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Impact assessment documents

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

Question 3: What are your views on the documents the Agency is required to provide to proponents if it is determined that an impact assessment is required?

tgray over 1 year ago
In terms of sequencing, it will be important that the Indigenous Engagement Plan be developed and implemented before approving the Tailored Impact Statement Guidelines. Good proponents will do this (are already doing this) without government oversight but it is still comparatively rare. Engagement with indigenous communities should, in most cases, provide strong direction for what goes into the IA terms of reference (the Tailored Impact Statement Guidelines). Separately, and in response to some earlier comments, I urge the Agency to develop a process where the proponent will NOT have done all of their studies by the time the TISG are issued. This is what we already see at provincial and federal levels, leading to proponents lobbying very hard with any number of tactics to tailor the Terms of Reference to match work they have already done. A collaborative Terms of Reference including government, first nations, proponent, and stakeholders is a very important part of an EA process that restores public trust. When we see a comprehensive ToR approved by regulators after much work and then a proponent turn and submit a 10,000 page EA matching that ToR within two weeks, it draws immediate and valid suspicion on the whole process.
U.S. Environmental Protection Agency over 1 year ago
The Agency is required to provide the proponent with a public engagement plan, but in the consultation paper it is unclear if in the timeline there is a period for the public to comment on the Impact Statement. We recommend clarification on a public comment period and response to comments during the assessment by the agency/ review panel. Further, we recommend clarification on whether comments will be responded to by the action agency, proponent, and/ or review panel before the decision.
Allan Webster NWMO over 1 year ago
The Tailored Impact Statement Guidelines and the Permitting Plan arrive too late in the process to provide value to a project proponent. Project proponents will have completed the majority of the studies in the development of the Project Description. As such any specific guidance that would assist in the development of those documents must be provided earlier. NWMO submits that if Tailored Impact Assessment Guidelines are to be issued they should be at the request of the project proponent and used to ensure the project description provides the information necessary to support the impact assessment. This will enable the proponent to obtain Agency and regulatory guidance on the methodologies and scopes of the studies it will perform, including best practices from current or completed impact assessments. NWMO expects that the request and guidance would both be published on the internet.Proponents, to the extent possible, will seek to perform studies and provide information that meets overlapping impact assessment requirements and permitting requirements in a single document. NWMO submits that the Tailored Impact Assessment Guidelines should address redundancy between the studies and information required by the impact assessment process and the permitting process such that overlapping requirements do not increase the burden on proponents. This will support the goal of “one review”. As such the Tailored Impact Assessment Guidelines will have to be issued jointly with the life cycle regulator, where this is applicable.The Permitting Plan as described only provides information on the content required to achieve the licences or other permits that will occur following the decision on the impact assessment. Proponents will have identified the permissions that they understand will be needed for the project and included that information in the Project Description; information on what is required to obtain those licences or permits from the federal regulators are already published or can be obtained by the proponent. NWMO sees no value in the Permitting Plan as described.
Andrea almost 2 years ago
I believe this is another great initiative for involving more members of the public and other stakeholders. It has potential for more concerns to be heard and hopefully, better influence the decision-making process. By having this as publicly-available information, it is a sign of rebuilding-trust, as there are no hidden or grey areas. I also believe that the Permitting-Plan should be non-optional for this reason. Moreover, I believe that public-commenting periods should be longer, as well as advertised through more sources, as many people are not always aware of these opportunities.
Carlie almost 2 years ago
I think provide the documents to the proponents if impact assessment is required is a good thought. With the document, it increased the transparency to proponents for the decision making process on the requirement of impact assessment.
Daniel Akpabio almost 2 years ago
The documents required should be sufficient enough in information required. The permitting plan should not be option as this can create a loophole for the proponent to explore during the project phase.
Kristyn almost 2 years ago
I think that documents encompass a large amount of information which is good. My only suggestion would be making the Permitting Plan non-optional. By providing the Permitting Plan, it shows that the proponent has looked at the project from all points of view and is aware of the impacts the project may have and the specific regulatory documents that are required. By making this non-optional, it holds the proponent accountable for ensuring thorough research is done prior to permit application.
Jeremiah Kevin almost 2 years ago
i have no problem with this system as long as the agency provide the informations in timely manner so it wont slow down the process.
