Implementing a regional, Indigenous-led and sustainability-informed impact assessment in Ontario’s Ring of Fire

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About the project

Development in Ontario’s “Ring of Fire,” a significant deposit of minerals located in a remote far north part of the province, has been on the table for many years. Although successive governments have hyped the value of the resources, the remoteness and lack of infrastructure―as well as the inability of governments to obtain the buy-in of all the First Nations communities in the region―has left the Ring of Fire undeveloped.

Thus, Ontario’s far north remains one of the world’s largest, most intact ecological systems. The boreal forest and peatlands play key roles in regulating the climate. Proposed mining in this region has generated significant controversy and conflict because of the potential for large, possibly serious, negative impacts and cumulative effects because infrastructure developments proposed recently quite literally “pave the way” for multiple mines and generations of extraction.

The proposals are also likely to distribute benefits inequitably and pose risks at a variety of scales: the remote Anishinaabe and Anishini communities and their ways of life are particularly vulnerable. These communities are already in a state of social emergency with youth suicide, addiction and housing crises, as well as a lack of essential community infrastructure, including safe drinking water.

For many years, analysts and First Nations leaders have been calling for a regional process to broadly assess the expected impacts of the proposed developments. They have noted the complexity of the contemplated infrastructure decisions, the potential for lasting negative impacts, and vast cumulative effects. And yet, without this regional framework in place, provincial and federal impact assessment regimes are proceeding to assess discrete road proposals that threaten to open the region up to mining.

This research synthesizes knowledge in a variety of areas, including Indigenous-led impact assessment (IA), regional and strategic approaches to IA, and the use of gender-based analysis plus (GBA+) in IA, and applies it to the example of Ontario’s Ring of Fire. The primary aim is to develop and propose a workable plan for how such an approach could be adopted in Ontario’s far north. 

Based on a long-standing research collaboration with the community, the principal investigator conducted a community discussion and some interviews in Neskantaga First Nation in November 2019. Subsequently, the team collaboratively prepared three draft models for how a regional IA could be implemented in partnership with an Indigenous Governing Authority (IGA) in the region. Finally, the team convened a day-long meeting with 14 community representatives, elders and leaders from Neskantaga First Nation in Thunder Bay on January 23, 2020, to discuss, debate and refine the models. The discussion was audio-recorded with permission, transcribed and coded.

Key findings

The central finding is that a credible regional assessment process for the Ring of Fire must be a joint decision-making process with an IGA. The remote Indigenous communities that have the most at stake in the Ring of Fire developments are the region’s sole occupants, and the long-term stewards of the lands and waters. They stand to be the most affected as they regularly interact with the land on multiple levels, including culturally, spiritually, socially and economically. They depend on the ongoing ecological integrity of the region to meet their livelihood needs. As stewards, they also bring crucial knowledge and visions for the future otherwise unavailable to IA proceedings.

The key messages communicated by knowledge holders, elders and leadership in the community engagement sessions include:

  • The people in the communities are the real authority: the grassroots and the elders must be heard for any process to be legitimate.
  • Because of ecological connectivity and socio-cultural impacts related to probable infrastructure locations, the appropriate IGA must be a collective of affected First Nations, rather than one of the existing tribal councils or regional organizations, such as the Nishnawbe Aski Nation or Matawa First Nations.
  • An Elders Advisory Council should be an integral element at all stages of decision-making.
  • The ongoing social emergency must be addressed before new projects can be adequately considered. Proponents must be required to demonstrate that their projects will mitigate the crisis, and enhance long-term social, cultural and ecological sustainability.
  • Any regional approaches need to provide a framework that can effectively guide project-level assessments, which in turn lead into community-level approvals, in line with local protocols.

Policy implications

The recommended model includes a semi-permanent Ring of Fire Commission to be established by agreement between the federal minister of Environment and Climate Change and an IGA made up of affected and interested First Nations. The Commission, in conjunction with an Elder Advisory Council, should develop a framework for cumulative effects; baseline data (including on the ongoing social emergency); criteria for a modified “positive contribution to sustainability” test; and a regional plan. Under the Commission’s umbrella, we recommend a joint panel review process for making subsequent decisions about individual projects proposed for the region, within the parameters established by the Commission.

Further information

Read the full report

Contact the researchers

Dayna Nadine Scott, associate professor & York Research Chair in Environmental Law & Justice in the Green Economy, Osgoode Law School;

Cole Atlin, postdoctoral scholar, Memorial University;

The views expressed in this evidence brief are those of the authors and not those of SSHRC, IAAC, or the Government of Canada.

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