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Submission to the Public Consultation on the BC Environmental Assessment PDF Print E-mail
Written by Joan Russow
Sunday, 31 May 2015 13:48

By Joan Russow PhD

Global Compliance Research Project

May 26 2015


The BC government through the BC Environmental Assessment displays a lack of vision, conflict of interest,gross negligence, inconclusiveness, questionable terms of reference, flawed process,disregardof evidence of harm, rush to judgement, an accident waiting to happen,tolerating absence of clean hands, lack of foresight, and a dismissal of viable alternatives,. failure to  act on UBCM resolution,  anoverlooking of primary evidence, a neglecting of best practices, unfortunate  conversion of use,a minimizing of disaster, an averting of danger,and a tempting of fate



In 1992, at the UN Conference on Environment and Development there was enunciated a new vision;


Humanity stands at a defining moment in history. We are confronted with a perpetuation of disparities between and within nations, a worsening of poverty, hunger, ill health and illiteracy and the continuing deterioration of the ecosystem on which we depend for our well being (Preamble, Agenda 21, UNCED, 1992)


And to fulfill this vision, the precautionary principle was enunciated:

Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent the threat." (Rio Declaration, UNCED1992).

This principle is also contained inthe Convention on Biological  Diversity:

Where there is a threat of significant reduction orloss of biological diversity, lack of full scientific certainty should not be used as a reason for postponing measures to avoid or minimize such a threat

 In the UN Framework Convention on Climate Change is the following version of the precautionary principle:

To take precautionary measures to anticipate, prevent or minimize the causes of climate change and mitigate its adverse effects. Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing such measures. (UNFCCC, 1992)

And in1995 agreement “relating to the Conservation and management of straddling fish stocks and highly migratory fish stocks …is the obligation to invoke the precautionary principle.


In August 1992, the government of BC endorsed at the Cabinet level, the Convention on Biological Diversity and the  UN Framework Convention on Climate change (document obtained through Freedom of Information).BC is thus bound by the principle and bound by the Conventions. Citizens on British Columbia have a legitimate expectation that BC will abide by these obligations;

 Many of the examples in this document reflect cases where the public has not been served by the environmental assessment process either by its commission or omission. Also in a recent Auditor General`s report, the Auditor General criticized the failure in environmental assessment to considered accumulated environmental effects of multiple intersecting projects



The environmental assessment should always take the conflict of interest into account.There have been numerous articles about the corporate donations of the Liberal Government such as the following:

“Since 2005, businesses have showered the party with $46 million”

By Gordon Hoekstra, Vancouver Sun march 21, 2014








“The top donors to the B.C. Liberal Party in the past decade are a well-heeled corporate coterie.

The top 20, which gave nearly $10 million to the Liberals from 2005 to 2012, include a who’s who of the mining, forestry, retail investment and building sectors, according to a detailed database constructed by The Vancouver Sun from Elections BC information. There’s also representation from resource sector suppliers, the oil and gas sector and the auto sales sector.

Corporate donors pumped $46 million into the Liberal Party coffers between 2005 and 2012.

There’s B.C. mining behemoth Teck Resources, at No. 1, which gave $1.7 million.

The New Car Dealers Association of B.C. was the second-largest contributor, giving $822,814.”

One man, Allan Paul Marking, an Alberta Oil dude, gave $150,000 to the Liberals. Alberta oil companies Encana and Cenovus gave them $68,000 and Texas based Spectra Energy gave $33,000”




Kinder Morgan

They may still be pipedreams in the eyes of most, but that didn’t stop pipeline proponents from donating generously to the B.C. Liberal party with donations from Kinder Morgan ($4,500), TransCanada Pipelines ($5,600), Coastal GasLink Pipeline ($12,500) and Enbridge Northern Gateway ($13,450).


As authorities scramble to clean up one of Canada's worst industrial disasters following the Mount Polley mine breach, cuts to mine and dam inspections since 2001 combined with Imperial Metals Corporation's at least $233,710 in BC Liberal Party donations since 2003 is adding insult to injury for some.





