Tailored Impact Statement Guidelines Template (generic interim version)
For designated projects subject to the Impact Assessment Act
Revised August 2025 (interim version)
Our website is undergoing significant changes to provide updated guidance on the Impact Assessment Agency of Canada's practice on the application of the Impact Assessment Act and its regulations. This webpage and its contents may not reflect the Impact Assessment Agency of Canada's current practices. Proponents remain responsible for following applicable legislation and regulations. For more information, please contact guidancefeedback-retroactionorientation@iaac-aeic.gc.ca.
This is an interim document. Content will change as a result of ongoing engagement and feedback received. Please check back regularly for updates. This generic interim version is focused on paragraphs (a) to (g) of the definition of adverse effects within federal jurisdiction under section 2 of the Impact Assessment Act (IAA). Other versions may be developed or available, including a version for nuclear reactors projects subject to the IAA and the Nuclear Safety Control Act as well as a version for projects subject to the IAA and the Canadian Energy Regulator Act.
Contents
- Abbreviations and short forms
- Using the Template
- Terminology for Indigenous collectives:
- 1 Introduction
- 2 Project description
- 3 Fish and fish habitat [and marine plants]
- 4 Migratory birds
- [Other VC(s) selected by IAAC related to adverse federal effects]
- 5 Indigenous Peoples
- 6 Contributions to inform decision making
Abbreviations and short forms
Term |
Definition |
---|---|
Adverse federal effects |
"Adverse effects within federal jurisdiction" and "direct or incidental adverse effects" as defined under the Impact Assessment Act |
IAA |
Impact Assessment Act |
IAAC |
Impact Assessment Agency of Canada |
COPC |
Contaminant of Potential Concern |
ECCC |
Environment and Climate Change Canada |
GBA Plus |
Gender Based Analysis Plus |
the Guidelines |
Tailored Impact Statement Guidelines |
GHG |
Greenhouse gas |
HHRA |
Human Health Risk Assessment |
IEPP |
Indigenous Engagement and Partnership Plan |
LSA |
Local Study Area |
Metal and Diamond Mining Effluent Regulations |
|
Minister |
Minister of Environment and Climate Change |
PA |
Project Area |
RSA |
Regional Study Area |
SARA |
Species at Risk Act |
SACC |
Strategic Assessment of Climate Change |
the Template |
Tailored Impact Statement Guidelines Template |
VC |
Valued component |
Using the Template
The Tailored Impact Statement Guidelines (the Guidelines) are a key document of the impact assessment process and outline the required information and studies that the proponent must include in its Impact Statement assessing the effects of its project. The Impact Assessment Agency of Canada (IAAC), or the independent review panel, will consider the Impact Statement, input received, as well as other information gathered through the impact assessment process when drafting its Impact Assessment Report.
The Government of Canada is committed to meeting the objective of "one project, one review" in its review of projects. As part of that commitment, IAAC will work to avoid duplication, including with the processes of other jurisdictions (e.g. provincial governments), and to increase efficiency when developing project-specific Guidelines. This may include issuing joint Guidelines, deferring to the requirements of other jurisdictions where overlap exists (e.g. provincial regulatory requirements), and/or leveraging the means of other jurisdictions to simplify requirements (e.g. relying on provincial standards). For substituted assessments, Guidelines will be developed by the other jurisdiction.
The following Tailored Impact Statement Guidelines Template (the Template) is the starting point to tailor project-specific Guidelines. Project-specific Guidelines will be focussed on key issues anticipated to be material and relevant to decision making based on the nature, complexity and context of the project, and as informed by input received and information gathered during the Planning phase.
To facilitate tailoring, the Template includes tailoring guidance that identifies when requirements are anticipated to be relevant only in limited project-specific circumstances – these are presented in square brackets throughout the Template with instructions in blue highlights. Additional requirements beyond those in the Template may be included in the Guidelines for individual projects, where required, for example when additional effects would result from a federal work or undertaking that is part of the project.
During the Planning phase, draft Guidelines will be posted to the Canadian Impact Assessment Registry (the Registry) for public comment. The final Guidelines will be issued to the proponent along with the Notice of Commencement and posted to the Registry so the process is clear and transparent for all participants.
Terminology for Indigenous collectives:
For the purposes of this document, the term "Indigenous group" is used to refer to a collective of Indigenous People who hold Aboriginal and/or treaty rights as recognized and affirmed in section 35 of the Constitution Act, 1982; while "Indigenous Peoples" is a collective term that refers to First Nations Peoples, Inuit and Métis Peoples in Canada. These are the three groups of Indigenous Peoples recognized by the Canadian Constitution.
IAAC will work with the Indigenous groups identified for consultation and engagement for each project to determine the most appropriate terminology for project-specific Guidelines and the Indigenous Engagement and Partnership Plan. Terminology may vary, for example, Indigenous groups may be replaced with Indigenous communities and Indigenous Nations, and, in some cases, Indigenous organizations may be most appropriate.
IAAC’s guidance on the practice of the application of the Impact Assessment Act and its regulations is being updated, and the current versions of the guidance, referred to in this document, may not reflect IAAC’s current practices. Proponents remain responsible for following applicable legislation and regulations. Proponents are encouraged to engage with IAAC regarding the applicability of the guidance. For more information, please contact [insert project contact].
1 Introduction
The federal impact assessment process is intended to prevent or mitigate significant adverse effects within federal jurisdiction — and significant direct or incidental adverse effects — by anticipating, identifying and assessing the effects of designated projects in order to inform decision making under the Impact Assessment Act (IAA). These [draft] Tailored Impact Statement Guidelines (the Guidelines) for [insert: Name of project] (the project) proposed by [insert: Name of Proponent] (the proponent) were tailored by the Impact Assessment Agency of Canada (IAAC) during the Planning phase of the impact assessment process. IAAC [or: A review panel] will use the proponent’s Impact Statement along with other available information to prepare an Impact Assessment Report.
The [draft] Guidelines include information and studies IAAC considers necessary for the conduct of the impact assessment based on adverse effects within federal jurisdiction, or direct or incidental adverse effects (collectively referred to as adverse federal effects hereafter) that could potentially be significant as informed by the nature, complexity and context of the project, as well as by consultation and engagement with [select those that have been engaged to date: the proponent, Indigenous groups, the public, lifecycle regulators, jurisdictions, federal authorities, and other interested parties].
[For coordinated or integrated assessments unless otherwise described in a cooperation agreement: In support of the Government of Canada’s objective of "one project, one review", the Guidelines identify where the federal impact assessment and the assessment processes of [insert: Name of jurisdiction or lifecycle regulator have shared information needs [or where the proponent is directed to follow the requirements of another jurisdiction.]
[Add for draft Guidelines: The Guidelines will be finalized following a comment period on these draft Guidelines, which will run from XXX to XXX.]
