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Detailed project description

by Dillon, over 1 year ago
CLOSED: This discussion has concluded.

Question 2: What are your views on the proposed components in the detailed project description (Annex II)?

tgray over 1 year ago
(View #1) Refer to my separate comment on Initial Project Description re. "proximity to [...] lands and resources currently used for traditional purposes"; (View #2) For the "Potential Effects" headings (#24 to 27), please consider reframing these requirements: move away from "description of effects", and adopt "identification of linkages". The focus as this stage should be identifying where there are positive and negative effect pathways, to prompt scoping discussions for what effect pathways need detailed studies, defined in the Tailored Impact Statement Guidelines. Asking proponents to "describe effects" on all of these topics will draw them into writing conclusive but likely unsubstantiated effects assessments. This then leads to positional statements and defensive actions by all parties at this early stage.; (View #3): Suggest re-wording #23 to state "A description of the health, social and economic setting in the region(s) where the project effects will manifest"; (View #4): Item #29 is duplicate of #11; (View #5): When asking proponent for details on what studies they propose to do (#32), be clear that these proposals must give strong rationale and methodology, and intended use of the information.
U.S. Environmental Protection Agency over 1 year ago
U.S. EPA has four comments on the proposed components in Annex II: 1) Item 13 provides a list of the location information that is to be provided in the Detailed Project Description. We recommend that proximity to the U.S. border and transboundary waters also be provided.2) Item 25 requires that applicants provide a description of any changes that may be caused to the environment that may occur as a result of carrying out the project outside of Canada. We appreciate inclusion of this requirement. The U.S. EPA has been involved in reviewing Environmental Assessments and Environmental Impact Statements prepared by applicants under direction from CEAA and the BC EAO for the last 20 years. Our reviews have mainly focused on discerning whether there are impacts to U.S. waters and environmental resources. However, that information is sometimes difficult to find given study areas that often stop at the border and the length and complexity of the documents. The EPA is currently participating in the workgroup for the Red Mountain Gold Project (British Columbia) and recently reviewed the EIS. The Red Mountain Gold EIS was the first EIS that we are aware of that had a discrete section entitled “Changes Outside of Canada”. We greatly appreciate that effects outside of Canada were analyzed and that the EIS included a discrete section in the document that summarized this analysis and referenced where to find supporting analysis in the EIS. This information enabled the U.S. stakeholders involved in the project review to more easily find information pertinent to potential trans-boundary impacts and target pertinent sections of the EIS. Requiring this information be included via the proposed regulations should ensure that future impact statements consistently include the assessment of environmental effects of Canadian projects occurring outside of Canada.3) Items 26 and 27 require that applicants describe effects of changes occurring in Canada that could impact Indigenous peoples. Consistent with the concept in item 25, we recommend that items 26 and 27 also require information be submitted related to potential effects to Indigenous peoples outside of Canada.4) Annex II (Potential Effects of the Project) requires that project proponents provide information on the project setting and descriptions of changes that could be caused by the project. There is currently no discussion regarding whether the description of changes would include the cumulative effects of the project, in addition to the consideration of effects of current projects or future projects in the same area. We therefore recommend that the cumulative impact contribution from the project also be assessed.
Allan Webster NWMO over 1 year ago
NWMO, as identified in the response to Question 1, is of the view that the information required to be included in the detailed project description cannot be adequately prepared in the 180 days provided in the timeline. As such we have suggested that the majority of the information identified in Annex II be required to be provided with the initial project description. NWMO submits that the second submission from a project proponent should be limited to its response to the issues raised that have been accepted by the Agency as relevant for purposes of the impact assessment and any additional studies or information that it will provide in response to those issues. An updated project description can be provided that improves the clarity of the initial project description. NWMO submits that the requirements in Annex II should be:• Provision of an updated project description that clarifies or provides incremental information to the initial project description in response to comments received;• A description of the information and studies that the proponent proposes will be submitted in response to the summary of issues provided by the Agency, including the methodologies for the studies;• A description of the planned engagement activities that will be undertaken by the proponent during the impact assessment process including who will be engaged, the method for engagement, and the timing of those activities;• A description of the planned engagement activities with Indigenous peoples that will be undertaken by the proponent during the impact assessment process and how the proponent will responded to Indigenous concerns raised during engagement.
jeffgeipel over 1 year ago
As with the initial project description, information needs to be provided on potential positive economic impacts as well as negative ones. While of course it is vital to understand potential negative impacts, projects that create little or no adverse impacts - but also do not create meaningful positive ones in terms of economic benefits - will be at risk of opposition. Simply "doing no harm" is not sufficient to assure host community support as so many currently stalled projects show. Information should be provided by project proponents on both expected direct employment and procurement, and this should be made explicitly clear from the very beginning as a means of encouraging proponents to consider how to maximize these potential benefits. At the stage where a detailed project description is required, proponents who cannot provide detailed information on expected direct employment and procurement raise serious concerns about their ability to manage a proposed project in a way that will gain support from stakeholders.
Citizen's Climate Lobby, Nelson West Kootenay chapter almost 2 years ago
Annex II, clause 28 says the proponent is to provide “an estimate of the greenhouse gas emissions associated with the designated project”. Given the June 2017 Discussion Paper describes one of the goals as “reinforcing through peer reviews of …evidence in the assessment phase” and given the often complex nature of this task, we believe the ‘estimate’ should be accompanied by the equivalent of a peer review so the Agency and the public can be confident in the results of the estimate.
Andrea almost 2 years ago
I believe that the proposed components in the detailed project description is a step in the right direction towards improving cooperation with Indigenous stakeholders (such as providing these groups with more information on project effects and involving them in collection of TEK in order to produce a more meaningful project description. However, I have to agree with some other comments received in that some areas may be weighted as a higher concern than others (such as social effects vs. environmental effects). If a proposed project is designated to be in a remote area, there may be less public engagement, therefore will this effect the consideration given to environmental impacts?
