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Compliance of EIS with Terms of Reference:

Table A5 and Table A6 reviews the proponent’s compliance with the EIS guidelines that were outlined by the joint panel review. The first column indicates the guideline and its section, the second column states if the guideline was answered or not, and the third indicates the corresponding section of the EIS. The asterix indicates that the criteria was addressed but involved flaws or was missing certain parts.

Table A5

Table A6

Other Relevant documents pertaining to alternative requirements in EIS’s:

UNEP EIA Training Manual – Review of EIA Quality

The UNEP Training Manual for EIA review states that when taking into account the consideration of alternatives the following should be included in order to allow for a strong EIA:

-        The consideration of reasonable alternatives

-        A comparison between the different alternatives

EIA Center – University of Manchester paper: “Reviewing the Quality of Environmental Statements”

An occasional paper from the EIA Center at the University of Manchester titled – “Reviewing the Quality of Environmental Statements”, by Lee N and Colley R (1992) outlines relevant areas of consideration with regards to alternatives:

-        Feasible alternatives to the proposed project should have been considered. These 

should be outlined in the Statement, the environmental implications of each presented, and the reasons for their rejection briefly discussed, particularly where the preferred project is likely to have significant, adverse environmental impacts.

-        Alternative sites should have been considered where these are practicable

and available to the developer. The main environmental advantages and

disadvantages of these should be discussed and the reasons for the final

choice given.

-   Where available, alternative processes, designs and operating conditions

should have been considered at an early stage of project planning and the

environmental implications of these investigated and reported where the

proposed project is likely to have significantly adverse environmental

impacts.

Compliance of Alternatives to the Project to EIS guidelines and Overall Strengths and Weaknesses:

Strengths:

This section addressed all of the issues outlined in the guidelines that were provided by the joint panel review.

The overall quality and performance was well done – fairly easy to read and comprehend.

Weaknesses / Omissions:

Following the guidelines that were outlined by the joint review panel seemed almost religiously done and left no outside room for additional thought with regards to the topic at hand. 

Only addressed the criteria outlined in the Terms of Reference and did not seem to take the question of alternatives to the project seriously.

Regarding criteria 4 in the terms of reference, the guidelines state that -  “the EIS must explain how the proponent developed the criteria to identify the major environmental, economic and technical costs and benefits of the alternatives, and how the proponent identified the preferred project based on the relative consideration of the environmental, economic and technical benefits and costs.” – however there is barely any discussion about the environmental cost and benefits throughout the text – and the main focus is solely on the economic and technical feasibility. This is further proven by the specific exclusion of the environment in the design of the 5 selection criteria that was used in the screening process to determine the most appropriate alternative.

Related to this, it was found that the screening selection criteria were very limiting, leaving little room for any real viable alternative projects to be considered. For example one of the criteria states that the alternative project must be capable of being sited at the Bruce Power site on approximately 200-300 ha of land. This places a very narrow scope with regards to the consideration of alternatives.

Compliance of Alternative Means to EIS guidelines and Overall Strengths and Weaknesses:

Strengths:

This section followed the Terms of Reference well – giving descriptions in all the right places and attempting to make certain all guidelines were adhered to.

Addressed all but one of the issues outlined in the guidelines that were provided by the joint panel review.

The overall quality and performance was well done; the methodology used was easy to follow and make sense of - allowing the material to be understood by a larger audience.

The section makes many references to Bruce Powers compliance with IPSP and OPA standards for energy and their strong partnership with the Ontario government in regards to its energy policy.

Weaknesses / Omissions

Major omissions were discovered that hinted towards the lack of serious thought being given to this section.

The main EIS assesses 6 project scenarios throughout the document, however the technical support documents, which are intended to go into more detailed information, only look at 5. Project scenario 6, which incorporates alternative site D and is the final site alternative is not assessed among all the TSD. This omission was also found by the joint review panel and the correction of this missing information has been requested on March 11^th of this year. It is very confusing as to why the proponent would leave out all this pertinent information – and especially because alternative project scenario 6 ranked the highest out of all scenarios in the comparison assessment that was stated before (see Table A4 “Summary of Comparison of Alternatives”).

Both alternative scenarios 4 and 6 ranked higher than the reference project during the comparison of alternatives. It is stated in the document that – “based on these results there are some benefits to locating the Project at either Site B or Site D.” Seeing as how all the environmental studies completed in the EIS are based upon the reference project, it is a little misleading as to why so much focus resided with this option and not with the higher-ranking alternative scenarios.

An omission that is evident has to do with missing information regarding one of the guidelines outlined in the terms of reference. It is stated, “the EIS must describe the environmental effects of each alternative means” – this was not completed for the alternative means that were identified at the beginning but were not used in the reference project and the project scenarios. This brings up questions of uncertainty because if there were no environmental assessment completed for these missing alternative means in what capacity were they deemed unworthy? – There is no explanation for this in the text.

It is difficult to keep track of different Alternative Project Scenarios (APSs) and their respective components. For example Alternative Project Scenario #1 is the Air Insulated Switchyard. However, throughout the rest of the document it is only referred to as APS #1, thus causing difficulty for the reader to immediately recognize which APS the text is referring to, especially when there is a discussion concerning multiple APSs. This aspect was also found by the joint review panel and the proper adjustments have been requested.

UNEP EIA Training Manual – Review of EIA Quality

The rating scale for EIA Review that is provided within the UNEP training manual for EIA Quality is shown below in Table A7. With consideration of all the components of this section relating to Alternatives and Alternative Means to carrying out the project – A grade of B is awarded.

Table A7

Rating Scale for EIA Review: