kuyek ea review submission

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Expert Panel Review of Environmental Assessment Processes November 8, 2016 Submission from Joan Kuyek, DSW

Thank you for this opportunity to present to the Expert Panel. I would like to say at the outset, that I completely support the proposals put forward by the Environmental Reform Summit in May 2016, and I will not reiterate them here. I will focus on the following five areas: 1) 2) 3) 4) 5)

The Need and Purpose of a project: Socio-Economic Impact Assessment as integral to EA The need for a proper risk-benefit analysis of proposed mining projects Voluntary and involuntary stakeholders: time and onus issues Problems with the registry and the need for a proper archival retrieval system Regional EA: recognizing perpetual care and the need to heal “sacrifice zones”

I lived in Canada’s largest mining-affected community, Sudbury, for thirty years where I was deeply engaged in community work and moved to Ottawa in 1999 to be the founding national coordinator of MiningWatch Canada. After I retired from Mining Watch in 2009, I have continued to be a consultant to mining affected communities, and I have been teaching Mining Law, Policy and Communities at Queens University, for five years. I am also the Chair of Ontarians for a Just Accountable Mineral Strategy Since 1999, I have been engaged in over 20 environmental assessments of mining projects in Canada including Diavik, Victor, Kemess North, Tulsequah Chief, Prosperity, New Prosperity, Raven Coal Mine, Niocan, Harper Creek, Giant Mine, Ajax and Sisson. My comments derive from my experience with these EAs. 1) The Need and Purpose of a project: Socio-Economic Impact Assessment as integral to EA One of the most eloquent descriptions of why the discussion in the EIS of “Need and Purpose” is so important was written by Anthony Hodge in Seven Questions for Sustainability- for the Mines Minerals and Sustainable Development Initiative of the International Council of Mines and Metals (2002). “If there is a fundamental question underneath all others, it is the question of whether society—or the world—“needs” any given project or operation. A significant debate has emerged regarding what would constitute a full needs assessment. The debate encompasses mining and minerals but also covers all other interventions in the natural environment as well—dams, irrigation projects, highways, pipelines and even urban expansion. The question arises because of growing concern that current human activity is undermining the capacity of future generations to meet its needs. This concern is a central driver of the sustainability/sustainable development set of concepts and the issue is very simple: why do something that is undermining the capacity of future generations?

2 In market economies, governments accept the proponent’s feasibility study along with their willingness to invest as a demonstration of need. If the proponent believes that a market exists for the product, need is established. For its part, the proponent will consider existing and projected demand and supply (as reflected in commodity price) and use that value to ascertain project/operation profitability. The assessment of financial feasibility and profitability is confidential and not open to public scrutiny in order to protect the competitive position of the proponent.”1 Currently, it is in the section entitled Need and Purpose of the Project, where the EIS should address the key questions of sustainability. This is not the case. Invariably in EA submissions, mining project proponents describe the need for and purpose of their project in terms of a market for the metal or metals that they want to extract: tungsten, molybdenum, copper, gold. This is usually accompanied by data on employment provided, “revenues to government” and contribution to GDP. Most EAs also include a section on “benefits to Canadians” which reiterates the company’s promotional information. . Although a lot of a data is available in the EIS about health, social and economic impacts and benefits, these sections are not integrated into the discussion of need and purpose or the assessment of “Benefits to Canadians”. Consultants prepare separate sections including health risk assessment, labour and housing statistics, community health data and section specifically about the affected indigenous people and resource users most affected. In my experience, these sections are often of questionable merit an almost always lack understanding of effects on vulnerable populations. An example of this problem can be found in the EIS for the Victor Diamond mine (2005). In one of the Appendices to the EIS, DeBeers specifically said that it would be difficult for the community of Attawapiskat to take advantage of employment and contracting opportunities at the mine and that the mine might raise expectations and increase population in the first Nation. The information was never integrated into the conclusions of the EIS nor into the final CSR. In 2009, during the Prosperity Mine Conformance Review, I went line by line through hundreds of pages of consultant data about socio-economic baseline and effects, and found many places where assertions were made without any substantiation, where links were provided to non-existent other parts of the report, and where analysis was just plain wrong. As examples of problems in these sections in the EIS, here are two of many critiques from that Conformance Review. There were many other problems. a. The Economic Analysis provided a simplified version of the population that will be affected by the mine, and did not examine if the project would contribute to equity and justice for affected peoples over the long-term.  Mining projects are notorious for the creation of an “Intrusive Rentier” syndrome, an observed effect in regions dominated by a small number of highly capitalized (and high wage) employers- not addressed.  Effects on existing community economic development initiatives. Not addressed. 1

