WCS Canada Comments on the Summary of Initial Project Description for the Northern Road Link Project (Reference No 84331)
We are submitting our comments on the Summary of Initial Project Description for the Northern Road Link Project (Reference Number 84331). In these comments, we first provide four overarching concerns and associated recommendations on the Summary of Initial Project Description for the Northern Road Link (NRL) as a whole. Following these are some specific comments on various Sections within the Summary of Initial Project Description.
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WCS Canada Comments on Draft Environmental and Socioeconomic Effects Statement Guidelines (ESE Guidelines) for the Proposed Casino Mine Project
An impact assessment screening is soon to occur, undertaken by the full Yukon Environmental and Socio-economic Assessment Board (YESAB), regarding the proposed Casino copper-gold mine, in west-central Yukon.
This would be a massive project, among the largest copper mines globally, with a tailings facility alone estimated at 11 square kilometres. YESAB has produced draft environmental and socio-economic effects (ESE) statement guidelines that the proponent, Casino Mining Corp, will need to follow and fulfill so as to satisfy required information submission to the Board for the impact assessment screening. Casino is expected to submit its proposal to YESAB in summer 2023. In this review of the draft ESE guidelines, we recommend some changes and additions that we think are necessary to provide the Board and the public with more comprehensive and detailed information required for a valid impact assessment
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WCS Canada Comments on the Draft Policy Framework Assessment under the Impact Assessment Act, 2019 (IAA)
With respect to Regional Assessment (RA), WCS Canada scientists have made the case for RA in the Ring of Fire since 20131. We previously submitted a number of public comments to the Impact Assessment Agency of Canada (Agency) including for a Regional Assessment (RA)2 in the Ring of Fire region in November 2019, identifying federal responsibilities and following Agency guidelines3. The following year, we also provided substantive and referenced information to the Agency on the Information Sheet: Planning the Regional Assessment in the Ring of Fire Area, to support the development of the Terms of Reference and Potential Agreement for the RA by the Agency and Ontario4. Finally, we submitted comments and recommendations to the Agency on the Draft Agreement to Conduct a Regional Assessment in the Ring of Fire5.
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WCS Canada and West Coast Environmental Law Comment on CWS Draft Offsetting Policy for Biodiversity
We focus here on four key themes we have identified as priorities for helping ensure that Canada meets its environmental obligations, particularly those arising under the Convention on Biological Diversity. Our overarching concerns are: 1) the lack of sufficient emphasis on the mitigation hierarchy as a necessary frame for addressing biodiversity impacts at the project level (p. 1), 2) the lack of consistence and clarity regarding the proposed offsetting policy goal (p. 4), 3) the unrealistic expectation that cumulative effects can be managed or mitigated through this policy (p. 6), and 4) the manner in which the role of Indigenous peoples are discussed (p. 6). Herein, we discuss each of these themes in turn, and provide 16 recommendations for improvements to this policy.
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Request for Time Limit Extension from Marten Falls FN to the Impact Assessment Agency of Canada
WCS Canada comments on the Request for Extension Report, prepared by AECOM Canada Ltd. and Dillon Consulting Ltd. on behalf of Marten Falls First Nation as the Proponent for the purpose of the Impact Assessment (IA) of the Marten Falls First Nation All Season Community Access Road (MFCAR) Project. In summary, we support the request by the Proponent for an extension of three and a half years to July 24, 2026. Of the factors listed in Section 2, we agree in particular that COVID-19 had significant impacts on First Nations communities in the far north in Ontario and have concerns that the Proponent chose not to pause the MFCAR Project despite First Nation community requests to do so given health and safety concerns, capacity, and social crises. We continue to think this experience highlights the limitations of impact assessment as a tool for social justice in northern Ontario.
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