MCCN Review of responses to IR 1 Package 3

Hello Stephen,

Apologies for the delay in getting this to you.

The responses from Alamos are largely inadequate, and MCCN submits that they should be sent back to Alamos for further response, as set out in the chart.

Our main concerns are summarized below. Please let me know if you have any questions.

• Effects characterization: Alamos’ characterization of effects for vegetation and wildlife VCs lacks important detail. Indirect effects, for example, have been poorly characterized and a quantification of these impacts are lacking in many of Alamos’ responses. For some species, such as moose, the characterization of direct effects is insufficient and lacks consideration of key or limiting habitat types. As a result, MCCN is concerned that the direct and indirect effects to these terrestrial VCs have been severely underestimated.
• Significance determination: From MCCN’s perspective, the thresholds of significance for plant and wildlife VCs are not consistent with the precautionary approach and may be insufficient to capture downstream impacts to Indigenous rights and interests. Effects to wildlife and wildlife habitat, for example, were only considered significant if it threatened the viability of wildlife and wildlife habitat within the RAA, or the survival and recovery of SAR and SOCC. Localized impacts to traditional harvesting practices, however, may be experienced before a species is no longer viable within the RAA. This threshold of significance places plant and wildlife species, and associated Indigenous rights and interests, at an inappropriately high risk.
• Environmental management and monitoring: Overall, the information provided to date on mitigations, monitoring, restoration, and adaptive management is very general. The details of how mitigation, monitoring, habitat restoration and follow-up activities will be accomplished are very important and must be subject to careful review by Indigenous Groups. MCCN requests that Alamos identify a process (including sufficient funds for engagement and review) for incorporating community-based monitoring, including observations of impacts and concerns, into continued monitoring and adaptive strategies. MCCN requests that triggers and thresholds for management actions are informed based on traditional use and Indigenous knowledge, as well as scientific information where available and that the adaptive management framework for each plan be developed utilizing Indigenous input.
• Offsetting: Offsetting measures for residual Project effects are notably lacking. This is inconsistent with provincial and federal regulations, such as the Manitoba government’s “no net loss” approach to wetlands (Sustainable Waters Act, June 2018), and the Federal Wetland Policy (1991). Offset measures must include consideration of equivalency, uncertainty, and time lags. 
• Assessment of impacts to Indigenous health and socioeconomic conditions: Alamos has made no meaningful attempt to collect MCCN's health and socio-economic baseline information. Alamos’ claim that no updates to the health and socio-economic assessments are warranted is therefore baseless. In accordance with best practice, MCCN must be provided with the right of first refusal to conduct such studies or, at a minimum, should be directly involved in the design and conduct of such studies.
• Assessment of impacts on physical and cultural heritage and current use of land and resources for traditional purposes: Of particular concern is Alamos repeated claim that MCCN’s TLRUS Report serves to "confirm the assumptions made in the EIS regarding the nature and extent of Indigenous traditional use in relation to the Project” and that “the information shared by Mathias Colomb Cree Nation is consistent with the EIS.” Alamos has made no attempt to incorporate the findings of MCCN’s TLRUS Report into the EIS. Rather, Alamos’ review of the TLRUS Report directs the reader to Alamos’ environmental mitigation and management plans, which have no direct bearing on the results of the MCCN’s study. The TLRUS report identifies multiple current use and heritage values that have the potential to be adversely affected by the Project, but which remain unassessed. The EIS is therefore not consistent with MCCN’s TLRUS Report.
• Assessment methods for current use and Indigenous rights: MCCN has substantial concerns with Alamos’ assessment methodology for current use and Indigenous rights. MCCN has already articulated many of these concerns in comments on the EIS provided to Alamos’ on October 10, 2020, but has not received a direct response from Alamos. Among other issues identified in the appended comments, Alamos has not assessed the full range of potential effects on MCCN’s current use and Treaty and Aboriginal rights, including project effects on MCCN members' knowledge transmission, sense of place, perceived risk, and feelings of safety, all of which are very real impacts that are amenable to assessment using appropriate social science methods. Instead, Alamos relegates these considerations to “narrative” consideration (i.e. documentation of MCCN’s statements but with no assessment of potential impacts). Given Alamos’ demonstrated inability to appropriately assess these effects, MCCN requires sufficient time and funding to carry out its own rights impact assessment of the project.