MMSD North America 2003. IISD . 2002. Seven Steps to Sustainability: how to assess the contribution of mining and minerals activity, Page 33 https://www.scribd.com/document/5046502/mmsd-sevenquestions-mining

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No analysis of the impacts of increased wage inequality due to higher mine wages. No gender analysis of the mine’s likely impacts, although women’s wages in the RSA were 3/5 of men’s on average, and there was already substantive evidence of violence against women.  No analysis of what happens when local businesses shift their focus to supplying the mine from their current focuses: what will happen to their current customers? Where will these businesses get credit to shift their focus? What happens to them when the construction period ends? When the mine closes either during a bust or at the end of its life?  No analysis of the consequences of the loss of mine incomes and contracts post closure, or in the event of an economically induced shut-down b. The Human Health Risk Assessment did not address the WHO Social Determinants of Health, but was only a baseline study of potential toxicity in country foods. a. The Risk Analysis model was fraught with undeclared assumptions. b. The modelling was not “ground-truthed” with testing of human or animal tissue to see if the modelling made sense in the real world, c. The modelling did not include impacts on particularly vulnerable populations What can be done to solve this problem? It is the responsibility of governments to make this determination of sustainability. Reflecting on the B.C. Government’s responsibility to assess the financial ability of a P roponent to fund mitigation and compensation costs in the EA process, Justice Afleck wrote in 2013: [126] I view the entire environmental assessment process, and the decision-making role of the ministers following receipt of a report, along with the executive director’s recommendations, as a “risk/benefit” analysis. The ultimate task of the ministers was to make a decision about the certificate after taking into account the technical analysis of environmental effects conducted by the EAO; the views of those affected by the project, prominent among which was the objections of First Nations; the risk of long term environmental damage and very substantial remediation costs if mitigation measures were not entirely successful, as well as the benefits to the people of this province of an employment and wealth generating project. They were then to weigh the risks against the benefits and decide whether it was in the public interest that the risks were worth taking.2 Basically, what is required is a Social Economic Impact Assessment (an SEIA) as an intrinsic part of the EA review. The questions and tools to do this have been well-developed already Guidance for undertaking this can be found in:  

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The Canadian Handbook on Health Impact Assessment, Volume 3: A Report of the Federal/Provincial/Territorial Committee on Environmental and Occupational Health, 2004 The Mackenzie Valley Environmental Impact Review Board (MVEIRB). A major study and consultation was undertaken during the creation of the Board which addressed many of the questions that are being asked by the Expert Panel today. The report provides valuable

Afleck, J. (obiter). Pacific Booker Minerals Inc. v. British Columbia (Environment), 2013 BCSC 2258 (CanLII), http://canlii.ca/t/g29tr obiter dicta

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guidance: Issues and Recommendations for Social and Economic Impact Assessment in the Mackenzie Valley3; Robert Gibson. Sustainability-based assessment criteria and associated frameworks for evaluations and decisions: theory, practice and implications for the MacKenzie Gas Project Review, January 2006.4

The Canadian Handbook on Health Impact Assessment, Volume 3: A Report of the Federal/Provincial/Territorial Committee on Environmental and Occupational Health” is the result of almost ten years of consultations. It is no longer available online, so I have submitted the Table of Contents and a summary of key points as an Appendix to this paper. The report sets out key concepts and issues that traditionally have not been adequately considered within the context of EA and/or health impact assessment (HIA). Among the issues it considers are  due consideration of stakeholder values,  social impact assessment (SIA),  economic evaluation of development projects,  indigenous HIA,  concepts and methods of environmental epidemiology,  occupational health  food issues The Mackenzie Valley Impact Review Board spent a great deal of time and effort grappling with the same questions, as did the Gibson paper for the Mackenzie Gas Panel Review. I urge the Expert Panel to revisit these studies, as they provide valuable guidance on how the questions of Need and Purpose should be analysed and determined. 2. The need for a proper risk-benefit analysis of proposed mining projects. Increasingly, mining projects are being submitted for EA that either have not done a bankable feasibility study, have one that is seriously flawed, or is very out-of-date. Since the metals price crash of 2011, most reserve and resource estimates are overly optimistic and out-of-date, are premised upon commodity prices that are considerably higher than current prices, and on exchange rates that are 2030% off current rates. The economic vitality of the project has to be assured if it is to meet its obligations for mitigation and closure planning. The Tulsequah Chief Mine is a case in point. Having gone through an EA, it went bankrupt. The new owners (who were in fact a different corporate configuration of the old owners) then proceeded through another EA with a different plan for shipping the ore out. They also went bankrupt. Meanwhile, the old mine workings continue to leak acid mine drainage into the Tulsequah and Taku Rivers, damaging salmon stocks. In terms of the risk-benefit assessment of the mine proposal, the following questions must be part of either regulation or operational policy statements:

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http://www.reviewboard.ca/upload/ref_library/SEIA_paper.pdf https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1663015

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Has the affected area already developed a socio-economic plan that obviates the need for the mine? As an example, the Raven Coal Mine was proposed for an area that had already spent over eight years developing a regional economic plan for the area- “A New Provence” - involving 1000’s of people and millions of dollars, when the Raven Coal Mine was proposed. The Mine was likely to destroy the shellfish industry at Fanny Bay. Eventually, the BC government cancelled the EA. Does the region/ country really need the metal that the mine will extract? Gold? Diamonds? What is their social utility? Is recycling or conservation a better option? According to the recently released report from UN’s International panel for Sustainable Resource Management, Assessing the Environmental Impacts of Production and Consumption5 , recycling metals can result in lower energy use and less ecological damage. What are the trade-offs in terms of long-term (and often perpetual) waste management for this project? Will a ten year mine result on hundreds of years of waste management for a toxic byproduct that in fact exceeds the amount of rock dug from the ground? Will the proposed mine be economically profitable enough to meet its commitments to protect the environment and future generations? Has a bankable feasibility study been conducted that accurately predicts the costs of extracting the metal(s)? What costs have been externalized to the natural environment, First Nations, government, the communities affected and private businesses and not included in the company’s costing? What will be the impacts of increased income inequality occasioned by the project to the community, First Nations, local economies and the region? 6

Three panel decisions that provide precedents for this approach to mining projects: The Bilcon Whites Point Quarry project was proposed for an area with its own sound community economic development plan. The panel found: “Based on its comprehensive synthesis and analysis of all the information provided, the Panel found that the Project would have a significant adverse effect on a Valued Environmental Component represented by the “core values” of the affected communities. The Panel’s review of core values advocated by the communities along Digby Neck and Islands, as well as community and government policy expectations, led the Panel to the conviction that the community has an exceptionally strong and well-defined vision of its future. The proposed injection of an industrial project into the region would undermine and jeopardize community visions and expectations, and lead to irrevocable and undesired changes of quality of life. In addition, the Project would make little or no net contribution to sustainability.” In Kemess North, the Panel determined:

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Raphael, D., Macdonald, J., Labonte, R., Colman, R., Hayward, K., & Torgerson, R. (2004).Reserarching Income and Income Dsitribution as determinants of health in Canada. NCBI Pubmed, May 2005. https://www.ncbi.nlm.nih.gov/pubmed/15802156

ttp://www.unep.org/resourcepanel/Portals/24102/PDFs/PriorityProductsAndMaterials_Report.pdf

6 The Kemess North Mine Joint Review Panel (the “Panel”) has concluded that development of the Kemess North Copper/Gold Project (the “Project”) in its present form would not be in the public interest. In the Panel’s view, the economic and social benefits provided by the Project, on balance, are outweighed by the risks of significant adverse environmental, social and cultural effects, some of which may not emerge until many years after mining operations cease…. The Panel’s main finding is based on a comprehensive synthesis and analysis of the information provided to the Panel regarding adverse and beneficial Project effects. These effects were used as the basis for the assessment of the pros and cons of Project development from a range of perspectives. One of the most important components of a panel review is to integrate public values, as well as government policy expectations, into the review process. In order to weigh the Project development pros and cons in the context of public values and policy expectations, the Panel chose to adopt what it considered to be an appropriate sustainability assessment framework. The Panel has considered the Project from five sustainability perspectives: Environmental Stewardship; Economic Benefits and Costs; Social and Cultural Benefits and Costs; Fairness in the Distribution of Benefits and Costs; and Present versus Future Generations. The Panel notes that the Project’s benefits accrue for only a relatively short period (two years of construction and 11 years of mining production). This period could be reduced if the Project, which is not economically robust, were to close prematurely. Key adverse effects include the loss of a natural lake with important spiritual values for Aboriginal people, and the creation of a long-term legacy of environmental management obligations at the minesite to protect downstream water quality and public safety. These obligations may continue for several thousand years, and include ongoing treatment of poor quality water from the open pit (the “North Pit”), and regular monitoring and maintenance of the waste disposal impoundment (the “Duncan Impoundment”) and its three dams, to preserve the desired water balance and water chemistry in the Impoundment and to ensure the health of its aquatic ecosystem. The Panel also notes that it may be difficult for Aboriginal people to increase their share of Project benefits, although as the region’s primary residents and users, they would experience first-hand any impacts on traditionally used resources. New Prosperity Mine. Similar reasoning was used by the Panel to turn down the New Prosperity mine, as the Panel felt the Tsilhqot’in would unduly bear the cultural, social and economic costs of the proposed mine, whereas the benefits would accrue elsewhere. 1. Voluntary and involuntary stakeholders: timelines and onus The Health Canada paper cited above makes the point that there are two kinds of stakeholders in any industrial project: voluntary and involuntary stakeholders. The voluntary stakeholders are usually the proponent of the project and those who choose to invest in it, those who have been able to make a decision to build it or not. The involuntary stakeholders are really everyone else: the indigenous original

