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May 26, 2017

The Honourable Catherine McKenna, P.C., M.P.
Minister of Environment and Climate Change
Canada 200 Sacre-Coeur Boulevard
Gatineau  QC   K1A 0H3

Dear Minister McKenna:

RE: Expert Panel on Environmental Assessment Processes Report

On behalf of the 850 members of the St. John’s Board of Trade, I write you today to  share our position against the unintended impacts of the recommendations in the Expert Panel on Environmental Assessment Process report, if actioned.

We are committed to helping business succeed and want to ensure that all businesses are treated fair, equitable in a timely manner. We support a process that places the right balance on protecting our environment and allowing Canada to compete and prosper on the world stage for the benefit of all Canadians.  We believe the recommended approach would make it harder to get Canadian natural resources to market and deter investment in this resource sector.

The St. John’s Board of Trade has submitted comments on the letstalkea.ca website however, we also want to make you personally aware of our members concerns. Below you will find our position.

  1. The St. John’s Board of Trade in partnership with the Canadian Chamber of Commerce supports a rigorous environmental assessment process that protects Canadians and our environment. A system that is clear, simple and timely is the best way to balance environmental protection with economic growth.
  2. While the panel report does contain helpful suggestions, overall the report is a move in the wrong direction, pushing Canada further away from an efficient but rigorous assessment process that could balance environmental protection with economic growth.
  3. Strategic and regional environmental or impact assessments provided by those such as the CNLOPB, can help provide information that would be of use to individual project reviews, such as baseline environmental information or an understanding of the scope and nature of indigenous rights. These exercises could also provide Canadians with additional opportunities to make their voices heard on policy issues outside the scope of an individual project review. Our members support the greater use of these tools by governments. It is essential that individual project reviews not be delayed due to a pending or potential regional and strategic assessment, and that the costs of these non-project reviews be covered by governments.
  4. We recommend that the CNLOPB be designated as an RA for CEAA 2012 and that exploration wells be removed from the CEAA project list.
  5. The panel’s proposed approach would likely expand the types of projects and activities subject to federal assessment in addition to provincial/territorial processes, leading to increased costs and duplicated efforts without improving environmental outcomes.
  6. The panel’s proposed approach to impact assessments would invite unilateral federal intrusion into provincial/territorial jurisdiction, creating the potential for conflict and confusion.
  7. The panel recommends that every step of the assessment process be based on consensus, which is not a realistic approach. Instead, the focus should be on enhancing collaboration, inclusion, engagement and transparency within a fact-based quasi-judicial process.
  8. The cost and complexity of Canada’s environmental regulatory processes is becoming yet another area of weighing down the competitiveness of the Canadian business. Canada’s economy cannot afford a regulatory process that is a barrier to investment.

I invite your staff to contact the St. John’s Board of Trade should you have any questions on these positions. We can be reached at mail@bot.nf.ca | 709-726-2961.

Sincerely,

Dorothy's signature full 1

Dorothy Keating
Chair
St. John’s Board of Trade
cc: Minister Carr, Newfoundland and Labrador MPs

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