Inuit Perspectives on Strange Lake Development

To the IAAC, ? 

This comment is provided in response to the proposed Strange Lake Rare Earth Mining Project. In our review of the Initial Project Description.  This comment is a summary of the feedback and insights generated from our team, and during our independent community engagement sessions, and is being submitted on behalf of Temiskaming Native Women’s Support Group and the AnânauKatiget Tumingit Regional Inuit Women’s Association, informed by Inuit people living in the community of Nain Labrador.

The first step in any engagement and consultation must be relationship building. Proponents and the Agency should try to introduce themselves and initiate a dialogue with communities, before launching formal engagements and consultation. This allows community members to express their capacity needs, cultural expectations, and preferred engagement style before being formally engaged with. By assessing the existing strengths and needs of a community, engagement can be done in a way that aligns with community expectations and efforts to support community-level capacity building can occur before seeking project level feedback. Beyond introductions and supporting capacity building, it is important for proponents and the Agency to take strides to learn the historical context of communities, situating themselves to be knowledgeable about the region and the historical displacement that Indigenous Peoples within that region have survived. If communities are expected to review documents and situate themselves on the logistics of a project, the Agency and proponents must similarly spend time reviewing the protocols of each community, reducing the burden to educate from community members and demonstrate a reciprocal desire to collaborate in project development. Acknowledging that each community is autonomous and self-determined. Therefore, efforts to learn the self-governance structure and protocols of each community is essential to build relationships rooted in trust and mutual respect. Only once this learning has happened can a meaningful relationship be formed.  

Gender-Based Analysis (GBA+) is mandated in all impact assessment processes, while we agree that it is essential to include GBA+ considerations when conducting engagements, we advocate for the application of intersectional identity inclusion and culturally relevant applications of GBA+.  Ensuring that all identities are given equal opportunity to engage in impact assessments and participate in land use planning decision making equally requires moving beyond considerations of only gender and sex. By seeking equal representation of intersectional identity holders, projects can ensure that opportunities are reaching everyone and making decisions with more complete community representation. To do this, a specific effort must be made to create inclusive environments and connect with a variety of identities including: gender, sex, sexual orientation, culture, disability, age, ethnicity, race, education, language, age, income levels, and geographic location. Typically, people with multiple marginalized identity features are left behind or excluded from such engagements. These same populations are those most affected by project impacts, and therefore, must be prioritized in project engagements. Decisions must be made with the most vulnerable populations in mind.  

In our report titled, “Shared Responsibilities: An Indigenous-lens GBA+ Framework” we have generated a framework for more meaningful and inclusive consultation processes. We suggest reviewing the questions to consider and recommendations within this framework to inform the methods applied throughout Strange Lake Rare Earth Mining Project consultations and engagement. In our research, we found that some of the major barriers preventing Indigenous women and other marginalized identities from getting involved in impact assessments include: a lack of in- person engagements, lack of childcare made available at engagements, lack of time to review long technical documents, and a lack of Indigenous knowledge representation throughout engagements. We suggest addressing and mitigating these barriers, to the greatest degree possible, to achieve more meaningful processes overall.  

We suggest providing childcare or welcoming children to accompany parents at in-person engagements, allowing communities to co-facilitate meetings, allowing cultural practices and equal representation of Indigenous knowledge systems to occur, which could create feelings of belonging and trust. We suggest using the knowledge that has been shared in previous consultations to be used as a baseline, rather than expecting communities to share the same knowledge for every project, allowing them to refer to previous contributions would reduce engagement fatigue and leave community members with more capacity to share new and relevant information. When notifying communities about upcoming opportunities, we recommend using a variety of methods going beyond the use of impact assessment registry announcements, additionally using community-led channels such as, radio announcements, in-community bulletin postings, social media announcements, and relaying invitations to Band councils, regional organizations, and community groups. These announcements should provide significant notice prior to engagements occurring, we recommend at least a month in advance. Additionally, providing engagement sessions consistently, with in person and online attendance options, allows more people to be able to attend and participate. Ensuring that engagement sessions are available with at least 2 weeks in between sessions is essential to ensure that fly-in-fly-out workers or their families can be present. 

 Extending review and comment periods to allow communities time to review documents, come together, and reach a decision would promote more productive meetings. Documents posted on the Impact Assessment Registry are typically lengthy and cumbersome for community members to review prior to engagements. Most of the information presented in reports are highly technical and academic. We suggest developing baseline reports, which outline the standardized procedure and processes, and then creating a project specific summary document which presents only new information or considerations that are unique to this project. This strategy would prevent communities from having to review, and re-review long documents for each project. This also makes it more clear to community members how their input is being considered and applied, building trust in the impact assessment system. A significant concern raised repeatedly during consultations with community members of Nain and Upper Lake Melville pertained to the char population and the potential for contamination in the Ikadlivik Brook. This brook serves as a crucial source of livelihood and food for many community members. Community members are also concerns about the potential hazards associated with having a road across Labrador. These apprehensions encompass the risk of spills, the threat of forest fires triggered by activities such as smoking, and the potential dangers of transporting radioactive materials.

The roadway intersects with a caribou migration path. Residents of the community have observed a significant decrease in the caribou population over the past few decades, a decline they attribute to the development of the Voisey's Bay mine.  Despite community members refraining from hunting caribou to support population growth, it appears that both governments and major development entities are indifferent to the declining numbers. This is evident in their plans to construct a road through the caribou migration path.

We discuss reconciliation, an integral aspect of which is self-determination. Despite feedback from the community indicating that the majority opposes the construction of a road from Strange Lake to Edward's Cove, various governments are contemplating this project. This goes against the essence of true progress in assisting the most vulnerable individuals in our Indigenous communities.

?Thank you for considering our comments in the Impact Assessment Process.??We look forward to an equitable, sustainable, and just future for all Canadians now and for future generations.???If you have any further questions or concerns, please contact one of our offices, or Alexandra Bridges the Project Lead for the Empowered Voices Project by emailing a.bridges@keepersoftheircle.com (mailto:a.bridges@keepersoftheircle.com) to engage in direct discussion. We value collaboration and transparency as we aim to work together to mobilize for a just, equitable, and sustainable future.????? 

Thank you | Nakkumek