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environmental & social impacts lessons learned Q & A references links Power Point Presentation |
Assessment
of Aboriginal issues
Methodology
The assessment of issues of importance to
Aboriginal communities was done by:
-
Describing
the existing environmental conditions focusing on the issues of importance;
-
Prediction
and assessment of the likely effects of the Reference Project including the
identification of plausible interactions and measurable changes;
-
Identification
of the likely effects of the Project;
-
Consideration
of opportunities to mitigate the effects and identification of effects that remain
following proposed mitigation (i.e. residual effects);
-
Prediction
and assessment of likely effects as a result of the Alternative Project
Scenarios following the method used for the Reference Project;
-
Evaluation
of the significance of all residual adverse effects and
-
Identification
of follow-up monitoring programs to ensure that effects are as predicted.
Most issues were determined to have no
measurable change or residual adverse affects. However, two issues regarding
First Nations were furthered for further assessment:
|
First
Nation Issues furthered for assessment |
Bruce
Power Assessment |
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No
measurable change in health is likely since the SON reserves are located
outside the area in which the air quality, traffic degradation and health
care effects are expected. Although no residual adverse effects are
identified from a radiological perspective, a potential interaction during
the Operations Phase was advanced for further assessment since a radiation
dose of any magnitude is a concern to members of the First Nations
communities. |
The
highest dose to the Saugeen First Nation community, the closest First Nation
community to the Bruce Power site, from the Reference Project will be 0.7% of
the regulatory dose limit of 1000uSv/yr. This is considered negligible. |
|
A
measurable change to economic viability (tourism) is likely due to the
decrease in the availability of tourism accommodation during the Construction
Phase. The decrease in availability could bring increased revenue to the
First Nations as a result of increased tourism demand (this impact was not
noted in the section on Aboriginal interests). |
The
Saugeen First Nation is located in a high-demand tourism area with
6,000-8,000 annual visitors and 1,250 rental or leased cottages. It is likely that, in the event of
increased demand for tourist accommodation, the Saugeen First Nation cottage
industry could operate at an increased capacity, which in turn would generate
increased revenue for the community. This is a likely beneficial effect. |
Issues that will need assessment if Bruce Power
proceeds with the Project:
-
The
Construction Phase could result in the physical alteration of the areas
encompassed by the First Nations' land claim to their traditional territories.
The First Nations claim of Aboriginal title to their traditional territories
under the waters of Lake Huron and Georgian Bay could be affected by infilling
of MacPherson Bay, construction of the cofferdam and construction of the intake
and discharge tunnels.
-
The
SON has also launched a claim for Aboriginal title to their traditional
territories under the waters of Lake Huron and Georgian Bay. The area of
disturbance to the lake bed as a result of the Construction Phase is approx
0.55ha for the intake and discharge tunnels and 8.3ha for the infilling of
MacPherson Bay. This area is small relative to the full area of the claim and
the modification to the lake bed will not affect the validity of the claim.
This issue requires discussion between the First Nations and Bruce Power if
Bruce Power makes the decision to proceed with the Project.
Mitigation
There are no likely adverse affects identified
on either First Nations or Mtis communities as a result of the Reference
Project or Alternative Projects - no alternative is assessed as being
preferable to the Reference Project with regards to Aboriginal interests.
Therefore Bruce Power has determined that no additional mitigation measures
beyond those inherent within the Project design are identified. As well, no
likely residual adverse effects to Aboriginal Interests are identified as a
result of the normal operation of the Project. There are no likely adverse
effects on the sustainability of the renewable surface water resource or the
fisheries resource as a result of the Reference Project and each of the Alternative
Project Scenarios. Overall, there are no likely adverse effects on the
renewable resources used by First Nations or Mtis in their respective
traditional territories and no further assessment is required.
However, considering the importance of the First
Nation fishery to their livelihood, further studies on Lake Whitefish should
have been conducted (see section on weaknesses).
Follow-up
The final follow-up program will be developed through peer and
public review as well as discussions with the following groups, at a minimum:
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The
CNSC, DFO and other federal regulatory agencies;
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Provincial
regulatory agencies including the MOE and MNR;
-
The
Municipality of Kincardine;
-
Community
organizations such as the Lake Huron Fishing Club, Saugeen Field Naturalists
and the Lake Huron Centre for Coastal Conservation; and
-
Members
of the Saugeen Ojibway Nations and the Saguingue Mtis Council.
The methods to consult on the follow-up program will be
similar to those used throughout the EA process and will include, at a minimum,
the following:
-
Notification
of stakeholders;
-
Workshops;
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Posting
of information on Bruce PowerÕs website; and
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Documentation
of comments and how they are addressed.
