Initial project description | Previous comments on Information Requirements and Time Management Regulations | Impact Assessment Regulations

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Initial project description

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

Question 1: What are your views on the proposed components in the initial project description (Annex I)?

tgray about 1 year ago
I think this is an improved and reasonable balance. People must realize it can be difficult for proponents to provide every minute detail at this stage. The outline in Annex 1 requires substantial by achievable homework by the proponent and should screen out the 100% speculative fishing expeditions, while giving enough content to guide the early end of the process. Suggestion under #11(e) that Initial Project Description guidelines state a default position for "Lands and Resources Currently Used for Traditional Purposes by Indigenous Peoples", wherein all lands are in this category unless demonstrated otherwise (ideally with consent of affected indigenous group). Also important to develop companion policy guidance on what this term means; specifically, that "current use" applies to the role of places and their attributes in culture and oral history, not just physical occupation. It is important that this be clarified and considered during early scoping.
U.S. Environmental Protection Agency about 1 year ago
Annex I, Item 11 provides a list of the location information that is to be provided in the Initial Project Description. The U.S. Environmental Protection Agency recommends that the project’s proximity to the U.S. border and transboundary waters be added to the list of location information. That information will enable the project proponent, as well as Canadian and U.S. agencies involved in environmental review, to determine at the earliest possible time whether the project could have potential impacts on transboundary waters. This information is needed to: (1) evaluate impacts outside of Canada and (2) determine the scope of stakeholder participation, including involvement of U.S. federal agencies, states, tribes, and stakeholders.
Allan Webster NWMO about 1 year ago
The initial project description must provide sufficient information to enable Canadians to identify if there are any issues that need to be studied that have not already been studied by the project proponent, or any issues identified as a result of the studies that require resolution. NWMO submits that it is impractical for the Agency to engage the public without information that enables them to understand what has been done by the proponent. NWMO understands that, in part, the purpose of the detailed project description is also to provide the information needed by the Agency to make its decision pursuant to section 16 of the draft Act whether an impact assessment is required. Providing this information at the beginning of the process will make that decision more timely to achieve.Further, without the information identified the Agency will not be in as informed a position as possible to judge whether comments raised by the public are issues that are relevant to the impact assessment.In practical terms, a project proponent will have to complete the work listed in the detailed project description (Annex II) before submission as the 180 days of the pre-planning period would be insufficient time to create the information identified, especially if the proponent is waiting for the summary of issues from the Agency. NWMO submits that it is more efficient to inform the proponent what information and studies are required such that they can provide a complete description of the project for public review. Based on the consultation paper, NWMO submits that the following additional information that appears in the detailed project description (Annex II) be required for the initial project description (Annex I):• Early planning results• A description of the purpose of and the need for the designated project• A description of any alternatives to the designated project• A description of the alternative means of carrying out the designated project that are technically and economically feasible, including the effects of those means• A description of the best available technologies and best environmental practices that will be used on the construction, operation and decommissioning of the designated project.• A description of any financial support that federal authorities are, or may be, providing to the project• A description of any federal land that may be used for the purpose of carrying out the project• A list of the permits, licences or other authorizations that may be required by a federal, provincial, territorial, Indigenous, or municipal authority to carry out the project• A description of the physical and biological setting• A description of the health, social and economic setting in the region where the project is located.NWMO also suggests that the initial project description should be expanded include any studies that the proponent has performed to determine the effects of the project on the natural environment, the social and economic well-being of Canadians, and on the health of Canadians that are listed in paragraphs 22(1)(a), (b), (c), (i), (j), (k), and (s). [Paragraphs (d), (e), and (f) are already included in the listing for a Detailed Project Description (Annex II)] Any Traditional Knowledge that has been shared with the project proponent will have been incorporated into the above studies and information. A report identifying the information that has been shared and how it was incorporated should be provided, if the Indigenous group that provided the information has accepted the loss of confidentiality.
jeffgeipel about 1 year ago
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.
