2.1 Purpose of Federal Impact Assessment

6 months ago
CLOSED: This map consultation has concluded

Impact assessment aims to identify and address potential issues and concerns early in the design of projects, plans and policies. In so doing, it can contribute to the creation of positive relationships among various interest groups, including reconciliation between Indigenous Peoples and non-Indigenous peoples.

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Please tell us your thoughts on what the Expert Panel proposed in this section.

Barbara Payne, Electromagnetic Pollution Illnesses Canada Foundation (EPIC) over 1 year ago
Canadians deserve the right to a healthy environment, including easy access to areas (for sleep, healing practices, and activities of daily living) where secondhand exposure to anthropogenic non-ionizing radiation emissions is rigorously truly negligible or absent. Impacts on fauna (including humans) and flora exposed to the anthropogenic non-ionizing radiation generated to enable power and ‘wireless’ connectivity and usage are extensively documented. It is essential that impact assessment of any method proposed to achieve a specific outcome include assessment of proposed and alternative methods that already are, or could be made, available. Assessment of all methods and potential environmental health impacts is essential prior to rollout of information, communication, and power technologies. Contamination of children and adults in Canada by firsthand and secondhand exposures to anthropogenic non-ionizing radiation occurs daily and is widespread, yet new non-ionizing radiation generators and emissions are being deployed to introduce or densify this pollution in all regions of Canada without prior impact assessment.
Martin Olszynski over 1 year ago
A good idea if the subsequent process does not allow proponents and/or governments to postpone the actual assessment of environmental effects to subsequent regulatory processes on the basis that such a level of detail is unnecessary at the EA/IA stage (which happens presently).
Marilyn Eriksen over 1 year ago
As a former government Compliance and Enforcement Officer, Quality Assurance Specialist for a fortune 100 firm and Public Health Professional with 20 years Risk Assessment experience I am glad to see the inclusion of Strategic Impact Assessments to provide guidance on how to implement government policies, plans and programs within the 5 pillar sustainability and Pan Canada Framework.
Marilyn Eriksen over 1 year ago
When providing access to information on the project please insure that the databases used are "user friendly" and that CSA standards and other technical standards are made available on line to participants.
Marilyn Eriksen over 1 year ago
I support the Proposed Process that provides for early participation and that allows all concerned citizens to participate by removing barriers such as having to prove that the project directly impacts the participant.
Marilyn Eriksen over 1 year ago
The Panel reference to "federal interest" presents a Red Flag to me. Although there is provision for Regional IA working in cooperation with federal project IA, a recommendation that I support, I would like to see included mention of provincial and municipal interests. The misleading "minor" project scope of the NEB Line 9 project left the Provinces of Ontario and Quebec without an Environmental Risk Assessment along the pipeline. The Province of Ontario told its concerned residents that it could not conduct an EA along Line 9 as the pipeline was a Federal Jurisdiction. NEB permitted the EA to be conducted only at the pumping stations leaving several Municipalities concerned about threats to costly City infrastructure and vulnerable residents living along the pipeline without an IA . I am encouraged to see that at least the interests of our Indigenous People are being considered but am still concerned about our non-indigenous people, particularly in highly populated cities like Toronto, rural communities and farmers on prime agricultural lands living along the pipeline who may lack a voice (by not fitting into the federal interest criteria) . I support the IA considering short term and future impacts on the 5 pillars, but I suggest that IA legislation provide for conducting periodic IAs throughout the life cycle of a project as communities continue to grow in proximity to projects with changes bringing potential risks initially not identified in the original IA.
Marilyn Eriksen over 1 year ago
I agree with the extending the EA to 5 pillars of sustainability IA. The inclusion of cultural and health facilitates a more inclusive Risk and Benefits Assessment including but not limited to Indigenous concerns. Please ensure that CNSC , oil and LNG pipeline projects are included as mandatory IA s, under the Governance model of an Impact Assessment Commission. NEB has proven, in the case of Line 9 pipeline, to lack independence from industry it regulates resulting in loss of public trust in NEB's decision making. Please ensure that both "minor" and "major" projects are assessed as the Line 9 project was misleadingly defined by the proponent and NEB as a "minor" project when in fact a major one and as a result to date the pipeline has not undergone an assessment along its 900 plus km. This injustice has created concerns to this day to communities living along the line and large legal fees to the Chippewa of the Thames 's, fees preventable had NEB proceeded at arm's length from the industry it regulated and consulted meaningfully.
Betty Geier over 1 year ago
I support the recommendations of the Expert Panel. I lived for a time on a reserve in Northern BC. I believe it is imperative that Indigenous rights and authority be upheld and that their consent be obtained for a project to proceed.
Dneo over 1 year ago
This is overreaching. It will result in the federal government intruding into areas of provincial and territorial jurisdiction. There are existing processes and safeguards to avoid or mitigate impacts on the environment. This encourages interference from ideologically driven individuals and organisations, including foreign concerns. If a proposed project is economically viable, satisfies provincial or territorial requirements, and provides a net benefit for a majority of the population it should be permitted to proceed. This is a very bad idea.
Meg Sears for Prevent Cancer Now over 1 year ago
Canadians deserve a right to a healthy environment, including clean air, water, soils, healthy ecosystems, and low levels of anthropogenic (caused by people) ionizing and non-ionizing radiation. Up front, IA should examine need, merit and alternatives to achieve a particular end. Only once communities and Canadians overall (depending upon scale) agree on need, feasibility and preferred alternative, then is it time to examine feasibility and optimize design of a particular project, with impact assessment as outlined in the document. Up front considerations should include higher-level considerations of options. One example is the possibility that a pipeline over large distances should only transport the safest possible petroleum products. In this case, transportation of dilbit would be proscribed, and the jobs would be created and hazards reduced close to the origin of the material.Another example of need to assess alternatives and potential environmental health impacts is rollout of wireless technologies. Impacts on wildlife are well documented (e.g. the US Dept. of the Interior has expressed concern); effects on humans of today’s exposures are extensively reported, and now a whole new technology – 5G – is being rolled out with zero impact assessment.
Anna Johnston, West Coast Environmental Law over 1 year ago
West Coast supports the Panel’s recommendations in this section. Regarding when federal EAs should occur, it should be noted that as climate change is a cumulative effect, all greenhouse gas emissions must be considered to be of “national significance.” Otherwise, both our climate and our progress towards achieving our climate reductions goals will suffer the “death by a thousand cuts” that causes cumulative effects. Regarding IA as a planning tool, we note that early engagement enhances strategic assessments in addition to project and regional assessments. Therefore, SIAs should also entail early collaborative planning wherever proposed policies, plans or programs are not subject to Cabinet confidence. We strongly support the Panel’s recommendation that a sustainability approach be adopted, and note that for IA to be successful, a sustainability approach will have to: recognize that the “pillars” of sustainability are in fact interactive and interrelated; provide equal weight to the goal of achieving net benefits to the environment, in addition to social, health, cultural and economic gains; and legislation should establish both generic sustainability criteria and trade-off rules in addition to those that should be developed on a case-by-case basis. Regarding the focus of federal EA on matters of federal interest that are consequential to present and future generations, we strongly urge that the determination of what gets assessed be a low threshold that captures all undertakings within federal jurisdiction, in recognition that even small projects and activities contribute to cumulative effects (see our comments on section 3.2).
Ecology Action Centre over 1 year ago
The Panel carried out widespread consultations on environmental assessment in Canada and provided numerous opportunities for interested individuals and organizations to provide input. In response to what they heard the Panel is recommending a major overhaul of CEAA 2012. We have participated in numerous environmental assessments in Atlantic Canada over the years and agree: federal EA is broken and needs to be fixed. We broadly support the Panel’s recommendations in the areas of sustainability, public participation, indigenous rights, removing NEB and CNSC as RAs, strategic and environmental assessments, governance and a cooperative approach between jurisdictions. In our submission we paid special attention to reclaiming science and other forms of knowledge in the EA process, in particular restoring the scientific integrity of environmental impact statements or impact assessments. An impact assessment is the foundational document of the IA process and if it is flawed, incomplete and mediocre, so too will be the entire exercise. The Panel has made some strong recommendations on how a new governance model will deliver good, independent science in the service of EA. We look forward to engaging with the federal government as it responds to the panel’s recommendations and begins the process of transforming their recommendations into legislation and policy.
Friends of Morice Bulkley over 1 year ago
We support the aim of early consultation to determine if a project fits with the sustainability objectives of the region. A great deal of money can be wasted by a proponent trying to justifying a project which conflicts with regional vision.
Jess over 1 year ago
I am concerned that IA proposal does not take full consideration of long-term cumulative effects, that the process be inclusive, that decisions be transparent and science-based, with consideration of indigenous traditional uses, and cultural impact.I do not see evidence that the proposed process will be broadly applicable to a wider range of small and medium sized projects. Yes, this will be a burden, and it is essential because the impacts of even small projects can be substantial cumulatively and/or over time. If not addressed at the outset, the effects of those project ‘externalities’ become costs to society that should be borne by those who impose the costs, not by future generations. To balance this, the IA process must be timely, cost-effective and consistent to avoid imposing undue costs on project proponents. Public participation, transparency of process, and ongoing monitoring are paramount. It is difficult to see how the above are possible with the IA so late in the overall process - too late to make any real difference. The true measure is whether the IA has the authority to actually halt projects with excessive overall impact.
L Ablack over 1 year ago
I am am very supportive of the proposed IA process which addresses many serious issues including some I am familiar with due to experience as a stakeholder. i.e.: Lack of transparency and and a public engagement process that comes too late to be able to make any difference as well as not enough input or consideration. In addition; through research into other stakeholder experiences, have discovered the committee members chosen for monitoring do not include public participation. I also would like this IA process to be able uphold and maintain the the value of the 5 pillars structure throughout the IA process and afterwards in perpetuity for monitoring. I hope to see a process such as this inspire and foster new thinking in project development and design so we may see an ecologically ,responsible, respectful future become mainstream. I feel that in order to see this processes truly support the 5 pillars from project conception to project end of life that the vision and IA should also incorporate Fundamental Human Rights - The right to clean water, clean air, safe fertile agricultural soils and healthy ecosystems none of which we can survive without.
Pat Moss over 1 year ago
Agree that the new legislation should be focussed on broader "impact assessment" rather than just environmental assessment. Impacts should include social and economic factors as well as examine cumulative effects.
Jane Howe over 1 year ago
I support the purpose as outlined in the Report, however, there is a risk that it may be too broad and extend federal oversight into areas that are the jurisdiction of the provinces and territories.
Elizabeth May over 1 year ago
The panel has recommended restoring one of the key features of pre-2012 environmental assessment - that any project be reviewed as early in the planning process as possible and before irrevocable decisions have been made. Essentially, environmental assessment (or a future impact assessment) is a planning tool. Early engagement of citizen groups, interested stakeholders and Indigenous peoples (First Nations, Inuit and Métis) must begin as early in the planning process as possible. The most important of these recommendations is related to 2.1.1 – that a federal IA should be triggered where either federal lands, federal funding or federal interest (as it relates to all matters under federal jurisdiction) are involved. One of the most damaging aspects of the Harper administration’s evisceration of Environmental Assessment was the decline in projects assessed under the framework – and drastically narrowing the scope of federal review. I am very pleased to see that Panel has recommended the emphasis return to ensuring federal interest, including funding, lands or jurisdiction, are central to determining the necessity of an Impact Assessment (IA). I also strongly support the inclusion of greenhouse gas emissions of national significance as a factor to consider in determining federal interest, as had been accepted practice before 2012. The Government should go further to legislate that all projects should be considered against the backdrop of our continued commitments to reducing emissions under the Paris Agreement. The emphasis should be on ensuring clarity in the legislative framework as to which projects will trigger environmental assessment. Government, non-government and corporate actors all will benefit from a legislate framework that lays out a clear, and hopefully extensive, scope for what triggers an IA. It is unfortunate that the process before us has separated the changes made to the Fisheries Act and the Navigable Waters Protection Act under the twin 2012 omnibus bills, C-38 and C-45. Those changes were made in a coordinated fashion to dismantle review of the vast majority of projects. The restoration of public trust and effective assessments requires the restoration of all three federal acts to their pre-2006 status. That entails rebuilding the "triggers" found in the pre-2006 CEAA.To reduce the number of duplicative reviews of small and similar projects, I support the expert panel's reliance on regional and class assessments. As to the matter of Impact Assessment – I agree that projects should be regarded holistically, with a strong focus on economic and social factors in addition to environmental assessment. The pre-2006 CEAA included in the broad concept of "environment" the socio-economic impacts, cultural impacts and community values. These should be restored, as should the requirement that alternatives to the project also be assessed.Where possible, and where co-operation allows, other impartial regulatory bodies should be responsible for these assessments, for example public utilities commission on the necessity for large energy projects. These analyses should undoubtedly be incorporated into federal IAs, as we have seen most recently in the deeply flawed Trans Mountain assessment process, where the National Energy Board refused to hear evidence on the project’s long-term economic sustainability or impact on jobs. The environmental reviews of Site C and Muskrat Falls both recommended that the projects be submitted to Public Utility Commission reviews. In both cases the provincial governments refused to do so and the federal government approved the projects claiming that benefits outweighed the clear environmental damage. in both cases, there was no evidence of benefits because no regulatory process had conducted a cost-benefit analysis.So long as traditional regulatory, economic reviews are by-passed, it is valuable to broaden the scope of environmental impact assessments to impact assessments. But the skills and mandates of the review agencies are different. Ideally the federal IA process would have the power to insist that no project could proceed without the appropriate body conducting an economic review. However, I would equally adopt the caveat of West Coast Environmental Law: that there should be “clear rules concerning what trade-offs are not acceptable,” to ensure that economic benefits should not outweigh environmental and human health concerns. There is a slippery slope here, as identified by Nature Canada in their response to the Panel’s recommendations. While the panel may seek to avoid ‘adversarial’ relations at the outset of an IA by shifting the focus from CEAA 1992s ‘adverse effects,’ it should not do so to the extent of moral and environmental ambivalence. Not all tradeoffs are recoverable from net benefits, and the Government’s legislation should make it clear as to where the burden of evidence will lie.