Since no significant adverse effects to aquatic biota (specifically Lake Whitefish larvae) there will be a continuation of on-going studies to determine extent of use of spawning shoals with no additional monitoring is required during the construction phase. During the operations phase it is simply recommended to quantify the presence of whitefish in the vicinity of the Bruce Power site.
The Responsible Authorities (CNSC, DFO and Transport Canada)
have the overall responsibility to ensure that appropriate mitigation measures
are implemented and the follow-up monitoring is designed and carried out.
Weaknesses
There are currently no active Mtis land claims
in Bruce or Grey Counties; however, these issues are not thoroughly discussed
in the EIS as Bruce Power simply states that these are issues that will require
further discussion if Bruce Power makes the decision to proceed with the
project.
As well, the EIS doesnÕt mention the
population of the two reserves. Only says that they are 1.9% of the population
of the Regional Study Area is Aboriginal.
Aboriginal traditional Knowledge may be obtained
through the review of published information and through dialogue with
Aboriginal communities. In section 2.6.2.1 the literature review of four
documents containing SON traditional knowledge is described. However, there is
clearly a problem with the obtainment of tradition knowledge through dialogue.
A traditional knowledge questionnaire was drafted for use in mid-2007 and was
submitted to the SON for review. This questionnaire was supposed to be
distributed to community events during August 2008 but it is not clear what
happened with this questionnaire, if it was ever distributed or if it was
incorporated into the EIS.
As well, interviews with the Saugeen First
Nation program directors were conducted but the directors were unable to
provide traditional knowledge themselves and referred the EIS consultants to a
community traditionalist. It is stated in the EIS that attempts were made to
obtain interviews with the program directors of the Chippewas of Nawash Unceded
First Nation but could not be conducted within the timeframe of the EIS. An
interview with a traditionalist on the Saugeen First Nation reserve was
discussed with the band administration; however, a consensus on the scope of
the interview could not be reached within the timeframe of the EIS.
The Review Panel submitted a request for
information regarding Aboriginal Issues. They stated that Òaccording to Table
14.2.4-1 the effect of increased temperature on Lake Whitefish spawning and
recruitment will be a minor residual adverse effect. Given the likely
importance of this topic to First Nations interests, further information is
requested in Section 15 (preliminary follow-up monitoring program) on how this
finding will be addressed relative to past efforts on the same topic. Bruce
Power has an existing EMS for Lake Whitefish that was implemented in 2003
(Chippewas of Nawash website, 2007). They could simply include this monitoring
program in the EIS with added measures for the construction phase.
In the EIS Bruce Power provides a summary of pre-submission
AND a summary of post-submission SON involvement methods and outcomes with a
list of activities, the dates, the topics and documents discussed and principal
outcomes. However, with regards to the Mtis, there is only one summary
providing this information for both pre- and post-submission involvement
methods and outcomes. Clearly there was much less dialogue with the Mtis than
with the First Nations groups.
Most VECÕs suggested at workshops and public
reviews are not included in the EIS as they were not considered good indicators
or there were other indicators that were very similar. However, due to public
complaint Round Lakefish was requested by the review panel to be incorporated
Another possible weakness is the lack of
consultation with American stakeholders. This Project is near the border with
Michigan and could involve trans-boundary issues. Bruce Power mentions sending
information to American NGOs but never mentions if or how they participated.
Strengths
Overall the EIS compliance with the Terms of
Reference is good; as well, the methodology and types of consultation used to
gather information were thorough and clearly stated in the EA report as well as
the results of the consultation regarding the questions and concerns of local
communities. Bruce Power clearly understands the importance of community
support with regards to nuclear projects.
Bruce
Power has an overall good relationship with the local Aboriginal communities. Objectives
for involvement of First Nations were developed through discussion between the
SON Chiefs, Chief Nadijwan and Chief Kahgee, and the Bruce Power President and
CEO, Duncan Hawthorne, in December 2006. These objectives include:
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Inform
SON leaders and their communities about the Project, in a timely and on-going manner,
as appropriate;
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Develop
an understanding of the SON, their communities and traditional knowledge and
how they might potentially be affected by the Project;
-
Provide
support to the SON to encourage their meaningful participation in the
environmental assessment;
-
Consider
and respond to the SON«s concerns and issues relating to the Project;
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Facilitate
SON review and discussion on the EIS and supporting technical studies.
In
September 2007, the SON hired an EA co-ordinator, funded by Bruce Power, with independent
reporting to the SON Environmental Office. The funding provided by Bruce Power
is also intended to supplement the funding made available to SON through the
CEAA«s participant funding program. Bruce Power also agreed to provide capacity
funding to the Saguingue Mtis Council to facilitate their involvement.
A Protocol
Agreement was signed on May 23, 2008 at the Administration Office of the
Saugeen First Nation. This agreement outlines the working arrangements between
SON and Bruce Power throughout the balance of the EA process. This agreement
also enables additional capacity funding to be provided retroactively to the
SON for activities since the beginning of the process.
