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Criteria-based approach

by Dillon, almost 2 years ago
CLOSED: This discussion has concluded.

Question 1: What are your views on using this criteria-based approach to guide the review of the Project List?

U.S. Environmental Protection Agency almost 2 years ago
• The U.S. EPA concurs that projects that could result in changes to the environment outside of Canada be included on the list of projects subject to federal impact assessment (page 4 of the Consultation Paper, Federal Jurisdiction for the Purposes of Reviewing the Project List). EPA previously expressed this view in our comments on the Expert Panel Report, Building Common Ground A New Vision for Impact Assessment in Canada, 2017 (May 24, 2017 letter from Jane Nishida, Acting Assistant Administrator Office of International and Tribal Affairs, EPA, to Honorable Catherine McKenna, Minister of Environment and Climate Change Canada).• The Consultation Paper describes environmental objectives and standards that would be applied that could influence the type of projects considered for the Project List. One of the environmental objectives is “Potential for transboundary air emissions in another province or the United States”. We continue to concur and agree that any projects with potential impacts outside of Canada be included on the Project List. We also agree that projects with the potential for transboundary air emissions in the United States be included on the Project List and we recommend that projects with the potential for transboundary watershed impacts also be included on the Project List. This recommendation was also made previously in our comments on the Expert Panel Report included in the above-referenced letter from Jane Nishida.• The Consultation Paper proposes factors and environmentally-based thresholds that may influence projects that would be included on the Project List. For example, projects with the potential for lower adverse environmental impacts might not be retained on the Project List. In the U.S., environmental documentation includes information analyzing and disclosing the project’s direct, indirect, and/or cumulative impacts. Therefore, we recommend considering cumulative impacts from multiple projects in the same or similar geographic areas as potential criteria for retaining a project on the Project List. • If the environmentally-based threshold approach for retaining projects on the Project List is carried forward, we recommend that more information be provided on how the frequency factor will be incorporated in the process to screen out projects based on impacts that may be rated as low frequency but could have high environmental consequences (e.g., mine tailings dam failure).
Robert Crosbie almost 2 years ago
Generally have no issue with Criteria based project list however the criteria are not clear and seem to be subject to political influence rather than a strict set of guidelines that should allow investors and the public to understand what should be included. Could not see where previous history of environmentally safe operations that are tightly regulated now will not be subjected to more costly , agenda driven reviews aimed at derailing investments.
Allan Webster NWMO almost 2 years ago
NWMO supports the criteria based approach to a review of the Project List. The criteria will add clarity on why some activities are on the list and others are not. NWMO anticipates that its project will be included on the list and welcomes the opportunity to show Canadians the Adaptive Phased Management approach has resulted in a safe repository location that has local municipal and indigenous community support.NWMO suggests one improvement that can be made to the Project List. NWMO submits that the list should be limited to construction or expansion and remove the language of operation or decommissioning. The effects of operation and decommissioning are included in the scope of the impact assessment undertaken prior to construction or expansion and should not require a second or third impact assessment. NWMO suggests that the scope of the assessment does not need to be repeated in the listing of which projects require an impact assessment. The current language can be enhanced to improve clarity in this respect.
The OGM almost 2 years ago
The Language in this whole process is overwhelming and complicated.Things need to be simplified - use video.In terms of a project list - one size does NOT fit all. We have many considerations and we should be trying to understand variables and conditions with ultimate impact. But even then, there is no one size fit's all solution because at the end of the day, every situation has a different set of variables to consider. Offshore oil does not equal on land drilling for example.A project list for everyone is like trying to have a list of house rules for all your kids, regardless of their age, progress, accomplishments, or capabilities. Life doesn't work that way.Having one project list gives certainty in terms of compliance to environmental concerns which is great, however that list cannot and should not negatively impact the progress of industries like oil and gas which are essential to our way of life - ie taxes for health care. When you consider that oil and gas industries are THE MOST environmentally compliant over all other industry sectors - you begin to realize it's a seriously expensive business and those who make the most money can afford to be environmentally compliant. The moment you start putting in unnecessary protocols from a cookie cutter project list we will be in serious trouble. We are already in trouble with lost revenue from the price of oil and it's spin off activity nation wide. We can't take another blow in terms of oil and gas jobs or oil and gas businesses.We have to be 'world leaders' in making things WORK. We can't afford to put our own obstacles in our own way. We need to be creative and solution oriented. Educate people in simple language and use tools that work like video. We must ensure that Canada is a seriously attractive place to INVEST, above all other regions in the world, or we will lose our current foothold as #3 oil producing nation in the world. Right now oil and gas is the foundation of the economy. And it's only FUELS from oil that will bring in new energy. Can't have one without the other. So we simply can't interfere with our oil and gas progress. The oil and gas industry is powerfully compliant in terms of safety and the environment ALREADY. We can't mess with that!
GHickey almost 2 years ago
Offshore oil and gas projects already have a process that is managed quite well historically between the Federal Government and the Provinces. Environmental assessment has always been problematic in the sense that it gives the impression that the environmental assessment process is about measuring a project against something when there are no actual substantive rules or regulations or standards of any kind in the statutes.
tgray almost 2 years ago
The purpose of this paper (p.1) "is to seek views on the proposed criteria to revising the Project List". I have read this paper three times now, trying to decipher what, exactly, these criteria are. As best I can figure, there is a lot of "may consider" language, but the actual criteria are the five bullets at the bottom of page 5, and one paragraph one page 7:1. A project type may be added / retained on the Project List if one or more applies:a) potential for effects on federal environmental jurisdiction to be medium to high (Annex B)b) Project type effects are complex and may require a complex set of mitigation measures;c) the project type is novel and the severity of effects or mitigations are unknown.2. A project type may be removed or not added to the Project List if:a) there is potential for such effects to be low; orb) There are standard mitigation measures for the effects identified that are always adopted as a matter of practice, are subject to stringent regulatory requirements and have proven to be effective in mitigating the effects.3. The Government may also consider specific project types or location-based entries that may merit consideration on the Project List due to location in, or within the potential to cause effects on an area of environment importance. For example, this could include some projects in federally protected areas. Consider criteria 1(a) or 2(a). These conclusions on low/medium/high effects are based on the application of a class-based impact assessment using typical EA jargon (“the factors” – magnitude, geographic extent, timing, frequency, duration, & reversibility). Five of these six factors could individually be given a ranking of low to high, though that itself is value-laden. Nowhere in the discussion paper, including Annex 2, is methodology given to integrate these factors into a single ranking of low to medium to high “effect”. What aspect of the effect are you referring to here?I also have serious doubts about the ability for Canada to conduct entire class-based assessment for project types in a country this large and diverse. This approach for criteria 1(a) and 2(a) implies that data and human resources will be available to assess things like magnitude, timing, duration, frequency, etc. with high confidence, in a way that is representative for the entire country. The paper spends time discussing environmental objectives and standards (p. 4 and 5). I believe the intent of this discussion is to provide some context to how the effect characterization using the factors will be interpreted. However that is not explicitly stated and I could be wrong (if so, I am totally confused about the intent of that section). If environmental objectives are used as a reference point for characterizing effects, that has a place in this process but must not be overly relied upon. Doing so puts all the focus on the effect pathways with the easiest interpretation. While this is helpful for unambiguous definition of significance, it ignores more complex socioeconomic impact pathways, such as rights-based assessments that must consider Indigenous culture. This focus on measurable transparency and significance also overlooks the value of an IA as a planning tool (not a significance-determination machine), which is supposed to be one of the new policy directions of the new Act. EAs (or IAs) don’t need to have all the measurable answers to have value. Identifying impact pathways, even for things that are not measurable, can help define mitigation and monitoring needs, and gives a much more comprehensive view of positive vs. adverse impacts for project decision making.Also very unclear is how any of these criteria apply to projects with potential to impact the environment on federal lands. I am thinking most specifically here about reserve lands. This circumstance is much different than the other areas of federal environmental jurisdiction, where the VC is pre-defined (e.g. fish, migratory birds, species at risk). How would a project type be evaluated here, where the word “environment” is necessarily broader than just biophysical considerations and must account for social, economic, and cultural factors? So rather than one VC like “migratory birds”, project types need to be evaluated for their possible effects on a broad suite of complicated VCs. I do not believe this can be done for any “project type” in a way that is representative of all reserve lands in Canada.Further to the topic of reserve lands, I urge Canada to consider projects (project types) that are not located on reserves, but will impact the environment (broad definition) on reserves. Things like noise, traffic, viewscape, accessibility… as a country we seem very amenable to allowing large industrial projects to be built next door to reserves, when they would never be allowed next to non-reserve communities. It impacts the human environment on-reserve greatly – certainly including possible impacts on aboriginal rights - and we need to be doing better. Criteria 1(b) and 2(b) are flip