Summary of Issues - Missing information on financial support from federal authorities

Dear Madam or Sir,

For the description of a designated project such as the Peace River Nuclear Power Project (https://iaac-aeic.gc.ca/050/evaluations/proj/89430), the Information and Management of Time Limits Regulations (https://laws.justice.gc.ca/PDF/SOR-2019-283.pdf) require, inter alia:

·         A summary of any engagement undertaken with any jurisdiction or other party, including a summary of the key issues raised and the results of the engagement, and a brief description of any plan for future engagement.

·         A description of any financial support that federal authorities are, or may be, providing to the project.

Comments (https://iaac-aeic.gc.ca/050/evaluations/proj/89430/contributions/id/62896) from the Sierra Club Canada Foundation note that the Initial Project Description (https://iaac-aeic.gc.ca/050/documents/p89430/161347E.pdf) does not address these issues.

The description of “financial support that federal authorities are, or may be, providing to the project” in section 6.1 of the Initial Project Description (https://iaac-aeic.gc.ca/050/documents/p89430/161347E.pdf) is:

Federal Funding

The Project is currently receiving funding from the Government of Canada through the Natural Resources Canada (NRCan) Electricity Pre-Development Program. This program is expected to continue to provide funding during the pre-development phase of work for the Project. There is potential for future federal funding, but this has not been confirmed at this time.

A standard definition of  “description” is “a statement or account giving the characteristics of something.”  The following “characteristics” would describe federal financial support for the project and enable public accountability and transparency:

1.      Describe the Natural Resources Canada (NRCan) Electricity Pre-Development Program from which funding has been provided, in terms of the scope, duration, total funding, and application guidelines for this Program.

2.      Specify the amount, duration, and funding type (e.g., grant, loan) provided to the Peace River Nuclear Power Project from the NRCan Electricity Pre-Development Program.

3.      Provide information on the “pre-development phase of work for the Project” (e.g., in terms of expected duration and activities), noting that this phase is not described elsewhere and is not included in Figure 4.5-1: Overall Project Schedule.

4.      Identify future anticipated activities that may receive federal funding.

5.      Indicate if the $304 million that NRCan is providing to AtkinsRéalis to support the development of the CANDU MONARK nuclear reactor is part of the Project.

Another issue is that the  Initial Project Description (https://iaac-aeic.gc.ca/050/documents/p89430/161347E.pdf) does not summarize engagement between Energy Alberta and AtkinsRéalis in the Project. This is a key issue because the Project “involves the permitting, construction, operation, and eventual decommissioning of four (4) CANDU MONARK 1000MWe-class power reactors;” and the CANDU MONARK is an AtkinsRéalis design (https://www.atkinsrealis.com/en/media/press-releases/2023/28-11-2023) currently in the definition phase.

We would be grateful for an explanation as to why these issues are not addressed in the Summary of Issues (https://iaac-aeic.gc.ca/050/evaluations/document/161842) prepared by the Impact Assessment Agency of Canada. 

Sincerely yours,

Ole Hendrickson

Chair, National Conservation Committee, Sierra Club Canada Foundation