Home      About Us      Press Releases      Reports      Events      Committees      Join FARE      Contact «Port Hope Radiation Issues in the News Public comments disregarded in CNSC process Vision 2010 plans go unchallenged This is the intervention F.A.R.E. has made to the CNSC, protesting the way the regulator has so far dismissed or disregarded all public concerns about Cameco's Vision 2010 project. We feel it is evidence for the Minister of Environment to order a mediation or panel review. ………….. OVERVIEW: The purpose of this written intervention is to provide evidence that the public participation process of this Comprehensive Review EA of the Vision 2010 project, as managed by the Canadian Nuclear Safety Commission staff, is fundamentally flawed and not worthy of respect. Public concerns have demonstrably not been treated seriously to date. Therefore, the Minister of Environment should exercise his authority to refer this project to a mediator or review panel. …………… 1.1. PUBLIC COMMENTS ARE DISMISSED: The Environmental Assessment Track Report for this project is supposed to “indicate how issues identified have been considered in the completion of the assessment, or where relevant, how they may be addressed in any subsequent CNSC licensing or compliance process.” There is nothing to suggest that issues raised by members of the public are to be accorded any less respect than those raised by the proponent or anyone else. CNSC staff response to issues raised during the public consultation process covered 41 pages of Appendix 2. However, suggestions made by members of the public are treated in a markedly different way than those made by the proponent, leading any reasonable person to conclude that the public consultation process on this EA is unreliable and inadequate. Cameco Corporation makes 17 comments or suggestions on the EA guideline document. Sixteen were fully accepted and acted upon by CNSC staff. Some involve substantial change, such as “criticality requirements have been removed from the EA guidelines.” Not once are these dismissive words used: “No change to the EA guidelines required.” When the industry speaks, the CNSC staff clearly listens. Not so with comments received from the Municipality of Port Hope’s peer review consultants and other members of the public. The report filed on behalf of the municipality by Hardy Stevenson and Associates makes 20 recommendations for revisions. Only five were accepted and acted upon, some of those only partially. One of those resulted in three phrases being added to the VECs table, but staff noted that “should the proponent disagree with these additions and would like to discuss them, a discussion with the CNSC can be had before the VECs table is finalized.” This is evidence of a fundamentally unfair process, where the proponent is given the opportunity to challenge public input privately with CNSC staff. Ten, or half, of the municipality’s suggestions are dismissed with “no change to the EA guidelines required.” Staff response to the submission of Lake Ontario Waterkeeper, filed by Mark Mattson, an environmental lawyer, was a virtual shutout. Eight of nine suggestions or comments were dismissed with “No change to the EA guidelines required.” The only change was a very minor one, adding a sentence to the Scope of the Project that did not seem to address the substance of Waterkeeper’s comment. Comments from concerned citizens were disregarded in their entirety. Every one of the 45 suggestions or comments received from concerned citizens was dismissed with “No change to the EA guidelines required.” It would not be correct to conclude that the ideas advanced by the public were worthless, as the following few examples will demonstrate: • The municipality’s peer review team called for site security to be included in assessing long term institutional control. “The assessment should address implications to the users of the areas adjacent to the PHCF site of changes to the security at the site.” They were no doubt thinking of implications to the yacht club or the redevelopment of the Centre Pier. But CNSC staff dismissed that, saying “since the proposed project is not for the decommissioning of the whole site (and therefore a study on the long term institutional control measures is not required), this suggestion was not incorporated into the EA Guidelines.” • The municipality also wanted assurances that the Port Hope Long Term Waste Management Facility, being built to accommodate historic (pre-1988) waste, would not be reopened for any additional waste from future decommissioning activities at Cameco. It seemed like a reasonable request under the circumstances. CNSC staff rejected that, saying that the closure of the long term waste facility “is outside the scope of this EA.” • A concerned citizen pointed out that a Comprehensive Study must consider alternatives to the project, and asked that two be included – a relocation of the entire Cameco operation to a site in Ward 2, which has already undergone a successful environmental assessment; and an alternative site to store cylinders and drums, which would eliminate more than 12,000 square metres of new buildings on the waterfront. CNSC staff said “since the project is for the redevelopment of parts of an existing site, a complete relocation of the whole facility would not be required to be considered.” It also said Cameco had the sole discretion to suggest alternatives, thereby closing off any input by the public. • The same citizen asked for assurances that the public will have the right to cross-examine witnesses at hearings. He noted that “the public has been frustrated at past EA screenings when its questions are not answered by experts appearing on behalf of the company or CNSC staff.” The CNSC staff dismissed this request without giving a reason. • Another suggestion was for the EA to document all suggestions made by Cameco’s stakeholder liaison committee, and what action Cameco has or has not taken on them. Since Cameco is crediting that committee with playing a key role in its public consultation for the project, it was suggested that the original members of that committee should be invited to assess the process. CNSC staff dismissed that without reason, noting that “Section 3.7 of the EA Guidelines includes the requirements for the Public Consultation Program.” • Noting that Cameco’s Gartner Lee report identified three “overarching, basic prerequisites for the Vision 2010 project,” one of which was minimizing site emissions, a citizen suggested this EA include specific targets for emissions curtailment. CNSC staff dismissed this, saying “the EA does not require emissions to be curtailed if the proponent is meeting current standards.” • In answer to other public concerns, CNSC staff refused to require Cameco to say how it plans to distinguish between historic waste (which is the responsibility of the LLRWMO) and materials which have leaked from Building 50 (which is Cameco’s responsibility to dispose of). It also refused to require Cameco to say how the leaking from Building 50 has affected plans to remediate the adjacent areas. It is therefore disingenuous for the CNSC staff to make the following statement: “CNSC staff recognizes that there are public concerns regarding this project. The planned outreach and public consultation activities will provide adequate opportunity for the public to identify their concerns and to communicate them to the appropriate authority.” It seems the public can certainly communicate its concerns, but the evidence is clear – none of them will be acted on. 1.2 PUBLIC REGISTRY IS NOT WORKING: According to Section 55 of the CEAA, the public registry will include all relevant information, including the availability of the EA Track Report and notices requesting public input. This has not happened. When a member of F.A.R.E. accessed the Registry on Aug. 23, 2008, he found neither of those on the site. The site had last been updated on March 4, 2008. It was updated again, belatedly, on Sept. 28, but only with announcements of where to write to obtain the Notice of Hearing (which had actually been issued more than three weeks before) and the Proposed EA Guidelines. Ten days before the end of the public comment period, there was no mention of the availability of the Track Report. We respectfully submit that the public registry is not working as promised and cannot be relied on as an instrument of public participation on this EA. Public comments disregarded in CNSC process Vision 2010 plans go unchallenged Cameco isn't telling us the full story What it hasn't told us about uranium leaking UF6 goes to the races Citizen catches Cameco trucks parked at gambling slots, emitting dangerous radiation 4 April 2005: David Suzuki Speaks in Port Hope Proposed sign fee slams freedom of expression Is Port Hope City Council's fee on lawn signs an attempt to muzzle opposition to Cameco's proposal to produce SEU? (article in the Northumberland News) Interview With Robert F Kennedy admin@ph-fare.com P.O. Box 202 Port Hope, Ontario L1A 3W3 Questions or problems regarding this web site should be directed to admin@ph-fare.com. Copyright © 2005 Families Against Radiation Exposure, Inc. All rights reserved. Last modified: 15 April 2005 Archived Information » top of this page « administration

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