Response to Information Request from Roberts Bank Terminal 2 Project Review Panel at the Public Hearing Session on June 20, 2019 Prepared by Dr. Peter Evans (Trailmark Systems) and submitted on behalf of Pauquachin First Nation

Methods The results analysis presented to the Proponent and to the Panel on June 20, 2019, and expanded on below, drew on several different types of information, including ethnohistorical research and analysis, ethnography, map biography interviews, participatory group mapping, AIS data from the Canadian Coast Guard, GIS analysis, and previous research.

The traditional use information in the W’SANEC Traditional Use Study (CEAR #1670) came from five different studies: the Sencoten Alliance Study (2002); the Parks Canada Study (2013); the TMX Study (2013); and the Places of the W’SANEC Nation Study (Fritz 2016). Three of the four projects were community-based, while one (Fritz 2016) was led by a university graduate researcher. Each used a slightly different methodology. Sencoten Alliance (2002) relied on the Tobias method (Tobias 2000; 2009); the Parks Canada study (2013) an Indigenous research method; the TMX Study a mixed method of qualitative oral history interviews and participatory mapping; and the Places of the W’SANEC Nation study used an ethnohistorical mapping method that relied mostly on texts and participatory engagement.

Variation on the “map biography” method formed the main technique used in three of the four traditional land and marine use studies. This method emerged as the dominant research technique for documenting land use extensity and occupation after the rise in Indigenous land claims in the 1970s. Its popularity is due in part to its centring of GIS as an appeal to scientific objectivity. However, the technique was never intended to create information to aid in impact assessment and evaluation.

Combining datasets from different research projects across methodological differences amplifies the shortcomings inherent in each of the discrete methods, while plastering over the incompatibilities between the methods. None of the studies employed a representative sampling technique, but nor did any attempt to survey more than a handful of knowledge holders.

The results, even though they are represented by GIS -- which quantifies locational data -- are not sufficiently quantitative in terms of their accuracy to draw conclusions or devise mitigations. For the purposes of impact assessment, traditional land use methods count the wrong thing. They purport to represent harvesting areas and species, but they are really only representations of memories from a small group of people. Thus the calculation they allow is not to elements of the biophysical environment or animals and fish, or to needs, but on memories.

Furthermore, the data does not contain within its attributes the information on location, seasonality, timing, purpose, practice, or access that CEAA requested the Proponent to provide as part of its assessment. There is no corresponding data on resource availability and household or community needs between which an assessment could be triangulated. Proponents and the Crown do not supply sufficient resources to Pauquachin to create the data that the Panel would need in order to determine the effects of the Project on its traditional marine use practices and exercise of Aboriginal and Treaty rights. Methods and techniques exist that could create this information, but they would require co-operation between the Proponent and Pauquachin, and resources similar to investments in biophysical research. The Community-based Monitoring Network in Nunavut, for instance, employs a mixed methods approach blending community surveys, oral history, and in-situ gathering of GPS tracks, harvests, and observational field forms to create a rich, detailed, and spatially accurate record of a community’s land and marine use over time (K Letto et al. 2015. See map below.)

Left: GPS tracks of harvesters (blue) and harvest sites (red), 2012 to 2015, Arviat, NU. Source:

https://www.nwmb.com/en/conservation-education/list-all-documents/docs-for-articles/community- based-monitoring-network-pilot-study/reports/6180-2015-arctic-net-presentation-english/file

The Panel is cautioned therefore to think of the information provided by Pauquachin as a visual analysis or representation of a small group of memories from Pauquachin knowledge-holders, and not as locational data describing the current use of lands and resources of Pauquachin. The visualization can help augment, for the Panel, Pauquachin’s concerns about the Project, but Pauquachin asserts that the Panel does not have at its disposal the requisite information on which to base an assessment of the effects of the Project on Pauquachin’s traditional marine use practices and exercise of Aboriginal and Treaty rights.

Places of High Co-Occurrence of Information The following places, which include tracts of water, land, and foreshore, have been identified by multiple sources across different projects undertaken at Pauquachin using qualitative-based interview research methods from 2002 to 2014, and represented on Map 13 of the Appendix A submitted in confidence to the CEAA Panel. From this perspective -- that there is a high co-occurrence of data from interviews and projects -- it is reasonable to assume that these places represent important resource use spaces for Pauquachin.

