on human and ecological health will be negligible. Comments and observations I made previously still stand and remain unaddressed. While the report predicts exceedances of regulatory thresholds for impacts of ...
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May 29, 2026 To: J. Esmonde, Cavalluzzo LLP From: Dr. Brian Branfireun, London, Canada (bbranfir@uwo.ca) RE: Great Bear Project – Impact Statement (https://iaac-aeic.gc.ca/050/evaluations/document/166124) 1) Introduction I was asked to review the above Impact Statement documents for the Kinross/Great Bear Gold Pro ject and provide an expert opinion. I have also reviewed the report of Dr. K. Morin (May 2026) re lated to this same Impact Statement, as his expertise in geochemistry- and mine-related processes is relevant and complementary to mine. I have provided expert opinion on many submissions and memos related to dimensions of this project leading up to this Impact Statement, and this document largely relies on those prior submissions which will be referred to here where appropriate, in the in terest of brevity. Given the extensive technical scope of the IS documents I am unable to comment on many aspects as they are outside of my area of expertise. As such I am focussing on the compon ents of the Impact Statement which concern themselves with sulphate release from the Project, the evaluation of mercury methylation in receiving ecosystems, and the potential exposure to biota. 2) Summary of Opinions 1) Despite a substantial shift in the degree of acknowledgement of the sulphate – mercury methyla tion issue by the Proponent, the Proponent’s ultimate conclusion of little to no impact on methylmercury levels in fish (or consumers) by the proposed Project is arrived at through a flawed conceptualization of the processes involved, flawed field methodologies, and oversimplified mod- elling that combine to minimize project effects. 2) The minimization of the Project impact on mercury ...
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TECHNICAL MEMORANDUM ____________________________________________________________________________ Date: May 28, 2026 To: Joseph B. Fobister, Lead Negotiator (Grassy Narrows Land Protection Team), David Sone (ANA Advisor), Jackie Esmonde (Legal Counsel) and Sydney Lang (Legal Counsel) of the ANA Advisory Team From: Martin Eunseo Shin (M.A.Sc., E.I.T.), Rina Freed (Ph.D., P.Eng.), Fraser Riddolls (B.Sc., B.I.T.), Sally Turnbull (B.Sc.) Subject: Review of the Great Bear Project Impact Statement – Preliminary Technical Review Comments Introduction Source Environmental Associates Inc. (Source) was retained by Asubpeeschoseewagong Netum Anishinabek (ANA) to review the Great Bear Project Impact Statement submitted in support of the proposed Great Bear Gold Project. The Great Bear Project herein represents a transition from the previously reviewed Advanced Exploration (AEX) Program to a proposed full-scale mining operation. The project includes both underground mine and open pit development, mine water management infrastructure, waste rock and ore handling facilities, water treatment systems, closure and reclamation components, and associated infrastructure with the potential to affect groundwater, surface water, aquatic ecosystems, and downstream receiving environments. This memorandum provides Source’s preliminary technical review comments on the Impact Statement and associated supporting documents. The review focuses on technical deficiencies, information gaps, uncertainties, and environmental risks, particularly with respect to: • Water quality and contaminant loading; • Groundwater and surface water interactions; • Mine water management and treatment; • ...
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Great Bear Gold Project - Review of the Impact Statement (IS) prepared for: Grassy Narrows Lands Protection Team c/o Cavalluzzo Attn: Ms. Jackie Esmonde prepared by: Kevin A. Morin, Ph.D., P.Geo., L.Hydrogeo. Minesite Drainage Assessment Group www.MDAG.com contact@MDAG.com May 27, 2026 Great Bear Gold Project - Review of the Impact Statement (IS) 2 TABLE OF CONTENTS List . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 List of Figures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Report Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 1. Introduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 2. Major Irrefutable Errors Invalidating the Great Bear Impact Statement. . . . . . . . . . . . . . . . . . 14 2.1 The Nature and Likely Origin of the Major Irrefutable Errors in the Great Bear Impact Statement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 2.2 Major Irrefutable Errors in the Great Bear Water Balance Invalidates All Estimates of Water Flows and Associated Qualities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 2.3 Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 3. Many Grave and Major Errors in the Great Bear Groundwater Model That Grossly Underestimate Impacts on ...

