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Scientific errors and ambiguities in prominent submissions to Canadian environmental assessments: 

A case study of the Jackpine Mine Expansion Project

Author: Sierra Raynea,
aChemologica Research, 318 Rose Street, PO Box 74, Mortlach, Saskatchewan, Canada, S0H 3E0

Keywords:
Environmental assessment submissions, Canada, Scientific c errors and ambiguities, Case study

In Canada, as in many other developed nations, natural resource development projects meeting certain criteria are required to undergo an environmental assessment (EA) process to determine potential human and ecological health impacts [1, 2]. As part of the Canadian EA process, the Canadian Environmental Assessment Agency (http://www.ceaa.gc.ca/) generally considers submissions (oral and/or written) by members of the public and experts. While the allowance of external submissions (i.e.,from sources other than the project proponent and/or government agencies) during EA hearings forms an important component of a functional participatory democracy, little attention appears to have been given regarding the quality of such EA submissions. In particular, submissions to EA hearings by prominent individuals and/or groups (particularly scientists and scientific c organizations) may be weighted more heavily in the overall decision making framework than those from non-experts. Important questions arise through the allowance and consideration of external submissions to EAs, such as whether inaccuracies in any such submissions may misdirect the EA decisionmakers to reach erroneous conclusions, and if such inaccuracies do result in sub-optimal EA processes (e.g., excessively long and/or expensive, potentially reaching decisions based on incorrect information, etc.), how the issues should be addressed.

In the current work, a representative recent external submission [3] by Dr. David Schindler from the University of Alberta as part of the broader Oil Sands Environmental Coalition (OSEC) submission to the Shell Canada Jackpine Mine Expansion (JPME) Project EA hearings (http://www.ceaa.gc.ca/050/details-eng.cfm?evaluation=59540) will be examined. The proposed JPME project is located in the Athabasca Oil Sands Region (AOSR) of northern Alberta near Fort McMurray, includes `mining areas and associated processing facilities, utilities and infrastructure," and is anticipated to \increase bitumen production by 100,000 barrels per day."

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