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Adaptive management and the Baffinland Phase 2 Proposal

A Review of Concerns and Considerations

IN RELATION TO THE

Adaptive Management System Proposed for Baffinland Phase 2 Development of the Mary River Iron Ore Mine

SUBMISSION TO THE NUNAVUT IMPACT REVIEW BOARD January 17, 2021

Hamlet of Pond Inlet

Joshua Arreak Mayor

______Prepared by Dr. Frank Tester, B.Sc., (Hon.), D.Phil., M.E.Des., M.S.W., Technical Advisor Rowan Harris, B.Sc., Research Assistant with contributions from Joshua Arreak, Mayor, & Tim Soucie, former Hamlet Councillor

TABLE OF CONTENTS

Introduction ………………………………………………………………………………………. 1

What is Adaptive Management …………………………………………………………. 4

1. Defined Management Objectives ……………………………………….. 5

2. Measureable Indicators ………………………………………………………. 5

3. Predictive Modelling of Indicators ………………………………………. 5

4. What to do? ……………………………………………………………………….. 6

5. What is Important ………………………………………………………………. 8

Lessons Learned ………………………………………………………………………………… 8

1. Inuit must have the power to make management decisions. …. 8

2. Differences between the way Qallunaat and Inuit communicate can create problems for adaptive management. …………………. 12

3. Being able to actually change things is important. ………………. 13

4. Biological and management time are not always the same...... 14

5. Adaptive management can create more cause for conflict. …… 16

6. Adaptive management requires a lot of people’s time and , enough (money included), and a common vision to make it work. ………………………………………………………… 16

Conclusion …………………………………………………………………………………………. 17

Introduction1

At issue are the environmental, cultural and social effects of and shipping at Mary River, Milne Inlet, and Eclipse Sound, Baffin Island.

Adaptive management is being proposed as a means for managing potential impacts. It is an approach being proposed and developed through the Inuit Certainty Agreement (ICA) signed by the Qikiqtani Inuit Association (QIA) and Baffinland. It is subsequently referenced and anticipated in agreements reached by parties to the hearing process, notable among them, and Oceans Canada.2

This submission to the NIRB by the Hamlet of Pond Inlet addresses what adaptive management is, how it works, and what some of the problems with implementing it might be. This is important background information given that adaptive management is being promoted by both Baffinland and QIA as a method for dealing with project effects if Phase 2 is recommended by NIRB and approved by the federal government. We submit this information and comments in hope that NIRB will find it useful in evaluating the many instances where adaptive management is referenced as a way of dealing with potential effects to the marine, terrestrial and socio- economic environments associated with Baffinland’s Phase 2 Proposal.

In addition to dealing with what adaptive management is and how it works, we raise concerns about its application to the Phase 2 Project. It is important to understand what adaptive management is, how it works and what some of the problems might be for communities affected by the Baffinland Phase 2 Proposal. What is somewhat unusual about the proposed use of adaptive management in regard to the Baffinland Phase 2 Project is the size, complexity and interconnected effects that are associated with any large development project.

The literature suggests that adaptive management is more commonly and successfully used for the management of smaller and more easily defined components of a larger ecosystem, for example by Indigenous people and environmental scientists who are committed to preserving a

1 This document is based on a review of 52 articles about adaptive management published internationally, and two books about adaptive management. Included were 14 articles and chapters that deal with traditional ecological knowledge (TEK) and/or IQ and their relation to adaptive management. The report is co-authored by Frank Tester, technical advisor to the Hamlet of Pond Inlet. He has a degree in Environmental Design – design and environmental – and is a former Professor of Environmental Studies, York University, a graduate programme where he taught social and environmental impact assessment and adaptive management practice. Rowan Harris is a biology graduate, University of British Columbia.

2 As evidenced by the content, cautions and matters both resolved and outstanding in FISHERIES AND OCEANS CANADA, Updated Written Submission, Baffinland Iron Mines Corporation, Mary River “Phase 2 Development” Project Proposal, Submitted to: Nunavut Impact Review Board, January 15, 2020, DFO File No.: 07-HCAA-CA7- 00050 , NIRB File No.: 08MN053. 1 | P a g e wetland or a species affected by a known threat, etc. Applying adaptive management to elements where there are multiple, and perhaps unknown or unrecognized considerations impinging on what is happening, is challenging.

The number of elements and interacting elements potentially impacted by an Arctic mining operation like Mary River makes adaptive management in this situation, demanding, with observations and conclusions that may be highly contentious. This means that the mechanism for making decisions in response to observed and documented effects is of critical importance; something complicated by competing goals and objectives and the interests of the parties involved in decision making. As noted below, this is of primary concern.

