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Webequie Supply Road Project P Webequie Supply Road Project – Agency responses to comments received until December 19, 2019 Commenter Comment Summary Response to Comment Accidents and Malfunctions Environment and Climate Change Commented about potential for accidents, including spills Section 23 of the Tailored Impact Statement Guidelines Canada, Health Canada, Webequie of hazardous substances. will require the proponent to assess the potential for First Nation malfunctions and accidental spills, including effects to water quality. Acoustic Environment Weenusk First Nation, Health Canada Commented on the potential impact of increased noise Section 16 of the Tailored Impact Statement Guidelines levels including from blasting, machinery use and require the proponent to assess the effects of noise on increased vehicle and air traffic. human health. Section 15.3 of the Tailored Impact Statement Guidelines require the proponent to assess the effects of the Project on wildlife, including noise. Atmospheric Environment Environment and Climate Change Commented that there may be impacts to air quality as a The Agency notes that Section 14.1 of the Tailored Canada, Health Canada result of use of diesel generators, construction equipment, Impact Statement Guidelines requires the proponent to an increase in road traffic, dust, and decreased natural examine potential effects to air quality, including from cover. emissions from diesel generators, emissions from increased vehicle traffic and dust generated by exposed soils that are cleared and stockpiled. Alternative Means of Carrying out the Project Neskantaga First Nation Commented on the lack of clarity on the criteria used to Section 4.3 of the Tailored Impact Statement assess potential road routes, including consideration of Guidelines require the proponent to examine and proposals from Noront Resources and Marten Falls First describe feasible alternatives to the Project. Nation. Section 4.4 of the Tailored Impact Statement Guidelines requires the proponent to examine potential alternative means to carry out the Project. Birds, Migratory Birds and their Habitat Environment and Climate Change Commented that the Project may have impacts to Section 8.10 of the Tailored Impact Statement Canada, Mushkegowuk Council, migratory birds and their habitat, including potential Guidelines require the proponent to study the baseline Wildlife Conservation Society of mortality, as a result of habitat loss, sensory disturbance, conditions for birds, migratory birds and their habitat. Canada, Eabametoong First Nation, disruptions to breeding, and changes to air quality. Attawapiskat First Nation, Osgoode Section 15.2 of the Tailored Impact Statement Hall Law School’s Environmental Guidelines requires the proponent to assess the Justice and Sustainability Clinic Project's adverse effects on birds, migratory birds and their habitat. Climate Change and Greenhouse Gas Emissions Mushkegowuk Council, Wildlife Commented on potential impacts of greenhouse gas Section 15.5 of the Tailored Impact Statement Conservation Society of Canada, emissions from the Project, including impacts on carbon Guidelines require the proponent to assess effects on Osgoode Hall Law School’s stored in peatlands in the region, and as a cumulative climate change, including the effects arising from Webequie Supply Road Project – Agency responses to comments received until December 19, 2019 Page 1 of 18 Environmental Justice and effect in the context of future development in the Ring of increased greenhouse gases emissions and the Sustainability Clinic Fire area. removal and alteration of wetlands. Environment and Climate Change Commented that climate change, including the emissions Section 24 of the Tailored Impact Statement Guidelines Canada of greenhouse gases and the Government of Canada's requires the proponent describe the effects of the ability to meet its environmental obligations, need to be Project in the context of environmental obligations and considered in the impact assessment. commitments in respect of climate change, with a focus on Government of Canada obligations and commitments. The Agency notes that Section 22 of the Tailored Impact Statement Guidelines require the proponent to carry out a cumulative effects assessment. Past and reasonably foreseeable developments in the Ring of Fire area, including additional roads and mining related activities, will need to be included in the assessment. Country Foods Health Canada, Weenusk First Nation Concerned about impacts on quality and quantity of The Agency notes that Sections 8 and 12.2 of the country foods, such as, fish, wildlife (including caribou), Tailored Impact Statement Guidelines require that the and plants for medicinal and traditional practices. proponent study