Evidence of meeting #36 for Indigenous and Northern Affairs in the 41st Parliament, 2nd Session. (The original version is on Parliament’s site, as are the minutes.) The winning word was yesaa.
NDP
Carol Hughes NDP Algoma—Manitoulin—Kapuskasing, ON
Two minutes? That's good.
Based on the information that I've provided and that you've provided to us, when we look at the policy direction, would you agree that it should be through consent by all parties in order to do a final agreement?
As well, I'm wondering whether KPMA is concerned that their industry will suffer with treaties not being respected. Because this is what it's all about: it's about treaties being respected and making sure that we can all move forward together.
President, Klondike Placer Miners' Association
I'm concerned about suffering no matter what happens, because if the treaties aren't respected and we go to court, we suffer. If some of these changes, and perhaps more changes to YESAB, aren't made, we also suffer.
I don't know what I would recommend except to say that I would be happy to sit down here. I think one thing that's perhaps been lacking is industry's technical support for the negotiating sessions or the consultative sessions between first nations government and the federal government on this subject. Even though industry, of course, does not belong at the negotiating table, they could be there as technical support to help everyone understand the problems better. I believe if everyone understood industry's problems better, then some resolutions would come to this.
I chastise all the governments for not solving this.
Conservative
Conservative
Ryan Leef Conservative Yukon, YT
Thank you, Mr. Chair.
Mr. Smith, I appreciated your comments towards the end there. You made some valid points, and they're well taken.
I'm not sure if you were present this morning when the premier talked about finding a path forward and, indeed, extended an opportunity to engage in bilateral discussions to work on the engagement of Bill S-6. He certainly promoted the passage of the bill, but he recognized clearly that continued consultation and greater work could be undertaken on this bilateral piece. The position of Yukon first nations is that their preference would be a trilateral discussion to that end, and we certainly take that consideration under direct advisement here as a committee.
You posited that industry would bring value to the table from a technical point of view and would allow your concerns to be understood more clearly. Taking that route, are you confident there might be some solution to these four outstanding pieces?
President, Klondike Placer Miners' Association
I hope so. I asked people to continue talking. It's always good to talk instead of going to war. Why not talk right up until the last minute, if we can?
I don't know enough about how this all works with legislation, how proper consultation works, and how it would have to be done, but I'm sure if there's a real will on the part of all the parties concerned, some sort of resolution could be found and Bill S-6 could go to the House of Commons.
That would be my absolute preference. I would love to see things go to the House of Commons. Maybe we can even make it better than it is right now through further consultation. I'm sure many people in industry would be more than happy to sit down and act as technical help for these discussions.
Conservative
Ryan Leef Conservative Yukon, YT
Thank you for that. Indeed, that's exactly the task of the committee, to seize itself with reviewing the bill through the stakeholder and witness testimony we've heard from all Yukoners today. It's been very positive and good for us to hear all the perspectives. Those points are well taken.
When we look at the evolution of this bill, there certainly has been feedback and advice from industry over the course of many years, some of which has stemmed from the five-year review. Some of these frustrations have carried on.
Can you refresh my memory? I know the chamber of mines had submitted its position on this to Yukon first nations. I should have asked them if they had received a response, but I didn't. Did the Klondike Placer Miners' Association forward anything to Yukon first nations and generate any sort of back-and-forth discussion to pre-empt its own side discussion on these things, so each one clearly understood its position, or not?
Conservative
Ryan Leef Conservative Yukon, YT
That's fair enough. You've highlighted that this could be an opportunity for that piece, and of course I do know that Yukon first nations are listening to the comments you're making here today, and I'm sure they appreciate that perspective.
Mr. Morrison, when we look at the executive committee piece that you worked through three different times, you did talk about the need for timelines. What are we talking about with respect to timelines? You mentioned that sometimes tens of millions of dollars are at risk when these timelines aren't clearly defined. Can you perhaps expand on why those tens of millions of dollars are at risk, and what happens in that regard if timelines are stretched?
Former President and Chief Executive Officer, Yukon Energy Corporation, As an Individual
When projects are developed and taken through to a decision point, you have a budget, a timeline, and a certain set of risk analysis that's been done around assessment and regulatory risk. When these things start to drag out, they have an impact on those things. As a project moves forward, if it doesn't start when it's supposed to, costs go up. If it's delayed, as Mr. Smith talked about, there are decisions or there are recommendations in the screening reports that go forward to regulators. Those add costs, not only because of the added time but also because of what's in the decisions made during that time. When you leave everything open-ended, how do you have some clarity around when you're going to start, how you're going to contract, and what those bids are going to be? The bids you got a year ago are no good 18 months out. You're starting all over again, and you're competing in a different environment. That can add significantly to a project.