sides of the same coin. I’m sure some credible examples for 2(b) could be provided in which case I think it is sensible to omit the IA and skip to conclusions and permit conditions, but I think the vast majority of project types, and individual projects, fall under 1(b). I feel there is a critical misunderstanding amongst EA decision makers about the effectiveness of mitigation measures. Implementation error (or outright omission) is *rampant*. Consequently, project types with “complex effects and complex mitigation measures” are the norm.I struggle with criterion 1(c) since the Project List can likely never keep pace with novel, unknown project types. By the time something makes its way into the Project List because of this criterion, it probably no longer fits the criterion.Criterion 3 is a sensible starting point but I feel generous defining it as a criterion at all. This paper was supposed to present the criteria that would be used to re-evaluate the Project List. Location-based context is, in my view, something that needs stronger, mandatory criteria in this investigation – not something “the government may consider”. The back half of the discussion paper (particularly Annex A) mentions that even for project types that are excluded from the Project List, individual projects may be designated for review by the Minister of ECC “if, in the Minister’s opinion, the physical activity may cause adverse environmental, health, social, or economic effects on areas of federal jurisdiction […] When making this determination, the Minister would take into account the impact that the project may have on the rights of the Indigenous Peoples of Canada and the results of any regional and strategic assessments”. This quote is the only place in the paper where effect pathways on health, social, economic, and aboriginal rights aspects of the environment are mentioned. Why are these omitted elsewhere? More importantly, experience has shown us that projects require rather extraordinary circumstances to be forced into provincial or federal assessments by way of Ministerial order. It is must easier to exempt projects that, upon triage review, are benign, than it is to pull in projects that at the 11th hour seem more harmful than initially expected. Seeing as how “transparency and clear criteria will be central in the development of the Project List”, I strongly urge Canada to take this entire paper back to the drawing board and to re-think the approach for revising the Project List. It is worth taking the time to get it right, where it can withstand evolving government policies and new governments altogether.Transparency and clear criteria would be more sensibly arrived at by adding to the Project List *any* undertaking with the potential to interact with aspects of the environment under federal jurisdiction. This is clear and transparent, and in reality is only an expansion of the current situation with s. 67 of CEAA, 2012. Then, any individual project would be subject to triage by a much-expanded Agency to determine if it should be waived, or assessed under one of three of four levels of assessment rigour.
Canadian Airports Council almost 2 years ago
The Canadian Airports Council (CAC) appreciates the opportunity to provide comments for the consultations occurring on the proposed new Impact Assessment System. The CAC has 53 members representing more than 100 airports, including all privately-operated National Airports System (NAS). While the intent of the new requirements appears to improve consistency and consideration of a broad range of environmental and community issues during project reviews, Canada’s airports find “project” in Section 81 defined too broadly. We also find “traditional knowledge” and “community knowledge” in Section 84 to be ambiguous and not clearly defined.Canada’s airports also have concerns with Section 86, due to the broad definition of a “project.” Section 86 states that airport authorities must post a notice on the new agency’s website on its intended determination, and if appropriate, invite the public to provide comments respecting that determination. As currently written, airport authorities could be required to post information on many small projects that have little or no environmental risks. Airports supported the language in Section 88 before it was amended in the House of Commons Standing Committee on Environment and Sustainable Development, which enabled authorities to develop their own class of projects which may serve as an exclusion list to reduce the need to assess low risk projects. Airports support the concept of individual authorities maintaining decision-making powers in regards to routine projects.Recommendations for the Designated Projects RegulationsCanada’s airports understand that the Regulations Designating Physical Activities, also known as the Project List, will identify projects that would be subject to the Impact Assessment Act.Canada’s airports recommend maintaining the current threshold for a designated project at an airport as defined by CEAA 2012 and the existing Regulations Designating Physical Activities. In particular, the list should be limited to the construction of an all-season runway with a length of 1500 metres or more, the extension of an existing all season runway by 1500 metres or more or the construction, decommissioning or abandonment of an aerodrome. Canada’s airports also recommend that airport authorities only post public notices of designated projects as defined above.
Laura Sacks almost 2 years ago
All projects should be included, with no exemptions. There is a huge urgency to reduce our GHG emissions, and every project needs to be looked at through this lens -- including in situ oil sands projects, which can emit significant amounts of GHGs. Similarly fracking operations also emit huge amounts of methane, a potent GHG, and should not be exempted. The argument about Alberta having a hard cap is not really relevant, as the cap includes a 40% increase in oil production at time when we need to be ramping down production. Studies suggest that Alberta may exceed that cap by 2030, and who knows if future governments will ignore the cap. Let's do what is right and have this fair for everyone.
Judy O’Leary almost 2 years ago
I agree with the previous comments and strongly oppose exempting in situ oil sands projects. These will comprise the majority of future projects and will have significant environmental impacts. Relying on a provincial emissions cap is totally insufficient. I am also concerned that the project list appears to exempt fracking projects. As these operations are expected to expand significantly in B.C. and Alberta, this does not make sense especially as methane(84 times more potent than C02 as a greenhouse gas during the first, critical 20 years) emissions will be massive, not to mention impacts on of fracking on groundwater.
Citizen's Climate Lobby, Nelson West Kootenay chapter almost 2 years ago
At first glance it appears the ‘criteria based approach to revising the project list is OK. In fact there are several changes to the old system that are good improvements. In particular we appreciate that:• Consideration will be given to environmental objectives and standards including the Pan Canadian Framework.• There will be cooperation and coordination with other jurisdictions in order to achieve the goal of ‘one project one review’.• That there will be alternate avenues to trigger a federal impact assessment [ie the Minister of Environment and Climate Change can decide, for good reason, to put a project on the ‘list’]• The determination of the public interest will be guided by several criteria including the ability to meet environmental obligations and climate change commitments.However we have several concerns.1. Exemptions. We understand there maybe situations that warrant an exemption from federal impact assessments. However we strongly disagree with exempting in-situ oil sands projects where a jurisdiction has in place a hard cap on GHG emissions because:a. We do not know of any credible analysis that indicates the hard cap will be held. In fact the Canadian Energy Research Institute estimates the 100 Mt cap on oil sands emissions in Alberta will be exceeded by 2030 [ ] .b. The recent past has shown caps and targets can be very fluid and tenuous. Governments can and do change, ignore or eliminate targets or caps. We see that ‘in-situ oil sands projects’ were used as an example. We would also disagree with exempting other projects with significant GHG emission potential and “hard caps” [eg new oil sands mines or fracking] for similar reasons2. Best practices. The consultation paper suggests [pg 5] if proponents adopt ‘best available practices and technologies’, a federal impact assessment may not be required. In considering this pathway, we trust that other factors be considered including:a. Will the best practices fully mitigate the anticipated adverse effects?b. Does the proponent have a good track record in adopting best practices and does the proponent update these best practices as soon as new information becomes available?3. Meanings/definitions/ambiguity. In several places there are words or concepts that are unclear or ambiguous. For example:a. Consideration. On page 4 the paper says ‘consideration will be given to environmental objectives and standards….’. We are concerned that the consideration will be superficial and would like to ensure the ‘criteria based approach’ gives SERIOUS consideration to environmental objectives and standards.b. Factors. On page 5 under the ‘Determination’ section the paper says a federal impact assessment is required if the effects are medium [moderate?] to high. The detailed descriptions in Annex B do not do a good job of defining low, moderate and high. There are a few instances where high is adequately defined ’ but there is little guidance on moderate and low, particularly what separates low from medium or moderate?4. Cumulative effects. The consultation paper says “considering activities proposed in areas subject to significant cumulative effects is essential” but there is very little detail on what this means. What triggers a cumulative effects analysis? Who does it? How does it affect the list of projects requiring a federal impact assessment? Can this issue be included in the “strategic assessment of climate change which will lay out how climate change considerations would be integrated in the impact assessment process”?
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.