1.1 Scope of the impact assessment
In determining what information and studies are required in the proponent’s Impact Statement, as set out in these [draft] Guidelines, IAAC took into account the factors listed in subsection 22(1) of the IAA, and focused on elements anticipated to be material to decision making under the IAA as described in section 1.2 Selection of Valued Components. [If relevant, specify IAAC’s determination of the scope of factors referred to in paragraphs 22(1)(a) to (f), (h) to (l) and (s) and (t), including the extent of their relevance to the impact assessment, under 18(1.2); specify if IAAC has identified other matter(s) relevant to the impact assessment under paragraph 22(1)(t).]
[If the project has been referred to a review panel: The impact assessment of the project has been referred to an independent review panel by the Minister of Environment and Climate Change (the Minister) as detailed in the Terms of Reference for the review panel.]
1.2 Selection of Valued Components
Valued Components (VCs) serve as the focal points for the impact assessment. The elements of the natural and human environments selected as VCs are those anticipated to be material for decision making under the IAA. The assessment of effects on VCs includes the assessment of the likely effect pathways that are cause-effect linkages between a project component or activity and the VC. The VCs must be assessed following the requirements presented in these Guidelines, as well as the generic assessment methodology in the Generic Requirements for Impact Statements which outlines the steps that must be applied to the assessment of each VC. [State if elements of the generic assessment methodology are not required to be followed in order to support alignment with the process of another jurisdiction.]
The Impact Statement must include, at minimum, the following VCs:
The proponent may select additional VCs, in consultation with Indigenous groups and participants and in consideration of Indigenous Knowledge and community knowledge. The Impact Statement must provide a justification if a VC suggested by an Indigenous group is excluded from the Impact Statement.
1.3 Preparing the Impact Statement
In preparing the Impact Statement, the proponent must adhere to ethical guidelines and cultural protocols governing research, data collection and confidentiality. The proponent must respect the obligation of protecting personal information, including for disaggregated data from small or unique populations, and adopt the established standards for the management of Indigenous data (e.g. the First Nations principles of Ownership, Control, Access and Possession or standards adopted by an Indigenous group), including obtaining permission from Indigenous groups before including information from or about them. The proponent may present the information in the Impact Statement in the manner it deems most appropriate. IAAC recommends the Impact Statement follow the structure of the Guidelines or provide a table of concordance that indicates where in the Impact Statement the information set out in these Guidelines has been provided.
The Impact Statement must address requirements outlined in these Guidelines as well as in IAAC’s Generic Requirements for Impact Statements [state if elements of the generic assessment methodology are not required to be followed in order to support alignment with the process of another jurisdiction], including the requirements on assessment methodology, general information, description of change to the project that may be caused by the environment, description of potential malfunctions and accidents that may occur in connection with the project, description of engagement with Indigenous groups, description of public participation, and Impact Statement Summary. Where the proponent is of the opinion that certain information is not required or cannot be provided, it should contact IAAC prior to submitting the Impact Statement to confirm whether the proponent’s rationale for excluding the information is appropriate. The rationale must also be provided in the Impact Statement. As applicable, the proponent is also encouraged to refer to the requirements of other jurisdictions to assess effects, as well as to means of other jurisdictions to address effects of the project and to report in the Impact Statement how these were leveraged to assess effects. The proponent should also notify IAAC of any changes made to the project relative to the [insert: Initial Project Description or Detailed Project Description].
The Impact Statement must take into account, where relevant:
- any relevant regional or strategic assessment;
- any study or plan that is conducted or prepared by a jurisdiction—or an Indigenous governing body—in respect to the region related to the project and that is provided to the proponent with respect to the project;
- any relevant assessment of the effects of the project that is conducted by or on behalf of an Indigenous governing body and that is provided to the proponent with respect to the project;
- Indigenous Knowledge, community knowledge, as well comments received from Indigenous groups, the public, and any jurisdiction; and
- Gender-Based Analysis Plus (GBA Plus) which, in the context of an impact assessment, is an analytical tool and process that examines how sex and gender intersect with other identity factors to assess who may be disproportionately impacted by a project and how they may experience impacts differently. It helps identify the diverse experiences and needs of various population groups and informs strategies to mitigate barriers and promote equitable access to project benefits.
The proponent is encouraged to engage IAAC as early as possible to clarify the requirements in the Guidelines and to support early resolution of issues. To support this, IAAC may establish technical advisory groups, consisting of, as appropriate, Indigenous groups, federal authorities, provincial authorities or others. The proponent is also encouraged to submit draft documents for review by IAAC (e.g. proposed study plans, draft sections of the Impact Statement) prior to submitting the formal Impact Statement.
As relevant, the proponent is also encouraged to refer to the policy frameworks and guidance available in IAAC’s Practitioner’s Guide to Federal Impact Assessments including the Technical Considerations and References for the preparation of an Impact Statement, and to keep apprised of updates.
1.4 Federal permitting coordination
IAAC will provide coordination of federal permits, licences or authorizations (collectively called permits) early and throughout the impact assessment process to provide:
- clarity on permitting requirements, timelines and processes through the development of detailed federal permitting plans; and
- transparency on the status and progress of permits through public reporting on the Canadian Impact Assessment Registry Internet site.
Under the IAA, federal authorities are prohibited from issuing permits before an impact assessment is completed. The proponent, however, is encouraged to develop federal permit applications concurrent with the impact assessment. In some cases, the same information and studies may be used to inform both the impact assessment and federal permits. Collecting and providing permitting information during the impact assessment process may expedite subsequent federal decisions, where applicable. Early engagement with the federal government, Indigenous communities and the public is essential to support a speedy review of federal permits.
2 Project description
2.1 Project overview
The project subject to the impact assessment is the designated physical activity [insert: name] and any incidental physical activity. [The following physical activities are incidental to the designated physical activity and are thus part of the project: insert: list of physical activities.]
The Impact Statement must:
- describe the project, including key components and activities and their scheduling, timing of each phase, and total lifespan;
- provide the geographic coordinates (i.e. longitude/latitude using international standard representation in degrees, minutes, seconds) for the centre of the main project site [for a linear project: as well as beginning and end points];
- if the project is part of a larger sequence of projects, outline the larger context; and
- [add any additional information requirements specific to the project and its context.]
2.2 Project components and activities
The Impact Statement must:
- describe project components and activities to be carried out during each project phase, with a focus on components and activities with the greatest potential for adverse federal effects and impacts on Indigenous Peoples and their rights:
- at a minimum, include [list key project components or activities],
- for each project activity, describe its location, method used to carry it out, schedule (expected start date, time of year, duration and frequency), magnitude and scale,
- identify activities that involve periods of increased disturbance related to adverse federal effects and impacts on Indigenous Peoples and their rights, and
- identify likely effect pathways between project components and activities and VCs in sufficient detail to support the assessment of effects on VCs and their interactions; and
- include maps of the project footprint and project components, major existing infrastructure, proponent lands, leased properties or lands and adjacent resource leases, land uses and federal lands.
