Request for Time Limit Extension from Marten Falls FN to the Impact Assessment Agency of Canada
WCS Canada comments on the Request for Extension Report, prepared by AECOM Canada Ltd. and Dillon Consulting Ltd. on behalf of Marten Falls First Nation as the Proponent for the purpose of the Impact Assessment (IA) of the Marten Falls First Nation All Season Community Access Road (MFCAR) Project. In summary, we support the request by the Proponent for an extension of three and a half years to July 24, 2026. Of the factors listed in Section 2, we agree in particular that COVID-19 had significant impacts on First Nations communities in the far north in Ontario and have concerns that the Proponent chose not to pause the MFCAR Project despite First Nation community requests to do so given health and safety concerns, capacity, and social crises. We continue to think this experience highlights the limitations of impact assessment as a tool for social justice in northern Ontario.
Request for Time Limit Extension from Webequie First Nation to the Impact Assessment Agency of Canada (Project reference number: 80183)
In summary, we support the request by the Proponent for an extension of three years to January 6, 2027 in order to address the information required as described in the Tailored Impact Statement Guidelines (TISG) for the WSR Project. We agree that COVID‐19 has had, and continues to have, significant impacts on First Nations communities in the far north in Ontario and we expressed concern throughout this process that the Proponent chose not to pause the WSR Project despite First Nation community requests to do so when faced with health and safety concerns, capacity issues, and ongoing and emergent social crises. We continue to think this current process with respect to COVID‐19 highlights the limitations of impact assessment as a tool for social justice and reconciliation with First Nations in northern Ontario.
Summary of Key Issues with the Draft Agreement to Conduct a Regional Assessment in the Ring of Fire Area and Recommendations
In 2021, the Government of Canada agreed to undertake a Regional Assessment (RA) of the Ring of Fire, an area of world‐class mineral potential located within the globally important Hudson Bay Lowland, under the federal Impact Assessment Act (IAA) at the request of WCS Canada and others. The Impact Assessment
Agency of Canada (IAAC), in negotiation with the province of Ontario, developed a draft
Agreement setting out the scope and form of the RA.
As our comments below make clear, the draft Agreement fails to capitalize on the opportunity
to undertake proactive planning for an area that is recognized internationally as a priority
region for action on the global climate and biodiversity crises, and is the homeland of First
Nations who are the only population living in the region. WCS Canada scientists have been
actively working to understand the critical ecosystems and the species and services they
support as well as approaches to conserving them, including with First Nation communities, for
the past 15 years. We have applied our scientific knowledge of the area to inform our
assessment and recommendations on the draft Agreement for the RA.
WCS Canada Comments_Draft Agreement to Conduct a Regional Assessment in the Ring of Fire (Reference Number: 80468)_January 2022
WCS Canada submits its comments to the Impact Assessment Agency of Canada (IAAC) regarding the draft Agreement for a Regional Assessment of the Ring of Fire Area. We make a number of recommendations around the need to address cumulative effects and governance. We identify key issues related to: 1) revising the goal to and objectives to address cumulative effects; 2) increasing the scope of the assessment to a “Regional Study Area” in which all human activities and climate change can be assessed through to the next 100 years; 3) including the current road proposals to the Ring of Fire; 4) expanding the assessment priorities to include peatlands and impacts to carbon storage and sequestration and a number of other ecological and social priorities; and, 5) specific recommendations on the composition and mandate of the Committee, and Advisory Groups, that will be conducting the Regional Assessment. We raise concerns about the process with First Nations and the lack of representation and inclusion to date.
WCS Canada Comments_Draft Project List Regulation Under The Environmental Act (ERO 019-4219_20220125)_ January 2022
WCS Canada submits comments to the Environmental Assessment Modernization Project Team of Ontario's Ministry of the Environment, Conservation and Parks. We recommend a complete overhaul of the proposed project list regulation in an expert-driven process based on four major concerns:
1) The project list is insufficiently inclusive of those most likely to have significant impacts;
2) There is no evidentiary basis for “thresholds” for inclusion on the project list;
3) The approach perpetuates lack of attention to cumulative effects in the EAA; and
4) There is no clear process that enables Ontarians to request designation of non-listed
projects that warrant a Comprehensive EA.