You don't think these things add money to projects, but they add a lot of money to a project.
Conservative
The Chair Conservative Blake Richards
I'll have to stop you there.
We'll suspend briefly to set up for our next panel.
Thank you very much to our witnesses on this panel. I appreciate your information and your testimony.
The meeting is suspended.
Conservative
The Chair Conservative Blake Richards
I call the last session of the day to order.
In our last group for the day, we have with us Amber Church, conservation campaigner from the Yukon chapter of the Canadian Parks and Wilderness Society; Felix Geithner, director of the Tourism Industry Association of the Yukon; Lewis Rifkind, mining analyst from the Yukon Conservation Society; and Karen Baltgailis, who is appearing as an individual.
We'll move to the opening statements. I will have you make the statements in the order that I've just introduced you, and then we'll move to questions from members. The first statement will come from CPAWS' Yukon chapter.
Go ahead, Ms. Church.
Amber Church Conservation Campaigner, Canadian Parks and Wilderness Society, Yukon Chapter
Thank you.
I'd like to start by thanking the committee for travelling to Yukon and taking the time to hear from Yukoners on this important bill.
CPAWS Yukon works with aboriginal and public governments, local organizations, businesses, and citizens to ensure the natural wealth we enjoy today is available for our children tomorrow. Here in the territory we have about 280 members from all walks of Yukon society who demand responsible development that will benefit sustainable communities nestled in healthy, ecologically rich environments. We are currently active participants in land use planning, energy consultations, outreach to and engagement of the public in sustainability initiatives, and of course YESAA.
Our organization has some serious concerns about four sections of the proposed amendments to YESAA that are included in Bill S-6. I imagine you've probably heard about some of these earlier today, but I will reiterate them.
With regard to the concept of “significant change” as outlined in proposed subsection 49.1(1), CPAWS Yukon feels that the term “significant change” is both too vague and too subjective. We are concerned that once the project's initial phase has undergone assessment, additional phases, such as major expansions or cumulative minor expansions, could be exempted from screening by YESAB. This amendment increases the challenge of assessments, as not all impacts can be foreseen at the time of the project's initial application phase and may result in negative impacts to the environment, the economy, and Yukon communities.
Our second set of concerns deal with the amendment to the timelines, which are included in proposed subsections 56(1), 58(1), and 23(2). These proposed changes would shorten the timelines for environmental assessments, making it difficult for the YESAA board and staff to meet their duties and obligations. This may ultimately result in the rushing of complex assessments, which will put our environment and communities at unnecessary risk.
Under current legislation, all documentation submitted by the proponent must have undergone an adequacy review before the clock starts ticking. The changes proposed in Bill S-6 start the clock as soon as documentation is submitted by the proponent, before an adequacy review has taken place. This amendment poses the risk of significantly reducing the time available to conduct a thorough adequacy review, a critical step to the overall assessment process.
Our third set of concerns deals with the binding policy direction as indicated in proposed section 121.1. We feel that this proposed change appears to be at odds with the intent of the Yukon devolution agreement, which transferred powers from the Government of Canada to the Yukon government.
Further, and probably more significantly, we feel that these amendments jeopardize the independence and impartiality of the assessment process in Yukon and have the potential to permit political interference in what is currently an independent body. YESAB was founded to be a transparent and public process through which all stakeholders are provided the opportunity to learn about and to submit comments on projects proposed in Yukon. The ability of the federal minister to dictate future binding policy directions has the potential to undermine sound environmental stewardship through the systematic stripping away of previously held standards for assessable activities.
Our fourth set of concerns deal with the delegation of federal powers as outlined in proposed section 6. This proposed change does a disservice to the honour of the crown as a signatory of the Umbrella Final Agreement, the UFA, which originally prompted the creation of YESAA. The UFA is a political document between the Government of Canada, the Government of Yukon, and Yukon first nations, and, as such, has always been viewed as a tripartite agreement between these three levels of government. This proposed change could be interpreted as the federal government abandoning its constitutionally entrenched responsibilities under the UFA by delegating federal obligations to Yukon.
Finally, we would like to note that YESAA is a made-in-the-Yukon piece of legislation, and we feel it addresses a set of unique Yukon perspectives that should be honoured and preserved moving forward, not cast aside in the name of conformity.