Marylee Banyard almost 2 years ago
In situ oilsands projects should not be exempted from Federal assessments. Alberta already has a hardcap, but there are many exemptions and these could be changed by a change in government.In situ mining has a 60% higher ghg emission than mining, and significant land disturbance.Where is the Project List for Bill G69?In situ sands should not be exempted. Federal assessment is necessary
Clare almost 2 years ago
Let's treat the activities of the IFAW and other international animal welfare groups as a "project" with socio-economic impacts that need to be assessed.Currently the Fisheries Act is used to manage these impacts, with a licensing scheme for IFAW and other observers who wish to approach within 10 meters of the hunting activity. While that does something to help regulate observer behaviour (you can refuse a license to someone who intends to disrupt the hunt), it has been of limited effectiveness in reigning in the aggressive tactics of the IFAW and the Sea Sheppard Society. Their primary objective is to disrupt the hunt regardless of what they might write in their observer application. This International group of bullies denigrates us to the world annually. They arrive annually , approach within meters of the hunting activity, and subject the sealers to photo-documentation scrutiny which is later edited, taken out of context, and used as evidence of the supposed cruelty of the hunt, An ethics battle has waged on seals for decades, reaching a climax in 2009 with the success of the animal welfare / animal rights groups campaigning effort in Europe and the resulting restrictions / ban on the import of seal products to Europe. Together with US, Mexico, and elsewhere, markets have closed and the sealing industry has become marginalized.Yet despite the doom and gloom there are bright spots. There is a National Seal Product Day endorsed by Parliament. Chefs are making waves with seal meat in Canada. Sealers have emerged from decades of scrutiny on their killing techniques with an internationally recognized humane killing process. It can be said that our Canadian humane hunting practices are the "gold standard".It is time to stop the exploitation. In decades past, there may have been some value in the scrutiny. These hunts in good years are taking hundreds of thousands of animals, the largest wild hunt on earth. So standards need to be high, and the world needs to be assured of the humaneness of the hunt. But whatever value there may have been in making sealers and the seal hunt a public spectacle is no longer worth the harm this negative attention causes. Today’s hunting represents a small but critical activity for sealer / fish harvesters at a time of year when other marine resource activities are not available. In fact, most other marine resources are in a state of decline while seal populations are burgeoning. Communities are struggling to remain viable, tensions are high, and sealers have a right to take seals for food, clothing, and what little they can still make off the few pelts the buyers will accept. Despite this greatly reduced economic activity, animal rights activists continue endangering sealers with their tactics, “buzzing” them with their helicopters and cracking the ice about sealers’ feet with their steel hulled vessels. While they state they do this to get the best photos, they are really doing it to scare the seals off the ice, and to disrupt the hunt. It is completely irresponsible to harass men on the ice, or in small boats with high powered rifles, in such a fashion. The sea ice is an unforgiving environment and someone could get hurt.Why use a piece of fisheries legislation to try and tackle a socio-economic problem. Instead, we need to realize that the IFAW triggers the new Impact Assessment Act. They are profiting in the tens of millions of dollars off of a federally managed resource. Why is there no expectation that some modest portion of this money be fed back into the coastal communities who rely of those marine resources? A group like the IFAW have close to 2 million members and have generated over 97 million USD annually. There are other international animal welfare groups, this is only one of them. There are approximately 500 thousand people in NL and about 11,000 registered sealers, plus a smaller number of Quebecers and Maritime sealers. The odds are greatly stacked and not in our favour. Efforts by the IFAW to harass sealers should not continue to be legitimized by a federal license. It is an abhorrent affront to just about every Newfoundlander. The privilege the IFAW has enjoyed needs to be reviewed under the Impact Assessment Act and either discontinued or severely restricted while at the same time heavily monitized to channel funds back to the communities they are killing.
Star-Ting Incorporated almost 2 years ago
Criteria-based approach falsely assumes the government will consider and fully assess the entire spectrum of project impacts. To undertake a project impact assessment properly one requires criterion that does not align equally on every project. Engineers in one capacity will require criterion that will contradict prioritization of another project. Impact analyses are not identical. Utilizing an inflexible guide is to misunderstand the changing underpinning risk elements that unequally apply to every project. Mistakenly, the Government of Canada assumes that one approach fits all projects. It does not. Change is constant which means that the criteria will change in a fluid and dynamic way. Government representation will not be able to significantly update the criteria to industry's technological advancements appropriately. The education system is proof of this where modules of training and curriculum is not as progressive as the needs of industry. Similarly, the criteria will remain regressive as government requires consultation to update and change its criteria-based requirements. The time involved to update the guidelines/requirements will create another risk for industry's projects where leading not just lagging risk indicators are required. Additionally, the focus area is on adverse environmental impacts which is only a segment