Attachment Grassy Narrows Preliminary Comments on Great Bear Gold Project Impact Statement

Great Bear Gold Project
Author: Grassy Narrows First Nation
Reference number: 98
Submitted: 2026-05-29 - 3:50 PM
Project phase: Impact Statement
Participation notice: Public notice - Comments invited on the summary of the Impact Statement
As a First Nation living immediately downstream from this project, we will live with the consequences for many generations to come. It is our children who will drink the water, eat the fish, pick the wild rice, swim, and learn what it means to be Anishinaabe on this river whose waters will carry the effluent from this gold mine if it is built. It is our people who will search in vain for moose and caribou to hunt on the landscape that has had its forests fragmented and degraded by access roads, clearcuts, seismic lines, pits, trenches, clearings, and mines. It is our people who will be impacted if the tailings dam fails. It is our people who will be poisoned when toxics leach into the water. It is our people whose fear and anxiety, already far too high and fatal due to the mercury crisis, will be heightened by the threat this mining project poses to our wellbeing. Grassy Narrows does not consent to the Great Bear Gold Project. And Grassy Narrows does not consent to the IS which contains inaccurate, insufficient, unreliable, and scientifically indefensible information about the impacts that are most dangerous to us, the first downstream community. The IS does not accurately nor sufficiently capture and assess the potential impacts of the Project on our environment, health, way of life, and ability to exercise our inherent, Aboriginal and Treaty rights, including the cumulative impacts of the Project and past, present, and future industrial activities. We urge IAAC not to move forward with the IA until Great Bear has provided a revised IS that meaningfully considers and incorporates our concerns including our Preliminary Land Use and Occupancy Study, the ETR and Grassy Narrows’ experts have had an ...
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May 29, 2026 Attention: Anjala Puvanathan (Director, Ontario Region) (greatbear@iaac-aeic.gc.ca) Impact Assessment Agency of Canada Ontario Region 600-55 York Street Toronto, ON M5J 1R7 RE: Grassy Narrows Preliminary Comments on Great Bear Gold Project Impact Statement On behalf of Asubpeeschoseewagong Anishinabek (“ANA” or Grassy Narrows First Nation”), we write to share with you Grassy Narrows’ preliminary submission with respect to the Impact Statement (“IS”) prepared by Great Bear/Kinross for the Great Bear Gold Project. This submission is in addition to the expert reports identifying major deficiencies with the IS and risks of the Project, the comments on the IS from our legal counsel, and our previous submissions on the Project that we have shared with you. Grassy Narrows continues to be extremely concerned that Kinross wants permission to put more dangerous pollution into our life-giving river. The purpose of the Impact Assessment (“IA”) is to evaluate the potential environmental, economic, health, and social impacts of the Great Bear Gold Project. We do not believe that the IS prepared by Kinross provides the Impact Assessment Agency of Canada (“IAAC”) with accurate, sufficient, reliable, and scientifically defensible information to proceed with the Impact Assessment. We believe, based on what our experts tell us and our own traditional knowledge and experience, that the Project will cause unbearable and irreparable impacts on our environment, health, and rights. Grassy Narrows has already suffered far too much from the cumulative impacts of industry that has been forced on our lands, waters, and people with terrible consequences. Our people are sick, our fish ...

Attachment ORA comments on the Great Bear Gold Project, Summary of the Impact Statement

Great Bear Gold Project
Author: Ontario Rivers Alliance
Reference number: 97
Submitted: 2026-05-29 - 7:45 AM
Project phase: Impact Statement
Participation notice: Public notice - Comments invited on the summary of the Impact Statement
The Ontario Rivers Alliance (ORA) is a not-for-profit grassroots organization with a mission to protect, conserve and restore Ontario riverine ecosystems. ORA advocates for effective policy and legislation to ensure that development affecting Ontario rivers is environmentally and socially sustainable. See ORA's full comments in the attached file.
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379 Ronka Road Worthington, ON P0M3H0 LindaH@OntarioRiversAlliance.ca OntarioRiversAlliance.ca “A World of Healthy River Ecosystems” 29 May 2026 Impact Assessment Agency of Canada Place Bell Canada, 160 Elgin Street, 22nd Floor Ottawa, ON K1A 0H3 By email: GreatBear@iaac-aeic.gc.ca Re: Great Bear Gold Project, Summary of the Impact Statement IAAC Reference Number: 85832 Dear Agency Team: The Ontario Rivers Alliance (ORA) is a not-for-profit grassroots organization with a mission to protect, conserve and restore Ontario riverine ecosystems. ORA advocates for effective policy and legislation to ensure that development affecting Ontario rivers is environmentally and socially sustainable. ORA has closely monitored the Great Bear Gold Project throughout each phase of the Impact Assessment process. These comments, submitted at the Impact Statement (IS) Summary stage as the third of four public comment opportunities, represent ORA's first formal submission to this assessment. We have engaged at this stage because the IS Summary places the proponent's full evidence base before the Agency and the public, and it is here that the substantive gaps in that evidence base are most visible and most consequential to address before the technical record is closed. The proposed project is a large-scale open-pit and underground gold mine located within Treaty 3 territory, 23 kilometres southeast of Red Lake, Ontario, in the Chukuni River watershed. It would operate for 26 years, process 15,000 tonnes of ore per day, discharge treated effluent to the Chukuni River, and retain approximately 345 hectares of tailings behind three dams in perpetuity. The Chukuni ...

