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Email to Panel "Presentation to the Expert Panel - Additional Comments" Oct 4, 2016

Submitted By: Halifax October 19, 2016
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Dear Panel Members:

I was asked about regional assessment, carbon emissions and the role of CEAA in providing standards. I wanted to provide some clarification on these two issues.

Carbon Emissions

It is appropriate for an EA to ask questions related to a projects contribution to climate change, but these need to be carefully bounded to avoid unnecessary costs. An environmental assessment document is not a vehicle for establishing policy. I referenced the Cape Breton - Commissioner's Report on the Effects of Potential Oil and Gas Exploration Offshore Cape Breton - that can be found on the CNSOPB web site. This hearing followed by ad hoc committee reports was established because two EAs in the coastal area of Cape Breton identified a lack of government policy to provide useful grounds for evaluation of impacts. Similar, with greenhouse gas emissions, policy needs to be established by federal-provincial-territorial discussions which are currently ongoing. I think understanding the problems of flaring from oil and gas operations, especially exploration offshore, provides a good example of the difficulty in writing regulations for defining emissions. The flares are a primary safety vehicle that, if all things go well, will generate very few emissions. Clearly the operation is designed to minimize emissions outside of safety requirements. It should be clear that the safety requirements, the lives of those on an offshore rig, must take precedence over an EA’s desire to identify quantities of greenhouse gas emissions. I suggest the panel might want to use this as an example. Note that a member of your secretariat has experience with flaring from oil and gas activities.

In addition, and Dr. Peter Duinker referred to it well, it is important that EAs focus on what is important to the decision maker to minimize environmental impacts associated with the project. Both mitigation and adaptation to climate change should be addressed in the EA but in ways appropriate to the process and the project or issue being reviewed. I believe it is important to understand how climate change may affect both the Valued Components but also our ability to predict outcomes over the life of the project. Seldom do we examine the environmental change in an EA, which is becoming more evident as time passes. If we look at northern projects and the strong influence of permafrost, we can see that climate change can greatly affect EAs. This is an area where research and guidance is needed.

Standards

When I referred to minimum standards I was thinking of guidance documents. The CEA Agency has produced both guidance and best practice documents. Both are needed. I was suggesting, that while the other EA authorities do not fall under CEAA, nonetheless CEAA had traditionally provided advice that was relevant to these other agencies and helped position Canada as a leader in environmental policy. I believe these roles were a important aspect of the CEA Agency, especially being able to fund applied research.

Regional EA

Again I agree with Dr. Peter Duinker that Regional EA is one of the few ways to help provide guidance in relation to cumulative impacts. It is also important to note that most jurisdictions globally do not incorporate cumulative impacts in their assessments because of the inherent difficulty in doing it consistently and to an agreed upon standard. I think that EA is not always the appropriate tool to look at regional issues and that a planning approach can be more valuable because it is a more open framework. However, the scoping stage of an EA can be largely equivalent to a planning process depending on how it’s done. I am not convinced that EA is the best tool for evaluating regional cumulative impacts because it does not sufficiently consider diverse viewpoints from the array of valued stakeholders.

I hope these comments are helpful to the panel. I hope to see a new CEA Agency that helps restore Canada to a lead role in EA globally.


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