The proposed list of…

The proposed list of projects to qualify for a full environmental assessment is incomplete and problematic through its lack of scientific explanation and required reference to the ministry’s Statement of Environmental Values.
The notice doesn’t provide evidence to explain how environmental risks of various types of projects were evaluated to produce the proposed list. It offers no explanation for why other potential project candidates (for example. sewage treatment plants, quarries, fracking, refineries, pipelines, forestry operations, pulp mills etc.) were excluded from the list. As a result, this list is not credible, transparent or accountable in determining projects with “the greatest potential harm.” The government must go back to the drawing board and show the basis for its decision-making.
The notice asserts the proposed list was guided by the government’s desire to “eliminate duplication with other legislation, policies and processes.” But the consultation materials have not identified any instances of unnecessary overlap between the EAA and other policies or laws. In fact, it is only the EAA that requires analysis of (a) the need for the project; (b) alternatives to the project (c) “alternative methods” of carrying out the project; and (d) the environmental, social, cultural, economic, and other effects of the project and its alternatives.
For projects such as new highways and railways, distance is not the appropriate measure of potential environmental impact — instead, the location of the project is more important in determining potential harm. For example, whether it crosses sensitive wetlands, woodlands wildlife habitat and farmland.
The incomplete nature of the proposed list (which contains 13 categories of designated projects) is demonstrated by comparing it to the federal project list under the Impact Assessment Act, which contains 61 categories of projects.