2.3 Receiving environment
The Impact Statement must describe the project’s location, including the geographical setting, meteorological conditions and socio-ecological context required to understand the effects of the project on VCs including and, where appropriate, located on map(s):
- services and infrastructure in the area, including:
- roads,
- municipalities and administrative regions,
- resource development projects and activities,
- local businesses and industries such as fisheries and outfitters, and
- any other relevant uses of land and water;
- local and regional climate, including historical records of weather variation;
- summary data, with data sources, including unique weather station identifiers for:
- monthly mean, maximum and minimum temperatures as well as precipitation,
- typical wind speed and direction, and
- evaporation (e.g. using the Penman, Morton or Meyer Methods) or of evapotranspiration;
- [for projects in permafrost areas: permafrost melting or loss and sea ice loss];
- primary, secondary and tertiary watersheds;
- waterbodies and watercourses, including intermittent and ephemeral, and their location;
- [drainage basins in relation to key project components, flood risk areas, wetlands, and watersheds, as well as direction of flow on topographic map(s), at appropriate scales];
- [riparian areas and wetlands (e.g. fens, marshes, peat lands, bogs) affected by the project, including [list, as applicable]:
- wetland class, ecological community type and conservation status,
- wetland habitat that provides important functions for species at risk, migratory birds and species of importance to Indigenous Peoples, and
- distribution, disturbance level and abundance, at local, regional and provincial scales];
- navigable waterways. In support of federal permitting coordination, if the project includes works that may interfere with navigation and which may require approval(s) or exemption(s) by Transport Canada’s under the Canadian Navigable Waters Act, the proponent is encouraged to coordinate the navigability assessment (baseline conditions) during the development of the Impact Statement in consultation with Transport Canada and users, including Indigenous Peoples, to allow Transport Canada to consider whether an approval or exemption under the Canadian Navigable Waters Act is required and to expedite any subsequent regulatory process, and to include a table listing:
- waterbody or watercourse impacted,
- type of work proposed,
- physical characteristics of waterbody or water course,
- known or suspected past, current or future use of the waterway,
- potentially affected waterway users and concerns regarding waterway use and access, and
- physical impacts from proposed work upstream and downstream;
- landcover in the area, including important vegetation species or communities;
- ecozones, ecoregions, and ecodistricts as per the province’s or Canada’s Ecological Landscape Classification (see Introduction to the Ecological Land Classification (ELC) 2017);
- environmentally sensitive areas, such as national parks, Indigenous Protected and Conserved Areas, UNESCO World Heritage Sites, ecological reserves, [if applicable: marine protected areas, marine refuges,] and habitats of federally listed species at risk;
- lands subject to conservation agreements;
- potable drinking water sources (i.e. municipal or private);
- [description of the terrain, soils and sediments affected by the project, including sediment stratigraphy. Provide surficial geology maps and cross-sections of appropriate scale];
- landforms associated with important wildlife habitat features [including elevated land forms, eskers, ridges, cliffs, rock outcrops, exposed bedrock, talus and other karst topography caves];
- geomorphology, topography and geotechnical characteristics of areas proposed for construction of major project components[, including the presence and distribution of permafrost];
- geology of the [surface, bedrock and unconsolidated sediments] for the project[, including a table of geological descriptions, geological maps and cross-sections at appropriate scale(s)];
- [instabilities caused by historical mining activities];
- [for bedrock blasting: areas of bedrock outcrops that will require blasting identified on geological maps];
- [for potential transboundary effects: distance to the international (e.g. the United States) or provincial border];
- Indigenous traditional territories and/or consultation areas, Treaty and/or Title lands, Reserve lands, Indigenous harvesting regions (with permission of Indigenous groups), Métis settlements;
- federal lands; and
- culturally important features of the landscape.
2.4 Project purpose, need and alternatives considered
The proponent must identify the purpose of and need for the project, as well as alternatives to the project and alternative means of carrying it out.
2.4.1 Purpose of the project
The Impact Statement must outline what is to be achieved by carrying out the project from the proponent’s perspective, broadly classify the project type (e.g. [insert as applicable: transportation, electricity supply, mineral extraction]), indicate the target market (e.g. international, domestic, local), and consider the perspectives of Indigenous Peoples, the public and other participants.
2.4.2 Need for the project
The Impact Statement must describe the underlying opportunity or issue that the project intends to seize or solve from the perspective of the proponent, such as demand for a resource or support for a federal or provincial government objective, provide a rationale that the project is a warranted response, and consider the perspectives of Indigenous Peoples, the public and other participants.
2.4.3 Alternatives to the project
[If sufficient information was provided in the Planning phase on 'alternatives to’: IAAC will rely on the proponent’s [insert as applicable: Initial Project Description, Detailed Project Description or response to the Summary of Issues] [insert as applicable: demonstrating that there are no or describing] "alternatives to" the project that are technically and economically feasible to meet the need for the project and achieve its purpose. No additional information is required.]
[If further information on 'alternatives to’ is required: The Impact Statement must:
- provide a description of the alternatives to the project that are technically and economically feasible to meet the project need and achieve the project purpose, from the perspective of the proponent [including [list any alternatives identified in the Planning phase that require further consideration]];
- present the rationale for selecting the proposed project over other options; and
- consider the views, information and knowledge from Indigenous groups impacted by the project, the public and other participants, as well as existing studies or reports considering alternatives to the project.]
2.4.4 Alternative means of carrying out the project
[If the project is subject to Schedule 2 of the Metal and Diamond Mining Effluent Regulations (MDMER): To support more efficient federal permitting, the proponent is encouraged to provide an assessment of alternatives for mine wasteFootnote 4 disposal in the Impact Statement that follows Environment and Climate Change Canada’s (ECCC) Guidelines for the assessment of alternatives for mine waste disposal. Doing so can reduce the time needed to obtain an amendment to Schedule 2 of the MDMER, if required for the disposal of mine waste into waters frequented by fish. For further guidance, the proponent should consult Guide To The Regulatory Process For Listing Water Bodies Frequented By Fish In Schedule 2 Of The Metal And Diamond Mining Effluent Regulations.]
