WCS Canada Comments: Marten Falls Community Access Road Project Draft Impact Assessment Report

Kirkwood, A., & O'Connor, C.

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Key points

In these comments, WCS Canada identifies four key areas where we consider that the draft Impact Assessment Report for the Marten Falls Community Access Road project can't assess or underestimates the significance of impacts to the environment because of incomplete information:

1. The draft Impact Assessment Report fails to acknowledge the narrow scope of the cumulative effects analysis and therefore underestimates the significance of some cumulative effects;
2. The use of so-called "floating roads" over peatlands is accepted as a key mitigation design with insufficient evidence about their effectiveness, and therefore underestimates the impacts on peatlands, carbon, and hydrology;
3. Many of the federal effects are likely underestimated based on restoration and management plans that are incomplete; and
4. The draft Impact Assessment Report accepts that the offsetting plan within the Project's Impact Statement is sufficient, despite the offsetting plans being incomplete and feasibility of many of these approaches being uncertain.

We recommend that IAAC should:

• Consider scenario-based analysis of future development pathways to adequately assess possible impacts;
• Provide an independent and evidence-based evaluation of the effectiveness of the "floating road" design, and if unable, revise its assessment of any federal effects of the "floating road" to take into account the high level of uncertainty;
• Require the proponent to provide sufficient detail on proposed restoration and management plans so that IAAC may complete the impact assessment with all of the required information; and
• Require the proponent to provide additional details on the offsetting plan so that IAAC may assess whether the offset plan adequately considers avoidance, minimization, and restoration, and whether the proposed offsetting approaches will be effective.

Recommended citation

Kirkwood, A., & O'Connor, C. (2026). WCS Canada Comments: Marten Falls Community Access Road Project Draft Impact Assessment Report. Wildlife Conservation Society Canada [WCS Canada]. https://wcscanada.org/resources/wcs-canada-comments-marten-falls-community-access-road-project-draft-impact-assessment-report/