Guidance: “Need for”, “Purpose of”, “Alternatives to” and “Alternative means”

This document is for information purposes only. This document is not intended to fetter decision-makers. It is not intended to suggest that the Government can regulate matters of provincial jurisdiction. It is not a substitute for the Impact Assessment Act (IAA) or its regulations. In the event of an inconsistency between this document and the IAA or its regulations, the IAA and its regulations would prevail.

For the most up-to-date versions of the IAA and regulations, please consult the Department of Justice website.

1. Purpose

The purpose of this document is to provide guidance to proponents when assessing the following four factors: the "need for", "purpose of", "alternatives to" and "alternative means" for a project.

This document is intended, in conjunction with other Impact Assessment Agency of Canada (the Agency) documents, to support proponents of designated projects in the planning of their project, and in the preparation of their project descriptions and Impact Statements. Following the submission of the Detailed Project Description, the Agency may also provide additional direction to the proponent with regard to these four factors in the Tailored Impact Statement Guidelines.

Further information on these factors, including definitions of key terms, is provided in the Policy Context: "Need for", "Purpose of", "Alternatives to" and "Alternative means". Proponents are encouraged to review this document prior to reading this guidance.

2. Process Overview

The alternatives analysis begins at the start of the Planning phase with the proponent's submission of the Initial Project Description. The proponent submits information on the "need for" and "purpose of" the project from its perspective, and provides a list of potential "alternatives to" the project that it is considering or has considered that are technically and economically feasible and directly related to the project. It also provides a list of potential "alternative means" that it is considering that are technically and economically feasible, including the use of best available technologies (BATs). This information provides the necessary context for meaningful engagement and participation on alternatives in the Planning phase.

The proponent provides an updated description of the "need for" and "purpose of" the project and describes the potential "alternatives to" and "alternative means" under consideration in the Detailed Project Description. This information will be used to inform the Tailored Impact Statement Guidelines (TISG) and will allow the Agency to scope the alternatives assessment, as appropriate.

If required by the Agency in the TISG, the proponent submits an assessment of the "alternative means" of carrying out the project and "alternatives to" the project. The alternatives assessments are scalable as qualitative information may be deemed sufficient by the Agency for some alternatives, whereas detailed analyses may be required for the alternatives that address key issues, or have the most potential for avoiding/reducing adverse effects or increasing positive effects, or in the case where there is no clearly preferred alternative.

Information on alternatives that was considered by a proponent before the Planning phase may be brought forward to support the alternatives analysis. It is recommended that previous work on alternatives be presented by the proponent along with the methods used to identify and assess the alternatives as well as the input of Indigenous peoples, the public and other participants.

The approach and level of effort applied to the assessment of "alternative means" is established on a project-by-project basis taking into account five key considerations:

For more information on the process overview, see section 3 of the Policy Context: "Need for", "Purpose of", Alternatives to" and "Alternative means".

3. Planning Phase Requirements

Initial Project Description

Key Deliverable #1: The proponent must describe the "need for" and "purpose of" the designated project as part of the Initial Project Description.

For example, information to demonstrate the "need for" a mine may include the results of a demand forecast or a regional plan that outlines objectives for expanding mining operations in the area.

The description of the "need for" the project describes the opportunity that the project is intended to satisfy. It establishes the fundamental justification or rationale for the project from the perspective of a proponent. In many cases, the need for the project can be described in terms of the demand for a resource. Proponents should report the comments or views of Indigenous peoples, the public and other participants on the proponent's description of the need for a project.

To describe the "purpose of" a project, proponents must outline what is to be achieved by carrying out the project. The statement should broadly classify the project (e.g. electricity supply, mineral extraction/processing, etc.) and indicate the target market (e.g. international, domestic, local, etc.)

The description of the "purpose of" a project should include any objectives a proponent has in carrying out the project. Proponents are encouraged to consider the perspectives of relevant participants (i.e. public, Indigenous groups, governments) in establishing objectives that relate to the intended effect of a project on society. This may help ensure that the process is guided from the outset towards finding mutually beneficial alternatives.