The Impact Statement must:
- determine the preferred means of carrying out the project, and justify the exclusion of alternative means, considering:
- technical and economic feasibility of alternative means, including use of best available technologies,
- potential for adverse federal effects and impacts on Indigenous Peoples and their rights, as identified by Indigenous groups,
- potential for malfunctions or accidents,
- [consideration of effects to species at risk listed under Schedule 1 of SARA, including any critical habitat, and how these effects may be avoided through alternative means of carrying out the project],
- application of GBA Plus to the analysis of alternative means of carrying out the project to inform how effects may vary for diverse population groups, and
- information provided by Indigenous Peoples, the public and other participants;
- address key project elements in its alternative means analysis, including, but not limited to, the following [include elements relevant to the project:
- route or corridor and means options for transportation (e.g. marine shipping, moving oil or gas),
- route or corridor and means options for linear projects (e.g. transmission lines, roads, railways),
- width of the right-of-way,
- project site and/or component locations,
- timing options for components and phases of the project,
- access to the project site,
- facility design,
- switchyard design,
- marine elements:
- drilling unit systems,
- offshore exploration or production systems,
- disposal of drilling mud and cuttings, gas or produced water, and
- marine storage and supply locations,
- energy sources to power the project site and other stationary sources to provide heat or steam to the project,
- water and wastewater management elements:
- location of effluent discharge points, and
- treatment technologies and techniques to control effluent quality,
- waste management,
- construction alternatives,
- location, construction and crossing methods for waterbodies, watercourses, wetlands and other obstacles,
- management of excavated materials, including those that are acid generating or leachable,
- suspension, abandonment or decommissioning options, and
- mining-related activities:
- mining operations (open pit, underground),
- processing facilities location and design (comminution, separation, concentration and dewatering, and
- mine waste management facilities (tailings, waste rock, overburden, low-grade ore, effluent)].
3 Fish and fish habitat [and marine plants]
The impact assessment must assess the effects of the project on fish and fish habitat, as defined in subsection 2(1) of the Fisheries Act [insert as applicable: and on marine plants, as defined in section 47 of the Fisheries Act] based on likely effect pathways from project components or activities. The spatial scale and pathway of effects will dictate the appropriate fish and fish habitat assessment methods, such as quantifying habitat loss and/or considering long-term population viability.
Where Fisheries Act authorization(s) under section 34.4(2)(b) or 35(2)(b) of the Fisheries Act are likely required for the project, the proponent is encouraged to provide the information required for permitting during the impact assessment in support of an efficient and shortened permitting approval process, and refer to Project Planning: Applying for a Fisheries Act Authorization and the Applicant’s Guide Supporting the Authorizations Concerning Fish and Fish Habitat Protection Regulations. [For projects requiring an MDMER Schedule 2 amendment: This information can also reduce the time needed to obtain an authorization to deposit mine waste into a tailings impoundment area if a regulatory amendment to list the water frequented by fish on Schedule 2 of the MDMER is required. For further guidance, the proponent should refer to the Guide to the Regulatory Process for Listing Water Bodies Frequented by Fish in Schedule 2 of the Metal and Diamond Mining Effluent Regulations.] Where it is not possible to eliminate, reduce or control adverse effects to fish and fish habitat, offsetting measures should be considered, which may include restoration of degraded fish habitat, habitat enhancement or construction, or stocking, refering to the Policy for Applying Measures to Offset Harmful Impacts to Fish and Fish Habitat.
3.1 Baseline conditions for fish and fish habitat [and marine plants]
The Impact Statement must:
- list in a table all waterbodies and watercourses frequented by fish, or on which fish depend directly or indirectly, likely affected by the project. Include in the table:
- whether freshwater, estuarine or marine,
- type and permanence (e.g. temporary, intermittent or ephemeral stream),
- size (e.g. width at the ordinary high water mark) and depths,
- ice regime, and
- whether flows are regulated;
- for each of the waterbodies and watercourses listed above, present maps at appropriate scales using aerial imagery overlaid with relevant descriptions, as well as relevant summary tables, that depict:
- the location and area of fish habitat,
- the location of any known or potential barriers to fish passage, both natural and constructed including water management infrastructure or waterbody crossings (e.g. bridges, culverts, dams, weirs, beaver dam, waterfalls),
- footprint areas of proposed works,
- physical and biological characteristics at a level of detail commensurate with the potential for effects on fish and fish habitat including:
- baseline habitat loss or disturbance (e.g. fragmentation),
- habitat use or suitability, including critical habitat and residences for species at risk, habitat function (e.g. spawning, calving, nursery) and sensitive times for habitat use (e.g. overwintering, migration), or how the habitat directly or indirectly support fish to carry out their life processes,
- important habitat features (e.g. substrate types, beaver dams, riffles, pools),
- habitat areas with high fish abundance or diversity,
- species present, including sub-species and sub-populations, considering inter- and intra-annual variations,
- if applicable, flow direction,
- existing local and regional sources of contaminants,
- [insert as applicable: proximity to protected or sensitive habitat areas],
- [insert as applicable: description and location of erosion-sensitive soils and areas of ground instability], and
- [insert as applicable: presence of invasive or introduced species of concern];
- identify the fish [and marine plant] species that will serve as the focus of the effects assessment, considering that different species may be affected differently by the project and may require different mitigation. Include: [insert as applicable:
- as needed to assess effects to the identified fish [and marine plant] species and fish habitat, providing summary data in maps and tables, and ensuring that sampling sites are co-located for different elements (e.g. fish presence, water quality, sediment quality) and including both sites likely and unlikely (as reference) to be affected by the project, describe [tailor based on project-specific key issues:
- [for underwater noise: underwater soundscape and vibration, including those offshore, based on acoustic measurements, including vibration and sound sources, geographic extent, as well as spatial and temporal variations within the water column and at the seafloor,]
- [for surface water flows: surface water hydrology in the local study area (LSA) and regional study area (RSA) from on-site gauging stations, considering ice cover, freeze-thaw cycle and snow regime, flow hydrographs, water levels and seasonal baseflow for streams and rivers, as well as stage hydrographs for lakes, including quantitative characterization of baseline hydrology in a model detailing baseline surface water flows. The model results must account for inter-annual patterns including trends in flow, permanence, or ice cover, as well as seasonal, or contain an explanation of why these patterns are not material to the effects. This information should be used to characterize the quantity of water in areas frequented by fish and the timing of flows and water levels,]
- [for hydraulic conditions impacting fish passage: local water velocities and levels, including measurements of water velocity profiles and characterization of water levels and flow variability in the potential perturbation zones (e.g. flow velocity, turbulence, shear stress),]
- [for groundwater-surface water exchanges: interactions between surface and groundwater and discharge location, including a quantitative site surface water balance model detailing water intake and outflow to the environment and incorporating surface-groundwater exchanges, as well as delineation and characterization of groundwater–surface water interactions, including groundwater-dependent areas frequented by fish. Where multiple factors or temporal and spatial scales require consideration, a consistent multi-model or integrated modelling approach should be employed. This information should also be used to characterize aquifers related to groundwater-dependent areas frequented by fish and to calibrate and verify numerical flow modelling,]
- [for surface water quality: surface water quality, including temporal trends and groundwater–surface water interactions, representative of seasonal and inter-annual variability and spatial representation relevant to the project components, the LSA and the RSA. The data should be presented in a compiled, tabulated, and graphed form using appropriately sensitive detection limits for water sample collection, and include estimates of relevant physicochemical parameters (e.g. temperature, pH, electrical conductivity, dissolved oxygen, turbidity, total suspended solids, total hardness, total dissolved solids, biological oxygen demand, carbonate equilibrium) and chemical constituents relevant to the project activities and components (e.g. major and minor ions, total and dissolved trace metals / metalloids, radionuclides, total mercury, methylmercury, polycyclic aromatic compounds, persistent organic pollutants, nutrients) in comparison to relevant environmental quality guidelines,]
- [for sediment quality: sediment quality representative of seasonal and inter-annual variability and spatial representation relevant to the project components, the LSA and the RSA. The data should be presented in a compiled, tabulated, and graphed form using appropriate sensitive detection limits for sediment collection. Sediment samples should target silt-clay range (<63um) and include appropriate replication to describe site heterogeneity. Sediment sampling should include relevant physical and chemical parameters relevant to the project activities and components (e.g. particle size, moisture content metals/metalloids, total sulphur, total organic carbon, polycyclic aromatic compounds, persistent organic pollutants),]
- [for bioaccumulation of contaminants: baseline tissue concentrations for [list relevant bioaccumulative contaminants] for fish and other aquatic biota contributing to bioaccumulation through the food chain in comparison to relevant environmental quality guidelines, and]
- [for nutrient enrichment: nutrients and/or productivity.]]
