Montana First Nation Comments on the Cando Sturgeon Rail Terminal West Expansion Project Initial Project Description

On behalf of Montana First Nation (MFN), please accept these comments in response to the Initial Project Description for the Cando Sturgeon Rail Terminal West Expansion (the Project).  

As a preface to the comments, due to capacity constraints and a change in staff, MFN was unable to respond or meet with Cando Rail & Terminals Ltd. (the Proponent). MFN intends to reach out to the Proponent for a one-on-one meeting to address any issues that may have arisen from their Initial Project Description review. 

I.    Historical Resources

Regarding historical resources, MFN requests an update from the Proponent once the Alberta Ministry of Arts, Culture and Status of Women evaluation is complete. 

II.    Indigenous Engagement

MFN agrees that a chance finds protocol should be co-developed with identified potentially impacted Nations. 

MFN also agrees that a site visit would be beneficial to review the project. A desktop analysis is insufficient for conducting a proper review. 

In terms of potential opportunities, MFN agrees that interested Indigenous contractors should have the ability to send in proposals or tenders for work that they can conduct. 

Potential social impacts from the Project on Indigenous Peoples need to be evaluated with values co-developed with identified potentially impacted Nations. 

III.    Planning Activities 

MFN requests an update from the Proponent on all listed planning activities. All planning activities listed are essential in the review of the proposed project. 

IV.    Potential Future Infrastructure 

For potential future infrastructure such as storage tanks and mobile transload, MFN recommends that the Proponent ensure there are no leaks or spills of diesel, gasoline, nitrogen, used oil, glycol, or any other potential contaminants. And if a spill or leak does happen, the proper procedures need to be in place for cleanup.  

V.    Water 

Water is a significant concern for MFN on any project and has specific concerns about the impacts to the thirty-two wetlands within the Project footprint. Wetlands are significant ecosystems that support healthy biodiversity and provide essential habitat to many species, including migratory birds. MFN relies on wetlands and riparian areas for culturally significant plants. MFN’s main concern with the impacts to wetlands is that financial compensation to support the replacement of destroyed wetlands as a mitigation measure may not be enough. If this is the direction that the Proponent chooses to go and that the Impact Assessment Agency supports, the replacement wetlands should be monitored, and continuous reporting should be done on the progress of any potentially established wetlands. 
 

Thank you for your consideration of these comments. If you have any questions, please get in touch with the Consultation Manager Kyra Northwest at 780-585-3744 ext, 268 or mfnconsultation.com.