WEBEQUIE SUPPLY ROAD ENVIRONMENTAL ASSESSMENT REPORT / IMPACT STATEMENT

June 9, 2025

AtkinsRéalis Ref: 661910

SECTION 26:

Project Contributions to Sustainability

Contents

• Project Contributions to Sustainability……………………………………………………………………………….. 26-3
  • Assessment Considerations……………………………………………………………………………………… 26-3
  • Project Context……………………………………………………………………………………………………… 26-4
  • Engagement and Consultation…………………………………………………………………………………… 26-5
    • Issues of Importance…………………………………………………………………………………. 26-5
    • Selection of Valued Components………………………………………………………………….. 26-6
  • Community Plans…………………………………………………………………………………………………… 26-7
    • Community-Based Land Use Plan (2019)……………………………………………………….. 26-7
    • Webequie Comprehensive Community Plan (2023)…………………………………………… 26-7
    • Webequie Community Readiness Plan…………………………………………………………… 26-8
    • Compatibility of the Plans with Government Initiatives……………………………………….. 26-8
  • Planning and Design……………………………………………………………………………………………….. 26-9
  • Evaluation of Alternatives to the Project……………………………………………………………………… 26-10
  • Sustainability Principles………………………………………………………………………………………….. 26-11
    • Principle 1: Interconnectedness and Interdependence of Human-Ecological

Systems………………………………………………………………………………………………… 26-11

• Principle 2: Well-Being of Present and Future Generations……………………………….. 26-15
  • Principle 3: Consider Positive Effects and Reduce Adverse Effects……………………… 26-16
  • Principle 4: Precautionary Principle and Consideration of Uncertainty and

Risk of Irreversible Harm…………………………………………………………………………… 26-18

• Conclusion………………………………………………………………………………………………………….. 26-20
  • References…………………………………………………………………………………………………………. 26-21

In-Text Figures

Figure 26.1: Interdependence and Interconnectedness of Valued Components within a Human-Ecological

System…………………………………………………………………………………………………………………… 26-12

Figure 26.2: Interconnectedness of VCs with the Human Health VC………………………………………………………. 26-14

26                 Project Contributions to Sustainability

This section provides a qualitative assessment of the Project’s contribution to sustainability in accordance with Section 22.1 (h) of the Impact Assessment Act (IAA) and the Section 25 of the Impact Assessment Agency of Canada (IAAC) Tailored Impact Statement Guidelines (TISG) for the Project. Sustainability “means the ability to protect the environment, contribute to the social and economic well-being of the people of Canada and preserve their health in a manner that benefits present and future generations” as defined in the IAA, while also considering a diversity of views including Indigenous perspectives.

26.1                 Assessment Considerations

In defining the Project’s contribution to sustainability, Webequie First Nation (the Proponent) considered the following:

Project context with respect to issues of importance identified through engagement and diversity of views expressed about the Project.

1. “Sustainability” as defined by Indigenous Peoples which is a central theme within the Webequie First Nation draft community-based plans:
   1. Community Readiness Plan (Appendix N of the Draft EAR/IS);
   1. Comprehensive Community Plan (CCP, 2023); and
   1. Community Based Land Use Plan (CBLUP, 2019).

These community plans stem from the Three-Tier model (Kanisso Pittawa Attayk Onakoonikun) which evolved from customary understandings of the protocols and teachings handed down from Webequie Elders and leaders six or seven generations ago.

• Key provincial plans and government priority initiatives such as:
  • Ontario’s Infrastructure Building Better Lives: Ontario’s Long-Term Infrastructure Plan 2017 (Ministry of Infrastructure [MOI], 2018);
  • the Growth Plan for Northern Ontario (MOI and MNDMF, 2011); and
  • Ministry of Environment, Conservation and Parks (MECP’s) Preserving and Protecting our Environment for Future Generations – A Made-in Ontario Environment Plan (MECP, 2018).
• Project Valued Components (VCs) that:
  • are of relevance to Indigenous communities and groups;
  • could experience long-term effects, including how those effects could change over time, and how they could affect future generations; and
  • may interact with other VCs, potential Project effects and/or Project activities.
• Sustainability principles, as identified in the IAAC (2021), Guidance: Considering the Extent to which a Project Contributes to Sustainability and the TISG:
  • Principle 1 – Consider the interconnectedness and interdependence of human-ecological systems;
  • Principle 2 – Consider the well-being of present and future generations;
  • Principle 3 – Maximize overall positive benefits and minimize adverse effects of the designated project; and
  • Principle 4 – Apply the precautionary principle and consider uncertainty and risk of irreversible harm.

• United Nations Sustainable Development Goals (SDG) include 17 goals and 169 associated targets that set out a path toward sustainable development by 2030. The SDGs were adopted in 2015 by UN member states, including Canada. Throughout this section, Webequie First Nation has indicated where the Project aligns with one of the 17 United Nations SDGs1.

