On The Failure of Environmental Assessment

by Dr. Ian Goudie

David Vardy has raised some major concerns aimed at the failure of democracy to ensure that the Lower Churchill Hydroelectric Project (LCHP) minimized and mitigated negative environmental impacts. In this article, I elaborate on this theme to emphasize that science is also failing us. Reflecting back to public hearings on the environmental impacts of the Muskrat Falls Project many may recall the opening statement by Nalcor that this project would have no adverse environmental impacts. From the ‘get go’ the environmental impact statement (EIS) was a sham. It was a failure of science also. The World Commission on Dams 2000 (Dams and Development: A new framework for decision makingwww.internationalrivers.org) should have been the starting point for the EIS but was apparently completely overlooked because the WCD categorically concludes that one of the most far-reaching negative environmental effects of dams are on the downstream ecosystems. How was it possible for Nalcor to be released from Environmental Assessment for an EIS that ignored downstream effects? The matter resurfaced in the major public concern for methyl mercury contamination and public health but there are many more negative downstream effects of dams, and a responsible proponent would be well advised to integrate the many scientific recommendations of the WCD.

Science has become the demi-god of our western culture. Newfoundland icon Greg Malone repeatedly emphasizes that the environmental crisis is grounded in a spiritual crisis. As a culture, we have lost contact with the sacred, which is to say, we have lost contact with Nature. The general public is easily swayed by the notion that due diligence has been exercised, and these EA conclusions and recommendations are science-based. But reality is that our environmental assessment processes are failing us, and there are subtle reasons for this. Environmental assessments evolved and were entrenched in legislation by the early 1980’s. EAs were meant to be some sort on ‘independent’ scientific approach, i.e., independent of industry and government agendas. The concept was that they could be evaluated by the public, scientific community, and EA assessment committees of government. For the first decade or so, a diversity of small consulting companies and qualified individuals provided EA services to clients and public debates intensified.

By the late 1990’s, the EA consulting business was progressively co-opted by big business, particularly larger engineering conglomerates that then offered the environmental component as an add-on to the development agenda. Through this approach science became progressively “controlled”, i.e., filtered through the lens of the proponent via the lead environmental consultant. Most EIS documents are largely cut-and-paste exercises overloaded with general information but extremely light on identifying any impacts, and even lighter on providing meaningful measures for avoidance or mitigation of those impacts. Scientists are kept at bay through the process of subcontracting leaving information control to the prime consultant. What better a way to have to do nothing than claim there are no adverse environmental impacts! Our government scientists and environmental assessment biologists are muzzled, and such EISs are approved by Governments with an agenda to proceed. There is wide variation in the handling of EAs across Canada. NL would do well to align with provinces such as BC that require from proponents in their EIS submissions clear compensation when negative impacts are inevitable.

It is important to reflect on why this happens. We blame Nalcor without fully exploring the role of the lead consultants. The prime environmental consultants may amass an impressive “scientific” team but ultimately all the information is controlled and honed by a few individuals that often do not qualify as the senior scientists they purport to be. We witnessed a similar credibility fraud with the now defunct Institute for Environmental Monitoring and Research (IEMR) established to study environmental effects of low-level flight training in Labrador. In 2002, I published effects of jet noise on Harlequin Ducks in international scientific journals while at the same time the IEMR Chair published glossy annual report stating that there were no demonstrated effects. Selling the notion of science-based and no adverse environmental effects for the LCHP ignored all the important outcomes of the World Commission on Dams. It seemed too preposterous to believe but such is the nature of environmental assessment processes in our time.

Writer David Abram points out that ” Of institutional scientists, many have been strangely silent in response to the rapid deterioration of wild Nature. Scientists in their zeal to be seen as “independent” are lost in the sea of binary information overload by thinking that all they have to do is research and publish. By extension, the rest is suppose to take care of itself. Scientists seem to be afraid to be seen in the limelight of the public debate. There is a fear that they could be labeled as environmental leftists, and thereby lose their scientific credibility. The problem with this weak-kneed approach is that totally unqualified individuals, often the developer, seem to have free reign to espouse grossly inaccurate scientific facts to the general public. Because these facts are not corrected, or better still such individuals muzzled, the debate becomes confusing and muddied to the public. We witnessed this with the real potential of mercury contamination to affect human health in the Muskrat Falls development. Imagine touting public health advisories as the measure to mitigate this negative effect! It is unbelievable and certainly unacceptable as an outcome for an EA in the 20th century.  Environmental engineering of the Lower Churchill Project to eliminate or reduce impacts is non-existent notwithstanding some straight-forward things like cleaning-up spills or reducing dust. But there is so much more swept under the rug here, when you comprehend the extensive estuarine and intertidal wetlands of inner Lake Melville, and what changes will proceed on the rich ecosystems downstream when we turn the massive sediment-loaded Lower Churchill River into a man-made lake.

The need for better consideration and mitigation of downstream effects of the LCHP was recommended by the review panel, and I am aware of a scientific approach that was provided to Nalcor. The full report on downstream effects that I prepared and submitted to Nalcor is available, here. Yet all this was seemingly ignored or otherwise too late to shift the ‘do-nothing’ momentum. The local First Nations, concerned citizens, and Academic researchers spent considerable energy and resources to demonstrate, and bring public attention to, the implications of mercury bioaccumulation and human health. It is a shame that such efforts are the only means by which balance can be brought to bear on EA. We are witnessing an era where big business and governments has co-opted the EA process, and politicians ignore the advise of their committees. Recently, our provincial court overturned the decision by the then environment Minister Perry Trimper to release the Grieg NL Ltd. Aquaculture Project in Placentia Bay from environmental assessment (http://www.thetelegram.com/opinion/columnists/russell-wangersky-lackadaisical-attitude-wont-protect-the-environment-182805/); a project to raise millions of salmons annually in sea pens with huge potential consequences to our wild salmon and the marine ecosystem (http://asf.ca/open-pen-fish-farming-a-mess.html). This is the same Mr. Trimper who was a prime consultant on the Lower Churchill Hydroelectric Project, and hence responsible to the conclusions and recommendations of the LCHP EIS.

At the end the day, the reality is that avoidance and mitigation of environmental impacts of economic developments have costs. With dams, there are tradeoffs to be made, such as the regular release of waters from dams to maintain minimum flows downstream, removal of organic materials from the inundation zone to reduce mercury loading and/or drawdown canals to ensure prime wetlands upstream are not inundated. The World Commission on Dams emphasizes that these approaches should be integrated, whereas we witness precious little that could be labeled as environmental engineering for the LCHP. Our society can spend billions on infrastructure yet reneges spending anything on environmental design. When it comes to development, the word ecology is essentially missing from the political and corporate dialogues. Yet it is ecology that teaches that everything in our natural environment is interconnected which is tantamount scientific support to the spiritual notion that all is one. Our natural environments are precious and deserve special considerations if we are to evolve above the Lost Landscapes and Failed Economies so eloquently described by Thomas Michael Power.


Dr. Ian Goudie is Scientific and Resource Management Advisor to FANE. He was an independent consultant who in 2011 researched approaches to managing downstream ecological effects of the Lower Churchill Hydroelectric Project.