3.2 Effects to fish and fish habitat [and marine plants]
The Impact Statement must:
- describe the likely effect pathways to fish and fish habitat [and marine plants] from project components or activities for each waterbody, watercourse and location likely affected by the project (e.g. point and diffuse sources of discharges and their receiving environment), including [tailor based on project-specific key issues:
- [habitat alteration, disruption or destruction (temporary or permanent) relative to baseline, described in a table in terms of area, habitat type, sensitivity of habitat and impact (e.g. magnitude, intensity, persistence), as well as on maps at appropriate scales,]
- [risk from increased access to the area or to fishing,]
- [for noise-generating activities: risk from noise and vibrations (e.g. blasting),]
- [for water intake or hydraulic structures: risk of entrapment, impingement or entrainment,]
- [risk of introduction of aquatic invasive species, including pathogens,]
- [for water-crossings: changes resulting from watercourse-crossing(s). For each crossing, describe and justify the techniques used, and risk of fish habitat loss from obstructions to fish passage,]
- [for marine shipping: changes resulting from marine traffic including risk of collision with vessels (ship strike), disruption or impairment of activities and behaviour, physiological effects of underwater sound on individuals, increased turbidity, and introduction of invasive species from ballast discharge,]
- [for creation, removal or diversion of waterbodies or watercourses or projects where surface water flows or hydraulic conditions affecting fish passage are a key issue: changes to the alignment of waterbodies and watercourses, locations of any intakes and proposed maximum pumping rates, and any resulting changes in surface water flows based on the quantitative characterization of the hydrology or in groundwater and surface water conditions at a scale, resolution and level of detail relevant to assess the effects to fish and fish habitat,]
- [for project where surface water flow and groundwater-surface water exchanges are a key issue: changes to surface water flows and levels and to groundwater quantity and flow pattern considering surface water and groundwater withdrawal (e.g. spatial scales, timing, quantity and quality of water withdrawn, flow rates and annual volumes), fluxes and the conditions under which this water is released into the receiving environment. Use a three-dimensional numerical groundwater flow model to simulate the hydrogeological system and estimate key water fluxes based on the calibrated baseline conditions model and include:
- major project components, including open pits, underground workings, waste rock piles, tailings management facilities, dewatering wells, water diversion ditches, and sediment ponds,
- changes to surface water flows and hydraulic conditions in the receiving environment caused by project components supported by quantitative data and quantitative characterization through modelling outputs, including:
- flow regimes (e.g. timing and volumes) based on the hydrological model calibrated to baseline conditions,
- velocity regimes and flow hydraulics (e.g. localized velocity perturbations, turbulence, shear stresses, flow reversals),
- sediment transport and deposition patterns affecting habitat structure and water quality, and
- groundwater-surface water interactions, and
- an assessment of the sensitivity of key model outputs to hydraulic properties and climatic parameters such as recharge,]
- [for projects where surface water quality is a key issue: changes to surface water quality at [list locations] due to direct and indirect discharges, surface erosion and sedimentation, generation and deposition of dust and particulate matter, including to physicochemical parameters (e.g. temperature, pH, salinity, dissolved oxygen, total suspended solids),chemical constituents (e.g. major and minor ions, trace metals, radionuclides, nutrients, organic compounds) and changes to water quantity in the receiving environment. Present expected changes as well as risk-based worst- and best-case scenarios. Use appropriate modelling and describe model assumptions, inputs and associated rationale,]
- [for mines and projects blasting rock or placing rock into surface water: changes to surface water and groundwater quality resulting from acid rock drainage and/or metal(loid) leaching from mined, excavated or blasted material, including:
- a consideration of all relevant material, including historical waste, such as waste rock, ore (including off-site), low grade ore, pit wall materials, underground development ramps, process waste (i.e. tailings, heap leach, treatment sludge, coarse coal rejects, processed kimberlite) overburden and potential construction material (i.e. mine rock, quarries, unconsolidated material), and
- a geochemical characterization study describing the spatial and compositional representativeness of samples, the analytical methods used to evaluate geochemical properties (including mineralogy, metal(loid) leaching, and acid generation potential), and the approach used to predict drainage chemistry trends over time, as well as how uncertainties will be addressed as the project advances. Consider relevant guidance, such as Mine Environment Neutral Drainage (MEND) report 1.20.1, International Network for Acid Prevention’s GARD Guide, ECCC’s Environmental Code of Practice for Metal Mines, and applicable provincial or territorial guidance. The study must include a Conceptual Geochemical Model that assesses how project activities and components may affect the quality of surface water, groundwater, and sediment in areas that support fish habitat. This model must include risk-based source terms, integrate geochemical data from relevant materials to predict drainage chemistry and quantify the potential for metal(loid) leaching and acid rock drainage under expected site conditions, especially from sulphidic geological materials,]
- [for projects where contaminants are a key issue (including contaminants not listed in Schedule 4 of the MDMER): temporal changes to water quality and sediment quality at [list locations], compared to applicable guidelines, site-specific objectives or benchmarks, and/or relevant toxicity test results (either site-specific or published):
- indicate the source(s) of contaminants, and their transport and fate, including geographic extent, in the hydraulic environment,
- as applicable, indicate where and when the water quality in the immediate receiving environment begins to meet water quality guidelines,
- estimate quality and quantity of effluent streams released from the site to the receiving environment, including effluent from treatment facilities, dewatering activities, seepage and surface run off from project components and compare their quality to applicable guidelines, objectives or standards. [applicable to novel sources of contamination: For contaminants without regulatory release limits or water/sediment quality guidelines, predicted concentrations should be as low as reasonably achievable, considering social and economic factors and the implementation of best available treatment technology economically achievable, in consultation with relevant regulators],
- update the models used to describe baseline conditions, and describe the contaminants associated with the project, their spatial and temporal locations, their potential flow paths (e.g. groundwater seepage pathways and how they relate to potential receptors), effects of the project on quantity of flow and how they could affect surface water, sediment and groundwater quality, and
- describe the contaminant attenuation capacity within the hydrogeological units in the project area and use this input to assess off-site groundwater and surface water contamination. Alternatively, the proponent may conservatively assume no attenuation capacity, and describe degradation products (i.e. daughter materials) during groundwater flow,]
- [for projects where bioaccumulation of contaminants is a key issue: modeled tissue concentrations for [list relevant bioaccumulative contaminants] for fish and other aquatic biota contributing to bioaccumulation through the food chain compared to relevant environmental quality guidelines,]
- [for projects where nutrient enrichment is a key issue: changes in nutrients and productivity and resulting indirect effects on fish (e.g. eutrophication, food availability),]
- [for projects that emit large quantities of sulphur dioxide or nitrogen oxides: changes due to acidifying emissions from the project and acid deposition in areas sensitive or vulnerable to acidification resulting from the deposition of atmospheric contaminants,]
- [for pipelines or fluid-carrying systems discharging water: discharges of hydrostatic testing waters to the aquatic environment,] and
- [for projects near known or suspected contaminated sites: re-suspension, release or disturbance of known or suspected soil or sediment contamination;]] and
- describe residual and, if applicable, cumulative effects to fish and fish habitat [and marine plants] based on the likely effect pathways and a comparison with baseline conditions.
