strange lake group comment submission

STRANGE LAKE GROUP COMMENT SUBMISSION

Attention to: 

The Nunatsiavut Government

Torngat Metals

Government of Newfoundland and Labrador

To whom it may concern:

We are a group of concerned Indigenous women from Nunatsiavut communities who will be impacted by the Strange Lake project. We are writing to you to voice a number of concerns and gaps that we have identified while reading the Strange Lake Rare Earth Mining Project Summary. Our concerns are related to: 

1. Impact of the road on Labrador Inuit/Innu and wildlife and land
2. Impact of the overall project in Indigenous peoples culture, food security and cultural heritage
3. Impact of the project on marine mammals and endangered species
4. Gaps in studies available and cumulative effects of the project

Concerns related to the road construction:

We are concerned that constructing a 125 Km access road through northern Labrador will change the landscape forever. It may cause environmental damage to permafrost, destroy habitat for caribou and other wildlife and the environment, including birds, and plant life. A road will change the land that could be burial sites, or contain valuable artifacts.

As outlined in the summary on page 62: 

“The lowland valleys of Ikadlivik Brook and Reid Brook belong to the Fraser River land region. Nearly three-quarters of this region are forested communities by coniferous moss forest (63%) wetlands form an important part of the landscape in the first 95 km road alignment section from the mine”. 

There is potential for impacts on water sources; that may see a deterioration in water quality. The proposed road will include 3 major water crossings in Labrador, which in essence will impact wildlife and Inuit land use. 

Pg 58 says:

“Approximately 80% of the mines’ site are drains towards lake Brisson, which waters, after flowing through lake Napea Kainiut, discharges into the Deat river watershed and ultimately leads to the george river (approximately 100km downstream).”

There is presently infrastructure in Quebec, I.e. the railway to Schefferville that is a much shorter distance than the proposed road to Anaktalak Bay in Labrador which does not clearly outline why it is not an option for transporting ore.

Concerns about the Impact of the overall project in Indigenous peoples culture, food security and cultural heritage:

Throughout the summary document significant attention was given to the potential impact of the road and mining site on the George River Caribou herd migration and calving grounds. This herd is important because although it is not an endangered species technically, on page 83 it says:

[the] “Herd is in a precarious situation following a drastic decline in the population.” the potential  cumulative impacts on the herd could expedite population decline. 

This caribou herd offers a great cultural significance as it allows for the passing down of knowledge related to traditional land use, hunting practices, allows for cultural continuity and contributes to food security in our region. This is important to note because food security rates in Inuit Nunangat are the highest in the country. Access to country food like Caribou helps to offset food insecurity.  Threatening the health of this herd threatens the cultural survival of Inuit and Innu from multiple jurisdictions.  

Impact of the project on marine mammals and endangered species:

The project does not clearly provide information or research related to the potential impact of increased marine traffic on marine mammals and the marine environment. With increased shipping comes increased acoustic noise, traffic, and vulnerability to vessel strikes as well as impact to sea ice formation and integrity which is critical to the health of certain marine mammals. These marine mammals such as beluga, and other whales, seals, polar bears, black ducks, eider ducks. These species are important food sources for Inuit and Innu from multiple land claims areas. 

Further impacts of sea ice disruption may negatively impact Indigenous hunters and travel routes because routes that are already vulnerable to climate change (rapidly changing and disappearing) may face further calamity as ice is being dislodged more frequently. Changing travel routes can have a detrimental impact as it disrupts the ability to pass on traditional knowledge related to where to go and family land use history. 

Gaps in studies available and cumulative effects of the project

Lastly we noted that there are gaps in information and studies available related to the potential impacts of the road, project area and processing site. These gaps specifically relate to the impact of noise on wildlife, impact of increased exposure to light on wildlife and flora/fauna health. 

Additionally on page 73 it was mentioned, “no study on quality of life and psychosocial impacts had been conducted as part of the Quest Rare Minerals Project.”

It is also noted that the studies mentioned in the summary are dated from 2011/2012, given climate change and the change in population size of the caribou herd a need for current data and studies would give a true picture of today's reality.  

Additionally, related to climate change and increased forest fires/dryer conditions, the summary report does not include forest fire mitigation. This is a concern as well because the cumulative effects of the project include decreasing water sources in and around the road and project sites which will contribute to drying conditions potentially leading to forest fires. 

In conclusion, we the Indigenous women of northern Labrador are concerned that the cumulative impacts of the road and project scope leave many unanswered questions. A project of this magnitude can have many overarching impacts on the people, animals, lands and waters that must be fully explored before any ground is broken given the sensitive nature of the areas to be exploited.