Blue Dot PEI over 1 year ago
We are very pleased to see the environmental assessment broadened to impact assessment and the recognition of the importance of sustainability for generations to come.However we are concerned about the seeming equal value among the pillars of sustainability. Our species cannot survive without a healthy environment. Our society has some reliance on our current economic system, but our species is in not unable to persist without it. Ecosystem function needs to be valued preeminently.With regards to the questions from the Joint Panel for the Kemess North Gold-Copper Mine, does fair distribution mean equitable distirbution? Because a key challenge with our current economic system, which major projects serve to uphold, is the inequities it causes, with greater hardships and fewer benefits being distributed to those of lower socioeconomic strata. An additional question to ask would be: what other trends/projects are currently occurring that may make this population and region more vulnerable than its current situation?
Luanne Roth, T. Buck Suzuki Environmental Foundation over 1 year ago
Your statement:"IA also needs to better address a review of alternatives. There is a need for an open and informed discussion about the nature of developments, and including the review of pros and cons of more than one option is essential" is good as a goal except that the proposed changes seem to miss an essential aspect of review of alternatives: Is one alternative far better than another? Your plan seems to only review alternatives in so far as they offer a net benefit, but in situations where all alternatives offer net benefits but one alternative results in far more harm, there should be a process whereby alternatives which result in less harm are assessed and recommended over the others. An example of this is PNW LNG which will have serious negative impact on critical Skeena Salmon estuary habitat. Some are arguing that despite this issue there is a net benefit. Whether or not this is the case, there is clearly a need for a review of an alternative site for the project which could be assessed and recommended.
Douglas Macaulay over 1 year ago
(1) I support a move to IA from EA, including the taking into account at the project level of positive as well as negative impacts. (2) I believe commencing IA early, for those projects subject to review, is of potential benefit to all parties; however the planning phase should reward proponents that engage fully and early by providing a set of clear questions or specific issues to be addressed in subsequent studies and project design work (as opposed to prescriptive requirements, or overly general and vague expectations). (3) I believe that tiering makes conceptual sense, but the onus should be on higher tiers to provide clear, constructive guidance to lower tiers. An individual project (on its own) should not be expected to meet the burden of addressing an issue that properly resides as a strategic or regional IA level (e.g. perhaps because of the cumulative impacts of previous projects), but if a regional IA identifies an issue affecting an area, watershed, airshed in which a proposed project would be developed a proponent should be able to demonstrate in the project IA how it is not contributing to worsening of the issue (or in certain cases, my be contributing to incremental or gradual improvement in the project's area of influence). In a transition period, I think it important that a way be found to facilitate continued progress of promising projects by responsible proponents in circumstances where regional or strategic IA are considered valuable but where properly implementing RIA/SIA is likely to take considerable time.
K Park over 1 year ago
I do not support the legislated planning phase for an IA, nor do I support a trigger for IA based on federal interest that are broadly defined. The model proposed is broad and unprecedented, extends federal oversight into areas that are the jurisdiction of the provinces and territories, creates significant opportunity for litigation and challenge, and is unworkable and unrealistic as proposed for industry. I am concerned with both the direct cost to Candians resulting from the required increase in regulatory oversight as well as the potential implications to the Canadian economy.
Greater Vancouver Board of Trade over 1 year ago
We agree with the Expert Panel that assessments must evolve from environmental reviews to ones that also examine economic and social impacts. This is a more holistic review process and ensures the many aspects of sustainability are considered.
Stacie Noble-Wiebe over 1 year ago
I see much that is positive in this report and would like to add one further suggestion that I didn't see included. I would like to see Canadians' right to live in a healthy environment - with clean air, clean water, and healthy ecosystems - recognized and included as part of the vision for impact assessment. That would help insure that perceived economic benefits don't overshadow the reality that our most basic need in order to survive and thrive is a healthy environment. Thank you.
Michael W over 1 year ago
This process as proposed will be overly complex and extend federal oversight into matters of provincial and territorial jurisdiction. An IA process based on an evaluation of sustainability without defined goalposts is going to be very subjective and open to interpretation. This will inevitably result in lengthy delays in projects, potentially causing huge social-economic loss, as projects are dragged through the court system with challenges from numerous groups opposed to the decisions made by the IAC. There needs to be clearly defined criteria that a project must meet before an IA is required. A determination of "consequential" seems a bit arbitrary when deciding if a project requires an IA or not. Millions of dollars are invested in preparing projects, there needs to be more clarity for when an IA will be required. All the while keeping in mind that this plan crosses into provincial and territorial jurisdiction.
Manitoba Infrastructure over 1 year ago
Regarding 2.1.1 - Provincial Infrastructure departments manage networks over very large areas and the vast majority of highway and bridge construction projects will have a direct "link" to the aquatic and terrestrial environment including fish and migratory birds, as well as such areas of federal interest as navigation and greenhouse gases and others. Routine work such as culvert replacement would have a link to matters of federal interest and to require engagement with the federal IA process for everyday maintenance work for example will create unacceptable cost and delays. The significance of the link and not only the existence of the link needs to be determined in assessing whether the federal process would apply. What criteria will be used to determine if a third party can request an EA?2.1.2 - Planning - The document makes no reference to how emergency projects will be handled, for example emergency flood response. 2.1.3 - As noted, we agree that impacts must be consequential to trigger IA. Very clear definitions of applicability are required so proponents can properly schedule and budget their future work.2.3.1 - Each First Nation may have different laws and customs and would need to be clearly understood at the start of the process. Management of engagement records is crucial as both elected community officials and government staff may change during the course of the IA process. 2.3.2 - Funding, timelines and roles and responsibilities need to be defined at the beginning of the IA. Any Federal IA agency must be sufficiently funded and staffed. 2.4.3 - The federal agency will have to maintain the database to ensure permanency. 2.5.1 - Data collection - if the Agency is determining the scope of the data collection required, it must be strictly limited to the project at hand, and not a broader regional scope. Proponents and First Nations may have confidentiality requirements on the data, for example Traditional Knowledge.
Q'ul-lhanumutsun Aquatic Resources Society over 1 year ago
In general, the recommendations put forth by the Panel regarding revamping the Canadian Environmental Assessment Act would be a major step in the right direction. As the Expert Panel heard, the current CEAA is fraught with gaps in knowledge that slow approval processes and put many people in the public and in Indigenous communities on the defensive. The proposed recommendations call for wider consideration of impacts in terms of long-term sustainability, and the recognition of First Nations rights on and off reserves. It also calls for pre-planning for development and the contemplation of cumulative impacts on a regional scale – something that has not been adequately done in the past. It is true that the recommended changes would create a major disruption in the current processes, but, as the Panel report points out, some responsible proponents with foresight are already doing the majority of the recommended changes, so the task is not impossible. The Q’ul-lhanumutsun Aquatic Resources Society and affiliated Nations hope that Minister McKenna and the Government of Canada seriously consider the recommendations and avoid the trap of assuming that other jurisdictions will protect federal interests in their environmental assessment process. In British Columbia we often see the Provincial Government ignoring impacts of proposed developments on First Nations Rights and Title and this process is a chance to rectify that oversight. While we welcome the opportunity to provide input into the recommendations put forward by the Panel, the format was difficult as it did not address all areas covered by the recommendations. We look forward to further consultations on the proposed changes to the CEAA.
Marlene Gifford over 1 year ago
Projects need to be developed to a stage where they have a high likelihood of being feasible (financially, technically, permit-able, etc.) before the early project 'plan' can be released for comment. Otherwise, more questions than answers will result and a proposed project may initiate undue 'alarm' before the project plan is sufficiently advanced. Also, the project footprint / layout may not be known at an 'early stage' in the planning process, so it is very difficult to determine who / what may be potentially affected. Projects such as planned renewable energy projects may be undergoing a competitive bid process to allow the project to be developed; therefore, the project location would need to be confidential until a Power Purchase Agreement is secured.
Northern Health Authority of BC over 1 year ago
Our review was conducted in concordance with Northern Health’s commitment, statutory and ethical obligation to build and strengthen the health of the people we serve in Northern British Columbia. Accordingly, Northern Health very much supports the following recommendations made by the Expert Panel regarding the “Purpose of Federal Impact Assessment”: - That what is now “environmental assessment” becomes “impact assessment” (IA) with decision making based on five pillars of sustainability (environment, economy, social, cultural and health). - That assessments consider the interactions between the five pillars. Specifically, we advise that attention is given to the important interactions between the environmental, economic, social and cultural pillars and human health. - That assessments include a review of net benefits and a review of trade-offs between benefits and negative effects. Projects which provide a net benefit to the country be approved, and those that do not be rejected.- That an assessment of alternatives be undertaken, with consideration of the impacts and benefits of each alternative on the relevant components of sustainability.-That federal IA should begin with a legislated Planning Phase that, for projects, occurs early in project development before design elements are finalized.- That federal IA decide whether a project should proceed based on that project’s contribution to sustainability.- That IA legislation require the use of strategic and regional IAs to guide project IA. We emphasize the importance of regional IAs given our experience with extensive resource development occurring throughout northern BC including both large and small projects. We acknowledge and support the following statement made in the report regarding sustainability: “Its ultimate goal is to advance initiatives that contribute to lasting improvement in society’s wellbeing.”
Ian Thomson, Oxfam Canada over 1 year ago
Oxfam Canada supports the Expert Panel’s recommendation that “sustainability” become the central priority of federal IA. To assure that approved projects, policies or plans contribute a net benefit to environmental, social, economic, health and cultural well-being, the IA process must incorporate strong gender-based analysis. Diverse gender perspectives are essential in all steps of the IA process:o Identifying and mapping the valued components of sustainability; o Gathering data to establish the baseline quality of each valued component;o Identifying and mapping the existing and foreseeable sources of impact to each valued component; ando Identifying alternative development scenarios.Oxfam has developed tools for project proponents to assist in implementing gender impact assessments, which could inform the development of the IA process in Canada. One such tool by Oxfam Australia provides guidance on conducting gender impact assessments in the extractive sector: https://www.oxfam.org.au/wp-content/uploads/2017/04/2017-PA-001-Gender-impact-assessments-in-mining-report_FA_WEB.pdf
Joanna Skrajny, AWA over 1 year ago
AWA supports the Panel’s recommendation to move Canada towards a sustainability based Impact Assessment (IA), which will seek to ensure that projects provide an overall environmental, social, cultural, health and economic benefit. A shift towards federal assessments having sustainability as a core objective would improve the process; clearly listing tradeoffs and determining whether projects provide an overall benefit will help to bring transparency and restore public trust.
Shane Borchardt over 1 year ago
The proposed model appears to back up the EA process to an earlier stage then previously. This doesn't make much sense due to project proponent often still developing the details of the project, which change frequently at this early stage. By starting the process too early, costly assessments will be completed on items that won't make the final design.
Kari Toews over 1 year ago
I do not support the purpose as outlined in the Report. The model proposed is broad and unprecedented, extends federal oversight into areas that are the jurisdiction of the provinces and territories, creates significant opportunity for litigation and challenge, and is unworkable and unrealistic as proposed.I do not support the broad definition of matters of federal interest provided in the Report. Federal interest relevant to the federal IA process should be determined based on federal jurisdiction and recognize federal regulatory oversight provided by existing federal legislation.I do not support a legislated planning phase that is initiated based on conceptual project information. Planning phase should be undertaken only when adequate planning has been completed by the proponent to determine that there is a business case to proceed and a degree of confidence that impacts can be managed.I do not support a trigger for IA based on consequential matters of federal interest that are broadly defined. Trigger for project IA should be based on a Project List that is defined based on clear criteria consistently applied. In the nuclear industry, projects that are likely to require the federal IA process are new uranium mines or mills, new nuclear fuel process facilities, new nuclear power plants, and new nuclear waste storage facilities.I do not support the broad and unprecedented approach to sustainability assessment outlined in the Report because it is overly complex, creates substantial potential for litigation and challenge, extends federal oversight into matters of provincial and territorial jurisdiction, and is not supported by any standards or guidance to support its implementation.I do not agree that IA legislation should require the use of both strategic and regional IA to guide project IA. Only two tiers of IA should be required in IA legislation in accordance with global best practice, and current legislation. Federally led regional IA must be limited to federal lands and marine areas where the federal government is responsible for land and resource management.
