From open letters to robust responses to government consultation on CEAA, Canadian scientists are organizing around the overhaul of our environmental assessment processes.
Renovating Canada's dilapidated environmental assessment system
Federal environmental assessment in Canada has been notorious in recent years for its weak ability to protect environments and communities. Changes to the Canadian Environmental Assessment Act (CEAA), enacted in 2012, were widely seen as having weakened the assessment process and reduced the scope of environmental assessments.
Yet, the environmental assessment (EA) process is critical for managing and protecting local and regional environments and communities, and needs to be robust and evidence driven. There have been thousands fewer environmental assessments since the Act was amended. Canada's scientific community at large has deeply criticized the CEAA and its processes for lack of scientific integrity.
The EA processes rely heavily on science, and scientific input. It is up to scientists to collect baseline data, generate impact predictions, anticipate risks, and design and implement monitoring programs. Much of the bulk of protecting ecosystems and human health comes down to the careful evaluation of scientific data. EA processes, falling short of acceptable standards, have spurred a number of open letters by scientists, decrying the insufficiency of scientific evidence in CEAA decisions, including the Pacific Northwest LNG Terminal (130+ signatures), the Site C Dam (200+ signatures), and the Northern Gateway Pipeline (300+ signatures). Recently, over 1,800 young researchers signed a letter calling for improved scientific integrity in Canada’s environmental assessment processes. The Liber Ero fellows, representing some of Canada’s top independent scientists, have specifically called for a stronger role for science, in a sentiment we echo: “we are concerned that current environmental assessments and regulatory decision-making processes lack scientific rigour.”
Recognizing the inherent issues with the CEAA as it is now, the federal government has undertaken an effort to overhaul the legislation, and began this process with both in-person and online consultations across Canada. In Evidence for Democracy's submission to the EA Review Panel, we gave a number of key recommendations for improving the legislation, which involve integrating robust science throughout the process. Our top suggestions are:
- Standardize methods for integrating community and traditional knowledge throughout the project life-cycle.
- All proposals, interim reports, and Environmental Impact Statements should include detailed, replicable methods and open data.
- 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.
- Establish an independent, arms-length body for decision-making which uses transparent and consistent criteria for significant adverse effects.
- 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.
- Establish a comprehensive online public registry with a standardized format for all information and data concerning projects under the CEAA.
- Establish a program of regional or ecosystem-level assessment to evaluate impacts on environment, economy, society, and human health at multiple scales.
Across the board, the Canadian scientific community and the wider public as been calling for scientific integrity and evidence-based decision-making, and we are hopeful that the Expert Panel is listening. Reworking CEAA to put transparency and scientific rigour at its centre would increase Canadians' confidence that infrastructure projects are approved on the basis of evidence, not lobbying. The national consultations have provided a solid body of evidence for the panel to consider, and we look forward to invigorated recommendations that focus on transparency, inclusion, scientific integrity, and evidence. The Expert Panel is due to report back to Environment Minister Catherine McKenna by March 31, 2017.
E4D's list of the top 5 submissions to the CEAA assessment (including contributions by members of our Network of Experts!):
BC Assembly of First Nations. Written submission for the Expert Panel review of environmental assessment processes.
Ecojustice. Federal environmental assessment for the future.
Hodgson, E., Winegardner, A., Davidson, A. Written submission to Canadian Environmental Assessment Act Review panel
West Coast Environmental Law. Preliminary submission on next generation environmental assessment.