Ministry Review of the Marten Falls Community Access Road Environmental Assessment

Summary of our review

Who

Marten Falls First Nation (MFFN, proponent)

What

MFFN is undertaking an environmental assessment (EA) of the proposed Marten Falls Community Access Road (MFCAR, project). The project includes a new all-season road corridor approximately 184 kilometres (km) in length, and associated infrastructure.

When

The EA was submitted on February 20, 2026. The comment period for the EA ended on April 10, 2026.

Where

In Northern Ontario, connecting MFFN to the provincial highway system via Anaconda/Painter Lake Road.

Why

The purpose of the MFCAR is to establish an all‑season connection between MFFN and the provincial highway network, enabling the safe and reliable movement of people, goods, fuel, and essential supplies year‑round. The project is intended to improve community well‑being, reduce the high cost of living, and create long‑term employment and economic development opportunities for MFFN. The project may also support broader regional uses such as mineral exploration, forestry and tourism.

Conclusions

The ministry concluded that MFFN has prepared the EA in accordance with the approved Terms of Reference (ToR) and the requirements of the Environmental Assessment Act (EAA). The ministry is satisfied that MFFN used a clear and logical decision-making process to determine how the preferred project was selected from the alternatives considered. Standard conditions of approval are recommended for the implementation of the project.

1. Environmental assessment process

The EAA establishes requirements for a proponent driven planning process designed to incorporate the consideration of the environment into decision-making by assessing the effects of a project on the environment. In Ontario, the EAA sets out the general contents for the preparation of a comprehensive EA, as well as the ministry’s evaluation process. For those projects subject to the EAA, approval under the EAA is required before they can proceed.

Proponents are required to address a wide range of potential effects to the natural, social, cultural and economic environments to assist in the protection, conservation and wise management of the environment. The EA helps decision-makers to determine, based on the environmental effects, if a project should proceed, and if so, how the potential environmental effects can be managed.

An EA may:

• identify a problem or opportunity
• consider alternative ways of addressing the problem or opportunity
• evaluate the environmental effects of the alternatives
• select a preferred project from the alternatives

A proponent must consider actions to avoid, reduce and mitigate potential environmental effects. In preparing the EA, a proponent completes various studies and consults with interested stakeholders, including staff from government agencies, known as the government review team (GRT), the public and potentially affected Indigenous communities to evaluate the alternatives and determine the preferred project. If a project is approved, a proponent is required to monitor the project to demonstrate compliance with requirements of the EAA and the approval.

Pursuant to the transition provisions under the February 22, 2024, EAA amendments, if a proponent submitted a ToR to the ministry under subsection 6(1) of the EAA in respect of a project before those amendments came into force, and no decision has been made under the EAA, the project is now deemed to be a Part II.3 project (comprehensive EA project). As this is the case for this project, pursuant to these transition provisions, the project is deemed to be a Part II.3 project.

The MFCAR is subject to federal impact assessment requirements under the Impact Assessment Act. The ministry is coordinating with the Impact Assessment Agency of Canada (IAAC) on provincial and federal requirements. This has allowed the proponent to submit one set of documentation to satisfy requirements of both the EA and IA.

1.1 Terms of reference

Completing the comprehensive EA process involves two separate steps — the ToR and the EA. On October 8, 2021, the Minister of the Environment, Conservation and Parks (minister) approved the ToR for the project. The ToR sets out how MFFN would prepare the EA, which includes:

• a description of the purpose and rationale for the project
• how specific alternative methods are identified including consideration of different road corridor alternatives and supporting infrastructure locations, such as aggregate sites and construction camps
• evaluating potential environmental effects (both positive and negative)
• mitigation measures
• a consultation plan for obtaining input from Indigenous communities, GRT and the public

1.2 Environmental assessment

After receiving the minister’s approval on the ToR, MFFN proceeded to prepare the EA for the project, in accordance with the approved ToR and the requirements of the EAA.

MFFN began its consultation on the EA through a notice of commencement and undertook consultation on the project, including preparation of the draft EA, starting in fall 2021. While preparing the draft EA, MFFN conducted consultation in four stages and prepared and distributed an accompanying progress report at the conclusion of each stage. MFFN also conducted five public information centres; held a number of meetings with various stakeholders and Indigenous communities; undertook an Indigenous knowledge and land and resource use program and a socio-economic data collection program; participated in several Indigenous community consultation forums; circulated early drafts of baseline information; provided information, newsletters, letters and updates directly to Indigenous communities and on the project website and radio; and made the draft EA publicly available for review from April 22 to June 23, 2025.

On February 20, 2026, MFFN submitted the final EA to the ministry, commencing the 7-week EA submission comment period, which ended on April 10, 2026.

In accordance with the approved ToR, as part of its Indigenous knowledge (IK) and resource use program, the proponent collected IK and information on Indigenous land and resource use relevant to and required for the EA. Where required by information sharing agreements reached with individual communities, certain collected information has been protected from public or third-party disclosure. The proponent used this information to prepare Aboriginal and treaty rights and interests impact assessment reports (ATRI reports) that documented the potential impacts of the project on Indigenous land and resource use and Aboriginal and treaty rights.

Although this resulted in the proponent sharing redacted ATRI reports with the ministry and IAAC in some cases in order to protect confidential information, the information collected nonetheless informed the effects assessment in the EA. The proponent provided the final community-specific ATRI reports to communities between May 5^th to 15^th, 2026. A consolidated summary of community impacts has been included in appendix O of the EA, which was revised after submission of the EA and is available on the proponent’s website. Section 11 of the EA includes a consultation summary from fall 2021 to September 2025. On March 17, 2026, the proponent provided MECP an additional consultation summary for activities occurring up to March 13, 2026.

1.3 Ministry review

The EAA requires the ministry to prepare a review of the EA. The ministry review sets out the ministry’s evaluation of the EA, including an assessment of whether the EA has been prepared in accordance with the approved ToR, whether it meets the requirements of the EAA, and whether the evaluation in the EA is sufficient to allow the minister to make a decision about the project.

The ministry review comment period provides an opportunity for the GRT, the public and the Indigenous communities to see how their comments on the EA and project have been considered. Refer to section 5 of this ministry review for next steps.

2. Description and purpose of the proposed project

MFFN is proposing to construct the MFCAR, a new two-lane all-season road approximately 184 km in length that will connect the community to the existing provincial highway network. The preferred route for the road runs northward from Painter Lake Road, crosses the Ogoki and Albany Rivers, and continues EAst toward MFFN near the confluence of the Albany and Ogoki Rivers in Northern Ontario. Approximately eight kilometres of the MFCAR would be located within MFFN reserve lands, with the remainder of the road corridor situated on public land.

The project includes the following main components:

• A two-lane all-season gravel road approximately 12 to 13 metres wide within a 60-metre cleared right-of-way (100 metre planning width), designed according to Ontario highway standards
• Maintenance and pull‑off areas along the MFCAR to allow vehicles and equipment to safely pull over or turn around during road operation
• Sixty-eight permanent waterbody crossings, including 47 bridges and 21 culverts
• Temporary supportive infrastructure associated with construction, including aggregate extraction and storage areas (pits and quarries), temporary access roads, temporary construction camps and work areas with laydown and storage areas, associated power supply, and communications infrastructure required to support construction activities and material hauling
• Permanent operational and maintenance infrastructure, including road maintenance and service facilities, permanent temporary aggregate areas with access roads, and associated power supply and communications, as well as storage areas for fuels, equipment, aggregates and wastes, to support the long‑term operation, maintenance, and reliability of the MFCAR

Average annual daily traffic volumes are projected to be approximately 700 vehicles on the north–south segment and approximately 100 vehicles on the east–west segment during operations, comprised primarily of light duty weight personal vehicles and medium to heavy weight commercial vehicles. Heavier truck traffic is expected mainly on the north–south segment associated with industrial and mining supply movements, with no anticipated use of the east–west segment for mining truck traffic or mineral ore hauling.

The primary purposes of the proposed project are to:

• provide safe, reliable, year-round transportation for the movement of people, food, fuel, construction materials, and essential goods between MFFN and the provincial highway network, replacing the increasingly unreliable winter road system
• support community wellbeing and long-term resilience by reducing the high cost of living, improving access to health, education, and social services, and enabling family and cultural connections that are currently hindered by isolation; and
• create employment, training, and economic development opportunities for MFFN members, while strengthening community capacity in construction, road maintenance, and regional development planning

From the perspective of MFFN, the MFCAR is intended foremost as a community-serving corridor, while also having the potential to support broader regional uses such as mineral exploration, forestry, and tourism in a manner that aligns with the community’s vision, values, and economic future.

2.1 Preferred alternative

In accordance with the approved ToR, the EA was focused to exclude a detailed assessment of ‘alternatives to’ the project. The alternatives evaluated in the EA are 1) a new all season road and 2) the ‘do nothing’ alternative. The preferred alternative is a new all-season road.

The EA assessed alternative road corridor alignments, narrowing focus to two primary route alternatives based on feedback from MFFN community members and the engineering team (Alternative 1 and Alternative 4). These routes were further evaluated by geographic segments using IK, environmental, social, cultural, engineering, and cost considerations. These geographic segments comprised:

• Segment 1— Ogoki River Crossing
• Segment 2 — Albany River Crossing
• Segment 3 — North of the Albany River to the community

Please refer to figure 4-2 on page 27 of the EA for a figure depicting the 3 geographic segments.

The proponent identified the preferred route based on its determination that the route best meets the project purpose while minimizing potential environmental effects. Alternative locations for ancillary infrastructure, such as aggregate sources and construction camps, were also evaluated and preferred locations selected. The preferred route is depicted in figure ES 4-1 on page v of the EA.

2.2 Summary of potential environmental effects and mitigation measures

The EA describes the existing environment that may be impacted by the project as well as the potential project effects, including residual and cumulative effects. A consolidated summary of potential effects, mitigation, monitoring, and follow-up commitments is provided in appendix AA of the EA (summary and recommendations tables), which draws from the technical support documents (appendices F to V). Potential environmental effects for individual valued components (VC), or environmental disciplines, are described in sections 8 (existing conditions) and 9 (effects assessment) of the EA, with cumulative effects assessed in section 10.