Key Deliverable #2: The proponent must list potential "alternatives to" the project that it is considering that are technically and economically feasible and are directly related to the project, and the potential "alternative means" of carrying out the project that it is considering that are technically and economically feasible, including through the use of best available technologies, as part of the Initial Project Description.

The Initial Project Description must include a list of potential "alternatives to" the project and "alternative means" of carrying out the project. "Alternatives to" the project are functionally different ways to meet the "need for" a project and achieve its purpose that are technically and economically feasible. "Alternative means" are the various technically and economically feasible ways, including through the use of BATs, of carrying out the project.

Further information on "alternatives to" and "alternative means" is provided in the Policy Context: "Need for", "Purpose of", "Alternatives to" and "Alternative means". Proponents must identify any known BATs for the alternative means under consideration. BATs are the most effective technologies or techniques for mitigating adverse effects on people and the environment that are economically feasible to implement. Proponents of projects that have the potential for high greenhouse gas (GHG) emissions will be directed to conduct a formal Best Available Technology/Best Environmental Practice (BAT/BEP) Determination for reducing GHG emissions.

The information included in the Initial Project Description provides the necessary context for Indigenous peoples, the public and other participants to support meaningful early engagement on alternatives. Participants may comment on the Initial Project Description and provide input for the Summary of Issues.

There can be reviews where the scope of "alternatives to" considerations are limited. For example, in the case of a nuclear energy project, an assessment of energy mandates established through federal and provincial legislation/policy may not be within the scope of the impact assessment (IA) - the alternatives to the project need not include alternatives that are contrary to, or not consistent, with federally mandated initiatives and/or a province's formal plans or directives. However, proponents should explain where this rationale has been applied to exclude consideration of possible alternatives to the project.

"Alternative means" of carrying out a project such as a nuclear reactor can include consideration of various options in alternative reactor technologies, cooling water technologies, site location, etc.

For example, a proponent could evaluate the alternative means of carrying out a transmission line project by assessing the various transmission line routes. Criteria used to assess each alternative could include their technical and economic feasibility, and environmental considerations such as avoiding environmentally sensitive areas, reducing habitat fragmentation, or avoiding or minimizing routing through unstable terrain.

Summary of Issues

Key Deliverable #3: The proponent must provide a response to the Summary of Issues, which may include issues raised related to "need for", "purpose of", "alternatives to" and "alternative means".

Following engagement on the Initial Project Description, the Agency will prepare a Summary of Issues that it considers relevant to the assessment, informed by input from Indigenous peoples, the public, other participants, other jurisdictions and the expertise of federal departments. For integrated assessments with lifecycle regulators, the Summary of Issues will be prepared collaboratively with the relevant lifecycle regulator. The Summary of Issues may identify issues of concern relating to the "need for", "purpose of", "alternatives to" or "alternative means".

Detailed Project Description

Key Deliverable #4: The proponent submits updated information on the "purpose of" and "need for" the project, including any potential benefits, according to any new information and input it has received.

A Detailed Project Description of the designated project, which provides more detailed information about the designated project and updates the information provided in the Initial Project Description, must be submitted in response to issues raised by provincial, territorial and Indigenous jurisdictions, Indigenous groups, the public, federal authorities and other participants during consultations and engagement.

Key Deliverable #5: The proponent provides a description of potential "alternatives to" the project that it is considering that are technically and economically feasible and directly related to the project.

The Agency recommends that the proponent follow the three steps below in providing the information relating to "alternatives to" required for the Detailed Project Description.

Step 1: Describe "alternatives to" the project that meet the project's need and achieve its purpose that are under consideration by the proponent

Taking into account the input from Indigenous peoples, the public and other participants, proponents must describe the "alternatives to" the project that are under consideration. It is recommended that the "alternatives to" be described in sufficient detail to determine their technical and economic feasibility as well as their major advantages and disadvantages and must be directly related to a designated project. If there are no alternatives to a project that meet the project's need and achieves its purpose, this must be documented in the Detailed Project Description, and the proponent would not be required to follow steps 2 and 3 below.

Step 2: Screen the "alternatives to" for those that are technically and economically feasible

For example, in the case of a company able to generate electricity from a variety of sources, a hydroelectric dam could be considered as an alternative to a solar farm to meet local energy demands, but a dam may be deemed economically infeasible, as there are no waterways in the region with sufficient flow rates to make the project financially viable.

The technical and economic feasibility of alternatives to a project can be determined using predefined criteria that are project-specific based on evidence and professional judgement. Initially, a qualitative approach may be used to establish how the "alternatives to" a project relate to the criteria, based on estimates and professional judgment. Thresholds and other quantitative decision-making tools may also be used, when available and relevant.

A rationale is to be provided for "alternatives to" that are screened out as not being either technically or economically feasible.

These do not have to be considered further, but it is recommended that they be documented. In such a case, the proponent could omit step 3 below.

Step 3: Describe the advantages/disadvantages of the "alternatives to" the project

Proponents provide a qualitative overview of the advantages and disadvantages of the "alternatives to" the project. Environmental, health, social, economic and technical benefits and costs would be considered in determining the advantages and disadvantages. The perspectives of Indigenous peoples, the public and other participants will inform the advantages and disadvantages for the various alternatives.

Key Deliverable #6: The proponent must provide a description of the potential "alternative means" of carrying out the project that it is considering that are technically and economically feasible including through the use of BATs.

The Agency recommends that proponents follow the steps below in providing the information relating to "alternatives means" required for the Detailed Project Description.

Step 1: Describe "alternative means" that are under consideration by the proponent

Taking into account the input from Indigenous peoples, the public and other participants, a proponent must describe the "alternative means" that it is considering. It is recommended that the "alternative means" be described in sufficient detail to determine their technical and economic feasibility as well as their major advantages/and disadvantages.

Any additional BATs associated with the various components of a project that have been identified must also be listed and described. Proponents should demonstrate what sources were considered in identifying BATs.

Step 2: Screen the "alternative means" for those that are technically and economically feasible

It is recommended that proponents establish criteria to determine the economic and technical feasibility of the "alternative means". These criteria are intended to screen out "alternative means" that are not viable. It is recommended that the criteria be relevant to the project component under consideration and make it possible to reasonably conclude whether the alternative is either technically or economically feasible. Examples of technical criteria include: availability of energy sources, mode of operation, performance metrics, requirement for supporting infrastructure, inherent risks (e.g. safety), use of proven technology, and distance to main project site. Examples of economic criteria include: estimated costs (capital and operating), revenue, profit, and production forecasts.

Initially, a qualitative approach may be used to establish how the "alternative means" relates to the criteria, based on estimates and professional judgment. Thresholds or other quantitative decision-making tools may also be used, when available and relevant for specific criteria.
A rationale is to be provided for alternatives that are screened out as not being either technically or economically feasible.

For example, a proponent proposing a mine identifies two alternative means for disposing of mine wastes as a result of field investigations: one west of the deposit and the other south of the deposit.

The proponent would describe each of these alternatives and then apply the previously established criteria to determine their technical and economic feasibility as shown below.

Criteria Alternative Means A – West of Deposit Alternative Means B – South of Deposit

Ability to implement in study area

Sufficient area within project site. Entails the drainage of a waterbody occasionally used for fishing by community members.

Sufficient area within project site. Minimal overlap with aquatic habitat, which is not frequented by fish.

Ability to manage waste rock and tailings

The waste rock and tailings management facilities would use proven technologies for placement of waste rock and tailings in water bodies.

The waste rock and tailings management facilities would use proven technologies for dry land disposal of waste rock and tailings.

Technically Feasible?

Yes

Yes

Capital costs

Higher costs due to compensation for fish habitat loss.

Slightly lower costs since it does not require compensation, but requires engineering of tall, steep slopes within given space on dry land.

