Northwatch Comments on Draft Integrated Tailored Impact Statement Guidelines for the impact assessment of Ontario Power Generation’s proposed “New Nuclear at Wesleyville Project

Northwatch is providing comments on the Draft Integrated Tailored Impact Statement Guidelines for the impact assessment of Ontario Power Generation’s proposed “New Nuclear at Wesleyville Project.

Northwatch has previously commented on the OPG’s Initial Project Description and described Northwatch and Northwatch’s areas of interest in that document, and will not repeat those introductions in this submission, given that our earlier comments are available on the public registry.

As a first step in our review of the draft guidelines, we created a list of the issues we had identified during the comment period on the IPD as one lens through which we will evaluate the efficacy of the draft guidelines.

In general, our review of the Initial Project Description determined that OPG had not provided a sufficient description of their project or its components, activities, and anticipated and potential adverse effects.  While problematic in an Initial Project Description, the same approach is wholly unacceptable in the impact statement and supporting documents.

The Integrated Tailored Impact Statement Guidelines must provide the OPG with direction that is sufficiently detailed to result in a detailed impact statement which must support an evidence-based assessment of OPG’s proposal and its potential effects. The Agency must ensure that the guidelines are sufficiently thorough and comprehensive in order to achieve a credible and scientifically and socially rigorous review process.

Our overarching observations were:

• the comment period was too short, and limited public opportunities for analysis and comment
• the draft guidelines are inadequate, and must be subject to serious revision
• it would be appropriate to provide the public with an opportunity to comment on the revised guidelines prior to their being finalized
• inadequate guidelines are likely to result in a deficient assessment
• the Agency must take the necessary steps now to protect the impact assessment process and build trust with the public that it is acting in good faith and in the interests of sound assessment, environmental protection, and the public good

Our comments are attached.