Indigenous Women, Girls and Gender Diverse Peoples Representation

Reference Number

Northern Road Link Project #84331 

To whom it may concern,  

We would like to submit our comments about the Northern Road Link Projects Initial Project Description in the hopes that the Gender Based Analysis+ planned parameters can apply an intersectional analysis that encompasses intersectional identity experiences. This would create more meaningful engagement with both on, and off reserve band membership, Indigenous women, girls, and gender diverse people who are likely to be impacted by this project. We believe in the equitable inclusion of all identities in resource development projects. There are known impacts and barriers that accompany resource extractive industry which are experienced in greater intensity by vulnerable or marginalized identity groups. The inclusion of Indigenous women and gender diverse people priorities from project planning outset is highly needed to combat structural violence impacting marginalized groups. It is highly important to consider existing reports and findings that indicate the correlation between extractive industry and increased risks of violence, human trafficking, and the socio-economic marginalization of Indigenous women, girls, and gender diverse persons. We would like to submit the following comments on the IPD for the Northern Road Link Project. 

Consultation & Engagement  

In the summary of consultation and engagement activities to date (Table 3-1), it was noticed that only 2 of the 42 activities were delivered in an in-person method. We appreciate the variety of methods used to communicated meetings and review opportunities for the Terms of Reference. While we commend the wide variety of techniques that were used, we want to stress that one open house, in one location is insufficient to satisfy in-person engagement requests of the community. In person engagement should take place at multiple locations, on multiple dates, in each of the surrounding communities that will be directly affected by the project. The hosting of open houses is a good strategy to ensure the inclusion of Urban Indigenous membership. However, though the early engagement was wide open and well-advertised there were only two opportunities to attend an open house, and this might prove to be a barrier to people who have work obligations or are otherwise unavailable to attend. Future phases of the impact assessment should specifically ensure to lead more in-person engagement. There is no mention of in-person engagement being prioritized or planned in the ‘3.3 Plan for Future Consultation and Engagement’ section. 

In section 4.0 Consultation and Engagement with Indigenous Communities and Groups, there are several communities listed, some with asterix (*), it remains unclear what the asterix represents. It is unclear which of these communities have been engaged with, or if they have simply been identified for engagement. There should be specific statistics about the number of people that were engaged with from each community. Additional reporting on the intersectional identities and GBA+ factors that were included in engagement consideration are needed. We appreciate there are additional consultation parameters from NFFN elders and WFN’s three-tiered approach to community engagement. This demonstrated there is consideration of how project planning may include Indigenous priorities from the outset.  

 Again, in the summary of consultation and engagement activities to date (Table 4-1), only 2 of the 53 activities were delivered in an in-person method. We wish to echo our previous comment that in-person engagement is required at multiple locations, in each of the surrounding communities that will be directly affected by the project. In Table 5-1 Communication and Engagement Tools it was noticed that public open houses are the only in person format. At these sessions, introductory materials are presented to the public however, only limited time is allocated for communities to present their input, beyond asking questions in a Q&A format. Beyond this, the open houses are livestreamed, which disables community members from presenting information in a private way or ask questions about sensitive content. For meaningful, two-way engagement, similar public open houses need to be organized where communities can present, sharing their insights, personal anecdotes, traditional knowledge, in a way that ensures confidential information is kept confidential. Without allowing communities the same opportunity to teach, bring forwards information, and lead engagement, these open houses remain insufficient.  

In addition to open houses where public information sessions are held, we suggest the addition of targeted focus groups that aim to acquire information and feedback from specific demographic ranges of people. One key point is to have Indigenous women, girls and gender diverse persons specific workshops and feedback sessions. This would serve to give space and place for gender specific feedback to be explored and discussed and assist in satisfying GBA+ data collection requirements by the agency. 

In section 5.1 Purpose, it is stated “The purpose of consultation and engagement is to promote effective two-way communication between the proponent and members of potentially affected Indigenous communities, Indigenous organizations, provincial agencies and federal authorities, the public and other stakeholders…” (pg. 34). However, at almost every engagement meeting we have attended, presentations led by the Agency or proponents go on for most of the engagement session, leaving only a brief question period at the end for community members and the public to bring their concerns forwards, ask questions, and engage in dialogue. This is an insufficient method to conduct true two-way communication. The Agency should not be the only stakeholder able to call or lead an engagement session. Allowing communities to lead information sessions where they share their knowledge, presenting to governments and proponents, would represent two-way communication.  