The proponent grouped the VCs into three categories: water, land, and people. A summary of key potential environmental effects and mitigation measures, as stated in sections 8 and 9 of the EA, is listed below. As described in section 10 of the EA, several VCs for which residual effects were identified form part of the cumulative effects assessment, including surface water, fish and fish habitat, groundwater and geochemistry, peatlands, vegetation, wildlife, ungulates, physiography, terrain and soils, Aboriginal and treaty rights and interests, noise, vibration, air quality, community well-being, and land and resource use. The key residual effects including cumulative effects are also listed below:

Potential effects on water-related VCs:

• Changes to vegetation and peatland ecosystems, including vegetation loss, soil disturbance and compaction, changes to surface water and groundwater flow, and potential long‑term alteration of localized peatland hydrology and associated hydrologic functions
• Effects on fish and fish habitat at watercourse crossings, localized to crossing locations
• Effect on peatland ecosystems due to changes in groundwater is considered uncertain and is categorized as significant in the cumulative effects assessment

Mitigation measures:

• Progressive restoration and revegetation of temporary construction areas, including access roads, camps, laydown areas, and aggregate source areas
• Use of a floating road construction approach in peatland areas, including minimizing peat excavation and using culverts to maintain surface water and groundwater flow connectivity
• Design and sizing of culverts and bridges to maintain natural drainage patterns and hydrologic connectivity, with consideration of peatlands, groundwater, climate change, fish habitat, and watercourse function
• Preparation and implementation of a vegetation restoration plan specific to peatland restoration and peat stockpile management
• Adherence to restricted activity timing windows for fish, or applicable permitting where avoidance is not feasible
• Limiting vegetation clearing and maintaining buffers around waterbodies and sensitive habitats

Potential effects on land-related VCs:

• Habitat loss and fragmentation, sensory disturbance, and changes to wildlife movement patterns associated with the presence and operation of the road, increased collision risk, incidental mortality, harvesting pressures, and changes to predator–prey dynamics
• Combined residual cumulative effects for boreal (woodland) caribou are considered to have a significant influence on self-sustaining and ecologically effective boreal caribou populations in the regional study area
• Residual cumulative effects on moose are predicted due to increased public access, which may lead to an uncertain increase in moose harvesting.
• Significant cumulative residual effects are also predicted for wolverine, due to the high level of uncertainty associated with how they will react to the project
• Combined cumulative residual effects from the project are predicted on wetland ecosystems considered significant as a precaution, due to high uncertainty of effects and probable occurrence

Mitigation measures:

• Pre‑construction wildlife and habitat surveys to identify species at risk and sensitive features
• Incorporation of wildlife passage features at select bridges and culverts, where feasible
• Adherence to restricted activity timing windows for wildlife or applicable permitting where avoidance is not feasible
• Limiting vegetation clearing and maintaining buffers around waterbodies and sensitive habitats
• Measures to reduce wildlife‑vehicle collisions, including speed management and signage
• Limiting dust deposition, erosion and sedimentation through mitigation measures
• Noise mitigation such as not allowing quarry activity within 4 km of active wolverine dens during the denning period
• Compliance with all environmental approval conditions, permitting or authorization requirements
• An environmental protection plan, vegetation management plan, vegetation restoration plan, and waste management plan will be developed and implemented that includes policies and actions to mitigate impacts to wildlife and ecosystems including wetlands

Potential effects on people-related VCs:

• Loss or alteration of lands used for Indigenous traditional activities, such as harvesting, hunting, fishing, access and travel, and the use of culturally and spiritually important sites
• Changes to access, travel patterns, and land and resource use resulting from the introduction of permanent road infrastructure, potential ecological and social effects during construction and operation from the road and associated infrastructure, including from dust generation, air contaminants, noise, vibration, and vehicle emissions
• Community well‑being and safety concerns associated with increased construction activity and workforce presence, strain on local healthcare and emergency services
• Cumulative residual effects are predicted to mental health and well-being due to loss of connectivity to the land; change in sense of place and identity due to presence of the road and other projects; potential increase in substance use due to easier access; reduction in quality and availability of traditional foods; increase in violence and harassment; and environmental effects affecting human health
• Impacts are expected on Indigenous communities’ ability to harvest caribou and/or moose for traditional purposes, as well as the ability to practice and transmit cultural traditions associated with caribou and/or moose harvesting

Mitigation measures:

• Project design measures to minimize the project footprint and avoid or reduce effects on areas identified as important for Indigenous traditional use and cultural practices
• Engagement with Indigenous communities to inform construction timing, including avoidance of peak harvesting periods and culturally important areas, where feasible
• Development of a construction best management practices plan, construction vibration work plan, noise control measures, and a fugitive dust management plan prior to construction to minimize potential effects on air quality, noise, and vibration
• Ongoing consultation with Indigenous communities to inform protocols for working near culturally and traditionally important sites and species
• Community well‑being and safety monitoring during construction and operation; driver safety training; working groups with Aroland First Nation, MFFN and other interested communities to discuss community-proposed topics related to well-being and safety
• Road safety design measures, including consideration of alignment, curves, slopes, sightlines, and the provision of operational pull‑off and turnaround areas

Potential positive effects of the MFCAR include:

• Increased employment opportunities, particularly for Indigenous communities, during construction, operation, and maintenance of the project
• Increased education, training, and skills development opportunities, including work‑related training and capacity building associated with construction and long‑term operations
• Increased household and community income resulting from employment and business participation
• Contracting and procurement opportunities for Indigenous and non‑Indigenous businesses at the local and regional levels
• Improved access to economic development opportunities, including those associated with mineral exploration and development in the region
• Improved food security and affordability, supported by increased incomes and reduced transportation costs for goods
• Broader improvements to social and community well‑being, including positive indirect effects on health, housing stability, and community services for MFFN and other Indigenous communities in the region
• Improved year‑round access and safety, supporting reliable transportation for community members, emergency services, and essential supplies

A summary of the overall advantages and disadvantages of the project is provided in the EA, with the overall conclusion that the residual effects of the MFCAR are acceptable based on an assessment against applicable evaluation criteria and the implementation of proposed mitigation measures. The EA also concludes that the project aligns with relevant federal and provincial policy objectives and supports the long‑term goals, priorities, and aspirations of MFFN, including improved community access, safety, and socio‑economic well‑being.

3. Results of the ministry review

The ministry review provides an analysis of the EA — it is not intended to summarize nor present the information found in the EA. For information on the proponent’s decision-making process, refer to the EA itself. The EA and supporting documentation outline the EA planning process and demonstrate how a proponent selected the preferred project and made the final decision.

3.1 Conformance with ToR and EAA

3.1.1 Ministry analysis

The ministry concluded that the EA followed the framework and commitments made in the approved ToR and meets the requirements of the EAA.

Appendix A provides a summary of this analysis.

Consultation requirements

Section 17.3 of the EAA states:

When preparing proposed terms of reference and an environmental assessment, the proponent shall consult with such persons as may be interested.

One of the key requirements of the EAA is consultation. MFFN consulted with Indigenous communities, the GRT and the public as part of preparing and finalizing its EA.

Shared approach to Indigenous consultation

On January 7, 2020, MFFN and Ontario signed a Memorandum of Understanding (MOU) on shared consultation activities with respect to consultation with Indigenous communities and partial delegation of procedural aspects of the Crown’s duty to consult related to the MFCAR. The MOU was signed between MFFN, the ministry and the Ministry of Energy and Mines.

The MOU identifies the Crown’s preliminary list of Indigenous communities whose established or credibly asserted Aboriginal or treaty rights may be affected by the MFCAR, and Indigenous communities that may be interested in the MFCAR.

Consistent with the MOU, MFFN consulted with the following Indigenous communities on a rights basis:

• Aroland First Nation
• Attawapiskat First Nation
• Animbiigoo Zaaag’igan Anishinaabek (AZA)
• Constance Lake First Nation
• Eabametoong First Nation
• Fort Albany First Nation
• Ginoogaming First Nation
• Kasabonika Lake First Nation
• Kashechewan First Nation
• Kingfisher Lake First Nation
• Kitchenuhmaykoosib Inninuwug (KI)
• Long Lake #58 First Nation
• Marten Falls First Nation
• Neskantaga First Nation
• Nibinamik First Nation
• Wapekeka First Nation
• Wawakapewin First Nation
• Weenusk First Nation
• Webequie First Nation
• Wunnumin Lake First Nation

Consistent with the MOU, MFFN consulted with the following Indigenous communities on an interest basis:

• Métis Nation of Ontario — Region 2
• Red Sky Métis Independent Nation

The proponent also engaged with Mishkeegogamang First Nation on an interest basis. Under the MOU, the proponent is responsible for procedural aspects of consultation such as providing timely information to Indigenous communities about the MFCAR; responding to concerns raised; adjusting its consultation planning, project design or mitigation measures as appropriate; and keeping a record of consultation.

The MOU also outlines a process by which MFFN can refer certain questions, comments or concerns received from Indigenous communities to Ontario that may be out of scope of the proponent, the project or the EA. MFFN also refers any requests for capacity funding to Ontario.

AZA was initially consulted on an interest basis. However, in March 2026, based on additional information, Ontario determined that the community should be consulted on a rights basis in respect of the project.

Funding

Since August 2019, Ontario has been implementing the participant funding initiative to support consultation with First Nation communities whose Aboriginal and treaty rights may be adversely affected by the MFCAR. This capacity funding has been made available throughout the EA process and is administered by the Ministry of Energy and Mines. This funding also assists Ontario in meeting its duty to consult obligations.

Funding was provided by MFFN through: a) the IK program to communities that chose to contribute IK and land and resource use information; and b) the community coordinator program (later called the community capacity funding program) with funding provided to support activities such as document review, participation in meetings and workshops, logistics, internal coordination, and preparation of community specific input.

Summary of proponent’s consultation activities

MFFN documented its consultation activities in section 11 of the EA and the record of consultation (RoC). The RoC provides a detailed overview of engagement carried out with Indigenous communities, the GRT, and interested persons.

MFFN’s consultation program included:

• issuing the notice of commencement of the EA in October 2021 and sharing updates throughout the process
• maintaining a project website that hosts notices, plain-language summaries, field updates, and EA documentation
• hosting five public information centres to present findings and gather feedback
• distributing monthly e-blasts, newsletters, field notices, and discussion guides, and using social media and news outlets to circulate project information
• delivering webinars and videos on VCs, cumulative effects, climate change, route selection, and project updates
• implementing the IK program and community coordinator program, supporting the incorporation of IK and facilitating community-specific engagement
• conducting socio‑economic and land use data collection with participating Indigenous communities
• producing progress reports summarizing community-specific input and how feedback influenced project development
• providing hard copies of EA and technical documents when requested to support accessibility
• meeting with Indigenous communities and stakeholders through both in-person and virtual sessions
• participating in Ontario-supported ATRI forums, as well as Three-Road Project Gatherings and Expos
• conducting targeted consultation on the cumulative effects assessment
• publishing the draft EA for review and comment, including an extended 120-day comment period (instead of the typical 30 days) for Indigenous communities and the GRT from February 19 to June 23, 2025 and extended 60-day comment period for the public (instead of the typical 30 days) from April 22 to June 23, 2025

MFFN has identified that consultation and engagement evolved throughout the EA process. They note that early outreach took place under pandemic‑related constraints, and that some communities did not respond or expressed concerns or opposition to the project. Over time clearer communication pathways, increased participation, and more community‑specific dialogue occurred.

After receipt of comments on the draft EA, MFFN revised the report to address comments to the extent possible and submitted its EA for a decision under the EAA. MFFN posted the EA and a Notice of Submission on its project website and distributed copies to Indigenous communities and stakeholders.

The ministry provided the GRT, the public and Indigenous communities an opportunity to review the EA and submit comments during the 7-week comment period.

Aboriginal Treaty Rights and Interests Impact Assessment

The EA includes a discussion of ATRI impact assessment based on secondary sources, consultation, and IK that was not identified as confidential. In accordance with community-specific IK sharing agreements, certain information has been protected from public or third-party disclosure. A consolidated summary of the community-level ATRI impact assessments has been included in a revised appendix O, which is available on the proponent’s website. Comments on this summary can be made during the ministry review comment period.

3.1.2 Comments received

Below is a summary of the key comments received from the GRT, public and Indigenous communities on the final EA. Appendix B of the ministry review includes copies of all comments and the proponent’s responses.

Government review team comments

The GRT reviewed the EA to confirm that the information and conclusions of the EA were valid. During the EA submission comment period, MECP’s Environmental Assessment Branch, Ontario Parks, Species at Risk Branch, Environmental Monitoring and Reporting Branch, Technical Assessment and Standards Development Branch; as well as the Ministry of Natural Resources, Ministry of Energy and Mines, Ministry of Transportation, and Ministry of Tourism, Culture and Gaming provided comments. The proponent has provided responses to these comments. Other ministries either provided very minor comments or did not have comments on the EA. The proponent is updating appendix AA of the EA to consolidate commitments made to address public, Indigenous community and GRT comments.

Public comments

During the EA submission comment period, one individual and three organizations submitted comments: Wildlife Conservation Society, Friends of the Attawapiskat River and Remote Outfitters Committee. The Wildlife Conservation Society and the Friends of the Attawapiskat River’s comments outline concerns about the project’s effects to fish, wildlife, peatlands, vegetation, climate change, cumulative effects including induced development effects, and concerns regarding mitigation and restoration. The majority of these comments largely echo concerns raised by Indigenous communities.

The Remote Outfitters Committee represents remote tourism operators who operate outpost camps and outfitters in the area. They are concerned that the remote tourism sector will be permanently impacted by unrestricted road access and loss of fly-in access. One member of the public commented asking to know more about how the project would change the landscape and benefit his family.

Indigenous community comments

The RoC documents all the consultation with Indigenous communities and will be reviewed and considered by the ministry when assessing the Crown's duty to consult before the minister, with the approval of the Lieutenant Governor in Council, makes a decision about the proposed project.

Comments were submitted on the draft EA by Aroland, Attawapiskat, AZA, Constance Lake, Fort Albany, Ginoogaming, Kashechewan, Nibinamik and Weenusk First Nations.

These comments were responded to and addressed by the proponent, where possible, and included in the EA (Eabametoong First Nation submitted comments on the draft EA past the comment period, and the proponent responded to these after submitting the EA). Ontario also responded directly to Indigenous communities regarding comments the proponent felt that they were not appropriately positioned to respond to. Appendix C4 of the final EA includes a summary of how the EA process was informed by information provided by Indigenous communities. Many comments on the draft EA were similar, thematically, to the comments received on the final EA and are reflected in this ministry review.

Comments were submitted on the final EA by Aroland, Attawapiskat, AZA, Constance Lake, Eabametoong, Fort Albany, Ginoogaming, Kashechewan, Long Lake #58, Nibinamik and Weenusk First Nations. Mushkegowuk Council and one individual identifying as a member of Attawapiskat First Nation also submitted comments on the EA. The proponent sent responses to the communities and ministry between April 26 and May 5, 2026. Similar to the draft EA, for situations in which the proponent felt that it was not appropriately positioned to respond to a comment, it referred the comment to Ontario for response. Ontario will respond to those comments and will provide these responses directly to the communities. A summary of the key comments raised on the EA, responses from MFFN and the ministry’s analysis are below.

Impacts to the environment

Most communities that submitted comments on the EA raised concerns with potential impacts of the MFCAR on the natural environment. Concerns were raised about:

• the project’s effects on wildlife such as caribou, wolverine, and moose and their habitat
• the potential for impacts to surface and groundwater quality and quantity
• contamination from spills, erosion and sedimentation and effects to fish
• air contamination and dust
• impacts to vegetation such as invasive species, removal of vegetation and peatlands
• potential effects to cultural heritage, harvesting, and effects to community health and safety
• potential carbon release from peatland removal, and how climate change might also impact the environment, operation of the road and communities in the area

Concerns were raised about the determination of significance of effects on VCs. Several First Nations wrote that negative effects of the project are being downplayed as the EA concluded that the majority of residual effects are negligible and insignificant, even in cases where the likelihood is certain. Some communities stated that many of the residual impacts on VCs should have been deemed significant. Communities also raised concerns that the assessment relies too much on future monitoring and design refinement to manage present uncertainty with effects on some VCs like peatlands, groundwater, caribou and Indigenous rights.

In terms of the social environment, Aroland, Constance Lake, Fort Albany, Eabametoong, Ginoogaming, and Long Lake 58 First Nations expressed the view that the true intended purpose of the road is to facilitate industrial mining, and concerns about how its development could affect community safety. Access restrictions were requested for outside visitors and recreational users. Concerns with the road’s effects on heritage resources were raised by AZA, Fort Albany, and Ginoogaming First Nations.

Additionally, communities raised concerns with matters such as post-EA permitting, timing for field studies and field work notification.

Proponent response:

In response to concerns about potential effects on natural environment VCs, the proponent explained how impacts were assessed, how residual effects were determined after mitigation, and how their significance was determined. MFFN stated that available IK and associated land use mapping were used to identify areas of cultural and ecological significance, and explained how input received from communities was reflected in monitoring plans. For example, the EA, including appendix I, were updated to reflect that impacts to peatland ecosystems resulting from changes to groundwater (quality and quantity) are significant including considerations informed by IK. Additionally, information about the floating road construction approach and how it minimizes disturbance to peatlands is included in the final EA, including in appendix W engineering memos.

In addition, monitoring programs are proposed for fish and fish habitat, ungulates, erosion and sediment control and other environmental components. Spill prevention and emergency response plans will be implemented, and geochemical testing will confirm the potential for acid rock drainage and/or metal leaching where road construction may expose bedrock or where aggregate materials may be sourced from. Mitigation measures will be applied if testing identifies acid rock drainage and/or metal leaching. The proponent commits to establishing an environmental advisory committee to support the development and implementation of all monitoring programs.

In response to concerns regarding timing of field studies and notice of field work, MFFN noted that notices for field work were provided. Should the project be given approval to proceed, where any future work cannot occur outside of sensitive timing windows for species, the proponent will meet all provincial requirements. MFFN indicated that they have addressed these issues through their approach in developing environmental protection, mitigation and enhancement measures outlined in documents such as the ungulates technical support document and draft biodiversity offset plan (appendix AB). The proponent commits to preparing plans and protocols such as the development of routine monitoring and maintenance protocols for water crossings, wildlife monitoring programs, an environmental protection plan, erosion and sediment control plan, vegetation management plan and biodiversity offset plan during the design phases of the project.

Ministry analysis:

The EA meets the requirements of the ToR and EAA for the assessment of potential effects to the environment. The impacts to the environment may in some cases require mitigation or offsetting, which the proponent has committed to do. The proponent would need to fulfill commitments in the EA to prepare plans and offset losses, identify mitigation measures, undertake monitoring and continue to consult with communities if the project is given approval to proceed under the EAA. Additionally, the proponent will have to meet all regulatory requirements before proceeding to develop the MFCAR, including obtaining any applicable permits or approvals.

The ministry has considered comments regarding the reliance on future monitoring and design refinement in future phases and the interest expressed by Indigenous communities in participating in mitigation, monitoring, and governance activities. The ministry notes that the EAA and the approved ToR describes a staged planning and implementation approach for large and complex infrastructure projects, whereby certain design details, permitting requirements, and implementation measures are developed during subsequent project phases. The purpose of the EA is to identify potential environmental effects, assess their significance, and establish a framework of mitigation, monitoring, and follow‑up commitments, recognizing that site‑specific refinement will occur during detailed design and permitting.

The proponent is updated appendix AA of the EA to consolidate commitments made during the EA process including those made to address comments from Indigenous communities. In recognition of the concerns and interests expressed by a number of communities about the project’s potential impacts to the environment, a condition of approval could be considered that would require the proponent to invite all of the Indigenous communities that were consulted during the EA process to participate in an environmental advisory committee.

Cumulative effects

Aroland, Attawapiskat, AZA, Constance Lake, Eabametoong, Fort Albany, Ginoogaming Nibinamik and Kashechewan First Nations raised concerns about potential cumulative effects of the project and the cumulative effects assessment in the EA. Many communities stated that the MFCAR is connected to, and will facilitate, larger regional development including additional roads, mining activities and increased industrial and public traffic, and that the combined effects to the environment and Indigenous communities’ way of life may be substantial. They believe the induced effects of growth and development should have been part of the cumulative effects assessment. Some communities (Nibinamik, Attawapiskat) indicated that the fact that multiple assessments (Webequie Supply Road, MFCAR, and Northern Road Link) are being completed, as opposed to one assessment for all three projects minimizes the assessment of regional and induced impacts.

Proponent response:

The cumulative effects assessment was undertaken in accordance with the federal tailored impact statement guidelines (TISG) and the approved ToR.