7 occupants of the property and downstream from its effects, the communities affected by the project, the governments that need to regulate it. Common sense would say that those whose participation is involuntary should be able to determine whether the project can proceed, the extent to which they wish to invest time and energy in studying and monitoring it, and the extent to wish they are willing to endure trade-offs. The onus should be on the proponent to prove that the project is to their benefit. In practice this works the other way. A mining company finds what they think is a mineable deposit and demands that all the involuntary stakeholders accommodate their agenda and self-imposed deadlines. This is unbelievably disruptive to the plans of the involuntary stakeholders for economic-social-cultural development and takes valuable energy and money from other activities

2. The Registry The federal registry has a number of very serious problems:  

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It does not have a key word, author and/or subject search engine and as a result requires hours of time to find particular submissions Submissions by the public are now summarized. Interestingly, when there are a lot of proand-con” submissions, no indication is given to how many submitted on each side. In the case of the Red Chris Mine EA, all the public consultation submissions opposed the mine, but one had to read all of them to find this out. Archived submissions are very difficult to find and/or retrieve, and in fact, many are no longer available. Generally they are archived by the RA. I made a request for all the submissions on the Victor Diamond Mine EA and was sent a summary of the EIS. Another request for the submissions during Kemess North took months to find out where the materials were archived. During EA hearings, very important data and analyses are submitted by highly competent experts, but they quickly become unavailable for future reference, unless a copy has been kept by the submitter. Often the submitter cannot be found or identified, or may not choose or be able to share what they found (as the proponent was their client). The consequence is that there cannot be accurate followup on predictions from experts, and for EAs on similar projects, reference cannot be made to analysis already done. As an example, very valuable gender analysis of the mine projects done during Voisey’s Bay and Mackenzie Gas is only available from the women’s groups that submitted during these projects. Making the registry effective will require the unearthing of these EA documents which have been buried and finding out which have been destroyed) , providing the means to archive them properly and to search them, and then making them available to the public.

8 3. Regional EA: perpetual care and the need to heal and contain sacrifice zones There are large areas of Canada that have become “sacrifice zones”. They are polluted by industrial activity and cannot be “remediated”. They will require care, monitoring, and emergency response capability forever. These sites include the Giant Mine in Yellowknife and the Faro Mine in the Yukon, the chemical valley in Sarnia, areas in and around Trail, Sudbury, Cobalt, Timmins, Rouyn-Noranda, Sydney, the uranium mines in northern Saskatchewan and so on. Any discussion of Regional Environmental Assessment will have to take these zones into account and make a decision about how these areas are to be contained and – to the extent possible - how the land and waters are to be healed and restored. Currently, there are two approaches to the EA of new projects in these areas:  

The project is considered to be an expansion of an existing project and does not require an EA, or The baseline environmental data is already so debased by pre-existing industrial pollution that the proponent is granted an exemption to water quality objectives, etc. For example, a river is not considered to be “fish-bearing” because the fish are already dead. Or, the background arsenic levels in Yellowknife or Falconbridge are already so high, that more pollution is not considered to be a problem.

I submit that this is unacceptable, and that any discussion of principles for sustainable EA and intergenerational equity has to include a mandate to improve the conditions of areas that are already debased by industrial activity.

