Summary of Issues

Impact Assessment Agency of Canada
Ontario Region
600-55 York Street
Toronto ON M5J 1R7

Agence d'évaluation d'impact du Canada
Région de I'Ontario
600-55 rue York
Toronto ON M5J 1R7

Sent by Email

October 11, 2019

Chief Bruce Achneepineskum
Marten Falls First Nation
General Delivery
Ogoki Post ON P0T 3A0

Agency File No: 80184

Dear Chief Bruce Achneepineskum:

Subject: Summary of Issues for the Marten Falls Community Access Road Project

The Impact Assessment Agency of Canada (the Agency) conducted comment periods from August 9, 2019, to August 29, 2019, and from September 11, 2019, to October 1, 2019, to invite participants to provide their perspective on any issues that they consider relevant in relation to the Marten Falls Community Access Road Project (the Project). All submissions received from Indigenous groups and the public are available on the Canadian Impact Assessment Registry (reference # 80184).

A Summary of Issues document, which reflects the comments received by the Agency is included as Attachment 1 to this letter. The Summary of Issues provides a record of the issues raised. As it is a high-level summary, the Agency directs the proponent to review the original submissions posted on the Registry.  

Pursuant to subsection 15(1) of the Impact Assessment Act, Marten Falls First Nation must provide the Agency with a Detailed Project Description that sets out how it intends to address the issues in the Summary of Issues and includes the information described in the Information and Management of Time Limits Regulations (the Regulations). The requirements for the Detailed Project Description are set out in section 4 and Schedule 2 of the Regulations. Please consult the Guide to Preparing an Initial Project Description and a Detailed Project Description at for further information.

Marten Falls First Nation is encouraged to provide meaningful responses to the issues documented in the Summary of Issues. The Summary of Issues and Marten Falls First Nation's responses will be used to inform the Agency's decision on whether to require an impact assessment for the Project, and to inform the Tailored Impact Statement Guidelines, should an assessment be required. In preparing the response, there may be some issues that, in the view of Marten Falls First Nation, are outside of its care and control. In this situation, Marten Falls First Nation may choose to identify the party or parties with the potential to address the issue(s).

Please provide the Agency with your Detailed Project Description, including the response to the Summary of Issues, by November 10, 2019, or inform the Agency that more time is required. Marten Falls First Nation is strongly encouraged to contact the Agency in the next few days to discuss how much time will be required to produce the Detailed Project Description. If more than 30 days is required, please send a request to the Minister of Environment and Climate Change Canada through the Agency at the address below, to ask that the Agency suspend the time limit until the required information is provided.

Important note: Marten Falls First Nation is reminded that all records produced, collected or received in relation to the impact assessment of the Project – unless prohibited under the Access to Information Act – will be considered public and posted on the Canadian Impact Assessment Registry Internet site.

For ease of reference, the Agency requests that the response to the Summary of Issues be provided in a table with reference to other parts of the Detailed Project Description as warranted. If you have any questions, please do not hesitate to contact me at 416-476-8915 or


<Original signed by>

Chiara Calabrese,
Project Manager


1. Summary of Issues for the Marten Falls Community Access Road Project

c.c.: Qasim Saddique, Marten Falls Access Road Project
Jack Moonias, Marten Falls First Nation
Christine Cinnamon, AECOM
Jennifer Bruin, J. Bruin Associates Inc.

Summary of Issues – Marten Falls Community Access Road

This document provides a high-level summary of the comments received by the Impact Assessment Agency of Canada (the Agency) on the Marten Falls Community Access Road (the Project), during the comment period on the Initial Project Description submitted by the proponent, Marten Falls First Nation. The original submissions are posted on the Canadian Impact Assessment Registry.

Accidents and Malfunctions

Effects of accidents, including spills of hazardous substances.

Acoustic Environment

Effects of noise and disturbance to animals and Indigenous peoples.

Alternative Means of Carrying Out the Project

Clarity on criteria used to assess potential road routes.

Effects assessment on alternatives to consider effects on fish and wildlife habitat.

Effects assessment to consider important wildlife areas, such as higher ground, travel routes and den sites.

Effects assessment to consider dedicated protected areas identified through the Community Based Land Use Plans (CBLUP) developed by Indigenous groups potentially impacted by the Project.

Alternatives to the Project

Consideration of alternatives to the Project, including rail as a mean of transportation of nickel and chromite and an East-West road corridor from Pickle Lake to the Ring of Fire area.

Atmospheric Environment

Effects on air quality.

Birds, Migratory Birds and their Habitat

Effects on wetlands, which represent the habitat of migratory birds during breeding season and migration.

Effects from the creation of clearings in the uplands, which could attract migratory birds to areas with vehicular traffic, thereby increasing collision risk.

Climate Change and Greenhouse Gas Emissions

Effect on climate change and effects due to greenhouse gas emissions.