Adaptive Management is proposed as a way of dealing with the physical environment, social, cultural, and economic impacts of expanding production at the Mary River Iron Ore Mine. What is presented here is based on a thorough review of the contemporary international literature dealing with adaptive management.

What is Adaptive Management?

Adaptive management is a -based approach to change. There are very few examples in the literature of situations where the science used in adaptive management has been applied in concert with traditional knowledge or, in this case, IQ.

Adaptive management focuses on the effects of what changing circumstances and conditions are doing to people and environments. It can involve both monitoring of processes being affected by some introduced or natural change, and it can be used experimentally to see what effect a particular change or a combination of changes have on the environmental or component in question. Adaptive management can focus on a particular element – a or a species – or a complex ecosystem.

There are dimensions of adaptive management that must be present in order for a management system to be called “adaptive”. The problem with adaptive management, since its inception by University of British Columbia professor, Crawford Stanley ‘Buzz’ Holling, in the early 1970s, is that, not unlike the term ‘sustainable development’, it has been applied to activities and used to describe actions that do not constitute adaptive management. The term has a certain social and political currency that explains its use - and misuse.

The literature on adaptive management makes it clear that there are five important and essential components to an adaptive management system that must be present and addressed for adaptive management to work..

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1. Defined Management Objectives

There must be a clear understanding about what is to be managed and monitored (environmental, social, physical, economic), and what sort of environmental changes are acceptable. This must be established before a project begins, and are called thresholds; levels or degrees of change where intervention is mandated in order to prevent environmental damage, or further environmental damage.

Where environmental damage is detected, changes are made to repair or restore the element or component in question. In this case, IQ is important to identifying priorities and to determining thresholds.

2. Measurable Indicators

Indicators must be things that can be observed and/or measured. Then people responsible for making decisions can learn and use the results to manage environmental, cultural, social and economic concerns. What these indicators are must also be determined ahead of time. Anyone evaluating a plan for adaptive management must be assured that there are appropriate indicators, that these can be measured or observed, and that the indicator(s) will, in fact, measure what is of concern.

An example would be the impact of stress and exertion on a species like narwhal over a period of time (a season). Indices or measurements of body fat, taken at the start of a season and again at the end of a season, could be an indicator of the impact of shipping on the vitality of narwhal exposed to shipping or other disturbances in their natural environment. As an example of the complex considerations in identifying indicators, in this case, there would need to be parallel evidence that summer supplies were not also disrupted or believed to have been affected by other intervening variables.

3. Predictive Modelling of Indicators

Western science and computer models are often used to establish a predictive cause and effect relationship among the things that are of concern.3

An example would be the effect of ship noise on narwhal. Collected data can be used to model what might happen if noise increases or if there are changes in frequency and duration.

3 Conroy, M. J., Barker, R. J., Dillingham, P. W., Fletcher, D., Gormley, A. M., & Westbrooke, I. M. (2008). Application of to conservation management: Recovery of Hector’s dolphin. Research, 35(2), 93–102. https://doi.org/10.1071/WR0714s

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Based on studies previously conducted, the effect on a local economy of guaranteeing everyone a minimum wage of $20 an hour, or introducing a guaranteed minimum annual income at a particular level of payment, can also be modeled.

4. What to Do?

There needs to be agreement on what things are important. There needs to be agreement on what might be done if change is needed.4 What are the options?

This is particularly relevant when there are no end of elements that attention and resources might be directed toward, and no end of possibilities for monitoring and intervention. What are the priority concerns, and where should the most attention be directed? What becomes a priority may be something that is identified as an indicator that all may not be well with other things. The priority may be the equivalent of ‘a canary in a coal mine’. When something happens to the bird, it indicates that something else is happening with implications for a component of ultimate concern; in this example, underground miners.

What is often missing from plans for adaptive management, and what often causes problems that undermine the effectiveness of adaptive management - and what might otherwise be seen as the good intentions that lie behind its implementation - is an a priori agreement on what options for action exist. Furthermore, there must be agreement on what actions will be taken if a certain and pre-established threshold is reached with regard to the system or element in question. The failure to have clear agreement on what actions will be taken before implementing an adaptive management plan can prove to be fatal.

This is a notable issue with regard to the issues resolved and outstanding in Fisheries and Oceans January 15th submission to the NIRB.5 Issues are resolved in most cases. But they are only resolved to the extent of some agreement being reached with regard to the monitoring and reporting that Baffinland will do relative to a list of issues and concerns.