Attachment Northwestern Ontario Métis Community Comments on the Impact Statement for the Great Bear Gold Project

Great Bear Gold Project
Author: Administrator on behalf of Northwestern Ontario Métis Community
Reference number: 114
Submitted: 2026-05-29
Project phase: Impact Statement
Participation notice: Public notice - Comments invited on the summary of the Impact Statement
La version française suit: Administrator Note: Please see the attached submission and notice of confidential Indigenous Knowledge received from the Northwestern Ontario Métis Community (document reference number 113). Note de l'administrateur : Veuillez consulter la pièce jointe et l'avis concernant le savoir autochtone confidentiel reçu de la communauté métisse du Nord-Ouest de l'Ontario (numéro de référence du document 113).
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Regional Councillor For the Northwestern Ontario Métis Community 1 May 29, 2026 Dietrich MacRae-Maahs Project Manager Great Bear Gold Project Impact Assessment Agency of Canada Sent via email: greatbear@iaac-aeic.gc.ca Dear Dietrich MacRae-Maahs: Re: Northwestern Ontario Métis Community’s Review of Kinross Gold Corporation’s Impact Statement for the Great Bear Gold Project This letter is submitted to the Impact Assessment Agency of Canada (“IAAC”) by the Northwestern Ontario Métis Community (“NWOMC”). On April 14, 2026, IAAC began a 45-day comment period for the Impact Statement submitted by Kinross Gold Corporation (“the Proponent”; “Kinross”), for the Great Bear Gold Project (the “Project”), having determined that the Impact Statement met the necessary requirements for the conduct of the impact assessment. The NWOMC completed a technical review of the Impact Statement with a focus on determining the adequacy of the Proponent’s assessment of impacts of the Project to the NWOMC’s s. 35 rights. In general, the NWOMC’s review found several discrepancies between the Impact Statement conclusions and the NWOMC’s Traditional Knowledge and Land Use Study (“TKLUS”) conclusions. Additional consideration of the NWOMC’s rights and perspectives, as well as additional mitigation measures, should be incorporated into the Impact Statement to address the discrepancy. This letter summarizes: (1) the NWOMC’s comments on the Impact Statement, and (ii) the NWOMC’s proposed additional mitigation measures. The NWOMC engaged MNP LLP to conduct a review of the Impact Statement and the draft Closure Plan. Below is a summary of key comments, along with the following enclosures: ...

Attachment Great Bear Impact Statement Response

Great Bear Gold Project
Author: Evolution Mining
Reference number: 96
Submitted: 2026-05-28 - 2:59 PM
Project phase: Impact Statement
Participation notice: Public notice - Comments invited on the summary of the Impact Statement
Please see attached PDF on behalf of Evolution Mining, Red Lake Operations
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Evolution Mining Limited Evolution Mining Gold Operations Ltd. CN: 1175320-7 (A subsidiary of Evolution Mining Limited ABN 74 084 669 036) Red Lake Operations P +807 735 2077 15 Eric Radford Way, Bag 2000 Balmertown, ON P0V 1C0 Canada Registered Office 66 Wellington Street West TD Bank Tower Suite 5300 Toronto, ON M5K 1E6 Canada www.evolutionmining.com.au 1 May 28, 2026 Kinross Great Bear Impact Statement Re: Impact Statement Response: Socio-Economic, Infrastructure and Regional Capacity Considerations - Great Bear Gold Project The Great Bear Gold Project Impact Statement presents a comprehensive overview of the proposed project, including anticipated economic benefits, environmental mitigation measures, Indigenous engagement activities, and community investment initiatives. The document clearly demonstrates significant effort toward consultation, environmental baseline work, and incorporation of Indigenous knowledge into the assessment process. However, while the Impact Statement provides substantial technical details regarding the mine footprint and environmental mitigation measures, many of the most significant operational, social, and reputational risks associated with the Project are likely to emerge not from the direct mine footprint itself, but rather from broader regional and cumulative socio-economic pressures. These include: • Regional labour competition • Housing availability and affordability • Community expectations regarding benefits • Municipal infrastructure and service strain • Long-term relationship management with Indigenous Nations and local governments The current impact statement appears to lack ...

