Improving B.C.’s Environmental Assessment Process

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RE: Call for input on BC’s Environmental Assessment process

To Whom it May Concern:

Watershed Watch Salmon Society strongly endorses the recommendations put forward in Mark Haddock’s 2010 report for the UVic Environmental Law Clinic. In addition, we offer the comments below.

Many members of the public are under the impression that an environmental assessment will determine whether or not a project is a good idea, and believe that they can provide input to government officials about a proposed project’s scope and location, and whether or not it should go ahead.

In reality, public and stakeholder feedback is solicited regarding project-specific details only, and how these details can be tweaked as the project goes ahead. Public concerns, when met at all, are addressed by mitigation measures (often unproven or vague), or by commitments to gather more information. Since scientific information is often inadequate despite the best efforts of the proponent, commitments to ongoing monitoring and adaptive management are often made. If these commitments are perceived to address the lack of information they will result in project approval. However if monitoring reveals unacceptable impacts, there is generally no recourse to reverse or change the project.

Environmental Assessments are frequently seen as a “rubber stamp,” since the process effectively asks “what is required for the proponent to get the project permitted?” instead of asking strategic questions about project acceptability, and just saying “no” to obviously ill-conceived or highly controversial projects. Public anger and disenchantment has been a frequent result.

As many studies and analyses have suggested, the most effective and efficient way to engage the public is at a more strategic level. It is also well established that operating at a strategic level is the most effective way to address cumulative impacts and preserve biodiversity and ecosystem function.

A practical solution to this systemic issue is to set up a provincial framework to conduct Regional Strategic Environmental Assessments. Among other things, these assessments use computer modeling to analyze different development scenarios brought forward by participants. These scenarios can then be used for land use planning. Members of the public and stakeholder groups can be full participants in scenario development and land use planning. This process would be the most effective approach to addressing the majority of project-level complaints, since the most common questions about the appropriate type and level of development would already be addressed.

Another major problem with Environmental Assessment in BC is that of project splitting. This has been a problem with river diversion hydropower projects (e.g. the Holmes River Hydro project near McBride). Similarly, shortly after being permitted, projects of various sorts are often granted permission to amend their certificates to allow increases in size or capacity, and level of impact. The EAO should be doing more to prevent this abuse of the EA process.

Finally, the current model that allows project proponents to directly hire the professionals tasked with conducting the Environmental Assessment puts these professionals in a conflict of interest. It is too easy in British Columbia to find professional environmental consultants who have experienced this problem first hand, and who will admit that their analyses and recommendations regarding project impacts, mitigations, etc., have been substantively influenced by their or their employer’s desire to please their client by reducing barriers to project approval and profitability. There are workable alternatives to the current proponent/consultant control model. These alternatives should be studied and this major problem should be fixed as soon as possible.

Thanks very much for the opportunity to comment on this important process.

Aaron Hill

Executive Director


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