Government of Canada


Comments on Environmental Assessments in Canada Received Dec. 17, 2016

Submitted By: Brian Pinch December 28, 2016
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I am now 63 and retired. In my 20's and early 30's I worked on E.A.s for the BC Government and ultimately was a senior coordinator reviewing the E.A.s of some very large projects. Subsequently I worked in the financial industry and saw the corporate viewpoint even as I remained active in environmental group. In short, I have been an informed observer and participant in E.A.s in Canada for a very long time.

It is easy to see the big flaws in our current system. It is not so easy to fix them. largely because to do so would require very large breaks with the current way we do business.

A key problem is projects are reviewed on a "one of" basis, which means that there is no larger perspective. For example, consider the Petronas LNG proposal in BC. Possibly there should be an LNG project but very few experts would say that Petronas has the most environmentally sound port site. But it is "their project", i.e. they have the land, so that is the way it is. A better E.A. process would somehow look at the bigger question of what is the best pipeline corridor and what is the best port site. Even then, the project might not be approvable but at least it would focus attention on the most intelligent configurations, not just the one submitted. Similarly, does it really make sense to have a major oil port in burnaby just because that's where Kinder Morgan would like it? (Note that the pipeline was originally built there just to supply local refineries}.

I suggest you look at the final report of the West Coast Oil Ports Inquiry, done by Andrew Thompson in the 1970s, which looked simultaneously at an array of pipeline proposals through BC to move Alaskan oil to the U.S. midwest. Maybe this shows a better way. (It is also a marvellous testament to the limitations of human analysis. The overwhelming view at the time it that one of the pipelines being proposed (or a U.S. alternative) HAD TO BE BUILT because Alaskan oil was coming on stream, could not be exported and was only needed in the U.S. midwest. By the time the oil was flowing, it was all absorbed by refineries on the west coast!)

Another problem is that no project can be looked at just by itself when it has larger implications. Taking the Petronas project again, the pipeline is a minor environmental issue versus the tens of thousands of incremental gas wells that need to be drilled and fracked to supply it. Another example is the Kinder Morgan project. Perhaps the key issue with it is that it will facilitate expansion of the oil sands which seems, on the face of it, to make it virtually impossible for Canada to meet its climate change objectives.

Another problem is that E.A.s should never be reviewed through a technocratic organization such as the National Energy Board. The NEB exists to approve and regulate pipelines and ports and will always find that environmental objections can be mitigated. Naturally this will be with stringent conditions but I cannot help but observe that these "stringent conditions" often fail later on.

To sum up, E.A.s should be:
• A neutral body that is focused on just the environmental implications.
• The body must somehow be able to consider the broader question of alternative projects and/or project configurations. For example, maybe the Petronas LNG project has manageable environmental impacts but should not be approved because another port site is far preferable.
• Crucially, the full impact of the project must be looked at, including upstream impact, climate change, etc.
• There must also be consideration of cumulative impacts. Five projects might each be approvable in their own right but the overall impact of building them might be catastrophic.
Perhaps there needs to be more than one kind of E.A. One would look at big questions such as how much development an area can stand and how it could best be done. A second level of assessment could be on individual projects with a focus on how best to build them and mitigation.

I suggest that you reflect carefully on the Report from the Ministerial Panel for the Trans Mountain Expansion Project (Nov 1, 2016) as it bares on many of these issues.
Yours truly,
Brian Pinch

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