01-125: THE "ST. JOHN RESERVE" AGRICULTURAL SETTLEMENT

By Dorthea Calverley

 

Part I: The Historical Background of the

Ft. St. John Reserve Land.

 

The Indian Reserves in northern British Columbia are unique.

Treaty No. 8, signed in 1899, stipulated that it covered the northeastern corner of British Columbia. At that time, title to the land referred to was vested in the Provincial Government, which was not consulted about the matter. A peculiarity of the matter was the so-called Peace River Block dating from 1883 when the British Columbia Legislature granted to the Dominion (Federal) Government of 3,500,000 acres. This land grant was "to compensate for land alienated by the Province in the Railway Belt, prior to its conveyance to the Dominion for the purpose of assisting in the construction of the Canadian Pacific Railway". Since the Dominion Government did not select the area it wanted until 1907, the Dominion Government at the time of the treaty had a right to the three-and-a-half million unspecified acres, and presumably some rights under the Indian Act to the natives who occupied it. In other words the area’s boundaries, and the actual Indians who inhabited it were "up in the air".

It had been the practice of the Dominion Government to "extinguish Indian rights to the soil" by treaty. The choice of the word "extinguish" is a curious thing, even when used in the strictly legal sense. Besides the meaning, "to put out - as a light" it has "to quench - as quench hope, life faculties; - to obscure, a person by superior brilliance; - to reduce (an opponent) to silence; to destroy; - to wipe out (debt) - to annihilate". (Ref.: Oxford Concise English Dictionary.) "Extinguish" is a cruel word, exceeded only, perhaps, by "extirpate" meaning "to root out or destroy . . . a nation".

Treaty No. 8 is cited as "the only instance since Confederation in which title to Indian land within the Province (of BC) was extinguished", and it is characterized as "of considerable historical interest". In time, it could become of considerable legal interest!

If one thinks about the meaning of the word, it is apparent that in choosing this word to express what the Dominion Government was about to do, it expressed by inference that the Indians were conceded to have rights in the land.

The land in question was the traditional hunting grounds of "the Beavers and Slaves of the present Fort St. John (Indian) Agency".

"There was some delay in bringing the British Columbia bands under the treaty. In fact it is very doubtful that the local Indians knew that a treaty had been concluded which applied to them. The intention was to include all those who traded at Fort St. John and Fort Nelson. None were actually contacted in 1899, but in 1900 at Fort St. John, 46 Beavers accepted treaty payments. The number rose slowly each year until 1914 when there were 162. In that same year, the Hudson Hope Band of Beavers accepted treaty payments. By this time the Peace River Block’s boundaries had been set at approximately thirty-five miles both north and south of the Peace River and seventy-five miles west of the Alberta boundary, and was being administered by the Dominion Government. A short time before 1914 a band of Saulteaux had settled at Moberly Lake.

Beginning in 1912, land in parts of the Peace River Block was opened up for homesteaders, putting additional pressure on the federal government to deal with the Indians in the area through treaty.

Until 1914 no Indians had been allotted reserve lands in the Block, but in that year the three bands (Fort St. John, Hudson’s Hope, and Moberly Bands) were allotted their full entitlement of reserve lands. "The allotment was based on the number in each band, not to exceed one square mile (a section) for each family of five, or one-quarter section to each person for families or individuals that preferred to live off the reserve. The lands set aside were the

Halfway River Reserve #168, 9890 acres

West Moberly Reserve #168A, 5025 acres

East Moberly Reserve #169, 4490 acres

St. John Reserve #172, 18168 acres."

 

In 1904 a roving band of Beavers under "chief" Montagneuse had migrated into the Pouce Coupe area vacated by Pouce Coupe’s band, which had been all but wiped out by disease. A tiny remnant of the band had moved to Dunvegan as reported by Twelve-foot Davis to the Edmonton Bulletin. They continued to move around from place to place in search of food and furs, both of which were in short supply in this area. In 1904 the Indian Affairs Department arranged for this band to move to an area ten miles north of Fort St. John but it was not until 1914 that the eighteen thousand acres was officially set up as a reserve, designated as Monteney Indian Reserve #172 - later called the St. John Reserve. Title was conveyed to the Band (not the Indians individually.)

The Fort Nelson Indians were first brought under treaty in 1910, when 126 Indians "mostly Slaves and a few Sicannees" accepted treaty payments. In the following year payments were accepted by 131 Slaves and 98 Sekani (Indian Annual Reports, 1911, 1912.) Soon after that time almost all of the Sikani moved away, afterward to appear as "The Nelson River Nomads" in the reports of the Stikine Agency at Telegraph Creek. The Slaves continued to receive payments but no provision was made to give them reserves.

For six years the Indians were receiving money without any relation to land or to what was expected of them when they were "settled" upon land. The transactions involving money in exchange for the rights to the aboriginal land was not and could not be meaningful to a people whose business sense was based more on barter and sharing than ownership.

In 1916 the Royal Commission on Indian Reserves acknowledged its responsibility to give them reserves but "were not able to visit the band". A resolution was passed that when the Indian Department found itself able to make a census and recommend suitable lands. The Province should convey these to Canada. The Slave band did not claim its reserve entitlement until 1956, at which time its extent was set as 24 448 acres. Five years after the Indians claimed their right, the Province transferred the land to the Dominion and "full and final settlement of the Indian lands covered by Treaty No. 8" were finalized.

 

THE ST. JOHN RESERVE

 

While other reserve problems were being settled, the St. John Reserve was becoming unsettled.

The Beavers had originally been buffalo-hunters. Buffalo required grazing range. For generations the Indians had burned off the popular brush which covered most of this area, so that it would come up to grass. As soon as they got their reserve, the Fort St. John Band under Montagneuse promptly burned it off. This scandalized the few white settlers, but was quite reasonable from the Indians’ viewpoint. The buffalo, most of the moose and the fur-bearers having been killed off, the Indians had taken to trapping as a way of life. To go back where the fur bearers were and where there were moose and deer to convert into "dry meat" for winter use the Indians needed saddle ponies and pack horses which in turn needed grazing. The Indian Department had ambitions to make the Indians settle down, keep cows and pigs (which they detested) and grow garden stuff and grain for which there was no sale because there were so few settlers. So many parties of geologists, surveyors, prospectors and adventurers were coming into the area, that there was a ready sale for horses. The Indians showed good sense in pasturing their horses on the prairie lands in their reserve, and going out to the trapping areas in winter. After all, that is what many, many white settlers did, in the homesteading era. The difference was that, after paying a $10 "filing fee" a homesteader was obliged to put up a house, and to break ten acres of land each year for three years in order to "prove up". No such strings were attached to the Indian lands, so no wonder they "showed no inclination to settle down." Very few white men except Hector Tremblay had "settled down" prior to 1912, when a few townships were surveyed near the B.C. - Alberta border in the Pouce Coupe, Dawson Creek and Rolla areas.

After World War I the government brought in veterans to form the community of Sunset Prairie, which required no Indian reserve land. When World War II was in progress the government began looking around for another tract on which to settle more veterans. The way was prepared for conflict. A commission had looked over the B.C. Indian reserves to see whether the Indians were using them to full advantage in the white man’s way. Here was the Montney (St. John) Reserve of beautiful, rich loam growing luxuriant grass and peavine, with only light second-growth bush after the clearing-fires. This was not the only reserve where land wasn’t being "properly" used. A claim is being made by an Indian band in the Okanagan to recover lands on which part of the city of Penticton now stands. Here only four or five families lived permanently on the reserve all year round - the rest returned in summer. Old Chief Montagneuse had died in 1918, and was succeeded by Chief Succona. In 1947 the reserve was sold by the Department of Indian Affairs to the Department of Veterans’ Affairs.

A Department of Veterans’ Affairs was set up under which the late Gordon Murchison became the Director of Soldier Settlement. "He was resourceful, a man of dynamic personality and a tireless worker," attributes he set in motion to obtain as much good farm land as possible before demobilization of the troops took place. Provincial lands, C.P.R. lands, Investment Companies’ lands and "unoccupied Indian Reserves" were his special targets. Mr. Harry Allan, District Superintendent for Alberta notified Murchison about the quality of the Indians’ land at St. John Reserve No. 172. Before long the Veterans’ Land Administration had first refusal on a township of land. The government at Victoria treated "The Peace River Area" like an orphan child. They didn’t know its potentials and didn’t care, so negotiations proceeded through Alberta, egged on by the local branch of the Canadian Legion, the Canadian Commonwealth Federation Association (forerunner of the N.D.P) and the local press.

