So you want to build a mine. You’ve done exploratory drilling, released a resource estimate, and you are prepared to move ahead at this site. The next critical phase will last several years. It will go a long way in determining whether your project, economics aside, is allowed to proceed. And it probably will cost a few million dollars. It is time to think about the environmental assessment (EA).
Beginning with the preparation of an environmental impact statement and concluding with the granting of approval, the EA is a company’s best attempt at predicting and planning for the effects its project will have on water, air, soil, plant life, wildlife, and human inhabitants, for the next ten, hundred, or thousand years to come. From its beginnings in the 1970s, the Canadian process has become more voluminous, more expensive, and more extensive in scope.
While changes to environmental regulation have been made to help accelerate the process in Canada, there are strategies a company can use to keep things moving – and to hold its costs in line.
“The bottom line is that environmental assessments have become more and more complex over time,” says Rick Hoos, principal consultant at EBA Engineering Consultants Ltd. “And they continue to become more complex.”
Advances in science have added to the standard inclusions in an EA. More sophisticated statistical models are now available, enabling researchers to make more confident and detailed predictions about possible impacts their projects may have on air, water quality or other aspects of the environment. A growing awareness of climate change has forced project proponents to consider their greenhouse gas emissions and how their environmental management plans will hold up under unpredictable conditions.
“Environmental impact statements continually raise this question: What is being proposed now – is that going to be good years from now in the face of climate change as predicted?” says Paul Wilkinson, vice-president, environmental and social affairs at New Millennium Iron Corp., which is developing a series of iron ore deposits along the Quebec-Labrador border. “If you’re relying on the fact that things remain frozen, and if you’re faced with the possibility that permafrost is melting, then what would be the consequences?”
But another reason EAs are more complex is that their scope has expanded, says Jeff Barnes, senior principal, environmental management at Stantec. In scoping a project assessment, regulators decide what laws apply, how the project is defined, what needs to be studied, and what level of detail is required.
Scoping naturally changes and expands to accommodate new concepts and concerns. Where an earlier EA would have taken a creek as the unit of study, for example, a complete assessment now looks at the creek’s watershed. But the task of determining a project’s scope falls to the individuals who oversee environmental assessments. Workforce demographics and turnover in regulatory agencies and consultancies, explains Barnes, has positioned young personnel in decision making roles they may not be prepared for. They respond to growing environmental concerns by broadening the scope of EAs. “We came very early, both in the literature and in guidance, to the conclusion that you need to focus an environmental assessment on the things that are important,” he says, referring to the EA veterans who helped refine practices in the late 1970s and the early 1980s. “You just can’t study everything. It’s just not feasible, it’s not practical, and we can’t afford it.”
The cumulative effects of development have taken a front-and-centre role in the gradual expansion of scope. Project proponents are asked to evaluate the impact of past projects, as well those that might be built in their area in future. Under the rubric of cumulative effects study, the global impacts of mining as an industry can and do take over the approval process for an individual project. “I often go to a mining EA hearing or public meeting, and people ask, ‘Why aren’t we recycling more?’” Barnes says. "It’s quite rational for the public to want to ask that question. But I think that regulatory authorities, when they’re scoping, shouldn’t be adding things like ‘Comment on the worldwide recycling of this metal’ to the EA process.”