Discussion paper on the review of the Physical Activities Regulations

Provide a comment

• Nuclear

  by Nicole Corrado, over 1 year ago

  https://letstalknuclearsafety.ca/regdoc-234-operations-programs-reactor-facilities I am quite concerned with 3.9.8, which mandates testing “fish tissue and other receptor species tests for exposure uptake”. As Canada is moving away from animal testing, this seems counterintuitive to include animal testing in a document to modernize practices, especially when there is no mention of phasing out and replacing the practice. Mining is harmful to all life, and to the planet. Forcing fish and birds to be exposed to the effluent, and cutting them up to test them for selenium and other pollutants is cruel and outdated. Canada is phasing out toxicity testing on animals. Please... Continue reading

  https://letstalknuclearsafety.ca/regdoc-234-operations-programs-reactor-facilities I am quite concerned with 3.9.8, which mandates testing “fish tissue and other receptor species tests for exposure uptake”. As Canada is moving away from animal testing, this seems counterintuitive to include animal testing in a document to modernize practices, especially when there is no mention of phasing out and replacing the practice. Mining is harmful to all life, and to the planet. Forcing fish and birds to be exposed to the effluent, and cutting them up to test them for selenium and other pollutants is cruel and outdated. Canada is phasing out toxicity testing on animals. Please switch to animal free methods of testing effluent and other substances. For wild fish and birds, please stop lethal sampling and switch to humane non lethal bio monitoring like is done in humans. https://www.change.org/p/stop-testing-sewer-water-on-laboratory-fish

  Mines destroy all sorts of animals in laboratory testing of their effluents, and in lethal sampling of birds, fish, frogs, etc. Please do not use animal testing for pollution monitoring.

  There are cruelty free modern alternatives to animal testing, including acute lethality testing. Cell cultures can determine effect of pollution for instance. Please reach out to antivivisection organizations regarding these tests, and lobby to change these outdated laws.https://www.change.org/p/stop-testing-sewer-water-on-laboratory-fishHere is a link from the Physicians Committee for Responsible Medicine on alternatives to fish in laboratory research.https://www.pcrm.org/news/good-science-digest/world-aquatic-animal-dayPlease stop the “acute lethality tests” on rainbow trout, three lined stickleback, and other fish species. These tests involve pumping effluents into fish tanks about once a month, and if more than half the fish die, the experiments are repeated. There are animal free ways to test for pollution. Any guardians of companion fish will test their tank using paper strips and test tubes. They do not deliberately expose the fish to effluents to see what happens. Please also end the practice of sublethal toxicity testing of effluent on baby fathead minnows and rainbow trout, and stop cutting up fish to test their livers for mercury. Please lobby the government to put an end to mandatory toxicity testing under the Fisheries Act and go cruelty free. Please only use non lethal sampling of wild fish, or take tissue samples from fish who were already caught for human consumption. Please do not kill or harm any animals for research. Many mining companies also kill animals as “pests”. Please only use non lethal methods of wildlife coexistence. www.bearwithus.org www.coyotewatchcanada.com Please only use humane non lethal methods to manage beavers and other wildlife. Killing beavers only leaves room for more animals to move in. And the traps kill many other animals. London Ontario and many other places manage beavers without killing. Here are some resources.https://thefurbearers.com/downloads/PDFs/Beaver%20Book%20-%202019-10-08%20The%20Fur-Bearers.pdf?fbclid=IwAR1wp4qVXhAiDt3OzeAmlNe5bo35m0opAuPKZ9oLgWYmVk6JNcohAMtlrpIhttps://www.beaverinstitute.org/?fbclid=IwAR2nZ0zjx5P4EeU5Iq3uUjtnNs7oV3RY3dTrfc6aydZ-pe2Op0DEU3wd4Ywhttps://beaverdeceivers.com/?fbclid=IwAR0FuQ_fWRsCgG4Tgy4zmdmG8gCX37xdfPjxiknY98OUnSk9kfrW97PwgWQhttps://www.animalalliance.ca/wp-content/uploads/2018/04/Beaver-Manual_May-2016.pdf?fbclid=IwAR2tlWjDkRgu-vBW9t3SSg9pfOqKN2ESUO3ezIndu9dLjijNa8lnIZt7qdE

  https://www.humanesociety.org/resources/humanely-scare-away-canada-geese

  https://www.canadageese.org/nlcontrol.html

  https://www.peta.org/wp-content/uploads/2021/06/humane-goose-control-pdf.pdf

  https://www.humanesociety.org/resources/what-do-about-canada-geese

  This company makes non lethal products. https://margosupplies.com/ca-en/ 

  Nicole Corrado

• Please consider animal welfare

  by Nicole Corrado, over 1 year ago

  I noticed a lot of wildlife live here. Please preserve the trees at this location. Please do not harm animals with this project. Please do not use animal testing for pollution and effluent monitoring. https://www.change.org/p/stop-testing-sewer-water-on-laboratory-fish

  
  

  Please work with the Canadian Centre for the Alternatives to Animal Methods. https://www.uwindsor.ca/ccaam/

  
  

  Please only use non lethal ways to live with geese, beavers, and other wildlife. Develop a Living With Coyotes program with the animal welfare organization Coyote Watch Canada. www.coyotewatchcanada.com

  
  

  Please only use non lethal ways to manage wildlife. There are humane, non lethal ways to deal with beavers. Here's a great resource... Continue reading

  I noticed a lot of wildlife live here. Please preserve the trees at this location. Please do not harm animals with this project. Please do not use animal testing for pollution and effluent monitoring. https://www.change.org/p/stop-testing-sewer-water-on-laboratory-fish

  
  

  Please work with the Canadian Centre for the Alternatives to Animal Methods. https://www.uwindsor.ca/ccaam/

  
  

  Please only use non lethal ways to live with geese, beavers, and other wildlife. Develop a Living With Coyotes program with the animal welfare organization Coyote Watch Canada. www.coyotewatchcanada.com

  
  

  Please only use non lethal ways to manage wildlife. There are humane, non lethal ways to deal with beavers. Here's a great resource. https://thefurbearers.com/downloads/PDFs/Beaver%20Book%20-%202019-10-08%20The%20Fur-Bearers.pdf?fbclid=IwAR1fP2wOYQKbWREX0E5QzYBhZLf9VjwMov3p37Vh8ToW1-NeQvAoVATZhEg%0A%0A

  
  

  https://www.change.org/p/stop-banff-from-killing-animals-after-conflicts

  
  

  https://www.humanesociety.org/resources/humanely-scare-away-canada-geese

  
  

  https://www.canadageese.org/nlcontrol.html

  
  

  https://www.peta.org/wp-content/uploads/2021/06/humane-goose-control-pdf.pdf

  
  

  https://www.humanesociety.org/resources/what-do-about-canada-geese

  
  

  This company makes non lethal products. https://margosupplies.com/ca-en/ 

  
  

  Conventional rodent control uses cruel methods. The companies use glue traps, and snap traps, which, like legholds, can cause injury. They also use rodenticide, which kills slowly and kills many non target animals.

  
  

  https://m.facebook.com/RFOntario/?paipv=0&eav=AfbUBVKF7c1YhT9VJVluqvql7GZ6aUMN4HXsj08GSKGr148rCtpTybY7c3qkHVWijzs

  
  

  Killing animals does not solve the problem. Montreal’s feeding ban bylaw and Rouge National Park's bear proof bins are far more effective because they remove attractants. Please change your pest control policy to instead remove attractants, and fix holes, along with a humane contraception program. Please invest in non lethal solutions like bear proof bins (which also keep out rats) and public education. Tuffbox is a garbage and recycling bin that keeps out bears and rodents. Please also visit www.bearwithus.org to learn more about bears.

  
  

  https://tuffboxx.com

  
  

  http://bonzaiaphrodite.com/2014/09/cruelty-free-pest-control-rats-and-mice/

  
  

  https://www.peta.org/about-peta/faq/is-there-a-humane-way-to-get-rid-of-mice-and-rats/

  
  

  https://m.facebook.com/groups/1117504815249691/permalink/1117515305248642/

  
  

  https://www.peta.org/?s=Humane+pest+control

  
  

  https://antipestrepeller.com/discountsca/sales-page.php?adid=ggdisplay&cid=luccse5&affId=6ACC337B&c1=ca&c2=maxcon_smartdisplay&gclid=EAIaIQobChMI8JyunKzz6wIVHggBCh3NGwocEAEYASAAEgIzTvD_BwE

  
  

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  CONNTRACEPTOL® EFFICIENCY IN MOUSE CONTROL - GUARANTEED MOUSE CONTROL

  via-pet.com

  https://www.via-pet.com/pest-control/p/conntraceptop-forte-for-rats?fbclid=IwAR15EVdQ21_4kYqPuqkX-m2Hyd6y_YF7c9XIVOkO58deqJqkylRcyu1Djvs 

  https://iaac-aeic.gc.ca/050/evaluations/document/155182

  
  

  
  

  Thank you for using bear bins. Please educate people on how to live with them, and develop a no kill wildlife coexistence strategy. www.bearwithus.org os a great organization. So are the Fur Bearer Defenders. https://thefurbearers.com/our-work/living-with-wildlife/

  
  

  More information on other animals can be found here.

  www.coyotewatchcanada.com

  
  

  https://www.humanesociety.org/sites/default/files/docs/HSUS_Deer-Advocate-Toolkit.pdf

  
  

  https://www.torontowildlifecentre.com/wildlife-emergency-rescue-hotline/conflicts-with-wildlife/

  
  

  https://horseshoelake.ca/resources/Documents/Rodenticide%20Free%20Ontario%20-%20Fact%20Sheet.pdf

  
  

  
  

• Support for LAND recommendations

  by Robin Faye, over 1 year ago

  To be brief, there are many, many negatively impactful activities that escape assessment according to the Physical Activities Regulations. There are many projects and potential projects that are not considered major, but should be (SMR's are just one example) because they can (and will) have major effects on their surrounding areas as well as areas downstream. The exemption for projects licensed by the Canadian Nuclear Safety Commission is particularly concerning because it allows industry (in our self-interested economy) to regulate itself regardless of the public's interest. Transparent oversight is necessary to ensure public safety and environmental stewardship. Therefore, I support... Continue reading

  To be brief, there are many, many negatively impactful activities that escape assessment according to the Physical Activities Regulations. There are many projects and potential projects that are not considered major, but should be (SMR's are just one example) because they can (and will) have major effects on their surrounding areas as well as areas downstream. The exemption for projects licensed by the Canadian Nuclear Safety Commission is particularly concerning because it allows industry (in our self-interested economy) to regulate itself regardless of the public's interest. Transparent oversight is necessary to ensure public safety and environmental stewardship. Therefore, I support the position of the Legal Advocates for Nature's Defense and request that you implement their recommendations in full. Thank you.

• Nuclear energy is not a solution to reaching Canadas energy requirements

  by Margaret Sagar, over 1 year ago

  As an informed member of the public and citizen of Canada, I object to the premise that nuclear power is essential to reach Canada’s net zero goals for carbon emissions as we move away from fossil fuels.
  1. Nuclear projects such as the proposed SMRs and MicroMRs have not been created on a commercial scale. They are new unproven technology

  2. They will be extremely expensive to build as are all nuclear power projects.

  3. They will take way too long to build, test etc., at least a decade which makes them come online way too late to meet energy... Continue reading

  As an informed member of the public and citizen of Canada, I object to the premise that nuclear power is essential to reach Canada’s net zero goals for carbon emissions as we move away from fossil fuels.
  1. Nuclear projects such as the proposed SMRs and MicroMRs have not been created on a commercial scale. They are new unproven technology

  2. They will be extremely expensive to build as are all nuclear power projects.

  3. They will take way too long to build, test etc., at least a decade which makes them come online way too late to meet energy needs.

  4. Nuclear power is no less dangerous to survival on earth than fossil fuel emissions. The dangers of radiation, nuclear accident or use of nuclear weapons are huge. The risks are high.

  5. Solar power is now the cheapest of renewables.

  6 Renewables are sustainable as batteries, storage, geothermal and so on become cheaper and more efficient and as industry advances and components such as lithium are recycled.

  7. Nuclear requires extensive mining for highly dangerous substances and is not sustainable.

  In conclusion, I wish to say that the exclusions of proper impact assessment offered in the discussion paper for the nuclear industry terrifies me. The components such as uranium and plutonium are the most dangerous substances on Earth. The high risks of any nuclear power production, mining for uranium etc. are not accounted for. It seems to me that the nuclear industry has lobbied hard for these omissions for its own benefit while ignoring the danger to human and non human beings, and Earth itself. To me this proposal and the money already being poured into research by the federal and provincial governments for SMRs in New Brunswick on the shores of Fundy Bay is insane. No proper studies have ever been done on the impact of such on the land and waters and life for pms found. The money is far better used for investment in renewable, sustainable energy production even as we cap and reduce fossil fuel emissions as quickly and urgently as possible. We are in a climate emergency and nuclear energy is too risky, too expensive and will take too long to develop.

  It is all too easy for nuclear energy for electrical power to be used to create highly destructive nuclear weapons.

  Sincerely.
  
  

  
  

• Rural Ontario home and transport route

  by KCollier, over 1 year ago

  I am a member of Nuclear Waste Watch (NWW) in northern Ontario, but my comments do not necessarily reflect details of their positions.

  In summary, NWW pointed out on several occasions the lack of trust by many, not only NWW, in Canadian Nuclear Safety Commission (CNSC) as a "captured regulator". Too many conflicts of interest and past lapses create no confidence in CNSC being able to carry out its roles.
  NWW believes that storing and management of nuclear waste in situ at or near the sites of nuclear power plants in far preferable to transporting those materials over public roads... Continue reading

  I am a member of Nuclear Waste Watch (NWW) in northern Ontario, but my comments do not necessarily reflect details of their positions.

  In summary, NWW pointed out on several occasions the lack of trust by many, not only NWW, in Canadian Nuclear Safety Commission (CNSC) as a "captured regulator". Too many conflicts of interest and past lapses create no confidence in CNSC being able to carry out its roles.
  NWW believes that storing and management of nuclear waste in situ at or near the sites of nuclear power plants in far preferable to transporting those materials over public roads, rail or by other means such as air or on water craft. Proposals by Dr. Gordon Edwards President of the Canadian Coalition for Nuclear Responsibility (See https://wp.ccnr.org/) about permanent storage and management, made to various government hearings, public meetings, in videos and so forth outline what ought to be done, available at their website - ccnr.org.
  General environmental protections given in the document provided may, in many instances, apply to nuclear waste as well. The recent court proceeding that ruled certain proposed powers of the federal government were unconstitutional drew attention to the powers of the provinces to deal with nuclear and non-nuclear issues. NWW would point out that if there has been a systematic review of the powers, policies and practices of the provinces and the territories to see if they are consistent and sufficient to deal with the complexities of the myriad topics and issues, NWW is unaware of it. As an one EXAMPLE among many, is there a common understanding among the sub-federal levels of government of the definition of a wetland? Are the places of wetlands in public policy across Canada common and consistent. Are wetland policies based on accurate and accepted science or are they subject to political and economic pressure to favour the corporations that damage and degrade them, or that promise to resurrect them to conditions identical to that before project development - likely an impossible promise to keep?
  NWW requests that strict attention be drawn to the kinds of expertise required to carry out tasks related to our previous commentaries made throughout the years and how to find or otherwise attract those who do not suffer from conflicts of interest arising from the dominance of private industry involved in the nuclear fields. Underfunded and fragmented research projects in universities, colleges, institutes and so forth, along with those conducted by private individuals with applicable and unconditional credentials, certainly help to pry open some fields for examination, but the noted funding and isolation problems cannot hope to even enter, let alone compete, in the policy, practice and decision-making fields related to nuclear power. Uranium mining is under-examined territory. The military aspect of these questions is another huge example.
  
  

• Question in overview

  by Sam Arnold, over 1 year ago

  The Overview states that the IAA applies only to major projects and to about ten designated projects per year. It therefore appears to me that the IAAC under section 16 will be able to disqualify any major project that it does not wish to study if it deems the project to not be in the interest of government and federal jurisdiction.

  For example, deep geological repositories (DGR) for high level nuclear waste. It’s well known that DGRs have a high likelihood of failure within 100 years of operation, and much more so for the 1 million years it will take... Continue reading

  The Overview states that the IAA applies only to major projects and to about ten designated projects per year. It therefore appears to me that the IAAC under section 16 will be able to disqualify any major project that it does not wish to study if it deems the project to not be in the interest of government and federal jurisdiction.

  For example, deep geological repositories (DGR) for high level nuclear waste. It’s well known that DGRs have a high likelihood of failure within 100 years of operation, and much more so for the 1 million years it will take for this radioactive waste to become benign. Nuclear energy should never have started 75 years ago, but today we have major and costly conundrum that is eluding a solution in Canada and globally. The IAA must find a solution for Canada’s nuclear waste, and this must be done in such a way that the waste remains accessible at all times forever, both for safety concerns and for possible future energy solutions that don’t yet exist.

  The Sustainable Energy Group is concerned that the operating regulations for the IAA will be weakened and that trust in federal environmental impact regulations will be diminished. We need to see proof that this will not occur.

• Pumped Storage Hydroelectric Facilities

  by Doug Shaigec, over 1 year ago

  
  

  The current inclusion of "hydroelectric generating facilities with a production capacity of 200 MW or more" in the Project List is too broad, in terms of encompassing pumped storage hydroelectric (PSH) projects that may have a production capacity of greater than 200 MW, but not have potential to cause adverse environmental effects in areas of federal jurisdiction.

  For example, closed-loop PSH projects that involve the development of new "dryland" reservoirs (constructed on lands where no existing watercourse is present) do not have the potential for non-negligible adverse changes to fish and fish habitat, or aquatic species as defined in the... Continue reading

  
  

  The current inclusion of "hydroelectric generating facilities with a production capacity of 200 MW or more" in the Project List is too broad, in terms of encompassing pumped storage hydroelectric (PSH) projects that may have a production capacity of greater than 200 MW, but not have potential to cause adverse environmental effects in areas of federal jurisdiction.

  For example, closed-loop PSH projects that involve the development of new "dryland" reservoirs (constructed on lands where no existing watercourse is present) do not have the potential for non-negligible adverse changes to fish and fish habitat, or aquatic species as defined in the Species at Risk Act, as might traditional hydroelectric generating facilities.

  Accordingly, it is suggested that PSH projects be excepted from the "hydroelectric generation facilities..." provision in the Project List. An alternative approach would be to qualify the definition of "hydroelectric generating facilities" here by stipulating that such hydroelectric generating facilities must include works/scope that have the potential to have adverse environmental effects on areas of federal jurisdiction.

  
  

  
  

• Nuclear exemptions

  by Draven, over 1 year ago
  Expanding the recommendation to remove the requirement for SMRs and large licenced technology to also include demonstrated international nuclear technologies both commercial and research reactors. This would also for Gen 4 nuclear reactors to be built in Canada if they have been demonstrated elsewhere. Of course all these technologies would still abide by the CNSC and other regulations.

  Expanding the recommendation to remove the requirement for SMRs and large licenced technology to also include demonstrated international nuclear technologies both commercial and research reactors. This would also for Gen 4 nuclear reactors to be built in Canada if they have been demonstrated elsewhere. Of course all these technologies would still abide by the CNSC and other regulations.