9 APPENDIX

The Canadian Handbook on Health Impact Assessment, Volume 3: A Report of the Federal/Provincial/Territorial Committee on Environmental and Occupational Health, 2004 Excerpts from the document and Table of Contents Values, Health, and Environmental Assessments: Values allow us to differentiate between costs and benefits and play an essential role in decisionmaking. Deciding on whether to proceed with a given project will therefore depend on how the values of the project’s stakeholders are factored into the decision-making process….To assess the impact of a project on the health of those likely to be affected by it, an EA must identify how the project will affect the capacity of its stakeholders to realize their needs and aspirations. This requires: 1) identifying those likely to be affected by a proposed project; 2) identifying and including the full range of values important to those likely to be affected; and 3) properly understanding the stakeholders’ values…perception and acceptance of risk vary, depending on the interests and agendas of different stakeholders By identifying all stakeholders and analysing how specific impacts (both positive and negative) affect different stakeholder groups, SIAs have the potential to ensure that the benefits of the project are equitable. The social environment is described in SIAs in terms of demographics and population characteristics, community and institutional structures, political and social resources, individual and family changes, and community resources. The types of social impacts identified in SIAs include 1) impacts on population; 2) impacts on community resources; 3) land use and occupancy patterns; and 4) economic impacts. An economic tool known as the “benefit transfer” technique is often used to valuate potential health effects. This technique involves using estimates from existing research (based on the primary methods cited above) to valuate the health benefits and detriments of the development scenarios under consideration. The main advantage of benefit transfer is that the process is less expensive and timeconsuming than primary valuation techniques. Finally, advice is provided on integrating the valuation of health impacts into the overall economic analysis (i.e., what baseline should be used; how to account for the timing of benefits and costs and also for inflation; how to treat non-quantified benefits and costs; how to account for uncertainty; and how to treat distributive effects and equity considerations). Indigenous Health Impact Assessment: Chapter 5 outlines HIA methods and approaches identified by indigenous communities in Canada. It points out certain general trends, activities, and needs in the area of HIA that are recognized by all or most of the indigenous communities, as well as by some national organizations of indigenous peoples. Indigenous HIA is based on three concepts: 1) indigenous communities rely heavily on naturalized knowledge systems (NKS); 2) HIA is very closely linked to EIA; and 3) HIA as a process depends on measurement and evaluation of health indicators, and indigenous communities themselves must develop their own specific community health indicators. Environmental Epidemiology and Health Impact Assessment: Epidemiology combines statistical and medical investigation methods to study the distribution and the determinants of health-related states and events in populations. Its ultimate purpose is to improve the public’s health by contributing to the

10 prevention, mitigation, or treatment of health problems. Chapter 6 focuses on development projects that have potential health impacts on the surrounding population and for which studies of an epidemiological nature need to be considered Environmental epidemiological studies serve a number of purposes: 1) to assess the health status of populations exposed to suspected environmental sources of pollution and to identify potential health problems; 2) to identify more vulnerable subgroups within environmentally exposed populations; 3) to assess the health risks or effects of environmental exposures; and 4) to assess the contribution of environmental factors to suspected environmental diseases, deaths, or other health conditions. Considerations Relating to Worker Health Protection: Workers are the individuals most likely to be exposed to high levels of hazardous substances on a daily basis over a working lifetime. They are most at risk by virtue of the “dose-response relationship” that is fundamental to toxicology. Thus, when conducting an HIA relating to a development or remediation project, it is important to consider the potential impacts – both positive (e.g., jobs and related benefits) and negative (potential hazards/risks). Food Issues in Environmental Impact Assessment: As an integral part of EAs for both development and remediation (contaminated site) projects, risk assessments of contaminant levels in foods must be undertaken. In general, it has been the practice to develop models to estimate levels of contaminants in country foods harvested in the study area. Although this modelling approach is considered acceptable, it does result in an uncertain degree of conservatism due to the variety of methodologies, calculations, and assumptions involved. In any case, a standardized procedure in regard to potential contaminants in country foods is imperative for risk assessment and sound management decision-making. The risk assessment methodology described in Chapter 8 has been designed to serve as a general outline. TABLE OF CONTENTS ACKNOWLEDGMENTS ................................................................................................. 2 EXECUTIVE SUMMARY................................................................................................. 4 CHAPTER 1:INTRODUCTION .................................................................................. 1-1 CHAPTER 2: VALUES, HEALTH, AND ENVIRONMENTAL ASSESSMENTS ....... 2-1 2.1 Introduction ................................................................................................. 2-1 2.2 What Values Are .............................................................................................. 2-1 2.3 Stakeholder Values in the Environmental Assessment Process............... 2-2 2.3.1 Step 1: Stakeholder Analysis .............................................................. 2-3 2.3.2 Step 2: Identifying the Full Range of Relevant Values..................... 2-4 2.3.3 Step 3: Understanding Stakeholder Values....................................... 2-5 2.4 Identifying Core Values................................................................................... 2-6 2.5 Identifying Use Values .................................................................................... 2-7 2.5.1 Instrumental Values ............................................................................. 2-8 2.5.2 Essential Values.................................................................................... 2-9 2.5.3 Symbolic Values ................................................................................... 2-9 2.6 How to Build Values into the Environmental Assessment Process ....... 2-12 2.6.1 Step 1: Project Description............................................................... 2-13 2.6.2 Step 2: Scoping ................................................................................... 2-14 2.6.3 Step 3: Determining the Significance of Project Impacts ............. 2-15 2.6.4 Step 4: Determining Mitigation and Follow-up............................... 2-16 2.7 Concluding Observations ............................................................................ 2-17 2.8 References and Suggested Readings .......................................................... 2-17

11 CHAPTER 3: SOCIAL IMPACT ASSESSMENT IN ENVIRONMENTAL IMPACT ASSESSMENT PROTOCOLS: A SOCIAL SCIENCE PERSPECTIVE.... 3-1 3.1 Introduction ..................................................................................................... 3-1 3.2 Social Impact Assessment and Health Impact Assessment Linkages...... 3-2 3.3 Mandate for Social Impact Assessment ....................................................... 3-4 3.4 Social Impact Assessment Defined and Described .................................... 3-5 3.4.1 Definition............................................................................................... 3-5 3.4.2 The Social Impact Assessment Team................................................ 3-6 3.4.3 Benefits of Social Impact Assessments............................................. 3-6 3.4.4 Key Steps in a Social Impact Assessment ........................................ 3-6 3.4.5 Public Involvement in Social Impact Assessment........................... 3-8 Canadian Handbook on Health Impact Assessment November 2004 Volume 3 18 3.4.6 Misconceptions about Social Impact Assessments ........................ 3-9 3.5 Social Environment Described in Social Impact Assessments ............... 3-11 3.5.1 Demographics and Population Characteristics............................. 3-11 3.5.2 Community and Institutional Structures ........................................ 3-12 3.5.3 Political and Social Resources ......................................................... 3-12 3.5.4 Individual and Family Changes ........................................................ 3-12 3.5.5 Community Resources ...................................................................... 3-13 3.6 Types of Social Impacts Identified in Social Impact Assessment........... 3-13 3.6.1 Impacts on Population ...................................................................... 3-14 3.6.2 Impacts on Community Resources.................................................. 3-14 3.6.2.1 Impacts of a Large Workforce ........................................... 3-14 3.6.2.2 Impacts on Cultural Resources......................................... 3-14 3.6.3 Impacts on Land Use and Occupancy Patterns ........................... 3-15 3.6.4 Economic Impacts ............................................................................. 3-15 3.7 Methods and Tools in Social Impact Assessment .................................... 3-16 3.7.1 Sampling.............................................................................................. 3-17 3.7.2 Data Collection................................................................................... 3-18 3.7.2.1 Literature Review................................................................ 3-19 3.7.2.2 Observation ......................................................................... 3-19 3.7.2.3 Interviews ............................................................................ 3-20 3.7.2.4 Household Surveys and Questionnaires ......................... 3-20 3.7.2.5 Participatory Tools............................................................. 3-21 3.7.3 Concerns about Social Impact Assessment Methodology ........... 3-21 3.8 Challenges Facing Social Impact Assessment Practitioners ................... 3-22 3.9 Conclusion ..................................................................................................... 3-23 3.10 References and Suggested Readings .......................................................... 3-23 CHAPTER 4: ECONOMIC APPRAISAL/EVALUATION OF PROJECTS .............. 4-1 4.1 Introduction ..................................................................................................... 4-1 4.2 Economic Analysis: An Overview ................................................................. 4-2 4.2.1 What Are the Major Components of an Economic Analysis? ........ 4-2 4.2.2 What Basic Principles Do Economists Employ to Measure Benefits and Costs? ............................................................................. 4-4 4.2.2.1 Willingness to Pay/Accept as the Measure of