26.2                 Project Context

Since 2015, the Webequie First Nation community has been involved in the investigation of an all-season road corridor to better service the community and provide economic development opportunities for its members and businesses that reside in or around the community’s reserve and traditional territory2. In September 2017, Webequie First Nation began the Webequie Supply Road Project (the Project) by going through the process of identifying a 10 km wide conceptual corridor and narrowing the route to 2 km wide3. This study process included community engagement with local trappers, land users and traditional harvesters, as well as the Webequie land use planning committee members to identify possible corridors from the airport, through to the mineral exploration and the proposed mine development areas.

Once the preferred corridor was identified, preliminary aerial environmental and geotechnical visual inspections were conducted in October 2017. Following this work, Webequie First Nation indicated that they wished to continue the Project planning process as the proponent of an Indigenous-led coordinated federal- provincial environmental assessment for the development of the all-season road.

The intent of the Project is to enable the movement of materials, supplies and people from Webequie First Nation’s Airport to mineral exploration and proposed future mine developments in the McFaulds Lake area (Section 1). Important objectives of the Project include providing opportunities through:

• Employment and economic development to Webequie First Nation community members and businesses in or around the community’s reserve and traditional territory, while preserving the language and culture;
• Experience and training for youth to help encourage pursuit of additional skills through post-secondary education; and
• Issues of materiality are listed below in Sections 26.3.1 and 26.3.2.

1  United Nations Department of Economic and Social Affairs. Sustainable Development. https://sdgs.un.org/

²     https://www.supplyroad.ca/faqs/

³     https://www.supplyroad.ca/community-approach/#Background

26.3                 Engagement and Consultation

The consultative approach taken by Webequie First Nation directly informed the Project’s sustainability assessment. Engagement and consultation and activities began early in Project development and took place over several years. These engagement activities were undertaken in consideration of the Elders’ Guiding Principles and the Three-Tier Model which are detailed in Section 2.4.1 of the Environmental Assessment Report / Impact Statement (EAR/IS).

Webequie First Nation endeavored to gather as much Indigenous Knowledge to inform the EAR/IS. In following with culturally relevant protocols, and recognizing the limited resources available within the communities, the Project Team dedicated the time needed by community members to gather important Indigenous Knowledge.

This approach was influential in identifying the key values and issues of importance for the communities (Section 26.3.1); in selecting the Project VCs (Section 26.3.2) and in the evaluation of Project alternatives (Section 26.6). These key values and issues framed the sustainability assessment and aided in identifying the potential positive and adverse effects on Project sustainability.

26.3.1             Issues of Importance

To date, three rounds of engagement and consultation activities have been undertaken with Webequie First Nation, along with other 21 neighbouring Indigenous communities. Additionally, the Project Team has had ongoing discussions with multiple parties to understand the important issues to be addressed with the execution of this Project, including with government agencies, technical experts, the public and stakeholders.

A fulsome description of engagement and consultation activities is provided in Section 2 of the EAR/IS, in addition to Project consultation progress reports which can be accessed on the website: https://www.supplyroad.ca/a-progress-reports/.

From these ongoing consultations and engagement activities, the Project Team has been able to better understand the existing conditions of physical, biological, social, economic and health environments, cultural context and traditional protocols. These existing conditions have framed the development of the EAR/IS and are rooted in what the Project Team heard as issues of importance.

These issues of importance are broadly listed below and are in alignment with the CBLUP (2019) and CPP (2023), in addition to enabling the development framework for the CRP (Appendix N of the Draft EAR/IS).

• Maintaining and uplifting community well-being;

• Access to clean water;
  • Improved living conditions and access to adequate housing;
  • Food security;
  • Improving climate resiliency within the communities;
  • Maintaining traditional customary practice and land use;
  • Improving the lives of youth;
  • Improving community education levels;
  • Improving community health;
  • Addressing colonial harms which have contributed significantly to destructive behaviours related to illicit substance use, intimate partner and gender-based violence;
  • Safety in the community;
  • Preservation and protection of the ecosystem(s), including the flora and fauna that are reliant on them;
  • Protection of archaeological features and historical artifacts; and
  • Opportunities for economic improvement through commerce and employment.

26.3.2             Selection of Valued Components

The Project VCs were defined early in the Project planning process primarily through consultations with the communities, in which the issues of importance were elucidated. In scoping the Environmental Assessment / Impact Assessment, the Project Team contemplated the issues of importance (Section 26.3.2), thereby setting the tone for selecting relevant VCs which placed emphasis on the following:

• Indigenous knowledge, land and resource use information;
  • The value placed on the VC by humans, including those using the affected area;
  • The functional relationship of the VC within the environment;
  • The VC’s role within the ecosystem;
  • Regulatory guidance and requirements, including those identified in the TISG, provincial Terms of Reference (ToR) and agency discussions;
  • Technical knowledge of the Project (i.e., the nature and extent of project components and activities);
  • Lessons learned from previous similar EA/IAs;
  • Professional judgement based on the experience of the Consultant Project Team (AtkinsRéalis); and
  • Lived experiences of the Webequie Project Team consisting of community members from Webequie First Nation.

Taking into consideration the issues of importance, in addition to the factors noted above, the Project Team were able to identify 16 broad-based VCs that were then assessed as part of the EAR/IS. These VCs included:

26.4                 Community Plans

Parallel to project planning, Webequie First Nation has undertaken a multi-year process to develop community-based plans for the benefit of the community, by the community. These community-based plans include the CBLUP (2019), the CCP (2023) and the CRP (Appendix N of the Draft EAR/IS). Environmental stewardship and social and economic well-being have been central to their development and align with the Three-Tier model and seven generations teachings. Actioning these plans will be a part of the execution phase for the Project.

26.4.1             Community-Based Land Use Plan (2019)

The CBLUP (2019) is based on the Three-Tier model and is intended to advance the economic and social development goals of the community and to provide direction for the protection of land, water, species habitat, cultural heritage features and community values. The CBLUP (2019) achieves Webequie customary stewardship responsibilities and Far North Act (2010) objectives together by enabling economic development benefitting First Nations, protecting areas of cultural and natural significance and providing for interconnectedness in protected area design.

26.4.2             Webequie Comprehensive Community Plan (2023)

The CCP (2023) has been a multi-year process and is a community-led process, rooted in Webequie’s Three-Tier model. The CCP is complementary to the CBLUP (2019) and the CRP (Appendix N of the Draft EAR/IS).

The CCP sets out community values and visions; establishes realistic goals, objectives and measurable targets. It provides direction and guiding principles for achieving and monitoring positive change, based on the principles of sustainability and self-reliance in the context of ancestral relationships with each other and the community’s land base. The CCP’s goals and action strategies are laid out in relation to the following eight (8) components:

• Education and training;
  • Cultural vibrancy and traditional life;
  • Housing and infrastructure;
  • Environmental quality and relationship with the land;
  • Community health and wellness;
  • Family and social conditions;
  • Economic development; and
  • Community leadership and governance.

26.4.3             Webequie Community Readiness Plan

The intent of the CRP (Appendix N of the Draft EAR/IS) is to provide a means to track and understand the changes in the conditions of the social, economic and health VCs in Webequie First Nation and other communities in the Local Study Area (LSA) and Regional Study Area (RSA). The CRP is relevant leading up to, and during the Project construction and operations phases.

The CRP provides a roadmap to support the accuracy of social, economic and health net effect findings of the EAR/IS via the implementation of mitigation and enhancement measures and follow-up monitoring. This serves to support response adaptation and the ability of Webequie First Nation and other communities to capitalize on key opportunities arising from Project influences, while laying out a plan for developing the necessary physical infrastructure and social support systems. The CRP will aid with:

• Transferring the EAR/IS results and commitments into a format for facilitating dialogue with the Webequie and other LSA and RSA communities.
  • Leveraging the Project through enhancing the positive benefits, minimizing the negative effects and envisioning the community under a consolidated plan of change.
  • Understanding where to focus and identify the necessary steps to best position Webequie and other communities (on and off-reserve) for the potential effects of Project prior to the start of the construction phase.
  • Being rooted to the values of the Three-Tier model and CCP and monitoring the Project effects against these values.

26.4.4             Compatibility of the Plans with Government Initiatives

Ontario Ministry of Infrastructure (2018) Building Better Lives: Ontario’s Long-Term Infrastructure Plan 2017, acknowledges that communities in northern Ontario need a multimodal transportation system and that the north is especially vulnerable to the impacts of climate change, particularly in communities that rely on seasonal winter roads, such as Webequie First Nation. The Infrastructure Plan is intended to address the problem of unreliable community access, and the province is working with First Nations to plan and construct all-season access roads for connecting communities to the existing provincial highway system.

Should the Webequie Supply Road (WSR) and other road projects proceed they will connect Webequie First Nation to the provincial highway system and provide potential economic opportunities and social benefits to Webequie and other Indigenous and non-Indigenous communities, which support the government’s commitment to create jobs, provide long-term benefits and improve the quality of life for people in the region. The focus on implementation of an all-season road route is further supported through government initiatives for an improved transportation system and community access in northern Ontario. The 2011 Growth Plan for Northern Ontario (MOI and MNDMF, 2011) outlines Ontario’s commitment to work with remote communities for improved access.

From the perspective of Webequie First Nation, the WSR could be constructed and operated as a facility that only provides a connection between Webequie First Nation and the McFaulds Lake area to serve mineral exploration and future mining development activities, with no connection to the provincial highway system. However, with implementation of the Project and should future mining and other road projects (i.e., Northern Road Link and Marten Falls Community Access Road [MFCAR]) proceed to the McFaulds Lake area, Webequie First Nation would gain year- round access to the provincial highway system. It is in this scenario that the socio-economic effects of the WSR Project would likely be realized or felt to the fullest.

26.5                 Planning and Design

Since 2015, Webequie First Nation and the Project Team have taken a long-term view of the Project, having built upon various regional studies that have been undertaken on a regional all-season community road since 2008 (Appendix D-1 – Preliminary Engineering). This has enabled them to understand the issues that have supported comprehensive planning, such as understanding multi-sector needs (e.g., mining, transportation) in the region, as well as socio- economic and gender-based disparities within resident communities in relation to other, better-serviced Canadian communities. The proponent ascertained through early consultations that the Project could provide ecological, health, social and economic benefits, such as improving education and training opportunities for present and future generations; and a way to potentially promote language and cultural preservation.

With an understanding of these issues, the Webequie First Nation community made the decision to move forward as the proponent in 2017, as it viewed the Project as a means to provide better service to the community, provide economic development opportunities for resident members and local businesses within the traditional territory, and provide an opportunity open a path to critical minerals development in the McFaulds Lake area.

Throughout project development, the proponent has made the commitment to achieve sustainable outcomes through:

• Taking a long-term planning approach to planning (preliminary engineering, engagement and consultation, assessment of alternative means to the undertaking) (Section 3);
• Implementing Seven Generations teachings via community plan development (Section 26.4);
• Commitments to improving the quality of life for present and future generations (Section 26.7.2);
• Developing climate resilient infrastructure, as assessed through climate resiliency assessment (Appendix I);
• Assessing and mitigation planning to minimize environmental impacts to air, water, land, vegetation, fish and wildlife (Section 6 to 13);
• Assessing and mitigation planning to minimize impacts to land use, historic and cultural impacts (Sections 16, 19, 20);
• Assessing and mitigation planning to minimize impacts to social, economic and health (Section 14, 15, 17, 18);
• Assessing and mitigation planning to address the potential for cumulative effects (Section 21); and
• Mitigation Measures and Construction and Operations Environmental Management Plans in Appendix E of the Draft EAR/IS.

26.6                 Evaluation of Alternatives to the Project

As part of Project development, in accordance with the requirements of the IAA and Ontario EAA, the Project Team undertook an evaluation of alternatives to the Project. The evaluation process ultimately led to the preferred development corridor, which became the subject of the current EA/IA process.

The initial identification of alternate concept-level corridors was based on results from previous studies (Section 3), as well as years of joint community-based land use planning work conducted by Webequie First Nation in collaboration with the

Ministry of Mines and Ministry of Natural Resources (MNR). The land use planning process incorporated and documented land utilization patterns, sites of Indigenous cultural significance, and historical and current traditional practices to establish a Webequie Community-based Land Use Plan (2019).

With the CBLUP, Webequie First Nation is bringing forward concepts of land use planning that date back several generations that involve consideration of the community. These concepts are the foundation for Webequie First Nation’s current vision for planning, based on dialogue that has taken place for many generations regarding land use, opportunities and benefits, and protocols and teachings handed down from their ancestors. Among the concepts is the development of an all-season road to connect communities in the north and the support resource-based economic development in the mineral sector.

Criteria for the development of the alternate corridor concepts included whether the corridor is a viable solution to issues faced by the community; social and economic benefits; impacts to the environment; technical feasibility and proven technologies; consistency with other planning objectives, policies or decisions; consistency with government priority initiatives; and capital and operating costs. Table 3-6 in Section 3 of the EAR/IS displays a comparative analysis of the alternate road corridor concepts with respect to the socio-economic environment, cultural heritage and resources, the built environment, the natural environment and technical considerations (cost and constructability).

On conclusion of the alternatives assessment, Alternative Concept 2C was selected as the preferred corridor alternative based on the following rationale:

• Intersecting fewer known traplines;
• Route is further east and away from significant hunting areas (e.g., waterfowl, moose, etc.) well used by community members;
• Runs east of areas used most intensively for traditional activities south of the community;
• Minimizes intersecting significant moose mating areas located south of the community and north of the proposed east-west section of corridor;
• Minimizes effects to known built heritage resources/cultural heritage landscapes (i.e., cabins, hunting blinds, sacred site);
• Minimizes impacts to Webequie First Nation Reserve lands;
• Minimizes the number of waterbody crossings required;
• Minimizes potential effects to fish and fish habitat, as it has fewer waterbody crossings and shortest route length where structures are required to cross waterbodies; and
• Has the lowest estimated capital cost for construction.

26.7                 Sustainability Principles

The following subsections discuss the EAR/IS in consideration of the sustainability principles developed for the purpose of meeting the requirements of the Impact Assessment Act:

• Principle 1:       Consider the interconnectedness and interdependence of human-ecological systems;
• Principle 2:       Consider the well-being of present and future generations;
• Principle 3:       Consider positive effects and reduce adverse effects of a designated project; and
• Principle 4:       Apply the precautionary principle and consider uncertainty and risk of irreversible harm.

26.7.1             Principle 1: Interconnectedness and Interdependence of Human-Ecological Systems

Webequie First Nation describes the land within the Project, through community planning, as rich in natural resources and a largely remote wilderness environment with abundant cultural and natural values (CBLUP, 2019). It is an intact cultural and natural landscape. All biophysical components of the environment are functioning and productive, including the air, water, and land. The lifecycle needs of fauna and flora within the region are interconnected and dependent on the natural resources of the surrounding areas.

Healthy rivers and lakes are a cultural and spiritual necessity for the Anishinawbek as well for all beings (CBLUP, 2019). Niibee (Water) gives life to the people and the beings upon which Anishinawbek depend for their way of life. The Anishinawbek see water as gift from Keyshay-Maniido (Creator). The series of lakes, wetlands and interconnected streams and rivers in the area support healthy fish and wildlife populations that, in turn, sustain the people. These waterways are central travel routes for Anishinawbek as they continue to practice their traditional way of life. Niibee is also a medicine used for the well-being of the individual.

Watershed flow and function, including maintaining healthy water systems and the life that they support is critical to the social, cultural and ecological environment.

As illustrated in Figure 26.1, relationships exist between the Project VCs in alignment with Webequie First Nation views on the human-ecological interconnectedness and interdependence with lands, water, fish and wildlife populations and natural resources.

For those VCs that may interact with the potential effects of the Project, these effects are not mutually exclusive but can have a cascading effect on other VCs either positively or negatively within a complex human-ecological system. These effects can be temporary in nature or persist into future generations, while recognizing that there is a degree of uncertainty in the magnitude or severity of the potential effect on a VC. This view on human and natural world interconnectedness is demonstrated in the EAR/IS in the assessments for many of the VCs, the VC-VC linkages and the pathway of effects related to the Project.

Figure 26.1: Interdependence and Interconnectedness of Valued Components within a Human-Ecological System

As an example, Human Health VC (Section 17) integrated the findings of the Country Foods Assessment, Human Health Risk Assessment and Health Impact Assessment. These studies were informed by Project studies on nine separate VCs, each with a pathway(s) of effects that link ultimately to human health:

Figure 26.2 illustrates an effect pathway from other VCs that could result in an adverse effect on the Human Health VC.

Figure 26.2: Interconnectedness of VCs with the Human Health VC

26.7.2             Principle 2: Well-Being of Present and Future Generations

The CBLUP (2019) discusses future use (Neegaan Aneekoo Pii-Mah-tii-si-win) in which Webequie First Nation envisions a future when community and cultural prosperity is built through integrated economic and cultural revitalization. It is a future when the principles, traditional protocols, culture and customary land-based knowledge of Webequie people are revived and brought forward to the next generation through education and practice. Through cultural and economic revitalization, the well-being of present and future generations can be improved. To do so, it is important to remember past land use and past way of life (Weh-shk-ach Pii-Mah-tii-si-win), as well as maintain current land use and the current way of life (Nohngohm Pii-Mah-tii-si-win).

Webequie Anishinniwk moved freely on the land and were organized according to the ‘dohdem’ (clan) system (CBLUP, 2019). The dohdem group is similar to a family group, but more encompassing than the current familial relationship system. The dohdem group made their livelihood within a particular area and held responsibility to care and maintain the area. The traditional territory system of the dohdem is not defined by rigid boundaries or exclusive use. In this customary system, people respected each other, shared the resources and lived by the Creator’s principles. Because of its traditional origins, Webequie Anishininniwuk hold familial ties to several other Northwestern Ontario communities (CBLUP, 2019). The people of Webequie rely on the richness of their resources to sustain all ways of life, including for food and economic livelihood.

Commercial activities, such as trapping and fishing, historically complemented traditional livelihoods and supported a land-based economy (CBLUP, 2019). Changes in market demands greatly diminished these traditional sources of income resulting in a loss of culture and the obligation to Webequie Anishinniwk stewardship responsibilities by way of wage-based income for sustainable living. To engage in traditional activities in current times requires reliance on modernized methods of transportation which are costly in a remote northern setting (CBLUP, 2019).

The influence from western society has affected the ability of First Nations to practice customary traditional culture and the ability to pursue traditional practices. For example, currently children attend school five days a week and families must maintain residence and find sources of income in the community so that children can attend school, as opposed to exercising customary livelihoods on a more frequent basis. Employment demands in the community leave limited opportunities to get out on the land.

Youth and other community members are also exposed to other influences that distract from a land-based livelihood. In recent times, substance abuse has resulted in severe challenges to exercising a traditional way of life; causing social trauma and removing the ability and desire to go out on the land.

The landscape and natural environment are also changing. Factors such as climate change have resulted in impacts to travel conditions and the availability of plants and animals at certain times of year. This has affected harvesting patterns, particularly in the spring and fall, and disrupted the traditional way of life.

The addition of the WSR to the region is a means to maintaining and improving the well-being of the present and future generations. The implementation of all-season roads in the region will result in the movement of people between communities and enable a more integrated economy. The supply of goods and services becomes more accessible which potentially improves affordability within the communities. Access to health and medical services can also

improve, with the WSR and other roads creating another travel option for citizens but also creating the opportunity for new health services to be established within northern communities. With improved access to health and medical services, health outcomes for northerners also improves.

Cultural revitalization can be fostered with the Project. The proposed road would improve travel conditions, providing the opportunity for community members to pursue traditional practices and get onto the land with greater ease, rather than sole reliance on alternate modes of transportation that may require more navigation effort (e.g., UTV, snowmobile, aircraft, watercraft). Dohdem groups and familial ties can also be revitalized by enabling more frequent visits to family members in neighbouring communities through road travel, as opposed to reliance on other modes of transportation, e.g., air travel, UTV.

With the implementation of the WSR, Webequie First Nation has committed to implementing several social enhancement plans aimed at readying the communities for the Project – through education, training, improvements to critical infrastructure, civil and community services. This includes implementing or establishing:

• The Community Readiness Plan (Appendix N of the Draft EAR/IS);
• Measures to enable new or improved housing within the community;
• Project employee-specific housing to offset housing demands within the community;
• The Community Well-Being Monitoring and Adaptive Management Plan;
• A dedicated childcare or drop-in centre;
• On-reserve and on-the-job training for prospective trainees, including supports to facilitate education and training program delivery;
• Pre-employment training;
• New and upgraded facilities for primary to secondary education, mental and physical health, community centres; and
• Other measures as identified in Section 14 or the EAR/IS.

These social enhancement plans and initiatives have linkages to the issues of importance to Indigenous communities and groups, VCs for the Project and the community plans developed by Webequie First Nation (Section 26.4). It is through these plans that the Project aims to revitalize the Webequie and other local communities and improve the well- being of present and future generations.

26.7.3             Principle 3: Consider Positive Effects and Reduce Adverse Effects

Section 5 of the EAR/IS describes the overall environmental assessment methodology for the Project which includes steps to identify positive effects and adverse effects of the Project on VCs, as well as the identification of mitigation and enhancement measures. To identify the Project effects, the Project Team undertook a scoping exercise to determine the VCs that would be most relevant to the Project and the affected communities. The selected VCs were defined through community engagement, Elder knowledge, professional judgement and western science research.

Furthermore, relevant study area boundaries for each VC were delineated to support the assessment of the Project’s adverse and positive effects.

The Project assessment has identified both adverse and positive effects on all VCs. Through the EAR/IS, Webequie First Nation has committed to implementing a suite of mitigation measures and design considerations aimed at reducing adverse effects from the Project, utilizing the mitigation hierarchy (avoidance, minimization, restoration and offsetting). These mitigation measures and design considerations are described in detail within the VC-specific chapters and appendices but generally include the following:

• Best management practices, technically proven and economically feasible mitigation measures;
  • Federal and provincial standards and codes (see Section 4.2.1) are used to design the Project to eliminate or reduce potential adverse effects;
  • Preliminary Engineering Report (Appendix D-1) provides an overview of technical and environmental considerations for carrying sustainability objectives into the Project’s final design;
  • Climate resiliency assessment of the preliminary design (Appendix I – Climate Change Resilience Report);
  • Project-specific mitigation measures to address adverse effects on environmental, health, social and economic effects;
  • Mitigation measures proposed by Indigenous Peoples and the consideration of these measures within the Project design;
  • Mitigation measures and programs to address disproportionate Project effects on subpopulations such as women and girls, youth, Elders, 2SLGBTQQIA (two-spirit, lesbian, gay, bisexual, transgender, queer, questioning, intersex and asexual) individuals;
  • Social enhancement plans and the Community Readiness Plan (Section 26.7.2 and Section 14.4);
  • Application of sustainable practices in the construction contract specifications (e.g., sustainable procurement practices, reduction of construction waste, water quality monitoring, erosion and sediment control protections, etc.); and
  • Implementation of an Environmental Management Plan during Construction and Operation phases with sustainability objectives, metrics, and targets, as well as monitoring and reporting processes, and adaptive management.

Positive effects have been identified through the Project assessment. The positive effects have been incorporated into commitments within the CRP (Appendix N of the Draft EAR/IS) to maximize Project benefits for the communities under these themes:

• Improving community health and wellness, and family and social conditions;
  • Improving education and training opportunities;
  • Improving housing and infrastructure;
  • Developing and maintaining the economy;
  • Maintaining and enhancing environmental quality, and the human-ecological relationship with the land;
  • Improving cultural vibrancy and traditional life; and
  • Improving community leadership and governance.

Some of the anticipated positive effects of the Project include:

Social

• A population increase in the LSA communities from potentially returning community members to access training.
  • The retention of resident community members because of new training and job opportunities specific to the Project and other industry opportunities.
  • The potential for the construction of new homes and permanent accommodations as part of the Community Readiness Plan to have available and affordable housing for returning community members and to alleviate the current demand for on-reserve members.
  • New community l infrastructure and services to address inequity and gender-based gaps in current services and prepare for increased demands of those services from newcomers (permanent and temporary).

• An improved movement of people and families between the communities with a new all-season road and assumed connection to other roads in the region. This improvement enables the strengthening of familial and cultural ties.

Education

• An increase in education and training programs both on and off-reserve, including facility space to prepare the prospective employees for the types of occupations necessary for the construction and operation of the Project.
  • Supports to improve current educational facilities from the primary to post-secondary level to address current space and availability challenges experienced by the local populations.

Economic

• An improved economy during the construction phase. Other industries and services will be required to accommodate a potential population influx including but not limited to healthcare, recreational services, hospitality (hotels, restaurants, entertainment).
  • An improved economy during the operations phase. It is anticipated that these industries and services would be maintained with the more people, goods and services utilizing the new road. Recreation, forestry, mining and other industries would benefit from the presence of an all-season road. This would create more job opportunities for northern residents.

In a broader context, the Project is also relevant to long-term provincial growth as it contributes to the development of multimodal transportation initiatives in the region. Furthermore, the 35 m right-of-way (ROW) offers the future opportunity to accommodate utilities such as a communications broadband fibre optic line and low voltage power distribution lines that could bring additional economic development, education and health benefits to the region.

26.7.4             Principle 4: Precautionary Principle and Consideration of Uncertainty and Risk of Irreversible Harm

In applying the precautionary principle within an environmental assessment framework, a proactive approach is commonly taken in protecting VCs to prevent irreversible harm, which may include circumstances of high uncertainty or low confidence in the assessment conclusions or efficacy of established or novel mitigation strategies. Throughout the EAR/IS, several examples of the application of the precautionary principle are evident.

Coordinated Environmental Assessment. By virtue of legislative requirements, Webequie First Nation has undertaken a comprehensive EA/IA process, covering both provincial and federal requirements under the Ontario Environmental Assessment Act (EAA) and the IAA. The Ontario-Canada coordinated approach ensures that both government bodies assess those aspects of the biophysical, socio-economic, health, cultural values that are required for procedural steps. For instance, for this Project, federal impact assessment process focuses the assessment on:

• Fish and fish habitat as defined under the Fisheries Act;
  • Aquatic species as defined under Species at Risk Act;
  • Migratory birds as defined under Migratory Birds Convention Act;
  • Adverse environmental effects on federal lands (including First Nation reserve lands);
  • Adverse effects on Indigenous Peoples in relation to changes in physical and cultural heritage; current use of land and resources for traditional purposes; objects of archaeological, paleontological, historical or architecturally significance;
  • Changes in health, social or economic conditions of Indigenous Peoples; and
  • Changes in health, social and economic matters.

Under the provincial Environmental Assessment (EA) process, MECP administrators of the Ontario EAA are to assess Project effects related to4:

• Air, land or water;
  • Plant and animal life, including human life;
  • The social, economic and cultural conditions that influence the life of humans or a community;
  • Any building, structure, machine or other device or thing made by humans;
  • Any solid, liquid, gas, odour, heat, sound, vibration or radiation resulting directly or indirectly from human activities; or,
  • Any part or combination of the foregoing and the interrelationships between any two or more of them.

There is significant overlap in the scope of review for provincial and federal regulators. Conversely, each regulator may have areas of review that are not within the purview of the other. Federal-Provincial coordination of the environmental assessment process ensures a robust and comprehensive assessment of major projects like the Webequie Supply Road Project.

Conservative Approach and Mitigation Strategies. Webequie First Nation adopted a conservative approach when assessing the Project’s potential adverse effects on VCs, outlining uncertainties in analysis and assumptions of the analysis. To address Project effects and associated uncertainties, a robust mitigation hierarchy was applied to each VC which established impact avoidance as a priority, and social or environmental offsetting of any residual impact (i.e., after the application of mitigation strategies) as a last measure.

All VCs have a set of mitigation measures proposed for both construction and operations phases of the Project. Mitigation measures included technically feasible and established protection measures, best management practices, VC-specific mitigations. Further to these, Webequie First Nation has committed to establishing and implementing separate Construction and Operations Phase Environmental Management Plans (CEMP and OEMP) to address potential effects of the Project.

The mitigation strategies proposed within the VC assessments included input from engagement with Indigenous communities and groups, the public, government agencies, and stakeholders in accordance with the guidance and requirements outlined in Section 20 of the TISG for the Project.

Monitoring Programs. To further address uncertainties in certain VC assessments and assess the effectiveness of mitigation strategies, Webequie First Nation has proposed to implement environmental monitoring programs during construction and operations. A few of the monitoring programs are listed:

• Culvert monitoring;
  • Surface water and sediment quality monitoring;
  • Construction environmental monitoring (e.g., erosion and sediment control, etc.);
  • Well water sampling;
  • Groundwater level monitoring;
  • Annual aquatic eDNA monitoring; and
  • Long-term Fish Habitat Offsetting monitoring.

4   https://www.ontario.ca/document/preparing-and-reviewing-environmental-assessments-ontario-0#section-0

Adaptive Management. As part of project execution, Webequie First Nation will take an adaptive management approach to assess the performance of the social enhancement plans identified in the CRP and Section 14. Webequie First Nation has emphasized the desire to improve community health, safety and well-being equitably across all residents and citizens and is in the process of developing a Monitoring and Adaptive Management Plan to track key parameters such as pressures on the community. The plan will assess existing service use and demand, identifying Project-related needs that may require additional mitigation (e.g., expanding community services).

Monitoring community well-being is essential for the enhancement of project benefits and to support the Webequie community’s future objectives (Section 26.7.2). The adaptive management approach can be used to provide direction for iterative Project design and monitoring plan refinements through continuous monitoring of specified social parameters. The Project adaptive management approach will be able to:

• Identify whether the sub-working group actions are achieving the desired changes and results for the community;
  • Review efforts and determine alternative actions for desired changes that are not being realized or positively affecting the community or subpopulations of the community;
  • Provide documentation of requests for new or additional support to overcome obstacles;
  • Review and optimize allocation of resources / re-focus priorities;
  • Demonstrate to the community, efforts that have adapted or responded to desired or newly emerging goals; and
  • Foster and strengthen community engagement and trust and transparency that is aligned with various community interests.

26.8                 Conclusion

Webequie First Nation has taken into consideration the sustainability principles outlined in the TISG and the Webequie First Nation CBLUP (2019) throughout Project planning. For nearly a decade, Webequie has engaged communities and stakeholders on their issues of importance which established the basis of VC selection for the EA/IA and studies that have taken place to date.

The precautionary principle was applied to the EA/IA, utilizing best practice in environmental assessment methods, recognition of interdependencies and interconnectedness between the VCs, consideration of adverse effects and the application of the mitigation hierarchy for all VCs, identification of positive effects through Webequie First Nations’ commitments to social enhancement programs for community well-being and safety. Furthermore, through the assessment of alternative means and preliminary engineering, Webequie has arrived at a preferred route that has measurably factored in social and economic benefits, impacts to the environment, impacts to culture and Aboriginal and Treaty Rights and Interests (ATRI). These criteria were prominent in selecting the preferred route of the Project and were in keeping with the CBLUP (2019).

Webequie First Nation is committed to sustainable development on this Project by facilitating economic growth in the region; preserving natural resources and achieving biodiversity net gains; creating educational, training and employment opportunities for the local communities to meet the economic demand; and enhancing the health and social well-being of community residents through an improved economy.

26.9                 References

AtkinsRéalis. 2024. Webequie Supply Road Project: Consultation Progress Report – Round 3. Prepared for Webequie First Nation. Accessed January 2025. Available at: https://www.supplyroad.ca/wp- content/uploads/2025/01/661910_20241101_WSR-Consultation-Progress-Rpt-No.-3.pdf. Pp. 123

Borrows, J. 2008. Seven Generations, Seven Teachings: Ending the Indian Act. Research Paper for the National Centre for First Nations Governance. Accessed January 2025. Available at: https://fngovernance.org/wp- content/uploads/2020/05/john_borrows.pdf. pp 34.

Clarkson, L, V. Morrissette and G, Regallet. 1992. Our Responsibility to The Seventh Generation. Indigenous Peoples and Sustainable Development. pp 92. Accessed January 2025. Available at: https://www.iisd.org/system/files/publications/seventh_gen.pdf

Impact Assessment Agency of Canada (IAAC). 2020. Webequie Supply Road Project – Tailored Impact Statement Guidelines. Available at: https://iaac-aeic.gc.ca/050/evaluations/document/133938?culture=en-CA

Impact Assessment Agency of Canada (IAAC). 2021. Guidance: Considering the Extent to which a Project Contributes to Sustainability. Available at: https://www.canada.ca/en/impact-assessment-agency/services/policy- guidance/practitioners-guide-impact-assessment-act/guidance-considering-extent-project-contributes- sustainability.html

Ministry of the Environment, Conservation and Parks (MECP). 2018. Preserving and Protecting our Environment for Future Generations – A Made-in Ontario Environment Plan. Accessed January 2023. Available at: https://prod- environmental-registry.s3.amazonaws.com/2018-11/EnvironmentPlan.pdf

Ministry of Industry. 2018. Building Better Lives: Ontario’s Long-Term Infrastructure Plan 2017. Accessed: January 2025. Available at: https://files.ontario.ca/ltip_narrative_aoda.pdf. Pp. 160.

Ministry of Northern Development, Mines and Forestry and Ministry of Infrastructure. 2011. Growth Plan for Northern Ontario, 2011. Accessed: January 2025. Available at: https://www.ontario.ca/document/growth-plan-northern- ontario

Poulton, D.W. and J.C. Ray. 2023. Knowledge, Perception and the Application of the Mitigation Hierarchy Among Officials in Canadian Federal Regulatory and Resource Management Agencies. Wildlife Conservation Society Canada and the Impact Assessment Agency of Canada. Accessed March 2025. Available at: Knowledge_Perception_and_Application_of_the_Mitigation_Hierarchy_Among_Officials_in_Canadian_Federal_ Regulatory_and_Resource_Management_Agencies.pdf. Pp. 63.

Seven Generations Education Institute. 2021. Seven Grandfather Teachings. Accessed January 2025. Available at: https://www.7generations.org/seven-grandfather-teachings/

United Nations Department of Economic and Social Affairs. Sustainable Development. The 17 Goals. Accessed: April 2025. Available at: https://sdgs.un.org/

Webequie First Nation. (2019). Draft Community Based Land Use Plan (CBLUP). Internal Document Review. Webequie First Nation. (2023). Comprehensive Community Plan (CCP). February 2023. Internal Document Review.