I am the current President…

I am the current President of the Ontario Association for Impact Assessment (OAIA). The OAIA is a volunteer forum for advancing innovation, development, and communication of best practices in impact assessment through the exchange of ideas and experiences among its members, and with other organizations with compatible interests. OAIA members come from a variety of backgrounds and at any given time, include: managers, engineers, planners, and consultants from the private sector; managers, officials, scientists, and analysts from the public sector; public interest advocates; lawyers; health professionals; educators and researchers; students; and interested citizens.
Several years ago, the OAI established a working group, hosted a workshop and held a conference that culminated in a report setting out recommendations for improving the EA Act. Attached to this letter is a copy of that report entitled “Environmental Assessment Program in Ontario: Is it Time to Hit the Reset Button?”
The OAIA report identified the following five themes to describe the key opportunities and recommendations to improve EA Program outcomes by addressing issues/problems with current EA practice and process without requiring legislative changes to the EA Act:
1) Efficiency of approvals process
2) Optimizing approvals under several Acts to reduce duplication
3) Clarity in the EA approvals processes
4) Indigenous Peoples: issues and consultation/engagement
5) Emerging issues
It is interesting to note that with one exception the themes accord with the objectives in the Ministry of the Environment, Conservation and Parks discussion paper:
1) Ensure better alignment between the level of assessment and the level of risk associated with a project
2) Eliminate duplication between environmental assessments and other planning and approvals processes
3) Find efficiencies to shorten the timelines from start to finish
4) Go digital by permitting online submissions
The OAIA report did not reference the advantages of “go digital”. However, it did identify the following emerging issues that need to be better incorporated into EA practice and Ministry EA guidance in order to provide an even and consistent playing field for participants and achieve a balance between benefits and costs in the future:
1) Sustainability – when and how is it appropriate in the EA process to use greater sustainability as a goal? OAIA recommends that the review consider using this goal in place of the “betterment” goals as set out in the EA Act, Section 1.1
2) Climate change – when and how to include climate change when evaluating projects and addressing this in an EA study?
3) Cumulative effects assessment – where in the EA Program is the appropriate place for consideration of cumulative effects? Should this be on a regional basis, such as an airshed, or on an individual project level? Is it reasonable to expect a proponent to provide all of the information required to make a meaningful assessment to inform a cumulative effects assessment?
4) Participant Funding – how could a program of participant funding be initiated on a fair basis to serve the various needs of stakeholders, Indigenous Peoples and other participants in EA projects?
5) Strategic Environmental Assessment – what can be learned from other jurisdictions and their use of Strategic EA process to address plans, programs, or new initiatives that may have socio-economic and/or environmental impacts?
The OAIA looks forward to participating in the dialogue initiated by the discussion paper to “modernize Ontario’s environmental assessment process, to eliminate duplication, streamline processes, provide clarity to applicants, improve service standards to reduce delays, and better recognize other planning processes."