Scientific integrity for environmental decision-making: A submission to Canada’s Expert Panel for reform of the Canadian Environmental Assessment ActSubmitted By: Alana Westwood December 22, 2016
This list summarises key recommendations for the Expert Panel to consider when reporting to the Minister of Environment and Climate Change regarding the Canadian Environmental Assessment Act. Further details, including suggestions for implementation, are given in the accompanying letter.
Recommendation 1: Standardize methods for integrating community and traditional knowledge throughout the project life-cycle. Traditional and community knowledge, both environmental and cultural, should be actively sought and integrated at all stages of the the decision-making process. Guidance should be given to collect and incorporate information in a standardized way to improve accountability and comparability between projects.
Recommendation 2: All proposals, interim reports, and Environmental Impact Statements should include detailed, replicable methods and open data. All scientific evidence submitted to an environmental assessment process should meet professional peer-reviewed standards. Reporting detailed methods and all data will strengthen the robustness of decisions and increase process transparency.
Recommendation 3: Provisions for peer-reviewed independent science and evidence through the establishment of either (1) a fund for stakeholders to contract environmental expertise in addition to the proponent, or (2) an independent, arms-length government body responsible for the entire impact assessment. Presently, the proponent hires contractors to prove that their project carries an acceptable level of risk. Although other stakeholders can contribute data, this is often beyond their resources. Funding communities and individuals besides the proponent, or situating impact assessments within an independent institution, will expand and strengthen the body of evidence.
Recommendation 4: Establish an independent, arms-length body for decision-making which uses transparent and consistent criteria for significant adverse effects. Transparency and accountability are paramount for the EA process to have public legitimacy. Instituting an independent regulator would limit vested interests of decision-makers in specific outcomes. Assessing similar projects using consistent criteria will likely also increase public trust.
Recommendation 5: Make follow-up reports mandatory and public, and allow the decision-making body to amend approvals and conditions based on new evidence. Projects have a long life after the assessment decision is made, and circumstances and conditions change. Mandating publically-available follow-up reports allows for longitudinal data on the health and sustainability of infrastructure and better adaptive management--particularly important in the context of cumulative effects and climate change.
Recommendation 6: Establish a comprehensive online public registry with a standardized format for all information and data concerning projects under the CEAA. A public registry of data increases the transparency of the process, and permits meta-analysis by internal evaluators, independent researchers, and journalists. This body of knowledge that can be used both to inform future assessments and to evaluate the efficacy the EA process.
Recommendation 7: Establish a program of regional or ecosystem-level assessment to evaluate impacts on environment, economy, society, and human health at multiple scales. Individual projects may carry an acceptable risk, but in combined across multiple projects it may reach unacceptable levels. Establishing a system by which regions or ecosystems are assessed as a whole for particular project-related impacts will more appropriately estimate risk factors across multiple projects.
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