The proponent reviewed feedback on cumulative effects from Indigenous communities and relevant projects and activities were incorporated into the project inclusions list in the EA. Relevant projects meeting the criteria for the list, including other proposed roads, were included in the EA where sufficient publicly available information was available to support an assessment of reasonably foreseeable effects. Although the MFCAR is frequently linked to larger regional efforts such as the proposed mineral development in the Ring of Fire, MFFN maintains that this EA is focused solely on the advancement of a road for access of their community to the provincial highway network.

Traffic and access effects were also considered as part of the cumulative effects assessment.

Some proposed projects are not anticipated to have spatial or temporal overlap with the VCs carried forward from the regional effects assessment in the EA. Therefore, they were screened out of the cumulative effects assessment. Project-related activities were reviewed as part of EA, and more detailed information will be provided during detail design.

Ministry analysis:

The ministry has considered comments received on cumulative effects, the proponent’s assessment of cumulative effects and responses to comments, and the requirements of the ToR and EAA in relation to this topic. The EAA does not have specific requirements related to cumulative effects. The ministry’s guidance, in the Code of Practice for Preparing and Reviewing EAs in Ontario, states that proponents are encouraged to “include information about potential cumulative effects of the project in combination with past, present and reasonably foreseeable future activities where possible. Proponents are advised to consult with government agencies to identify any already-approved projects that will be built in the future, and to consider their potential cumulative impacts to the extent possible.” The guidance further states that if quantitative information about these projects is unavailable, proponents are encouraged to carry out qualitative assessments of potential cumulative impacts and suggests using IAAC’s cumulative effects assessment practitioners guide for conducting cumulative effects assessments.

MFFN has followed the guidance in the Code of Practice as the EA includes information about potential cumulative effects in combination with reasonably foreseeable developments, using publicly available information. Information about past and present activities was incorporated into the existing conditions — Section 8 of the EA.

The ToR (section 8.4) states that the results of a comparative analysis of the advantages and disadvantages will be the identification of the preferred alternative. The preferred alternative will then be compared against the “do nothing” alternative and used to predict cumulative effects. The notice of approval for the ToR includes additional requirements for the cumulative effects assessment: targeted consultation with Indigenous communities on the cumulative effects assessment work plan; consideration of the cumulative effects assessments in the Webequie Supply Road or Northern Road Link EAs, if available; and inclusion of a cumulative effects consultation report in the EA. MFFN has fulfilled these requirements in section 10 of the EA — cumulative effects assessment.

A number of Indigenous communities requested a broader regional development view with respect to assessing potential cumulative effects. The ministry notes that while other road projects have been proposed or are being assessed in the broader region, each is subject to its own regulatory process. The proponent has assessed potential interactions and cumulative effects in accordance with the approved ToR.

The ministry is satisfied that ToR requirements were met for the cumulative effects assessment, which does not require assessing a range of regional development scenarios, but rather requires assessment of the preferred alternative’s net, or residual, effects that may overlap temporally and spatially in combination with effects of past, present and reasonably foreseeable projects.

Consideration of Federal Regional Assessment

Aroland, Constance Lake, Fort Albany, Ginoogaming and Eabametoong First Nations note that the Interim Report for the federal Regional Assessment (RA) for the Ring of Fire area was released in February 2026, and a final report is expected by June 2027. The First Nations state that these results should be considered before a decision is made about whether to give approval to proceed with the proposed MFCAR.

Proponent response

The proponent responded that the RA is being led by IAAC and is intended to consider the MFCAR and other related projects within a broader cumulative effects framework for the Ring of Fire region. Because the RA interim report was released in February 2026, the same month the final EA was submitted to the ministry, it was not possible for the proponent to incorporate information from the Interim Report into the EA. The final RA report is not expected until mid-2027. MFFN remains committed to transparency and collaboration and will continue to share relevant information with IAAC to support their work.

Ministry analysis:

Ontario will not be delaying decision-making on the MFCAR until the RA is complete. The terms of reference for the RA states that it is a “planning tool used to assess the potential effects of multiple existing and potential future developments and activities in a specific geographic region to help inform decision-making.” IAAC has confirmed with Ontario that the ongoing federal RA will not impact timelines for individual project assessments nor create any obligations on Ontario.

The notice of approval for the MFCAR ToR states that if there is an ongoing or completed RA for the Ring of Fire area, as part of the development of its EA, MFFN will consider, where appropriate, any publicly available information that may be generated through that process which MFFN considers relevant. The timing of the release of the Interim Report and the release of the final EA report prevented the information from being considered in the EA.

Concerns regarding consultation

Several Indigenous communities, including Attawapiskat First Nation, Eabametoong First Nation, Fort Albany First Nation, Kashechewan First Nation, Nibinamik First Nation, and Weenusk First Nation, as well as Mushkegowuk Council and Friends of the Attawapiskat River, raised concerns regarding the adequacy of consultation timelines during the EA process, reliance on online consultation methods, the size and complexity of the EA documentation, and the transparency and accuracy of the consultation record. Communities indicated that these factors limited their ability to meaningfully review information and participate in the process. Some communities expressed the view that the EA outcome appears to have been pre‑determined prior to the conclusion of the process.

Indigenous communities raised concerns that they were not consulted about the Community Partnership Agreement between MFFN and Ontario before the agreement was executed expressing the concern that governance decisions may influence project direction.

Communities further noted that the EA RoC and supporting appendices do not clearly or consistently demonstrate how community comments, questions, and identified interests were received, tracked, interpreted, and addressed throughout the EA process.

While raising these concerns, some First Nations also expressed support for MFFN’s objective of establishing an all‑season road connection to the provincial highway network, emphasizing that their support is contingent on assurance that community‑specific concerns are meaningfully considered and addressed.

Proponent response:

The EA including the technical support documents, was prepared to meet the requirements outlined in the ToR, the TISG and the technical discipline-specific study plans. MECP will determine whether the EA meets the provincial requirements and IAAC will make a determination on whether or not it addresses the key issues under federal jurisdiction. The EA is written in plain language to make it accessible to a broad audience, while the technical details are provided in the appendices for those who wish to review them in depth.

Consultation for the MFCAR has been conducted in accordance with the ToR and TISG and has been ongoing since 2019. Engagement with Indigenous communities, the GRT, stakeholders, and the public was initiated EArly and carried out throughout the EA process to inform design, effects assessment, and mitigation measures. The RoC for the project includes milestone‑based reports prepared at key stages of the EA process. As per requirements of the ToR, four progress reports were issued and provided to Indigenous communities, with opportunities for review and feedback, prior to the reports becoming part of the public record.

The accelerated schedule announced by Ontario in March 2026 only applied to the timing of the EA submission and does not affect the scope, quality, or extent of consultation undertaken for the project. The accelerated schedule does not diminish the completeness or integrity of the consultation process.

Ministry analysis:

Ontario recognizes that it has a constitutional duty to consult and, if appropriate, accommodate Indigenous communities with respect to potential adverse impacts to established or credibly asserted Aboriginal or treaty rights from the MFCAR. This means that Indigenous communities must be provided with reasonable consultation opportunities throughout the process. Ontario has offered to meet with interested communities to discuss their concerns.In addition, Ontario has offered and provided capacity funding to potentially impacted communities since 2019 to support communities’ participation in the EA process. This funding could be used for activities such as hiring experts and preparing comments. Several communities took advantage of this opportunity.

Ontario has publicly stated the strategic importance of advancing all-season road projects linked to the Ring of Fire mineral development area. Under the EAA, proponents may not proceed with a project that is subject to comprehensive EA until the minister decides, with the approval of the Lieutenant Governor in Council, to give approval to proceed with the project.

The ministry notes that MFFN has conducted an extensive consultation program, which followed ToR and EAA requirements, as summarized in section 3.1.1 and appendix A of this ministry review. Following the ministry review comment period, the ministry will be considering all comments received during the comment periods and the proponent’s responses, and this information will  be provided to the minister to inform his decision on the project.

Final versions of the community-specific ATRI reports were provided to communities in May 2026 and redacted copies were provided to MECP and IAAC on May 22, 2026, with the exception of MFFN’s own ATRI report which the community has indicated will be available May 29, 2026. The proponent included a summary of its ATRI impact assessment in appendix O of the EA (May 2026). As part of its assessment of the Crown’s duty to consult, the ministry will consider, among other things, comments on the EA, the consultation record, and ATRI report information.

With respect to the concern that decision-making has been pre-determined, the ministry notes that the decision concerning whether to give approval to proceed with the project, and, if so, under what conditions, remains outstanding. As required by the EAA, the minister will consider the factors set out in section 17.15 (3) of the EAA in making the decision, including the purpose of the Act, the ministry review, the ToR and EA, and comments received during the EA and ministry review comment periods.

Impacts to Aboriginal and treaty rights

Several communities have expressed concerns that the assessment process does not uphold the principle of free, prior, and informed consent, contrary to Canada’s commitments under the United Nations Declaration on the Rights of Indigenous Peoples Action Plan. It was asserted by some Indigenous communities that significant information gaps related to cumulative effects, combined with compressed timelines, undermine Indigenous communities’ ability to understand and assess the project’s potential impacts on their Aboriginal and Treaty rights.

Communities have emphasized the need for concrete and enforceable accommodation measures, developed in partnership with Indigenous communities, to address project-related impacts. AZA indicated that meaningful inclusion of their community in project governance, particularly in environmental monitoring, oversight, and adaptive management, is a necessary component of accommodation. Eabametoong First Nation expressed concern that they did not have an opportunity to provide IK about the preferred route and in relation to mapping information relied on in the draft ATRI report. Ginoogaming First Nation stated that it does not consent to the use of the MFCAR as a gateway to mining and industrial development in the Ring of Fire. Additional concerns were identified by some communities regarding the accuracy of information presented in their community-specific draft ATRI report, as well as the proponent’s approach of deferring several issues to the detailed design phase.

Aroland, Attawapiskat, AZA, Constance Lake, Eabametoong, Fort Albany, Ginoogaming, Kashechewan, Marten Falls, Nibinamik, and Weenusk First Nations, along with Mushkegowuk Council representatives, identified potential impacts to hunting, fishing, harvesting, medicinal plants, and cultural continuity. Communities highlighted an imbalance between the significant impacts anticipated from the roads and the lack of direct benefits.