Field Supervisor, the Veterans’ Land Act Administration, Mr. G. H. Robertson (locally known as "Gil,") carried out an appraisal of the Reserve and in September 1944 made the following report:

"It is a most desirable block of excellent land that would be ideal for the development of a community venture for about thirty settlers on a half-section basis . . . The soil is amongst the best to be found in the Peace River Country and may even exceed the quality of the better parts such as the Rolla district."

That was superlative praise! Action was started to obtain the land. A notable team was involved besides Mr. Murchison.

1) Mrs. R. A. Hoey, Director of Indian Affairs Branch, Ottawa, who represented the Indians

2) Mr. Harry Allan, District Supt. Soldier Settlement and V.L.A. Administration, Edmonton, experienced in farming and stock raising, and a former District Agriculturist.

3) Mr. W. G. Duncan, Supervisor of Lands for Alberta.

4) Mr. D. J. Macdonald, former Regional Supervisor for the whole Peace Country succeeded by Mr. H. (Goldy) Goldfinch for a branch office at Peace River Town and Mr. A. F. Honner (Alf) for Dawson Creek, devoted to keeping veterans from settling on poor land.

5) Mr. Errel O’Sullivan who held the position of Office Manager and personal supervisor and counsellor of veterans.

6) Mr. J. A. Paul (Jack), Settlement Supervisor.

7) Mr. L. P. Worthington who, along with appraisals, arranged for an aerial survey which was used to divide the lot into farm units.

8) Mr. Kelly Haugen, born in the region, who supervised good farming practices, and especially took measures to control erosion.

9) Mr. Duncan Cran, a well-known surveyor. Several astute veterans persuaded Mr. Cran to hire them as "chain men" and thus got a decided advantage in selecting the best plots.

10) Mr. Cliff Stacey, Superintendent of the Dominion Experimental Station at Beaverlodge, a practical farmer as well as a scientist who gave expert advice on what to grow and how.

In all, five different Federal Departments and four Provincial Departments were involved. In Mr. Honner’s comprehensive report, which is the basis of this article, he puts it mildly when he says that "conflicting legislation and regulations were encountered and difficulties experienced" not to speak of the practical consideration of

Between May and August of 1946, Mr. Cran completed the survey and drew up the blueprints, for submission to the Dept. of Public Works at Victoria, and the Surveyor General at Ottawa. And then they waited - and waited - and waited - patiently explaining at long intervals why the pieces were irregular in shape. Finally in January 1947 word was received that the Chief Engineer, Dept. of Public Works, Victoria, had told the Department of Mines and Resources at Ottawa that the Veterans’ Land Administration had found out what was holding it up - "All existing roads had to be widened, all roads must be sufficiently graded. Some grades were too steep, and a road through a low spot had to be changed and access had to be provided to the S. W. quarter of Lot 20." Came another blow on March 4, 1947 - Indian Affairs advised that the V.L.A. would have to bear the cost of road construction - an unprecedented demand since the Province of B.C. was allowing other veterans to settle on Crown Lands without any question of roads! So off went "doughty old warrior" Harry Allan and Bill Duncan to do personal battle with the officials at Victoria. On the spot, the red tape was cut, and reasonable concessions were arranged.

By July 1946, a price of $70,000 was offered for a block of land appraised at $93,000. The Dept. of Indian Affairs at first refused but finally gave in. Since the money was to go into Band funds, we could say that the Indians lost $23,000, but the deal seemed about to go through.

Now, a month later, another bombshell - The Land Titles office of B.C. had more technical demands. In January a cheque was issued for Seventy Thousand Dollars. In May the title was registered.

The time involved seemed incredibly long to the veterans who were pressing the local officials for action, not to speak of the long-suffering staff through unexpected and seemingly senseless frustrations.

We do not know at this point what the Indians, the actual owners of the land, thought about it. Perhaps the Indians were as well satisfied with the very rolling, and less arable land they were settled on. We also do not know whether they will feel as the Okanagan Indians do who are now trying to get back, or get compensation for the land on which Penticton now stands. After all, there is land that has never been broken or improved within five miles of Dawson Creek, but owned by white men, who still have the privilege to sell at today’s prices.

Part III

Assuming that the sale would eventually go through, the Veterans’ Land Act Administration had tried to deal with the pressure of would-be veteran buyers to "get on with it".