Ed Dyna over 1 year ago
I am concerned that we are taking a lengthy and complex process and making it more lengthy and complex by adding additional steps to the process and then expanding the criteria and circumstances it will apply to.
Wayne Summach over 1 year ago
This recommendation extends federal oversight where it shouldn't be, that is provincial and territorial. Oversight does not have to be increased. The existing requirements is already to cumbersome and overbearing, more oversight is unrealistic and counter productive. Only two tiers of IA should be required in IA legislation in accordance with global best practice, and current legislation.The Planning phase should be undertaken only when adequate planning has been completed by the proponent to determine that there is a business case to proceed and a degree of confidence that impacts can be managed. Trigger for project IA should be based on a Project List that is defined based on clear criteria consistently applied. These requirements will stop any further industry growth in Canada due to burdening processes and exorbitant costs.
Waterford Energy Services Inc over 1 year ago
Of particular concern to our organization is the following:the establishment of a new single ‘Impact Assessment Commission’ (IAC) with the appropriate technical capacity;a disconnect between the Atlantic Accord Acts and IAC;the creation of new impact assessment legislation creates uncertainty as to how the existing environmental assessment legislation will apply;the IAC will complete the environmental impact statement with funding from the proponent;the IAC will utilize best science available;no limitation on public participation;all decisions are appealable by any participant.
Richard over 1 year ago
This is a monumental waste of time and effort. Unless a project is going to happen specifically in an area under federal government jurisdiction, this already fall under the jurisdiction of the provinces and territories. Projects with potentially significant impacts on the environment already need to design in safeguards and mitigation, and cover financially the cost of restoring the project to a reasonable state after completion. There will always be people, however, who are not satisfied, and this would just give them a reason to say no, which is just another way for a small minority of people to be detrimental to the majority. If a project is economically viable, and meets all requirements of the local (provincial or territorial) jurisdiction, then that means there is enough demand by people as to have a net benefit for all. The unsatisfied people however, will voice their displeasure. At this stage, I will use someone else's words:"As long as human beings are imperfect, there will always be arguments for extending the power of government to deal with their imperfections. The only logical stopping place is totalitarianism - unless we realize that tolerating imperfections is the price for freedom" Thomas SowellI would like to point out to the committee that developed all this, that yes, you may think you need to "make something better", but there is a different way. Each and everyone one of you who thinks that projects in Canada are either "unsustainable" (a word which is rather meaningless without a time frame - forever?) or have too much impact on the environment, to you I say, get educated in the sciences and engineering, roll up your sleeves, and pitch in to make it better. If you aren't willing to do that, but you are still unhappy, go complain to a mirror.This is a bad idea.
Ontario Rivers Alliance over 1 year ago
In general ORA is very pleased with the substantial recommendations put forward in the Panel’s report, “Building Common Ground, A New Vision for Impact Assessment in Canada”, with a focus on meeting the objectives set out by the Prime Minister’s mandate letter. It is apparent that the Panel was listening carefully to those who took the time to attend the public consultation sessions and make comments; however, there are a few areas where we feel the recommendations didn’t go far enough. The true test will be whether the government is willing to do meaningful justice to those recommendations set out by the Panel. The idea of real sustainable development that goes beyond the bio-physical environment to identify future consequences and cumulative impacts, in a process that is transparent, inclusive, informed and meaningful is badly needed. Currently only a very small fraction of projects are subject to an Individual EA; however, ORA recommends that all projects that could have negative impacts on water, air or a community should trigger an EA under the CEAA.Having a process that uses an Impact Assessment (IA) approach, rather than the environmental assessment sounds promising; however, the devil is in the details. The real test will come when the government writes the legislation and policy – will it reflect the Panel’s well-informed recommendations, or will we end up with a watered down and weakened version that continues to undermine trust and confidence?ORA recommends that in addition to decision-making criteria, there should be clear rules concerning what trade-offs are, and are not, acceptable. These rules should ensure that environmental and human health are not traded off for economic benefits. Additionally, the ecosystem benefits of an undisturbed natural environment should be assessed and weighed against the potential benefits of the project if completed.
Campaign for the Protection of Offshore Nova Scotia over 1 year ago
Generally, CPONS believes the Report’s recommendations are a step in the right direction to improving environmental assessments in Canada, and the sustainability approach underpinning the Panel’s Report is a much needed feature. Broadening assessment processes from environmental assessment (ES) to impact assessment (IA) and including all impacts (positive and negative) resulting from a project is a positive change in perspective. Moreover, CPONS supports the Report’s four principles guiding IA processes in future. IA processes must be transparent, inclusive, informed and meaningful.
David Suzuki Foundation over 1 year ago
These are the comments of the David Suzuki Foundation and are intended to complement joint submission of the Environmental Assessment Caucus of the Canadian Environmental Network (including the David Suzuki Foundation).We encourage Canada to explicitly recognize Canadians’ right to live in a healthy environment – that is, environmental rights – as part of the vision for impact assessment.This would be in keeping with the 1972 United Nations Stockholm Declaration on the Human Environment, which proclaimed that people have “the fundamental right to freedom, equality and adequate conditions of life, in an environment of quality that permits a life of dignity and well-being.” There is strong public support for recognizing environmental rights in Canada. The Expert Panel Report includes an excerpt from “supporters of the David Suzuki Foundation” (page 89):Environmental assessment should do five things for people in Canada:1. Allow everyone, including Indigenous peoples, to say “no” to environmentally damaging projects in their communities.2. Ensure that the environmental safety net, which includes other laws and regulations, is intact and working to keep air, water and soil healthy.3. Guarantee public participation and the free, prior and informed consent of Indigenous peoples.4. Consider the “big picture” and include cumulative effects from multiple projects on interconnected ecosystems in ways a case-by-case approach cannot.5. Include scientific and traditional Indigenous ecological expertise on all environmental assessment panels.The same letter – sent by some 11,000 Canadians – also included an appeal to “acknowledge the right to a healthy environment — every person’s right to clean air and water, safe food and a stable climate — as a guiding principle to help interpret the [Canadian Environmental Assessment Act].” Environmental rights include substantive and procedural guarantees. Substantive rights include clean air, safe water, a non-toxic environment and healthy ecosystems. Related procedural rights include access to information, participation in environmental decision-making and access to justice.
Alyse K over 1 year ago
Federal interest extends into areas that could be more effectively managed by provinces and territories. I worry this broad federal interests list will result in projects being overlooked due to the high resource demand this list requires and therefore does not instill confidence. Trigger for project IA should be based on a Project List that is defined based on clear criteria consistently applied. The legislated planning phase as currently recommended could result in a very timely process with very little benefit as many of the project details would not have been planned or thoroughly researched by proponents resulting in ambiguous discussions. Sustainability should be central to IA and have an unbiased focus on all five pillars; however the panel’s recommendation does not introduce methods related to any standards or guidance materials that would aid in a realistic implementation. Using both strategic and regional IAs to guide project IA seems to be excessive but I think the application of regional IAs to clarify on thresholds and objectives of a narrowed* federal interest (i.e. federal lands and resources) would be of great value.
Robert Zurrer over 1 year ago
There is no need for federal oversight in areas already covered by the provinces and territories period!!!!
Anne Gent over 1 year ago
The Panel's vision for a new impact assessment model would seem to remove any certainty on timelines and create competing jurisdictional overlap. There is no need for federal oversight in areas already covered by the provinces and territories unless it is on federal lands or marine areas where the federal government is responsible for land and resource development.In addition, beginning the federal IA before design details are finalized would not benefit the process. While knowing where adjustments may be needed early in the process is beneficial, involvement at a conceptual stage is an over-reach.
Charlene B over 1 year ago
The federal IA model is broad, and oversight extends into other provincial and territory jurisdictions. Legislating planning phase only when adequate preparation is complete so the business can ensure it's economically and environmentally feasible. It would likely result in a decrease in investment and jobs within Canada. Criteria should be clear should be defined for triggering a project for IA (e.g., new mines, process facilities, waste storage facilities, power plants). Guidance and standards are needed before the approach to sustainability assessment can be implemented. These aspects are not supported as they are currently presented in the review report.
Richard Corbet over 1 year ago
My concerns are as follows:1. I see the clear possibility of federal involvement in assessment of projects currently subject to provincial or territorial jurisdiction. Not only is this a needless duplication of effort, it is likely an infringement of these bodies' rights as established in precedent and in law.2. Further, the supposed justification that federal involvement is required on issues of 'national' concern, e.g. climate change and greenhouse gas emissions, is a smokescreen for the creeping extension of federal powers into local jurisdictional issues as noted above.3. Environmental assessment was originally introduced to require "cradle to grave" aspects of a proposed project; relevant wording from the Canada Environmental Assessment Act gives the required scope of an assessment as "Construction, operation, modification, decommissioning or abandonment of, or other activity in relation to" the proposed project. This language is repeated in other provincial and territorial assessment acts. The intent, according to one of the lawyers who wrote and used this phrase repeatedly was that ALL these activities be considered in the (single) assessment. It has now become policy in many places, however, that EACH activity is to be assessed separately and in Yukon, for example, not only is each activity to be assessed individually, any renewal of a permit or licence by the regulator is deemed, with no justification whatsoever in law, to trigger a re-assessment before the renewal can be issued. This is a blatant make-work policy, a complete waste of time and resources and a contradiction of the original intent of the legislation.4. The stated objective of 'inclusivity' meaning to involve ALL levels of 'government' - federal, provincial or territorial, municipal or local and First Nations - will mean a completely paralytic process that will never achieve a meaningful set of recommended mitigative measures for anything more complicated than building a fence. If the federal government is trying to gut industrial activity and development in this country, this proposal is an excellent way to do it.
K.England over 1 year ago
• Do not support the purpose as outlined in the Report. The model proposed is broad and unprecedented, extends federal oversight into areas that are the jurisdiction of the provinces and territories, creates significant opportunity for litigation and challenge, and is unworkable and unrealistic as proposed.• Do not support the broad definition of matters of federal interest provided in the Report. Federal interest relevant to the federal IA process should be determined based on federal jurisdiction and recognize federal regulatory oversight provided by existing federal legislation.• Do not support a legislated planning phase that is initiated based on conceptual project information. Planning phase should be undertaken only when adequate planning has been completed by the proponent to determine that there is a business case to proceed and a degree of confidence that impacts can be managed.• Do not support a trigger for IA based on consequential matters of federal interest that are broadly defined. Trigger for project IA should be based on a Project List that is defined based on clear criteria consistently applied. In the nuclear industry, projects that are likely to require the federal IA process are new uranium mines or mills, new nuclear fuel process facilities, new nuclear power plants, and new nuclear waste storage facilities.• Do not support the broad and unprecedented approach to sustainability assessment outlined in the Report because it is overly complex, creates substantial potential for litigation and challenge, extends federal oversight into matters of provincial and territorial jurisdiction, and is not supported by any standards or guidance to support its implementation.• Do not agree that IA legislation should require the use of both strategic and regional IA to guide project IA. Only two tiers of IA should be required in IA legislation in accordance with global best practice, and current legislation. Federally led regional IA must be limited to federal lands and marine areas where the federal government is responsible for land and resource management
Jamie Kneen, MiningWatch Canada over 1 year ago
The change to sustainability criteria for assessing projects as well as plans, programs, and policies is needed and welcome, as is the Panel’s emphasis on strategic and regional IA.In order for IA to function as a planning tool, the need for and alternatives to the project or proposal must be considered, as well as alternative configurations.The process for initiating SIA and RIA needs to be clear; there also need to be clear pathways for issues to be brought to SIA and RIA out of project IA.