An example is the observation by Fisheries and Oceans that: “Increased shipping activities, including those occurring during conditions, may increase acoustic disturbances and negative impacts to marine mammals. Adequate modelling must be provided in order to fully assess these impacts” (page 19). By way of resolution, “DFO acknowledges Baffinland’s updated commitment for DFO technical comment 3.3.3 NEW, and is of the opinion that

4 Scarlett, L. (2013). Collaborative adaptive management: Challenges and opportunities. and Society, 18(3). https://doi.org/10.5751/ES-05762-180326

5 FISHERIES AND OCEANS CANADA , Updated Written Submission , Baffinland Iron Mines Corporation, Mary River “Phase 2 Development” Project Proposal, Submitted to: Nunavut Impact Review Board, January 15, 2020, DFO File No.: 07-HCAA-CA7-00050 , NIRB File No.: 08MN053. 4 | P a g e

implementation of this commitment will satisfy DFO’s concerns” (page 20). Establishing what actions will be taken, depending on results, is important to the entire process of monitoring. The collection of data is an essential action to be taken before a project is initiated. A failure to do so undermines the principles and the viability of an adaptive management system.

As this an element of adaptive management systems that is most difficult to put in place, not having this relying upon an adaptive management system that ultimately, may not work. This is a weakness of what is currently being proposed for the Phase 2 Project. It is a reality easily overlooked in relation to the number of outstanding issues that appear to have been resolved, for example, between DFO and Baffinland. These deal only with monitoring. The Hamlet is very concerned about where the development of an adaptive management approach ‘is at’, going into the final public hearing. NIRB does not have what it needs to be assured that adaptive management will work.

The literature reveals that the difficulty in identifying thresholds and clearly establishing what will be done if they are reached, is heightened where parties to the adaptive management plan have competing, and perhaps incompatible, ultimate objectives. The word ‘ultimate’ is important. It is easy to agree on the importance of preserving a particular species. For example, no organization or economic interest is going to deny that polar bear should be protected. However, where the ultimate objective of a corporation is to maximize profits and a return to shareholders, this may well interfere with a willingness to do what, in the final analysis, needs to be done to protect the species. This tension will be reflected in the establishment of thresholds and actions to be taken.

Fisheries and Oceans Canada has a wealth of experience with this, with which the author (Tester) is familiar. For example, Marine Protected Areas created by Fisheries and Oceans Canada with local communities and interests, often do not accomplish their stated objectives. Adaptive management can help. But what adaptive management has sometimes indicated needs to happen in order to protect a species (Atlantic cod, for example), confronts the issue of ‘economic value’ and commercial fishing ‘rights’. These situations are a clear example of what happens when competing ultimate objectives are involved.6 Not having prior agreement on thresholds and actions puts adaptive management systems at .

6 A clear example of this was the Department of Fisheries and Oceans attempts, commencing in 1998, to protect Atlantic cod and its habitat. In Labrador, fishing was found to remove from the population, large adult Gilbert Bay Cod that seasonally moved outside a Marine Protected Area set up to stop a decline in the population. A lack of agreement among processes and stakeholders created problems when the adaptive management initiative identified to deal with an exceeded threshold came up against the competing interests of the fishing industry. And we all know what happened to the Atlantic cod . See Corey j. Morris & John M. Green, MPA regulations should incorporate adaptive management – the case of Gilbert Bay Labrador Atlantic Cod (Gadus morhua), Marine Policy, 49 (2014) 20 – 28. 5 | P a g e

5. What is important?

There has to be a very strong commitment to doing things using the principles and practices associated with adaptive management. Putting in place the resources necessary to gathering, making sense of, and using information when doing adaptive management is essential.

An important consideration revealed by the literature is the importance of leadership. There may be many important and competing interests gathered around the adaptive management table. Having an adaptive management process that is not led or co-ordinated by someone who is knowledgeable about adaptive management, and strongly committed to the process and its merits, has been a major flaw in the design of adaptive management systems. A proliferation of committees, competing and different agendas, and the absence of a manger or administrator with the skills and diplomacy to bring people together working with common cause and conviction, has been fatal to many adaptive management initiatives.

Too often the emphasis has been on people with technical skills – be they in a discipline like biology or sociology or chemistry – when what is needed to head an adaptive management team is someone with extraordinary ‘people skills’, coupled with a capacity to appreciate the subject matter and, as would be true in this case, Inuit culture.

