8. Comment Form Distribution
COMMENT FORM FOR NIRB SCREENINGS
The Nunavut Impact Review Board (NIRB) has a mandate to protect the integrity of the
ecosystem for the existing and future residents of Nunavut. To assess the environmental and
socio-economic impacts of the project proposal, NIRB would like to hear your concerns,
comments and suggestions about the following project proposal application:
Project Proposal Title:
Proponent:
Location:
Comments Due By:
Nunavut Coal Project: Fosheim Peninsula
Canada Coal Inc.
North Baffin Region
May 31, 2013
NIRB #:
13EN001
Indicate your concerns about the project proposal below:
 no concerns
 water quality
 terrain
 air quality
 wildlife and their habitat
 marine mammals and their habitat
 birds and their habitat
 fish and their habitat
x heritage resources in area
 traditional uses of land
 Inuit harvesting activities
 community involvement and consultation
 local development in the area
 tourism in the area
 human health issues
 other:____________________________________________
__________________________________________________
__________________________________________________
Please describe the concerns indicated above:
Archaeological research in the Fosheim Peninsula has shown that the region contains numerous
archaeological remains, and is of particular significance in documenting and understanding the
history of the Inuit and pre-Inuit occupations of Arctic Canada. Sites have been identified as
relating to the entire known range of Arctic occupations, from the Independence I Palaeo-Eskimo
people of approximately 5000 years ago to ancestral Inuit of the past millennium.
The extent and richness of the local archaeological record is not apparent in the report
(Archaeological Investigations for the Canada Coal Inc. Nunavut Coal Project, Class 2 Permit
Number 2012-034A, Final Report) presented by Canada Coal, in which the archaeological
remains located during survey are classified simply as “Pre-contact”, “Historic” or
“Contemporary.”
The cultural significance of the area derives in part from its unique environmental characteristics
as a “High Arctic Oasis”, with land mammal resources which attracted hunters throughout
history and supported unique terrestrial adaptations. Three specific periods can be noted as of
particular interest in the local archaeological record:
(1) The earliest Palaeo-Eskimo occupation of the High Arctic, by people of the Independence
I culture, dating from about 5000 years ago. Ellesmere Island sites have produced the
earliest radiocarbon dates relating to human occupation in Arctic Canada. The importance
of a muskox-hunting adaptation has been argued for this first movement of people into
the region, and is particularly well expressed in the “oasis” conditions of the Fosheim
Peninsula.
(2) The Dorset Palaeo-Eskimo culture, dating between approximately 2000 and 500 years
ago, in which the Fosheim region marks the most northerly significant occupation of this
8. Comment Form Distribution
culture in Arctic Canada.
(3) During the early Thule Inuit period the region was used by Inuit related to those who
inhabited the Bache Peninsula, which has the earliest remains of Inuit occupation known
from Arctic Canada. It has been suggested that the presence of early Inuit in the region
was associated with the acquisition of metal, both from the Cape York meteorites of
northwestern Greenland and from Greenlandic Norse ventures into the area. The
archaeology of the region is important in assessing whether it was the presence of metal
that drew ancestral Inuit eastwards from their Alaskan homelands. In this regard, a
portion of a bronze balance of the type used by mediaeval Norse merchants was
recovered from site SlHq-3 on the Fosheim peninsula, and this and other sites may
contain significant information relating to early relationships between Inuit and
Europeans.
The archaeology of the region extends the range of past Inuit land use and occupancy. The
evidence relating to initial Inuit occupation of Arctic Canada, and its relationship to contact with
mediaeval Europeans, is of particular interest to present-day Inuit. The community of Grise Fiord
has been associated with archaeological work on the Fosheim Peninsula, and shares concerns
relating to the heritage resources of the area.
Further information on the archaeology of the region could be obtained from the following
reported, which were not cited in the archaeological assessment report.
Sutherland, Patricia
1980 “Archaeological Excavation and Survey on Northern Ellesmere and Eastern Axel
Heiberg Island: A Preliminary Report.” Archaeological Survey of Canada. 44 pp.
1981 “Report to the Presidential Committee on Northern Studies, McMaster University:
Excavations at Buchanan Lake, Axel Heiberg Island.” Archaeological Survey of
Canada. 19 pp.
1983 “1983 Field Report, Eureka Upland Archaeological Project." Archaeological Survey
of Canada. 37 pp.
1989 “An Inventory and Assessment of the Prehistoric Archaeological Resources of
Ellesmere Island National Park Reserve.” Microfiche Report Series #43, Parks
Service, Environment Canada. 388 pp.
1991
“An Archaeological Inventory and Assessment of the Fosheim Peninsula, Ellesmere
Island, with a regional overview and a summary of archaeological research on the
Fosheim Peninsula and in Borup Fiord.” Report prepared for the Global Change
Programme, Geological Survey of Canada. 71 pp.
1992 “Archaeological Mitigation in Ellesmere Island National Park Reserve: Final Report
for 1989-1990.” Canadian Parks Service, Central Region. 59 pp.
1993 "Report on Preliminary Faunal Analysis of Six Site samples from the Eureka
Upland." Global Change Programme, Geological Survey of Canada, Ottawa. 25 pp.
1993
"Prehistoric Adaptations to Changing Environments on Western Ellesmere Island
and Eastern Axel Heiberg Island." Royal Canadian Geographical Society, Ottawa. 68
pp.
8. Comment Form Distribution
1994 "Chapter 10: Prehistory and History". (with Lyle Dick and Gary Adams). In
Resource Description and Analysis - Ellesmere Island National Park Reserve, pp. 101- 10-58. Natural Resource Conservation Section, Parks Canada, Department of
Canadian Heritage, Winnipeg
1998 The Archaeology and Petrology of Coal Artifacts from a Thule Settlement on Axel
Heiberg Island, Arctic Canada. (with Wolfgang Kalkreuth) Arctic 51 (4): 345-49.
2000 Preliminary Results of Archaeological Research on the Fosheim Peninsula and
Adjacent Areas of Western Ellesmere Island and Eastern Axel Heiberg Island. In
Global Change on the Fosheim Peninsula, edited by Michelle Garneau. Geological
Survey of Canada Bulletin 529, pp. 319-23. Ottawa.
Do you have any suggestions or recommendations for this application?
Further exploration and development should be conditional on full and complete archaeological
investigation and mitigation undertaken by researchers who have considerably greater expertise
than those who have undertaken the initial assessment report.
The archaeological report prepared for Canada Coal is clearly inadequate in assessing the
significance of local archaeological resources. It also underestimates the potential damage to
these resources by exploration and development; the archaeological sites described in the report
may not be situated on the exact locations of drill-sites, but an unknown number of sites will be
impacted by transportation and other off-site activities. Most of the archaeological features in the
region are clearly visible on the surface, and vulnerable to looting or disturbance from simple
curiosity.
I am particularly concerned by the comment from the Executive Summary of the archaeological
assessment report, stating that “the potential for Project impact to archaeological sites is deemed
to be low because archaeological investigations are being completed during exploration.” The
documentation described in this report significantly underestimates the quantity and quality of
potential archaeological information contained in many of the sites that were visited.
Do you support the project proposal? Yes  No x
Any additional comments?
Name of person commenting: Patricia Sutherland
Position: Adjunct Research Professor Organization:
Signature:
Date:
of Ottawa
Carleton University, Memorial
University of Newfoundland
May 31, 2013