» James Island, and the waters surrounding it; » , and the waters surrounding it; » Forest Island, and the waters surrounding it; » Waterway between Domville and Brethour Island; » Waterway between Gooch Island and Sidney Island; » Prevost Passage (including Greig island, Reay Island, and Imrie Island); » , especially the south east Point, and the waters surrounding it; » North Pender and South Pender* Islands, and the surrounding waters; » Tumbo Island, and the waters surrounding it; » , and the waters surrounding it; » Active Pass; » Satellite Channel; » ; Uses and Practices associated with these areas include the following:

» James Island, and the waters surrounding it o Ling cod o Rock cod o Sea urchins o Crabs o Deer o Halibut o Habitation site (c,h,t)/Overnight site o Salmon o Upland game birds o Waterfowl o Clams o Cockles o Rabbits o Red snapper o Special story o Hunting area o Burial o Special wood and firewood o Salmon o Herring

» Sidney Island, and the waters surrounding it o Rock cod o Ling cod o Chinook salmon o Deer o Crabs o Clams o Sea urchins o Habitation site (c,h,t)/Overnight site o Berries o Waterfowl o Flounder o Halibut o Burial o Boat anchorage o Medicine gathering - consumption plant o Forest Island* o Rock cod o Ling cod o Chinook salmon o Salmon o Seaweed o chitons/stick shoes o Sea urchins o Habitation site (c,h,t)/Overnight site o Sea gull eggs

» North Pender and South Pender* Islands, and the waters surrounding o Clams o Habitation site (c,h,t)/Overnight site o Salmon o Rock cod o Fishing area o Berries o Special wood o Deer o Seaweed o Herring o Cockles o Boat anchorage o Waterfowl o Bear o Salmon o Longhouse o Upland game birds o Oysters o Reefnets o Material gathering place o Storied place o Hunting area o Ceremonial place o Burial o Gathering place o Sea cucumbers o Crabs o Abalone

» Saturna Island, especially the south east Point, and the waters surrounding it o Ling cod o Rock cod o Clams o Habitation site (c,h,t)/Overnight site o Deer medicine plant o Clams o Waterfowl o Deer o Berries o Special wood o Salmon o Berry/plant drying site o Flounder/sole o Trout o Upland game birds o Storied place o Hunting area o Ceremonial place o Burial o Firewood o Seaweed o Abalone

» Tumbo Island, and surrounding waters o Sea urchins o Oysters o Clams o Special wood o Seaweed o Abalone o Habitation site (c,h,t)/Overnight site o Halibut

» Mayne Island and surrounding waters o Clams o Herring o Habitation site (c,h,t)/Overnight site o Sea urchin o Octopus o Chitons/stick shoes o Herring o Ling cod o Rock cod o Gathering place o Salmon o Red snapper o Deer o Herring o Medicine plants o Seaweed o Spirit site o Berries o Seal o bathing/cleansing site o Special wood o Sockeye salmon o Burial o Herring o Sacred area o Crabs o Cutthroat trout o Salmon o Upland game birds o Waterfowl o Abalone o Chum salmon o Cockles o Sea cucumbers o Oysters o Sea urchins o Reefnets o Material gathering o Marine food gathering o Firewood o Sacred area o bathing/cleansing site

» Active Pass o Ling cod o Rock cod o Salmon o Sea urchins o Clams o Chitons o Red snapper o Herring o Spirit site o Seal o Bathing/cleansing site o Sockeye salmon o Trout o Waterfowl o Reefnets o Travel route o Sacred area o Satellite Channel* o Travel route o Octopus o Chinook salmon o Ling cod o Rock cod o Bathing/cleansing site o Clams o Cockles o Deer o Salmon o Sea urchin o Red snapper o Storied place

» Saanich Inlet o Salmon o Habion site (c,h,t)/Overnight site o Travel route o Seaweed o Clams o Chinook salmon o Octopus o Oysters o Ling cod o Rock cod o Red snapper o Prawn o Longhouse o Crabs o Waterfowl o Flounder o Herring eggs o Herring o Seal o Cockles o Abalone o Berries o Burial o Ceremonial places o Deer o Gathering place o Geoducks o Hunting area o Material gathering place o Medicine gathering place/medicine plant o Mussels o Sacred area o Sea cucumbers o Storied place o Terrestrial food gathering

» Waterway between Domville and Brethour Island o Salmon o Ling cod o Rock cod o Red snapper

» Waterway between Gooch Island and Sidney Island o Travel route o Ling cod o Red snapper o Rock cod o Waterfowl o Halibut