Attachment Northwest Training and Adjustment Board Letter of Support and Workforce Planning Considerations

Great Bear Gold Project
Author: Northwest Training and Adjustment Board
Reference number: 95
Submitted: 2026-05-19 - 3:38 PM
Project phase: Impact Statement
Participation notice: Public notice - Comments invited on the summary of the Impact Statement
Please find attached the Northwest Training and Adjustment Board’s letter of support for the Great Bear Gold Project. NTAB recognizes the project’s potential economic and workforce impacts for Northwestern Ontario and looks forward to continued engagement with Kinross Gold as planning and development move forward.
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www.ntab.on.ca Northwest Training and Adjustment Board 113-100 Casimir Avenue Dryden • Ontario • P8N 3L4 Tel: 807.223.3813 May 19, 2026 Impact Assessment Agency of Canada 55 York Street, 6th Floor Toronto, Ontario M5J 1R7 Telephone: 416-952-1576 Email: GreatBear@iaac-aeic.gc.ca Dear Sir or Madam, SUBJECT: GREAT BEAR GOLD PROJECT On behalf of the Northwest Training and Adjustment Board (NTAB), I am pleased to express our support for the advancement of the Great Bear Gold Project, owned by Kinross Gold Corporation. NTAB recognizes the significant economic and workforce opportunities this project may create for Northwestern Ontario through employment, skills development, and regional business growth. We also appreciate the project’s ongoing engagement with Indigenous communities, municipalities, training partners, and regional stakeholders. As the Project advances, continued coordination around workforce availability, training alignment, and regional service capacity will be important to supporting long-term success and maximizing local benefit. NTAB looks forward to continued collaboration in supporting regional workforce planning and labour market development related to the Project. We are pleased to provide this letter of support and look forward to continued engagement with Kinross Gold and the Great Bear Gold Project. Sincerely, Afreen Shabbir, Junior Executive Director mailto:GreatBear@iaac-aeic.gc.ca?subject=CIAR%2C%20Information%20Request

Attachment Local Trapline Concerns

Great Bear Gold Project
Author: Ken Anderson
Reference number: 94
Submitted: 2026-05-16 - 12:06 PM
Project phase: Impact Statement
Participation notice: Public notice - Comments invited on the summary of the Impact Statement
My concerns are for what are we leaving for Grandchildren's way of life on our family trapline. Will the water quality be the same so they can fish as we do? Will the forest be able to support animals for them to trap? Will there be moose for them to hunt in our traditional area? Will the noise pollution from the Mine site chase away all the animals? Will the air quality remain the same for these animals to exist? And finally, do the financial gains outweigh the lose of all this natural habitat? Is it worth the risk of loosing the clean air, water, and land that my grandchildren may not get to enjoy as I have. What is more valuable to them?

Attachment Pakwash Lake Owners Association, Formal Stakeholder Impact Submission addition

