Mrs Valerie Walsh

I’m writing to express serious concerns with the Draft Co-operation Agreement between Newfoundland and Labrador and Canada on Environmental and Impact Assessment.

To be blunt, this reads less like an effort to improve environmental review and more like an effort to streamline project approvals by reducing scrutiny and limiting meaningful public input.

There is a lot of language in the document about “robust processes,” “transparency,” and “public participation,” but when you look at what is actually being proposed—“one project, one review,” substitution of federal assessments, and reliance on provincial processes “to the greatest extent possible”—it’s hard not to conclude that this will weaken oversight, not strengthen it.

Many of us are already dissatisfied with the current provincial process. It is not seen as rigorous, transparent, or particularly responsive to public concerns. Harmonizing federal review with that system, without first fixing its shortcomings, does not serve the public interest. It risks locking in a lower standard.

The substitution provisions are especially troubling. Allowing federal assessments to be effectively replaced by a provincial-led process removes an important layer of independent review. Publishing a notice for comment is not the same as ensuring meaningful public participation—especially if the overall process is being compressed and coordinated behind the scenes.

There is also a clear emphasis throughout the document on efficiency, timelines, and creating a “positive investment climate.” That may be good for proponents, but where is the equal emphasis on strengthening environmental protection, public trust, and accountability? Faster decisions are not better decisions if they come at the cost of proper scrutiny.

On public participation specifically, the agreement talks about it, but does not actually strengthen it in any concrete way. There are no clear commitments to early engagement, expanded access, or stronger consideration of public concerns. Given how limited public input already is in the provincial process, this is a major gap.

I am also concerned about the inconsistency around Indigenous rights. While the federal government maintains its commitment to UNDRIP, the province explicitly does not apply it as law. It is not clear how a harmonized process will reconcile that difference in a way that truly respects Indigenous rights in practice.

At the end of the day, the problem here is not duplication—it’s confidence. People do not trust that the current system adequately protects the environment or reflects public input. This agreement does nothing to address that. Instead, it appears to make it easier for large projects to move ahead with fewer checks.

If this agreement is going to move forward, it needs to be revised to:

• Strengthen—not reduce—independent federal oversight

• Include clear, enforceable requirements for meaningful public participation

• Improve transparency at every stage of the process

• Ensure that harmonization raises the bar, rather than lowering it

As it stands, this agreement looks like it is designed to facilitate approvals and is for corporations, not to ensure they are done properly.

Sincerely,

Valerie Walsh