Scratching Along over 1 year ago
As many comments allude to; Venezuela is really much closer than the Political Class is willing to accept because making any significant Change in Governing which does not enhance the Bureaucracy and their Captured Polticos will always be too much trouble.It really is time for the Reckoning of the "Two Solitudes" which forms essentially the Northern Half of the North American Continent.The U.S.A is in the final stage of diminishing Or abandoning the East Coast preference for European culture and direction of how to think. Fly-over Americas "couthness" is just not up-to-standards. It is not really practical to call the Mid-West; the South; the Inner City; the Mexican/Hispanic; the Texas; the Desert Areas; Uncouth."Not really practical" doesn't mean Politically Correct, now Pass'e, it means Y'all are not part of the non-regional groupies of the East in accent and thought process. Heaven's to Betsy; in New York City speak WTF; or part thereof. This attitude of superiority will not or cannot change anymore than the cattle flesh on ones table is called Beef ala Norman English instead of Saxon Cow.Quebec for all of its faux dislike of Continental French and France's Aritoscracy 'bugging out" of New France when times got tough; is really much closer to the New York pretentiousness than Mid-America et al.Except for the overwhelming affect of the Toronto Immigrant population, Ontarioario joins with North Ontario and the Remaining Western Canada Provinces-except Southern British Columbia- joins with Middle America; in the Mid-West; the South; the Mexican/Hispanic; the Texas; the Desert Areas FAR More than the effete urban Quebecois and metro-sexual New York-Oregon-Washington State/D.C.California is itself-We know more; Californication is what everybody needs and wants because We californians know about your "California Dreaming". It should stand on its own and slip into Venezuela Governance before bringing the rest of North America to It's knees-whatever that means?-.If this babble means anything except "Old White Guy" good for you; Because I truly believe Ontario/Alberta/Southern British Columbia will never escape the Clutches of the Liberal 5-C's-Corrupt-Craven- Cargo Culture Crowd.Manitoba & Saskatchewan will take their Resources and Hopefully Alberta with an alternative solution to Edmonton's desire for couthness will join in the Mental Move to the United States Market Place.Southern British Columbia is lost. The North West States of the U.S.A. & Southern B.C. fit together. They are peopled by the "Look at Us" we made it all the Way to Asia's Pacific Ocean"; therfore you need us. Northern British Columbia and the Yukon are already under the table Alaskan's. The blending will be easy.Ontario is the Biggest by far; as a Problem and as a Population.If Ontario, with Toronto joined Western New York-it really is different than East Coast New York City (Atlantic Ocean Singapore?)-joining Ontario with Western New York State will make the New Yortario State one of the largest in Geographic and Population States of the U.S.A. OR Ontario joining with Michigan-almost encircling the Fresh Water Seas of the Great Lakes. (western New york & Ohio will complete the U.S.A. Encirclement.Tornto is still the Problem. Not for the U.S.A.-already the Corrupt Liberal Cronyism hangs on every dirty trick the Democrat Party can produce. The problem with Toronto remains. The population of Toronto is as ignorant and Greedy as New York City; It is on the Cusp of collapse into the Dirty Rat Infested Urban Mess New York City was until Rudy Guilliani and what New York City is returning to under Bill de Blasio.Flooding the City of Toronto by damming the Lake Ontario water flowing into the St. Lawrence, probably won't work. Soooo?
Patrick Landine over 1 year ago
The proposal process is too broad, the federal government would be reaching into areas of provincial and territorial concern. The whole process would be open to legal challenges that would make it unworkable.A legislated planning phase initiated based on conceptual project information would not work. The regulatory planning phase can only be undertaken when adequate proponent planning has been completed to determine if the project could be "a go" both economically and environmentally.Sustainability assessment as described in the Report is too complex and broad, while at the same time being vague. It will be subject to legal challenges from all opponents, other governments and potentially competing proponents. Two levels of IA are sufficient, as is the practice in other countries.
Stuart Juzda over 1 year ago
Under the proposals made by the panel would the following developments have gone forward 1) Kinder Morgan pipeline 2)the Giant mine 3) the development of the tar sands. If the answer is yes to any of the 3 then the report is about show not substance. This report parrots the current governments line on the environment which is the promotion of capital over the risks to the environment which sustains us.
Andy over 1 year ago
Removed by moderator.
Andy over 1 year ago
Canada: 1.6% of world total CO2 emissions - (a statistical error)You live like it's 1662 for 1 year first - then I will consider these inhuman proposals.
Dr. Susan Diamond over 1 year ago
Every Canadian deserves the right to comment on issues of the environment- at any time. The public consultation processes are being overwhelmed and thus corrupted by private/vested interests, and governments need to STOP this from happening. It is deliberate and should be transparently called out.
Thevenot over 1 year ago
Re 2.1.2: I am very concerned that the early planning phase proposed will be overly detrimental to proponents, who could face significant costs as each potentially affected individual places themselves for maximum gain (e.g., augmenting value of a home that will probably need to acquired by the proponent). I believe this would be detrimental to the economy. Instead, the planning phase should focus on strengthening of alternatives assessment phase that is unfortunately currently conducted as an afterthought for most projects.Re 2.1.3: I agree with the main themes, particularly the need to assess all aspects of the environment (i.e., including health and cultural) and their linkages. However, it is unfortunate to use the sustainability lingo as it has been diverted from its original intent and no longer commands respect or trust. It is also very difficult to assess all the linkages thouroughly, so this should be limited to the net benefit analysis and maybe identifying those linkages that could be futher studies during the follow-up monitoring program in partnership with researchers, rather than have consultants try to cobble something together that is unconvincing. Re 2.1.1 and 2.1.4: I agree with other comments that regulatory oversight of Project IAs should primarily fall to the provinces/territories affected by the project. Federal involvement should be limited to conducting strategic assessments, overseeing regional assessments in close collaboration with the provinces/territories, and reviewing Project IA's cumulative effects on a national level.
John Takala over 1 year ago
There are a number of serious flaws with this section. First, federal jurisdiction should determine if a federal IA is required, not federal interest. Creating a legislated Planning Phase is an unnecessary intrusion into the normal planning processes of business and would create a significant barrier for industry to develop projects in Canada. It is not possible to support the broad and ill-defined use of sustainability as described in the report as test for IA. The need for both strategic and regional IA was not made and introduces an unnecessary layer of complication into the process. Overall the Panel's recommendations in this section would lead to an extremely complicated process with little apparent benefit.
Kirsten Ketilson over 1 year ago
I do not support the not support the purpose to move away from environmental assessment towards a much broader, complex, unworkable, unrealistic and unprecedented sustainability assessment model as outlined in the Report. The model proposed would extend federal oversight into areas that are the jurisdiction of and are currently regulated by the provinces and territories, would create significant opportunity for litigation due to the absence of any standards supporting sustainability criteria or assessment, and is unworkable and unrealistic as proposed. Further, I do not agree with the broad listing of matters of federal interest or definition of consequential as proposed in the report - as it is outlined it is so broad as to trigger IA for any development in Canada. I also do not agree that three tiers of federal IA process would provide any benefit to the environment or society, and I am concerned about the cost to Canadians of implementing such a burdensome process.
Jeff Pryznyk over 1 year ago
The general purpose is too broad. Federal oversight is being unnecessarily increased leading to a more burdensome process that is not likely to improve environmental outcomes.
Jon Henderson over 1 year ago
Although I support the involvement of various stakeholders in principle, in practice, mandating engagement when only conceptual and preliminary project information is available could lead to confusion and make it more difficult to build the trust that is necessary to ensure the success of the process.
Ron Pask over 1 year ago
Should be a strict, reasonable time line for the entire process. What is proposed will take longer than the approval of the McKenzie Valley Pipeline which began in 1972. Only lawyers and consultants benefit from NEB review.
Ron Pask over 1 year ago
The NEB is not required. Save tax dollars and lay-off all employees. Canada is unable to build anything now under NEB jurisdiction, so forget it. The natives and enviros control our economy and the weakness of our currency is a key indicator.
Brady Balicki over 1 year ago
The proposed approach is unnecessarily broad and unprecedented, introducing multiple layers of process while extending federal oversight into provincial responsibilities. As structured the approach is unworkable and will likely result in litigation or legal challenges for many Impact Assessments.Triggers for project-level Impact Assessment must be based on a Project List defined using clear and consistent criteria. The scope of these assessments should be limited to large scale activities (e.g. construction of a new gold mine).
Stuart Juzda over 1 year ago
I posted several comments critical of the report. They have been removed and I would like to know why. The report reflects the correct biases of it's members. It favours development over the evironmental concerns. It favours political solutions rather than recourse to impartial courts. Consensus is not a positive outcome. For instance 2+2=4 is a correct statement. 2+2=5 is an incorrect statement. A consensus answer of 4.5 is also incorrect.
David Fermor over 1 year ago
The prospects of creating "positive relationships" with radical environmentalists such as Greenpeace, Tides foundation, WWF etc. are non-existent and we shouldn't waste time and money attempting to do so. They will obstruct for the sake of obstructing. It's what they do. The system as it exists is utterly Byzantine and should be simplified so that a single process can generate a definitive "yes" or "no" for a project in a timely fashion. It should review the inputs of legitimate experts who know something about the technical ins and outs of a project, not a collection of flakes (e.g. elementary school children in Brazil) who would have us living back in the stone age.
Rebecca Peters over 1 year ago
While early consultation and agreement on scope is critical to the successful completion of an environmental assessment and ensuring that major undertakings by industry are appropriately managed, it is also important to remember that no project will achieve 100% consensus. It is also important to ensure that the right projects are being reviewed at this level - and that subjecting all initiatives to an extensive process can have a detrimental impact on the economy, the environment and the relationships between interest groups.The federal IA should be triggered within areas under federal jurisdiction only, as clearly defined in federal legislation. Within the areas of federal jurisdiction should be a defined project list, based upon clear criteria that can be consistently applied, thereby ensuring that all relevant project proposals are assessed, not just those that the public become aware of - and that project proponents are aware of the requirements in advance of developing the project.Proponents must be enabled to develop their conceptual project information before an IA is initiated to ensure that there is a business case to proceed and that an initial review of potential mitigations to manage impacts can be completed.The subjectivity of sustainability assessments is concerning as there is not currently clear standards or guidance on how this is to be completed/implemented.
Mark Winfield over 1 year ago
I strongly support the overall direction of the panel's report, particularly the emphasis on the role of environmental assessment in reconciliation between indigenous and non-indigenous peoples in Canada. On the whole the report is very strongly focused on the assessment process for large projects. This potentially leaves some significant gaps in the federal assessment process. The report seems to underplay the importance of the review smaller project subject to federal approvals (e.g. Fisheries Act s.35) which although individually minor in their impacts, may be very significant in terms of their cumulative effects.The report also seems to downplay the importance of the CEAA process within the federal government. In many cases review under CEAA was the only environmental review of any type of projects on federal lands or with federal proponents. The report is at best ambiguous about the application of the process it proposes to such projects.
Canadian Association of Physicians for the Environment over 1 year ago
Seems straightforward enough. The switch to "impact assessment" is sound. Goals are wonderful; implementation is the key.
Roger Gladstone over 1 year ago
System or process must be clear, simple and timely is the best way to balance environmental protection with economic growth. The process must protect Canadians and our environment.
Mark Walker over 1 year ago
Generally, unless the project in question falls within the historic bounds of federal jurisdiction all EA and project assessments should be left to the provincial and municipal bodies affect. The Federal gov't should act to limit it's involvement/scope as narrowly as possibly. Further, unless projects impact directly Indian Reserve lands, participation by indigenous groups should be limited to commenting/observer status.
Susi E over 1 year ago
Impact assessment is critical, but above all we need the right to healthy air, water, food and EMF emissions. This should be enshrined in Canadian Law.
ROBERT WOOD over 1 year ago
"Sustainability" is bogus. Nothing is sustainable, not even the solar system. Had humans stayed in the trees, the "sustaianable" position, we would have become extinct.
ROBERT WOOD over 1 year ago
The purpose of environmental assessments is not "the creation of positive relationships among various interest groups" but to ensure that development does not damage the environment.
Trace over 1 year ago
To much involvement from outside third party's. They should not be allowed.
Robert Huck over 1 year ago
This is a gross overstep of constitutional authority of the environment, which is clearly the jurisdiction of the provinces. By enforcing a specific planning phase before sufficient information of the project is known, you place the proponent at risk in terms of their business case as well as undermining stakeholder confidence in the project without merit.The criteria for determining federal interest is far too broad, which would place proponents at significant risk for very little or no environmental benefit.The sustainability criteria is incredibly complex, which would add years to any given project, especially given the possibility of opening up the criteria even further while a project is under review. It would be impossible to enforce this and still allow for projects to proceed.In short, the federal government should retain its jurisdiction to its constitutionally defined areas of oversight and provide clearly defined bounds which will allow projects to move ahead with some semblance of certainty.
Les Hicks over 1 year ago
I agree with the proposals.