Great Bear Gold Project
Author: Pakwash Lake Camp
Reference number: 93
Submitted: 2026-05-11 - 11:53 AM
Project phase: Impact Statement
Participation notice: Public notice - Comments invited on the summary of the Impact Statement
The concerns from mining operations of the water/ecosystem. There is one other major concern that I would like to add to our previous submittion; that is controle and monitor ammonium nitrate entering the discharge water from spilled/wasted/undetonated explosives used in mining (ammonium nitrate is a major component of most blasting agents). I am aware from my time in the mining industry that this is a potential significant issue if not adequately addressed. Ammonium nitrate (NH4NO3) dissolves rapidly in water, releasing ammonium (NH4+) and nitrate (NO3-) ions. While nitrate is relatively safe, elevated ammonium levels, especially at high pH and temperature, are highly toxic to fish, causing gill damage, respiratory distress, and death. High levels can lead to rapid mortality, often causing "brown blood disease" or severe gill damage. Effects on Fish and Aquatic Life Ammonium/Ammonia Toxicity: The "ammonium" component is highly pH-dependent. At higher pH (alkaline) and temperatures, ammonium (NH4+) converts to ammonia (NH3), which is significantly more toxic. Ammonia causes tissue damage, particularly to gills, leading to difficulty breathing, listlessness, and potential death. Nitrate Toxicity: While less toxic than ammonia, high nitrate concentrations ((NO3-) from blasting compound wastage can stress fish, causing poor growth, weakened immune systems, and long-term health issues. Fish Kill Symptoms: Fish affected by ...

Attachment Pakwash Lake Owners Association, Formal Stakeholder Impact Submission

Great Bear Gold Project
Author: Pakwash Lake Camp
Reference number: 92
Submitted: 2026-05-11 - 11:30 AM
Project phase: Impact Statement
Participation notice: Public notice - Comments invited on the summary of the Impact Statement
FORMAL STAKEHOLDER IMPACT SUBMISSION DATE: May 11, 2026 TO: Impact Assessment Agency of Canada (GreatBear@iaac-aeic.gc.ca (mailto:GreatBear@iaac-aeic.gc.ca)) RE: Project 85832 – Great Bear Project – Formal Stakeholder Impact Statement FROM: Kim Budweg, Owner, Pakwash Lake Camp; Representative, Pakwash Lake Owners Association SUBJECT: Stakeholder Submission – Environmental Protection, Monitoring, and Enforceable Thresholds INTRODUCTION As a primary downstream stakeholder, I am submitting this response regarding the proposed Great Bear Project and its potential effects on the Pakwash Lake–Chukuni River watershed and the regional tourism economy. Having reviewed the Impact Statement, I acknowledge that it generally addresses several core requirements under the Impact Assessment Act, including: · Identification of valued ecosystem components · Description of potential pathways of environmental effects · Consideration of mitigation measures · Assessment of cumulative effects These elements appear to have been developed through consultation and technical study. However, the effectiveness of the proposed mitigation measures is fundamentally dependent on robust monitoring, transparent reporting, and enforceable thresholds tied to clear ...

Attachment GBG Comment Brief

Great Bear Gold Project
Author: ParadigmForge AI Inc.
Reference number: 91
Submitted: 2026-04-28 - 6:19 PM
Project phase: Impact Statement
Participation notice: Public notice - Comments invited on the summary of the Impact Statement
Cover Letter — Comments on the Summary of the Impact Statement, Great Bear Gold Project To: Impact Assessment Agency of Canada Re: Great Bear Gold Project — IAAC Registry Project #85832 Consultation closing: 2026-05-29, 23:59 ET Submitter: ParadigmForge AI Inc. Submission date: 4/28/2026 To the Impact Assessment Agency of Canada, ParadigmForge AI Inc. respectfully submits the attached comment brief on the summary of the proponent’s Impact Statement for the Great Bear Gold Project, published April 14, 2026 on the Canadian Impact Assessment Registry. The brief is filed under ParadigmForge’s own name, from ParadigmForge’s own chair, as a non-Indigenous Canadian regulatory-intelligence company participating in the public record of this proceeding in its institutional capacity. Nothing in this submission purports to speak for any First Nation, Métis community, Indigenous governing body, or rights-holder; the named rights-holder communities in this assessment — Asubpeeschoseewagong Netum Anishinabek (Grassy Narrows First Nation), Lac Seul First Nation, Wabauskang First Nation, the Métis Nation of Ontario (Region 1), and Grand Council Treaty #3 — remain the only authoritative voices on the nature, scope, and impact of their own rights, on the content of their own communications to the Crown, and on the adequacy, as a matter between rights-holder and Crown, of the Crown’s conduct toward them. The posture under which this brief enters the record. ParadigmForge’s position is that Canadian ...
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Comments on the Summary of the Impact Statement — Great Bear Gold Project Filed with: Impact Assessment Agency of Canada Project: Great Bear Gold Project (Kinross Gold Corporation) IAAC Registry: Project #85832 Proponent: Kinross Gold Corporation Location: 23 km southeast of Red Lake, Ontario (Treaty 3 territory) Comment period closes: 2026-05-29, 23:59 ET Submitted by: ParadigmForge AI Inc. Submission date: [to be inserted] Institutional posture declaration This submission is filed under the ParadigmForge Submission Protocol, the operational expression of the Living Processes Doctrine adopted by ParadigmForge AI Inc. in April 2026. Every regulatory, quantitative, or structural claim in this submission carries a section-level citation to the primary source with effective date; every claim resolves, through ParadigmForge’s provenance architecture, to the specific retrieved evidence chunk that supports it; every submission is stress-tested through a fifty-two-indicator adversarial validation suite and a cross-jurisdictional conflict detector before entering the record. The chair from which this submission is made — what this submission purports to do, and what it does not purport to do — is declared in the positioning section that follows; readers on files where the chair is particularly sensitive are asked to read the positioning section before the substantive content. The full Protocol is published at paradigmforge.ai/doctrine/protocol and the Doctrine it realises at paradigmforge.ai/doctrine; a reader who wishes to verify this submission’s compliance with either can do so through the published reference documents. Section 0 — Analytical Methodology The four ...

