From Ginoogaming First Nation to the Impact Assessment Agency of Canada re: Comments on the Webequie Supply Road Project Assessment and Time Limit Extension Request

Hi Caitlin,

I am writing in response to the IAAC’s letter and email dated October 25, 2022, regarding the Time Limit Extension Request for the Federal Impact Assessment (IA) Process of the Webequie Supply Road (WSR) Project.

GFN is in support of WSR’s request for a timeline extension (to January 2027) to complete their IA, and understands the challenges and limitations placed on the IA to-date due to the global pandemic.

GFN also continues to experience ongoing challenges surrounding participation in this IA, due to the absence of Proponent and Provincial funding to support needed consultation, engagement and technical support.

GFN would like to better understand the WSR team’s plans for in-person engagement throughout the project, now that pandemic restrictions have eased. 22 Indigenous communities are listed as requiring engagement, however GFN knows that a ‘lesser level’ of consultation effort is being applied to communities perceived to be further from the impacts of the project. GFN would like to see efforts made to bring together all Indigenous communities engaged on this project for a collective discussion and knowledge sharing session.

Regarding the technical content of this document, it is far too complex for effective community-level conversations. Documents need to be made more approachable by being paired down or by providing summaries to clearly convey key messages. A thorough review of this document respective of GFN’s community communication processes was not possible. For future engagement, GFN is very interested in understanding the project’s impacts to the peatlands specific to the carbon storage services that will be lost once the land is impacted by development.

Regarding the technical studies completed to-date, they appear to have been very limited in-scale, with the Regional Study Area (RSA) restricted to a buffer around the proposed road. The RSA would be more appropriately sized at the watershed scale, since all of the waters surrounding the project will be affected by the road’s construction (impacting flows in the region, animal pathways, etc.).

GFN would also like to see the project take into consideration the full cumulative effects of impacts to the region as this road contributes to the opening of the Ring of Fire area for mineral development, forever changing the face of the north. The road cannot be discussed in isolation of the larger development looming on the horizon, since its very construction will increase the feasibility of mineral development in the area. It is not ‘just a road’ as the Proponent has insisted; indeed this proposal would not even exist in the absence of mineral development interests in the Ring of Fire.

GFN welcomes continued engagement by the WSR team and the IAAC throughout this IA process.

We look forward to hearing from you.

Kind Regards,

Denan