Cree First Nation v. Canada, 2. 00. 5 S. C. J. No. 7. 1 SCC at paras. Mikisew Cree and Little SalmonCarmacks at para. The duty to consult was previously recognized in other contexts but Haida and Taku River fundamentally altered the legal landscape in. SCC recognized that the duty extends to asserted but not. Aboriginal rights and title and it established the overall framework. See, for example Sparrow at. R. v. Nikal, 1. 99. S. C. J. No. 4. 7 SCC at paras. R. v. Gladstone, 1. S. C. J. No. 7. 9 SCC at paras. Delgamuuk at para. Return to footnote 7 referrer. Footnote 8. Haida at para. The honour of the Crown is a constitutional. Crowns assertion of sovereignty over an. Aboriginal people and de facto control of land and resources that were formerly. Its purpose is the reconciliation of. Belkin Wireless G Extender Software Engineering. Aboriginal societies with the assertion of Crown sovereignty and. It requires the. Crown to act honourably in its dealings with Aboriginal peoples, although SCC. Manitoba Mtis Federation that not all interactions between Aboriginal peoples. Crown engage the honour of the Crown. See also Little. SalmonCarmacks at para. Manitoba Mtis Federation Inc. Canada, 2. 01. 3 S. C. J. No. 1. 4 SCC at paras. Return to footnote 8 referrer. Footnote 9. Mikisew Cree at paras. Little SalmonCarmacks at paras. Return to footnote 9 referrer. Footnote 1. 0Haida at para. Return to footnote 1. Footnote 1. 1Haida at paras. Return to footnote 1. Footnote 1. 2Haida at para. Return to footnote 1. Footnote 1. 3Mikisew Cree at para. Return to footnote 1. Footnote 1. 4Taku River at para. Brokenhead Ojibway Nation v. Canada, 2. 00. 9 F. C. J. No. 6. 08 FC at para. BrokenheadReturn to footnote 1. Footnote 1. 5Haida at para. Return to footnote 1. Footnote 1. 6Grassy Narrows First Nation v. Ontario, 2. 01. 4 S. C. J. No. 4. 8 SCC at para. Grassy Narrows. Return to footnote 1. Footnote 1. 7Haida at para. Mikisew Cree at para. Little SalmonCarmacks at para. Yellowknives Dene First Nation v. Canada, 2. 01. 5 F. C. J. No. 8. 29 FCA at para. Return to footnote 1. Footnote 1. 8Haida at para. Halfway River First Nation v. British Columbia, 1. B. C. J. No. 1. 88. CA at. para. 2. 4 Halfway River Long Plain First Nation v. Canada 2. 01. 5. F. C. J. No. 9. 6 FCA at para. Long PlainReturn to footnote 1. Footnote 1. 9Tsilhqotin at paras. Return to footnote 1. Footnote 2. 0Nunatukavut Community Council v. Canada, 2. 01. 5 F. C. J. No. 9. 69 FC at paras. Nunatukavut Hupacasath First Nation v. Canada Minister of Foreign Affairs, 2. F. C. J. 9. 27 FC at para. Snuneymuxw First Nation v. Board of Education School District 6. B. C. J. No. 1. 34. SC at para. 5. 9 Gitxaala Nation v. Canada, 2. 01. 5 F. C. J. No. 2. 89 FCA at para. Return to footnote 2. Footnote 2. 1Examples of this include Environment and Climate Change Canada, the Canadian Environmental Assessment Agency, Transport Canada, the Canadian Nuclear Safety Commission, and Parks Canada. Return to footnote 2. Footnote 2. 2These training sessions cover a wide range of consultation and accommodation issues and provide further guidance on common challenges and legal developments in this area. Between 2. 00. 8 and 2. Consultation 1. 01 session. Since 2. 01. 2, INAC has provided training in a more in depth two day Consultation 2. Return to footnote 2. Footnote 2. 3Regional Consultation Coordinators RCCs work to improve coordination amongst federal departments and agencies and with provinces and territories as well as negotiate consultation protocols, among other things. The coordination role of RCCs is largely internal but their ability to coordinate depends on their powers of persuasion asthey do not have any authority over other departments. They do not interact significantly with Aboriginal communities, although there are some exceptions. The RCCs also have other non consultation related responsibilities in their respective regional INAC offices. Return to footnote 2. Footnote 2. 4These Committees include Deputy Ministers, Assistant Deputy Ministers, or other senior representatives from INAC, Natural Resources Canada, Environment and Climate Change Canada, Fisheries and Oceans, the Department of Justice, the Canadian Environmental Assessment Agency, the Canadian Northern Economic Development Agency, the Canadian Nuclear Safety Commission, and the National Energy Board. Return to footnote 2. Footnote 2. 5Canadian Northern Economic Development Agency, Community Readiness. Return to footnote 2. Footnote 2. 6See Major Projects Management Office West. Return to footnote 2. Footnote 2. 7Douglas R. Eyford, Forging Partnerships, Building Relationships Aboriginal Canadians and Energy Development, November 2. Return to footnote 2. Footnote 2. 8Some federal departments and agencies have issued additional guidance to proponents, such as the Canadian Nuclear Safety Commission in REGDOC 3. Aboriginal Engagement and the National Energy Board in its Filing Manual. Return to footnote 2. Footnote 2. 9A couple of participants raised concerns with the insufficiency of consultation by Parks Canada for the creation of additional park lands. The failure of Parks Canada to consult with an Aboriginal group was also the subject of the first SCC case that considered whether Canada had met the duty to consult see Mikisew Cree. Return to footnote 2. Footnote 3. 0Parks Canada, Promising Pathways Strengthening Engagement and Relationships with Aboriginal peoples in Parks Canada Heritage Places, 2. Promising Pathways Parks Canada, The Land is Our Teacher Reflections and Stories on Working with Aboriginal Knowledge Holders to Manage Parks Canadas Heritage Places, 2. Return to footnote 3. Footnote 3. 1I have reviewed many guidance documents across the country for this engagement and this one distinguishes itself in its practicality and message, including, among other things, providing helpful lessons from the field of Parks Canada employees, examples of specific successful relationship building initiatives, as well as a message from the former CEO which makes it clear that it is an organizational priority. Return to footnote 3. Footnote 3. 2See British Columbia, Building Relationships with First Nations Respecting Rights and Doing Good Business. Return to footnote 3. Footnote 3. 3 The 2. Guidelines state that reconciliation has two main objectives 1 the reconciliation between the Crown and Aboriginal peoples and 2 the reconciliation by the Crown of Aboriginal and other societal interests. This does not explain what is exactly being reconciled.