Attachment Concerns with the Great Bear Resources Gold Project

Great Bear Gold Project
Author: Ayicia Nabigon
Reference number: 90
Submitted: 2026-04-16 - 11:02 PM
Project phase: Impact Statement
Participation notice: Public notice - Comments invited on the summary of the Impact Statement
As a resident of northern Ontario, I have too often experienced and seen the harmful effects of gold mining in our home. I have several concerns with the impact statement that I would like to highlight. In section 3.4 of the document, the company states that they gave presentations to Lac Seul First Nation, Asubpeeschoseewagong Netum Anishnabek, Waubaskang First Nation, and the Northwestern Ontario Metis Community about "potential health effects to Indigenous people" and hosted workshops related to "fish habitat offsetting, Species at Risk, mine closure scenarios, and effects assessment". In presentations to Government Agencies, the company shared presentations on "migratory birds, water management, aquatic effects and fish and fish habitat offset measures, and also included methylmercury bioaccumulation modelling in fish and consumption of fish by Indigenous people. I have concerns about whether the information shared with government agencies was the same information that was shared with Indigenous communities. While the company engaged in Traditional Use and Knowledge consultation with communities, where concerns including health of fish, methyl-mercury contamination, and water protection were raised, they do not include the details about whether these topics (that were presented to government agencies) were shared in detail with the affected communities. The maps in Section 5 do not show the position of the mine in relation to the larger watershed of the region. The maps are not detailed enough to see how the tailings facility(ies) may impact the surrounding waterways, and is not detailed enough to give communities a sense of areas that could be ...

Attachment Opposition to proposal

Great Bear Gold Project
Author: Concerned Citizen
Reference number: 89
Submitted: 2026-04-16 - 11:07 AM
Project phase: Impact Statement
Participation notice: Public notice - Comments invited on the summary of the Impact Statement
This project should not proceed without the explicit and informed consent of all Indigenous peoples who this development would directly impact. I am deeply concerned for the ongoing disregard of the peoples who live in this region. I strongly oppose this development.

Attachment Not in support of Great Bear Mine

Great Bear Gold Project
Author: Lydia Johnson
Reference number: 88
Submitted: 2026-04-16 - 10:28 AM
Project phase: Impact Statement
Participation notice: Public notice - Comments invited on the summary of the Impact Statement
I am strongly opposed to the Great Bear Mine. I encourage IAAC to look to the ALIA for guidance, and disagree with the impact assessment summaries conclusions that there is "not significant" and "reversible" impacts to the Treaty Rights of Indigenous Peoples. The land is our relative and a massive clearing and destroying of an area will have impact forever. The land will never be the same. I would never harvest, hunt or fish on an area I knew was once a mine. Proposed mitigations need to be checked upon and have ensured success, for example the loss of manoomin and planned replanting. Mitigation must go beyond "replanting" and Kinross should be responsible for checking on that process to ensure success. Indigenous communities in this area, most notably Grassy Narrows, have historical and on-going trauma due to industry. I am extremely concerned for downstream communities and the fact that 50% of the population in this area are Indigenous. Lastly, gold is an unessential mineral and I disagree with this project being fast-tracked.

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Date modified:: 2019-03-01

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