baseline conditions of the quality and Concerned about increased access to traditional territory. quantity of country foods. Section 16 of the Tailored Impact Statement Guidelines require the proponent to assess potential contamination of country foods. Section 19.1 of the Tailored Impact Statement Guidelines require the proponent to assess potential adverse and positive effects to the current use of land and resources for traditional purposes, physical and cultural heritage, and environmental, health, social and economic conditions of Indigenous peoples. Cumulative Effects Mushkegowuk Council, Environment Commented that cumulative effects will need to be Section 22 of the Tailored Impact Statement Guidelines and Climate Change Canada, Wildlife assessed to adequately understand potential increase in require the proponent to carry out a cumulative effects Conservation Society of Canada, mineral exploration and development activities as well as assessment. Past and reasonably foreseeable Innovation, Science and Economic future road development in the Ring of Fire area. developments in the Ring of Fire area, such as Development Canada represented by additional roads and mining related activities, will need the Federal Economic Development to be included in the assessment. Initiative for Northern Ontario, Ontario Ministry of Natural Resources and Forestry, Natural Resources Canada, Health Canada, Aroland First Nation, Eabametoong First Nation, Kasabonika Lake First Nation, Nibinamik First Webequie Supply Road Project – Agency responses to comments received until December 19, 2019 Page 2 of 18 Nation, Attawapiskat First Nation, Neskantaga First Nation, Weenusk First Nation, Webequie First Nation, Marten Falls First Nation, Osgoode Hall Law School’s Environmental Justice and Sustainability Clinic Drinking Water Health Canada, Webequie First Nation Expressed concern that the Project may negatively The Agency notes that Section 14.2 of the Tailored impact the availability of safe drinking water. Impact Statement Guidelines require the proponent to assess any changes to groundwater and surface water. Section 16 of the Tailored Impact Statement Guidelines require the proponent to assess the effects to human health, including contamination of drinking water. Section 25 of the Tailored Impact Statement Guidelines require the proponent to assess the Project’s contribution to sustainability, including long-term effects. Economic Effects Employment and Social Development The potential for economic benefits and employment Section 11 of the Tailored Impact Statement Guidelines Canada, Women and Gender Equality opportunities associated with the Project and future require the proponent to provide baseline information Canada, Wildlife Conservation Society developments in the Ring of Fire area. on the economic conditions of potentially impacted of Canada, Nine Individual members of communities for diverse subgroups within the the public, Noront Resources community. Employment and Social Development Commented that community profiles should be provided to Canada understand current economic conditions in the region. Section 18 of the Tailored Impact Statement Guidelines require the proponent to describe both positive and negative economic effects of the Project. Ontario Ministry of Energy, Northern Identified 56 active, unpatented mining claims and one The Agency notes this comment. Section 10 of the Development and Mines mining Tailored Impact Statement Guidelines require the proponent to describe the access, ownership and use of resources (e.g. land tenures, minerals, etc.) for the project area. Effects of the Environment on the Project Environment and Climate Change Commented about the effects of the environment on the Section 23.2 of the Tailored Impact Statement Canada Project (such as extreme weather events and increased Guidelines requires the proponent to describe the precipitation due to climate change), which have not been effects of the environment on the Project, including how characterized or evaluated for the Project at all phases. climate change impacts have been incorporated into the project design and planning over the lifetime of the Project. Webequie Supply Road Project – Agency responses to comments received until December 19, 2019 Page 3 of 18 Fish and Fish Habitat Wildlife Conservation Society of Expressed concern about fish and fish habitat resulting Section 8.9 of the Tailored Impact Statement Canada, Environment and Climate from construction and operations, including impacts to Guidelines require the proponent to study the baseline Change Canada, Fisheries and Oceans water quality, stream morphology, change to spawning conditions to fish and fish habitat. Section 15.1 of the Canada, , Mushkegowuk Council, habitat, alterations in
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