Lake Sturgeon, Indigenous Women, Girls and Gender Diverse Persons, Ecological Impacts

Timiskaming Dam-Bridge of Quebec Replacement Project 80151 Comment

To whom it may concern,???

This comment is provided in response to the proposed, Timiskaming Dam-Bridge of Quebec Replacement Project. In our review of the environmental impact statement, we prepared a summary of information and disseminated it to interested parties from nearby communities. This comment is a summary of the feedback and insights we obtained and is being submit on behalf of Keepers of the Circle. Our organization has locations based in Kirkland Lake and Timiskaming Shores and therefore, our communities will be affected by the bridge reconstruction, as employees and their families have relied on this bridge and will continue to do so well into the future.

We agree that the bridge is an essential transportation channel, connecting Northern communities to major roads and infrastructure, as well as connecting Ontario and Québec. Since the bridge is now over 100 years old, we agree that the bridge should be updated to ensure continued safe transportation can be provided. Nevertheless, we seek to emphasize that the wellbeing of ecosystem and community health, extending to aquatic and land-based species, is essential in the deconstruction and construction process.

Upon reviewing the 3 options presented in the environmental impact statement, we caution that option 1 would overlay into a sturgeon spawning ground and the population is vulnerable through its life cycle in the proposed area. We also note that this option creates a significantly larger loss of fish habitat compared to option 3 (12,361m and 11,153m of fish habitat lost, respectively). It is stated that there is very little discrepancy between value component impacts, however we are worried about the additional 1,210m of lost habitat and the ecological impacts that might create for a variety of fish species in the river.

We would like to advocate for the inclusion of a fish passage ‘fishway’, as is mandated by the DFO. The dam is currently not passable by fish, in either direction. We believe that a fishway would improve ecosystem connectivity and minimize the negative environmental impacts of the dam replacement. We read that other nations have expressed concerns related to the different fishway options that were presented, due to the lack of data available on the effectiveness of these options. We request that the agency take steps to conduct or fund research that can provide a greater degree of confidence in the effectiveness of various methods, in order to make an informed decision. Our initial concerns are that if fish passage is currently not possible, how have the distinct waterways adapted distinct ecosystem dynamics? Could the reintroduction of fish passage create negative implications to overall ecosystem health? Is there a risk of introducing invasive species or non-native species? How will the addition of a fishway alter the existing ecosystem dynamics, and how will those dynamics be monitored?

We wish to echo many of the key concerns summarized in the environmental impact statement including:

• water quality impacts
• waterway obstruction
• cumulative impacts to the Ottawa River waterway system as a whole
• cumulative impacts from past development projects
• cumulative impacts from adjacent resource extraction projects
• fish population dynamics, habitat degradation, preservation of essential fish spawning grounds
• potential adjusted flow rates, altered flood risk
• risk of contaminants in water from construction or demolition
• potential impacts of fishways, riparian habitat preservation
• ensuring socio-economic opportunities are reaching Indigenous people (training, employment, business support)
• impacts to community health & wellbeing
• maintaining the rights of Indigenous people, preserving artefacts and traditional land use
• key species of the area: lake sturgeon, American eel, walleye, bass, yellow perch, northern pike, lake trout, freshwater mussels, painted turtle, snapping turtle, two-lined salamander, beaver, birds, eagle, ducks, geese
• culturally important wildlife, including: amphibians, reptiles, birds, monarch butterflies, and species at risk

Finally, we would like to request that, to the greatest degree possible, material be sourced locally and ethically, with local, Indigenous construction workers and companies being hired. Prioritizing jobs to Indigenous people who live in the region and would not have to be relocated for work.                                                                                 ? 

Our organization explicitly requests that steps are being taken to ensure that Indigenous women, girls, and gender diverse people are being included in decision making and implementation of this project and that their input is being thoroughly considered with tangible, measured mitigation of impacts as Indigenous women are water keepers and carry sacred knowledge and responsibilities to the waterways. We would like to ensure that surrounding First Nation communities and urban Indigenous people have been sufficiently informed in advance of project developments and are given support and time to provide input.? Specifically, we request the voices of Indigenous women, girls and gender diverse people are intentionally being included when assessing the potential impacts from project development and prioritized during the implementation of the project through providing equal hiring access to Indigenous women, providing safe and secure employment throughout project development.?Thank you for considering our comments in the Impact Assessment Process.??We look forward to an equitable, sustainable, and just future for all Canadians now and for future generations. We value collaboration and transparency as we aim to work together to mobilize for a just, equitable, and sustainable future.?? 

Thank you for considering our comments and ensuring that nearby First Nation communities are included in the Impact Assessment Process.