Mémoire présenté au Comité permanent de l’environnement et du développement durable

Mémoire présenté par Heather Kleb, présidente et chef de la direction par intérim, Association nucléaire canadienne
au Comité permanent de l’environnement et du développement durable
le 9 mai 2013

Good morning, Mr. Chairman, members of the Committee and the public.  My name is Heather Kleb and I am the Interim President and CEO of the Canadian Nuclear Association (CNA).

The CNA has about 100 member organizations that mine uranium, process fuel, generate electricity and advance nuclear medicine.  Our industry provides the safe, reliable, low-carbon energy that offsets the greenhouse gases released by fossil-based energy sources.

In all, we represent about 60,000 Canadians whose livelihoods depend directly, or indirectly, on the nuclear industry.  Our members work and live in the communities that are home to our industry.  And they have a strong interest in conserving the environment where they live and work.

They share the interests articulated in the Study to Provide Recommendations Regarding the Development of a National Conservation Plan, and routinely take steps to:

• Protect Canada’s natural spaces;
• Restore degraded ecosystems; and
• Enter into partnerships that connect Canadians with nature.

Today I’m going to speak to you about some of these contributions to environmental protection and restoration.  I will also speak about the opportunity to increase these contributions through partnerships and other means.

First, let me set the context regarding the rules that govern our industry, and how we see them.

The nuclear industry is very highly regulated.  We are subject to the same legislation that applies to other major resource industries.  This includes the Canadian Environmental Assessment Act, the Species At Risk Act, the Fisheries Act, and other legislation aimed at protecting the environment.

In addition, we have a dedicated regulator – the Canadian Nuclear Safety Commission.  The commission ensures the protection of health, safety and the environment through the application of the Nuclear Safety and Control Act.

In this Act, and its supporting regulations, we find the principle of ALARA, which stands for As-Low-As-Reasonably-Achievable.  In other words, our industry expects not just to comply with regulatory requirements, but rather to go beyond them.

In fact, our industry has developed a culture of going beyond compliance when it comes to safety, and the protection of the environment.

As an example, look at the approach to habitat enhancement that Ontario Power Generation (OPG) took at the Darlington Nuclear Generating Station in Clarington, Ontario.

OPG constructed a settling pond to intercept drainage from its construction waste landfill.  Instead of simply constructing the pond, they went beyond what was required to develop a pond that supports amphibian reproduction and provides Northern Redbelly Dace habitat.

The Redbelly Dace has no commercial value.  It’s a small fish, like a minnow with silver on its back and black stripes down the sides.  It’s common in Southern Ontario, but scientists sometimes monitor it, because the health of its population depends on the health of its habitat.

In 2008, initiatives like this one earned OPG the Corporate Habitat of the Year Award.  This award recognizes continuous site improvement in wildlife habitat enhancement.  Darlington was selected from among 146 sites across North America to receive this award.

Mr. Chairman, this is one example of the measures our industry takes not only to meet requirements, but to exceed them.  The benefits of such an approach are clear.  Of course, there are also times when our industry must work not simply to enhance habitat, but rather to restore it.

We have developed considerable knowledge, experience and technology in the field of environmental restoration.

You can see this at Atomic Energy of Canada Limited (AECL).  AECL is considering decommissioning a stack that was built some 60 years ago for safety reasons.  The stack has gone unused for more than 25 years, except for some Chimney Swifts who now call it home.

Chimney Swifts are small, black-and-white birds whose population has declined as their habitat has disappeared.  They use chimney-like structures as roosting, or nesting sites, but industry doesn’t build them anymore.  Changes in operations have caused them to tear down the stacks and not replace them.  This is one of the reasons why the birds are now a threatened species.

Three years ago, an AECL biologist confirmed that the birds were using their stacks.  They also determined that there was a real lack of information about the species, and almost nothing on their roosting behaviour.  AECL sought out a chimney-swift specialist at Trent University and launched a research program to find out more about the species, and what could be done if the stacks had to be torn down.

The knowledge that they have gained to date, and will gain in the future, will not only help them understand the species better, it will also feed into AECL’s operations.  Now the company has solid information on which to make decisions about the maintenance, or decommissioning of the stacks.  They are also looking to gain knowledge on how to build successful replacement habitat for Chimney Swifts.

So, as you can see, we take a proactive approach to environmental restoration and we’re committed to going beyond compliance.  We also enter into partnerships to help us achieve these goals.

Our members agree that the National Conservation Plan must foster and support strong, long-term conservation partnerships between stakeholders.

Here’s an example of how we see these conservation partnerships at work.  In 2012, the Finalized Recovery Strategy for the Woodland Caribou, Boreal Population, in Canada identified significant information gaps regarding Saskatchewan’s Woodland Caribou habitat.

Woodland Caribou are found in old-growth coniferous forests where they feed on lichen, and willows and other plants.  They occur in seven provinces across Canada, including in Northern Saskatchewan.  And in 2002 they were deemed to be a threatened species.

One of our members, Cameco Corporation, mines uranium in Northern Saskatchewan.  When they became aware of the data gaps, they responded by developing a Woodland Caribou monitoring program in the area.  They also sponsored a broader provincial research initiative aimed at filling the gaps.

Given the amount of data required, a government led project of this scale could only succeed with industry funding and support.  So Environment Canada teamed up with the province, Cameco and other industry stakeholders to gain a better understanding of Saskatchewan’s Woodland Caribou habitat.

Moving forward, the stakeholder partnership that has been established in Saskatchewan will serve to better inform provincial management decisions.  Through the funding of the provincial program, and the development of their monitoring program, Cameco has collected valuable information regarding an at-risk species and its’ habitat.

Mr. Chairman, whether it’s researching Woodland Caribou habitat, building habitat for Chimney Swifts, or enhancing the environment for Northern Redbelly Dace, you can see how the nuclear industry approaches conservation.

These three projects demonstrate our industry’s commitment to environmental protection, our experience in environmental restoration and our willingness to enter into partnerships in carrying out such projects.  They also demonstrate the need to find new opportunities for partnerships and projects to offset environmental effects.

Looking at the National Conservation Plan, our members see the need for provisions to offset effects on species and their habitats through flexible means.  We also see the need for documented policies and guidelines for offsetting.

While some species recovery policies and strategies have been successful, the regional variation in Canada’s natural environment means that a one-size-fits-all approach does not work.  A prescriptive national conservation plan would be difficult to implement at a provincial level.

The provinces are responsible for species recovery, but the federal government could provide a national guiding framework for habitat conservation.  This should be developed in collaboration with other jurisdictions and supported with policies and guidelines, or Best Management Practices that help guide habitat conservation efforts.

Coordination and collaboration between the two levels of government is essential to avoiding duplication and will ultimately lead to improved habitat conservation outcomes.  Provincial governments should lead the efforts on habitat conservation by implementing and managing habitat conservation strategies that align with the national plan.

One aspect of such a framework could be the use of habitat banks to offset habitat loss.  Habitat banks have been established in several Canadian provinces, to varying degrees.  A well-defined and formalized habitat banking process would provide yet another tool for improving habitat conservation.

Of course, any frameworks, policies and guidelines would need to be developed in consultation with those who have experience in environmental protection, restoration and conservation partnerships.  Like us, the Canadian nuclear industry.  Given our knowledge, experience and technology, we must be a part of those conversations.

Mr. Chairman, I’ve covered a great deal of ground in a short time.  Your Committee may have questions and I would be pleased to answer them.  Thank you.