Additional concern was raised regarding the timing and availability of final ATRI reports, with communities indicating that delays in receiving this information restricted their ability to confirm whether rights‑related information and perspectives were accurately reflected in the assessment and considered in decision‑making.

Eabametoong, Weenusk and Constance Lake First Nations raised concerns regarding the lack of clarity about future ownership, management, and access control for the MFCAR. Communities stated that uncertainty about who will own and operate the road following construction limits their ability to assess potential long‑term effects on Aboriginal and treaty rights, including impacts related to increased public access, industrial traffic, harvesting pressure, community safety, and unauthorized use of the surrounding lands and waters. Weenusk First Nation commented that lack of clarity on who will own the road creates uncertainty for the design and implementation of post-construction and operations monitoring.

Proponent response:

Several steps were undertaken to share information and to gather feedback on ATRI reports. Communications with Indigenous communities on the IK Program began in December 2019. Funding was offered by the proponent to First Nations beginning in 2021. First Nations were also offered funding for community coordinators and later on to support their reviews of the draft EA. Two ATRI forums were held that were exclusive to Indigenous community representatives and Elders. Draft existing conditions sections of the ATRI reports were prepared and sent to First Nations for review. The draft EA and draft community well-being technical support document were circulated to Indigenous communities in February 2025 for a 120-day comment period ending June 23, 2025. This date was later extended to September 5, 2026, to accommodate requests from Indigenous communities and regulators. each community was sent its community-specific ATRI report in June-July 2025 with a 90-day review period and final versions were provided in May 2026.

The proponent conducted regular monthly outreach, information sharing and regularly extended offers to meet with communities. The IK, community coordinator and the community capacity funding programs were offered to provide capacity for Indigenous community engagement and participation in the EA process. Should the project be given approval to proceed under the EAA, a consultation and engagement program would be established to guide discussions through the next phase of the project.

Information contained in the community-specific ATRI reports was based on IK available at the time of assessment and reflects the information shared for the purposes of informing the project-specific evaluation. The assessment in the ATRI reports acknowledges that the information provided may not be comprehensive and that the depth and scope of IK varied among communities.

Ministry analysis:

Under the EAA, proponents are required to consult with Indigenous communities and other interested persons. Ontario has a constitutional duty to consult and, where appropriate, accommodate Indigenous communities whose Aboriginal or treaty rights may be adversely affected by a proposed project. Consultation for the project has occurred over multiple years and included a range of engagement activities, including meetings, workshops and forums, public information centres, targeted cumulative effects consultation, the provision of capacity funding to support Indigenous participation, and circulation of draft reports.

The ministry notes that MFFN began consulting with the 22 identified Indigenous communities in 2019 during the development of the draft ToR. The RoC indicates that MFFN sought participation from the communities in several IK‑gathering initiatives and review of draft study plans intended to support the EA. The ministry understands that some, but not all, communities participated in those initiatives and recognizes that each community determines its own priorities, capacity and preferred methods of engagement.

The proponent distributed the final ATRI reports to Indigenous communities and the ministry in May 2026. Communities will have the opportunity to review the reports and submit any comments during the ministry review comment period. These comments will be considered in the final EA decision.

The EA identifies potential effects associated with increased access created by the road. MFFN has committed to developing mitigation, monitoring, and management measures during construction and operation, and engaging with Indigenous communities regarding access. Future ownership of the road is still under discussion.

With respect to comments received regarding the recognition of the principles of free, prior and informed consent, it is the federal government that has the lead role in working with Indigenous communities and organizations on how to address Indigenous communities’ requests for recognition of these principles in alignment with the United Nations Declaration on the Rights of Indigenous Peoples within Canada.

The ministry is satisfied that the efforts to collect knowledge and input from Indigenous communities to assess potential impacts of the MFCAR on Aboriginal and treaty rights were completed in accordance with the ToR and EAA requirements. The ministry is also satisfied that the proposed mitigation measures and commitments identified in the EA and community-specific ATRI reports address potential impacts to Aboriginal and treaty rights.

Interests in project implementation, mitigation and monitoring

Aroland, AZA, Constance Lake, Eabametoong, Fort Albany, Ginoogaming, Kashechewan, Nibinamik and Weenusk First Nations expressed interest in participating in mitigation programs, development of various environmental plans, monitoring activities and project governance, and requested funding for future participation.

Proponent response:

If the project is given approval to proceed under the EAA, the proponent commits to establish an environmental advisory committee to support the development and implementation of all monitoring programs. The proponent will work with relevant agencies and Indigenous communities to establish a terms of reference for the committee. The terms of reference would define committee purpose, scope of work, membership, reporting relationships, and meeting structure The terms of reference would specify the committee’s membership composition, including representation from Indigenous communities, technical specialists, and relevant government agencies.

The proponent has noted no funding has been set aside for capacity building in relation to the construction and management of the MFCAR, and that should the project be given approval to proceed, funding requests and opportunities related to future project phases would be addressed at a later date.

Ministry analysis:

In recognition of the concerns and interests expressed by a number of communities for involvement in project implementation mitigation and monitoring work, should the project be given approval to proceed, a condition of approval could be considered that would require the proponent to invite all of the Indigenous communities that were consulted during the EA process to participate in an environmental advisory committee.

Conflict of interest

Constance Lake First Nation raised concerns that Ontario is in a conflict of interest as both the primary funder of the MFCAR EA and the regulatory authority responsible for reviewing the EA and making approval decisions. The community expressed concern that this dual role, combined with stated provincial development objectives, undermines confidence in the independence and impartiality of the EA process and raises questions about Ontario’s ability to objectively assess environmental effects and fulfil its obligations for meaningful consultation with affected Indigenous communities.

Proponent response:

The proponent notes that this issue relates to Crown decision‑making and regulatory responsibilities and has therefore been deferred to MECP for a response.

Ministry analysis:

Funding arrangements, public policy objectives, and broader government infrastructure priorities do not alter or replace the statutory requirements of the EA process or the ministry’s obligations to review the EA against the approved ToR and the requirements of the EAA.

The EA planning and decision‑making framework is established in legislation and provides for the evaluation of potential environmental effects, consultation outcomes, and proposed mitigation measures to be conducted in a transparent and accountable manner. The ministry’s review focuses on whether the EA documentation meets the requirements of the ToR and the EAA and whether sufficient information has been provided to support a decision. Comments related to broader government policy direction or funding decisions do not change the scope or application of the ministry’s review under the EAA.

3.1.3 Conclusion of consultations 

Overall, for the EA process, the ministry believes that MFFN adequately documented consultation and provided appropriate opportunities for the public, GRT and Indigenous communities to be consulted during the preparation of the EA, including at key stages of the process. MFFN has committed to continuing to engage with and provide information to Indigenous communities, the public and the GRT during the implementation of the proposed project should it be given approval to proceed.

Generally, the ministry is satisfied that the consultation undertaken to date meets the requirements of the EAA, followed the consultation plan outlined in the approved ToR and is consistent with the Code of Practice for Consultation in Ontario’s EA Process and best practices. Refer to conclusions provided in appendix A with respect to consultation undertaken. Indigenous communities are invited to submit comments on the final community-specific ATRI reports and revised appendix O regarding ATRI during the ministry review comment period.

3.2 Conclusions pertaining to the EA process

MFFN followed a logical and transparent decision-making process to identify the preferred method for the proposed project, and considered the benefits and potential effects of the alternative road corridor options and supporting infrastructure evaluated in the EA.

The preferred road alignment and locations for supporting infrastructure were selected based on an assessment of environmental, social, cultural heritage and economic considerations, and were determined to best meet the project’s purpose and objectives, including providing safe and reliable year-round access between MFFN and the provincial highway network while seeking to minimize potential environmental effects.

The ministry is satisfied that the assessment considered the broad definition of the environment, the advantages and disadvantages of proceeding with each of the alternatives, and the potential effects following the application of mitigation measures.

The ministry is also satisfied that the process used to identify, assess and select the preferred alternative was consistent with the approved ToR and the requirements of the EAA.

Refer to appendix A of this ministry review for details of the ministry’s analysis of how the EA has met the requirements of the EAA and the approved ToR.

3.2.1 Monitoring and commitments

MFFN has committed to implementing monitoring and follow‑up measures during the construction and operation phases of the MFCAR, should the project be given approval to proceed. The EA describes follow‑up, compliance monitoring, and adaptive management commitments throughout the EA, with monitoring requirements and responsibilities identified by VC. Mitigation and monitoring measures specific to each VC are described throughout sections 8 and 9 of the EA, with cumulative effects monitoring considered in section 10. A consolidated summary of mitigation, monitoring and follow‑up commitments is provided in appendix AA (summary and recommendations tables), which draws from the technical support documents prepared in support of the EA.

The monitoring and follow-up program identified in the EA includes activities to:

• verify environmental effects predictions identified in the EA
• assess the effectiveness of mitigation measures and best management practices
• support adaptive management where monitoring indicates mitigation is not performing as expected
• document implementation of commitments made in the EA and, if applicable, any conditions of approval
• confirm the implementation of action plans and emergency response procedures, where required

The EA indicates that follow‑up and monitoring programs will include ongoing engagement with Indigenous communities and participation in monitoring activities, as well as involvement of qualified professionals during construction and operation of the project, as summarized in appendix AA.

The EA also outlines a framework for the development and implementation of project‑specific environmental protection, monitoring, and management plans to be applied during construction and operation. These plans are intended to provide guidance on mitigation measures and applicable legislative, regulatory, and policy requirements to be implemented throughout the life of the project. The preparation and use of such plans, including plans addressing topics such as erosion and sediment control, water management, fish and wildlife protection, spill prevention and emergency response, waste management, air quality and noise, vegetation management, and community health and safety, are identified as key mechanisms for implementing mitigation and monitoring commitments described in the EA and consolidated in appendix AA.

