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Timeline suspension

by Dillon, almost 2 years ago
CLOSED: This discussion has concluded.
Question 4: What are your views on the proposed criteria under which the timelines in the proposed legislation could be suspended?

tgray almost 2 years ago
My main comment is in response to the bullet list of four criteria. The third bullet speaks to "critical information is missing". I suggest this be reconsidered and expanded, away from "missing information" and instead toward "inadequate information". One challenge of mandatory timelines is how to manage with spam EAs. There may be all the right headings and some content under each to match the Tailored Impact Assessment Guidelines. I believe that the Agency should canvass early input from participants and consolidate information requests within the first 60 days of review. Any request for substantive information from the proponent should not only stop the clock, but should re-set it - bearing in mind the legislated timelines are the maximum, and would still allow the assessment to conclude earlier if warranted.
Allan Webster NWMO almost 2 years ago
NWMO submits that the criteria identified are suitable for a suspension of the timelines. NWMO understands that suspension of the timeline will also automatically occur if the proponent requires time to respond to a request. For example, if the review panel requests additional studies or information from the project proponent under section 52(2) of the draft Act for purposes of performing its impact assessment, the proponent in indicating how long it will take to provide that information does so on the understanding that they have requested the suspension of the legislated timeline. NWMO suggests that the proposed regulation on timelines confirm this understanding.
Maurice Cramm almost 2 years ago
In the Case of Offshore Oil and Gas we already have a process that is managed jointly between the Federal Government and the Provinces as part of the Offshore Petroleum Boards - the system has functioned quite well for the last 30 years.
Andrea almost 2 years ago
Stopping the clock for legislative timelines would be good in terms of the proponent gathering more information and data if there is newly-arised issue or a design change in their project that could change the potential impacts of the project on the environment or local communities. This could ensure that a re-evaluation be conducted and prevent any possible critical information from being missed during these changes.
Carlie almost 2 years ago
I think the proposed criteria are good, especially including the clock can also be stopped if the information is missing at the early planning stage and during the assessment by agency process (e.g. scientific data to support the decision).
Daniel Akpabio almost 2 years ago
I do not support the suspension of a timeline. Proponents could take advantage of this by delaying projects until a new government comes into power, this new government could be willing to ignore some regulations in favour of the proponent. Also, I believe the proponent would be more focused to get the job done knowing they have a timeline to work on. But exceptions could be given for reasons that seem legit enough.
Kristyn almost 2 years ago
While a balance between timeliness and level of detail is needed, suspensions of time should be available at all phases of the impact assessment. If the proponent needs more time to accurately assess the environmental effects occurring, they should be able to do that (within a reasonable time limit to ensure up to date data). Additionally, if further consultations are necessary, a suspension should be granted to ensure that all parties are involved.
Jeremiah Kevin almost 2 years ago
Extension of Timeline should be available for all phases and not only for the planning phase, the impact assessment by the Agency, the Review Panel, or the decision making phase. this decision should made together with the minister and not only by Governor in Council.
Heather Webb almost 2 years ago
If the proponent is to remain in control of all phases of the process, they should have a chance to suspend certain timelines to provide the needed documents. Timeline extensions should be made available during all stages of the process (within reason) and should not just be left up to the Minister of Governor in Council. Reducing the time limits for each stage could add to this problem as the proponent will have a shorter time period to provide needed documents. However, reducing time limits is also a good idea as it will speed up the assessment process.
Jack T. almost 2 years ago
The proponent should be able to stop the clock, as financially, they are the ones who will lose out from delays. If they figure that the timeline should be suspended it should be up to them. Although, the suspension should be temporary and have a decision made upon it within a certain timeline.
Stephen Young almost 2 years ago
According to me, the criteria of stopping the clock or suspending the project are just right. The timelines for stopping the clock are well-defined in allowing the proponents to review and to make proper adjustments if required for better transparency and efficient outcomes and in mitigating unprecedented adverse effects. However, from my point of view, a project should be completely terminated if it is found that it would have deadly impacts such as the extinction of wildlife or would be greatly affecting the environment, the health of people; including Indigenous communities, at an extremely high degree.
Drew about 2 years ago
The proposed timeline of the impact assessment process seems to be good as it will allow for a more efficient and quick assessment to be completed. The early planning stage should hopefully allow proponents the necessary time to collect information and find any potential problems that might occur during the project.
Louis about 2 years ago
I agree with the timelines in the proposed legislation could be suspended, since it will give them more time to review about the project (find whats missing on that project, what needs to be added in the project) and find a way to solve that problem.
Alyssa about 2 years ago
My views on the proposed criteria for the timelines is that they should also be suspended if an animal becomes endangered or is categorized as threatened and lives in the location of the project. Considerations must be made and the project must be re-evaluated during the stopped time to make sure that they are able to continue with the project, or shut it down altogether.
Rmorrison11 about 2 years ago
They appear to be suitable. The concern about a new issue being raised later in the process (post early engagement) and allowing the agency to stop the clock means the early engagement process is not working as it should to identify the issues of concern. Perhaps setting a specific range of potential new issues that could trigger a stop the clock is worthwhile to ensure that it is fully understood how the clock could be stopped.
Tyler about 2 years ago
If the propenonts can’t prove that they did their due diligence, can’t prove that they have a satisfaction and solid plan in place to respond to any accident that involves their assets either directly or indirectly. The track record of the propents.