Carlie almost 2 years ago
I think include the ideas/ knowledge that collected from Indigenous, stakeholders and public and how did the proponents modify their proposed project based on the comments from public is a good ideas. This would show to Indigenous, stakeholders, and public that their participations are meaningful and encourage them to participate in the future assessment.
Daniel Akpabio almost 2 years ago
The current list of components in Annex II is sufficient but more detailed studies should be required instead of predictions. This information can be derived from similar projects undertaken in the past.
Kristyn almost 2 years ago
I think that the proposed components in the detailed project description is a major improvement. By making it mandatory to outline such things as methods and Indigenous engagement, it holds the proponent accountable to actually follow through on what they say they will do to perform project activities. It also ensures that public and Indigenous engagement is started very early on in the project.
Joby almost 2 years ago
Information in Impact Assessment Planning lists means of identifying project alternatives. When proposing the assessment there may be bias in the proposal of alternatives comparatively with the project owners preferred locations. Maybe submissions of effects by local groups in areas of potential project locations.
Jack T. almost 2 years ago
The detailed project description says that it will include the proponent’s information about the possible environmental, social, health, and economic effects. There seems to be more of a heavy focus on the effects made to people over the effects made to the environment. If people are coming forwards and making comments on potential impacts on the environment, such a cultural heritage, are these comments one of the major factors in why there is mitigations measures taken against adverse environmental effects? For example, a project is no where near civilization, and no people have any connections to the project. Therefore, not many if any comments or concerns are brought forwards. Will this result in a weak environmental assessment, with potential adverse environmental effects slipping through the cracks because the public weren’t aware or weren’t concerned by the project?
Dana almost 2 years ago
There are several sections that require knowledge of local Indigenous populations and the potential effects the project could have on their traditional lands and livelihoods, which I believe will make the project description more inclusive and set the stage for Indigenous consultation and involvement throughout the impact assessment process. Section 27 is particularly important as it requires understanding what changes in Canada could have contributed to the current health and socioeconomic status of nearby Indigenous communities.
Stephen Young almost 2 years ago
From my point of view, the detailed project is more specific in that issues or information discussed during consultation in the early planning phase with the Agency, with Indigenous communities and the general public are clearly explained and are provided explanation in finding alternatives of the project or mitigation measures for the project. Descriptions for alternatives of the designated project with their anticipated effects, and the descriptions of technologies and methodologies that would be used in implementing the project would be greatly beneficial for all. Moreover, decisions made by the Agency in classifying the project as being designated for undergoing impact assessments, the adverse effects or possible effects that would have direct impacts and concerns for Indigenous communities would be more transparent. I believe that Annex II is clear, detailed and transparent in providing more meaningful responses and information.
Drew almost 2 years ago
Having an additional early planning phase and providing updates on any changes made during that early planning phase is a good idea since it will allow for more efficient and accurate information and data to be collected for the project. Also will help determine any foreseeable issues that may occur once the project is started.
Louis almost 2 years ago
I totally agree with an addition of early planning phase since it will cover more research about project description and the assessments needed, therefore it will lead to a better project design.
Alyssa almost 2 years ago
The detailed project description should include large amounts of information on the project. This information should be categorized and should show the importance each area has. For example environmental or endangered wildlife impacts should be given more consideration than some of the other categories that are not as much of a concern.
LeannaR almost 2 years ago
My view is that Indigenous groups should be informed and consulted on the detailed project description as it will have changed. This process can affirm input provided during initial consultation and provide feedback on the appropriateness of changes that were made.
Desiree Langenfeld almost 2 years ago
The detailed project description is sufficient. I agree with the addition of an early planning phase.
Andrew McLeod almost 2 years ago
This is a detailed system that covers more aspects of an all-encompassing system than just the environment. I am concerned about the lack of a weighted system, this seems to insinuate the environmental effects, for instance, could be easily outweighed. Perhaps I am misunderstanding the context.
Mark Wittrup about 2 years ago
Annex II again, largely requires information that would be in a normal project/technical description and the changes. In the normal course of the IA process, the information provided to government would be at the pre-feasibility level. At this level, the proponent can generally discuss a preferred option, but may still have material alternatives to consider. The engineering required to support the IA at the feasibility level and/or detailed engineering required to support any licensing within this process, would be done during the period allotted for the proponent to complete the work requirements in the documentation the agency provides at the end of the 180 period. As per Annex I, Annex II should have the ability to consider alternatives until a final description is done in the IA. In fact, a proponent may carry forward alternatives though the whole process (e.g. a variety of mining methods or process methodologies to allow the project to respond to changing conditions. This should be acceptable as long as the net level of impacts remains relatively constant. Sections 15 to 17 speak to this.It would be good to put some bounds on what the agency expects from a "description". As someone with >30 years doing EIAs, I would expect a description to be largely anecdotal, comprised largely of available information and be data light. Sections 25 to 31 are largely speculative at this stage of a normal project. While educated guesses can be made and some data will be available, the level of information sought here would be better focused in the development of the IA.
Rmorrison11 about 2 years ago
As per previous comments on initial project description, there should be a way to categorize the project to specific industry categories and types and include a statement as to whether the project follows industry standards or is using new techniques or technologies. This would help to initially understand potential effects based on past industry practice.
Tyler about 2 years ago
Make sure that neither level of government, taxspayers, & customers don’t have to pay a single cent if there is a spill