David Day about 1 year ago
I am most familiar with projects submitted to Parks Canada for ski areas operating within National Parks. Parks Canada already has a robust process for conducting environmental assessments and is recognized as a Cooperating Agency by CEAA. I believe that the greatest challenge faced by Parks Canada is addressing cumulative effects because, although developments can be governed through policy and planning processes, including the environmental assessment process, in National Parks such as Banff and Jasper, through which major national transportation arteries, pipelines and power systems pass, regulating the number of visitors has proven very challenging. These parks are very popular with Canadians and visitors from other countries, and finding ways to provide appropriate visitor services and facilities will remain a challenge.It is very important to me that Parks Canada retain its position within the Federal Government's CEAA legislative and policy context. It is equally important that effective overview of Parks Canada's performance be provided periodically by Canada's Environmental Commissioner to ensure that the Government's expectations for quality reviews and a rigorous process are upheld. It is my understanding that Parks Canada has received a very positive report card to date.Initial project description (PD's) do not usually come from unexpected sources within National Parks. No one is going to propose a new mine and no hotel project will be advanced outside an established hierarchy of National Park Plans. For example, I am presently managing the development of a new Long-Range Plan for the Lake Louise Ski Area, and that plan (and its component developments) can only be submitted because it will be consistent with the National Parks Act and Policy, Parks Canada's 2006 Policy for National Park Ski Area Management, the 2015 Site Guidelines for Development and Use of the Lake Louise Ski Area, and the 2015 Strategic Environmental Assessment of the same 2015 Site Guidelines. Parallel planning and development contexts exist for Townsites and Service centres within National Parks, and for all Oitlying Commercial Accommodations. Only by developing a strong policy and planning context, has Parks Canada been able to envisage a cap on development that responds to conservation needs, and not the pressure of continuing visitor popularity.An Initial Project Description in a National Park has no validity unless that project has already been anticipated within pre-existing plans. As such, while I support the types of information proposed for projects in this legislation, I believe that Parks Canada has the ability to 'narrow-down' the policy funnel, by expecting that Initial Project Descriptions relate not only to the general requirements outlines in the proposed legislation, but to specific National Park Plans, and Area Plans or Sectoral Policies. Parks Canada should NOT have to consider any other types of projects.
Peggy Zhou about 1 year ago
I think the initial project description gives useful information to the proponent, the public in the early stage of the assessment. The background information is fully prepared to the government to determine the classification of the project. I think it helps people to understand the project and may want to participate in the decision making in the future.
Andrea about 1 year ago
I believe that the proposed components in the initial project description is crucial to ensure that detailed information about a project is available early, and communicated/engaged with indigenous groups and the public. This will ensure efficiency and effectiveness in getting more people involved and informed about the types of environmental, socio-economic, and cumulative effects going on in different regions around Canada.
Carlie about 1 year ago
I think the proposed components in the initial project description is nice. May be also include a list with potential wastes that could be generated or chemicals that would be used in the proposed project, which was one of the components in CEAA, 2012.
Douglas George Massey about 1 year ago
Too complicated for the average citizen. Any development that could possibly affect the life of the Fraser River Estuary and the migration route of the salmon, should be subject to a federal environmental review and the cumulative affects it could have on the Fraser River and the Salish Sea. We must preserve the remaining 15% of the of what is left if the Fraser River is to remain as life giving resource.
Daniel Akpabio about 1 year ago
The proposed components in the initial project description (Annex I) covers the key information required to get the public informed about the project. This information would give the public information on what could possible affect them and have them get their opinions heard before the project is approved.
Kristyn about 1 year ago
I think that this is great improvement from CEAA. The early stages of the project are arguably the most important so everyone involved or affected understand what is happening. I would add within the location section something about the land area within a wider radius that may be affected by residual or cumulative effects from the project. The more information at the beginning the better.
Jeremiah Kevin about 1 year ago
based on my understanding this a better way to begin a project. the government will have a better engagement with Indigenous groups, provinces, stakeholders and the public in how best to meet the requirements of the legislation.
Joby about 1 year ago
In 'Location Information' perhaps a specific designated section of described location for areas not necessarily immediately relevant to the project but could have potential cumulative or unforeseen effects in the future.
Jack T. about 1 year ago
For the impact assessment process, the early planning stage provides the project to get ahead. Although, the agency is who contacts stakeholders and Indigenous. I believe that it is good to consult, but also that the stakeholders and indigenous peoples should be able to voice their opinions directly to the proponent. This can help create a more personal exchange, making those who are being consulted feel more than just a number or a landowner that can be negotiated into selling off their land.
Stephen Young about 1 year ago
According to me, the initial project description has been well-outlined and is the best way to begin a project. It is provided with sufficient time to be done and starts very early to obtain meaningful responses from Indigenous communities and the general public to voice-out their different opinions in knowing what would be the ultimate purpose of the project, the impacts (both positive and negative) that it would have on them, and the mitigation measures that they could think of. It is well presented and gives sufficient time for good interpretation of the project.
Drew about 1 year ago
The initial project description is a great method of delivering information to the public and stakeholders in a clear and detailed way so that they're able to fully understand the potential impacts and footprint will have in the environment. The earlier that public and Indigenous peoples engagement is done, the assessment will be more efficient and have less problems will occur.
Louis about 1 year ago
I think the initial project description is really great since it provides the information about the project, so the public knows what are they facing and it is inviting everyone to give feedbacks or comments on the project (not limited to only some groups). These comments also great, it provides different point of view, not only from the government sides but from the public and people near the project area. I also agree that this should be done early.
Alyssa over 1 year ago
I think the initial project description is a great way to start a project. Everyone that may be impacted has the chance to learn about the project. It allows everyone involved to bring forward their opinion and knowledge and help with further development of the project. It is important to make sure that everyone's voice is heard and that each participant brings forth information for the project. This will help determine which area/tools/methods are best for the projects development. As it says in Annex 1, I agree that it should be done early on in the process before too much development has occurred and potentially already caused damage to the environment/surroundings.
LeannaR over 1 year ago
The initial project description should include baseline data and predicted impact.
Desiree Langenfeld over 1 year ago
The initial project description is sufficient as a starting place for impact assessments.
Andrew McLeod over 1 year ago
I think the proposed framework laid out in the description is strong. Focusing on making sure enough project details are accessible to the public and groups and organizations that would take interest in a said project. Focusing on early engagement is crucial for making this process more efficient and preventing potential hangups later in the assessment process.
Mark Wittrup over 1 year ago
Most of this is fairly basic information that can be easily assembled by a proponent. Normally at this stage of the regulatory process, projects are still formative. In all likelihood, a proponent has submitted this information as the result of a pre-feasibility study or similar and the project has not finalized most material items. So when Annex I asks for the information in sections 7 to 10, there are still a wide range of options being considered. It would be impractical for a proponent to lock the project here as that would not allow any changes arising from the initial consultation this description would elicit. The Annex needs to align with the business world and at this stage acknowledge that projects are formative and evolving - in fact, up until the process is finished, there needs to be the flexibility to alter the project in response to a wide range of factors. There is unlikely to be any engineering available at this point beyond the conceptual.Annex 1 should clearly indicate that the information is as complete as the proponent understands it to this point, and allow for the listing of all of the alternatives being considered.
Rmorrison11 over 1 year ago
Not sure if there is a way to categorize projects to understand the industry standards and past industry practices. For example, all hard rock mining projects should be lumped into same category and sub-categories would be open pit or underground. The company should also identify if it is proposing a new technique or approach to that industry or if it is using same technology as existing. This would help to better understand the issues through category as opposed to project name which may not help.
Tyler over 1 year ago
My views are on this is what are the oil & gas companies going to respond if there is a spill?