Thank you, Madam Chair.
I'm Ed Wojczynski, president of the Canadian Hydropower Association. With me are Genevieve Martin of BC Hydro, who is chair of our regulatory processes working group, and Pierre Lundahl, our chief consultant with the Canadian Hydropower Association.
The CHA is the national voice of the hydro power industry. It represents generators, manufacturers, engineering firms, and construction companies. Hydro power, as I think you probably already know, supplies over 60% of Canada's electricity. It is our largest generation source, and has made Canada's electricity system one of the cleanest, most renewable, and most reliable in the world.
Hydro power has virtually no greenhouse gas emissions, and it has a key role in achieving Canada's climate change targets. Studies indicate that to meet our 2030 and 2050 commitments, Canada needs to electrify the economy and further reduce the greenhouse gas emissions of the electricity sector, among other measures. This means doubling or even tripling electricity generation by 2050 through a major expansion of hydro power, in concert with wind, solar, maritime, and geothermal power.
Our industry is up to the challenge. Canada still has vast amounts of hydroelectric resources that can be developed. For this to happen, though, Canada needs a predictable and timely project review process that engages all stakeholders and indigenous peoples and has the confidence of the public. Bill C-69 will, in the view of CHA, bring us closer to that objective.
CHA generally supports the bill, but there are some important improvements that are still needed. We are pleased that a number of the suggestions we made in response to the government's 2017 discussion paper are in the bill.
The bill has many good elements, but today we will focus on further suggestions to improve the process. We will later provide the committee with a written submission commenting on several areas of the proposed legislation, and we will suggest specific amendment wording in that submission. We will also provide comments on revisions to the Navigation Protection Act, which we have some concerns with as well. This afternoon, we would like to highlight five recommendations on the impact assessment act.
First, focus the act on projects of national significance. Second, include guidance to the minister when she or he is thinking of applying the act to a non-designated project. Third, guide the ability to extend timelines. Fourth, set a time limit for the establishment of panels. Finally, provide the minister or the agency with a more explicit authority to issue a notice of commencement when a party is taking an unreasonable amount of time to respond, or refuses to respond or participate during the planning phase.
I would like to turn now to the first of these five items. The proposed impact assessment process, with its broader scope, two-phased approach, and large number of decision points, will be more challenging to manage and more complex than what we have today. It will call on specialists from many different areas. It will have to coordinate work from many departments and agencies. It will have to accommodate a large number and a broad variety of intervenors.
The complexity and overall effort required by governments, indigenous peoples, stakeholders, and the proponent argues strongly for focusing the act only on large projects of national significance. We suggest that this be added to the act's purpose statement, to assist in interpreting the bill. This would also guide development of the designated project list.
Large projects of national significance tend to be ones that have more impact than small projects. They involve more public concerns and expectations for a major review. Their proponents would be more likely to be able to manage the complexity and rigorous demands of the process. Projects of that scale already take time to develop and are managed by experienced teams with access to wide-ranging expertise.
If the regulations designating physical activities cast too wide a net, there are two risks. First, medium and small projects with significant benefits and minimal impacts might not be pursued. If the regulatory costs are unpredictable and potentially too large, and the review outcome is uncertain, then the financial viability of entire classes of projects could be undermined.
The other risk is that legislation leads the government to use its regulatory resources inefficiently. These smaller projects, with only minimal impacts, are likely already subject to provincial environmental assessment mechanisms. There are also federal statutes to protect various aspects of the environment such as the Migratory Birds Convention Act, the Species at Risk Act, the Navigation Protection Act, and the Fisheries Act, which is currently being made more stringent as we speak.
Turning to the second recommendation, the impact assessment act would also give the minister the discretion to assess a project that is not on the designated project list and thus would otherwise not qualify for review. Some sort of provision to this effect is necessary, and CHA supports that, but apart from the impact on indigenous rights, there are no criteria in the act to guide the minister's discretion.
As currently drafted, the minister may order an assessment on the basis of her opinion on adverse effects or on the basis of public concerns related to these effects—and that makes sense—but there's no explanation of the procedure or considerations that would help form that opinion. This is inconsistent with the goal of greater process transparency.
CHA recommends establishing criteria in the act to guide the minister's discretion. Our written submission will suggest specific criteria similar to those the government is already utilizing in development of the designated project list regulation. If it's good enough for the project list regulation, it's good enough to put in the act.
Geneviève Martin, my colleague from B.C. Hydro, will take over.