There had been numerous prior warning about problems with the Polley mine


``Mount Polley mine tailings pond breach followed years of government warnings``

By Jenni Sheppard, CBC News



Posted: Aug 05, 2014 9:50 PM PT Last Updated: Aug 06, 2014 6:22 PM

Elections BC after every election reveals the donations to political parties. Imperial metals has donated over 234.000 since 2005

The Tyee has pointed out that imperial Metals had contributed considerably to the Liberal party of BC

Imperial Metals' Political Gifts to BC Liberals Total $234,000





 After an incomplete environmental assessment and a request for clarification, the company withdrew its application but it left the community in a state of continued apprehension by stating it does not preclude the applying again.


EAO Evaluation of Raven Coal Mine Application Reveals Missing Information



‘A review of the 62-page EAO Application Evaluation Comment tracking table by the Coal Watch Comox Valley Society (Coal Watch) indicates that required information on significant issues was still missing in the latest Compliance Application.‘


Press Release, Coal Watch Comox Valley, March 16 2015 On March 11, 2015 the BC Environmental Assessment Office (EAO) released to the public, the draft Application Evaluation Comments tracking table for Compliance Coal Corporation’s (Compliance) Environmental Assessment Certificate Application (Application) for the proposed Raven Coal Mine Project submitted on January 30, 2015.

Subsequently, the company withdrew its application but state “But he said the project is a good one and he hopes it can be resubmitted in the future.

Leaving the community in continued apprehension

Coal company withdraws proposal for contentious mine on Vancouver Island



A controversial proposal to mine more than 16 million tons of coal in the Comox Valley on Vancouver Island has been withdrawn in the face of growing criticism about the negative impacts it could have on rich shellfish and salmon grounds.

Stephen Ellis, president of Compliance Coal Corporation, said his company has backed out of the B.C. environmental assessment process for the proposed Raven coal mine not because it’s environmentally risky, but because there is so much public misunderstanding about the project. And he made clear the company hasn’t given up on the proposal yet.

Proposed Raven Underground Coal Project 
Evaluation Notes for Compliance Coal Corporation’s Response to EAO’s May 16, 2013 Direction on Additional Public Consultation 

DRAFT dated March 2, 2015





There was a flawed process because at the hearing in 2010 the NEB asked the interveners to outline their issues with the project and then the board proceeded to ignore the issues in the terms of references

Global Compliance Research Project Oral Presentation to the Northern Gateway Review Panel,



``The interveners raised the following issues

The need to examine the TOTAL IMPACT OF oil sands, pipelines and tankers, and the importance of addressing the threats to indigenous rights, to livelihood and subsistence, to marine life and resources, to future generations and to cultural and natural heritage.




The National Energy BOARD has been deemed to be conducting a flawed process or even a rigged process for some of the following reasons:



By Chief Eric Pelkey





Potential Project Impacts from increased marine shipping, accidents and malfunctions:


. Disruption to Tsawout’s way of life, including increased alienation and interruption with 


1. Tsawout’s sacred relationship and reliance on the waters and lands of our Territory


2. Disturbance to burial sites, other spiritual and cultural sites 


3. Disturbance to food gathering locations, including fishing, harvesting aquatic resources, 


plant gathering and hunting activities


4. Disturbance to distribution, health, abundance and long term sustainability of fishery and 


aquatic resources, birds, mammals, vegetation, threatened and endangered species, 


benthic communities and other resources from increased shipping operations and from oil 




5. Impacts and disturbance throughout the marine ecosystems from wake, noise, air 


emissions, and lighting


6. Disruption to historic, modern and future marine travel ways and marine access throughout the Territory, including areas now considered within the U.S.


7. Decreased water quality and increased pollution, including introduction of non-native 


invasive species, 


8. Increased risk of collision and accidents, including water contamination, shoreline 


contamination and physical contact between a tanker's hull and marine sub-tidal habitat 


from vessel grounding


9. Increased risk of impacts because of insufficient knowledge and capacity to contain and 


clean up diluted bitumen in the marine environment 


10. Continued and cumulative effects throughout the Territory, including contributing to 


climate change impacts, ecosystem effects, and the health/physical, emotional/social and 



Expert quits 'rigged' Trans Mountain oil pipeline review




"The game is rigged," she wrote. "We are being conned by the very agency entrusted to protect us."

``Among Allan's criticisms is that the NEB is examining the project based only on Kinder Morgan's applied for capacity of 540,000 barrels from the new pipeline, not its design capacity of 780,000 barrels, meaning the project is not undergoing proper scrutiny based on the full amount of oil it could carry, or risks associated with the existing pipeline.

That's just one of a series of "biased" NEB decisions that Allan said have restricted the review's scope in favour of Kinder Morgan and effectively minimized the analysis of project risks‘




Throughout the world has been mounting evidence about the environmental and health impacts of fracking. In addition fracking has been linked to a cause of earthquakes:


2.   Ban Fracking Now - Put health over corporate profits‎


Sign the petition.

Food & Water Watch has 185 followers on Google+


Methane Leaks & Health Impacts

How Great Is the Risk to Health? fracking, natural gas, water pollution, methane





Fracking Industry Shakes Up Northern BC with 231 Tremors



``British Columbia's shale gas fracking industry triggered more than 231 earthquakes or ''seismic events'' in northeastern British Columbia between Aug. 2013 and Oct. 2014.

Some of the quakes were severe enough to ''experience a few seconds of shaking'' on the ground in seven areas of the province on top of the large Montney shale gas basin.``





A B.C. First Nations group rejects $1-billion offer for LNG venture



``The lure of the money, which would be spread over 40 years, is being overshadowed by what the native group views as excessive environmental risks. The Lax Kw’alaams fear the Pacific NorthWest LNG project led by Malaysia’s Petronas will harm juvenile salmon habitat in Flora Bank, located next to the proposed export terminal site on Lelu Island.``


A Clear Look at BC LNG

Energy security, environmental implications and conomic potential


David Hughes

- See more at: https://www.policyalternatives.ca/publications/reports/clear-look-bc-lng#sthash.3NdfYvg3.dpuf




Liquefied natural gas (LNG) exports from the west coast of Canada have been heralded as economic salvation for the province of British Columbia. This report undertakes a reality check that reveals several major problems with this narrative, both in the stewardship of finite non-renewable resources by provincial and federal governments, and in the environmental implications of large-scale development. - See more at: https://www.policyalternatives.ca/publications/reports/clear-look-bc-lng#sthash.3NdfYvg3.dpuf


The Dogwood initiative expresses concerns and reservations about LNG


``Substantial pipeline capacity connected to southern markets † Advantageous shipping costs Safety Concerns †

The risk of explosions on LNG tankers have resulted in many US jurisdictions not allowing LNG tankers on the coast.

 † LNG carriers require large buffer zones– which could restrict other maritime traffic around proposed terminals.

Safety Concerns

† LNG accidents are rare but they do occur.

† Fires can occur if LNG spills near an ignition source and can cause second degree burns 1.6 km away.

Vapour clouds can form if LNG spills and does not ignite which can cause asphyxiation. ‘``




 And ignoring of food security and viable options such as geothermal

A Waste of farmland


`:The Peace River Valley contains unique growing conditions that allow it to grow a wide range of fruits and vegetables: enough to feed over a million people, states expert Wendy Holm, an agrologist and economist with over 40 years’ experience.

The Peace River valley would lose up to 31,528 acres of Class 1-7 land if Site C proceeds. Given changing climate conditions and the increasing global pressure on food producing land and food prices, BC needs to protect valuable agricultural land, not flood it!

There are many energy alternatives, but there are no alternatives to food producing land!``


A viable renewable source


·         >

·         Geothermal Energy: The Renewable and Cost Effective Alternative to Site C

Geothermal Energy: The Renewable and Cost Effective Alternative to Site C


This 60-page report provides an assessment of what CanGEA believes to be the true value of geothermal resources in British Columbia. Moreover, it is asserted that geothermal energy as renewable, cost-effective alternative to the Site C hydro dam proposed by BC Hydro. This report builds upon Joint Review Panel (JRP) of the Site C Clean Energy Hearings. The hearings concluded that: “a failure to pursue research over the last 30 years into B.C.’s geothermal resources has left BC Hydro without information about a resource the BC Hydro thinks may offer up to 700 megawatts of firm, economic power with low environmental costs.” CanGEA was granted interested party status at the JRP hearings, and this conclusion largely stems from CanGEA’s submissions. CanGEA considers this number, or 700 megawatts, low. To ensure the true value of geothermal energy is assessed, CanGEA has released The 10 Advantages of Geothermal Energy not Considered by BC Hydro or the Joint Review Panel. Seven of these are economic considerations, and the other three address socio-economic and environmental considerations.