4 Migratory birds
The impact assessment must assess the effects of the project on migratory birds as defined under the Migratory Birds Convention Act, 1994 based on likely effect pathways from project components or activities.
4.1 Baseline conditions for migratory birds
The Impact Statement must:
- identify species likely present in the LSA and RSA based on data from existing sources and recent field habitat surveys for the breeding and non-breeding season, as well as Indigenous Knowledge and community knowledge that is provided;
- identify the bird species (e.g. a species at risk) or groups of species (e.g. seabirds) that are indicators for effects and will serve as the focus of the effects assessment, considering that different species and groups of species may be affected differently by the project and may require different mitigation. Where there is uncertainty as to bird species likely present in the project areas, the selection of birds should be inclusive and representative. Birds must include:
- as needed to assess effects, for each bird identified:
- describe population, including subpopulations or subspecies that may have distinct ecological requirements or migratory routes, distribution, seasonal ranges, migration, movements, frequency and timing of occurrence, habitat association(s) and requirements for relevant life cycle stages, and sensitive periods (e.g. seasonal, time of day), including estimates of abundance or density where available,
- describe and quantify habitat based on the best available existing information and recent field habitat surveys, including:
- maps with habitat survey locations,
- maps with expected areas of concentration of key birds, including sites likely used over the course of the year for breeding, feeding, wintering, movement, resting or roosting, staging and migrating, as applicable,
- description and maps of the location of areas important to birds (e.g. bird sanctuaries), and of residences and critical habitat for species at risk as defined in recovery strategies,
- maps of rare, unique or threatened habitat or habitat features (e.g. old forest, species-specific breeding habitat, eskers and other similar geological formations), and a description of how migratory birds are expected to use that habitat year-round (e.g. winter, spring migration, breeding season, fall migration, movement corridors) based on available information,
- maps of the project’s footprint relative to information about birds, identifying temporary and permanent infrastructure, and description of whether project components avoid sensitive habitat such as breeding territories or areas of seasonal concentration, and
- maps of nests that will be or have been added to the Abandoned Nest Registry and are being monitored to comply with the Migratory Birds Regulations, 2022; and
- justify whether existing information and recent field habitat surveys are sufficient to support the assessment of likely residual and cumulative effects on the migratory birds identified and to determine the extent to which these effects are significant considering uncertainties and bias, as well as spatial and temporal representation, in the baseline. If not sufficient, conduct and include additional field bird or habitat surveys, as needed to assess effects, which may include:
- targeted field bird surveys of presence or locations of species at risk where unique mitigation measures and/or follow-up could be required,
- field habitat surveys to identify rare habitats or geological features, nests, and critical habitat for species at risk, and
- field bird surveys where risk or uncertainty related to effects on birds are moderate to high, where bird presence, population or distribution are poorly understood (e.g. flyway or stopover that could be affected to a high extent), or where appropriate mitigation measures are unknown or uncertain.
4.2 Effects to migratory birds
The Impact Statement must:
- describe the likely effect pathways to birds from specific project components (temporary and permanent) and activities during all phases of the project, considering risks of mortality (e.g. from collisions, predators) and disturbances (e.g. from light, presence of workers). [Project components and activities considered must include [list as relevant]]; and
- describe residual and, if applicable, cumulative effects to migratory birds resulting from the likely effect pathways to birds, including an estimate of effects resulting from habitat changes (e.g. degradation, removal) and of effects to species at risk critical habitat.
[Other VC(s) selected by IAAC related to adverse federal effects]
[If applicable, add requirements anticipated to be material to IAA decision making for the additional VC(s) identified by IAAC related to adverse federal effects in section 1.2 Selection of Valued Components. Additional VC(s) can be presented in separe sections of the Guidelines, or combined with other VCs, and may include:
- marine environment outside Canada;
- interprovincial, boundary or international waters;
- environment on federal lands;
- a VC likely affected by a physical activity that is part of the designated project and that is a federal work or undertaking or is carried out on federal lands; or
- a VC likely affected as a result of a federal decision permitting or enabling the project, in whole or in part (direct or incidental adverse effect).]
5 Indigenous Peoples
The Impact Statement must demonstrate how impacts on Indigenous Peoples and their rights were considered and assessed, including:
- impacts resulting from any change to the environment on physical and cultural heritage or any structure, site or thing that is of historical, archaeological, paleontological or architectural significance;
- impacts resulting from any change to the environment on the current use of lands and resources for traditional purposes;
- changes to the health, social or economic conditions of Indigenous Peoples; and
- any adverse impacts on Indigenous rights.
Indigenous Peoples are best placed to understand how a project may impact them. The assessment of impacts on Indigenous Peoples and their rights must be done in collaboration with Indigenous groups as outlined in Description of engagement with Indigenous groups. Where relevant, the proponent must collaborate with Indigenous groups to incorporate information from or about them into the assessment of all VCs (e.g. biophysical VCs). The proponent must respect each Indigenous group’s preferences for assessing impacts, and discuss with each Indigenous group whether it is appropriate for the proponent to provide its conclusions regarding (residual and cumulative) impacts on Indigenous People and their rights. If an Indigenous group has provided their own conclusion, the proponent is not required to provide one.