Arlene Kwasniak over 1 year ago
Re Section 1 and 2.1.3: Moving from EA to SIA - This is a positive move and I support it, as it has been put forth by experts in the area. However I have concerns regarding how it will be reflected in legislative language. My greatest fear is that in the end we will have legislated sustainable development, which is not what SIA is, and that would be regressive and regrettable. The concept of "sustainable development" has proven to be unwieldy and too often overly supportive of development rather than sustainability. Accordingly, the legislation must be clear that SIA is the objective, and that there must be net gains under each pillar of sustainability. I support a legislatively required minimum for the acceptability of a project if adverse environmental impacts have been avoided, AND if the project has no significant environmental impacts taking mitigation into account, PLUS the project results in net gains for each sustainability pillar, including the environment pillar. "Significance" can be clearly defined by legislation to avoid issues with the term. I believe that requiring no significant environmental impacts as a base will best avoid a slide to sustainable development. Re 2.1.1: Federal jurisdiction, there are missing matters, e.g. (a) fishERIES (not just fish), both inland and seacoast; (b) marine MAMMALS (not just plants); (c) off-shore and ocean pollution; (d) the criminal law (e.g. toxins listed under CEPA); (d) matters falling under Peace, Order, and Good Government.Re 2.1.2: IA as a planning tool - Thank you Panel for putting planning back into the assessment picture and for requiring it to be a discrete IA step. I have concerns about implementation though. The legislation must be clear on what is required of a proponent in the planning stage and set out consequences for non-compliance, including the potential for a proponent’s application for an authorization to be denied if the proponent fails to carry out prescribed planning responsibilities including regarding Indigenous and public participation. Another concern deals with small and routine projects (discussed later) that may not have a discrete planning phase or a very considerable planning phase. Although intention to carry out such projects should be registered in a manner so concerned people may be aware of them, some may not require an elongated planning phase compared to projects that are listed on a major projects list. But this is more of a problem regarding the Panel's recommendations on what to assess, which is quite narrow and may not be an improvement over what we have in CEAA 2012, which I discuss later. Re 2.1.4: Tiering - I strongly support IA project integration with tiering with strategic assessment (SA) and regional assessment (RA). However the Panel report is lacking details on how the federal responsibilities regarding SA and RA are to be carried out. These details should be set out in legislation as clear requirements. I question the adequacy of the Cabinet Directive to deal strategic assessments. The legislation should provide for developing and implement strategic assessments beyond the scope of the Cabinet Directive.
Jule Asterisk over 1 year ago
During Impact Assessment, it is important to keep True Cost accounting principles in mind. When Canada assesses the impact of potential projects, long term health and environmental effects must be considered, if we don't want to have more episodes like 'Giant Mine'While the Giant Mine is widely credited with founding the city of Yellowknife, mine owners made $2.7B on the total 198.5 tonnes of gold before going into receivership, leaving behind 237,000 tonnes of arsenic trioxide endangering the Great Slave Lake – and the entire Arctic, if this toxic waste spreads through water. It is now being contained by a system of freezers, costing Canadian taxpayers $25M/year to maintain, on top of the cleanup bill of over $900M.At a ~30% combined tax rate at that time (not including any subsidies the mine may have received), Giant would have paid Canada $810M in corporate income taxes, Canadians lost at least $200M, on this project, to say nothing of the long term cost of health and environmental effects.In today's world, we need to watch out for potentially stranded toxic sites, not just 'stranded assets'
Rick Palmer over 1 year ago
The Canadian upstream petroleum industry continues to operate in a safe, environmentally and socially responsible manner, through constructive engagement with governments, the public, and stakeholders in the communities in which we operate. The responsible growth our industry is based on these principles and we welcome the opportunity to respond to the Expert Panel report “Building Common Ground: A New Vision for Impact Assessment in Canada.”
Art Jackson over 1 year ago
I repeat Sharon Willan comment from 3 days ago...A must is the need to look at the impacts of current decisions on 7 generations down the road. That impact includes ALL life forms not the current narrow view of how much money industry can make at the expense of all life forms for generations. It is not enough to "look before you leap" - you must look to the 7th generation before you leap." Assessment must be required when the health and welfare of all peoples, all species within the area is impacted: in other words all projects. The purpose of the vision appears all-inclusive. But look at the Tar Sands:- people, land, water, air, species of fish, birds, greenhouse emissions are greatly negatively impacted. This project is not following the principles of Assessment and is still allowed to continue.A healthy environment must be accessible to all people in Canada as well as the species we live with.We must embed a healthy environment first and foremost within all assessment projects. It must be a legal requirement that cannot be overturned when a new government is elected!
Edna Hobbs over 1 year ago
I didn't see anywhere that the Panel addressed cumulative effects of multiple projects on one aspect whether it be environmental, social or whatever. I think this has been one of the greatest downfalls of our environmental and social safety nets...one project may have little impact on an ecosystem, but when a second, third, fourth factor enters the picture, the integrity of an environmental or social perspective is compromised to a much greater degree.
Stuart Juzda over 1 year ago
The protection of the environment is the primary concern of Canadians. Resource development is secondary. Canadian taxpayers are paying between 800 million to one billion dollars to temporarily immobilize the arsenic left by the Giant mine near Whitehorse. There is no reference to this or other environmental disasters in the report.
Canadian Chamber of Commerce over 1 year ago
The idea of moving from an environmental assessment to a process that looks at a wider range of impacts and federal interests is worth consideration. That said, we fear that implementing the Expert Panel’s recommendations without careful consideration would greatly expand the types of projects subject to both a federal and a provincial environmental assessment process. This would lead to duplication of efforts that would increase the cost and uncertainty of the assessment process, materially harming Canada’s investment climate without improving outcomes for the environment, communities or human health. Guidelines for the new impact assessment (IA) process should be developed in a transparent manner and engage in extensive consultation with industry on the scope of the impacts to be included in this new process. It is essential that any federal IA process respect constitutional divisions of responsibility, and does not unilaterally impose processes on areas of provincial or territorial jurisdiction. We support the use of a carefully constructed project list to determine what projects will be subject to a federal IA process. This list must recognize the need to apply criteria consistently and to spreading too wide a net. While we recognize the need for Ministerial discretion in triggering projects, our members are concerned that having a federal IA triggered by legislated criteria would lead to uncertainty and increased use of litigation, and should not be adopted.
Killian Smith over 1 year ago
The Government should establish a predictable and consistent economic and regulatory framework that clearly enables investment in Canada’s resource sector, which will result in jobs and innovation. The Canadian upstream oil and gas industry continues to advance methods for reducing its carbon footprint, and that should be encouraged.
Jamie McLean over 1 year ago
The study should take into account all that the energy industry does to cooperate with others where it operates. The energy industry is the largest employer of indigenous people in the country, and numerous other groups benefit from a positive relationship with the industry. We should allow those relationships to flourish and work to give them as much freedom to cooperate as possible. A strong energy industry is good for all of Canada, and while other jurisdictions seek to lower regulation and costs for investment, this federal impact assessment should take that into consideration as well.
Nicole B over 1 year ago
There need to be triggers enacted to ensure ALL projects are assessed before they can receive a federal or provincial permit.
Ms. over 1 year ago
Public Participation: All Canadians should be able to have a say in environmental decisions that concern them. The current NEB process is an affront to "democracy" as it excludes most concerned citizens, limits the scope of comments from those who do participate and even refuses to allow questions by intervenors. At this time, the process is nothing more than public relations spin to look as though "consultation" is taking place when it is clear that a decision to proceed has already been made.
Sharon Willan over 1 year ago
It is not enough to "look before you leap" - you must look to the 7th generation before you leap." Assessment must be required when the health and welfare of all peoples, all species within the area is impacted: in other words all projects. The purpose of the vision appears all-inclusive. But look at the Tar Sands:- people, land, water, air, species of fish, birds, greenhouse emissions are greatly negatively impacted. This project is not following the principles of Assessment and is still allowed to continue.A healthy environment must be accessible to all people in Canada as well as the species we live with.We must embed a healthy environment first and foremost within all assessment projects. It must be a legal requirement that cannot be overturned when a new government is elected!
Linda V. Lewis over 1 year ago
Reconciliation w/ and genuine communication w/ Indigenous Peoples is very important. It must include real listening, deep listening, and questions. Talking circles ideally could be used, so that many Indigenous voices could be heard without speedy interruption.
L Daoust over 1 year ago
Reading the purpose section was informative however, where is the outline for legal protection of our basic human rights to fresh clean drinking water, healthy air to breathe, and good healthy food. Various interest groups doesn't seem to protect every Canadian's right to fresh clean water, healthy air to breathe and good healthy food.
Grace Fix over 1 year ago
I am pleased that your vision includes a scientific approach and that you encourage participation amongst stakeholders. What I would like the Panel to acknowledge is that a healthy environment is not a luxury, but a necessity. Canada needs a healthy environment to prosper and because it’s a human right. Without a healthy environment, we have nothing.
Lyn Ellis over 1 year ago
It should always and forever be a right to have clean water, air, & land. This is not a luxury.
Lyn Ellis over 1 year ago
Please always consider a clean environment as a right!
Terrence Conroy over 1 year ago
I feel that the panel report is excellent as far as it goes. I do feel however that it is necessary to include strong laws that recognize environmental rights and responsibilities to protect the people and places we love. The right of all Canadians to a healthy environment needs to be incorporated into all proposals for development.
Terrence Conroy over 1 year ago
I feel that the panel report is excellent as far as it goes. I do feel however that it is necessary to include strong laws that recognize environmental rights and responsibilities to protect the people and places we love. The right of all Canadians to a healthy environment needs to be incorporated into all proposals for development.
Jacqueline Steffen over 1 year ago
I find the wording at the end of paragraph 1 under the heading Context to be to extremely vague. "In sum, IA processes should give Canadians confidence that projects, plans and policies have been adequately assessed.". What does 'adequately assessed' mean exactly? I believe we need stronger wording and it needs to be clearly stated in what that intends. In my view, 'adequately assessed' is insufficient and lacks in any legal substance. It leaves far too much room in the court of law when citizens must address negligence from corporations in the future due to oil spills or any other environmental damage.
Malick Diene over 1 year ago
I agree that there is a need to improve the vision pertaining to the conduct of an EA; however I don’t think conducting IA vs. EA is the appropriate answer. The current EA process is weak on Scoping under CEAA 2012. A proper scoping phase in EA is critical to the acceptance of the EA findings. A Good scoping usually will lead to a comprehensive EA, where not only the impacts on the biophysical environment are considered, but social and cultural effects are also included in the scope. Therefore, the vision should not necessary be to move from EA towards IA, but rather to strengthen the scoping phase during the EA process. Strengthening the scoping phase by broadening the scope, engaging with all key stakeholders during the determination of the EA scope and including more potential effects for consideration likewise in the CEAA-1992 will naturally lead to a more effective and credible EA process. The loads with the current processes (EIA, SEA, REA, CEA, etc) are enough heavy to start adding more layers of complexity with new processes such as IA, SIA or RIA. That would completely overload and stall the system. Dealing with environmental issues may be very complex sometimes due to the facts that divergent interests are often at stake. The current EA process under CEAA 2012 faces some real challenges and limitations. The role of an effective EA is to foster a fruitful dialogue between different stakeholders in order to bring mutual understanding while producing reliable, scientific and factual information about a project in a way that is open and transparent to help inform the decision making. The current Consultation process under CEAA 2012 is viewed as flawed because often times the consultation is not taken seriously. It comes very late during the EA process, and rather than being a real dialogue, in many cases, it is just an information session where the proponents give a lecture about the project and the mitigation measures. Consultation need to be done in a more inclusive, collaborative and partnership manner. Furthermore, the follow-up and monitoring phase is not given enough consideration. There is a need for a robust follow-up and monitoring system that would allow to systematically analyze the gap between the predicted effects and the actual effects in order to take the necessary corrective actions. Communities and the general public have the feeling that once the project is approved, there is little or no follow-up leading to mitigation plans not being implemented properly.In light of those limitations in the current EA process under CEAA 2012, refocusing on reinforcing the Act (CEAA) and its subsequent regulations by mandating a systematic follow-up and monitoring program, strengthening public participation and broadening the scope of the EA are some of the key ingredients for restoring public trust in EA without necessary moving towards a totally new IA (Impact Assessment) or SA (Sustainability Assessment) which will likely be more complicated to execute considering the number and the variety of issues and factors to be included. A thorough and comprehensive EA does exactly what the type of IA envisioned and described in the report will do. Changing a name from EA to IA will not automatically restore public confidence. What restore public confidence is how the process is conducted. It is important to find a middle ground that is acceptable for all stakeholders and parties in order to ensure a sustainable Canada’s future; a future that hold a solid economic growth deeply rooted in a tangible environmental stewardship, social progress and prosperity for all.
Jeannie Nash over 1 year ago
I also find it very hard to have to read through all of your information...it takes too much time for me to read it all...What I really hope for is the transparency that we need, and an easier way to respond. I was not impressed with the fact that only 500 people have responded...and that you only talked to 1000 people. That tells me that others are also having the same problem and cannot respond easily
Jeannie Nash over 1 year ago
Im concerned about the Kinder Morgan Pipelines and other such pipelines ...we need to stop those pipelines and invest and create jobs in newer and lower impact innovation...everything from car emissions, to Oil and gas spills, and the issues that are happening in British Columbia......how can we lead an environmental impact without considering these issues?
Bonnie. Denhaan over 1 year ago
IA must be the primary action before any activity onsite takes place.
Bonnie. Denhaan over 1 year ago
Early involvement is absolutely essential. All concerned must be actively involved, but the Federal position must be fully clear and firm.
Bonnie. Denhaan over 1 year ago
Steps in the right direction. Must make sure that provinces, etc.do not sidetrack (or sidestep) Federal input.