Guiding Principles  

We approve of the list of guiding principles used in engagement; meaningful, transparent, inclusive, accessible, flexible, and collaborative. To build inclusive and accessible systems, there should also be attention paid to the formatting and design of presentation materials that are visually appealing and access a range of learning styles, making sure there are refreshments and snacks available at meetings for people with health issues. We also advocate that there be childcare available on-site for people who have children and want to attend the meeting. There are significantly advanced values and principles and consultation practices within this Initial Project Description that go beyond other proponent projects standards and should be considered an example of braiding knowledge systems in a respectful way from project registration.  

 We suggest adding self-determined, and consensual to the list of guiding principles. Self-determined meaning that communities are given the freedom to determine their contributions and decisions by oneself/themselves, independently from outside influence or coercion. Allowing Nations to, not only participate in the process, but to determine their own future political status, this is aligned with the principles of UNDRIP, a Declaration which the Government of Canada has committed to upholding.  Consensual should also be added, it is one thing to consult the communities and seek their input, it is another to allow them to veto a project entirely or to withhold consent. Without the ability to say no or give full and informed feedback, these consultations are performative and represent a one-way engagement where opinions of the public and Indigenous communities are heard, but not given weight in decision making.  

In the entire 175 page document, we did not find a single mention of concepts like:  

  • UNDRIP or the Declaration (the United Nations Declaration on the Rights of Indigenous Peoples) which the Government of Canada has committed to upholding  

  • Consent, or FPIC (free, prior, and informed consent) and the federal obligation to seek the free, prior, and informed consent of communities  

  • OCAP (ownership, control, access, and possession) essential to giving communities confidentiality and control over the information and knowledge they are sharing  

  • And there was only one mention of the duty to consult  

For meaningful, two-way engagement to occur, and for Indigenous peoples to rebuild their trust in a system that has historically marginalized and excluded them, it is essential that these rights and principles are upheld consistently. Without the clear statement of these principles, many Indigenous people may reframe from participating due to concerns of how the information will be used, reworded, or misrepresented.  

While the Ring if Fire remains a significant driver for the Northern Road Link Project, there remains no mention of the opposition to the project by other nations outside of Webequie and Marten Falls. How does the proponent plan to address the concerns about impacts to traditional ways of doing experienced by other nations who do not welcome development? The Ring if Fire development has been heavily scrutinized as having the potential to cause immense GHG emissions and permanently alter the boreal shield of Northern Ontario.  

Data Collection  

Though the plans for baseline data collection are widely incorporating all studies into data collection applications, there is no mention of directly impacted Indigenous people’s participation in the studies being undertaken, the methodologies utilized to ensure adequate data is reciprocally shared to communities. There are opportunities to provide input into studies that will be conducted on communities behalf, and no mention of how community members will guide or execute portions of research or conduct consultation activities that would increase access to information and reciprocal feedback. There also remains significant questions about how information will be collected about valued components from community members. The practices employed about general data collection remain unclear.  

If the project were to move forwards, there is extensive tree/vegetation clearing that must be done to prepare the site for construction. What would plans be to repurpose these materials? How will these plants, trees, medicines be respected? Will these plant medicines be available in other regions? How will the interruption to the forest change, creating an edge effect, introducing new disturbances, and interrupting migration channels? At this time, there are no actions related to conservation, building migration corridors, or repurposing cleared materials within the Summary of Project Activities (Table 10-2). There is no mention of wildlife crossing sections in the planning of the road, while watercourse cross over is projected to be minimized as much as possible there is no mention of how wildlife impacts will be mitigated into infrastructure planning. In the “Construction Phase & Operations Phase” again makes multiple mentions of water crossings but no mention of wildlife corridors, or the building of overpasses to allow for caribou, herd animals, large mammals to cross under the highway safely. The boreal shield is a safe haven for a wide range of species and there is no consideration of wildlife safety in this IDP thus far. This is contrasted against plans to essentially remove animal carcasses resulting from vehicle collisions on the road, and no mention of preventative measures in the planning. Culverts for waterbody crossings alone are insufficient, migration channels for mammals and large game animals are essential to prevent roadkill and unnecessary loss of life. There is only a brief mention of ‘installation of mitigation measures’ with no elaboration on what those mitigation measures will be, and the extent that they are anticipated to mitigate various affects. There is a clear trend towards mitigation and conservation measures are loosely outlined and ill-defined, while the processes of environmental degradation and the extent of harm are well-known and well-defined. Attention must be turned to make conservation strategies as robust as the project implantation plans.  