The proponent is expected to engage with all Indigenous groups impacted by the project, as set out in the Indigenous Engagement and Partnership Plan (IEPP), and to describe the outcomes of that engagement in the Impact Statement. In addition, the results of engagement should be analyzed and presented separately for each Indigenous group. This group-specific assessment does not need to repeat the entire analysis of each VC, but should summarize and present the information relevant to that group. To the extent possible, each group-specific assessment should be done in a way that works best for that Indigenous group.
Where requested by Indigenous groups, parts or all of the assessments of effects on Indigenous Peoples and their rights can be combined in the group-specific assessment. For example, effects on the current use of lands and resources for traditional purposes and impacts on Indigenous rights to hunt, fish, and trap can be reported together. Indigenous groups may also identify holistic VCs that encompass multiple environmental, health, social, or economic elements. Undertaking these assessments together, when requested, will support consistent conclusions. In all cases, the Impact Statement must demonstrate that all requirements were met.
5.1 Indigenous physical and cultural heritage, and structures, sites, or things of significance
The Impact Statement must assess and clearly distinguish the impacts of the project to physical or cultural heritage from the impacts to specific structures, sites or things, as well as align with the considerations set out in the Technical Guidance for Assessing Physical and Cultural Heritage or any Structure, Site or Thing.
5.1.1 Baseline conditions for physical and cultural heritage, and structures, sites, or things of significance
The Impact Statement must describe baseline conditions including:
- how existing cumulative effects have already impacted physical and cultural heritage;
- the location of physical and cultural heritage features on maps, if they have been shared by Indigenous groups with the proponent and if the proponent has permission from the Indigenous groups for the information to be shared publicly. If required, a coarser geographic resolution can be presented; and
- how Indigenous groups participated, including by leading or contributing to studies.
5.1.2 Effects to physical and cultural heritage, and structures, sites, or things of significance
The Impact Statement must:
- assess effects to physical and cultural heritage, and structures, sites or things of historical, archaeological, paleontological or architectural significance based on a comparison with and without the project, including: [add any relevant structures, sites or things of significance, and potential effects, identified by Indigenous groups during the Planning phase:
- [effects on structures, sites or things of significance including:
- burial sites,
- spiritual sites, including rivers and watercourses,
- cultural landscapes,
- teaching areas used to transfer knowledge between generations,
- sacred, ceremonial or culturally important places, plants, animals, objects, beings or things,
- places with archaeological potential or artefacts,
- historically occupied sites, and
- elements of the environment identified by Indigenous groups as having heritage value,]
- [loss or destruction of physical and cultural heritage, including:
- oral histories,
- cultural values and experiences on the land,
- Indigenous governance systems and Indigenous laws tied to the landscape, and
- place names, language and other elements that make up a culture,]
- [changes to access to and/or experience with physical and cultural heritage,]
- [changes to the cultural value, spirituality, or importance associated with physical and cultural heritage,]
- [changes to sacred, ceremonial or culturally important places, objects or things,]
- [changes to visual aesthetics over the life of the project and post-project abandonment or decommissioning,]
- [changes to elements of the environment identified by Indigenous Peoples as having heritage value,] and
- any other effects identified by Indigenous groups];
- describe how impacts on Indigenous Peoples and their rights will also impact the ability of Indigenous Peoples to transmit their culture, language or Indigenous Knowledge intergenerationally, for example, through ceremonies, harvesting, teaching of stewardship laws, or a community tradition of sharing;
- provide copies of correspondence with provincial, territorial or Indigenous authorities responsible for heritage resources with comments on any physical and cultural heritage resource assessment; and
- describe how Indigenous Knowledge as well as engagement with Indigenous groups informed studies, including the identification of the sites to assess, and include any studies provided by Indigenous Peoples if permission has been obtained from the Indigenous group to include them.
5.2 Current use of lands and resources for traditional purposes
The Impact Statement must assess the impacts of the project to the current use of lands and resources for traditional purposes. The analysis must align with the steps set out in the Technical Guidance for Assessing the Current Use of Lands and Resources for Traditional Purposes under CEAA, 2012.
5.2.1 Baseline conditions for current use of lands and resources for traditional purposes
The Impact Statement must describe baseline conditions, including:
- how existing cumulative effects have already impacted the current use of lands and resources for traditional purposes;
- Indigenous governance systems and Indigenous laws associated with the current use of lands and resources for traditional purposes;
- traditional activities presently or historically practised (e.g. hunting, fishing, trapping, gathering of plants or medicines, access or travel routes); and
- baseline conditions for likely effect pathways to impacts on the current use of lands and resources by Indigenous Peoples for traditional purposes, in sufficient detail to support the assessment of impacts, including:
- species use (e.g. magnitude, timing) and availability as country foods (traditional foods) or for other traditional purposes. Include a description of each species of importance [including [list species identified as of importance by Indigenous groups]] and whether their consumption has cultural importance for Indigenous groups, including medicinal uses. For each species, describe baseline conditions at a level of detail relevant to assess adverse federal effects considering population, distribution, seasonal ranges, migration, movements, frequency and timing of occurrence, habitat association(s) and requirements for all relevant life cycle stages, sensitive periods (e.g. seasonal, time of day), including maps and, where available, estimates of abundance or density.[For fish and birds, refer to the requirements in the fish and fish habitat section, and migratory birds section of the Guidelines respectively]. Where possible, sites used in the study areas or historically important sites for the collection of country foods must be identified and mapped, such as important fishing sites, and
- existing navigable waters and their uses, navigable water users, and existing concerns regarding navigable water use and access.
5.2.2 Effects to current use of lands and resources for traditional purposes
The Impact Statement must:
- assess the effects on current use of lands and resources for traditional purposes, based on likely effect pathways and a comparison with and without the project, including changes to:
- the quantity, distribution, and quality (including perceived quality) of resources available for harvesting and consumption of country foods (traditional foods), specifying the species and resources used or important for traditional and cultural purposes,
- navigation and navigation safety, including to navigable waters for each affected waterway and likely effect pathway (dewatering of watercourse or water body, water-level changes, diversion, crossing, etc.),
- specify the crossing method for all project components that will be constructed in, on, under, over, through or across navigable waters (e.g. temporary or permanent bridges),
- navigable water users and navigational use,
- the locations, frequency, duration or timing of fishing, hunting, trapping, gathering, cultural or ceremonial activities and other traditional practices, including any avoidance of resources due to perceived quality,
- access to:
- culturally important harvesting areas or resources and travel routes for conducting traditional practices (e.g. physical access to harvest-specific species, culturally important locations),
- traditional territories, communities and reserves, and
- locations of importance for traditional use, including camps, cabins and gathering, staging, or teaching grounds,
- economic burdens of, and increased time for, travelling further to hunting, fishing, trapping, and gathering opportunities,
- efforts by Indigenous groups to restore traditional practices,
- the experience of being on the land (e.g. changes in air quality, noise and sensory disturbance, artificial light, fragmentation of traditional territory, visual aesthetics/landscape and any corollary wellness impacts as a result of sensory changes, including perceived contamination),
- the use of riverbanks, travel ways, navigable waterways and waterbodies, including for social and ceremonial purposes, travel or recreation, and
- other current uses identified by Indigenous groups; and
- describe how the information provided by Indigenous groups, including Indigenous Knowledge, has been considered.