Bruce
Power has been collaborating for the last five years with the SON on research
regarding aquatic environment supporting the Aboriginal commercial fishery
which harvested Lake Whitefish in the eastern main basin of Lake Huron. Bruce
Power has also maintained good relations with the Mtis since its 2001
inception and sponsored the formation of the MNO Chartered Community Council in
2002. The Saguingue Mtis Council also participated in the collaborative
research on the lake whitefish fishery.
Since
Bruce PowerÕs inception in 2001 they have maintained good community relations and
Duncan Hawthorne, the CEO, has even been called the ÔKind of KincardineÕ by the
local media.
Consultation
with DFO biologists relating to the possible infilling of MacPherson Bay led to
the identification of three alternative approaches and the selection of the
alternative requiring the least infill. This consultation resulted in an 80%
reduction of the area to be infilled compared with Bruce Power«s original
proposal.
Comparison
with Hydro QuebecÕs Gentilly-2 Nuclear Generating Station
Hydro
QuebecÕs Gentilly-2 nuclear power station is located near Becancour, Quebec.
The main difference: between the Bruce Power nuclear station and Gentilly-2 is
that Gentilly-2 is smaller with only one operating reactor. Hydro-Quebec
submitted an EIS in February of 2006 regarding refurbishment of the reactor in
order to extend its life from 2007 to 2040. Eventhough the proposal is of a
much smaller scale than the Bruce Power project both projects encountered the
same issues.
Unlike the
Bruce Power EIS, in the Gentilly-2 EIS, Hydro Quebec gives has a section
entitled Portrait
gnral des communications sur Gentilly-2 where it gives a summary of public
engagement methods and activities since commissioning in 1974. This would have
been beneficial in the Bruce Power EIS as it presents a big-picture of overall
public engagement and puts into context the relationship between the Project
and the Public. Bruce Power has a section entitled Community Relations since
their inception in 2001 but they donÕt describe the public engagement methods,
only the funding they have provided to First Nation projects. However, Hydro
Quebec does not describe their previous relationship with the local Aboriginal
group.
Both groups
held workshops regarding VECs. Bruce Power only incorporated two publicly
suggested VECs but Hydro Quebec makes no mention of any of their VECs coming
from public consultation. Therefore in this regard Bruce Power was more
successful in engaging the public; perhaps the methodology they used was better
developed than that of Hydro Quebec or perhaps they were clearer in
communicating the requirements for selecting VECs.
Both companies
respect and carefully abide by the regulatory requirements regarding public
engagement.
With regards
to distribution of information and public consultation Hydro Quebec and Bruce
Power used very similar methods. The methods employed by Hydro Quebec are:
-
Analysis
of environmental reports on Gentilly-2 from 1993 to 2001;
-
Analysis
of public polls on health and safety risks from 1986, 1991, 1993 as well as new
polls in May and June of 2003 regarding refurbishment and perceptions of risk;
-
Public
opinion surveys – the survey was administered by telephone to a
sample
of
800 adults distributed in different regions of the province. Results were analyzed:
approval rating was generally between 65 and 70% from 2003 to 2005;
-
Group
discussions - Six
interviews with discussion groups made up of 12 interested people from the
public;
-
Two
workshops regarding VECs were held in 2002. Results were reconfirmed in 2003
during public consultations;
-
Development of a
consultation programme began in 2003;
-
Newsletters–
distributed to 1600 people;
-
Information
telephone line;
-
Hydro-Quebec
welcome office;
-
Email;
-
Internet
site for the project;
-
Information
column published in a number of regional weekly newspapers from 2003-2005;
-
Analysis
of published articles on Genilly-2 in the press (the analysis showed an approval rating
of 67 to 79% during 2002 to 2004);
-
Articles
published in magazines regarding various subjects concerning Gentilly-2
(propaganda);
-
Public
notices in newspapers regarding information events, public hearings and open
houses;
-
Invitations
for information events and open houses were sent to all residents of
surrounding municipalities – 68,500 homes;
-
Documentation
posted by Hydro-Qubec in response to requests for information;
-
Information
Kiosks in local towns and municipalities;
-
Videos
regarding Gentilly-2 are available to the public;
-
Open-houses;
-
Media
relations – press releases, press conferences, interviews with
journalists;
-
Individual
meetings with mayors, deputies and Aboriginal leaders;
-
Meetings
with target organizations;
-
Information
events and public consultations;
-
Questionnaires were distributed at the public information
meetings and analyzed in 2003;
-
Hydro
Quebec participated in a nuclear debate was held on October 9th, 2003,
organized by a college in Trois-Rivires; the aim was to permit the exchange of
information and education;
-
Le Plan des mesures
dÕurgence nuclaire externe (PMUNE) was
incorporated into the public consultation plan;
-
Meetings
of members of the Table of Information Exchange (TIE) –
comprised of 9 members from regional organizations including the First Nation
Community of Wolinak. However, Aboriginal members pulled out of these meetings
following their opposition to the project in 2003. The other members included two representatives from the town of Becancour and the municipality of
Bcancour, one representatieve each from the Conseil rgional de
lÕenvironnement du Centre-du-Qubec (CRECQ), the Chambre de commerce de
Bcancour, the Centre local de dveloppement (CLD) de Bcancour, the Confrence rgionale des lus du
Centre-du-Qubec (CR, rgion 17), the Confrence rgionale des lus
de la Mauricie (CR, rgion 04) and the Socit du parc industriel et
portuaire de Bcancour.