Thank you so much for the opportunity to speak.
Conservative
Felix Geithner Director, Tourism Industry Association of the Yukon
Good day, members of the standing committee, and thank you for allowing me the opportunity to speak with you.
My name is Felix Geithner. I'm a tourism operator and a member of the board of the Tourism Industry Association of the Yukon, also known as TIA Yukon, which represents over 400 tourism businesses in the territory. I've been asked by the board to speak to you on behalf of the tourism industry today about Bill S-6.
First, let me tell you a bit about tourism in Yukon. Tourism is a major driver of Yukon's economy. According to the 2013 Yukon business survey, tourism generated approximately $250 million in 2012 and constituted almost 5% of Yukon's GDP that year. Tourism visitation has grown by an average of 3% per year from 2004 to 2012, with 2013 being the best year on record for tourism visitation. With this fall's announcement of an additional $3.6 million over two years from the federal and territorial governments to go towards a tourism marketing campaign, we expect visitation and tourism revenue numbers to increase even more in the coming years.
It's important for you to get a snapshot of how important tourism is to Yukon's economy. Far too often, people downplay the importance of tourism because its successes are difficult to measure and its profits are scattered throughout a multitude of businesses and sectors. With mining, it's so much easier to draw a line from A to B to show exactly where the money is coming from.
Even when people stop and think about the word “mining”, the mind conjures up images of gold and silver, diamonds and riches, and exploration with cash as the reward. The word “tourism” makes people think about exploring. Not many people think about the monetary value of tourism, but they should. When you add up the revenue from airlines, hotels, car rental agencies, wilderness guiding operations, outfitters, museums, aurora-viewing businesses, plus a big percentage of restaurants, retail shops, and other more indirect sources, tourism stands out as a cash cow, one that if properly cared for will produce forever.
Tourism is a big business in Yukon. It's a slow-growing, steady economy for us that's needed in the territory when Yukon's mining industry goes through one of its bust cycles, as has been the case in the past three years. It makes no sense to make changes such as the ones proposed in Bill S-6 unless one knows for a fact that they will not be detrimental to Yukon's tourism industry and are certain to benefit Yukon's mining industry. TAI Yukon calls both these points into question.
In the letter that TAI Yukon wrote to Yukon's MP, Ryan Leef, dated November 21, 2014, we expressed our concern that one of our partners, the Council of Yukon First Nations, was not properly consulted on all points during this process, especially given that YESAA is the cornerstone of the Umbrella Final Agreement. In fact, most of the Yukon public and key stakeholders of the business community, such as TAI Yukon, were not consulted on the bill prior to its introduction. In our letter, we also stipulated that taking land use planning decisions away from the territory will ultimately give tourism operators in Yukon less of a say over land use issues where resource extraction interests conflict with the interests of tourism businesses. These issues continue to trouble the tourism industry.
The most pertinent question isn't why Bill S-6 should be prevented from being passed, but why it was ever put forward in the first place in its current form. On April 22, 2010, Yukon Senator Dan Lang addressed a crowd of potential investors as the keynote speaker at the Yukon Forum in New York. According to a news release on the senator's website, Senator Lang praised the Yukon Environmental and Socio-Economic Assessment Board. He described YESAB as “implementing responsible environmental and social guidelines while providing certainty to investors”.
Even when the senator introduced the bill four years later on June 10, 2014, he acknowledged that Yukon's regulatory system has been a model for the rest of the country. The reason he provided for introducing a bill that proposed sweeping changes to a fundamental part of this regulatory regime was the need to involve and maintain a competitive and predictable regulatory system that remains competitive internationally.
Taking something that is a model for the country and giving it a drastic overhaul requires more than an inside design job. Throwing black paint at a white house isn't a renovation; it's a mess.
The extent of the mess this bill has created reached all new levels on November 28, 2014, when the president of the Casino Mining Corporation in Yukon wrote about “Bill S-6 and the negative impact this is having on the territory's mineral industry”. The Casino Corporation believes that if YESAA has the full support of all levels of government, it will provide greater certainty for the mineral industry.
From TIA Yukon's perspective, Bill S-6 is a shoddy piece of legislation that sows discord rather than the certainty it sets out to create. More than this, the proponents of this bill have set an adversarial tone in Yukon with Yukon first nations and a number of key organizations and businesses through their attempt to ram it through without adequate consultation. Consultation requires two-way communication. If one party doesn't believe that there was adequate consultation, then there was not adequate consultation.