12 Project Benefits ..................................................................... 4-4 4.2.2.2 Opportunity Cost as the Measure of Project Costs ......... 4-5 4.2.3 How Do These Principles Apply to the Valuation of Health Effects? ................................................................................................. 4-5 4.3 Primary Methods Applied to the Valuation of Health Effects................... 4-6 4.3.1 Stated Preference Methods ................................................................ 4-7 4.3.1.1 Contingent Valuation ............................................................ 4-7 4.3.1.2 Conjoint Analysis .................................................................. 4-8 4.3.1.3 Risk-Risk Trade-offs .............................................................. 4-8 4.3.2 Revealed Preference Methods ........................................................... 4-9 4.3.2.1 Wage-Risk Studies ................................................................. 4-9 4.3.2.2 Cost-of-Illness Studies ........................................................ 4-10 4.3.2.3 Averting-behaviour Studies ............................................... 4-11 4.4 Benefit Transfer Techniques ....................................................................... 4-12 4.4.1 Overview of Benefit Transfer ........................................................... 4-12 4.4.2 General Approach to Benefit Transfer in Valuing Morbidity Risks ... 4-13 4.4.2.1 Step 1: Describe the Project Case..................................... 4-14 4.4.2.2 Step 2: Identify Relevant Studies ...................................... 4-15 4.4.2.3 Step 3: Review Relevant Studies for Quality and Applicability...... 4-16 4.4.2.4 Step 4: Transfer the Benefit Estimates............................. 4-19 4.4.2.5 Step 5: Address Uncertainty.............................................. 4-21 4.4.3 General Approach to Benefit Transfer in Valuing Mortality Risks ..... 4-21 4.4.3.1 Value of Statistical Life ....................................................... 4-21 4.4.3.2 Value of Statistical Life-Years ............................................ 4-22 4.4.3.3 Summary of Studies............................................................ 4-22 4.5 Integrating the Valuation of Health Impacts into the Overall Economic Analysis....... 4-24 4.5.1 What Baseline Should Be Employed?.............................................. 4-24 4.5.2 How Should the Timing of Benefits and Costs Be Accounted for? ................ 4-25 4.5.3 How Should the Analysis Account for Inflation? ........................... 4-26 4.5.4 How Should Non-quantified Benefits and Costs Be Treated?...... 4-27 4.5.5 How Should Uncertainty Be Accounted for? ................................. 4-27 4.5.6 How Should Distributive Effects and Equity Considerations Be Treated?................ 4-28 4.6 References and Suggested Readings .......................................................... 4-29 20 CHAPTER 5: INDIGENOUS HEALTH IMPACT ASSESSMENT............................ 5-1 5.1 Introduction ..................................................................................................... 5-1 5.2 Naturalized Knowledge Systems................................................................... 5-1 5.3 Comparison of Indigenous and Non-indigenous Health-related Environmental Impact Assessment Methods.............................................. 5-3 5.3.1 Context ..................................................................................................5-3 5.3.2 The Akwesasne Environmental Impact Assessment Process........ 5-5 5.4 Indigenous Community Health Indicators................................................... 5-7 5.4.1 The Need for Community Health Indicators.................................... 5-7 5.4.2 The Life Indicators Wheel................................................................... 5-8 5.4.3 Comments from the Communities..................................................... 5-9 5.4.4 Methodology for Indicator Development ....................................... 5-10 5.4.5 Cultural Sustainability and Community Health Indicators .......... 5-11 5.5 References and Suggested Readings .......................................................... 5-13

