Government of Canada


Public comment on EARP review

Submitted By: Siegfried (Ziggy) Kleinau December 23, 2016
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Dear Chair, dear Members of the Environmental Assessment Review Panel,

My name is Siegfried (Ziggy) Kleinau.
I spent almost 30 years of my life researching energy generation modes.
In 1989, together with Lynda Hoita (deceased 1998) I founded the Bruce Peninsula Environment Group (BPEG), a community-based non-profit organization in Bruce County, still holding monthly meetings in Lion's Head, Ontario.
In 1996 I founded and incorporated as a not-for-profit Ontario-based organization the Citizens For Renewable Energy (CFRE).
In 2010, due to age-related health problems of the coordinator, CFRE was amalgamated with the Ontario Clean Air Alliance (OCAA).
I am mentioning all this to refer to many years of experience participating in Environmental Assessments (EAs), mainly intervening, initially, before the Atomic Energy Control Board (AECB), and then its successor, the Canadian Nuclear Safety Commission (CNSC). Over the years I represented my organizations in all categories, from Screening EAs to Joint Review Panel EAs.
Many times I was advised that issues brought forward were 'taboo', not included or not valid.
That is why I felt compelled to explain and submit my comments and recommendations to you, dear Chair and Members of the EARP.

Many important issues have evolved over recent years:
1) Climate Change - with all its unforeseen events and extreme weather effects.
This must be a high priority point to weigh in any EA.

2) Alternatives to a planned project, not often being addressed :
example: a car ferry over a large water body instead of a bridge
a study on how to preserve existing resources to avoid creating new
Monitored above-ground fortified storage of radioactive waste instead of
high-risk, irretrievable deep underground burial

3) The Precautionary Principle (PP)!
'After all is said and done' every EA MUST BE REVISITED to prove if the proposed project , etc. is absolutely necessary.
Scientists are not prophets, they cannot predict the extreme effects of Climate Change (Did any of them foresee the effects of the long drought in BC and Alberta that led to the wildfires and near-destruction of Fort McMurray and surroundings ?).
In the Guidelines for the Joint Review Panel to assess Ontario Power Generations Environmental Impact Statement (EIS) on its proposed Deep Geological Repository (DGR) current scientific knowledge is called limited.
A strong emphasis on the Precautionary Principle adaptation was proposed.

These three Pillars should be the Foundation of an Environmental assessment approach and the basis for the new Environmental Assessment legislation !
(Remember - a 3-legged stool does not wobble !)

Thank you for accepting these comments and recommendations.
Please be kind enough to acknowledge receipt.

Respectfully submitted,

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