From a report on the selection of possible settlers, we find that the men in charge were determined that the project was going to be a success. Many years after the event it was disclosed how they proceeded. At the time many veterans were being assisted to settle on farms of their own choosing outside the Reserve. All applicants for soldier settlement were "sized up" and a secret system of "ratings" was compiled. Veterans with little or no capital were not encouraged to apply but were set up on land "more in keeping with their ability". Veterans with higher ratings were advised to defer their applications, although no guarantee could be given that they would eventually be chosen. This caused a good deal of grief later. When the time to settle came, there was a backlog of veterans of good caliber to occupy the reserve.

The prime requirement was that the veterans must have resided in the Peace River Block before enlistment. Second, they must have been raised on farms, be well experienced, intelligent and industrious in nature.

Moreover, if married, their wives must have the same qualities. They must be those who would work together well in a community. They must be amenable to directions from the Field Supervisor and willing to follow directions for proper farm utilization. Such veterans as "passed" were issued a Qualification Certificate. The report states that there were no complaints from non-qualifying veterans.

When the "green light" came on, meetings had already been held with delegates from the four Legion Branches in the Block. It was decided that the land should be allocated by a lottery. First chance went to veterans with overseas service, the second on the following day for veterans with Canadian Service only. To expedite matters, two "draws" were set up for each day, the first to select the veterans who could participate in the "draw" the second day to determine the order in which they could select one of the farm units.

Bill Duncan carried out the "assembly line" procedure. After notification by letter and in the press, the veterans came not only prepared to select their unit, but to complete all papers with cost estimates of everything needed to set themselves up and a 10% initial cash deposit.

The draw took place at Fort St. John, May 3rd and 4th. Mr. Duncan made clear all of the covenants and terms of sale, and the way to get a further conditional grant at the end of ten years. Due to the "paper work" only eleven were processed on the first day for overseas veterans and four the next, thus disposing of fifteen units of good land and a grazing unit which went to the veteran on the adjoining land.

It was an elaborate but orderly procedure. Immediately the veteran had been "drawn" and had selected his unit he was steered to a long table where Mr. Philip Kench sat for registration and receipt, then to Mr. Kelly Haugen who discussed the $4800 allocation and how best to use it. Then Mr. Jack Paul wrote up and attested the application for Veteran’s assistance. Then finally the man had to meet the advisory Committee to get approval of the plans, and to Bill Duncan who signed the Approval of Expenditure. So well was it set up that District Office immediately set up the loans and made funds available.

Permits were made available to cut logs for buildings or firewood on three of the lots that were not suitable for farming. It was a good day’s work!

The remaining units were sold before the end of 1949 to veterans in the order of their applications, in all, forty-one veterans, since two purchased two units.

It might be interesting to record the name of the veterans who passed the rigid qualifications, and were able to participate in the draw for the fifteen choicest parcels of land:

Mr. M. A. Warden W1/2 Lot 7

Mr. J. B. Bjornson W1/2 Lot 12

Mr. J. Wopecka S1/2 Lot 11

Mr. C. N. Sparr W1/2 Lot 6

Mr. J. J. Wastrodowski Lot 25

Mr. A. N. Burton S1/2 Lot 15

Mr. N. R. Mitron N1/2 Lot 11

Mr. W. R. Sail S1/2 Lot 13

Mr. P. L. Sail N1/2 Lot 13

Mr. L. N. Mitron S1/2 Lot 14

Mr. L. G. Cavers N1/2 Lot 7 N1/2 Lot 2

Mr. C. L. Sculthorpe N1/2 Lot 4

Mr. C. L. Murray N 1/2 Lot 20

Mr. W. Almond SE7 and S1/2 Lot 2

Mr. E. D. McNeely NE8 and N1/2 Lot 1

 

Later established were Borge Langerud, George Dayton Clark, John Matt Martier, Brode Langrud, Chas Gunnlaugson, E. D. Large, J. F. Hurn, H. E. Knudsgaard, E. T. Lacina, J. T. Jarratt, A. W. Jeanotte, C. F. Kinderman, C. E. Elliott, L. C. Stark, C. Cameron, C. M. Stein, G. O. Langerud, R. J. Large, C. L. Avery, D. F. Hunter, W. J. Boughen, G. W. Clelland, C. C. Bessey, J. C. Finlay, K. Kirwood, and J. A. Clelland. Being included in this list is a sort of "Honour Roll" of extra-desirable farmer. 30 Army, 2 Navy, 5 R.C.A.F. and 2 Allied veterans, of whom 90% had seen active service, 79.5% Overseas. Only 3 had reached the rank of Sergeant.