13 CHAPTER 6: ENVIRONMENTAL EPIDEMIOLOGY AND HEALTH IMPACT ASSESSMENT................................................................................. 6-1 6.1 Introduction ..................................................................................................... 6-1 6.2 Epidemiological Study Designs ..................................................................... 6-3 6.2.1 Experimental Studies........................................................................... 6-3 6.2.2 Observational Studies ......................................................................... 6-5 6.2.2.1 Cohort Study ......................................................................... 6-5 6.2.2.2 Case-Control Study ............................................................... 6-9 6.2.2.3 Cross-sectional Study......................................................... 6-12 6.2.2.4 Ecological Study.................................................................. 6-13 6.2.2.5 Comparative Advantages of the Main Epidemiological Study Designs ...................................................................... 6-16 6.3 Data Sources for Epidemiological Health Impact Assessment ............... 6-18 6.3.1 Population Data.................................................................................. 6-18 6.3.2 Disease/Health Outcome Data ......................................................... 6-18 6.3.2.1 Mortality............................................................................... 6-18 6.3.2.2 Cancer .................................................................................. 6-19 6.3.2.3 Morbidity (Disease/Injury) Databases............................. 6-19 6.3.2.4 Special Databases and Data Access ................................. 6-20 6.4 Health Impact Assessment: Suggested Approach .................................... 6-20 6.4.1 Context ................................................................................................ 6-20 6.4.1.1 Health ................................................................................... 6-21 6.4.1.2 Occupation .......................................................................... 6-23 6.4.1.3 Environment ........................................................................ 6-25 6.4.2 Prospective Data................................................................................ 6-25 6.4.2.1 Phase 1: Monitoring........................................................... 6-26 6.4.2.2 Phase 2: Risk Factor Identification.................................. 6-27 6.5 Conclusion ..................................................................................................... 6-28 6.6 References ..................................................................................................... 6-28 6.7 Suggested Readings ...................................................................................... 6-29 CHAPTER 7: CONSIDERATIONS RELATING TO WORKER HEALTH PROTECTION................................................................................ 7-1 7.1 Occupational Health Risks and Health Impact Assessment ..................... 7-1 7.2 Facets of, and Professional Disciplines in, Occupational Health ............. 7-5 7.3 Occupational/Environmental Hygiene ......................................................... 7-6 7.4 Occupational Disease and Its Prevention: Occupational Exposure Limits (OELs) as a Tool.................................................................................. 7-9 7.5 Occupational Hygiene Applied to Health Impact Assessment ............... 7-13 7.5.1 Prospective ......................................................................................... 7-13 7.5.2 Actual (Post-project Appraisal) ....................................................... 7-17 7.5.3 Biological Monitoring ........................................................................ 7-18 7.6 Pitfalls of Occupational Hygiene in Health Impact Assessment............. 7-18 7.7 References and Suggested Readings / Information Sources ................... 7-19 CHAPTER 8: FOOD ISSUES IN ENVIRONMENTAL IMPACT ASSESSMENT ...... 8-1 8.1 Introduction ..................................................................................................... 8-1 8.1.1 Regulatory Context.............................................................................. 8-1

14 8.1.2 Background........................................................................................... 8-2 8.1.3 Overview ............................................................................................... 8-3 8.2 Potential Contaminants, Available Foods, and Exposure Pathways........ 8-4 8.2.1 Identification of Potential Contaminants.......................................... 8-4 8.2.2 Identification of Foods Available in the Area................................... 8-7 8.2.3 Determination of Exposure Pathways for Potential Contaminants in Foods .. 8-7 8.2.4 Contaminants of Potential Concern (COPCs) .................................. 8-8 8.3 Hazard Assessment – Toxicology ................................................................. 8-9 8.4 Food Consumption Information.................................................................. 8-10 8.5 Monitoring and Background Data............................................................... 8-1122 8.6 Analytical Data .............................................................................................. 8-13 8.7 Human Health Risk Assessment: Contaminant Levels in Foods ............ 8-14 8.7.1 Risk Characterization: Calculations and Presentation ................. 8-14 8.7.1.1 Case Study #1: Development Project ............................... 8-16 8.7.1.2 Case Study #2: Contaminated Site Remediation Project .................................. 8-24 8.7.2 Conclusions and Recommendations............................................... 8-26 8.8 Review Requirements for the Draft Environmental Impact Assessment: Critical Timing ... 8-27 8.9 Risk Assessment and Risk Management.................................................... 8-27 8.9.1 Uncertainty in Risk Assessment ...................................................... 8-28 8.10 Concluding Remarks..................................................................................... 8-29 8.11 References ..................................................................................................... 8-29 8.12 List of Acronyms ........................................................................................... 8-30 APPENDIX A: VALUES THAT AFFECT ENVIRONMENTAL DIALOGUE: A LIST OF DEFINITIONS APPENDIX B: GUIDELINES ON THE SELECTION OF AN OCCUPATIONAL HYGIENE SPECIALIST APPENDIX C: TABLE OF PROVINCIAL CONTACTS REGARDING FOOD ISSUES APPENDIX D: MERCURY LEVELS IN FILET OF PIKE AND ARSENIC LEVELS IN THE MEAT OF CHICKEN APPENDIX E: REFERENCES PERTAINING TO THE FIRST NATIONS AND INUIT APPENDIX F: GLOSSARY (VOLUMES

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