Heather Webb almost 2 years ago
I believe that the documents the agency provides will promote transparency to the public. It is nice to see indigenous engagement included in these documents. Overall, these documents will help create a more well-rounded impact statement. However, these documents will need to be provided in a timely manner as to not slow down the assessment process.
Jack T. almost 2 years ago
Because the documents the Agency is providing to the proponent are translucent for the public to see, this can enable the public to read the documents to ensure proper information is included and nothing gets left out. This may also build trust, having all documents available for the public, rather than hiding this phase of determining if an impact assessment is required.
Aidan12 almost 2 years ago
The documents that the agency will provide to the proponents are a great way of speeding up the entire environmental assessment process. By completing these in the early planning stages of the project, it will allow for more opportunities for public engagement and aboriginal consultation on future projects. These plans need to be thought out and make meaningful efforts on how to address public comments to the project on the Impact Assessment Cooperation plan particularly. One concern I do have is that the agency could take some time to produce all of these documents, and the proponent could get annoyed with the length of time that it takes to develop these plans. A timetable for these plans to be completed needs to be implemented in order for all parties associated to make plans around this and prepare for the next stage of development. Overall I believe that these documents will create a more well thought out impact statement on both environmental, and socio-economic issues, as long as they are completed in a timely matter, and information on their completion is given out to both the proponent, and any major stakeholders.
Stephen Young almost 2 years ago
I believe that the documents that the Agency would provide to the proponents are strong enough; provided that those documents are made available in a timely manner, with trust and with sufficiently clear and transparent information so that the proponents would be aware of the advancement of their projects and hence, would be able to work collaboratively well. The establishment of harmonized timelines and tailored impact statement guidelines would be key advantages in the advancement of the projects. Overall, this technique is well-outlined and enthusiastic.
Drew almost 2 years ago
This system works as long as the Agency provides all information in a timely manner. It also help the proponent stay involved, keep up to date information and have an overall better assessment done for the designated project.
Louis almost 2 years ago
Make sure the Agency must provide significant informations regarding the impact assessments and proponents be ready to tailor up if something is missing.
Alyssa almost 2 years ago
My views are that the documents the Agency must provide are sufficient as long as they are posted in a timely matter and contain significant amounts of information.
Desiree Langenfeld almost 2 years ago
I think that these documents will aid the proponent in coming up with a well thought out impact assessment. I like the idea of having a tailored impact assessment guideline for the proponent.
Andrew McLeod almost 2 years ago
I have no issues with this system, it is important to be sure that the proponents are committed to the next phase and this keeps their involvement up.
Mark Wittrup about 2 years ago
As a preliminary comment, the consultation process should have a fifth comment area available for general comments not specifically related to the 4 the government is directly focussing the reviewers on.Calling the guidelines 'tailored' belies an ignorance of the how government works. Having seen this process before several times, the project-specific (or "tailored") guidelines rapidly become generic, all encompassing and rarely project specific. The draft legislation would actually lead one to believe that studies could be very focussed on the areas of potential impact to federal or Indigenous interests, but that is not likely to happen. The challenge I would give is for the agency to actually tailor guidelines to avoid the former one-size fits all/shotgun approach to guidelines.The cooperation plans may seem like a good idea, but .... They will work until they don't. And if they don't what mechanisms are in place to assist all parties in making this work. Some parties are notorious for being non-responsive to process. How will the federal government guarantee that this process will be effective and of value to all parties? There is no lack of good intentions here, but there is also a complete lack of detail. For most proponents, this is very concerning as they will not at this point see a way through. This is the specific area that most proponents will believe that there will be significant delay. I
Tony R Walker about 2 years ago
Recommendations for the federal government of Canada to consider during reviews of the federal environmental assessment processes are to:(i) reorganize the website to reflect transparency and clarity so that monitoring reports and data are made publically available; (ii) create a legally binding aquatic monitoring programs to ensure that all Canadian aquatic ecosystems are monitored with equal rigour; and (iii) ensure that monitoring frequency is included and justified in all aquatic monitoring reports.
Rmorrison11 about 2 years ago
To make sure that all assessments are conducted equally and to the required level of detail, the agency needs to prescribe as much detail as possible. The list as proposed appears to prescribe sufficient detail to allow the proponent to understand the requirements.
Tyler about 2 years ago
That proponents should be required to have all required permits by lower level of governments before applying for federal permits.