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Comments on the Discussion Papers on the Proposed Project List and the Proposed Information Requirements and Time Management Regulations

MiningWatch Canada submitted these comments on the Discussion Paper on the Proposed Project List and the Discussion Paper on the Proposed Information Requirements and Time Management Regulations under the proposed Impact Assessment Act, Part 1 of Bill C-69, An Act to enact the Impact Assessment Act and the Canadian Energy Regulator Act, to amend the Navigation Protection Act and to make consequential amendments to other Acts that were published on May 1, 2019.

We conclude that:

Environmental assessments should make mining projects better from a technical and environmental protection perspective, but they should also provide a participatory public forum to allow people to assure themselves that the highest standards are being applied and that community concerns are being appropriately and adequately addressed, especially if the rights and title of Indigenous peoples may be affected. In addition to assisting in meeting other legal obligations, this helps provide the project with a social licence to operate. Allowing mines to escape this scrutiny based on an arbitrary production threshold does no favours to the public, the environment, or the proponent. If there is some reason that we have been unable to discern that requires a threshold to be set, it should be set based on reasonably anticipated environmental and sustainability impacts.