Thank you, Mr. Richards.
I'm happy to be here today. Thank you for the invite. Over the years, I have spent a great deal of time involved in the YESAA process. Today I want to talk primarily about the ex-com—or executive committee—process, so I think you have a bit of both sides of it here with my friends from Klondike Placer Miners' Association.
I'm here to talk about what I see and what my experience is in terms of the amendments related to the YESAA process as a whole. Before I start into what I would call the technical part, I want to preface my remarks by saying something about what I see as the issues.
One of the things that I think has been a benefit in terms of having YESAA—and this is my experience—has been that we've been able to work through large projects. I'm not telling you that there haven't been bumps in the road. There have been a lot of bumps in the road, and there are a lot of things about the YESAA process that I would like to see improved, but in any event, from my perspective, there are parts of the YESAA process that have improved over the years. Whether it's through how YESAA's own internal processes, or rules, or operating rules have changed, I've seen some improvements. We've had some good experiences through the YESAA process, and we've had some costly experiences in the YESAA process.
But whether we get to a point through your work such that we have amendments that we go forward with, I want to talk for a minute about the fact that this YESAA process lives and works here in the Yukon, we all live and work here in the Yukon, and the projects that we do are here in the Yukon. It has to work for all of us. If there are significant differences of opinion on issues, we have to find a way to sort them out, because trying to go through an assessment process and then all the various regulatory processes that we find ourselves subject to is a long and detailed process. If we have certainty around the fact that those processes work, we at least have that comfort, but if we don't have that certainty, then this process doesn't work any of us, and it has to work.
Let me talk about timelines for a quick minute. I believe strongly that there have to be some timelines. Having said that and having told you that I want to talk about the ex-com process, in my previous life we went through three ex-com screenings. That's probably more than anybody, but I might be wrong. Beginning to end, individually, they lasted 10 months and three days, one year and two months, and one year and 12 days. From my perspective, I think the 16 months is a good timeline. It gives people enough time to get their work done from an assessment process view, and certainly the projects that I'm talking about were not small projects. They were big projects.
Part of the process when you look at timelines is that we're talking about assessment timelines and people are talking about project timelines. There's often a big difference. Even if I go through a process—let's pick the middle road and say that it was one year to get from assessment beginning to assessment end—only if that assessment end finishes in May or June do I really get to start a project. If my 12 months end in September or October, I won't be doing anything until May or June of the next year.
Timelines sound simple and they sound easy, but it's really necessary to be clear on them when you're starting to work on projects that are worth hundreds of millions of dollars or tens of millions of dollars. It's an imperative, because you're at risk when you talk about the costs and the budgets for those projects.
The other area that I think is important to talk about is adequacy. Adequacy has to be defined, and it needs some clarity. Now, as to whether or not it's included, I'm not going to debate that. But the problem with some of the pieces of the legislation that companies have a difficult time with is that there's not enough clarity and definition around adequacy.
The last area I want to talk about today is cumulative effects. We've added the term “likely to be carried out” to the legislation, but for the life of me, I don't know what that means. Likely to be when? That's really important. How do you as a proponent deal with cumulative effects that might happen five years down the road? I don't know how you deal with that in an assessment process, because I don't know how you have information to deal with it. That needs some clarity and some definition as well.
The final piece is maybe tied to timelines, but it's really about finishing the YESAA process. When I talk about timelines, 16 months or whatever number people settle on, that for me is one thing, but I think having the ability, under that 16-month period, to put some fences around times of stages is also important. I'll give you the example of what we went through in those three projects. The time to go from a draft screening report to a final screening report was 62, 76, and 82 days, and 76 or 82 days, to go from writing the draft screening report to the final screening report, is just a lot of time when you're trying to get to a project and move it forward. When you have a draft screening report, you have the vast majority of the work done.
I'd put some fences around the stages within the timeline periods. As well, I think we'd all benefit from clarity on a couple of those issues: adequacy and cumulative effects.
Thank you.