Effect on carbon sink due to the removal of wetlands and muskeg.

Country Foods

Effects on quality and quantity of country foods, including fish, wildlife (including caribou) and plants, including medicines.

Effects on country foods from contaminants due to changes in water and soil quality, which could be absorbed by foods sourced through hunting, trapping, fishing, hunting, harvesting, or grown for subsistence or medicinal purposes.

Effects on peatland and wetland areas, which could increase the mercury methylation processes and be absorbed by people through country foods.

Cumulative Effects

Cumulative effects from industrial uses of the road and from future infrastructure and projects facilitated by the road, such as mineral exploration activities and mines, in a previously pristine environment.

Cumulative effects on the environment and on Aboriginal and Treaty rights resulting from the Project and its potential expansions.

Cumulative effects on cultural, social, health and economic conditions.

Cumulative effects caused by the Ogoki River diversion project carried out in the 1940s-1950s.

Drinking Water

Effects on drinking water sources due to alterations to groundwater and surface water flow patterns.

Economic Conditions

Effects on economic conditions resulting from increased population, economic activities and opportunities, changes to cost of living, social and cultural settings, and in- and out-migration.

Effects on economic and cultural way of life due to changes in economic conditions.

Dialogue and cooperation with current and future industrial stakeholders whose interests and holdings may be impacted by the Project, including KWG Resources and Noront Resources.

Spillover effects on regional development in the Far-North due to the Project and the Webequie Supply Road.

Fish and Fish Habitat

Effects on fish passage resulting from the construction of water crossings, including effects on water quality, stream morphology, spawning habitat, fish habitat, death of fish and increased fishing activity.

Effects on fish and fish habitat resulting from construction and operations, such as runoff from roads and parking lots typically containing sediments, oil, grease and heavy metals that may be harmful to aquatic biota.

Follow-up and Monitoring Programs

Allocation of financial resources to cover the costs of any cleanup, restoration, reclamation or enhancement work required.

Food Security

Effects on food availability, including country foods, and cost.

General Assessment Type

Value of federal assessment due to the regional context, the social, health, economic and environmental effects, cumulative effects, and the Project listed in the Physical Activities Regulations.

Value of a regional assessment to support land use planning, and understand cumulative effects, including to freshwater, Aboriginal and Treaty rights, and climate change.

General – Project Description

Long-term feasibility for this proponent to manage all phases of the Project given proposed industrial use.

Transparency regarding funding (from federal and/or provincial government, private sector businesses or extractive industries) for the construction and operation, including maintenance, of an industrial road of this length.

Clarity on the Project's components, including the exact location of quarry pits and work camps.

Effects due to potential volume of traffic on the road for future mining projects.

Use of road (a community access road or an industrial road to enable future access to potential mineral development activities in the Ring of Fire area).

Clarity on locations of all potentially impacted Indigenous groups and their traditional territories for each project alternative.

Nature of the proponent's consultation activities and participants, including any responses provided to Indigenous groups.

Reasons for estimated timeline for the construction of the road.

Clarity on lead for the Project and information on the extent of involvement of the Marten Falls First Nation Project Team, including a list of the community members involved and examples of meeting minutes.

Clarity on workforce characteristics for the Project, including by gender, as well as main employment barriers for local under-represented groups.


Effects to groundwater, including from wetland contamination.

Human Health and Well-Being

Health impacts from noise on human receptors may vary based on construction timing (e.g. nighttime activities) and duration.

Indigenous and Stakeholder Engagement and Consultation

Involvement and support of Indigenous peoples for development in the Ring of Fire area.

Sufficient and timely funding for Indigenous groups and other stakeholders to participate in the Planning Phase.

Collaboration with Indigenous groups for provincial planning, due to the effects of the investment in the North-South Infrastructure corridor, which is a catalyst for regional development.

Early collaborative planning process and multi-party meaningful Indigenous

consultation throughout the federal impact assessment, including during the definition of the project design, taking into consideration Indigenous Knowledge and traditional land use.

Use of inputs gathered from Indigenous groups during consultation to revise effects assessment and alternative routes presented, in particular due to the effects on wildlife.

Indigenous Knowledge

Incorporation of Indigenous Knowledge into planning, management, and operational decisions as well as during environmental data collection, monitoring studies and identification of mitigation measures related to social, economic and environmental assessment of exploration activities or potential developments.

Indigenous Peoples' Current Use of Lands and Resources for Traditional Purposes

Impacts on Indigenous peoples' ability to continue traditional practices, such as trapping and use of trap lines, hunting, fishing, harvesting, berry picking, medicinal plant harvesting, teaching, and spiritual practices.

Impacts of easier access by non-Indigenous peoples to Indigenous traditional territories.

Indigenous Peoples' Economic Conditions

Effects on economic conditions (living cost, compensation, poverty, available land) of Indigenous peoples (including women and youth).

