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GUIDE 2: Environmental Impact Report comments. What else should YOU consider?

Yes, you can indeed, raise any issue under the sun with no supportive evidence during an EIA public request for comments. However, your comment will carry much more weight (and not risk landing up in file 13 – i.e. the rubbish bin) if your comment is supported by evidence or facts.

But whatever your situation, please do not let (or use) your “lack of expertise” to prevent you from trying to comment on the environmental impact concerns that you have.

 

With that in mind, here´s a few more tips that we’ve thrown together to assist you:

Before we start, just a friendly word of advice: Stay away from the temptation to just use a "boilerplate example, or just copy and paste someone else’s comment" - its guaranteed not to be taken serious and just ignored. The same goes for "petition type submissions", or just adding your name to one SINGLE submission.

Let's GO!

  1. Objectively evaluate the project and be VERY specific. Generalities can be dismissed with generalities.
    Consider the activities proposed as part of the project and determine if these actions will result in a direct or indirect impact or change to the physical environment.

  2. Would it be a negative impact? How? Why?
    Also consider your sources when providing evidence. Seek out recognized information; published data and reports whenever possible. Also, whenever possible, avoid sources that can be perceived as biased. As we've said before, you can simply raise an issue with no support – the burden of proof is on them – but if you have some data – give it to them! A project will in most scenarios, include many elements over an extended period of time, such as demolition of existing buildings prior to the start of construction of a site well; or construction of new buildings; or roads, etc.. It can (or should) also include actions by others that are necessary because of the project, such as temporary access roads, or a parking lot for heavy construction equipment, during the construction or drilling period, etc. Make sure the project description takes all of these related activities into consideration. Consider immediate and future impacts, and temporary and long-term impacts. These are generally associated with both construction and operation of the proposed projects. Short-term or temporary does not necessarily mean insignificant and the indirect impacts of a project, such as increased growth in an area or higher light levels at night may not be evident during construction or initial development.

  3. If an impact will occur, will it be substantial or “significant”?
    Significance is determined by the difference between what currently exists and what will exist during or following completion of the project. If you conclude there would be a significant adverse effect, does the document agree with that assessment? If not, why not or does it simply fail to discuss it at all?

  4. Generalities will be dismissed with generalities, so be specific!
    Do NOT assume the assessing Environmental Agency knows everything about your neighbourhood! The value of having multiple citizens comment is the fact that each person knows details about a specific location, that when added to the public comments, can actually change an environmental impact report.

  5. Separate your concerns into clearly identifiable paragraphs or headings and keep a tight focus on each separate issue. Don’t mix topics.

  6. Avoid saying (writing words such as) “I DON’T support the proposed Oil and Gas Exploration Project, but…” – just list your concerns or you run the risk of having your letter be classified as a letter of opposition instead of addressing your concerns. Or worse, your letter could be totally dismissed.

  7. Consider ways to avoid impacts or enforceable ways to reduce the severity of impacts. Quantify your objections whenever possible. If the impact is potentially significant, are there mitigations (ways to reduce the severity of the impact) included in the document? Will they reduce the impact to a less than significant level? For example, if trucks movement noise is an issue, would a noise barrier wall that reduces the noise below a certain level ibe considered to be an effective mitigation measure?

  8. All mitigations must be feasible and enforceable.
    If a potential significant impact has not been adequately identified; or
    if no mitigation has been proposed for a potentially significant impact; or
    if the mitigation proposed doesn’t appear to be sufficient or appropriate, then:
    · Identify the specific impact in question;
    · Explain why you believe the impact would occur;
    · Explain why you believe the effect would be significant; and, if applicable,
    · Explain what additional mitigation measure(s) or changes in proposed mitigations or to the project you would recommend.
    · Explain why you would recommend any changes and support your recommendations.

    Your reasons cannot simply be a subjective dislike for the entire oil & gas exploration project or a particular segment. You will need to objectively identify the deficiencies and explain the basis for your recommendations.

  9. If you cannot support the project as a whole, be sure to identify why you oppose it in as much detail as you can. Explain why it doesn’t work in your community or neighbourhood. For example, if there are vibration issues from drilling operations that could result in earthquakes affecting local water sources, point out current problems and how this project will make them worse. Quantify your objections whenever possible. Don’t just complain.

  10. Economic issues are usually not really properly addressed in public consultations. However, decision-makers consider them. If your comments address potential economic impacts, send a copy of your concerns to your Mayor, to your City Council, political leaders and local Members of Parliament .

  11. Whenever possible, present facts or expert opinions. If not possible, then provide personal experience or your personal observations. Don’t just complain. Explain the basis for your comments and recommendations (facts, reasonable assumptions based on facts, or expert opinion supported by facts) and, whenever possible, submit specific data and/or references supporting your conclusions. If you simply write, “I don’t like this project”, your comment may be logged as “Comment Noted” and nothing else!

  12. Include suggestions for making it better or offer specific alternatives and describe how they meet the requirements of the project. Your goal should be to write something that causes them to respond in a future document based on the evidence you have given.

  13. Point out any inconsistencies in the document or the data. Point out outdated information or errors in logic. Focus on the sufficiency of the Environmental Impact Report in identifying and analysing the possible impacts of the project on the environment.

  14. Write a comment that includes a valid name, and contact address. Submit it before the deadline.

  15. KEEP A COPY OF YOUR COMMENTS. They can be misfiled, misclassified or lost and you want to ensure there is a record of your comments.

  16. Send your comments in time, so that you ensure that your submission is included in the final evaluation report.

 

 

Disclaimer: The guidelines in this article is intended to serve as a guide and is not intended to be legal advice. Please seek professional help from a lawyer if you have legal questions or concerns.

 

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