» Prevost Passage (including Greig island, Reay Island, and Imrie Island) o Seaweed o Ling cod o Red snapper o Rock cod o Waterfowl o Oysters o Halibut o Travel route Travel Routes Pauquachin harvesters have identified travel routes throughout waters around southern including:

» Active pass » East of Mayne and Saturna » Boundary Pass » Around South » Trincomali Passage » Captain Passage » Swanson Channel » Moresby Passage » Satellite Channel » Shute PAssage » Stranger PAssage » Colburne Passage » Prevost Passage » Sidney Channel » Miners Channel » Cordova Channel » Hughes Passage » » Saanich Inlet » Cowichan Bay » Fulford Harbour Information on Other Areas Information also, but to a lesser degree, co-occurs for the following areas across individuals and projects. There is a high likelihood that these areas are used by Pauquachin harvesters.

» Discovery Island and surrounding islands » Maynard Cove » D’Arcy and Little D’Arcy Islands » Halibut Island » Henry Island » Pearl Island » San Juan Island » Flattop Island » John’s Island » Mandarte Island » Moresby Passage (waterway between Portland Island and Moresby Island) » Portland Island » Boundary Pass » Sucia Island and surrounding islands » Matia Island » Orcas Island » » » Porlier Pass » Waters on the East side of » Pylades Channel » Trincomali Passage » Houston Passage and Waters East of Thetis and » Clam Bay and Telegraph Harbour » » Saltspring Island (including Ganges, Fulford and Long Harbours) » Waters around North East tip of (including Swartz Bay, Blue Heron Basin, Page Passage, Iroquios Passage, Coal Island, Coalburne Passage, Pym Island, Stranger Passage, Knapp Island, Gosse Passage and )* » Boundary Bay » Roberts Bank » Sturgeon Bank » Nanaimo Harbour » Stuart Channel » Sansum Narrows » Cowichan Bay

Co-Occurrence of High Vessel Traffic and Traditional Marine Use Information The following analysis is based on maps 13, 16, 17, 18, and 19 of the Confidential Appendix A provided to the CEAA Panel.

Co-occurrence of the highest volume vessel traffic (2017 data) and data for traditional marine use occurs at a number of places. Locations where the greatest co-occurrence include the following:

» Active Pass; » Between , Moresby Island and the North end of the Saanich Peninsula; » Along the south coast of Saturna Island and South Pender Island;

Species and practices at areas where high vessel traffic data and information on traditional marine use are contiguous with one another include the following:

» D’Arcy and Little D’Arcy Islands o Salmon o Halibut o Rock Cod o Abalone o Sea Urchins o Seaweed o Special Wood o Firewood o Waterfowl o Deer o Seals and Porpoises o Travel Routes

» Sidney Island o Salmon o Halibut o Rock Cod o Ling Cod o Clams o Seaweed o Waterfowl o Deer o Burial Sites o Habitation Sites o Travel Routes

» Forrest Island o Sea Urchins o Seaweed o Seagull Eggs o Habitation Site

» Gooch and Rum Islands o Rock Cod o Ling Cod o Abalone o Habitation Site o Travel Routes

» San Juan Island o Salmon o Reefnet Sites o Red Snapper

» Henry Island o Salmon o Sea Urchins o Habitation Site

» Stuart island o Salmon o Herring o Octopus and Squid o Seaweed o Habitation Sites

» Moresby Island o Halibut o Rock Cod o Ling Cod o Waterfowl o Special Wood o Firewood o Sacred Sites o Habitation Sites o Travel Routes

» Pender Island o Salmon o Rock Cod o Herring o Clams o Oysters o Cockles o Seaweed o Sea Cucumbers o Deer o Berries o Special Wood o Bathing Sites o Sacred Areas o Habitation Sites

» Saturna Island o Salmon o Rock Cod o Flounder and Sole o Clams o Seaweed o Waterfowl o Deer o Berries o Special Wood o Firewood o Habitation Sites o Travel Routes

» Tumbo o Salmon o Sea Urchins o Clams o Oysters o Seaweed o Special Wood o Habitation Sites o Travel Routes

» Active Pass o Salmon o Rock Cod o Ling Cod o Oysters o Crabs o Seal o Deer o Berries o Firewood o Travel Routes

» Prevost Island o Rock Cod o Sea Urchins o Abalone o Cockles o Deer o Habitation Site o Travel Routes

» Point Roberts o Salmon o Reefnet Sites o Longhouse o Habitation Sites