To get a sense of the tone being set by the government in the House of Commons with regard to this bill, one needs only to listen to Alberta MP John Barlow, who sits on the Standing Committee on Aboriginal Affairs and Northern Development. On March 11 Mr. Barlow said:
We have to take some very aggressive steps to get Yukon back to where it was before and regain that success as a resource extraction economy.
TIA Yukon believes that Bill S-6 and these aggressive steps should be abandoned by the Government of Canada in favour of meaningful discussions and collaboration with Yukon first nations and all sectors that constitute Yukon's business community, including the tourism industry.
Thank you.
Conservative
The Chair Conservative Blake Richards
Thank you very much.
Our next presenter is Mr. Rifkind.
Please begin your presentation.
Lewis Rifkind Mining Analyst, Yukon Conservation Society
Good afternoon, and welcome to Yukon. My name is Lewis Rifkind and I'm the mining analyst for the Yukon Conservation Society.
I would like to acknowledge that we are on the traditional territory of the Kwanlin Dun and Ta'an Kwach'an first nations.
The Yukon Conservation Society, or YCS, is a grassroots environmental non-profit organization, established in 1968. Our mandate is to pursue ecosystem well-being throughout Yukon and beyond, recognizing that human well-being is ultimately dependent upon fully functioning and healthy ecosystems. We have about 250 members and are currently active participants in land-use planning issues, energy consultations, outreach and environmental education, Yukon Water Board hearings, and Yukon Environmental and Socio-economic Assessment Act applications.
We regularly participate in the YESAA process. There isn't a month that goes by that YCS does not submit comments on a wide variety of projects. I checked over past records, and during 2014, I submitted to YESAA on behalf of YCS comments on 18 unique projects, and I’m but one of four employees at YCS who submit comments. We like to think our comments are helpful and informative to the YESAB staff so that the recommendations they prepare on projects ensure that impacts to the environment are minimized.
As you have probably heard before, we are concerned about four changes being proposed in Bill S-6. Our concerns are as follows. Clause 14 of Bill S-6 proposes adding the following after subsection 49(1):
49.1 (1) A new assessment of a project or existing project is not required when an authorization is renewed or amended unless, in the opinion of a decision body for the project, there is a significant change to the original project that would otherwise be subject to an assessment.
The term “significant change” is too vague and subjective. YCS is concerned that under this change, projects would be assessed once and then major expansions or cumulative minor expansions such as a mine developing further open pits or an oil company gradually drilling more wells within its existing lease area would not undergo the additional environmental assessments necessary to identify and develop mitigation for economic, environmental, and societal impacts. This is not acceptable.
Second is modification to the time frames in clauses 16 and 17 and subclause 23(2) in Bill S-6. I won't read the wording, but YCS is of the opinion that these proposed changes would shorten the timelines for environmental assessments. Under current legislation, the clock starts ticking only once all the documentation submitted by the project proponent has been reviewed and is deemed adequate. Bill S-6 would start the clock as soon as documentation was submitted by the proponent, not after an adequacy review had been completed.
The proposed changes would run the risk of reducing the time available to conduct a thorough adequacy review. This review is critical to ensuring all appropriate documentation has been submitted prior to the assessment commencing.
The third concern of YCS regards policy direction. Clause 34 of Bill S-6 would add the following:
121.1 (1) The federal minister may, after consultation with the Board, give written policy directions that are binding on the Board with respect to the exercise or performance of any of its powers, duties or functions under this Act.
This proposed change would seem to undo the intent of Yukon devolution, whereby responsible government was transferred to Yukon territorial legislature and away from Ottawa. Furthermore, the proposed change undermines the very foundation of YESAB as a transparent, public process through which all stakeholders are provided the opportunity to learn about and submit comments on projects proposed in Yukon.
Given that the nature of future binding policy directions from Ottawa is unknown, will there be any consultation with Yukoners prior to orders being issued from Ottawa that will have economic, social, and environmental implications for the people and the environment in Yukon?
YESAA is meant to be arm’s length from interference by politicians, proponents, and special interest groups. Let's keep it that way.
A fourth concern regards delegation of the federal minister's powers. Bill S-6in clause 2 would replace section 6 of YESAA with the following:
6.1 (1) The federal minister may delegate, in writing, to the territorial minister all or any of the federal minister’s powers, duties or functions under this Act, either generally or as otherwise provided in the instrument of delegation.
This proposed change does a disservice to the honour of the crown as a signatory of the Umbrella Final Agreement, from which YESAA was created. The UFA is a political document between the Government of Canada, the Government of Yukon, and Yukon first nations as represented by the Council of Yukon First Nations. This has always been seen as a tripartite agreement between these three levels of government.
This proposed change could be interpreted as the federal government abandoning its constitutionally entrenched responsibilities under the UFA by delegating federal obligations to the Yukon Government. This is unacceptable.
As a helpful suggestion, YCS respectfully suggests that Bill S-6 could include a clause that lays out a periodic review of the YESAA legislation. This will ensure that YESAA is reviewed on a regular basis, such as once a decade, and is amended when necessary in an up-to-date and timely fashion.
Thank you for the opportunity to submit these comments. If you have any questions, of course I'm available.
Conservative
The Chair Conservative Blake Richards
Certainly. Thank you very much.
Our last presentation will be from Karen Baltgailis.
Following your presentation, we will go to questions.
Karen Baltgailis As an Individual
Hello.
Thank you to the Kwanlin Dün First Nation and the Ta’an Kwäch’än Council for hosting these hearings in their traditional territories.
Thank you to the standing committee for the invitation to present.
I was executive director of the Yukon Conservation Society from 2006 to 2014. Before that I was their forestry coordinator. During my time with the conservation society I participated in many YESAB assessments and took part in the YESAA five-year review.
My interest in presenting as an individual stems from the fact that Yukon first nations final agreements are the law for all Canadians. They are embedded in the Canadian Constitution. The Yukon Environmental and Socio-economic Assessment Act is one of the most important tools for implementing the final agreements. As you've heard here from so many first nations today, the Government of Canada is breaking Canadian law by unilaterally imposing four contentious amendments upon YESAA.
Like most of the speakers you've heard today, I oppose the following four changes to YESAA that are proposed in Bill S-6, the four changes that are so contentious. Of these four proposed amendments, to my knowledge, the public consultation for the YESAA five-year review only consulted about timelines, none of the others. As well, the consultant's report suggested longer timelines for assessments. The consultant's report did not recommend legislated timelines. Therefore, none of these changes to YESAA can validly be considered to stem from the five-year review.
I will briefly comment, just like everybody else, on each of the four proposed amendments.
Allowing the Government of Canada to delegate its powers to the Yukon government is not consistent with the Government of Canada's fiduciary duty. The Umbrella Final Agreement and individual land claims agreements were signed by all three parties. It's not consistent with the honour of the crown for Canada to abdicate these responsibilities. Furthermore, as a less directly involved government, one would hope that Canada would be less susceptible to local political motivations for approving projects, and should provide a more unbiased approach to assessments.
Allowing the Minister of Aboriginal Affairs and Northern Development to provide binding policy direction to the YESAA board is a very disturbing proposal. YESAB is meant to be an independent body, not subject to the political goals of the federal minister. The minister could influence things like timelines and what is considered an assessment. Looking at the four contentious changes proposed by Canada to Bill S-6, one can predict that this kind of policy direction would likely be aimed at weakening YESAA.
Regarding the proposed legislated timelines for assessments, as you know, some of the assessments that go through YESAA are extremely complex. To do its job, YESAB needs the time to comprehensively review projects, get expert advice, and solicit more information from the proponent. First nations and the public also need time to do research, possibly engage experts, and respond.
It appears to me, from looking at the YESAA website, that the timelines proposed in Bill S-6 for executive committee screenings would reduce the executive committee screening from a maximum of approximately 30 months to 16 months—so about half the time. There's of course the risk that as a result there would be inadequate assessments. Furthermore, the board's policies and guidelines already include timelines for assessments. YESAB has the knowledge and experience to determine appropriate timelines. In my opinion, the federal government does not.
The proposal that no new assessments would be required for the renewal of projects, or amendments to permits and licences, if a decision body deems there are no significant changes is frankly frightening. I'll give you an example of the kind of situation that this change could make possible. It's an issue that is very top-of-mind for Yukoners right now.
Let's say an oil and gas company underwent an environmental assessment of a drilling program that did not include hydraulic fracturing. Later they want to amend the project to include this controversial process. The Yukon government could decide that no new environmental assessment was required, and the Yukon public would never even know. The impacts of fracking from the project might never be assessed.
But even if a project hasn't changed really significantly and the company is applying for a renewal of a permit, the environmental and socio-economic conditions surrounding the project may well have changed due to things like climate change. There may be changes to wildlife populations in the area for completely other reasons. Water quality impacts, cumulative assessments—all of those things need to be looked at even if a project doesn't involve significant changes.
