Government of Canada



Submitted By: Cheryl Bronw December 21, 2016
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Review of the Environmental Assessment Process by

Cheryl Brown

As a community member of the North Western British Columbia I would like to comment on the EA process and the difficulties it has created both in participation and in consequences both environmentally and the socio economically.

Participation for the public is tokenism.

There is no meaningful way that an individuals or groups can engage. Comments can be submitted, questions asked but there is no response. In other words it is not interactive and CEAA or the proponent does not respond to questions. There needs to be a requirement and mechanism that enables interaction.

For the public engagement requirement it appears for both the CEAA and the proponents that only an open house with minimal information is the norm. The formats should be varied and this should be required. Open houses are only one form, as people also want to hear presentations and be able to ask questions. If a group asks to meet with the proponent regarding a question or concern it may or may not be granted.

The access to the CEAA registry is awkward and cumbersome without an adequate search engine. If an individual asks to be notified of new submissions it does not happen.

If an individual does not have adequate internet access the documents are often too large for access. Mailing of documents if requested by the public needs to be accommodated,

Media notification for both CEAA and the proponent is difficult to find, is often small and not easily understood. As well addendums that are significant i.e. changes, are not made public except through the registry, which is difficult to access and has to be “watched” to be aware of something “new”. Notifications should be in the papers, Internet and social media.

The ”public” in the EIS are often eliminated in the discussion of Human Health effects and socio economic issues. It is only directed to the Indigenous concerns. The discussion of these effects is universal and should not be separated or eliminated for the general public.

The public is at a disadvantage to participate due to lack of expertise and monies. A larger public funding base should be available. A portion of the proponent monies should go to funding pubic review of the EA. Funding should include the opportunities for communities/ regional districts etc to hire an individual to monitor the CEAA registry for projects and distribute to the community as often the volume is large and overwhelming.

The timing is often too tight of short for the public to react and respond. Often the notifications are posted and then only seen several days to a week after the release and it expected that an adequate response can be made within the 30days of the time of posting. This is unrealistic and is meant to ensure that public comments are limited. The time frames must be at the least 60-90 days and longer if the documents to which the comments are to be directed are large.

Environmental and Socioeconomic Impacts

Once an EA has been granted CEAA requires that to maintain the certificate a certain level of development have to be done even though a final investment decision (FID) has not been determined. As a result land is cleared and semi prepared. For example-large environmental impacts happen as result of pipeline right of ways being cleared. These have large linear impacts along with a scouring of the land to prepare it; interfering with connectivity, wetlands and the biological balance of the land base – and then it sits. Large swaths of crown land and cleared and scoured for “lay down” areas and camps. These areas sit for years and then the FID is determined not to be viable Mean while the land base has been comprised and there is no mitigation.

Speculators prepare for the advent of these proposed projects. Timber is removed, housing becomes inflated, land swaps with inflation, increase in the cost of living occur and have a profound effect on the stability of the community. It creates some economy growth but it is only a temporary boom and not sustainable as companies procrastinate for the best economic outcome. Fair enough for them but there needs to a mechanism to protect communities from the chaos and the bust that occurs. The larger the project proposed the greater the risks and speculation and impacts on communities.

As an environmental process these impacts need to be addressed as the current EA in itself is creating environmental degradation and impact.

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