Bonnie. Denhaan over 1 year ago
Takes into consideration the longstanding complaints and problems with the current system.
Bonnie. Denhaan over 1 year ago
A positive approach
Bonnie. Denhaan over 1 year ago
Thorough and detailed understanding of what is currently lacking
Bonnie. Denhaan over 1 year ago
Generally in agreement with the proposed process
D Jackson over 1 year ago
In order for me to provide a truly informed comment regarding the potential issues and concerns in the design of projects, plans and policies of the Federal Impact Assessment process for Canada would require a panel of experts to study the government’s panel of expert opinions and recommendations contained in this report.With that in mind, I will comment based upon the above summary.My major concerns with the current assessment process is the lack of transparency, a lack of compliance with scientifically based expert opinion, a lack of compliance with economically based expert opinion, a lack of compliance to previously negotiated First Nations treaties and land claims, the lack of inclusion for any and all Canadians to be heard and a lack of faith that any review process would be adopted by a provincial government when it does not favor their position. I do agree with the majority of concepts expressed in this report but I am not seeing any process that would ensure compliance with a federal assessment report. If legislation was enacted to compel compliance, what would prevent future legislation from being dismantled by a future government with a majority position in parliament? This was witnessed when the previous Conservative government, with the stroke of a pen, decimated years of environmental protection legislation in favor of economic benefit, at the direct expense of the environment, which to this day remains unaddressed.What is the purpose of this process if a single Canadian politico with a majority position in parliament has the ability to thwart all reasonable efforts to protect the health and welfare of Canadians in general, the environment and the integrity of a new review process?
stu lip over 1 year ago
all Canadians should be able to have a say in environmental decisions that concern them.uphold Canada’s obligations towards Indigenous peoples.ensure all projects and activities are good for Canada’s environment and communities, enact triggers for all projects before they can receive a federal permit.should be a right of appeal for both interim and final decisions, and an independent tribunal should be established to hear those appeals in order to ensure justice and accountability. Allow right of appeal and an independent tribunal to hear those appeals.early planning stage is essential
David Inwood over 1 year ago
I am generally very supportive of the direction of this report, especially the ideas of starting the consultation process earlier, and ensuring that projects have a net benefit for affected people.I like how section 2.1.3 said that benefits in one of the five pillars of sustainability should not come at the cost of losses to other pillars, although trade-offs may sometimes be necessary. I would hope that these trade-offs would depend on the specific context of each individual case, and would be done without any pillar being prioritized over another.
Michael Herauf over 1 year ago
I find the wording at the end of paragraph 1 under the heading Context to be to vague "In sum, IA processes should give Canadians confidence that projects, plans and policies have been adequately assessed.". Adequately assessed for "what" is not stated clearly. "Adequately assessed for their environmental impact" is what is missing after all is this all not relating to environmental assessments and as such this needs to be clearly stated not just implied as without it the law leaves far too much wiggle room for later abuse not in harmony with the spirit and intent of the law as a reflection of the will in best interests of the people of Canada.
A.G. Lewis over 1 year ago
With regard to item 1A (see below) - throughout the entire section - and even the entire report - the concepts so pertinent to ENVIRONMENT are replaced with POLITICS. Environmental objectives are not adequately displayed throughout the report.From the abstract: "Therefore, what is now “environmental assessment” should become “impact assessment” (IA). Changing the name of the federal process to impact assessment underscores the shift in thinking necessary to enable practitioners and Canadians to understand the substantive changes being proposed in our Report."
Rachel Wilson over 1 year ago
"Conservation Versus Preservation - Which?" https://www.linkedin.com/pulse/conservation-versus-preservation-which-rachel-wilson on @LinkedIn
Brad Jones over 1 year ago
I agree!
Dennis over 1 year ago
The list of things requiring an environmental assessment seems reasonable but i find it interesting that there is nothing to address factors that affect human health. As an example at least two commentators have identified light pollution as items that are not addressed. Perhaps there should be broader area that could include light pollution and other items that affects the health of Canadians.
Shawn Nielsen over 1 year ago
I would like to see light pollution included for impact assessments. Outdoor lighting from street lights, businesses, homes illuminates not only objects on the ground, but the overhead sky as well. This light pollution has been researched in both the science and medical fields and has been shown to disrupt nocturnal ecosystems and have negative effects on circadian rhythms of both humans and animals. The spread of high Kelvin (4000K, 5000K) white LED lighting is now exasperating the problem of light pollution. This type of light which contains a lot of blue light, is well documented for its far greater contribution to skyglow and overall brightening of the sensitive night environment. Light pollution is growing more each year and is no longer contained to urban areas and is spilling out into rural and natural areas. This environmental pollution needs to considered and mitigated within impact assessments. Lighting is always viewed as a technical issue even though it is primarily an environmental issue - because you are changing the natural environment for one reason or another and nature is qualitative, not quantitative. In order for people, wildlife and other species to have a healthy daytime, we need to have a healthy night time.
Andrew Duthie over 1 year ago
This initiative to modernize the Canadian federal EA process is very welcome, long overdue and contains valuable proposals. Below are a few points that I hope will be helpful.The primary purpose of EA/IA is to provide a basis for fully informed decision-making. Greater understanding and emphasis on the theory and practice of decision-making and precisely how it permeates EA/IA and the project life-cycle would help this analysis, especially the relationship between facts and values/beliefs as a basis for decision-making.Changing Environmental Assessment to Impact Assessment is immaterial - the two are interchangeable. Instead redefine and adopt a more modern definition of "environment". e.g."The surroundings within which humans exist and that are made up of -i. the land, water and atmosphere of the earth;ii. micro-organisms, plant and animal life;iii. any part or combination of (i) and (ii) and the interrelationships among and between them; andiv. the physical, chemical, aesthetic and cultural properties and conditions of the foregoing that influence human health and well-being. This includes the economic, cultural, historical, and political circumstances, conditions and objects that affect the existence and development of an individual, organism or group." ( reference https://www.environment.gov.za/sites/default/files/docs/series0%20_overview.pdf)Adopt all the Basic Principles set out by IAIA for effective EA/IA not just the four chosen (reference https://www.iaia.org/uploads/pdf/principlesEA_1.pdf )You may find the Integrated Environmental Management framework a good basis for developing the vision and connecting for connecting Land Use planning and Strategic Environmental Assessment to Environmental Impact Assessment and various jurisdictions https://www.environment.gov.za/documents/strategies/integrated_environmentalmanagement_eim )
Author Commented Canadian Environmental Assessment Agency over 1 year ago
Thanks for all your comments. Keep them coming!
Vanessa Holland over 1 year ago
I also have a question regarding the change of scope when shifting from an environmental assessment to a impact assessment. Will this new impact assessment be the stand alone assessment for projects moving forward or will they continue to undergo separate social and economic analysis? I just wanted to make sure that the other components of sustainability were not getting a stand alone and integrated review whereas the environment does not get its on analysis process.
Vanessa Holland over 1 year ago
I do not think that the approach to sustainability best represents the true nature of the interaction between the five components, you have identified as the five pillars. The pillar model itself is inherently flawed as it does not take into account the dependency of the economy, society, health and culture on the environment. These components require a healthy and intact environmental system in order to operate, and cannot exist in isolation. In order to be more sustainable we must recognize that there are limits to growth which are dictated by the environment. As well, the environment, economic, societal, health and cultural systems are nested and therefore sustainability requires that actions be based on a systems thinking approach rather than each system being an independent entity. In order to achieve sustainability we must make sustaining the environmental system the center of decision making so that we are operating within the ecological carrying capacity of the earth.
Dr. Monique Dube over 1 year ago
Thank you for the opportunity to comment. The purpose of impact assessment is stated clearly in the report and is accurate based on the science and policy understandings of IA. That said, it is important to not assume that this is a common understanding of the aim of IA. In some jurisdictions in Canada IAs have become "checks for application completeness" by the provincial authority. An evidence-based assessment of impact is not occurring in some cases for 2 reasons: 1) there is not an understanding of the intent and methodology for impact assessment within the agency and 2) the competency within the organization does not exist to assess the application from an impact perspective. This is having a significant negative effect on industry in terms of time, cost, efficiency and being given clear direction on mitigation that may or may not be required. This is also resulting in a lack of independent oversight to ensure environmental impacts were clearly assessed. Advice to the panel; basic organizational structure and core competencies for regulatory authorities should be assessed to ensure they have 1) the knowledge and background to evaluate an impact assessment and 2) the core competencies on staff to do so.
James Cleland over 1 year ago
Impact of a project should also include how the site will be cleaned up after the life of the project. There needs to be an assurance that there are funds available to do the job. We have seen abandoned oil wells,pipelines,mines etc that have not been cleaned up properly.
James Cleland over 1 year ago
I would like to see light pollution as one of the criteria looked at. Generation of light uses about 20% to 25% of generated electricity and as such is a major generator of greenhouse gases.The impact of ALAN is widespread. Light from a major city can be seen and impacts the environment for over 200 km. Studies done show major impacts on all types of wildlife. For example over one billion birds per year are killed by impacting lit buildings. Use of light is growing at a rate of 5% to 7% per year so we are using over 300 times more light than we did in the 1920's. Is it helping to make us safer or more secure? Based on what studies and based on what criteria? There is also growing evidence that ALAN(Artificial light at night ) may be adversely affecting our own health in such areas as obesity,diabetes ,depression and sleep disruption.
The Explorers and Producers Association of Canada over 1 year ago
The member companies in our Association invest billions of dollars each year in energy development projects which employ tens of thousands of Canadians. We rely on major energy infrastructure projects to move resources to markets which will deliver the highest value for Canada's energy resources. Canada's reputation with investors as a predictable, rule of law governed jurisdiction has suffered in recent years from the uncertain timelines and uncertain outcomes encountered by project proponents seeking to construct resource development and related infrastructure. There are few major resource infrastructure projects currently under development in Canada and the lack of business confidence and investment is the major reason for Canada's weak economic performance, slow wage growth and low productivity. The Panel's vision for a new impact assessment model is a recipe for more of the same, if not worse, with proposals, for example, to: (i) abandon certainty on timelines, (ii)remove reasonable and appropriate qualifiers for participation in project reviews, (iii) give indigenous groups something resembling a veto on project approvals which is incompatible with Canadian law and (iv) attempt to resolve competing jurisdictional overlaps and indigenous interests through seeking consensus with no clear road map on how to get to a timely decision for the project proponent.
Ole Hendrickson over 1 year ago
The Concerned Citizens of Renfrew County and Area are pleased that the Panel clearly heard our concerns in our submission about the proposed million-cubic-meter radioactive waste dump (“Near Surface Disposal Facility”) at the Chalk River Laboratories.We agree with the Expert Panel’s focus on impact assessment as a planning tool. Our experience is that impact assessment needs to “better address a review of alternatives” early in the planning stages. The Canadian Nuclear Laboratories – a corporation created by the Harper Government to operate the Chalk River Laboratories, currently run by a consortium of multi-national corporations on a 10-year contract - did not initially engage the public in a discussion of alternatives to a landfill-type facility for “permanent disposal and eventual abandonment of a variety of low- and intermediate-level nuclear wastes within 1 km of the Ottawa River. We strongly concur with the Panel’s observation that early public involvement in planning can “reduce conflict later in the IA process” and avoid “adversarial relationships with project proponents… prior to large investments of time and money into publicly contested options.”
Ivan Touko over 1 year ago
I believe the most essential recommendation made was that (federal) IAs should begin with a legislated Planning Phase as early as possible before. The earlier the discussion is started the earlier all the stakeholders can be involved, provide valuable information and perhaps prevent the start of projects that could potentially be more harmful than beneficiary in the long term. Because once critical decisions and investments are made, it is less likely that a project can be stopped even if found more harmful by an IA as money, resources and labor would have been used. I also do partially agree that federal interest be central in determining whether an IA should be required as long as this does completely annihilate the ability for each provinces to be involved in the IAs processes as well. Each provinces have different hardships and we could assume they each know what is best for their provinces. This leads us to the recommendation about sustainability centrality in IAs. Here, sustainability will have to be very well defined so that stakeholders do not take advantage of any ambiguities in the regulations. Furthermore, economic pressures might not allow all the pillars to be always accounted for.
Ashley Tod over 1 year ago
I agree with the Panel that implementing a planning phase would be beneficial to future IA’s. This way, affected groups could be brought in for public participation, more time would be spent looking at potential impacts and all participating parties would be informed on all aspects of the project. The planning phase is designed such that all groups can critically analyze the project prior to implementation, and provide their input on projected issues. The issue I find with this concept of a planning phase, is the fact that the Panel plans to base all decisions/planning off of “5 pillars of sustainability.” These pillars are not easily accessible, and in order to maintain some of them such as “social” and “culture”, further studying is necessary leading to increases in economic burden which would not be valued by the developer. The Panel also suggests that consequential impacts on matters of federal interest should determine whether or not an IA is required. I disagree with this, as there are many other aspects that should be considered when deciding whether or not to do an IA, and federal interests do not always pertain to those interests of other parties such as aboriginal groups.