Operating costs

Lower costs due to shorter transportation distance.

Greater costs due to longer transportation distance.

Economically Feasible?

Yes

Yes

Tailored Impact Statement Guidelines

The Agency will use the information provided by the proponent, as well as other information gathered during the Planning phase, to inform the TISG. The TISG may provide additional direction to the proponent regarding requirements for describing the "need for", "purpose of", "alternatives to" and "alternative means" in the Impact Statement.

4. Impact Statement Phase Requirements

Key Deliverable #7: If required, the proponent must provide statements on the "purpose of" and "need for" the project as well as collect the necessary information and conduct the "alternatives to" assessment according to the Tailored Impact Statement Guidelines.

The proponent may be requested to provide information on the "purpose of" and "need for" the project in the Impact Statement.

If there are no "alternatives to" that meet the need for the project and achieve its purpose, or if "alternatives to" is not an issue of concern and the information provided in the Planning phase is deemed sufficient, the "alternatives to" factor may not be included in the TISG.

When further consideration of "alternatives to" is required in the TISG, the proponent will be directed to follow the following steps in assessing the alternatives to the project in the Impact Statement:

Step 1: Describe the no-action alternative

The no-action (null) alternative may serve as a benchmark for the assessment and comparison of a proposed project and any alternatives to a project. It may also highlight the underlying need (or lack thereof) for a project as well as the advantages of carrying out a project. If required by the TISG, the description of the no-action alternative should note the baseline conditions of the VCs associated with the project, as well as changes to these baseline conditions that are likely to occur in the future if a project was not carried out (e.g. changes in result of other projects already planned for the region, changes to the socio-economic conditions, increased resource demand, etc.) In some cases, the description of the no-action alternative will entirely satisfy the requirement of assessing "alternatives to".

Step 2: Comparatively assess the potential effects of the technically and economically feasible "alternatives to" on VCs and other relevant parameters

The Agency may direct a proponent to include the adverse and positive environmental, health, social and economic effects on VCs and the technical and economic parameters of the alternatives when comparatively assessing the alternatives to a project. In addition, the Agency may direct proponents to include other parameters, such as community preference and impacts on Indigenous rights.

Step 3: Identify the proponent's preferred alternative to be the focus of the alternative means assessment

For example, when engaging a local community, the proponent for a mine learns that the local community is seeking new employment opportunities as a result of a recently closed forestry operation. The proponent then describes meeting the need for local employment opportunities as a major positive effect of the project.

The Agency may, in the TISG, require proponents to provide a rationale for the selection of its preferred "alternative to" that includes how the positive and adverse environmental, health, social, and economic effects on VCs, as well as any other parameters used to compare the alternatives, including the project's contributions to sustainability, were taken into account.

Key Deliverable #8: If required, the proponent must collect the necessary information and conduct the "alternative means" assessment in conformity with the TISG.

The TISG may outline the components of the project required to be considered in the alternative means assessment, and evaluation parameters, as appropriate. In consultation with expert federal departments and jurisdictions, Indigenous groups, the public and other participants, the Agency may also identify BATs that are required to be considered as part of an assessment.

During the Impact Statement phase, proponents can consider new (or reconsider previously rejected) alternative means in response to newly obtained information. When conducting the alternative means assessment, the Agency may direct a proponent to follow the steps below.

Step 1: Comparatively assess the potential effects of the technically and economically feasible "alternative means" on VCs or any other relevant parameter

For each set of alternative means:

Proponents may also be required to consider the views or information provided by Indigenous peoples, the public and other participants in establishing parameters to compare the alternative means. Depending on the context of each project, the TISG may require the proponent to apply Gender Based Analysis Plus (GBA+) to the analysis to describe the effects on diverse or vulnerable subgroups.