Proponent's contribution to training, skills development and employment.

Indigenous Peoples' Health Conditions

Effects on malnutrition, country food contamination, diabetes, cardiovascular issues, mental health and accessibility of health-care services.

Effects on air quality, air emissions and dust, which can cause adverse impacts on human sensitive receptors.

Effects of accessibility on increased number of pregnancies, sexual violence, sexually transmitted infections and gender-based violence on women and youth.

Indigenous Peoples' Rights

Impacts on rights protected under the Constitution Act, 1982, including rights to land and resources, Cree language, spirituality, family trap lines/Cree Nationhood, values-mores, choice of livelihood and vocation.

Indigenous Peoples' Social Conditions

Effects on social conditions from youth delinquent issues, child hunger, poverty, child-rearing responsibilities, single parenting.

Effects on social conditions due to loss of elders as teachers of culture/heritage, loss of spirituality, loss of language, loss of culture, traditional camps, family structure, and bush survival skills, loss of family homelands and alteration of social values.

Effects on social conditions due to changes in quality of life, urbanization, increased connectivity, rapid social changes, access to technology, increased mobility.

Effects on social conditions due to changes in accessibility, personal finance, career guidance, legal aid, essential workplace and life skills.

Effects on social conditions stemming from smoking, alcohol and drug use, as well as driving under the influence.

Indigenous Peoples' Physical and Cultural Heritage

Effects on cultural heritage and archaeological resources of Indigenous groups.

Mitigation Measures

Mitigation measures related to impacts on Indigenous people, their rights, their social, health, economic and environmental conditions.

Clarity of mitigation measures, including of blasting noise, loss or effects to flora and fauna.


Effects on navigable waters.

Operations, Decommissioning and Abandonment

Clarity on all aspects of the operations phase. Effects from the lack of appropriate de­commissioning, revegetation and reclamation activities.

Project Contribution to Sustainability

The Project's contribution to sustainability, recognizing the interconnectedness and interdependence of human-ecological systems and well-being of present and future generations.

Weight of negative effects versus positive effects of the Project.

Project Expansion

The Project's potential expansion to the Ring of Fire area, noting the baseline studies already being carried out for such a purpose along the corridor north from the Project to the Ring of Fire area.

Effects, and cumulative effects, due to increased industrial traffic, resulting from the road potentially being extended to the Ring of Fire area.

Purpose of and Need for the Project

Linkage between mineral developments, the Project and the Webequie Supply Road Project.

Project scope and its potential use for industrial purposes and expansion to the Ring of Fire area.

Riparian and Wetland Environments

Effects to riparian and wetland environments (which have a high ecological and social value in the Far North), buffer zones, spread of invasive species and disturbance.

Effects of changes to water levels, including decreased bank stability and effects to the muskeg that provide carbon sequestration.

Social Conditions

Effects of vandalism to infrastructure, such as cabins and trap lines, due to increased access to the territory.

Species at Risk, Terrestrial Wildlife and their Habitat

Effects on federally listed species at risk, including wolverine and caribou, as a result of the change and disruption of their habitat, such as changes to home range and movement patterns, sensory disturbance, air quality, increased predation, barriers and migration.

Effects on federally listed species at risk, including wolverine and caribou, as a result of increased human disturbance, increased recreational activities, stress and data collection activities, such as attaching radio collars for monitoring Woodland Caribou.

Structure, Site, Things of Historical, Archaeological, Paleontological or Architectural Significance

Consultation and presentation of impacts on Indigenous peoples' physical and cultural heritage, current use of land for traditional purpose, or any structure, site or thing that is of historical, archaeological, paleontological or architectural significance.

Surface Water Quality and Quantity

Effects from contamination, sedimentation, dust deposition, erosion, petroleum/chemical spills, water quality and quantity, water flows, beavers damming activities, permanent disruption of wetlands hydrology and other adverse effects to surface water quality and waterbeds.

Effects on the Albany River and downstream of the Project.

Topography, Soil and Sediment

Effects of the Project on permafrost.


Effects on native and rare vegetation due to construction activities, use of roadside herbicides, soil disturbances and the introduction of invasive plant species.

Vulnerable Population Groups (GBA+)

Impacts on vulnerable population groups (GBA+) such as women, disable persons, elders and youth as a result of gender-based violence, human trafficking, resulting from the influx of male worker to the communities.

Indigenous groups' access to economic benefits and opportunities and for mitigation measures for long-term youth unemployment.

Identification of the segments of the population that will either benefit or be negatively impacted (directly or indirectly) by the Project, such as information on indigeneity (quality of being Indigenous), religion, education levels, disability or accessibility, etc.

Waste and Wastewater

Effects from pollution, waste, including hazardous waste, and wastewater disposal.

Document Reference Number: 9

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