Focus on Sustainability and Positive Effects

Reference Number
16
Text

Introduction

Firstly, I would like to make fully clear that my points below are based on my thoughts are certainly debatable. I have not included any resources/citations; however, my thoughts are a continuation of my studies in Impact Assessment (IA). Despite the points that I am making, it is absolutely true that mitigating adverse effects is a main goal of IA by design, especially historically. My argument is generally that we should focus on positive effects towards the ends of contributing to sustainability and improving the country for Canadians. Given the purpose of IA is to identify whether a project is in the interest of Canadians, then we should expend more effort on focusing on the overarching concepts of (1) purpose of the project, (2) positive effects, and (3) sustainability. These three components can broadly be framed by or paired with the idea of human health and well-being insofar as I would propose the premise that the project should be to improve upon human well-being, otherwise it is definitionally not in the interest of Canadians (i.e., I would equate human health and well-being with "interest" of Canadians).

1 - Need for the Project

At a surface level, the need for the project is clear: that nickel, iron, and cobalt are necessary for steel and production of batteries and other "clean technologies". The final outputs referenced (e.g., steel, batteries) are necessary for the purpose of further development. What technologies exist now, do we anticipate a need for the ore new technologies, and what alternatives are there to the implementation of these technologies requiring nickel (f.ex.). Ultimately, our thinking must be rooted in the actual material benefit to obtaining the metal. We must aim to prove this as concretely as possible at a fundamental human, and maybe even philosophical, level. 

The idea proposed in the project description that the project benefits include ta revenue from mining, while obviously true entirely misses the point of considering the need for the project. The real question is do people need the product, yes or no? Are our lives benefited by having the product yes or no? Of course, in a roundabout way, if people go from not having a job to having a job, that is an economic benefit to them, but if there are better jobs to be had where the same person could be employed at the same wage to make a product that is more beneficial to people, then of course the latter situation is better. The way that tax revenue is brought up as a positive in the project description is obfuscation of the project need.

2 - Positive Effects

We should focus more on positive effects than is typical to get a good read on pros and cons, essentially. If a project fulfills a critical strategy of our country (i.e., there is a strong need for a project), the question should never be "can we do this", it should be "how do we do this". It is my impression that IA does decent job in assessing and identifying mitigation measures for adverse effects as this is where our collective expertise is. 

Generally, it is crucial that project-level IA have a greater focus on positive effects than they historically do. A big part of the reason that the Impact Assessment Act was enacted over CEAA 2012 was to restore public faith in the process. The most important elements that a system needs for people to have faith are (1) outputs that align with public opinions and (2) public participation such that people feel that their input effected the process. It stands to reason that IA participants have historically been directly affected by the projects subject to IA (definitionally so under CEAA 2012). As the result, I would expect a selection bias of individuals that are more antagonistic towards a project than the general public. This is certainly fair; however, this can lead to a problematic dynamic between stakeholders. For example, while not directly negatively affected by a project, someone who benefits positively from a project is conversely negatively affected by a project not moving forward, or even project delays. 

I am also curious about whether the focus on adverse effects and lack of focus on positive effects feels disingenuous to the general public, especially insofar as the discussion around economic impacts. In my experience reading proponent environmental impact statements (EIS), the discussion is lackluster and includes generalities about estimated employment numbers, etc., but doesn't link well into how projects link into the country's economic vision as a whole, and how meaningful their work is. To be fair, likely how the media writes headlines about the results of IA will certainly matter more than what is written in the actual IA. On this note, perhaps the Impact Assessment Agency of Canada (IAAC) should work with journalists to accurately report on IAs. 

3 - Sustainability

Specifically, what minerals do we need, and for what purpose? Do we have the smelters and infrastructure necessary, in Canada? Furthermore, will the ore be thus smelted/refined in Canada, then manufactured here, or will we rely on global markets to circulate "green technologies" back to Canada. Based on this, will the transportation costs associated with all this industrial activity truly reduce our impacts? What are the break-even points of this? This thinking must be reflected in a sustainability assessment. 

Sustainability can apply to anything - we must evaluate the whole of a system and understand inputs of outputs and minimize outputs to match inputs as possible as closely. When it comes to metals, to be sustainable, they should be fully recycled - there's no reason why not. 

There's just so much to say about sustainability and how it can really apply to everything, that I strongly believe that this needs to be an entire discussion and even a primary focus of the IA - there's no section that should not consider this. When it comes to water quality for example, we can evaluate this simply groundwater is pumped to clear the mine and diverted - we need to ensure that all water effluent leaving Site has NO IMPACT off-site. This can be done using natural filtration, but how much space is required to do this? Oftentimes the project area is limited to an area based on the assumption of on-site water treatment, but we may want to consider other ideas such as natural filtration and consider all of this as part of the Site which would give a better overarching understanding of the true environmental impacts of a projects (this argument can apply to any project).

Conclusion

We should focus on project need first and foremost based on material need of the project, not on the basis of there being market value in the product. Positive project effects are a second point of focus that may be crucial (at a high level) to demonstrating public utility of IA and helping to make good determinations as to whether a project is in the public's interest. Thirdly, sustainability is an important topic to expand on as much as is reasonably practicable. It is already the case with respect to requirement of the minister under IAA 2019 to include consideration of sustainability within the decision statement, however this is not enough, we should have a comprehensive evaluation of sustainability as a theme engaged in throughout the entirety of the IA process. This is the lens through which all ideas should be evaluated. 

What we really need at a country level is a VISION, how does the project fit into this? I understand that this is a nebulous idea difficult to act on without further direction, but I think this is where IAAC can step up. IAAC can compile federal strategic documents, work with experts from other agencies across the spectrum from ESDC, GAC, Canadian Heritage, Indigenous and Northern Affairs Canada, NRC, etc. (especially during the planning phase).

Apologies that this input does require refinement, and there's so much more to say, but I hope this helps to provide an idea of the direction of thinking that I think is necessary in IA, whether comprehensive IA or even just in project screening. On this note there is a whole lot to be said about regional assessment (RA) and strategic environmental assessment (SEA) and how these can contribute to the IA process in a broader sense. 

Submitted by
Patrick Moullas
Phase
Planning
Public Notice
Public Notice - Public Comments Invited on a Summary of the Initial Project Description
Attachment(s)
N/A
Comment Tags
Human Health and Well-Being Need for the Project Project Alternatives Purpose of the Project Project Contribution to Sustainability
Date Submitted
2022-09-07 - 8:50 PM
Date modified: