DAOD 4003-4, Environmental Impact Assessment

Table of Contents

1. Introduction
2. Overview
3. Operating Principles
4. Compliance and Consequences
5. Responsibilities
6. References

1. Introduction

Date of Issue: 2025-07-23

Application: This DAOD is a directive that applies to employees of the Department of National Defence (DND employees) and an order that applies to officers and non-commissioned members of the Canadian Armed Forces (CAF members).

Supersession: ADM(IE) Directive of Environmental Impact Assessment, July 2016

Approval Authority: Assistant Deputy Minister (Infrastructure and Environment) (ADM(IE))

Enquiries: Director Environment and Sustainable Management (DESM)

2. Overview

Context

2.1 To fulfill mandates, the DND and the CAF are entrusted by Canadians with significant land and infrastructure holdings. Careful management is:

1. necessary to maintain Defence operational readiness, ensure continuity of missions, and support present and future training and testing requirements; and
2. accomplished through meeting environmental obligations and minimizing the environmental impacts of defence activities, while supporting operational requirements.

2.2 This DAOD is to be read in conjunction with other applicable policies, federal statutes, and special agreements on environmental impact assessment (EIA) as well as relevant federal direction or policy that communicates federal obligations and commitments to Indigenous peoples.

Purpose

2.3 The purpose of this DAOD is to:

1. provide direction to DND employees and CAF members on:
   1. when to undertake an EIA to enable them to meet federal environmental obligations of applicable federal statutes and special agreements, and policies; and
   2. a process to consider whether to conduct an EIA when an activity is not captured under applicable policies, federal statutes and special agreements; and
2. identify the federal sources of requirement and general principles to consider during an EIA.

2.4 As the EIA processes vary according to the requirement (i.e. the applicable federal statutes or special agreements), several standards accompany this DAOD and additional guidance to support the EIA process for projects can be found in the Environmental Impact Assessment Manual and the Supplemental Guidance on Strategic Environmental and Economic Assessment.

2.5 The identification of potential Aboriginal and treaty rights or other Indigenous considerations are outside of scope for this DAOD.

Contribution to Desired Outcomes

2.6 This DAOD contributes to the policy direction included in DAOD 4003-0, Environmental Protection and Stewardship to integrate environmental concerns with other relevant concerns including those from operations, finance, safety, health and economic development in decision-making through the completion of the relevant EIA process for appropriate activities, projects, policies, plans or programs.

3. Operating Principles

Requirement for an EIA

3.1 An EIA may be required under one or more of the following:

1. the Impact Assessment Act (IAA);
2. another federal statute or a special agreement, including:
   1. Mackenzie Valley Resource Management Act;
   2. Nunavut Planning and Project Assessment Act;
   3. Yukon Environmental and Socio-economic Assessment Act;
   4. Inuvialuit Final Agreement;
   5. James and Bay  Northern Québec Agreement; and
   6. Labrador Inuit Land Claims Agreement;
3. the Cabinet Directive on Strategic Environmental and Economic Assessment (2024); and
4. as an element of due diligence.

Decision-Making

3.2 Decision-makers:

1. are DND employees or CAF members with decision-making authority for an activity for which an EIA is being conducted, for example, a project director, project manager or commanding officer at all levels assigned to:
   1. deliver a project;
   2. develop a proposal seeking approval from the Minister, Cabinet or Treasury Board;
   3. plan a military exercise; or
   4. authorize an activity being conducted by a third party;
2. are responsible for DND and CAF activities that are subject to the other federal statutes, special agreements or proposed to take place at, or above 60 degrees north latitude must follow DAOD 8007-0, Notification of DND and CAF Activities Within the Joint Task Force (North) Area of Responsibility; and
3. must seek advice and guidance from ADM(IE), Director General Indigenous Affairs (DGIA) regarding Indigenous rights and obligations for DND and CAF activities that may:
   1. take place on lands below 60 degrees north latitude and subject to ongoing, completed land claims agreements or Land Codes; or
   2. have the potential to affect Indigenous rights.

3.3 Environmental Subject Matter Experts (ESME) are DND employees or CAF members within Defence establishments and organizations who have been appointed with EIA responsibilities.

Early Start

3.4 The EIA process must start as early as practicable, before taking action or making a decision that would enable a project to proceed, so that environmental factors are considered with other relevant factors during the decision-making process. For example, the environment effect determination for projects captured under the IAA should be started as early as practicable so that information can be posted on the Canadian Impact Assessment Registry (CIAR). The IAA requires that:

1. no decision on the environmental impacts related to a project can be made until a notice of that decision is posted on the CIAR; and
2. although the notice period can be no less than 30 days; projects that are more complex should plan for a longer time period on the CIAR before posting a decision.

3.5 Other relevant factors could include timing, required resources, requirements of activities, projects, policies, plans or programs such as:

1. possible permits;
2. authorizations; or
3. whether public engagement must be undertaken.

Due Diligence

3.6 Due diligence requires individuals to:

1. know and obey applicable federal environmental statutes and regulations;
2. exercise caution;
3. prepare for risks that a thoughtful and reasonable person would foresee; and
4. respond to risks and incidents as soon as practicable.

3.7 Despite individual responsibilities and liabilities, commanding officers and other senior authorities must:

1. ensure that DND employees and CAF members under their direction or command are appropriately educated in environmental matters related to their duties; and
2. allocate appropriate resources to properly handle their environmental responsibilities.

Self-Directed Process

3.8 Most activities, projects or proposals undertaken by the DND and the CAF operate under the principle of self-directed assessment that requires a decision-maker to ensure that the appropriate process has been completed when they propose an activity, project, policy, plan or program that triggers the requirements of sections 82 or 83 of the IAA, the Cabinet Directive on Strategic Environmental and Economic Assessment (2024) or an assessment of due diligence. Responsibilities include:

1. determining the scope of the assessment;
2. managing the process;
3. determining whether the activity, project, policy, plan or program should proceed once the appropriate process is complete; and
4. incorporating and implementing mitigation measures from the process into the project, policy, plan or program.

Note – Other EIAs conducted for projects or activities identified as designated projects under the IAA or in accordance with other federal statutes listed at paragraph 3.1 do not operate under the principle of self-directed assessment but are subject to a process of an independent assessment or review process. In these instances, independent organizations have been established under their respective statutes to determine the scope of the assessment, manage the assessment process and provide recommendations to an approving authority.

Objectivity of the EIA Process

3.9 An EIA must be objective and use relevant scientific, technical and environmental expertise.

Open and Participatory EIA Process

3.10 The EIA processes must be open and transparent. The decision-maker working on an activity, project, policy, plan or program that is being assessed for environmental effects must:

1. determine the need for scope and nature of public input as early as possible; and
2. consider any public input provided during the EIA process.

3.11 Unless identified under other departmental direction, activities being assessed as an element of due diligence are not required to consider the need for public input. After conducting the pre-consultation, decision-makers must:

1. determine the need for, and scope and nature of, engagement or consultation with Indigenous groups; and
2. consider any concerns raised.

Back to top

Completion of an Assessment Process Before Proceeding

3.12 No decision-maker may proceed with an activity, project, policy, program or plan for which an EIA is required, until they have fulfilled the requirements in accordance with conditions of the IAA, another federal statute or special agreement, the Cabinet Directive on Strategic Environmental and Economic Assessment (2024) and this DAOD. For projects subject to sections 81 to 91 of the IAA, the process is completed:

1. once the EIA report has been approved by the decision-maker; and
2. when the decision is communicated to the public in a notice of determination on the CIAR.

Process Documentation

3.13 A file for an EIA must:

1. be established, maintained, and retained by the decision-maker for the activity, project, policy, plan, or program in accordance with local file management requirements and the Defence Subject Classification and Disposition System; and
2. contain records and information including:
   1. additional reports undertaken as part of the EIA and reference to any background technical reports that were used in the EIA;
   2. the registration numbers assigned in the DND EIA Portal and the CIAR, when applicable;
   3. any meeting records in the scope of Indigenous engagement or consultations conducted;
   4. input received from Indigenous peoples of Canada with respect to the EIA;
   5. comments provided by the public if any were submitted;
   6. records requiring mitigation measures to be implemented; and
   7. a signed copy of the final EIA report.

Availability to the Public

3.14 Further details on the cases when information in the EIA file can be made available on request from the public are included in the Standards that accompany this DAOD. The decision-maker responsible for the activity, project, policy, plan or program must ensure the timely provision of any requested document or record.

4. Compliance and Consequences

Compliance

4.1 DND employees and CAF members must comply with this DAOD. Should clarification of the policies or instructions set out in this DAOD be required, DND employees and CAF members may seek direction through their channel of communication or chain of command, as appropriate. Managers and military supervisors have the primary responsibility for and means of ensuring the compliance of their DND employees and CAF members with this DAOD.

Consequences of Non-Compliance

4.2 DND employees and CAF members are accountable to their respective managers and military supervisors for any failure to comply with the direction set out in this DAOD. Non-compliance with this DAOD may result in administrative action, including the imposition of disciplinary measures for a DND employee and administrative or disciplinary action, or both, for a CAF member. Non-compliance may also result in the imposition of liability on the part of His Majesty in right of Canada, DND employees and CAF members.

Note – In respect to the compliance of DND employees, see the Treasury Board Framework for the Management of Compliance for additional information.

5. Responsibilities

6. References

Acts, Regulations, Central Agency Policies and Policy DAOD

• Access to Information Act
• Impact Assessment Act
• Mackenzie Valley Resource Management Act
• Nunavut Planning and Project Assessment Act
• Yukon Environmental and Socio-economic Assessment Act
• Cabinet Directive on Strategic Environmental and Economic Assessment
• Cabinet Directive on the Federal Approach to Modern Treaty Implementation
• Framework for the Management of Compliance, Treasury Board
• Inuvialuit Final Agreement
• James Bay and Northern Québec Agreement
• Labrador Inuit Land Claims Agreement
• DAOD 1000-11, Policy Framework for Infrastructure and Environment Management
• DAOD 4003-0, Environmental Protection and Stewardship

Other References

• DAOD 4004-0, Indigenous Affairs
• DAOD 8007-0, Notification of DND and CF Activities Within the Joint Task Force (North) Area of Responsibility
• Environmental Impact Assessment Manual
• Aboriginal Consultation and Accommodation, Updated Guidelines for Federal Officials, March 2011
• Standard 4003-4-1 EIA Processes Under the Impact Assessment Act
• Standard 4003-4-2 EIA Processes Under Other Federal Statues and Special Agreements
• Standard 4003-4-3 EIA Processes in Accordance with the Cabinet Directive on Strategic Environmental and Economic Assessment
• Standard 4003-4-4 EIA Process as an Element of Due Diligence
• EIA Portal, AMD(IE) intranet site
• Environment and Sustainable Management, ADM(IE) DGESM intranet site
• Indigenous Affairs Resources and Tools, Director General Indigenous Affairs intranet
• Canadian Impact Assessment Registry (CIAR)
• Guided Template - Duty to Consult Determination (DTCD)

Back to top