Timelines placed on federal comprehensive studies

Timelines placed on federal comprehensive studies

The Establishing Timelines for Comprehensive Studies Regulations under the Canadian Environmental Assessment Act were recently published in the Canada Gazette.  These timelines apply to all Comprehensive Studies under the Canadian Environmental Assessment Act except where the responsible authorities are the Canadian Nuclear Safety Commission or the National Energy Board.

Summary flow chart

The Regulations requires the completion of a comprehensive study within 365 days of the notice of the commencement of the environmental assessment.  This 365 days excludes:

  1. Time during which the proponent is collecting information to complete the EIS Guidelines (unless the Agency has sufficient information to continue with the Comp Study)
  2. Any period requested in writing by the proponent, or
  3. Any time (up to 30 days) following receipt of the environmental impact statement needed to determine whether the information has met the Guidelines.

Timelines for public comment on the comprehensive study (which are prescribed in the public notice) and the government response to the study and related public input are not prescribed.

Concerns had been raised about the impact of placing such timelines on environmental assessments where the capacity of both the CEA Agency and consulting departments may be under pressure.  The Regulatory Impact Analysis Statement, oddly in my view, addresses this point stating that the Agency “has been resourced accordingly and has the expertise and the capacity to deliver high quality environmental assessments”.  It is not clear how this conclusion was made and, how, even if currently accurate, it won’t change tomorrow.

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