A large coalition of farmer, first nations, citizens communities and opposition leaders were ignored when they pointed out the potential loss of food security

Farm land protection Coalition campaign against Bill 24


``We need a variety of strategies to protect farmland that could include our local and municipal governments creating zoning and bylaws that could serve functions similar to the restricted land use zoning the ALR has historically used to protect some of the best farmland in BC. Another possible strategy is leveraging public and/or private capital to buy farmland and protect it through community ownership in partnership with local governments and/or farmland trusts``.

Submission on Bill 24; The Agricultural Land Commission https://pejnews.com/index.php?option=com_content&view=article&id=10215:re-bill-24submissionsubmission-on-bill-24-the-agricultural-land-commission-act&catid=89:bc-earth-news&Itemid=213

``With the proposal to reduce the ALR, BC  government`s own commitments seem  to be ignored and  the bill is out of sync  with the important considerations, principles and directions of the global community  With bill 24 the BC government  will be negligent in its defying  of the precautionary principle and in  its moving towards food insecurity  and  towards lack of food sovereignty. BILL 24 has also been conceived with little regard for the rights on future generations. ``




B.C. municipalities pass resolution for GE-free province



“Leaders of regional and municipal governments from across British Columbia has adopted a resolution asking the provincial government to declare B.C. a genetically-modified organism-free area with respect to all plant and animal species.

The resolution was brought before the Union of B.C. Municipalities (UBCM) 2013 annual convention Thursday in Vancouver.

``The resolution asks for a ban on importing, exporting and growing plants and seeds containing genetically engineered (GE) DNA, and raising GE animals within B.C.”

Altered Genes, Twisted Truths” : A Challenge to Monsanto






``Solving``  problem by offseting of problem rather than addressing the issue on site

Violation of Article 19 of the Declaration on the Rights of Indigenous Peoples


``Article 19

States shall consult and cooperate in good faith with the indigenous peoples concerned through their own representative institutions in order to obtain their free, prior and informed consent before adopting and implementing legislative or administrative measures that may affect them.``


Nicola Valley residents protest biosolids being dumped


``Protesters say they are concerned about water contamination from biosolids being dumped at Sunshine Valley. The group Friends of the Nicola Valley says biosolids are currently being dumped at a composting facility in the Sunshine Valley. The dump site is close to the Nooaitch Band's reserve and borders the Nicola River, says the group's organizer Georgia Clement.

"The Nooaitch and a number of First Nations communities draw water from the Nicola River," Clement told Radio West on Tuesday. "So there's a serious concern from their point of view with regard to contamination to their water."



There has been years of negligence on this issue. When there was an assessment in 1996, the government ignored primary evidence related to the environment and to the health of the first nations and more recently the government has ignored the research outlined in the salmon confidential



Salmon Aquaculture Confidential

Salmon Confidential is a new film on the government cover up of what is killing BC’s wild salmon. When biologist Alexandra Morton discovers BC’s wild salmon are testing positive for dangerous European salmon viruses associated with salmon farming worldwide, a chain of events is set off by government to suppress the findings. Tracking viruses, Morton moves from courtrooms, into British Columbia’s most remote rivers, Vancouver grocery stores and sushi restaurants. The film documents Morton’s journey as she attempts to overcome government and industry roadblocks thrown in her path and works to bring critical information to the public in time to save BC’s wild salmon. The film provides surprising insight into the inner workings of government agencies, as well as rare footage of the bureaucrats tasked with managing our fish and the safety of our food supply. 


Refuse to expand the salmon farming industry in BC | rabble ...


`` Prime Minister of Canada, Stephen Harper, has given the Norwegian salmon farming industry the green light to expand in British Columbia marine waters.  Days later one of these companies was listed on the New York Stock Exchange announcing big plans to expand.  This industry never shovels its manure - waste, viruses, and drugs flow directly into the wild salmon migration routes of BC.  This is a dirty industry that does not belong in our increasingly polluted oceans.``




There has not been a comprehensive environmental assessment review of the impact of the mechanical harvesting of seaweed and a report written by experts appears to have been disregarded.


`Seaweed Harvesting on the East Coast of Vancouver Island, BC: A Biological Review

By I.K. Birdwell, R.C. Degraaf, D.E. Hay, G.R. Peterson


``The stimulus for this report was the initiation of beach-cast seaweed harvesting in 2012, close to Deep Bay and Bowser on the east coast of Vancouver Island. This area supports valuable fish habitat, recreational and commercial fisheries, seabirds and eagles and other animals that rely on the shore line and adjacent marine waters. This coastal area provides food, spawning habitats, nursery and rearing habitats, and migration pathways for many species of fish, birds and mammals. The area is adjacent to, and the waters are contiguous with, Baynes Sound which is used for an expanding shellfish aquaculture industry that supplies approximately fifty percent of BC’s total shellfish aquaculture production. Seaweeds provide food and cover for many organisms when growing. However, it has been well-documented that when detached and washed ashore they provide readily-available nourishment for organisms at the base of the food chain. In the location of Baynes Sound that food chain includes the organisms that are used for food by fish, birds and mammals aside from that needed to meet the requirements for aquaculture``


See petition at https://secure.avaaz.org/en/petition/The_Provincial_Government_of_British_Columbia_An_immediate_moratorium_on_the_harvesting_of_seaweed_for_commercial_use/?tgbQrab




In the 1960s Merv Wilkinson and Macmillan Bloedel undertook to compare their forest practices in the same amount of acreage; after a period of time, there was a report that demonstrated that Merv Wilkinson’s practices were more sustainable, ecologically and economically.



(i).Selection forestry



End the clear cut logging, and the esthetic fringe which hides a clear cut from view.

“With this system, your land is never out of production – you’re always growing trees. Merv Wilkinson. Merv feels his management style is fairly close to what foresters call “a true selection system,” but with one major exception. “I don’t over manage my forest,” he says. “I take my lead from nature rather than a textbook. Good forestry requires the flexibility to make decisions based on what is going in the forest, not always according to rules and theories.” See More on Selection Forestry in Other issues #2


(ii) Identification of biodiversity


Another important job would be to identify biodiversity which is required under the legally binding Convention on Biological Diversity.


(iii).Keeping it living

Learning the ways that first Nations take medicines from nature without destroying nature


iv. Value added

End the export of raw logs and using them here

Merc Wilkinson’s Sustainable Selection Forestry


By Tisha Wilkinson


Sustainable selection forestry is a method of managing the forest and harvesting forest products in a manner that conserves forest ecosystems.  This method of forestry is a valuable tool and management practice to help ensure we retain for the future the forest resource opportunities we have today.


Manage the forest for diversity.  This involves maintaining a mixed species forest.  The benefits of maintaining a mixed species forest are:

·        Healthy and varied bird populations, which control/prevent insect infestations

·        Improved soil quality

o   Soil building species such as alder add nitrogen to the soil

o   humus building species, such as maple shed leaves that protect soil from evaporation and provides essential organic matter

Encourage natural seeding.  Identify and leave seed (parent) trees.  Parent trees are those that are healthy; demonstrate strong growth, free of genetic defects, and producers of good quality cones.


Selective Harvests.  Select individual candidate trees to harvest in order to:

·        maintain species diversity

·        maintain forest stand health

·        maintain forest stand structure including mixed species and ages

·        manipulate the forest canopy to encourage and protect productive natural regeneration

Sustainable Harvest.  Never harvest more timber than the annual growth rate of the timber.  Determine and monitor the growth rate as represented by the number of cubic meters of growth per hectare per year. This is used as the basis for the maximum annual allowable cut.


 Protect forest capital during harvest.  Harvesting activities during bird nesting season may be disruptive to bird population.  Compaction of soils may occur more easily during certain seasons when the soil is saturated by rainfall. The drop zone must be carefully considered in order to minimize damage to surrounding trees and seedlings.   Methods of extracting the fallen tree from the drop zone must be considered prior to felling the tree.  The more difficult to extract, the more damage that the surrounding fauna could sustain during the extraction process.  Minimizing the collateral damage is key.


Protection of soils.  Methods of extracting fallen trees should be well planned and executed in order to prevent soil erosion and compaction.  Ensure that the top, branches, leaves, needles, rotten wood and unusable portions of the trunk remain on the forest floor so that they are left to rot and contribute to the improvement of the soil.