Below is a list of mitigation and monitoring committed to by the proponent in the EA:

• Before-after control-impact study will be conducted prior to construction and continue during operations to allow for a quantitative assessment of potential effects of the project (may include a moose access and monitoring plan, caribou collaring, sensory disturbance monitoring)
• Vegetation restoration plan
• Soil management plan
• Spill prevention and emergency response plan, spill contingency plan
• Blasting and communication management plan (for aggregate sites), explosives management plan
• Permafrost management plan
• Construction vibration workplan
• Equipment mobilization plans
• Stage 2 and 3 archaeological assessment where required as a result of the findings of a stage 1 archaeological assessment
• Cultural heritage evaluation report
• Waste management plan
• Emergency response plan
• Wildlife management plan
• Traffic management plan
• Environmental protection plan (includes wildlife sweeps, ungulates management and monitoring plan)
• Communications protocol
• Final biodiversity offset plan
• Construction monitoring of surface water, fish and fish habitat, groundwater, geochemical testing, invasive species, peatlands, rare plant and species at risk, vegetation near dewatering sites, nest surveys, caribou and moose. Monitoring for most VCs continues in operation phase where warranted
• Additional surveys/mapping/detail design for: aggregate pit/quarry locations, vegetation communities including sensitive areas, temporary access roads, staging areas, camps, and debris and/or timber stockpiles, and traditional use plant harvesting areas
• Additional surveys could include: black ash, active beaver lodges, pileated woodpecker habitat, effects to Albany River Provincial Park, re-evaluation of potential atmospheric/effects from work camps, prohibited locations based on traditional/spiritual use
• Sensitive data use agreement made with Ontario to obtain caribou data to support monitoring and mitigation commitments
• Community wellbeing programs and visual impact monitoring
• Collaboration with local existing environmental advisory committees to support the development and implementation of all environmental monitoring programs

The proponent recommends that the development of plans and community-based initiatives such as local training plans, local content plans, safety and wellness plans, and access management for hunting/trapping/fishing occur following any EAA approval.

4. Summary of the ministry review

The ministry review has explained the ministry’s analysis of the EA, and the following is a summary of this analysis:

• The ministry is satisfied that the EA has met the requirements of the ToR and the EAA.
• The ministry is satisfied that MFFN has provided sufficient opportunities for the GRT, the public, and Indigenous communities to provide input into the EA. The results of the consultations have also been clearly documented in the record of consultation provided in the EA. Appendix O (ATRI reports) are available for review as part of the ministry review 5-week comment period.
• The ministry is satisfied with MFFN’s responses to the comments submitted by the GRT, the public and Indigenous communities.
• MFFN used a clear and logical decision-making process to determine the preferred project in accordance with the approved ToR.
• The ministry has enough information about the potential environmental effects as documented in appendix A to enable a decision to be made about the proposed project.

4.1 Proposed conditions of approval

If the project is given approval to proceed under the EAA, conditions could be considered that would, if imposed address comments received on the EA. These could include:

• Documentation requirements for the public record
• Annual compliance reporting
• Requirement to invite the 22 Indigenous communities to participate in an environmental advisory committee, including developing and implementing environmental protection, monitoring, and management plans

5. What happens now

The ministry review is available for a 5-week comment period. During this time, all interested parties, including the public and Indigenous communities, can submit comments to the ministry about the proposed project, the EA, the revised appendix O and/or the ministry review. At this time, anyone can make a written request that the minister refer either all or part of the EA to the Ontario Land Tribunal for a hearing if they believe that their environmental concerns have not been considered.

When making a decision, the minister will consider the purpose of the EAA, the ToR, the EA, the ministry review, the comments submitted during the EA and ministry review comment periods and any other matters the minister may consider relevant.

The minister will make one of the following decisions, with the approval of the Lieutenant Governor in Council:

• Give approval to proceed with the project
• Give approval to proceed with the project subject to conditions
• Refuse to give approval to proceed with the project

Prior to making that decision, the minister may also:

• Refer the application (which consists of the ToR and EA), or a matter that relates to the application, to the Ontario Land Tribunal for a decision
• Refer matters in connection with the project to mediation

5.1 Modifying or amending the proposed project

Given the large scale and complexity of the project, and commitments to ongoing monitoring and consultation, it is anticipated that there could be proposed changes to the design and implementation of the project. The process to make changes to the project, if required, is set out in section 5.16 of the EA.

Making a submission

A 5-week public review period ending June 26, 2026, will follow publication of the ministry review. During this time, any interested parties can make submissions about the proposed project, the EA, the revised appendix O or the ministry review.

Should you wish to make a submission, please email: dorothy.moszynski@ontario.ca and simon.zhao@ontario.ca and address it to:

Kathleen O’Neill, Director
Environmental Assessment Branch
Ministry of the Environment, Conservation and Parks
Re: Marten Falls Community Access Road Environmental Assessment
Attention: Dorothy Moszynski and Simon Zhao, Special Project Officers

All personal information included in a submission-such as name, address, telephone number and property location of requester-is collected, maintained and disclosed by the ministry for the purpose of transparency and consultation. The information is collected under the authority of the Environmental Assessment Act or is collected and maintained for the purpose of creating a record that is available to the general public as described in s.37 of the Freedom of Information and Protection of Privacy Act. Personal information that is submitted will become part of a public record that is available to the general public unless a request is made that personal information remain confidential. For more information, the ministry’s Freedom of Information and Privacy Coordinator can be contacted at 416-327-1434.

To request an electronic copy, contact:

Dorothy Moszynski and Simon Zhao 
Special Project Officers, Environmental Assessment Branch
dorothy.moszynski@ontario.ca and simon.zhao@ontario.ca 

Appendix A: Environmental Assessment Act requirements

Requirements in O. Reg. 53/24: General and Transitional Matters

Summary of the EA

O. Reg. 53/24: s.4.(1)(a)

EA should contain a brief summary of the EA organized in accordance with the matters set out in subsection 17.6 (2) of the Act.

Analysis of the EA

An executive summary is provided before the table of contents and is organized in accordance with the matters set out in the EAA.

It presents an overview of the purpose and rationale for the MFCAR, describes the existing environmental and socioeconomic conditions, summarizes the development and comparative evaluation of project alternatives, outlines the potential environmental effects and proposed mitigation measures, and provides a summary of the consultation and engagement undertaken throughout the EA process.

1. List of proponent-led studies

O. Reg. 53/24: s.4.(1) (b)

EA should contain a list of studies and reports which are under the control of the proponent and which were done in connection with the project or matters related to the project.

Analysis of the EA

The table of contents provides a listing of technical assessments completed for the EA, and the EA and appendices provide further details regarding the types of studies that were completed.

2. List of additional studies

O. Reg. 53/24: s.4.(1)(c)

EA should contain a list of studies and reports done in connection with the project or matters related to the project of which the proponent is aware and that are not under the control of the proponent.

Analysis of the EA

The main report of the EA and the technical appendices contain references sections at the end for non-proponent studies and resources.

3. Maps

O. Reg. 53/24: s.4.(1) (d), 4.(2), 4.(3)

If the EA is for a project with a fixed location, at least two well-marked, legible and reproducible maps showing the location of the project and the area to be affected by it.

Of the maps referred to above, one shall be a simplified base map suitable for reproduction in any notices that may be published and the other may include more detail such as a 1:10,000 scale Ontario base map.

The maps referred to may show alternative proposals.

Analysis of the EA

Figure 1-1 is a well-marked map of the preferred road corridor and ancillary infrastructure. Several maps in section 4 (how we selected our road) show the alternative route corridors for each segment as well as alternative ancillary infrastructure.

Maps of the study areas for each environmental criterion are provided in the specific sections for those criteria (sections 8 to 10, life on our land, how the road will change our land, cumulative effects assessment). These include discipline-specific study area maps for surface water, fish and fish habitat, groundwater, peatlands, vegetation, wildlife, birds, ungulates, acoustic and atmospheric environments, cultural heritage, land and resource use, and visual environment. These maps are supported by accompanying mapping in the technical appendices.

In addition, several detailed maps are provided in section 4 (how we selected our road), including figures illustrating route alternatives for each of the three segments (Segment 1 — Ogoki Crossing, Segment 2 — Albany Crossing, and Segment 3 — North of the Albany). These maps show the alternative route concepts, their points of divergence, and the locations of alternative ancillary infrastructure.

Problem and opportunities

1. Identify an existing problem or opportunity and purpose of the project:

Environmental Assessment Act s.17.6 (2) (a)

The EA should contain a brief explanation of the problem or opportunity that prompted the proposed activity.

If a specific project has been identified provide a brief description.

Analysis of the EA

Section 2 (why we need this road) provides the rationale and purpose for the project.

The purpose of the project is to build a new multi-purpose all-season road of approximately 184 kilometres, which will connect MFFN to the Ontario provincial highway network.

Marten Falls is a remote community that is only accessible year-round by airplane and for a few weeks per year by a winter road. Air travel is costly, and the winter road season has become increasingly shorter and unreliable due to the impacts of climate change. The ability to bring food, clothing, fuel, housing supplies and health care into the community, as well as the ability for community members to travel in and out for social, educational and economic opportunities, has become increasingly expensive and challenging. The all-season road is proposed to help remedy these issues.

Alternatives

1. Description and statement of the rationale for the alternatives to:

Environmental Assessment Act s.17.6 (2) (b)(iii)

“Alternatives to” represent functionally different ways of addressing the problem or opportunity.

A reasonable range of “alternatives to” should be identified and evaluated. The proponent should be able to justify that it has considered a reasonable range of alternatives.

The “do nothing” ‘alternative to’ should be included in the evaluation and will represent the “benchmark” situation.

Analysis of the EA

In accordance with the approved ToR, the EA excluded consideration of ‘alternatives to’ as the ToR identified and justified a new all-season, multi-purpose road as the preferred “alternative to”.

The ‘do nothing alternative’ is assessed in section 4.1.1 of the final EA, as required by the ToR section 8. Section 4.1.1. summarizes the advantages and disadvantages of proceeding with the project versus maintaining the status quo, indicating that the do-nothing option would perpetuate high costs of living, limited access to essential goods and services and increasing unreliability of the winter road due to climate change.

2. Description and statement of the rationale for the alternatives methods

Environmental Assessment Act s.17.6(2)(b)(ii)

“Alternative methods” include a description of different ways of implementing the preferred “alternative to”.

A reasonable range of “alternative methods” should be identified and outlined.

Analysis of the EA

In accordance with the ToR (section 6.3), the alternative methods included three east-west route alternative segments, with one segment that included two options. The preferred alternative road corridor comprises the preferred options within each segment plus two other sections of the road that were common to both east and west alternatives.

The decision-making process explains how the proponent evaluated the alternative methods to determine the proposed project. Section 4 (how we selected our road) and appendix B (route selection methodology) assessed each road segment based on natural environment, social, cultural and technical criteria as well as IK and community feedback, to identify the preferred route for each segment.

