Environmental Review

The environmental assessment of the Grays Bay Road and Port Project is being conducted by the Nunavut Impact Review Board (NIRB), the regulatory body established under the Nunavut Agreement to assess the potential impacts of proposed developments in Nunavut. The process is legally required, technically complex, and politically charged. The outcome will determine whether the project proceeds, and under what conditions.

The NIRB Process

NIRB operates under the Nunavut Planning and Project Assessment Act. When a project is proposed in Nunavut, it goes through screening and, if warranted, a full environmental review. NIRB determined that the Grays Bay project requires a full review, a determination that was confirmed by the federal minister.

The review centres on the Impact Statement filed by West Kitikmeot Resources in early 2026, prepared in partnership with Nunami Stantec Limited. This document is the proponent's comprehensive assessment of the project's potential effects on the natural and human environment. NIRB will evaluate the Impact Statement through technical review, public comment periods, and community hearings before making a recommendation to the responsible federal minister.

The Impact Statement covers an extensive range of subjects: air quality, noise, climate, terrain, soils, permafrost, vegetation, birds, terrestrial wildlife (including muskox, moose, grizzly bear, and wolverine), caribou, surface water, freshwater fish and fish habitat, marine water and sediment, marine fish and fish habitat, marine mammals, traditional land and marine use, community health and well-being, infrastructure and services, food security and food sovereignty, employment and economy, non-traditional land use, and heritage resources.

Caribou: The Central Environmental Concern

Of all the environmental issues associated with the project, caribou impacts generate the most concern. The project area intersects the range of the Bathurst caribou herd, one of the most studied and most troubled barren-ground caribou populations in Canada.

The numbers tell a stark story. The Bathurst herd has declined from an estimated 400,000 animals in the 1990s to fewer than 4,000 today. This catastrophic decline is driven by a combination of factors including climate change, habitat disturbance from mining and exploration activity, predation, and changes in vegetation patterns. The herd is under a harvest moratorium in the Northwest Territories.

The proposed road route passes through or near areas used by the Bathurst herd for calving, post-calving, and migration. Road infrastructure creates several potential impacts:

• Direct habitat disturbance: The road footprint and associated borrow pits physically alter caribou habitat.
• Sensory disturbance: Vehicle traffic, construction noise, and dust can cause caribou to avoid areas near the road, effectively reducing usable habitat beyond the physical footprint.
• Movement barriers: Roads can impede caribou migration, particularly during sensitive periods when animals are reluctant to cross novel features in the landscape.
• Increased access: Roads enable hunting access to previously inaccessible areas, increasing harvest pressure.
• Cumulative effects: The road enables mining development, which brings additional disturbance, creating cumulative impacts beyond the road itself.

The Impact Statement addresses caribou through field studies, population modelling, and proposed mitigation measures. However, the adequacy of these measures for a herd already in crisis is a legitimate subject of debate.

Permafrost and Terrain

Road construction through continuous permafrost inherently disturbs the thermal regime of the ground. While the road can be designed to minimize permafrost degradation (using insulating embankments, as done on the Inuvik-Tuktoyaktuk Highway), any construction activity on permafrost carries risk of localized thaw and subsidence, particularly in a warming climate.

Climate projections for the Kitikmeot region indicate continued warming over the project's design life, meaning the permafrost conditions at the time of construction will not be the same as those decades later. The engineering must account for a thermal regime that is actively changing, adding uncertainty to long-term stability projections.

Surface disturbance on tundra is also slow to recover. Vegetation in the Arctic grows at a fraction of the rate found in southern ecosystems. Disturbed areas along the road corridor may take decades or centuries to revegetate, if they recover at all.

Marine Environment

The deep-water port at Grays Bay introduces marine environmental concerns. The Coronation Gulf supports diverse marine life including Arctic char, ringed seals, bearded seals, and beluga whales. The waters are used by Inuit for traditional hunting and fishing.

Port construction and operation would affect the marine environment through:

• Physical disturbance from wharf construction and potential dredging
• Increased vessel traffic and associated noise, wake, and risk of fuel spills
• Discharge of ballast water from visiting ships, which can introduce non-native species
• Light and noise from port operations affecting marine mammals
• Potential for mineral concentrate dust during loading operations

The Scope Challenge: Oceans North

In March 2026, Oceans North, a marine conservation organization, filed for judicial review of the scope NIRB set for the environmental assessment. The core of their argument is that NIRB's scope covers only the road, port, and airstrip themselves, but excludes the mining operations and industrial shipping traffic that the infrastructure is designed to serve.

This is a substantive concern. If the environmental assessment examines only the road and port in isolation, it cannot account for the cumulative environmental effects of the mines, truck traffic, and bulk carrier shipping that would follow. Oceans North argues that the infrastructure and the industrial activity it enables are functionally inseparable and should be assessed together.

WKR and its supporters counter that the road and port are general-purpose infrastructure that would serve multiple users and purposes (including military and community supply functions), and that individual mining projects will undergo their own separate environmental assessments.

The outcome of this legal challenge could significantly affect the project timeline and the scope of environmental protection measures required.

Inuit Perspectives

Inuit perspectives on the project are not monolithic. The Kitikmeot Inuit Association, as majority owner of WKR, is the project proponent and views the road and port as essential infrastructure for economic self-determination and improved quality of life in the region. The KIA has emphasized that the project would create employment, reduce the cost of goods, enable mining royalties, and connect isolated communities.

Other Inuit voices have raised concerns about impacts on traditional land use, caribou hunting, and the marine environment. Food security in the Kitikmeot is closely linked to access to traditional foods, particularly caribou and Arctic char. Any project that could reduce the availability of these food sources affects community well-being in ways that economic benefits may not offset.

The NIRB process provides formal opportunities for community input, and the Impact Statement includes a Traditional Knowledge component. Whether the process adequately captures and weighs the full range of Inuit perspectives is a question that will be tested through the public hearing process.