Emily W over 1 year ago
I agree with section 2.1.2 proposing a formal Planning Phase for federal assessment. The early involvement of and communication between proponents, communities, and other stakeholder groups is optimal because it generates transparency as well as a more efficient IA process. What fails to be mentioned is the approximate time frame of this Planning Phase. Is there potentially a point in time where the planning phase is conducted too early in relation to the project? For example with early preliminary project plans, there may be a lack of information to facilitate meaningful public/indigenous participation and collaboration. Yet overall, a legislated Planning Phase is optimal for federal IA. Developing the project design earlier includes collaboration between proponents and communities/stakeholders while reducing cost and conflict in later IA stages.
Jeff Anderson over 1 year ago
Federal Impact Assessment needs to protect the environment without significantly restricting economic benefits. The stated intent, in Section 2.1, has a focus on sustainability without a clear definition of what determines whether a project is sustainable. Many of the areas of concern are similarly vaguely defined. Any legislation which is designed to protect our environment should be explicit, so that there are as few loopholes as possible. Fish needs to include seasonally fish-bearing waters, as well as non-commercial fish species. A clear definition of the threshold at which emissions are “of national significance” will be necessary. Identifying and valuing environmental services is challenging, and some indication of the guidelines which govern the decisions about economic versus environmental values would help developers as well as the public.
Felysia over 1 year ago
I agree with The Panel recommendation that the IA needs to be clear when a federal jurisdiction IA is required. This is essential to better understanding of the IA process and increased compliance. The list supplied, which encompasses the federal interests, is comprehensive but should only be a foundation for a more extensive list. A more exhaustive list is better because there will be less confusion about an IA under the jurisdiction of the federal government. Secondly, I believe including the Planning Phase in the formal IA was a positive step. Currently, this is not happening and there seems to be miscommunication regarding information gathered and submitted by the proponent. I appreciate that the federal government is including this step because it will encourage communication between the proponent and stakeholders impacted by the proposed project. The communication encourages compromise and a solution that allows all stakeholders to be satisfied.
YADVINDER BHARDWAJ over 1 year ago
The initiative of early engagement of the public and indigenous people in conceptualizing, design and planning a project, is to be appreciated as it will help in mitigation the gaps and conflicts between the proponents, government and the public. This participation will allow a great feeling of equality and harmony in the Indigenous community and on the other end will turn out to save significant investments of time and money made on by the proponents. My belief is that this approach will also reduce the workloads, and ease the process of decision making for the assessment agencies and add transparency on the federal level. It is not much clear how the process is to be distributed among the provincial, strategic and regional levels as doing the impact assessment on the three tier level would also duplicate the efforts, which seemed to be a resource and time-consuming. The other primary concern to me is, how an appropriately knowledgeable indulgence of public in their opinions will be regulated, and not just random thoughts.
Carl Thiele over 1 year ago
The addition of strategic or regional IAs provides a good solution to looking at sustainability in a broader context in the IA process. It could also allow for cumulative effects to be considered more easily and how new projects contribute to sustainability within Canada. As pointed in 2.1.3 sustainability does need further clarification and how that applies to IAs. A clear definition of sustainability would be required however adding sustainability to the IA process would be of great benefit to Canadians. Sustainability could however differ in how it is prioritized if it be cultural, environmental, or economic and or any combination of these. The priorities should be made public so that everyone is aware of where the Federal priorities stand.
Martijn Dieleman over 1 year ago
Firstly, I agree with the expert panel in that the federal interest should be noted for the application of federal IAs. The federal process should not cover everything, as autonomy on behalf of the provinces for IAs is important for provinces to manage their own province’s environment as well. The early involvement I also agree with, and the quote by Mr. Friesen encompasses this well. Additionally, this allows for communities affected by projects to be able to ask normative questions early on, about why a project is needed or specific impacts on their community as a whole. This allows for the best pathway of information to the public. The next major section of interest is the sustainability section, which describes “five pillars of sustainability”, it is a good idea in theory, but there is little specifics given for how these will applied. A major criticism I have this is that there should be more description for how these pillars interact with each other and which of them will be given more weight, e.g. economic over environmental?
Kristina over 1 year ago
I do not agree with the idea of inputting environmental considerations earlier in the impact assessment. Although there may be a few key biophysical or social factors that could be affected by a proposed project, the volume of environmental data to be collected for this earlier proposition would require money and resources that I don’t believe either firms or taxpayers would be willing to pay. Most of the data would be wasted, because only after the project is proposed can impacts on the environment or surrounding communities be fully understood and quantified, and so only a fraction of that data collected previously would actually be used.
Shawn over 1 year ago
I strongly agree with the section of this report where it speaks about how earlier engagement is critical to the success of an IA. If we start to consult stakeholders about their opinions on the project before it is fully designed and built this will foster trust and better communication relationships. Currently, if the project is already designed and a stakeholder has issues with it then they must take on a defensive standpoint to try and prevent the project from going through. However, if stakeholders are consulted before the project is fully designed this will result in them feeling like their voice is being heard and that they are contributing to the success and optimal design of the project. Not only would this change foster better communication, but it would also result in cost savings for the companies. If they can design the project after hearing concerns from the public, then fewer changes will have to be made and the project can be designed with input from multiple stakeholders.
Jennifer Weeks over 1 year ago
According to this document, the purpose of the Federal Impact Assessment process is to try and address the disjoint between the impact on biophysical components and social concerns. Beginning to collect information earlier and monitor later after the project is completed is also an issue, as the current Environmental Impact Assessment process does not do this regularly. However, this proposed document lacks any solution on how exactly they are going to encourage companies to spend money on intensive data collection and monitoring practices. Early planning and data collection could be good for social license in the future, but not good for pre-assessment costs and could be detrimental to the economy due to some projects not being feasible. Since this is a Federal proposal, subsidies and incentives will have to be offered to ensure this is done. The environmental component is addressed, however the economic factor that businesses will have to address due to the IA is not.
Caitlin Herrick over 1 year ago
Specifically, I agree with the expert panel regarding early involvement in section 2.1.2. It is crucial to involve and engage the public as early as possible in the planning process so that their concerns may be heard and conflicts will be minimized. As well, it was mentioned that the project planning would be suboptimal without early input of the public. I think this is especially important because the public involved, like Indigenous people, experts and affected community members, because they offer critical knowledge of the area, which will benefit project planning. This involvement of concerned and affected citizens will greatly benefit both the public and proponent to strengthen relationships and the quality of the project planning. I think greater involvement in the IA process to gather information that can be implemented into the planning is a step forward to improving the process and purpose of environmental impact assessments.
Julie Jodoin over 1 year ago
In this section, the term “sustainability” is discussed at length about how its definition varies with each person or stakeholder. I believe that the five pillars of sustainability - environmental, social, economic, health, and cultural well-being - are an accurate representation of what must be carefully considered during an impact assessment. However, the report details that “all five must be examined to assess impacts to Aboriginal and treaty rights and interests”, but these five pillars should be used to observe impacts on all populations and lands of Canada. I understand the emphasis on Aboriginal interests, but the wording suggests that this framework will only be used in circumstances involving Aboriginal peoples. Furthermore, there is no mention on how the five pillars will be compared against each other in the event where one pillar has a large net benefit, but another one has a significantly negative impact. The concept of positive and negative trade-offs seems extremely vague and inefficient to the process, while the yes/no negative significance criteria from before feels like a more assertive decision.
Casi Bouchie over 1 year ago
I agree that identifying and addressing concerns in the early stages of project development facilitates positive relationships between all the parties involved. Early engagement with interested parties allows for discussion of normative issues and brings public values to the forefront. The report acknowledges that face-to-face engagement should be prioritized in the planning stage. Unfortunately, it does not offer any specific details about the forum in which this will be achieved. Additionally, the current provisions in CEAA 2012 regarding public comment are often restrictive or vague, particularly when the responsible authority is the CNSC or the NEB. Will this newly introduced planning stage only apply to projects that the CEA Agency is responsible for? I also have concerns about the sustainability aspect, which comes off a bit as window dressing for social license. Will the “5 pillars of sustainability” be weighted equally in considerations of risks and benefits? How is the government planning to quantify factors such as social and cultural well-being? Will judgments be subjective and at the discretion of the Commissioner? I am concerned that economic factors may be overemphasized if we do not have definitive and measurable standards in place for all the aspects of sustainability.
KendraR over 1 year ago
I agree with the IA panel regarding early project development before any elements are finalized because this gives the opportunity for more public participation and can potentially reduce costs in the development phase. Although enhanced interactions are beneficial to project proposals and opinions are considered, more involvement can slow down the process of passed proposals and difficulty reaching a consensus. I also agree with the IA Panel by transitioning from a significant to sustainable approach since there is more initiative to focus on the ability of future generations and production. A potential downfall to this transition is that society weighs sustainability in the environment, economy, culture and health in different ways. I would be interested to know if the IA can implement a strategy or type of assessment that could quantify these objectives in order for it to be easier to measure and provide a basis on what is important concerning new projects.
JD over 1 year ago
Moving from a "significance" model to "sustainability" model injects a great deal of uncertainty into how projects are to be assessed. They note that the sustainability framework should be based on five pillars including environmental, social, economic, health and cultural yet the current system already assesses each of these topics via CEAA 2012. Moreover, the very nature of sustainability is subjective depending on different peoples' worldview raising the question how they intend to weigh and objectively evaluate the various criteria. For example, how do you weigh or account for the vast benefits oil or natural gas has brought to humanity? 2. The report advocates for the assessment of alternatives. Who do they intend will conduct this alternatives assessment? The IA Commission (IAC) or the proponent?
Jamie G. over 1 year ago
Dale Friesen’s analogy is perfect to show why the Panel wants early involvement of the public. If the public is approached before the decision is finalized, they won’t feel like their rights to oppose the project have been taken away. I think that the Panel’s idea of early IA and public involvement will definitely save time and money in the future. On the other hand, too much public involvement could delay a project or may cause more harm than good. It will be difficult finding the boundaries of just how far public involvement should go (especially timewise). It’s great that the Panel has acknowledged that sustainability means something different to each person. But they want every assessment’s sustainability framework to be defined specifically and objectively to each project according to the impacts and interactions of the 5 pillars of sustainability, but emphasis on each pillar might be different weights. The Panel also says trade-offs between pillars will be necessary. How often will the economic pillar prevail over the others? If a project will create jobs and enrich Canada’s economy, the environment, social, health and cultural pillars will probably take the hit, making objectivity hard to accomplish.
Lauren Erdely over 1 year ago
I agree with the notion that sustainability should be a component for assessing projects in regards to the IA process. I also agree that assessing the future consequences of a given project as well as the net benefit (or net negative) impacts will allow for more complete and holistic decision making when creating a meaningful IA. However, where my main concerns lie is that the five pillars used to assess sustainability cannot all be easily quantitatively measured. For example the cultural and social benefits of a project will be much more difficult than the economic or the environmental benefits to measure and assess to make a statement regarding sustainability. Therefore, I believe the Panel should outline more specific measures for each pillar to ensure all components are quantifiable so they can be reasonably assessed.
Melissa over 1 year ago
I agree with the panel’s statement that it is important to develop a clear list of requirements for when an IA is required. This will ensure that neither time nor resources are wasted by either the companies or the government. By keeping federal interests central in determining IA, there is a specific goal that can be addressed, rather than completing ambiguous and possibly unnecessary work or assessments. I believe that using IAs as the preliminary planning tool is the best way to avoid future negative relationships between stakeholders and, if done properly, will also help to avoid wasted time and money that might be put to better use elsewhere or assist in changing the project design. The Expert Panel stated that the “assessments do not currently start early enough”, which I agree with; IAs should be the first order of business when a project is proposed. If any planning or construction is undertaken before a thorough assessment has taken place there is potential for some aspect to have been missed and therefore the “project itself will be suboptimal”. Earlier and increased involvement of stakeholders means that there is a better chance of conflict resolution.
Tayla Lazenby over 1 year ago
The list of aspects Federal IAs should be involve contains them to national concern rather than provincial. If Federal IA assessed all aspects this could lead to overlooking of some important aspects. I agree IAs should be done early in the Planning guiding project decisions to minimize effects by avoidance rather than compensation later on. Having the IA happen early could increase trust and have stakeholders voice concerns about the project early giving them a chance to have impact on the planning phase. I like to concept of changing from significance to sustainability as many proponents get away with saying no significant residual effects based long time lines and assumptions that mitigation will be effective. Having sustainability take both positive and negative impacts, as well as future generation, into consideration will be beneficial. However, as stated, there needs to be a universal definition of sustainability to reduce confusion and guide the decisions to a common point. There should also be a way to make sure no pillar is represented more in the final decision than any other, and I believe that environmental impacts should not be negated just because there happens to be large economic benefit of a project.
Janelle Goodine over 1 year ago
2.1 While the purpose of IA is to “identify potential concerns related to a project, plan, or policy,” I believe that integrating the entire concept of sustainability into each individual development may be challenging. Given that the definition of sustainability varies by perspective, its pillars provide a clear understanding of which components should be considered in an IA. However, I think that the net benefits of some values attached to environmental, social, economic, health, and cultural aspects cannot be compared against one another. The decision that lies with determining if a project will contribute positively to sustainability may be subjective and in this manner, a bias towards one of the pillars is highly likely to arise. To eliminate these tendencies, I agree that the role of planning should have a higher significance than it currently does. This way, there is more co-operation and respect between involved parties to establish what the true value of certain biophysical and socio-economic factors are. As a result, I think that in order to develop a clear framework for evaluating impacts, a system in which negative and positive effects have trade-offs will need to be highly structured given the multiple parameters used to quantify these values.
Shannon F over 1 year ago
The panel’s recommendation that federal IA should begin with a legislated Planning Phase for projects prior to development and design finalization would be beneficial. I like that the panel suggests that earlier planning phases would allow for various sides to provide input when addressing project concerns. This would allow the government and proponents to save valuable time and money in the long run by reducing the likelihood of having to reinitiate the process when unexpected obstacles occur partway through the project. Although this can make all necessary information available, the vast array of potentially conflicting opinions could render it hard to come to a decision that all affected parties can agree with. If everyone isn’t happy with the decision there is the potential for unsatisfied parties to feel like they were unheard. Though making sustainability a central consideration could be valuable, it doesn’t take into account the fact that sustainability has varying definitions and no guidelines for measurement. Although there is a framework for sustainability, it is highly subjective. Some pillars of sustainability may have more emphasis placed on them due to personal bias. This can allow for one project to be unrightfully favoured over another.
KierstenS over 1 year ago
Overall I am in agreement with this section. In 2.1.1, I agree with the list of what Federal IAs should include and I think that this is a very important part of the process. Determining which projects require an IA is imperative to conducting any sort of project. Requiring proposed projects to include consultation with affected proponents before the “important decisions have been made” is a way to earn the trust of groups that may or may not be affected by the project and a good way to earn social license. This will allow disagreements to be discussed and potentially be resolved before any projects start to proceed. The only part within this section I find problematic is in 2.1.3 when it states “projects which provide a net benefit to the country should be approved. Those that do not should not”. Using a blanket statement like this groups all proponents together and does not take in to account individual problems and issues. It also makes it seem as though these individuals are not as highly regarded as “the country as a whole”. Therefore I disagree with this particular statement.
Jamie Card over 1 year ago
I agree with the Panel that there is a strong need to start the Impact Assessment earlier than it previously has been started. Through the encouragement of public participation and cooperation with Indigenous peoples I believe that Impact Assessments will be more informed earlier on in the process and that it will save time and money from being wasted further down the line. This early engagement will allow major decisions to be critiqued early in the planning process and can mitigate issues that the current process has. Currently, most of the big decisions regarding projects are implemented before input from the public and Indigenous peoples occurs. If this is changed, the Impact Assessment process can be transparent, inclusive, and informed – three of the four fundamental principles of IA processes as defined by the Panel. This engagement can be undertaken in a way that builds relationships amongst every party involved creating meaningful participation – the fourth fundamental principle of Impact Assessment processes. Overall, this early engagement stands to increase efficiency of Impact Assessments which I believe is a pivotal component to the success of Impact Assessments.
Chris Arbter over 1 year ago
Although it is important to look at the combined impacts a project may have, I believe it is still necessary (depending on the project) for individual components to be examined. An impact that may not seem to have an effect on a large scale may in fact be a detriment on a smaller, local scale and therefore it should still be closely examined. I definitely agree that IA and its planning/design should happen as early as possible. By doing this, a lot of time and money may be saved in addressing issues prior to anything that may arise from a project further down the road. Regarding what IA considers; the current legislation does a good job in determine the general importance of environmental effects. However, I agree that in the future a transition to a more specific review that determines more precisely what the effect of an impact is would greatly benefit all parties involved with the IA process. By more clearly understanding the impacts created by a project, mitigation strategies may become easier to assess and the continued implementation of these strategies will be more likely to happen.
Ashley Sarauer over 1 year ago
2.1.3 This section of the report details how the term ‘sustainability’ can have different meanings depending on the stakeholder or individual. I agree with the ability for sustainability to encompass different values, so as to” contribute a net benefit to environmental, social, economic, health and cultural well-being.” But in order to capture this diversity in values, the report suggests “a review of net benefits and a review of trade-offs between benefits and negative effects.” This sounds good in theory, but in practice it doesn’t seem clear how, say, cultural benefits will be calculated in comparison to economic benefits. Considering it is likely that the same economic consultancy agencies will complete these ‘net benefit’ reports, how will the methods of calculating cultural or socioeconomic benefits become more stringent or robust compared to the past? Considering the metric will remain the same, in terms of calculating ‘net benefits’ (which usually comes down to calculating a monetary value), I am interested in knowing how economic assessments will change in order to more affectively capture cultural and socioeconomic conditions? If the methods in which consultants calculate ‘net benefits’ don’t change, then I cannot foresee how the report would ‘more effectively’ capture socio-cultural values than previous.
Jessica Newman over 1 year ago
A federal IA may help address cumulative impacts of multiple different projects across federal interests. When done successfully I believe that an IA done early on in the planning process will help guide proponents through a better understanding of the impacts associated with a project or a plan. However, I think that there are issues with the IA deciding whether a project should proceed based on the projects contribution to sustainability. I think that it is hard to compare the economic benefits in which a monetary value can be determined from the project compared to environmental impacts in which monetary values are difficult to determine. There needs to be clear transparency in the decisions about when the economic benefits to society are greater than the impacts on the environment and how the 5 pillars of sustainability were used in the end result whether it was approved or not. Another concern in the IA process is subjectivity when considering if the process fails or passes the “sustainability test”. There needs to be clear guidelines in the decision making process that are objectively-based on the science, evidence and the 5 pillars of sustainability presented in the IA.
Glen Schmidt, Laricina Energy over 1 year ago
The Panel has spent little time on evaluating what works. By understanding the centers of regulatory excellence that exist and processes that address the concerns expressed solutions that capture the best of what has been developed can be made. A design assumption that what exists needs to be replaced will create a poor outcome. A starting point should be improvement not replacement, innovation in building upon Canada's world class regulation vs. the assumption it needs replacement should be the starting point.
Haley Quadros over 1 year ago
Regarding 2.1.2: The previous section (2.1.1) identifies Indigenous Peoples and lands as a deciding criteria by which to conduct a Federal IA. It follows then that early engagement and inclusivity should be the primary priority when beginning a project IA. This is especially true not only to ensure concerns are identified and discussed, but because the Indigenous people can be a valuable asset when collecting information about a proposed site. Their knowledge base is a wealth of untapped potential when it comes to issues regarding sustainability of local resources and identifying culturally significant areas. Perhaps this section can expand on the potential of utilizing Traditional Ecological Knowledge (TEK) as a tool by which to aid the Planning Phase.
Grayson Wagner over 1 year ago
I like the broad shift from purely an environmental assessment to a policy that aims to weigh all impacts; environmental, socio-economic and otherwise. I think this is most notably stated in the opening paragraph, where reconciliation between Indigenous and non-Indigenous people is toted as a goal before any mention of environmental protection. That said, though IAs are a great place to start, reconciliation may be larger problem than the IA process can address. Having looked at the current "Regulations Designating Physical Activities" for EAs, I like that the panel desires to make it more obvious when an IA is needed. The list of activities looks fairly comprehensive, but it would need to be a living document, that is, adjusting to new technology and industries as soon as possible when they become available. The quote from Dale Friesen of ATCO used in the document is apt in summarizing measures that could be taken to minimize controversy right off the start of a project. I believe it ties in with the goals of sustainability based off the five pillars, in that the sustainability goals for a project are decided on a case-by-case basis as early in the project development as possible.
Thomas Milligan over 1 year ago
A federal IA may not always be required, but the federal government should always be involved. The federal government considers multiple aspects of Canada (economic, social, environmental, cultural, and health). It is because of this that the federal government should be involved in IAs across the country regardless of whether it is a federal IA.Although I agree that the planning portion of IAs should be done early in the process to create a fully inclusive and informed report, not all interested parties should be engaged. Involving every interested group could result in the involvement of people not affected by the proposed project, wasting time and money. Further, planning before important project decisions have been made will reduce the need to mitigate or compensate impacts later. Relocating and redesigning projects will be most effective before major decisions have been made, and will in turn be more effective in protecting Canadians.Sustainability is fundamental in the IA process. Sustainability includes the analysis of both positive and negative impacts. Positive impacts are important but, I believe negative impacts should carry more weight in determining the efficacy of a project, because they will have a larger affect to future generations than positive impacts.
jmw over 1 year ago
This proposal is cumbersome and unclear with vague lingo that is not easily understood. I do not think the science is settled regarding greenhouse gases. It appears your information is not guided by recent science which indicate that our boreal forests and the action of sunspots more closely affect our climate than greenhouse gases, yet you are willing to make sweeping and possibly unnecessary changes to industry in Canada at great cost. Of great concern to me is that you are listening to lobby groups who do not have Canada's best interest at heart and are funded by foreign oligarchs and foundations specifically for their own financial interest. So far, all of the IPPC predictions regarding climate change have been wrong and their models are in question. Those of us who have been following this issue for years understand the carbon tax is a tool for redistributing money from Canadian taxpayers to other areas of the world and thus far, the sacrifice of Canadians has elicited no change whatsoever in the reduction of greenhouse gases in these so-called developing countries. How sad that Margaret Thatcher's effort in the 1970's to demonize carbon dioxide so that she could move nuclear power ahead in Great Britain, has had such disastrous unintended consequences.By focusing on this issue of climate change, issues we can improve on such as pollution, clean water, air quality are relegated to secondary issues.I'll end with this. If the railways and highways in this country were managed the way you are suggesting in this panel, they would never have been built.
McFadzean over 1 year ago
I am pleased to see the degree of understanding that has been shown by the Expert Panel relative to input from individuals and groups who presented to them over the duration of their study. They seem to have incorporated the input in a very positive manner. We would support a wider mandate for environmental assessments in the future with the process being known as an impact assessment.
Mark A. Kavaagh over 1 year ago
Sorry but this section is poorly written for it wastes time describing what an Impact assessment "can contribute to..." rather than what must be done. I suggest this section better focus on actual requirements rather than describe what could, should or might be done. .e.g. replace the introduction to the second line with: " Impact assessments MUST describe how a proposed project will contribute to the creation of positive relationships..."
Mark Wittrup over 1 year ago
1) Agree that the IAs should be focussed on federal issues, but reasonable bounds need to be put in place. Under the old CEAA, there were inclusion lists that triggered IAs for ridiculously minor projects (e.g. clearing more than 100 m-squared), wasting time, money and stifling innovation. The removal of these lists allowed for a focus on projects that had a potential to impact the environment in a significant manner.2)The report recommends the IAs be informed by Strategic IAs (SIA), but the wording is such that it appears as though an SIA is a pre-requisite to an IA. It also leaves unresolved who is responsible for SIAs. As the SIA is correctly identified as a policy/strategy process, it must be clear that SIAs are the responsibility of government and that their absence should not impede the progress of a proponent's IA. That an IA should use all available information is imperative, but to wait for that information to be generated through an SIA ahead of a proposed project would create undue delays in projects and be a barrier to investment. 3) While consultation as early as possible in advance of a project is fine to say, all parties in that process have a responsibility to engage to make that work. All too frequently, early, meaningful engagement is difficult to achieve because of a lack of identified contacts or contact mechanisms. Help is needed in this area as proponents at the early stages of projects (e.g. exploration work) are not well funded and are leery about spending money without some form of outcome. 4) IA process should broadly follow the investment patterns of business so that proponents are not handicapped by having to spend considerable upfront dollars ahead of normal steps of acquiring such funding. Currently, project proposals align roughly with pre-feasibility studies, and IAs align roughly with feasibility studies with permitting (detailed design and engineering) aligning with full financing. These levels of data and design appear sufficient to address issues at each level.5) If an agency is to be created, let's avoid the problems with the MPMO, which did little but add process and delay to projects.
Sheryn Sauve over 1 year ago
"Sustainability is a term that has different meanings to different people in different contexts. As such, on its own it may pose challenges to implementation. Therefore, at the outset of each assessment, a sustainability framework should be defined to address specific aspects of a project and the potential for interactions and impacts on five pillars of sustainability:environmentalsocialeconomichealthcultural."Is there a way to weigh or prioritize these various components. Given any particular project, there may be higher considerations given. An impact assessment is similar to a risk assessment. There are positives and negatives within the sustainability, but some weighed differently than others. Using scientific evidence is very important. Anecdotal evidence is also important. Historical evidence should also be of concern. Modelling for future impact . . .