From Nibinamik First Nation to the Impact Assessment Agency of Canada re: Comments on the Webequie Supply Road Project Assessment and Time Limit Extension Request

Hello Caitlin,

As legal counsel for Nibinamik First Nation, I am writing in response to Canada’s request for comments on the request to extend the time limits under the Impact Assessment Act for the Webequie Supply Road project to January 6, 2027.

Nibinamik is still in the process of reviewing and considering the implications of the request, however, since you have asked for comments by November 25 (today), we would like to provide the following preliminary feedback. In particular, we want to make the point that if the extension request is approved, Canada should ensure that it is able to require updated or additional studies or surveys from the proponent, where needed, in order to accurately reflect the environmental, cultural, or cumulative impacts of the project.

It is of critical importance that Canada has accurate information to rely upon when monitoring and assessing the project. Circumstances change and data/information will stale date. This is part of the rationale for having time limits in the Act to begin with.

Webequie only identifies two studies that will be completed during the extended time (caribou winter aerial survey and caribou calf recruitment survey) and the remaining studies/surveys/data will be relied upon “as is” without any clear commitment to updating or verifying the accuracy of this information after an additional 4 years. At a minimum, Canada should ensure that there is a clearly justifiable scientific reason for why any old data (which could be up to nine years old if the extension request is approved) for a particular study can be adequately relied on, and where there is not a justifiable rationale, Canada should ensure you have a way to require that updated or additional studies or surveys are undertaken.

If you have any questions regarding this preliminary input please feel free to contact me directly.

Thank you,

Alexandria Winterburn