The resulting preferred corridor is composed of the highest‑performing segment option in each of the three route segments, combined with two additional sections that were common to all alternatives.

Evaluation 

1. Description of the environment for the project and alternatives

Environmental Assessment Act s.17.6(2)(c)(i)

Proponents must consider the broad definition of the environment including the natural, biophysical, social, economic, built and cultural conditions.

The EA must provide a description of the existing environmental conditions in the study area.

The EA must identify those elements of the environment that may be reasonably expected to be affected, either directly or indirectly, by the proposed project and/or the alternatives.

Analysis of the EA

As part of the final EA, environmental studies have been completed to document and assess existing natural, socio-economic and cultural environmental features for both the preferred route and previously considered alternatives. The proponent grouped the 17 valued components, or environmental disciplines, listed below into three categories: water, land, and people.

Water

• Surface water
• Fish and fish habitat
• Groundwater and geochemistry
• Peatlands

Land

• Vegetation
• Wildlife
• Birds
• Ungulates
• Physiography, soils and terrain

People

• Acoustic and vibration environment
• Aboriginal and / or treaty rights and interests
• Cultural heritage
• Archaeology
• Atmospheric environment
• Community well-being
• Land and resource use
• Visual environment

Existing conditions for each of the disciplines listed above are described in detail in section 8 (life on our land) of the final EA/IS, supported by mapping and analysis in appendices F to V, and Y.

The three areas determined for each discipline were: construction disturbance (project footprint), local study area and regional study area. The study area size for each discipline could vary.

The final EA identifies the elements of the environment that may be reasonably expected to be affected, either directly or indirectly, by the proposed project and/or the alternatives. Direct and indirect effects are discussed in section 9.

The EA includes a discussion of the ATRI impact assessment, which is documented in community specific ATRI reports based on secondary sources, consultation, and IK that was not identified as confidential. In accordance with community specific IK sharing agreements, certain information was protected from public or third-party disclosure. While this information informed the proponent’s effects assessment, it resulted in the submission of redacted community specific ATRI reports to the ministry and IAAC in May 2026. To address these limitations and improve transparency, the proponent revised appendix O to include a consolidated summary of community level ATRI impacts assessment findings.

The revised appendix O is available on the proponent’s website, and comments on this summary may be submitted during the ministry review comment period.

As described in the final EA, these community‑specific ATRI reports include, for each Indigenous community:

• Project – environment interactions
  • Indigenous current use of lands and resources for traditional purposes
  • cultural continuity and well-being
• Description of community‑specific IK and land use information, gathered through IK sharing agreements, engagement activities, and available studies, and how this information informs the understanding of rights and interests.
• Proposed avoidance, mitigation, and accommodation measures, including measures to reduce effects on traditional harvesting activities, culturally important areas, travel routes, and access to lands and resources.
• Assessment of predicted residual effects on Aboriginal and treaty rights following the application of mitigation measures.
• Identification of follow‑up, monitoring, and adaptive management measures, including opportunities for Indigenous participation in monitoring programs and ongoing engagement during subsequent project phases.

Input received on the ATRI impact assessment to date has informed key project decisions, including refinements to the preferred route and the development of mitigation and monitoring commitments addressing issues such as culturally appropriate access controls, protection of traditional land and resource use areas, and Indigenous participation in ongoing monitoring programs.

In the final EA, the redacted community-specific ATRI reports, with the inclusion of the revised appendix O, demonstrate consistentcy with the ToR that the proponent has incorporated IK alongside western science in establishing existing environmental conditions and identifying valued components. IK directly informed the understanding of cultural, ecological, and rights-based baseline conditions and helped refine which environmental elements may reasonably experience direct or indirect effects from the project.

2. Description of the potential environmental effects for alternatives

Environmental Assessment Act s.17.6(2)(c)(ii)

Both positive and negative environmental effects should be discussed.

The EA must identify methods and studies used to analyze the potential environmental effects. The methods used are contingent on the type of project.

Impact assessment methods and criteria used during the evaluation should be identified.

The methods chosen must be clear, traceable and replicable so that interested parties can understand the analysis and logic used throughout the EA.

Analysis of the EA

The final EA includes an overview of the methods and results and incorporates feedback from Indigenous communities throughout and includes the final results or specific commitments made to communities related to impacts on Aboriginal and treaty rights.

Otherwise, the final EA provides a complete assessment of both positive and negative environmental effects across all other valued components. The effects analysis is documented in section 9 of the final EA/IS, with detailed discipline-specific assessments contained in appendices F to V, and Y.

Section 4 discusses how MFFN examined effects of alternative solutions to select their preferred solution of a new all-season road. Environmental effects of route segments are also discussed in appendix B – route selection methodology. The predicted residual effects in section 9 tables discuss direction of effects as either positive or negative.

Section 4.3.1 discusses how the alternative routes identified were then divided into segments based on geographic location. Appendix A contains metrics to help identify a preferred route based on these segments. Sections 4.3.3 and 4.3.4 describe how findings were presented to the community and feedback was incorporated into route selection. Route selection methodology is described in appendix B. The reasoned argument (trade off) method was used to qualitatively compare the advantages and disadvantages of route segment alternatives and included a relative significance of potential net effects.

Section 6 describes the methodology used for the final EA. It describes how IK was collected and used in effects assessment. The section also speaks to consultation and engagement and data collection for gender - based analysis plus. Section 6.3 speaks to the valued components identified through the environmental and federal EA/IS processes and further refined with community feedback. Section 6.4 summarizes the criteria and indicators chosen to measure potential effects for each valued component, with more detail provided in the technical documents in the appendices. Project phases and boundaries are described in section 6.5. Section 6.6 summarizes how existing conditions were documented and used to inform the selection of the preferred route in section 4. Section 6.7 discusses how the preferred route and the infrastructure associated with it were subject to a residual effects assessment.

Section 9.2 details the effects assessment approach:

• Review construction and operations activities to identify potential interaction(s) that could result in environmental effects
• Characterize the existing environment for both route alternatives
• Identify potential environmental effects of the preferred route and recommend mitigation measures to avoid or minimize identified effects as well as identify opportunities to enhance benefits to the environment
• Predict and assess potential environmental effects remaining after taking into consideration the recommended mitigation measures (in other words, residual effects) using direction, magnitude, geographic extent, duration, frequency, reversibility, and likelihood
• Predict cumulative effects that may result from a combination of the residual effects of the preferred route with the effects of other past, present, and reasonably foreseeable projects
• Identify a follow-up program for the preferred route that includes monitoring to verify the prediction of the effects assessment and effectiveness of the mitigation measures and a requirement for monitoring of the commitments made in the EA/IS Report

In feedback on the final EA, government reviewers identified several areas for further refinement including data gaps, inconsistencies in the EA, and modelling corrections. Government reviewers also requested commitments to implement mitigation and monitoring measures related to these matters. The proponent is updated appendix AA of the EA to consolidate commitments made to address public, Indigenous community and GRT comments.

The EA/IS describes positive effects, including improved access to services, enhanced community well-being, increased opportunities for traditional land use, and strengthened intergenerational knowledge transfer. It also evaluates negative effects, such as habitat loss, changes to hydrology, sensory disturbance, air emissions, and potential impacts to Indigenous rights and cultural practices.

The methods presented are clearly documented and can be readily traced and replicated.

3. Description of the actions necessary to prevent, change, mitigate or remedy the environmental effects for the alternatives

Environmental Assessment Act s.17.6(2)(c)(iii)

A description of future commitments, studies and a work plan may be included as part of the actions necessary to prevent, change, mitigate or remedy environmental effects for each alternative for the ultimate purpose of comparing them.

Analysis of the EA

The final EA provides a description of the future commitments, additional studies, and work planning required to prevent, mitigate, or remedy environmental effects. These commitments are documented primarily in section 14 (monitoring programs and future commitments), which outlines pre‑construction, construction, and operations monitoring programs, follow‑up requirements, and commitments that will be carried forward into detailed design and project implementation. Mitigation and management actions for each valued component are described within section 9 and within each corresponding technical support document (appendices F to V, and Y). These documents outline discipline‑specific commitments, including requirements for additional field verification, timing restrictions, adaptive management triggers, restoration plans, watercourse protection measures, wildlife movement considerations, community well‑being monitoring, and commitments to protect rights and cultural heritage.

Section 6.7.2 outlines how mitigation and enhancement measures are identified using a systematic process that evaluates each project environment interaction and considers IK, regulatory requirements, and discipline‑specific best practices. It explains that mitigation measures will be refined during detailed design, and that additional field verification, engineering refinements, and community input will guide finalization of these measures.

Section 6.9 outlines the approach for developing follow‑up and monitoring programs, including commitments to verify effects predictions, assess the effectiveness of mitigation measures, and apply adaptive management if needed.

The final EA does not incorporate a complete ATRI assessment, including mitigation and enhancement measures, residual impact predictions, cumulative impacts, and future commitments specific to ATRI. Table 9‑1 in appendix O outlines a summary of commitments. The province has requested the proponent to provide a summary of potential impacts in the final EA.

A final redacted community‑specific ATRI reports have been provided to Ontario by the proponent in May 2026. These reports have also been provided directly to each community for review, and communities will have the opportunity to provide input for consideration as part of the minister’s decision.

4. Evaluation of advantages and disadvantages to the environment for the project and alternatives

Environmental Assessment Act s.17.6(2)(d)

The preferred alternative should be identified through this evaluation.

Analysis of the EA

Advantages and disadvantages to the environment are evaluated in the Final EA.

Section 2 of the final EA outlines the purposes and context for an all-season road (the preferred alternative solution) while identifying the concerns and limitations associated with conditions (existing winter road and air travel).

Consistent with the approved ToR for a focused EA, the final EA evaluates alternative methods and the “do nothing” alternative. Section 4.1 provides a high-level comparison of the disadvantages of proceeding with the alternatives with Section 4.1.1 specifically detailing the limitations of the “do nothing” option and benefits with the preferred solution.

Section 4.2 describes the process used to identify route alternative methods. The evaluation and selection of route alternatives is documented in sections 4.3 and 4.4, with further details provided in appendices A and B.

5. Description of consultation with interested stakeholders

Environmental Assessment Act s.17.6 (2)(e)

A description of stakeholder consultation that occurred during the preparation of the EA needs to be documented and should include consultation methods used, frequency of consultation, dates that events occurred, target audience, descriptions of key milestones for which stakeholders are providing input, comments received.

