Understanding SON's Recommendations for the Bruce C Impact Assessment
What is an Impact Assessment?
An Impact Assessment is a process used by regulators to evaluate the potential environmental, social, cultural, economic, and health effects of a proposed project before governments make approval decisions.
For projects that may affect Indigenous rights, responsibilities, and interests, the assessment must also consider how those may be impacted by a proposed project (like Bruce C) and what information is needed to understand those potential impacts.
The purpose is to gather the information necessary to support informed decision-making.
What are Regulators?
Regulators are the federal agencies responsible to implement the laws and rules for how a certain industry operates. For the Bruce C Project, the federal Impact Assessment process is being led by the Impact Assessment Agency of Canada (IAAC), in collaboration with the Canadian Nuclear Safety Commission (CNSC), Canada’s nuclear regulator.
What is the Impact Statement?
An “Impact Statement” is one of the most important documents in the current Canada’s Impact Assessment process. The Impact Statement is where the project developer, for Bruce C, this is Bruce Power, has to show how the proposed major project could affect the land, water, economy, and local communities. Bruce Power will have to submit this document to the regulators, IAAC & CNSC.
Why did SON submit 500+ requirements?
As part of the federal Impact Assessment process for the proposed Bruce C Project (the Project), Saugeen Ojibway Nation (SON) completed a detailed review of the draft Tailored Impact Statement Guidelines (TISG).
The TISG is an important document because it sets out what Bruce Power must study and assess before the Government of Canada will assess the impacts of Bruce C.
SON's review resulted in more than 500 initial requirements in the form of comments identifying where additional information, stronger methods, or different approaches are needed to ensure the assessment properly considers SON rights, interests, knowledge, and responsibilities.
These requirements submitted by SON are not a decision about the Project itself. They are very initial and are only to ensure that the information used to assess the project is as complete, accurate, and meaningful as possible.
What are the Tailored Impact Statement Guidelines?
The Tailored Impact Statement Guidelines (TISG) are developed by the regulators and informed by input from Indigenous Nations and communities, the public, government agencies and other participants. They are essentially the instructions for what must be in the Impact Statement. They identify the studies, information, and analysis that Bruce Power must complete as part of the assessment.
They cover a wide range of topics, including:
Fish and fish habitat
Water quality and groundwater
Wildlife and species at risk
Climate change
Cultural heritage and archaeology
Human health
Indigenous peoples
Aboriginal and Treaty Rights
Emergency preparedness
Cumulative effects
Socio-Economic
Long-term monitoring
SON reviewed every section of these Guidelines to identify where additional work is needed.
What Does SON Require?
SON's requirements focus on ensuring the assessment considers both scientific information and SON Knowledge, while providing a more complete understanding of how the proposed project could affect SON Territory, Rights & Interests, and SON Members.
Some of the key areas include:
Better Environmental Studies
SON requires stronger information about the historic state of the lands and waters, additional field studies to understand the current state of the lands and waters, and more comprehensive information to better understand potential effects before decisions are made.
Protection of Fish and Water
Lake Huron and the SON fishery are central to SON rights, culture, and livelihoods. Bruce Power cools its current facilities by pulling in cool lake water and pumping warmer water back out to the Lake. Because of this, SON requested additional studies related to fish health, fish habitat, water quality, thermal effects, groundwater, and long-term aquatic monitoring.
Recognition of Cumulative Effects
SON requires that the assessment consider Bruce C in the context of existing and historical development in the Territory rather than assessing Bruce C in isolation.
Protection of Cultural Heritage
SON requires additional archaeological investigations and cultural heritage studies to better identify, understand, and protect ancestral sites and culturally significant places.
Indigenous Rights
SON emphasizes that the assessment must meaningfully assess potential impacts to Aboriginal and Treaty Rights and that impacts to SON rights can not be appropriately determined by the proponent alone.
Community Health
SON requires that the assessment consider health in its broadest sense, including physical, mental, cultural, social, spiritual, and community well-being.
Long-Term Monitoring
SON required stronger follow-up monitoring, adaptive management, and ongoing collaboration to ensure potential impacts continue to be monitored throughout the life of the project.
Why does this matter?
The quality of an Impact Assessment depends on the quality of the information that is collected.
By providing detailed requirements at this stage, SON is working to help ensure that Canada’s federal assessment:
- reflects SON Knowledge alongside scientific information;
- meaningfully assesses impacts to SON rights and responsibilities;
- examines potential impacts thoroughly;
- identifies information gaps before studies are completed; and
- supports informed decision-making.
This work helps shape how the proposed project will be studied before any governments consider future decisions.
What happens next?
Bruce Power is now responsible for preparing the Impact Statement in accordance with the finalized Tailored Impact Statement Guidelines and is expected to address SON’s 500 requirements in developing the Impact Statement.
Once completed, the Impact Statement will be reviewed by regulators, SON, and the public as part of the federal Impact Assessment process.
SON will continue monitoring this process to advocate for and protect SON rights, responsibilities,interests, lands, waters, relatives, and future generations.
The complete 500 requirements submitted by SON can be viewed here:
https://iaac-aeic.gc.ca/050/evaluations/proj/88771/contributions/id/63936
Canada’s Impact Assessment Process May Change
Through Bill C-5, Canada is pushing for faster Impact Assessments. Canada is considering changes to the Impact Assessment Act that could affect how federal assessments are conducted, including assessments of projects regulated by the CNSC. SON is very concerned about what potential changes could mean for Bruce C. What any changes would mean for the Bruce C assessment process is still uncertain.
SON Leadership is actively working to protect SON rights and interests. That requires a strong, credible, and thorough assessment process for Bruce C. Anything less is unacceptable.