97.4% were raised on a farm, 23% had farmed for themselves, and 92% had experience working on other people’s farms. The general level of education was said to be comparatively low, ranging from Grade 5 up, with only 5 having attained Grade 12. The largest number had completed only Grade 8. Eighty-six percent had cash assets of less than $1000, and 59% had other assets of less than $1000. It wasn’t exactly "starting from scratch", not counting the $4800 loan, but 8 of the settlers had cash assets between $1 and $249 and 4 had $2000 or over. Six had other assets - livestock, machinery or household effects worth less than $250 and only 11 had other assets of over $1500. Of these, none intended to go into ranching and 2 had no definite plans.

The "rating system" used is interesting. Each veteran was assigned points from 1 to 13 for various criteria. The single veterans rated pretty consistently between 5 and 10, with only three being in the 11, 12, and 13 group, and that in education.

The 12 married veterans had a tougher set of "exams." - age, health, agricultural experience, education, capital reserves, personality and character, and service record, and then the "crunch" - wife’s personality, character and aptitude. The final item considered was the number of dependent children.

Although the gentlemen in charge pronounced that the twelve wives were "satisfactory" to them, one got no points at all for personality and character, and none of them rated over 10 out of 13. While one wife got no points at all for "aptitude," the rest rated from 5 for three of them, to 11, 12, and 13 for another three. Clever ladies! On the basis of percentage of maximum points available, the average for single veterans was 66%, for married 67%.

Progress

Under Kelly Haugen the work began at once in an orderly fashion, by cooperative effort, and it was carried out thoroughly setting a good example of husbandry from the very start. In 1949 some of the finest stands of wheat and oats ever seen were raised. "Magnificent crops and a sight to see" with wheat yielding 70 bushels and oats 100 bushels per acre.

In July 1949 Dr. T. N. Stevenson, Dominion Agrologist, carried out an inspection tour with Mr. Stacey, Superintendent of the Beaverlodge Experimental Station. Dr. Stevenson said, "I consider this the finest example of land development of its kind that I have ever seen", and congratulated Mr. Haugen and Mr. Honner.

The average cost of clearing the land was kept a little below the estimate of $10 per acre.

When Mr. Haugen was transferred to a similar new program at Notikewin in Alberta, Mr. Jack Paul became Settlement Supervisor until ill health forced his retirement, to be followed by Mr. Erroll O’Sullivan.

In 1961 electric power came to the "reserve." as it continued to be known. When obviously natural blonde ladies mentioned that they "lived on the reserve," eyebrows registered a question when "outsiders" heard the remark.

The average cost was only $4.58 an acre; the average initial amount spent on building (V.L.A. money) was only $775, clearing and breaking $1333; water supply $295, fencing $210 and equipment $1200. In 1961 the salable value of the land was $45 to $50 per acre, not including the mineral rights attached to the title. Total average net worth was reckoned at $33,000.

Taxes, insurance and repayment of loans were 98.4% paid in full in 1959 and 100% in each of the years 1957 and 1958, "something a Supervisor only hopes to do in his dreams".

 

Reasons for Success

 

Mr. Honner made this assessment of the veterans and their success:

"It is often problematic as to whether it will prove successful to establish certain groups on a project; possibly more often than not it is an unwise venture. There are certain ethnic groups bound together by a religious faith, or nationality that will work together in order to preserve their particular identity. But unless there is a strong binding the groups are apt to break up into little sects and pull apart so that the principle of regression sets up dissension and decay.

"While there is a strong comradeship between veterans as a whole, it can be weakened by jealousies between different branches of the Services, length and type of service, or differences in former rank. There is always the danger of a few who have a chip on their shoulder and become agitators and preach the gospel of discontent. It needs something more than just being veterans to cement them together so they will work and prosper in unity. The concept of those who made the decision to set up a group settlement on the "reserve" was that something more would be found in the inherent spirit in these veterans. Furthermore, as they were being established in a pioneer area where a man traditionally respects and helps his neighbor, they would pull together and not apart. This concept proved to be correct and from the start the veterans worked side by side to brush and break their land. They shared their machinery with one another and developed a fine community spirit."

