Agreement with Extension Request + Recommendations

To the Impact Assessment Agency of Canada,
Subject: Marten Falls First Nation All Season Community Access Road

December 6^th, 2022
 

Keepers of the Circle is operated by the Temiskaming Native Women’s Support Group, an Indigenous Family Learning Center in Kirkland Lake and Temiskaming Shores. Our mandate is to maintain quality programing for Indigenous children, women, and families through implementing various projects such as, employment training, healthcare, childcare and more. Our organization works closely with our partner the AnanauKatiget Tumingit Regional Inuit Women's Association (ATRIWA) to raise capacity for Indigenous women, girls and gender diverse persons in Northern Labrador as well as in Northern Ontario to participate in Impact Assessments.

While Indigenous Peoples are frequently regarded as key partners in project assessments, Indigenous women’s concerns and aspirations regarding industrial projects have historically been marginalized, as have the opportunities and benefits from such developments. Indigenous women, girls and gender diverse persons are frequently made invisible in impact assessment processes and their systematic exclusion has contributed to the significantly higher rate of gendered violence, poverty, and homelessness experienced. These trends are explained further in national publications such as the Final Report of the National Inquiry into Missing and Murdered Indigenous Women and Girls.  Our project aims to help remediate intergenerational impacts of colonization that contribute to systems that have oppressed and marginalized Indigenous women from decision-making processes that affect their wellbeing and economic security. Our organizations explicitly requests that steps are being taken to ensure that Indigenous women, girls, and gender diverse people are being included in decision making for this project and that their input is being thoroughly considered with tangible, measured mitigation of impacts. 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.

This comment is in response to the request for timeline extension submitted by AECOM, WSP and Dillon. Our team has carefully reviewed the proposal for extension and wish to extend our agreement with the stance that the proponent has taken in this matter. It remains clear that there is insufficient data collection occurring that would represent the interests and priorities of the Indigenous communities impacted by the project development. It remains a crucial piece in land use, cultural practices, and historic and current land use practices. This request for timeline extension reflects the needs of community for further time and consideration of all knowledge holders and key information sessions. The proposed plan for engagement is thoughtfully planned and timed, however we would include recommendations on method of engagement and inclusivity parameters.

The plans to hold a two-day open house for people to attend could be duplicated on a monthly or bi-weekly basis, to ensure that space is held for people who cannot make the open house timeline, there is only one opportunity to get information about impacts to treaty rights. The information is distributed in newsletters and emails which is a conventional and appropriate way to communicate in many spaces, however due the communities being rural remote there remains significant barriers in the dissemination of information using this format alone.

The workshop scheduled in Thunder Bay is a great initiative, there will be multiple (frequency unknown) opportunities to provide information and insights that the proponent will utilize in planning the project impacts. For the sharing of ATRI Assessment Effects and Mitigation Discussion is reserved for communities to ask for a workshop upon request. How will the requests be made? What efforts will there be to ensure that the findings make it to the membership of the impacted communities? Once the parameters have been established through the workshop there will only be an opportunity for community members to review the conclusions of the study, concerns brought forward might not have sufficient time necessary to be fully investigated by the proponent.

For the finalizing of the rights impacts document and Indigenous Knowledge survey there remains significant opportunities to conduct meetings in person in communities that will be impacted. The tendency to focus on virtual meeting spaces limits the ability of non-technology accessing people to attend, and when technology is available internet accessibility is extremely limited and drops frequently in signal strength, leading to poor quality and understanding of what is being said between people in the meeting. Having more in-person engagements with multiple opportunities to attend each session is more effective in ensuring people have the chance to attend.

Beyond the limitations of the ATRI open house and workshops, significant emphasis is placed on interviews with key people about a range of topics for the study on socio economic impacts. Little is described in the section about key interviews that would be conducted in community about health, social economic and land impacts, though this comprises a significant level of activity for quarter one of 2023. In planning these interviews the demographic sampling must be reflective of a range of lived realities and areas of expertise. To achieve thoroughness and rigor in this area of study interviews and workshops must centre and include Elders, Youth and Indigenous women, girls and gender diverse persons. There remains significant historic lapse to account for socio-economic impacts in large development projects and it remains acutely tied to the health, security and safety of the people who are living in and around the project area. Ensuring the demographic sample size accurately reflects the population of the communities that are being studied and includes a range of membership when considering scope and study parameters for project impacts.

Submitted respectfully,
The Invitation to Voices project team