There are many valid approaches for comparatively evaluating alternative means. Qualitative analyses can often be applied to several project components without considerable commitments of resources. These types of analyses are most suitable when alternate means are well understood, differences in effects are clear, and one alternative outperforms the other. Proponents may base the analysis on information from baseline studies, professional judgement, reasoned argumentation, collaboration and consultation with stakeholders, or, ideally, a combination of these.

For example, in the environmental assessment for the Victor Diamond Mine Project, the proponent considered work scheduling alternatives. Four evaluation parameters were used to comparatively evaluate the alternative means using a qualitative approach:

  Assessment Parameters
Work Scheduling Alternatives Cost-Effectiveness Ability to Service the Site Effectively Adverse effects to Environmental Conditions Effects to the Socio-Economic Conditions

Three weeks at site, one week off site

Lowest flight frequency

Rest intervals not suited to long-term operation

Least disturbance

Difficult for workers and families

Two weeks at site, two weeks off site (preferred)

Lowest flight frequency

Balances change-overs and family life

Least disturbance

Increased family time

One week at site, one week off site

Not financially supportable

Change-overs disruptive to operations

No appreciable effect

Increased family time

Four days at site, three days off site

Not financially supportable

Change-overs disruptive to operations

No appreciable effect

Increased family time

Proponents may be directed to justify the selected approach to the comparative analysis and clearly document methods and results of the assessment. This may include a table comparing the alternative means, outlining the key VCs, the parameters used to measure the effects on the VCs, and qualitative or quantitative descriptions of the effects associated with each alternative.

Step 2: Identify the proponent's preferred alternative to be the focus of the effects assessment

For mining projects proposing the use of natural water bodies frequented by fish for the disposal of mine waste, including tailings and waste rock, and for the management of process water, the Metal Mining Effluent Regulations (MMER) require the affected waterbody to be added to its Schedule 2, in order to designate them as tailings impoundment areas (TIA). This regulatory process will not be initiated until a detailed assessment of alternatives for mine waste disposal has been undertaken by the proponent.

It is customary for the MMER assessment of alternatives to be included the IA process. Conducting this robust and thorough assessment of alternatives during the impact assessment is intended to streamline the overall regulatory review process and minimize the time required to proceed with the MMER amendment process. The proponent is strongly encouraged to include MMER requirements for an assessment of alternatives for mine waste disposal in the Impact Statement.

The assessment must be conducted in such a way that it clearly demonstrates that the chosen location is the most appropriate alternative for mine waste disposal from environmental, technical, economic, social and health perspectives. The assessment of alternatives report shall include the following steps with all supporting documents and/or references:

  1. Identification of Candidate Alternatives (including threshold criteria)
  2. Pre-screening Assessment
  3. Alternative Characterization (including environmental, technical, economical and social considerations)
  4. Multiple Accounts Ledger (including the determination and evaluation of impacts generated by each alternative)
  5. Value-Based Decision Process
  6. Sensitivity Analysis
For further guidance, the proponent should consult Environment and Climate Change Canada's Guidelines.

During the earlier stages of the Impact Statement phase, a proponent would select one or multiple preferred "alternatives to" that become the focus of the impact assessment. Multiple "alternative means" may be brought forward if a proponent remains undecided on its preferred alternative, or if a more detailed assessment of the alternatives is warranted.

In selecting preferred alternatives, a proponent provides a rationale for its selection of its preferred alternatives that describes how the positive and adverse environmental, health, social, and economic effects on VCs, as well as any of the other parameters used to compare the alternatives, including the project's contributions to sustainability, were considered.

5. Conclusion

The key deliverables described in this document outline how to address the "need for", "purpose of", "alternatives to" and "alternative means" in the impact assessment process. The Agency or review panel, federal authorities, other jurisdictions, and other participants, as required, review the proponent's Impact Statement to determine if the information received meet the requirements of the TISG. During the Impact Statement phase, additional information related to the "need for", "purpose of" and alternatives may be requested by the Agency. The resulting information provided is brought forward into the Impact Assessment phase. For more information, see the Policy Context: "Need for", "Purpose of", "Alternatives to", and "Alternative means".

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