of a full impact analyses. Projects are subject to safety, regulatory, political, social and many other risks. So, if the government of Canada assumes the role of providing One and Only one project impact assessment the government of Canada exposes additional vulnerabilities on the project, its owner, sponsor and other stakeholders who will ask why were the other assessment factors missing? The goal of "one project one review" is dysfunctional. The eyes of an independent body without a hidden agenda adds to the robustness of the assessment. This consideration of an external expert is missed. When a project fails or worse, should a project bear a serious liability, who will be at fault? Obviously, the Canadian government because it did not remain at an arm's length and sanctioned the project, another unnecessary exposure. The role of government is not to be all things to all people, nor is the role of government to provide the services for all companies in Canada. Already, companies like Star-Ting Incorporated exist to provide specialized services. Star-Ting Incorporated has attained accreditation by the Global Risk Management Institute, the Society of Risk Management. The proposal that the only entity who would conduct impact assessments would be a single federal Agency is a direct attack against small business and other corporations who are equally competent to provide project impact assessments. The fact the Canadian government would lead ALL impact assessments for major projects is not necessary, inefficient and shows that the Canadian government does not want small business growth in Canada. Instead by the Canadian government undertaking all impact assessments it provides a serious threat to the operational aspects of businesses like Star-Ting Incorporated. Under the proposal, the Canadian Environmental Assessment Agency would become the Impact Assessment Agency of Canada and be responsible for leading all assessments and coordinating Crown consultations for all federally designated projects. What right does the Canadian government have, to operate and function in the risk management business and step away from its jurisdiction? Putting companies out of business is not a legitimate act of government. Should this proposal go through, then companies like Star-Ting Incorporated who is licensed, accredited and specializes in "Responsible Risk Management®” will not be able to provide service to major projects. This is unfair, unreasonable and an unfair competitive disadvantage to its founders, a woman and retired military Master Warrants Officer who served the Canadian government for 25 years.
Paul Greg almost 2 years ago
Yes a criteria based approach is good if you can make the criteria clear and understandable. Also, some small projects can have a large impact. Need to include pipelines that do not cross provincial or federal boundaries, e.g. 400km Grand Rapids pipeline that went through caribou CH did not undergo a federal NEB review. Same for several 400km powerlines. List needs to include Steam Assisted Gravity Drainage projects that affect caribou critical habitat. Need to include SARA as an area of federal responsibility. Green projects are not always green: windfarms can have more than 200 turbines and cover a township of land and can kill many listed bats and induce avoidance by species, and need to be included. Solar power is new and not well regulated and can occur on native prairie and needs to be included until the industry is better regulated (should occur only on marginal lands...e.g. ditches, utility corridors.
David Day almost 2 years ago
I support a consistent, reliable approach that make it easy for the public and for Canadian Business / Industry to understand the type(s) of review processes that development proposals must undergo, including environmental review. I don't support processes that change with the party in power, as seems to be the case in Canada, and which is serioulsy underming business confidence and investment. As we gain experience with the effectiveness of review, our process should become more simple, more stable and well-attuned to the expectations of the public and Canadian business / industry.
Ozzy almost 2 years ago
This is a good approach and is helpful in selecting projects
Caitlin Barber almost 2 years ago
I believe that a criteria based approach is an effective way of determining if a project quality’s for an environmental assessment and defining the severity of the impact. While some large projects have obvious impacts to a greater area it is important to ensure that smaller projects which may also be causing adverse impacts are not overlooked. Smaller projects may be located on more ecologically sensitive areas or be adding on impacts to a already heavily burdened system.
Carlie almost 2 years ago
I think it is a great idea for using criteria-based approach, especially with the consideration of type and location of project. The reason is some project may not have much effect on land. However, when it is closed to river/ stream, it may have higher potential to contaminate the water and lead to adverse effect to aquatic ecosystem.
Daniel Akpabio almost 2 years ago
I think the criteria based approach gives priority to project that may cause greater impact to the environment. It is also effective because it would solicit public issues on already existing project list, which would give greater insight on similar projects.
Kristyn almost 2 years ago
I think the criteria-based approach makes sense as it looks at the project as a whole to determine its impacts initially triggering the need for an Environmental Assessment.
Rachel Dyck almost 2 years ago
The criteria-based approach appears to be the best option in terms of making sure that each effect of a project is being equally considered. Despite the size of a project it usually has some level of impact on either the environment, economy, health or society therefore it's important that sufficient information is being provided regarding each of these factors. This approach will also help to eliminate any bias that can affect which projects get exempt from Environmental Assessments and which ones go through the process.