Having an interested party in charge, where there may be competing interests involved in an adaptive management initiative, is a mistake. If there are pre-determined thresholds and clearly defined mitigative measures that will be put in place if thresholds are met or exceeded, then the importance of having someone with diplomatic skills and an accompanying measure of energy and commitment at the helm is obvious.

The literature also makes it clear that adaptive management is not cheap. The resources required to do adaptive management are often underestimated and the results are predictable.

Lessons Learned

Lesson 1: Inuit must have the power to make management decisions.

In the case of the Phase 2 Proposal, an important question to ask is whether or not Inuit will have the power to participate as equals in management decision making. The problem is that what Inuit bring to the table are the results of monitoring in relation to knowledge (IQ) of their environment, species, culture and society. Inuit knowledge and insight is confronted by western science.

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Traditional Ecological Knowledge (IQ in this case) has been successfully used in adaptive management. It has been used to manage for grazing cattle in Botswana,7 and the fields of Norwegian farms, using the knowledge of farmers with decades of experience.8 This is because people who needed to make changes in what they were doing were relied on for information and insights relevant to management options and decisions.

Adaptive management has been shown to work best when IQ is used to help manage fish and animals that are being hunted.9 In these situations, IQ will look at all the things that are important. This informs decision makers about how harvesting is affecting the population. It is important to understand who has the power to make decisions – and why.10 These are among the most important considerations for NIRB in deciding what to recommend with regard to the Baffinland Phase 2 Proposal.

While there may be – and some would say ‘should be’ – agreement and compatibility between what is observed and measured by western science, and what is seen, understood, and measured by Inuit - interpreted on the basis of hundreds of years of experience - there are good reasons to be skeptical. While Baffinland has agreed to the outline of an Inuit Stewardship Plan, there is no clear indication that the corporation will ultimately share decision making power with Inuit. It is willing to receive from Inuit the results of monitoring and IQ studies; to discuss and possibly debate the results with Inuit in relation to its own findings. Baffinland currently chairs the working groups established for the first phase of Baffinland’s operations. It has decision making authority, and the extent to which it is prepared to relinquish this in return for a joint or approach is anything but clear.

This is evident from correspondence between Baffinland and Mr. P.J. Akeeagok, President of the Qikiqtani Inuit Association, January 29, 2020.

7 Stringer, L. C., Dougill, A. J., Fraser, E., Hubacek, K., Prell, C., & Reed, M. S. (2006). Unpacking “Participation” in the Adaptive Management of Social-ecological Systems: a Critical Review (Vol. 11, Issue 2). and Society. https://about.jstor.org/terms

8 Wehn, S., Burton, R., Riley, M., Johansen, L., Hovstad, K. A., & Rønningen, K. (2018). Adaptive management of semi-natural hay meadows: The case of West-Norway. Policy, 72, 259–269. https://doi.org/10.1016/j.landusepol.2017.12.063

9 Ellis, S. C. (2005). Meaningful Consideration? A Review of Traditional Knowledge in Environmental Decision Making (Vol. 58, Issue 1).

10 Casdy, P. (2005). The Anti-Politics of TEK: The Institutionalization of Co-Management Discourse and Practice (Vol. 47, Issue 2). https://about.jstor.org/terms

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Baffinland maintains that it cannot defer its decision-making responsibilities to QIA or an Inuit Committee for the safe and sustainable operation of the Mary River Mine. Baffinland understands this view will be taken into consideration when QIA develops its proposals.11

This position is to be expected for a company with much at stake, a commitment to bond holders and other investors, and a primary objective of ensuring the viability of the operation. There is psychology, history and experience at work here. This logic is easily appreciated.

Where Inuit come from is not so easily grasped. The Qallunaat looking in on Inuit culture and communities have a window on a way of ‘making sense’ - a way of valuing and doing things - that in many not-so-obvious ways, is almost as old as human presence on the planet.

The heart of Inuit culture is in a gathering and hunting culture with a very different understanding of ‘what it means to be human’ and what is to be valued. Observations like this are easily dismissed. Don’t Inuit own and drive trucks? Don’t kids go to school and learn many of the same things Qallunaat children learn everywhere? Don’t Inuit have bills to pay? Don’t they like popcorn, peanuts and Coca-Cola, just like the rest of us? Haven’t times changed?

