Environmental Assessment
It’s hard not to sympathize with those who want to drastically change provincial and federal government environmental assessment processes. You only have to suffer through one or two, witnessing seemingly endless meetings, memos, draft terms of reference, real terms of reference, draft reports, real reports, and the obligatory sprinkling of highly structured consultations — all much more concerned about process and bureaucratic milestones than substance — to know something is seriously wrong.
The problem, however, is not so much the amount of time these processes take. The problem is that in the end they typically do not address the most fundamental question that major project developments entail — are these major projects in the general public interest? As tedious and detailed the impact assessments are, they do not meaningfully investigate whether, to what extent, and for whom the projects offer economic or other benefits. And they certainly don’t consider whether those benefits offset the risks of adverse impacts and other social and environmental costs the projects will inevitably give rise to.
The process itself has become a substitute for the sensible airing of a project’s benefits and costs. Proponents and their supporters in government just want to get through what they see as a bureaucratic hurdle, convinced that the economic benefits far outweigh whatever risks and costs the projects entail. The fact that there may be no net benefits, because of shortages of skilled workers (limiting the benefit of the job creation), major power requirements (imposing costs on existing ratepayers), exchange rate effects (hurting other industries), new public infrastructure and service requirements (paid for by taxpayers) does not matter. The assumption of benefits is a matter of faith, not the result of publicly-vetted, methodologically sound analysis.
Opponents may want to debate the issue of benefits versus costs, but typically are restricted in what they can raise or what the review panel will consider. For them the only option is to use the process to delay and ultimately stop projects they do not want to proceed, where they are convinced that the adverse impacts and risks far outweigh whatever benefits the projects may entail.
As for the the bureaucrats managing the process — they just want to play by the legislated rules, satisfying all legal requirements with whatever tedium and redundancy is required to avoid court action. The goal is not so much to shed light as to avoid the darkness of even longer delays and ministerial wrath.
All in all it is a remarkable and frustrating waste of resources for a scandalously limited scope of inquiry. Details abound; meaningful analysis and insight are in short supply.
Change is needed, but not the change the feds brought in. The feds clearly just wanted to tilt the process game in their favour. Fewer formal reviews and shorter time frames mean quicker approvals.
Shorter time frames are good if and when they can be achieved. However,what is really required for the assessment of major projects is a broader scope of inquiry — one that explicitly addresses the question of the public interest. We need better, not shorter assessment processes.