July 2008 Comments on Draft Process Improvement Initiatives for Screening Environmental Assessments
Thursday, July 17, 2008Ottawa Riverkeeper/Sentinelle Outaouais ,
Canadian Environmental Law Association,
Sentinelles Petitcodiac Riverkeeper, and
Lake Ontario Waterkeeper offer this comment in response to the Canadian Nuclear Safety Commission’s (“CNSC”) draft document entitled Process Improvement Initiatives for Screening Environmental Assessments at the CNSC.
We oppose the proposed “process improvements” because they fail to improve on the current process. More specifically:
- The projected “efficiency gains” are dubious
- There is a false distinction between “complex” and “smaller” projects
- The elimination of meaningful public consultation is unacceptable
- The elimination of public consultation in the early stages of environmental assessment contradicts the CNSC’s stated goals
- The Integrated Approach for environmental assessments will lead to confusion and the appearance of bias
- Licencing and environmental assessment processes have different aims
- The relationship with the MPMO contributes to the appearance of bias
- Delegation of decision-making to CNSC staff further weakens the Commission’s authority
- There has been inadequate public consultation on the restructured process
Click here [pdf file: 0.74mb] to the full submission
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