They have. But there are answers as to why labour turnover is high among Inuit mine employees and, in many cases enthusiasm. The idea of a career in the industry is hard to come by. There are answers to why some Inuit are okay with a ‘two-week in, two-week out’ work schedule that affords time to go hunting on ‘days off’. There are explanations for why someone with pipsi (dried fish) announces it on the Pond Inlet community Facebook page, and invites anyone who would like some to drop by and pick it up. There are reasons why high school graduation rates are low, and Inuit miss work when a pod of narwhal show up a few kilometres offshore.

Despite appearances, by way of a long list of often overlooked and subtle – as well as not so subtle - behaviours, Mittimatalingmiut – are still a hunting culture. Coming to grips with the reality that preservation of land, animals, culture and interactions (of all kinds) is just as valuable to Inuit as turning a profit and operating a sustainable iron ore mine is to Baffinland owners, management and staff, is more than a challenge for the average Qallunaat observer.

Should Inuit disagree with decisions made in what is being proposed, they will have recourse to a mediation process. But to assume that IQ carries a weight equivalent to the importance given to western science is to fly in the face of history. It is time to try, but experience suggests that there is still a long way to go before Euro-Canadian institutions and thinking recognizes in more than a

11 Letter from Brian Penny to P.J Akeeagok, January 29, 2020. 8 | P a g e ceremonial and token way, the value and importance of an Inuit world view to the environmental and other challenges we all face.12

It is also true that decision makers sometimes do not really want to use IQ or TEK. They decide that the information is not useful, but might not say that this is what they are thinking and why they do not use the information. This is what has sometimes been observed in situations where adaptive management was supposed to involve the use of TEK (IQ). In many situations we have studied, Qallunaat scientists and decision makers do not accept the thresholds suggested by Traditional Knowledge or IQ.13

That IQ - originating in a culture foreign to most Qallunaat, and that challenges in important ways, the logic of western culture - should supplant ideas about progress and development is nearly impossible for many project managers to accept. The ethos of western culture is progress and development. In the management of effects, thresholds suggested by IQ and Indigenous experience often don’t fit with what scientific models tell a western (Qallunaat) mind.

It is also naïve to believe that western science, numbers, research results and interpretations are somehow ‘objective’ indicators of a condition or development in the natural world. Science can be, and is often bent to serve particular purposes; to suggest or “prove” that something is insignificant, when other scientists may, using the same data or their own results, come to opposite conclusions.

How will Inuit Qaujimajatuqangit fare in this historical, cultural and decision-making context? What will mediation (most likely practiced by a lawyer schooled in western law and mediation practices) look like in the face of an operating licence legitimizing the mining and shipment of 12 million tonnes of ore a year? Will the terms and conditions allow for the possibility of a stoppage should the impact on narwhal (for example) be warranted? Has this been addressed in relation to adaptive management plans? Have thresholds and actions to be taken been identified and agreed upon?

These are matters not to be ignored in assessing the effectiveness of adaptive management with regard to Baffinland’s Phase 2 Proposal. The Hamlet of Pond Inlet has serious reservations about what is being proposed, given that it is incomplete and has not fully addressed concerns of critical importance to the operation of an adaptive management approach to project effects.

12 Oosten, J. & Laugrand, F. (2017) Inuit Worldviews: An Introduction, Iqaluit, Nunavut Arctic College Media, & Karetak, J., Tester, F. & Tagalik, S. (2017) Inuit Qaujimajatuqangit: What Inuit have always known to be true, Halifax and Winnipeg, Fernwood Publishers.

13Moller, H., Berkes, F., O’, P., Lyver, B., & Kislalioglu, M. (2004). Combining Science and Traditional Ecological Knowledge: Monitoring Populations for Co-Management and Society. (Vol. 9, Issue 3). http://www.ecologyandsociety.org/vol9/iss3/art2

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Lesson 2: Differences between the way Qallunaat and Inuit communicate can create problems for adaptive management.

Adaptive management uses Qallunaat and scientific ideas that require written annual records and the use of numbers. Decision makers must be able to look at the effects of different management policies. Gathering information and looking at how this information changes over a period of weeks, months or years, are necessary to determine best practices.

The oral transfer of knowledge in Inuit culture does not easily fit the requirement of adaptive management for written annual records and numbers. For those who have Inuit Qaujimajatuqangit and an understanding of how things work, this creates problems in dealing with decision makers who rely on scientific monitoring and scientific data.14

Experience tells us that IQ or Traditional Ecological Knowledge (TEK) is often not taken seriously by decision makers. When IQ or TEK is presented to these decision makers, it is sometimes presented in a way that Qallunaat decision makers do not understand.15 How will QIA present information to Baffinland? Will Baffinland accept, understand and be willing to use IQ information?

