Northern Road Link Project

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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
  • Participation Notice: N/A
  • *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 ...
  • 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 ...

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Cumulative effects Current Use of Lands and Resources for Traditional Purposes by Indigenous Peoples Human Health and Well-Being Indigenous Consultation Method Indigenous Culture Indigenous Knowledge Indigenous Rights Vulnerable Population Groups (Gender-based Analysis Plus (GBA ))

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 ...
  • 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 ...

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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 ...

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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 ...

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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 ...

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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
  • Participation Notice: N/A
  • 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, ...
  • 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 ...

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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 ...
  • 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 ...
  • Attachment Included
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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
  • Participation Notice: N/A
  • 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 ...

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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 ...
  • 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 ...

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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 ...

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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 ...

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