The EA must identify any Aboriginal consultation efforts that have been made including methods for identifying potentially interested First Nations, who was consulted, when and how consultation occurred and any comments received from First Nations.

The EA should outline conflict resolution techniques used by the proponent to resolve outstanding issues with any stakeholders. There must be clear documentation as to how issues and concerns have been addressed.

Analysis of the EA

Section 11 of the final EA provides a summary of consultation and engagement to inform the EA from October 29, 2021, to September 5, 2025. This includes consultation on the first four project milestones: notice of commencement of EA, effects assessment methods, identification of preferred alternatives, and review of the draft EA/IS.

Appendix X contains a record of consultation with the public, government agencies and Indigenous communities. The record of consultation and engagement is organized into four milestone progress reports, each aligned with a key stage of the assessment process. These include milestone 1, covering the period from the notice of commencement of the provincial EA on October 29, 2021, to June 30, 2022; milestone 2, addressing effects assessment methods from July 1, 2022, to May 31, 2023; milestone 3, identification of preferred alternatives from June 1, 2023 to July 31, 2024 and milestone 4, documenting engagement on the draft EA/IS from August 1, 2024, to September 5, 2025. Progress reports 1 to 3 are available on the project website.

The final EA identifies that 23 communities have been consulted. Both rights-based and interest-based communities identified by MECP were consulted.

The proponent First Nation is also a potentially affected Indigenous community. MFFN was consulted by virtual and in-community meetings. Other neighbouring communities were consulted according to criteria described in section 11.2.2. Section 11.3 identifies the participants for the EA and how they were engaged, including funding for Indigenous communities. For Indigenous communities the following were identified by the ministry that may have constitutionally protected Aboriginal, or treaty rights adversely impacted by the Project and were included in the consultation process:

• Marten Falls First Nation
• Aroland First Nation
• Constance Lake First Nation
• Eabametoong First Nation
• Ginoogaming First Nation
• Neskantaga First Nation
• Nibinamik First Nation
• Webequie First Nation
• Long Lake #58 First Nation
• Attawapiskat First Nation
• Fort Albany First Nation
• Kashechewan First Nation
• Kasabonika Lake First Nation
• Kingfisher Lake First Nation
• Wapekeka first Nation
• Wawakapewin First Nation
• Wunnumin Lake First Nation
• Kitchenuhmaykoosib Inninuwug First Nation
• Weenusk First Nation
• Animbiigoo Zaagi’igan Anishinaabek (AZA)*
  • AZA was identified for rights-based consultation after the start of the final EA process.

Additionally, Indigenous communities to be consulted on an interest basis include:

• Metis Nation of Ontario, Region 2 and Greenstone Metis Council.
• Red Sky Metis Independent Nation
• Mishkeegogamang First Nation*
  • Identified by MFFN to be consulted on the project.

Sections 11.5 to 11.7 describe the frequency of consultation i.e. milestones and timing. Section 11.4 contains descriptions of key milestones for which stakeholders are providing input and their timing. Section 11.5 provides a complete list of consultation activities which included newsletters, individual community meetings, public information centres, provincially supported forums, and other notices. It also lists consultation activities’ timing and audience and describes the content of notifications and events.

Sections 11.7 discusses consultation and engagement with Indigenous communities and includes a summary of input and information received and how it was reflected in the first four milestone reports. Summaries were provided for government agencies and interested persons, see appendix X.

Section 11.3 states that potentially interested Indigenous communities were identified using lists provided MECP and IAAC, which considered proximity to the Project, potential impacts to Aboriginal and treaty rights, and regional affiliations.

Section 11.3.3 speaks to the IK program, how IK was collected and how it will be used.

Section  11.9 outlines additional consultation that occurred or comments received after milestone 4 (September 5, 2025). During this period, which continued through to the final EA/IS submission in February 2026, MFFN maintained active engagement with 23 Indigenous communities, government agencies, and other stakeholders through public information centres, meetings, monthly e-blasts and field notices.  Section 11.10 speaks to potential future consultation activities.

Section 11.11 outlines additional consultation and reporting requirements from the ToR amendments and the federal agency.

Section 11.12 outlines that ongoing issues resolution is occurring and how the proponent plans to resolve outstanding issues with any stakeholders. The Final EA discusses how the issue and resolution will be documented. For issues outside the mandate of the Proponent, the Marten Falls-Ontario Memorandum of Understanding on Shared Consultation Responsibilities allows those issues to be addressed by Ontario.

The EA outlines several approaches used to manage and resolve issues raised by Indigenous communities and other stakeholders. These include iterative feedback loops, where technical recommendations were revisited in response to community concerns (section 11.4), and Council to Council meetings with neighbouring First Nations to address issues related to land use, safety, and cumulative effects (section 11).

The EA also describes the use of IK sharing agreements, which sets out how IK was to be shared and incorporated into the assessment including provisions related to community control over how their knowledge was incorporated into the assessment (section 6.1). In addition, the proponent held regular meetings and targeted follow‑up sessions to resolve ongoing concerns, as documented in the consultation summaries provided in tables 11‑8 through 11‑11. These engagement activities informed adjustments to route alternatives and mitigation measures, which reflected issues identified throughout the consultation process (sections 4.3 and 9).

Selection process

1. Proposed undertaking

Description and statement of the rationale for the undertaking: 

Environmental Assessment Act s.17.6(2)(b)(i)

The description of the undertaking should specify what the proponent is seeking approval for under the EAA.

The description should include information on the location, attributes, dimensions, emissions etc.

The evaluation process should identify which is the preferred undertaking.

Analysis of the EA

Sections 1 and 2 of the final EA speak to the rationale for the undertaking. The section states the remoteness of the community, and the impacts climate change has had on the existing winter road. The only year-round access to the community is by air travel, which leads to high social and economic costs of limited access to the community. The final EA proposes a new 184-kilometre all-season road led by MFFN.

Section 4 documents the full range of alternatives considered, including continued reliance on the winter road, year‑round access by air, construction of a rail line, and the do‑nothing alternative, and concludes that an all‑season road is the only option capable of meeting the community’s long‑term access, safety, and socio‑economic needs. It also sets out the rationale for selecting the preferred alternative route, describing how the comparative analysis led to the choice of specific preferred segments for each portion of the alignment, and provides an overview of the ancillary infrastructure that forms part of the proposed undertaking. Sections 4.2 and 4.3 describes the alternative route development process. Section 4.4 identifies the preferred route, supported by a Band Council Resolution passed on August 26, 2024.

Section 6 describes project temporal and spatial boundaries. Section 6 also summarizes how information on existing conditions was gathered, and how it was used to identify the preferred route. The evaluation process described earlier in this table identifies the preferred undertaking.

Section 7 gives a description of the road and associated components. The road is approximately 184 km in length, with a two‑lane gravel platform approximately 12–13 m wide, set within a cleared 60 m right‑of‑way, and supported by bridges, culverts, aggregate sources, temporary access roads, maintenance facilities, and rest areas. Section 7.2 describes construction, operation, maintenance, and decommissioning activities; associated emissions (noise, dust, GHGs); and other project‑phase characteristics relevant to understanding environmental effects.

While the proponent has not yet finalized the ownership, operations, and maintenance model for the road, sectio 7 acknowledges that these decisions remain under discussion with the Province and will be confirmed as the project proceeds through detailed design and permitting. The EA acknowledges the need for further geotechnical investigation to confirm the feasibility of engineered approaches through detailed design.

Section 8 describes the existing environmental, social, and cultural conditions in the area of the proposed community access road and helps set the context for the undertaking under the EAA and the approved ToR. The section outlines where the project would be located, including the road corridor and the local and regional study areas used for the assessment of water, land, and people. It includes information on the general physical characteristics of the project, such as the road alignment, right‑of‑way, construction disturbance area, water crossings, and related project components. Section 8 also identifies potential sources of emissions and disturbances, including air emissions, greenhouse gases, noise, vibration, light, and changes to water and habitat. This information supports an understanding of the scale of the undertaking and provides a baseline that is used to assess potential effects and consider mitigation measures, consistent with the requirements set out in the ToR.

ATRI impacts were considered in the evaluation of the preferred undertaking through engagement with Indigenous communities and the incorporation of available IK as summarized in appendix O. ATRI considerations informed refinements to the Preferred Route and the identification of mitigation and monitoring commitments to address potential impacts on traditional land and resource use.

Next steps and additional commitments

1. Additional commitments

Outline any further commitments made by the proponent in the ToR and EA.

Analysis of the EA

Concordance tables for the ToR are provided in appendix C. The concordance tables indicate where the requirements and commitments of the ToR are addressed in the EA/IS.

Section 9 of each technical support document in appendix F to appendix V include detailed information, on monitoring programs to be conducted during pre-construction, construction and operations, and future commitments.

Additional commitments are provided in appendix O, as part of the ATRI technical support document.

2. Additional approvals

Outline additional approval requirements. Provide sufficient detail about the nature of the approval.

Analysis of the EA

Provincial and federal approval requirements associated with the Project are described in sections 5.1.1 and 5.1.2 of the EA, which outline applicable provincial Class EA approvals and federal Impact Assessment requirements, respectively.

A comprehensive, project wide list of all permits and approvals, including the responsible agency and legislative authority, is provided in appendix AA.

Collectively, this information provides sufficient detail regarding the nature and applicability of future approvals required for the Project.

Appendix B: Submissions received during the initial comment period

Table 1: Government review team comment-response table

To be provided with an electronic copy of this table, please contact Simon Zhao and Dorothy Moszynski, Special Project Officers, Environmental Assessment Branch, at simon.zhao@ontario.ca and dorothy.moszynski@ontario.ca, or 437-225-5790 / 437-247-9628.

Table 2: Public comment-response table

To be provided with an electronic copy of this table, please contact Simon Zhao and Dorothy Moszynski, Special Project Officers, Environmental Assessment Branch, at simon.zhao@ontario.ca and dorothy.moszynski@ontario.ca, or 437-225-5790 / 437-247-9628.

Table 3: Indigenous community and organization comment-response table

To be provided with an electronic copy of this table, please contact Simon Zhao and Dorothy Moszynski, Special Project Officers, Environmental Assessment Branch, at simon.zhao@ontario.ca and dorothy.moszynski@ontario.ca, or 437-225-5790 / 437-247-9628.