There are other matters that Qallunaat are often not aware of. Inuit culture is based on concensus. Avoiding anger and conflict is, for most Inuit, of considerable importance. Decisions – including deciding what something means and how to respond – are not matters to be handled by a single individual. They require consultation, thought, and discussion. Voting is a strange way to decide anything. These cultural norms can create a lot of misunderstanding. When someone is asked for an opinion, they are likely to get answers that are hesitant or find themselves in a conversation that seems to wander all over the place, as someone tries to both meet the request of a Qallunaat and, at the same time, honour an Inuit way of developing an opinion or making a decision. It is too easy to read this as meaning that someone does not understand what is being said or asked of them. This is but one example of things that can happen with cross-cultural communication.

This helps explain why QIA wants a parallel structure in which Inuit will do monitoring and discuss among themselves - in their own ways and in their own time - what they are seeing and experiencing. They can then advance what they conclude is the right thing to do, within a time frame of their making. How this will relate to the the pace at which Baffinland feels it needs to make decisions is unknown.

14 Scarlett, L. (2013). Collaborative adaptive management: Challenges and opportunities. Ecology and Society, 18(3). https://doi.org/10.5751/ES-05762-180326

15 Drew, J. A. (2005). Use of Traditional Ecological Knowledge in . , 19(4), 1286–1293. https://doi.org/10.1111/j.1523-1739.2005.00158.x

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A different kind of discussion and focus is needed to make adaptive management work. Focusing on the ‘nuts and bolts’ of an adaptive management plan is necessary, but insufficient. Two different cultures need to have a mutual understanding of each other, and be respectful of differences to a degree where they can meaningfully work together. This appears, to the Hamlet, to be more demanding and requires more time and attention than has, to date, been directed at what is essential to make adaptive management work.

Lesson 3: Being able to actually change things is important.

Doing a lot of monitoring of any one of the very many things that need attention in a project as large and complicated as Baffinland Phase 2, does not mean that things will change.16 Adaptive management has to make good use of information that has been collected. Making sense of that information is important. This lesson is firmly tied to the earlier consideration given to power – who has it, and how it is exercised.

An inability or unwillingness to adjust management plans is the most common cause of adaptive management failures.17 This is especially true when big decisions have to be made that, for example, might affect the production schedule of a mine, or the profits that are being made, or because the change costs a lot of money.18,19

Everyone involved in adaptive management has to agree on what has to be changed, if needed. Those involved may have different values, or think that some things are more important than others. People may be concerned about different things.20 This causes management problems. Things that need to be changed don’t get changed. Then things that are causing problems continue to cause problems. This was true of the attempt to better manage cod at Gilbert Bay Labrador, cited in footnote 4. As noted, having in place thresholds and agreed upon courses of

16 Williams, B. K., & Brown, E. D. (2014). Adaptive management: From more talk to real action. Environmental Management, 53(2), 465–479. https://doi.org/10.1007/s00267-013-0205-7

17 Walters, C. J., & Hilborn, R. (1978). Ecological Optimization and Adaptive Management. In Source: Annual Review of Ecology and Systematics (Vol. 9). https://www.jstor.org/stable/2096747?seq=1&cid=pdf-

18 Conroy, M. J., Barker, R. J., Dillingham, P. W., Fletcher, D., Gormley, A. M., & Westbrooke, I. M. (2008). Application of decision theory to conservation management: Recovery of Hector’s dolphin. Wildlife Research, 35(2), 93–102. https://doi.org/10.1071/WR07147

19 Slooten, E., Fletcher, D., & Taylor, B. L. (2000). Accounting for in Risk Assessment: Case Study of Hector’s Dolphin Mortality Due to Gillnet Entanglement. In Biology (Vol. 14, Issue 5). https://about.jstor.org/terms

20 von der Porten, S., de Loë, R. E., & Mcgregor Journal, D. (2016). Incorporating Indigenous Knowledge Systems into Collaborative Governance for : Challenges and Opportunities (Vol. 50).

11 | P a g e action does much to ensure that actions will be taken. Otherwise conflicts and the decision making process related to actions that need to be taken can absorb an inordinate amount of time. They drag on while damage continues to be done to species, people or environmental systems that require immediate action and intervention. The experience of Mittimatalingmiut with dust manage is an example.

As noted, having strong leadership to make sure that adaptive management is being used properly is really important.21 This is hard work. The person or those in charge of an adaptive management process have to be trained in adaptive management, have experience, be willing to do the work and in this case, need to understand Inuit and Qallunaat cultures. The functioning and results of existing working groups for marine, terrestrial, and socio-economic environments are what has given impetus to the attempt by QIA to create an alternative and parallel structure to ensure that Inuit are heard and that IQ is taken seriously in decision making.

Working groups are currently chaired by Baffinland, with the company having ultimate authority to chair meetings, control who may attend, the agenda, and the flow of information.22 Depending on the forthcoming recommendation with regard to Phase 2, this is a matter that NIRB may wish to address. These are considerations that QIA has attempted to address with a proposal for an Inuit Certainty Plan. The Hamlet respects QIAs attempts. Unfortunately, there has not been enough time to address all the things that need to be done to make sure that an IQ approach to adaptive management will work. These needed to be addressed before, not after approval is (or is not) given to the Phase 2 Proposal.

Whether the existing structure of working groups is continued and integrated into a revitalized and reconsidered adaptive management plan, or restructured to better accommodate Inuit interests, IQ and results of monitoring, it makes sense to have a neutral third party with excellent facilitation skills and cultural insights, chair existing working groups.

Lesson 4: Biological and management time are not always the same.

Adaptive management is used to learn about how to manage change. Indicators need to be chosen that give current information about changes that have been made, and the effects of

21 Walters, C. J. (2007). Is Adaptive Management Helping to Solve Fisheries Problems? in Source (Vol. 36, Issue 4).

22 This and related matters are dealt with in a submission from the Hamlet of Clyde River and rather than repeat them here, the reader is referred to their submission to NIRB on this topic.

12 | P a g e recent management decisions.23 The careful selection of an indicator, and when it will be measured, are very important for a successful adaptive management plan.

Influences on the population of animals often build up over time. That is, over time, large animals like caribou and narwhal may suffer from many small-unobserved stressors that cause large future problems. When population numbers start to decline, it may be too late to make management changes. The length of time it takes to discover a problem, and the length of time it takes for a human or an animal population to get into serious problems, don’t always go together. For example, if a wolf population is being stressed, it may take many years of study to observe or discover this.

It might take 5 years to notice that a population is stressed. But to do something about it that works, this is something that researchers and managers would need to have known 3 years earlier. By the time those doing the monitoring realize there is a problem or that what they may have done – or not done – has created a problem, it might be too late. This is especially true for the management of large mammals like wolves, caribou and narwhal.24

NIRB is advised to pay attention to what happened to Atlantic cod stock in this regard. We have addressed this consideration, recognizing the IQ and current observations of Inuit hunters, in a separate Hamlet submission to NIRB; The Effects of Shipping on Marine Mammals in Milne Inlet and Eclipse Sound.

The Hamlet’s concern with potential effects on seal and narwhal populations is related to a concern for food security in the community. We have yet to complete a study of food security, but are well aware of indicators that Mittimatalingmiut are struggling with getting enough food to meet their needs and those of their children. Our food bank is a busy place and school breakfasts and lunches are necessary to our children and to their ability to participate and learn. Some Mittimatalingmiut end up selling things that they would normally keep in order to raise money to feed their families. Our concern about the health of our resources, and keeping our culture and practices that hold our community together – our Inuit culture – are based on our experience and what we see happening around us.

23 Dana, L. P., & Anderson, R. B. (2014). Mining and communities in the Arctic: Lessons from Baker Lake, Canada. In International Journal of Entrepreneurship and Small Business (Vol. 22, Issue 3, pp. 343–361). Inderscience Publishers. https://doi.org/10.1504/IJESB.2014.063780

24 Theberge, J. B., Theberge, M. T., Vucetich, J. A., & Paquet, P. C. (2006). Pitfalls of applying adaptive management to a wolf population in Algonquin Provincial Park, Ontario. Environmental Management, 37(4), 451–460. https://doi.org/10.1007/s00267-004-1041-6

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Lesson 5: Adaptive management can create more cause for conflict.

This has also been discussed in relation to other lessons learned. Adaptive management involves the collaboration of many stakeholders. This can result in a more comprehensive management plan. But it can also present more opportunities for conflict if the people involved in the process do not hold the same values or experiences.

IQ is a way of understanding everything that happens when something (marine mammals, birds, people) is affected by change. IQ can vary between communities. When it is time to decide on what objectives, indicators, and management plans will be best, disagreement can occur between and within communities. This is especially true where a large area is being managed.25 The possibility that there will be differences in knowledge and understanding becomes greater, and deciding how to respond to a problem becomes more complicated.