Furthermore, just even extending the time period of a licence does imply significant changes to the project. With a mining project, for example, there are more tailings, more water impacts, more waste rock to dispose of, and so on. Of course extended time periods for projects need to be assessed.
In conclusion, I'm concerned that a number of organizations that had important information to contribute were not able to present to these hearings. For example, I understand that Mike Smith from the Assembly of First Nations was not given an opportunity to present, although he wanted to. He was one of the negotiators of Yukon land claims. He would have been an expert witness who would have made an important contribution.
I was also surprised that the Yukon Fish and Wildlife Management Board was not allowed to make a presentation as a land claims mandated body. Furthermore, the grassroots organization Yukoners Concerned About Oil and Gas Exploration and Development was also denied the opportunity.
I have to wonder what other well-informed and relevant people and organizations were also excluded from the process.
I appreciate the standing committee making the effort to come all the way to Yukon to hear from Yukoners. I have to admit that I'm a little nervous that these eleventh-hour consultations may not have a lot of meaning, when Bill S-6 has already had two readings. I very much hope that this standing committee will prove me wrong and that you will advise the Government of Canada to uphold the laws of Canada by dropping the four controversial amendments to YESAA.
Thank you.
Conservative
The Chair Conservative Blake Richards
Thank you.
I will point out, just for your information, that this is typical of what committees do. After the second reading of a bill, the study is done, so this is a typical process in that regard. But I do appreciate your comments.
We will move to questioning from members, with five minutes for each member.
We'll start with Mr. Bevington.
NDP
Dennis Bevington NDP Northwest Territories, NT
Thank you, Mr. Chair.
Thank you for the testimony today from the witnesses.
I want to talk a little bit about the federal government's attitude about Yukon and just get your reaction to it. Here's the Honourable Bernard Valcourt speaking about the changes or the amendments that are going forward:The government had already proceeded with changes to the Nunavut and Northwest Territories regulatory regimes, and it is important for all northerners, wherever they are in the north, to benefit from the same legislative framework....
Then, in an answer to Mr. Leef on the delegation authority, he stated the following: This amendment is consistent with other northern legislation, namely the Mackenzie Valley Resource Management Act and the Nunavut Planning and Project Assessment Act, where these provisions exist.
So really, what the government is saying here is that we need to have a cookie-cutter approach to northern development.
I just find this bizarre, knowing the north—knowing Yukon and what kind of arrangement it has going, knowing what the Northwest Territories is composed of, which is seven different aboriginal governments that all have regional authorities. Then we have Nunavut, a single government based on a land claim. Do you see any relevance to Yukon in what the government's talking about here, that we should have the same system for these three territories?
I'll just let you all answer that.
Conservation Campaigner, Canadian Parks and Wilderness Society, Yukon Chapter
I would agree with you. I'd say no. We have different devolution agreements. We have different first nations. We have the Umbrella Final Agreement, which is different from what we have in the NWT or what we have in Nunavut.
At the moment, YESAA addresses a set of Yukon-specific issues. The north is not consistent. The eastern Arctic is very different from the west. We can't just cookie-cutter it. We have different impacts going on. We have different industries coming in. It is important that it be suited to our home territory.
Director, Tourism Industry Association of the Yukon
I guess I could answer this by a question from my side, right? For me in Yukon, the YESAA is a strong and very important piece of what works in Yukon and possibly in the rest of Canada. It's a strong example of how these kinds of issues of assessment processes for the region, for first nations, and for everything involved can be dealt with.
Really, here's my question in regard to what you're saying. Is there maybe an interest for generalization in certain processes that work in other areas, such as the Northwest Territories, Ontario, or even Quebec? Is this an attempt to generalize and simplify a well-running system that works in Yukon, one that has a strong hold and has its purpose, in an attempt to simplify and make it more adjusted to maybe what the most common directions are in the federal legislation?
Mining Analyst, Yukon Conservation Society
Yes, the comments you've quoted are a bit disturbing. We tend to regard this move to try to standardize environmental assessments, not just across the north but in Canada, as almost a race to the bottom. You find a jurisdiction that has, from the environmental point of view, the worst or lowest form of assessment and then try to apply it across to other jurisdictions.
It's not very helpful in protecting the environment. Actually, I would argue that it does a disservice to industry as well, because if you don't have decent environmental assessment, you're going to have horrendous issues later on, which companies are often on the hook for, especially when we come to projects that go wrong, whether it's mining, or forestry, or whatever.