Andrea almost 2 years ago
I believe that a criteria-based approach (in reviewing the magnitude, geographic extent, timing, frequency, duration, and reversibility factors) is a critical step when evaluating the potential effects of projects, specifically in cases where Species At Risk are involved. As seen in the past, the proponent often does not provide enough sufficient information in regards to potential environmental and health effects. For example, in the Trans Mountain Expansion project, the proponent failed to consider many environmental and human-health hazards, such as the effects of a POTENTIAL oil spill on indigenous peoples, different organisms and ecologically-sensitive areas. Potential impacts were not considered for ALL areas/locations of the project. Even though some of the environmental effects had a low probability, the consequences of the potential effects are high, and having these new, clear and transparent criteria to evaluate a future project will be beneficial in insuring that fewer impacts be over-looked.
Jeremiah Kevin almost 2 years ago
In my opinion this is a good method to determine a potential for adverse effects in a smaller scale.
MQ L. almost 2 years ago
I admit criteria-based approach can achieve a comprehensive and clear scoping process, especially for some smaller projects which were neglected to be reviewed.
Jack T. almost 2 years ago
In step 3 of the project list in the criteria-based approach is listed very clearly and is understandable. Although, for the factors of environmental effects, with the magnitude and geographic extent, will this be including the migration and territory patterns of species that may be impacted? As well, will this be covering top-bottom and bottom-up trophic level adverse impacts that may be made? Such as, if one species is to have adverse impacts made to it by a project, this may cause a chain reaction to make a negative impact to another species, but if not studied properly, may appear as though the project was not the source of the impact. The criteria based approach appears vague and should have the option to add in other factors that may be discovered throughout the process.
Brett almost 2 years ago
The criteria-based approach seems like a beneficial revision for evaluating projects to determine if they require a federal impact assessment or not. The consideration of all potential effects including environmental, social, health, and economic is a great way for determining the full range of effects as opposed to just the environmental effects. Projects with the potential for smaller effects in areas of federal jurisdiction continue to be subject to other federal regulatory processes. This is beneficial as it helps to prevent the Impact Assessment Agency from having to do impact assessments for smaller projects so that they can focus more on larger projects where the adverse effects are more significant. The Minister of Environment and Climate Change may also designate a project for an impact assessment if the Minister feels that the project may cause adverse effects based on the criteria set out in the Impact Assessment Act. This is beneficial as if a project is not captured by the Project List but has the potential for adverse effects, the Minister may designate that project to undergo an impact assessment.
Stephen Young almost 2 years ago
According to me, the methods and approaches that would be used in reviewing the Project List have been clearly well-explained and transparently defined in giving good understanding to everybody. Moreover, it has also been well-stated that the new Impact Assessment Act would take into account a whole range of factors when regarding the Project List; such as the public responses on sustainability, adverse effects that they consider would be threatening them, ways to mitigate those adverse effects, the rights of Indigenous communities, effects of a project on Indigenous communities, and Canada’s duties on the environmental thresholds and the considerations for climate change which is a completely new strategy. Hence, the goal of “one project, one review”. All of these considerations would be more advantageous and more efficient when reviewing the Project List as compared to the CEEA 2012, which was less broad in terms of the environmental considerations. Also, as clearly stated that projects with smaller effects would also be taken into consideration to be reviewed, this leads to less unsafe decisions and less biases in allowing such projects with minimum effects to take place, as previously undertaken by CEAA 2012, smaller projects were neglected to be reviewed. However, concerning the consideration for climate change; how and what types of strategic assessments would be used in this evaluation? More detailed information on this subject could be given.
Patricia Rogerson about 2 years ago
When identifying projects the size must include the life cycle of the project, to include in mining, for example, the mining, the milling, the smelting and the transporting. The criteria are then based and assessed on the whole environmental impact. This allows the assessors of a project to interrupt/stop a project that is not mitigable before any portion of the project is approved. This is an important concept when considering regional effects.
Savini about 2 years ago
I think the criteria based approach is the best approach so far because it allows for efficency and creates a larger scope, whereas before smaller projects were often neglected in past legislature. This set up also reduces biases and therefore allows for more consistency.
Drew about 2 years ago
I believe the criteria-based approach is the best option. Having one Agency, the Impact Assessment Agency, will allow for a more universal, equal and unbiased review of designated projects. Having the Agency focus only on the larger projects will likely be more efficient and provide a better assessment of potential positive or negative environmental, social, and economic impacts while the Canadian Energy Regulator can focus on all small projects that may cause potential smaller impacts.