Letter from Sea to Sea, to Auditor General, about Conversion of TFL

Errol Price, Acting Auditor General John Doyle, Auditor General 8 Bastion Square Victoria, BC V8V 1X4 RE: Request for an Audit and Examination of Private Land Deletions from TFLs 6, 19 and 25



``Errol Price, Acting Auditor General John Doyle, Auditor General 8 Bastion Square Victoria, BC V8V 1X4 RE: Request for an Audit and Examination of Private Land Deletions from TFLs 6, 19 and 25`

``On behalf of the Sea to Sea Greenbelt Society1 we hereby request that you undertake an examination of: • the Minister of Forests and Range’s decision2 of January 25 and 31, 2007 to delete all the private lands from three tree farm licences (TFLs) held by Western Forest Products Inc. (WFP), and • related government management of finances and resources.

We urge you to undertake this examination pursuant to your general powers to audit and report under sections 11 and 12 of the Auditor General Act (the “Act”), as well as pursuant to section 13(1) of the Act, which empowers the Auditor General to undertake an examination respecting the government or in relation to a transfer under an agreement if the Auditor

General is satisfied that undertaking such an investigation is in the public interest.3 The Minister’s decision removed 28,283 hectares4 of private land from Crown regulation of forest management in TFLs 6, 19 and 25. The lands deleted

(the “WFP deletions”) include parcels around the Sooke Potholes and a substantial portion of the coastal and coastal view properties on the south coast of Vancouver Island.

Portions of these lands are now being advertised for sale as “some of British Columbia’s most amazing land with waterfront, views, development potential and timber value.”5 Vast tracts of other lands were deleted on the north Island as well as two small parcels on the central B.C. coast.6

By making these deletions without requiring public compensation in return, government has apparently neglected its duty to manage Crown resources and finances in an economic, effective and efficient manner.7

In the past the Crown obtained compensation for deletions of private land from TFLs, and the failure to obtain such compensation in this case appears to be contrary to important public interests.

As a result of the WFP land deletions described above: •

The public will suffer economic loss because government failed to obtain compensation from the licence holder.

 Both the Provincial government and industry have previously recognized that it is appropriate for government to recover compensation for past consideration it provided to the TFL holder, and for the increased value created by deletion of private TFL lands.8 In this case, the deletion gives the licence holder a windfall increase in land values, without obtaining proper compensation for the public

.The public will suffer economic loss because of government’s failure to recover compensation for the decades of substantial benefits that have accrued to the TFL holder (and its corporate predecessors), and will continue to accrue.9 • The public’s interest in environmental protection and public recreation will be compromised because the deletion removes environmental and social protections available under the Forest and Range Practices Act and various other laws and policies.10 For example, the Forest and Range Practices Act regulations that restrict logging in environmentally sensitive riparian zones will no longer apply, and public access to the lands will be reduced. Yet government failed to address the resulting loss of public recreational and environmental values. Specifically, government has failed to seek or obtain compensation in the form of:

• parkland acquisition,

• continued waterfront access,

 • public access to the lands for recreational purposes,

 • acquisition, or other fully equivalent protection, of ungulate winter range and community watersheds that were removed from Crown protection as a result of the deletion, and

• other similar public benefits….”


Auditor General`s response indicated opposition to the conversion auditor general, criticizes releasing private land from tree farm wood lots. in 2007 without benefit to the public or consideration http://www.cathedralgrove.eu/media/01-3-auditor-general.pdf

Was there an environmental assessment done to address the the above concerns?




I 1991, all but one member of the legislature, and 8 out of the 10 municipalities, supported a nuclear-free Victoria.  In a court case which was launched, the decision was that the visits did not require an environmental accessment review  because of federal cabinet perogative. It appears that the BC government has never done an environmental assessment of the visits.



  Exercise Trident Fury 2013: Rogue States engaged in ...



May 3, 2013 - Citizens in 2006 had demonstrated against Exercise Trident Fury but it is still happening, and an environmental assessment review of the war games has never been done in BC.






Submission to the Environmental Assessment Review of the expansion of the Northwest training Range Complex along the coast.




In Conclusion, there must be an authentic environmental assessment process for projects in BC; a process that would examine the accumulative environmental effects, while observing the precautionary principle, the principle of the rights of future generations  and those of First nations.  In addition if there is to be a future for future generations there must be a shift from short term economic benefit to socially equitable and environmentally sound development.  It is time to exercise due diligence and embrace the Doctrine of Legitimate expectation









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