According to table 15-3, there are 22 species at risk potentially present in the vicinity of the project. These 22 species must be presented back to communities and the public in engagement sessions, outlining that they are vulnerable to impacts from the project and inviting feedback on any cultural uses of these animals and their potential significance to traditional knowledge. It is also important to consider if any of these species are keystone species, and their loss would have a significant impact on the overall ecosystem function. It should also be considered the global state of conservation, endangered species must be prioritized in protection. Of these, the Little Brown Myotis, Northern Myotis, and the Tri-colored bat are listed as endangered. Will more recent population surveys be done than the ones cited from 2017? Over 5 years have passed since the previous environmental inventory was collected, leaving much room for shifts in ecosystem dynamics to have unfolded. 

In section 16.2 socio-economic context, the community services and infrastructure are outlined, stating that these will be provided by coordinated local and regional supports. It remains unclear who is responsible to build, lead, and fund support systems; the community? Proponents? The government? This section discussed the necessary considerations of healthcare, policing, and housing. We seek additional considerations for education, childcare, and gender-based support systems (women’s centers, shelters, health, and support services). In the community safety section, it is clearly outlined that Indigenous women are more likely to experience violence, while being less likely to benefit from employment opportunities. There remain for consideration the significant impacts to Indigenous women, girls, and gender diverse peoples that are distinct and may be acutely exacerbated by industrial developments in close proximity to communities. We would like to add that not only are Indigenous women are less likely to uptake economic benefits from resource development projects, but they are also likely to be employed in traditionally softer or ‘feminine’ roles such as housekeeping, cooking or other domestic duties in developments. They also experience heightened risk of harassment, difficulty in providing quality childcare because of work rotation schedules that create less availability at home. It is imperative to include these lived experiences and plan to mitigate the barriers that marginalized identities experience during engagement, project implementation, and beyond.  

In table 16-1, community profiles of indigenous communities potentially affected by or interested in the project, by adding all the membership estimates from each community, we found that approximately 38,571 people are members to a community that will be potentially affected by this project. How many of these 38,000 people will be engaged in the impact assessment? How will people from various identities be included in engagement?  

Alternative Options 

In section 13.2 “Alternatives to” the project, it is stated that, “If the “do nothing” alternative is selected, the Ring of Fire mineral deposits in the McFaulds Lake area may remain undeveloped and there would be a loss of potential social and economic benefits to MFFN and WFN, as well as to other Indigenous communities and other levels of government”. Although this statement is true, it is also important to consider the inverse perspective that if the ‘do nothing’ alternative is selected, both communities will not experience the negative social, environmental, health, and economic impacts that are associated to resource development projects. We know that communities close to large scale development projects are often left with a degraded environment and poor water and air quality. We know that women, especially Indigenous women, are the demographic least likely to be able to access potential benefits of projects, and most impacted by negative impacts. How would this project ensure that the economic and social benefits brought to MFFN and WFN are evenly distributed between youth, Elders, women, two-spirit people, and other marginalized identities? Will these potential social and economic benefits be worth the cost of the certain environmental, health, social, and economic negatives that will result from the project? 

The statement, “Due to the remote location of the Project, the surrounding environment is considered to be a pristine setting.” (pg.79) was of particular interest to us. Would the same statement hold true, in that the environment is considered to be pristine, after project development has occurred? Or will this project degrade what is now considered pristine air quality?  

Thank you for your consideration of our comments. We look forwards to reviewing future project documents and seeing how the Impact Assessment Agency of Canada addresses these concerns about the Initial Project Description for the Northern Road Link Project.

Thank you | Miigwetch?? 

Invitation to Voices Project Team? 

Submitted by
Temiskaming Native Women's Support Group
Public Notice
Public Notice - Public Comments Invited on a Summary of the Initial Project Description
Date Submitted
2023-03-23 - 8:34 AM
Date modified: