Regional Planning

There are limited transportation options in the far north in Ontario. Most of the First Nations in the region are remote, accessible only by air or ice road in the winter.

This has led to two First Nations — Webequie and Marten Falls — taking the lead as proponents on three segments of a road that would connect the communities and what mining companies are calling the Ring of Fire mineral region to the provincial highway network.

Leaders in the two First Nations say year-round road access promises an improvement in health and social services, better access to materials for infrastructure development, economic opportunities like mining jobs, and an overall improved quality of life for community members.

“That access road would provide for better lives in our community because we would have 24-hour transportation to another community for health reasons, or for education, employment and training, and the list goes on.”

 

— Marten Falls Chief Bruce Achneepineskum told the Canadian Press in a 2023 interview

The proposed road has garnered a significant amount of media attention and opposition from other First Nations leaders, who fear significant development in their homelands without their consent will forever affect their way of life — including by polluting the lands and waters, and harming the fish and animals in the area.

Notably, Neskantaga has repeatedly and publicly criticized the ongoing process to plan and assess the possible impacts for the road. Several successive chiefs from the First Nation have declared that they will not let any roads be constructed through their homelands without their explicit consent.

The leaders from several other First Nations in the Treaty No. 9 territory — including Attawapiskat, Fort Albany, Kashechewan, Eabametoong, and Kitchenuhmaykoosib Inninuwug — have expressed concerns about the way development is moving forward in the Ring of Fire, and their exclusion from decision-making processes.

While the chiefs of Marten Falls and Webequie have said the first priority of road access is to improve the quality of life and socio-economic conditions in their communities, any mining extraction in  the area that is known as Mammamattawa to local First Nations, and as the Ring of Fire to mining companies, is contingent upon year-round access.

Since the initial discovery of minerals, governments and mining companies have discussed different options to expand year-round transportation access into the remote region, including railroads and highways. At this point, the proposed road — which has been divided into three segments — is the furthest ahead in terms of planning, and each of the three segments are now going separately through provincial and federal assessment processes.

Read more about the three proposed road segments here:

Marten Falls Community Access Road

  • Marten Falls proposed this 190 to 230-kilometre road segment in 2018, with the goal of improving community well-being by providing year-round access to the First Nation. The road will connect the community to the provincial highway network beginning near Aroland First Nation and Nakina, ON. The terms of reference for the provincial environmental assessment were approved in October 2021, and studies as part of that assessment are now underway.

Webequie Supply Road Project

  • This 107-kilometre road section was proposed in 2018 by Webequie First Nation to connect the community airport to the proposed mineral exploration and extraction projects in the McFaulds Lake region of the Ring of Fire. The purpose is to create employment and economic development opportunities for Webequie community members, and to help move materials, supplies and people into the mineral-rich region. The terms of reference were approved by the province in October 2021, and an environmental assessment is now underway.

Northern Road Link

  • Years after the first two road segments were introduced, Marten Falls and Webequie jointly proposed in 2020 to build, operate and maintain a 117 to 164-kilometre road. The all-season, multi-use road would connect the Marten Falls Community Access Road and the Webequie Supply Road, creating year-round access to Webequie and the Ring of Fire mining development area. The terms of reference for a project assessment was approved in March 2023, and the environmental assessment is now underway.

Environmental & Impact Assessments

As part of their work to create economic growth in northern Ontario, the provincial government has supported, funded, or approved several major infrastructure projects that are either proposed or in active construction — from the Wataynikaneyap Transmission Line, to proposed hydroelectric power projects, and an all-season transportation corridor into what is being called the Ring of Fire region.

Many of these major projects will inevitably have environmental and social impacts, and are thus subject to provincial environmental assessments — and sometimes federal impact assessments. These assessments are planning and decision-making tools used by governments to assess the potential positive and negative effects of a proposed project.

While the scope and length of time to complete an environmental or impact assessment varies considerably depending on the project, they generally follow the same process.

1

Intention to conduct project declared by proponent

2

Draft terms of reference for the scope of the assessment is completed and circulated for consultation

3

Final terms of reference are approved by government and the assessment begins

4

A draft assessment, with potential positive and negative effects of the project, and suggested mitigation measures, is published and circulated for consultation and review by government

5

Final assessment is submitted to government, and the relevant minister or cabinet makes a final decision if the project will be granted an environmental or impact assessment approval. A project that is subject to assessment cannot go ahead unless it has obtained approval, as well as any other required licenses and approvals. 

6

If project goes ahead, agreements are reached for funding, contracting and project implementation

Garth Lenz/The Narwhal

In the Ring of Fire area in northern Ontario, the three proposed segments of the new road are subject to both provincial environmental assessments and federal impact assessments. This means that there are currently six individual, project-based assessments underway related to the one road. Diving the road into these segments means that the full cumulative impacts of what is effectively a single road aren’t captured in any of the individual project-based assessments.

It is expected that the assessments will take years before they are ready for review and a decision about whether and how construction can begin.

Additionally, two proposed mining projects — the Cliffs Chromite Project and Noront Resources Eagle’s Nest nickel project — had begun federal impact assessments. Those have since been terminated, as of 2015 and 2019, respectively, according to the Impact Assessment Agency of Canada’s registry.

Ontario’s environmental assessment into the “Eagle’s Nest Multi-metal Mine” has not officially been terminated, although there has not been a public update on the assessment since 2015, when the terms of reference were approved.

The problem with these assessments is that they are all focused on individual projects. They do not look at the broader, cumulative impacts that will come from all of the proposed development projects.

For years, First Nations, scientists, and provincially appointed expert panels have warned this uncoordinated approach is simply not acceptable, given the size and importance of the region. It’s a place where ecosystems are still shaped by dynamic predator-prey relationships, where species at risk hold onto a last refuge, where 35 billion tonnes of carbon are stored within some of the world’s largest boreal forest and peatland areas.

Read more about major developments and assessments in the Ring of Fire

In 2019, the federal Impact Assessment Act was passed and created the legislative framework for regional assessment, which is a region-wide planning approach that can assess cascading and cumulative effects of resource and infrastructure projects in key regions. The Act established a federal decision-making process for the development of large projects across Canada, and allows for the federal government to conduct the assessments alone, or in partnership with other jurisdictions like a province or an Indigenous governing body.

If thoughtfully developed, a regional assessment is more likely to lead to positive outcomes by better understanding and reducing risks of development to the environment, people and the economy. To be successful, it requires a proactive, participatory approach that engages decision makers like governments and First Nations, and other stakeholders like local communities, NGOs and industry. Collectively, these groups can discuss and determine what the future of the region should look like, and how we can get there.

In 2020, Canada’s Minister of Environment and Climate Change announced there would be a regional assessment for the Ring of Fire region because of concerns about cumulative effects of multiple, major infrastructure projects in the area. This announcement came following three separate requests by Aroland First Nation, WCS Canada, and the Osgoode Environmental Justice and Sustainability Clinic.

The process was quickly criticized, after the federal government drafted a terms of reference for the regional assessment without meaningfully including First Nations. The federal minister withdrew the draft terms of reference, and a new draft is expected to come in early 2024 following consultations with First Nations in the region.

The Impact Assessment Act is being amended after the Supreme Court of Canada ruled parts of the legislation were unconstitutional and overstepped federal jurisdiction. However, the Impact Assessment Agency of Canada said it will continue its work on assessments already underway at the time of the court ruling, including both project-level assessments and the regional assessment into the Ring of Fire region.

Land Use Planning

In addition to the project-level and regional assessments that are ongoing, the Ontario government has an assortment of policies and legislation that affect the governance and planning processes for the lands and waters of the far north in Ontario.

 

Read more about the provincial policies governing land and waters in northern Ontario

Ontario Public Lands Act, 1990

  • All public lands and forests are regulated by this legislation, which offers a guideline for the use, management, sale and disposition of the resources. It also regulates land-use planning and development, public and private roads on public lands, and empowers the province to construct and operate dams on waterways. Howewver, this Act does not apply to community-based planning on Crown lands in the far north in Ontario under the Far North Act (see below).

Ontario Far North Act, 2010

Ontario Mining Act, 1990

Ontario Crown Forest Sustainability Act, 1994

  • The stated purpose of this law is to ensure the long-term health of the forests in Ontario, and to manage “Crown forests” in a way that balances the social, economic and environmental needs of the province. It breaks the province into a network of forest management units, and requires a forest management plan to be prepared and approved before any forestry activities can happen. In recent years, forestry regulations have been amended to include forest management units in the far north, including small-scale community-based forest management plans.

Ontario Environmental Assessment Act, 1990

  • The purpose of this legislation is to protect, conserve and manage Ontario’s environments, and requires infrastructure and resource development projects to undergo an environmental planning process. The planning must assess the potential effects of certain public-sector projects — such as a proposed road — on natural, social, cultural, economic and built environments. Ontario is the only Canadian jurisdiction in which environmental assessments are generally not required for private-sector projects, meaning that mines rarely are subject to provincial assessments. There is a public consultation process that gives First Nations, organizations and individuals the opportunity to voice their perspectives on a proposed project — but it is ultimately the provincial cabinet that decides whether a project is granted approval. A key problem with the Act is that it requires only project-level assessment and does not require the assessment of the cumulative impacts of multiple projects in one area. 

Ontario Fish and Wildlife Conservation Act, 1997

  • This legislation relates to the conservation and management of fish and wildlife resources in the province, regulating licenses and activities of hunting, trapping and fishing, as well as the purchase and transport of fish and wildlife. It also includes a list of specially protected species and those that can be hunted, trapped or fished. This law largely applies to non-Indigenous People, as Indigenous Peoples in the province are permitted to hunt, trap, fish and gather under treaty rights.

Ontario Water Resources Act, 1990

Ontario Lakes and Rivers Improvement Act, 1990

  • Focused on surface water resources, this law applies to how companies and people can use Ontario’s lakes and rivers. It also includes restrictions for what can be deposited into lakes and rivers that may impact water quality or quantity, and addresses the construction, repair and use of dams. The legislation requires hydro power facilities to create water management plans to ensure environmental, social and economic concerns are addressed.

Ontario Aggregate Resources Act, 1990

There have been previous efforts towards regional planning. For example, there was a Far North Land Use Strategy that was mandated under the Far North Act, 2010 to address broader issues such as cultural heritage, biological diversity, freshwater, cumulative effects, and climate change. 

However, the draft Far North Land Use Strategy was never finalized or released to the public. There is still no comprehensive strategy from Ontario that looks at how to manage development and cumulative effects in this vast, intact region. Instead, in 2021, Ontario eliminated the requirement to prepare a Far North Land Use Strategy.

Cumulative Effects

Across Canada, and especially in the area that is being called Ring of Fire by mining companies, there is growing recognition about the cumulative effects of resource and infrastructure development.

Experience elsewhere shows that once a road is built that provides basin-opening access, industrial growth — such as infrastructure, mining, and other extractive projects (e.g., gravel for road building materials) — will follow. This produces cumulative impacts. It is therefore important that potential cumulative impacts in the region be carefully considered in advance — through scenario analysis, for example — so that the design, pace and scale of any development can be well-planned.

Garth Lenz/The Narwhal

Highway 60 running through Algonquin Park

Photo credit: Dimana Kolarova / Creative Commons

The cost to build the proposed road into the area known as Mammamattawa to local First Nations, and as the Ring of Fire to mining companies, will be in the billions of dollars. Governments and companies alike will seek to pay off that investment through additional mines and resource extraction projects.

There is already growing interest by mining companies in lithium deposits further west in the far north in northern Ontario — but access to the projects are dependent on the construction of additional roads through the region. Similarly, there are proposed hydroelectric projects in remote regions of Ontario — again, dependent on all-season roads.

Growing road networks will open up opportunities to explore for more mineral deposits, and increase access for recreational hunters and gatherers.

“Attawapiskat First Nation is aware that the western worldview in which you operate has great difficulty understanding cumulative impacts because it is too linear and fragmented and fails to consider the lands in a holistic and circular manner, as we do, however, your difficulty in understanding our perspective is not an excuse to fail to address our concerns.”

 

Attawapiskat Chief David Nakogee wrote in a 2022 letter to the Ontario government

This kind of creeping industrial activity will have cumulative effects on the health of the lands, waters, wildlife, plants and people living in northern Ontario. It will compromise the ecological integrity of the region through habitat fragmentation and degradation, disturb valuable peatlands, and will likely worsen the climate crisis.

The regional assessment mechanism under the federal Impact Assessment Act offers the best approximation of a comprehensive assessment that can be conducted in advance of any project developments. Throughout the history of Canada, including in recent resource extraction projects, governments and industry have demonstrated a failure to advance industrial activity without irreparably altering the delicate balance of local and global ecosystems. Now is the opportunity to avoid this for Mammamattawa.

As the Ontario and Canadian governments continue to push forward on opening up the Ring of Fire region, we are left with one question: what will we sacrifice in the name of economic growth?

Resources & Toolkits

In the face of growing development pressures in the northern half of Ontario, WCS Canada is working with our partners to protect the region and its significance for biodiversity and climate change. Stay up to date with changes in northern Ontario, and take action to help us protect and conserve wildlife and ecosystems in the region.