A rather humorous note creeps into Mr. Honner’s report when he comments on the failures of the administration. "Hindsight reveals the weaknesses, and in this connection one of the mistakes made was in establishing too many single veterans. It was a natural mistake because the laws of nature provide the instinct for young eligible bachelors to find themselves wives. Strange to say, this law did not work out on the Reserve and most of the unmarried veterans were still single [in 1961]".

Now comes a revealing comment on the role of the farm wife! "Bachelor farmers frequently do not take kindly to keeping livestock. After batching all summer they like to leave the farm and go out to work so as to enjoy the company of others and someone else’s cooking. It is for this reason there is not the livestock population ... that was anticipated. Much more concerted effort should have been made by the Administration during the inceptive years . . . to encourage livestock production . . . "One wonders whether Mr. Haugen set up a matrimonial agency on the Notikewin venture or whether he practiced "discrimination" against the non-marrying lads.

Not having livestock to utilize the forage, and finding that small seeds were bringing good prices, the veterans jumped too heavily into seed production. When seed prices dropped and alfalfa for some reason refused to set many were caught in the gamble.

When the gas and oil boom hit the Block in 1950 much of the activity centred on the Reserve. When the Beaver Band were given title in 1914, the Crown did not reserve the mineral rights. They passed to the Director, Veterans’ Land Act who held them in trust for the veterans. In 1950 the Sun Oil Company canvassed all on the reserve and obtained their signed consent allowing the Director to lease their gas and oil rights. Compensation was 50 cents per acre for the first year (1950) and 25 cents an acre for a further nine years plus a 12-1/2% royalty on any production. The first $7764.75 rental was prorated amongst the 41 veterans or their heirs and applied as a payment on their accounts. The following years’ payments materially reduced their annual payment on their loans. When Sun’s lease expired in 1959 only three veterans renewed their leases for one year for a total compensation of $5615.50. The rest considered the remuneration inadequate and advertised their lands for lease. Texaco made a much more adequate deal - a bonus of $16.56 per acre on 4633.9 acres or 12 lots. The first year’s rental of $81,371.48 was paid and one dollar per acre for another nine years guaranteed. The result was that by 1961, eighteen veterans had fully paid off their loans, and had title to their land.

As the boom continued, it became evident that producing wells might be sunk on certain properties, in which case those veterans might become wealthy, while others were left holding the bag. The spirit of co-operation led them to pooling their rights, the Director acting as trustee. Wells had not been sunk on the reserve up until 1961.

Because some veterans wanted to speculate on the mineral rights on the two and a half lots that were not suitable for agriculture, the lots were sold by public tender and the $24,231.04 was prorated among all.

The boom affected the settlement in other ways. There was a huge demand for unskilled labor around the wells, and later for the building of the W.A.C. Bennett Dam above Hudson's Hope. The unmarried veterans, especially, just put in crops and went off to work in construction for fantastic wages, returning in the fall to take off the crop. Further improvement of the reserve came to a standstill - especially the erecting of good buildings and the keeping of livestock. Where "big money" was made easily, it generally went the same way - many veterans formed the habit of living full time off the land. Thus the V.L.A.’s dream of a showplace settlement faded into a half-deserted area, at least for a time. The veterans, in all, received the sum of $129.615.00 from the oil companies.

 

Conclusion

 

Notwithstanding the interval of the boom years, the Fort St. John Indian Reserve project "could be rated as one of the most successful settlements of its kind. The project was meticulously planned and carried out and all those involved in its development deserved to be proud of their work.

Of the veterans none was a failure. They started with an average of $3500, and by 1961 were worth from $30,000 to $40,000. By 1974 that figure has expanded enormously.

 

This information is intended for research purposes only.

Any other use may violate one or more copyrights

which rest with the original authors

 

Update, 1998: In March of 1998 the Doig and Blueberry bands won a long court battle to get some of the oil and gas wealth flowing from the Reserve they lost in 1945. The federal government has agreed to pay $147 million in compensation to the two bands. The lawsuit took 20 years to settle. The money will be administered by the bands on behalf of all 400+ members of the two First Nations groups.

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