Often, there is too little time to work out such differences. In a review of lessons learned from mining and the community of Baker Lake, Canada, it was found that when disagreements do occur, often there is not enough time to discuss issues in the short consultation meetings organized to deal with the problems.26

Within the framework of adaptive management, there must be active work to resolve and work through conflict.27 In many cases, this occurs through workshops for those in leadership positions. It also depends on good initial relationships, both between local communities and, in this case, with Baffinland.

Lesson 6: Adaptive management requires a lot of people’s time and energy, enough resources (money included), and a common vision to make it work.

This lesson has also been discussed in relation to other lessons. However, it is important enough and is a matter that is discussed in the literature on adaptive management to the extent that it deserves to have further attention drawn to it as a separate ‘lesson learned’.

25 Westgate, M. J., Likens, G. E., & Lindenmayer, D. B. (2013). Adaptive management of biological systems: A review. In Biological Conservation (Vol. 158, pp. 128–139). https://doi.org/10.1016/j.biocon.2012.08.016

26 Dana, L. P., & Anderson, R. B. (2014). Mining and communities in the Arctic: Lessons from Baker Lake, Canada. In International Journal of Entrepreneurship and Small Business (Vol. 22, Issue 3, pp. 343–361). Interscience Publishers. https://doi.org/10.1504/IJESB.2014.063780

27 Scarlett, L. (2013). Collaborative adaptive management: Challenges and opportunities. Ecology and Society, 18(3). https://doi.org/10.5751/ES-05762-180326

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Adaptive management is labour intensive.28 It takes a lot of work to do a good job of it. It requires a lot of time spent monitoring. People have to meet to decide what should be monitored, how it should be monitored, and what kinds of changes are acceptable. As noted elsewhere, this is time consuming and important. And with regard to the Phase 2 Project, it is something that, while initiated, has not yet been done.

If things don’t change, and people are putting in a lot of time attending meetings and having to deal with conflicts and disagreements, they ‘burn out’.29 They get tired and discouraged, and no longer see any point in what they are doing. This happens when projects and the need to manage them take place over long periods of time. The literature makes it clear that adaptive management efforts fail when this happens.

Unless parties agree from the beginning, when adaptive management is being talked about, on what environmental changes are acceptable, and what changes are unacceptable, adaptive management is likely to fail.

Conclusion

The adaptive management plan advanced by QIA’s Inuit Stewardship Plan is a work in progress. As a work in progress, there are many important aspects of the plan and adaptive management that have received only partial, incomplete – and in some cases – little consideration.

These are essential to guaranteeing that adaptive management will work with regard to Phase 2. It is absolutely critical as there are so many ‘unknowns’ involved. A case can be made that guarantees that plans such as this will work are never possible. But as researched and outlined in this submission, there are many elements of adaptive management that, when put in place, enhance the probability that adaptive management will work.

There is considerable risk associated with Baffinland’s Phase 2 Proposal, as illustrated by the following cautionary statement made by Fisheries and Oceans Canada in framing its latest submission to the NIRB.

DFO has worked directly with Baffinland in the development of mitigation, monitoring and commitments for adaptive management to reduce the impact this project may have on the of the marine mammal populations within the study area.

We however note that there is uncertainty in both the efficacy of the mitigations proposed and the ability of current monitoring programs to detect project impacts, should they occur.

28 Walters, C. J. (2007). Is Adaptive Management Helping to Solve Fisheries Problems? In Source (Vol. 36, Issue 4).

29 Nadasdy, P. (1999). The Politics of Tek: Power and the “Integration” of Knowledge. In Nadasdy Source: Arctic Anthropology (Vol. 36, Issue 1). https://www.jstor.org/stable/40316502

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DFO remains concerned that the impacts to marine mammals from project related shipping activities may not be fully mitigated or avoided. However the extent of these impacts cannot be defined. Thus, robust monitoring and the commitment to adaptive management is crucial to the protection of the marine mammals. 30

The Hamlet concludes that in structuring and defining a system of adaptive management and a commitment to what that structure and system might look like, we are not there yet. Going forward, there is therefore very considerable risk related to adaptive management doing what all parties to the Public Hearing would like to see it accomplish.

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30 FISHERIES AND OCEANS CANADA , Updated Written Submission , Baffinland Iron Mines Corporation, Mary River “Phase 2 Development” Project Proposal, Submitted to: Nunavut Impact Review Board, January 15, 2020, DFO File No.: 07-HCAA-CA7-00050 , NIRB File No.: 08MN053, page 3.

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