Response to Draft Tailored Impact Statement Guidelines

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Access to jobs for community members is far from the project site, so there would be limited job opportunities for Temagami First Nation community members. Training opportunities that took place in the community might allow a greater access to jobs. We would recommend considering that indigenous communities be directly involved in environmental monitoring throughout the entire project.

We would like to see the positive economic effects clarified and specified. We would be interested in understanding what economic benefits the region will experience, and how long these economic benefits will last.

There is a potential for this project to impact the section of highway 11 which cuts through our traditional territory. The transportation of heavy-duty equipment for mining or mine construction, or gold doré, would add to the presently dangerous conditions of this highway, making life more difficult for local residents.

It is our understanding that some archaeological assessments have already been completed. We would request that copies of the assessment reports be made available, and that all parties could be assured that members of a local First Nation’s community participated in the archaeological assessment process. First Nations being directly involved in the work which reveals their own history is an invaluable step towards reconciliation which cannot be overlooked.

Demonstration of need

When fulfilling the requirement to demonstrate the need for another gold mine, we would request that the proponent reconcile their answer with the exclusion of gold from Ontario’s Critical Minerals list.

Climate Change and Environment

We believe that the proponent should be asked to demonstrate how this project would fit into Canada’s goal of net zero emissions by 2050, and how it could contribute to an overall goal in the reduction of CO₂ emissions. A life-cycle analysis of the project taking the effects of climate change into account would be valuable.

With the proposed schedule of 13 years of operation, and 16 years total for operation to decommission, we would require a plan outlining that three years would sufficiently allow for the project to be fully decommissioned. Three years is a very short period of time for a project of this magnitude. Examples outlining the decommissioning of comparable projects would be appropriate to include.

Wildlife

A project of this nature would decrease the amount of wildlife in the area. A few species of note which must be considered as valued components would include moose, bears, beavers, fish (including pickerel and lake trout).

Moose are important for subsistence and culture (especially so for youth). The TISG requirements for the proponent should include a review of the quantity of yearly MNRF hunting permits issued for moose each year over the last ten years (as the number issued relates to moose population), as well as protection measures for moose emphasis areas near the site.

The project could also decrease the habitats (and the numbers) of bears in the area, and affect the associated hunting activities and availability of bears. This project could also decrease the habitats and population of beavers in the area, and would impact trapping activities.

The nature of this project would have a direct impact on fish, including spawning areas, quality of habitat, water quality, and invasive species. The plans for mitigating these issues should directly involve the local indigenous communities, especially in regards to aquatic habitat replacement and addressing any invasive species that may be removed from York Lake. We seek clarification on how local First Nations groups will be involved in the aquatic habitat replacement process. Having conducted our own Use and Occupancy Study, we would be able to provide guidance and recommendations at a later point.

Invasive plant species brought in through soil are also of great concern, and this must be addressed.

The construction phase of this project could impact breeding birds in the project area. We would recommend that the agency use the MNRF guidelines for both temporal and spatial buffers to mitigate these impacts.

Watershed

The proponent must study and mitigate the long-term effects of the project on the watershed. If the overall size of York Lake would increase after the mine closure, how does this impact the water flow, water levels, downstream hydroelectric and water control dams, and navigability in the future. Various scenarios demonstrating the impacts of climate change should be modelled here to fully explore the outcome. It should be noted that rising water levels in the past have damaged and destroyed cultural and spiritual sites, as well as villages.

Consultation

Quoted from the draft tailored impact statement guidelines:

“The proponent must engage with Indigenous communities at the earliest reasonable opportunity, in order to identify and understand the potential impacts of the Project on Indigenous peoples and their rights, including their lands, territories and resources, and to incorporate Indigenous knowledge into the impact assessment. “

We have received no communications from the proponent to date, and no consultation has taken place between Temagami First Nation and the proponent yet. We would request that the proponent make their plans for notification, consultation and accommodation clear.