15-Mile Processing Hub Project

Attachment 15-Mile Processing Hub Project - Invitation to Comment on the Summary of the Initial Project Description Sipekne'katik First Nation

• 15-Mile Processing Hub Project
• Author: Administrator on behalf of Sipekne'katik First Nation
• Reference number: 460
• Submitted: 2026-07-14 - 2:09 PM
• Project phase: Planning
• Participation notice: Public notice - Comments invited on the Summary of the Initial Project Description and participant funding available
• See the attached submission / Veuillez consulter la pièce jointe
• Attachment included
• July 14, 2026 Impact Assessment Agency of Canada 200-1801 Hollis Street Halifax, Nova Scotia B3J 3N4 RE: 15-Mile Processing Hub Project - Invitation to Comment on the Summary of the Initial Project Description Sipekne'katik First Nation This submission provides interim comments and observations from Sipekne’katik First Nation concerning the Initial Project description (IPD) for the 15-Mile Processing Hub Project, as submitted for initial review to the Impact Assessment Agency Canada (IAAC) by 15-Mile Minerals and Renewables. These comments do not represent Sipekne’katik’s final position or decision on the Project, nor do they constitute consent. Consultation on this project is ongoing, and these comments must not be relied upon by the Proponent or any regulatory authority as evidence or satisfaction of the Crown's Duty to Consult under Section 35 of the Constitution Act, 1982. Sipekne’katik understands that this comment period is to determine whether this project will have impacts to areas of federal jurisdiction including impacts to Indigenous communities and Aboriginal and Treaty Rights. Further, Sipekne’katik understands this comment period is also intended to determine whether this project will undergo a federal impact assessment. To be clear, this project has the potential to negatively impact the health of Sipekne’katik community members and to appreciably and significantly impact the ability of community members to exercise their Aboriginal and Treaty Rights. See Appendix 1 for specific comments on potential impacts. This project spans multiple locations over a range of 75 kilometers and is located within 50 kms of Sipekne’katik First Nation. ...
• Attachment included
• Dr. Roger J. Lewis, CM Director of Consultation Sipekne’katik Governance Initiative 515 Church Street Indian Brook, Hants County, Nova Scotia I am writing this in my capacity as Director of Consultation for the Sipekne’katik First Nation, but more importantly as an educator and member of the Sipekne’katik Community. I wish to offer a response to the proposed “one project, one review” on Environmental and Impact Assessments. I opt not to speak to the scope or intent of the laws that define the division of powers as they currently exist between our federal and provincial institutions. However, if my personal interpretation of Canadian history serves me correctly, I respectfully offer: • The Constitution Act, 1867, says that the provinces are federally united to form Canada. • Section 91 (24) of the constitution Act, 1867, states that Parliaments has exclusive authority over “Indians and lands reserved for Indians’. • In Canada, the federal Crown owes a sui generis (unique) fiduciary duty to Indigenous peoples, stemming from the historical relationship of the Royal Proclamation of 1763, and section 35 of the Constitution Act, 1982. Rooted within this history is a foundational constitutional principle (Honour of the Crown) that dictates how federal and provincial governments must interact with Indigenous peoples in Canada. • The “Honour of the Crown” requires the government to act with loyalty, good faith, and diligence when exercising discretionary control over specific First Nations interests. The “one project, one review” position of the Nova Scotia government with respect to the assessment process is a turning point that must be addressed ...
• Attachment included
• 1 Impacts within Federal Jurisdiction Assessment Framework Section 35 of the Constitution Act, 1982 recognizes and affirms existing Aboriginal and Treaty rights. For the Mi'kmaq of Nova Scotia, these rights include hunting, fishing, gathering, travelling throughout traditional territory, accessing culturally significant places, and sustaining practices necessary to maintain Mi'kmaq culture and way of life. The exercise of these rights depends not only on continued physical access to the land but also on the continued availability, quality, safety, and ecological integrity of the resources upon which those rights depend. Accordingly, the central question for this review is not whether the Project allows continued access to the landscape, but whether the Project maintains the environmental conditions necessary for Mi'kmaq rights to be meaningfully exercised over the long term. While, the Initial Project Description does recognize ongoing Mi'kmaq use of the project area it gives comparatively little consideration to how environmental effects interact to influence the exercise of rights. This lack of an integrative approach to effects assessment is precisely the reason a federal assessment is required. A synthesis of potentially adverse effects and their relationship to impacts on Mi’kmaq communities cannot be achieved through a provincial only assessment, or various federal regulatory processes acting on silos. Effects on the Exercise of Harvesting Rights The Mi'kmaq Ecological Knowledge Studies document ongoing fishing, hunting, trapping and gathering within or immediately adjacent to the Project Development Areas. The Project Description emphasizes maintaining physical ...