Good morning. My name is Liam Mooney. I'm the vice-president of safety, health, environment and quality, and regulatory relations, with Cameco Corporation.
I'd like to thank you for the opportunity to appear before you today. I'll start by saying that I'm pleased to present to the Standing Committee on Environment and Sustainable Development as part of your ongoing review of the Canadian Environmental Assessment Act, or CEAA.
I am joined today by Jeff Hryhoriw, Cameco's manager of government relations. We have provided a written brief, but before I get into our proposal for positive pragmatic reform for CEAA, I want to provide you with some background on our company.
Cameco is headquartered in Saskatoon. We are one of the world's largest producers of uranium for nuclear energy, accounting for roughly 16% of total global supply. Most of it is generated from our mining operations in northern Saskatchewan.
We also have uranium refining processing and fuel fabrication facilities in Ontario, and we are part of a partnership in Bruce Power's nuclear plant on the shores of Lake Huron. On top of this, we are actively exploring for additional uranium resources in a number of provinces and territories throughout Canada.
Through these various activities, Cameco directly employs almost 3,200 people in this country, with nearly a quarter of our Canadian workforce comprised of first nations and Métis citizens. We are proud to be Canada's largest industrial employer of aboriginal peoples.
With that introduction I'd like to turn now to our views regarding CEAA.
Environmental assessment provides an important framework for sustainable development in Canada, development that builds this country's economic and social well-being. However, some serious flaws inherent in CEAA and its regulations run contrary to the interests of Canadians.
The 2009 report of the Commissioner of the Environment and Sustainable Development cited a number of these problems, specifically noting that the federal EA process suffers from systemic delays, lack of coordination, and focuses on expensive and frustrating process without being able to demonstrate value to the environment or society.
Some positive steps were taken toward improving the federal EA system through the 2010 Jobs and Economic Growth Act. However, more change is necessary, and this review of CEAA presents a welcome opportunity to make further progress.
As an industry proponent of many projects that have been subject to the federal EA process, Cameco has developed a set of four practical reforms that we are proposing. In brief, they are as follows: one, eliminate multiple environmental assessments—in other words, adopt a one project, one process model; two, rationalize project triggers. three, better integrate environmental, social, and economic considerations; and four, establish environmental assessment cycle times.
One additional recommendation we would propose is to ensure that any changes made to improve the federal EA process are extended to all projects that are subject to it, including those involving the Canadian Nuclear Safety Commission in the case of our industry.
We would emphasize that the changes we are proposing are not aimed at lowering environmental standards or removing any area of industrial activity from regulatory scrutiny. Rather, they are simply intended to improve the efficiency, timeliness, and predictability of the EA process. In short, they are reforms that would benefit all Canadians interested in fostering sustainable development by allowing legitimate development to proceed without unnecessary process.
I will now briefly expand on each of these points.
First, with regard to eliminating multiple environmental assessments, there is broad consensus between the provinces and the federal government that the concept of one project, one assessment, appropriate to the scale and complexity of the project, is a laudable goal that should be pursued. This would put an end to the practice where two independent and separate processes are conducted, scrutinizing essentially the same work to accomplish the same overall end. This duplication of effort often results in lengthy delays to projects, without any additional environmental benefit whatsoever. Instead, a single thorough review process undertaken by one level should satisfy both federal and provincial requirements.
In our view, the solution is straightforward: provide the federal authority with the ability to designate another jurisdiction's assessment of a project as equivalent under CEAA. This would eliminate redundancies of overlapping review.
Our second proposed amendment is to rationalize project triggers. Environmental assessment is intended to serve as a planning tool for projects and not be the last word on a project. In practice, the EA process has become much more invasive than that. It has been extended to decisions made with respect to minor approvals on projects that are already covered under an existing licence. The net result is that there are a great number of EAs for minor works or undertakings, introducing lengthy process delays into essentially administrative decisions.
To address this issue Cameco proposes amendments that would end costly and unnecessary reviews on a large number of minor projects while allowing for an increased focus on major projects.
Our third proposed reform is to better integrate environmental, social, and economic considerations. When evaluating environmental mitigation measures, it is important to consider what is technically and economically feasible and to factor in the economic and societal benefits of the project to Canadians.
The intent of CEAA is to promote sustainable development and thereby achieve or maintain a healthy environment and healthy economy. This is reiterated in the Federal Sustainable Development Act, which holds that the basic principle of sustainable development “acknowledges the need to integrate environmental, economic and social factors in the making of all decisions by government”.
In practice, however, EAs tend to be reduced to the environmental considerations only and do not contemplate overall regional or even global benefits. As a result, a project offering broader environmental, socio-economic, or sustainable development advancements can be buried under a relatively minor, potentially localized, impact. In addition, CEAA maintains that the facts to be considered in an EA include the need for the project and mitigation measures to be “technically and economically feasible”.
This would suggest that a degree of proportionality should be factored in when mandating solutions to rectify an identified potential environmental impact. However, this is seldom the case. In practice, responsible authorities do not appear to contemplate whether a specific environmental protection measure is economic in its own right, whether it's reasonably balanced with the potential economic environmental impact, or what effect it will have on the overall project viability.
Our fourth proposed amendment is to establish environmental assessment cycle times. Without compromising appropriate environmental stewardship, it is vital to shorten EA timelines and accelerate the review of projects that are subject to the federal EA process. The stated goal of the Major Projects Management Office is to complete EAs within two years. Much would be gained by requiring federal authorities to follow timelines mandated by legislation or the federal environmental assessment coordinator.
The new establishing timelines for comprehensive studies regulations are a very promising first step in this regard. They set firm timelines and a transparent means of tracking how the timelines are met. However, our optimism here is premised on these regulations and any other improvements to CEAA being sent to all industry proponents, including uranium industry proponents, irrespective of other federal regulatory regimes.
This leads to our final recommendation, that these and other positive reforms made to the EA process be extended to all projects that are subject to the federal EA process, including those led by the Canadian Nuclear Safety Commission.
In summary, Cameco agrees that Canada's environmental assessment regime must be robust and thorough to ensure that the pristine environment for which our country is world renowned remains well protected. At the same time, it must also be efficient and well coordinated so as not to stifle the development that has enabled Canada to thrive economically and socially.
At present, this balance is not being met. However, changes are possible to CEAA that would vastly improve the efficiency, timeliness, and predictability of the EA process without weakening overall protection of the environment afforded by the current regulatory regime.
The positive pragmatic reforms that we have proposed will go a long way toward addressing the frustrations project proponents in this country regularly encounter under CEAA. We hope that as members of the committee you will likewise appreciate the benefits of these recommendations and incorporate them in your final report to Parliament.
Thank you.