Louis about 2 years ago
I agree with this approach, and I feel like this would be likely to be the best approach.Why? because before this new act, the CEAA2012 only focus on the higher risk project and ignoring the small environmental impact, lets say for example in fisheries act before it is only cover and care about commerical fisheries and the new act covers all the fishes and all fish habitats (which is good). We should always pay attention to small things because every big things start from small things and in this case its the environmental effect (we should pay attention even though it only causes small environmental effect). I also suggest the government should pay more attention and review the import of oil and gas and its impact on the environment, since the new act doesnt really touch on that.
Adam about 2 years ago
I agree with the criteria based approach but there needs to be a specific area that cannot be left up to interpretation. These areas need more clarity in their decision making abilities in order to have a holistic approach of all races, genders, ages etc, not just in favour of companies and decision makers. Also if a project list is minimal in its description of environmental, social and economic effects, criteria-based approaches will be uninformed thus more likely to make poor decisions. More unity of the decision board such as an encompassing group will eliminate confusion of decision outcomes and can help in the efficiency of Impact assessments.
Bruce Greenfield about 2 years ago
There will be areas where this historical approach to project lists falls short. An example here in Alberta is development of unconventional oil and gas resources that utilize horizontal fracking technology. These developments are undertaken by multiple industry developers and each development has been and will likely continue to be too small individually to trigger any IA requirements. Associated with this is a lack of clarity or coordination of environmental monitoring. I recommend that there needs to be a shift in approach in that the provincial government wanting a resource developed can be viewed as the proponent. Development of that resource could be subject to strategic and regional assessments. This could have benefits in terms of relieving the need for industrial proponents to undertake cumulative effects assessment, and would drive regionally coordinated monitoring guided by policy outcomes.
Alyssa about 2 years ago
I believe that it is a positive idea that the adverse effects will be considered based on the extent of the effect and that the appropriate measures would be used to deal with the problem. It is also good that the project with smaller effects are still monitored because there is always a chance that the environment will change, causing the effects to change as well. The criteria-based approach appears to be a good solution, with information clearly found within it.
Desiree Langenfeld about 2 years ago
The proposed changes to the project list broaden the scope of projects that will be assessed. I agree that all projects on the project list should be reviewed by the Impact Assessment Agency, this will eliminate biases of other regulators and provide more consistency in the review process.
Andrew McLeod about 2 years ago
The criteria based approach allows for a more efficient way to process the information while going through properties of a specific project. The incentives to modify effect thresholds for specific types of projects is a wise move. Many environmental effects are still being studied and are not well understood, this gives the legislation some room to adapt.
Dagney about 2 years ago
I believe that the criteria could be stricter and more encompassing of a variety of projects. As a first step it is good though but I would want to make sure that these criteria are being applied properly and being closely monitored so that they are properly followed
Elizabeth Latta about 2 years ago
The criteria based approach is okay IF the criteria are the most up to date and scientific available. Where there has been no definitive understanding of the impact of possible ‘accidents’ the project should not proceed until this researched answer has been adequately demonstrated in both public and scientific presentations. e.g. what happens to diluted bitumen when it is spilled on salt water, fresh water and a mixture of the two, especially when in conjunction with river outflows and tidal impacts.
Bonita Poulin about 2 years ago
A review should also be required any time ownership of these identified items changes to a foreign entity. Foreigners from countries with poor environmental regulations may not take our regulations seriously and damage could be done before it becomes obvious.
Imports should follow same process about 2 years ago
Imports into Canada from other countries can have a global impact on the worlds environment and health and safety. Other countries do not operate as cleanly and safely as Canada. When deciding which projects go ahead we need to consider this as well. Why is the government not reviewing the import of oil and gas as well and it's impact on the Canadian economy as well as on the overall world environment and health and safety of it workers before allowing imports into Canada? Our focus needs to consider the world environment and the competitiveness and cost to Canadians in terms of jobs and the environment overall of these imports. The new act recommends no review of imports ignoring this important part of the equation and there are huge impacts on Canada competing on the world stage and worsening the environment overall.
Rmorrison11 about 2 years ago
Agree that this is likely the best approach. During each subsequent list review, the list should be informed by the latest science and if projects currently on the list are found to not cause significant adverse effects then they should be delisted and projects previously delisted that are subsequently found to cause significant adverse effects should be relisted.
Tyler about 2 years ago
I believe it is okay but for pipelines the company should be required to prove to all levels of government as well as the public on how they be able to clean up any spills from pipelines that leak before being allowed to build on.