This Table of
Information Exchange was an important part of their consultation process. In
2004, the members of the TIE held two meetings where Hydro-Qubec resented a
summary of the impact study conducted in January of 2004 and a summary of the
study conducted on the Projects economic impacts on the region.
Hydro Quebec is much more detailed in
describing its methodology and includes several forms of engagement not used by
Bruce Power such as analysis of local media coverage, publishing a weekly
information column in local newspapers and participation in a debate with the
theme of La
central nuclaire de Gentilly doit-elle tre rnove ou ferme? As well, the
organization of a ÔTable of Information ExchangeÕ was an interesting way to
approach group discussion.
Another
difference was that Hydro Quebec ordered the results of the public consultation
into 8 themes and addressed them accordingly in the EIS. This is perhaps a
better method than the one used by Bruce Power who addressed the top 10
questions in the body of the EIS, as the themes cover more ground giving a
better overall view of concerns and we can always go to the Appendix to see the
specific questions.
The
question themes for Gentilly-2 are:
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Environment
and health;
-
Social
impacts;
-
Management
of radioactive waste and storage;
-
Emergency
plans and the security of storage of waste;
-
Decommissioning
and dismantlement of Gentilly-2;
-
Electric
shocks;
-
Economic
impacts;
-
Nuclear
energy in Canada and around the world
Bruce
Power has better relations with the local Aboriginal groups compared to Hydro
Quebec. Bruce was successful in signing a protocol agreement with both the SON
and the Mtis. More involved with Aboriginal groups through sponsorship of
activities and events, development of Native Circle at plant, collaborative
research on Lake Huron Lake Whitefish fishery. On the other hand, Hydro Quebec
was not successful in engaging the local Aboriginal group, Wolinak. Following
several meetings between the band council and Hydro Quebec representatives in
2003 the band submitted a letter of opposition against the project. The band
council declined all invitations to participate in meetings in 2004 and 2005.
Hydro Quebec was met with a demonstration against the project in September of
2005.
Lessons
Learned
Public
consultation is not just a means to gain support but can be very effective in
providing the proponent with useful information. For example, public
consultation resulted in new VECs and in finding an alternative for the
infilling of MacPherson Bay which resulted in an 80% reduction in the area to
be infilled.
The
obtainment of Traditional Knowledge can be very complicated. Aboriginal
communities are often not willing to provide this information if they do not
think it will be beneficial for them to do so. The gathering of this
information requires great sensitivity and patience on the part of the
proponent.
Videos
Life at
Bruce Power
(http://www.youtube.com/watch?v=j05R-nJxEsM)
Citizens
for Bruce C
(http://www.youtube.com/watch?v=W61JHQa9OMs)
References
Major Projects Management Office, Government of Canada: Early Aboriginal Engagement: A Guide for Proponents of Major Resource
Projects. Retrieved March
15, 2009 from http://www.mpmo-bggp.gc.ca/desc/aboriginal-autochtones-eng.php
Department of
Justice: Canadian Environmental Assessment Act. Retrieved March 15, 2009 from http://laws.justice.gc.ca/en/C-15.2/
UNEP: Environmental Impact Assessment Training Resource
Manual, 2nd Edition. Topic 9:
Review of EIA Quality. http://www.unep.ch/etu/publications/EIA_2ed/EIA_E_top9_tit.PDF
Nuclear Energy
Agency Organisation For Economic Co-operation and Development: Society and
Nuclear Energy: Towards a Better Understanding: Retrieved April 6, 2009 from: http://www.nea.fr/html/ndd/reports/2002/nea3677-society.pdf
Kleinu, S., coordinator for Citizens for Renewable Energy
(2009, Jan 8). Round Whitefish and VECs. [Email to program funding officer]. Canadian
Environmental Assessment Agency.
Chippewas
of Nawash website. (2007). Retrieved April 5, 2009 from: http://www.nawash.ca/index.shtml