Government of Canada


EA Review of the Process Received Oct. 12, 2016

Submitted By: Susan Michetti December 23, 2016
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To Whom It May Concern:
• Canada’s environmental assessment process is broken. We need to fix and reform and reinvent the EA process to give top priority and rigor and thoroughness to scientific thought, analysis, and assessment to solve all problems, and to label and identify as insufficient all parts of the process that are less than competent in this scientific methods way. If staff and decisionmakers cannot abide by scientific rigor, completeness, and scrutiny for the smallest details upon which safety and healthy conditions depend, then those people need to be replaced by people who do think and act in a scientific manner using scientific processes. We need reviewers and decisionmakers that seriously understand and respect all questions or concerns pertaining the quality of EA, which must start requiring the highest and best scientific methods and analyses to the point of seriously making changes to accommodate and perfect the process in this long expected way for any predominately technological detailed nuclear process and its building of physical materials to create the technological process of nuclear generation from cradle to grave.
• The safety of nuclear power depends on scientific technical perfection because an error of the narrowest magnitude can destroy humanity by destroying humanity's only habitat---planet earth--as the background radiation increases from leakages that are not supposed to happen and as the drinking water and food chain are now acquiring radiation that when consumed becomes internal radiation of much more dangerous intensity and duration than external radiation exposure from the same ionizing rays.
• We must clearly admit and identify correctly that internal emitters are much more dangerous than external emitters; and that in the past, external emitters tend to be used to assessed internal exposure inaccurately, incorrectly, as a direct violation of scientific thought and conclusions. Internal emitters must be viewed as unacceptable to wildlife and to human health.
• Those who represent the government in the case of leakages must not start their public information with a false claim of public safety but instead must be required to be trustworthy for the public to be able to assess their own individual best interests regarding health and safety by being exactingly correct as to the actual danger. As soon as anybody says the public is safe, that means that nothing forthcoming can be trusted. In turn, that lack of trust exhibited actually distances the government from the very citizens that it should be protecting as much more numerous in numbers than the individuals represented by the corporation where the leakage occurred that should be suddenly under intense public scrutiny pertaining to why sufficient scientific information in advance did not prevent that leakage in order to do nuclear the way the nuclear needs to be regulated in order to even have public safety.
• The most important reform is put scientific thought, analysis, and assessment as top priority, not politics, not corporate profits, not some other consideration.
• Following that, corporations who send in sloppy work that does not contain such materials presented with sufficient scientific methods need rules that avoid wasting time of everyone including the staff as that immediately gets returned as unacceptable insufficient information. Corporate studies must be disclosed to everyone upfront, and independent confirmation of those conclusions must occur.
• Government has too often accepted corporate statements at face value, only to find out much later that those corporate statements were not as solid as claimed initially. Fines need to be established to fit the "crime" of misinformation or disinformation that has become the trend of corporations particularly pertaining to environmental safety vs damage and to safe healthy conditions vs adverse health conditions in advantage-disadvantage assessments and promises that later turn out to be significantly erroneous and not conforming to the future reality promised after the future arrives within their plans.
• Following that, the First Nations need more respect, more inclusion from the first step in the process forward, without being excluded from the communications loop at any time.
• It must become unacceptable that safety of nuclear waste is allowed to ride as if somehow magically in the future a safe solution will be found because that is irrational and unrealistic. We've had 70 years of the best scientific nuclear physicists trying to solve the nuclear waste problem of intense danger to the survival of humanity into the future but they have been unable to find a solution because a safe solution does not exist. Admit reality, instead of hiding one's head and pretending that emperor, so to speak from the fairytale, has clothes on when the emperor clearly does not.
• Rationally, it is time to accept and act on the facts that nuclear waste is extremely dangerous and must not get into our air, food chain, and water and that requires complete stopping new generation of nuclear waste.

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