5.3 Health, social and economic conditions of Indigenous Peoples
The Impact Statement must assess the impacts of the project on the health, social and economic conditions of Indigenous Peoples. The proponent is encouraged to refer to the Indigenous Mental Wellness and Major Project Development: Guidance for Impact Assessment Professionals and Indigenous Communities; the Final Report on Missing and Murdered Indigenous Women and Girls, in particular the Calls for Justice for Extractive and Development Industries (Calls for Justice 13.1 to 13.5), and Health Canada’s Interim Guidance: Health Impact Assessment of Designated Projects under the Impact Assessment Act.
5.3.1 Baseline conditions for the health, social and economic conditions of Indigenous Peoples
The Impact Statement must:
- describe the health, social and economic conditions of each impacted Indigenous group using disaggregated data where available and considering intersecting identity factors and differing access to resources, opportunities and services;
- describe how cumulative effects have already impacted the health, social and economic conditions of each Indigenous group;
- consider Indigenous governance regimes and relevant Indigenous laws;
- describe how Indigenous Knowledge and input were used in establishing baseline conditions;
Baseline health conditions of Indigenous Peoples
- consider health conditions in the context of physical, mental and social well-being;
- develop community health profiles for each impacted Indigenous group, including diverse population groups within them, using definitions of health and well-being from the perspective of the group. Include health outcomes identified as of interest by Indigenous groups, as well as the biophysical and social risk and protection factors relevant to these health outcomes identified by Indigenous groups;
- describe existing health services and programs, including their capacity;
- describe the level of food security and food sovereignty within Indigenous groups, including consumption of country foods (traditional foods);
- to support the biophysical determinants of health (e.g. exposures to chemical and radiological substances) assessment, describe in sufficient detail:
- the location of representative current and foreseeable future human receptors, including Indigenous groups’ hunting, gathering, trapping and fishing areas, permanent and temporary residences (e.g. Indigenous cottages and camps) and infrastructure (e.g. schools, hospitals, community centres, retirement complexes, health care centres). Include maps where possible,
- the contaminants of potential concern (COPC), and
- the connections existing between the COPC, human receptors and the current and future exposure pathways as shown by a conceptual site model, which may be complemented by preliminary model predictions;
- describe and locate recreational, cultural and drinking water sources, from surface or groundwater, permanent, seasonal, periodic or temporary, including wellhead capture zones, and their properties as identified by Indigenous groups such as taste, colour, clarity, temperature, odour;
- provide baseline concentrations of the COPC, which may be in ambient air; recreational, cultural or drinking water sources; soil or sediments; and tissues of country foods consumed by Indigenous groups based, where possible, on environmental samples collected with Indigenous groups;
Baseline social conditions of Indigenous Peoples
- provide a demographic profile of each Indigenous group consulted, using disaggregated data where available;
- describe the community profiles including the Community Well-Being Index for each Indigenous group consulted, using publicly available data and determinants of social well-being identified by Indigenous groups, which may include for example:
- community cohesion, including level of support and engagement in the community or neighbourhood, social networks and social activities,
- access, ownership and use of resources, including land tenure, minerals, food, water, social infrastructure, and
- relevant historical context (e.g. assimilation policies) and past experiences with developers;
- describe the existing infrastructure and their capacity in the study area[, including:
- roads and traffic safety,
- railways, ferries, marine terminals, and airports,
- pipelines, water mains, sewer lines, and utilities, and
- power lines and other infrastructure];
- describe existing local and regional services and their capacity [including:
- accommodation and lodging (e.g. affordability, availability, suitability), including camping facilities,
- public transportation,
- recreation and parks,
- waste disposal,
- educational services, facilities and daycare,
- Elder care and services,
- ambulance, police and fire services, and
- social services and other services];
Baseline economic conditions of Indigenous Peoples
- describe the main economic activities of Indigenous Peoples in the study areas, including:
- information on economically active members of the Indigenous population (e.g. participation in wage labour, entrepreneurial activities and traditional economic activities),
- overview of Indigenous businesses that may provide supplies and services for the project, and
- description of any use of lands and waterbodies for economic activities (e.g. commercial fishing, ecotourism and outfitters);
- describe the Indigenous workforce, including:
- availability of skilled and unskilled workers, and conditions influencing workforce availability over the project timeline,
- existing barriers to employment and participation in the labour market,
- workforce development and training plans for Indigenous Peoples, and
- overview of Indigenous participation in the local and regional workforce;
- describe Indigenous or federal economic development plans for the study areas; and
- describe relevant treaty provisions pertaining to economic activities for Indigenous Peoples.
5.3.2 Effects on Health, Social and Economic Conditions of Indigenous Peoples
The Impact Statement must:
- describe effects of the project on the health, social and economic conditions of impacted Indigenous groups, including:
- ability to engage in traditional and other social and economic activities,
- well-being, including mental and social well-being (e.g. stress, depression, anxiety, sense of safety) as well as opportunities for enhancement of positive effects (e.g. economic opportunities, increased access to services),
- alignment with goals from local or regional land use, development, welfare and safety plans,
- environmental and cultural stewardship,
- differential effects among diverse population groups from the GBA Plus,
- interactions and interconnections within and between effects and VCs, and
- the anticipated absolute and proportional levels of Indigenous economic participation (e.g. number of workers, revenue sharing, ownership, equity and other related measures);
Effects on Indigenous Peoples health
- based on the conceptual site model, conduct a Health Impact Assessment, including biophysical and social determinants of health or provide a rationale for why it is not warranted;
- if a quantitative Human Health Risk Assessment (HHRA) is not conducted, provide a rationale for why it is not warranted based the problem formulation and/or preliminary model predictions;
- if a quantitative HHRA is conducted:
- assess likely exposure pathways for COPCs and consider a multimedia HHRA for contaminants with multiple pathways. The proponent is encouraged to refer to the best practices in Health Canada’s Guidance for Evaluating Human Health Effects in Impact Assessment: Human Health Risk Assessment,
- describe and quantify thresholds (e.g. toxicological reference values) used in the HHRA, including those for vulnerable populations (e.g. children) and justify any exclusions, and
- justify if any human receptors, COPC, or exposure pathways have been excluded from the quantitative HHRA. In cases where there are no guidelines, standards, or criteria available for screening an environmental medium (e.g. country foods), the COPC must included to determine whether there may be health risks associated with the predicted concentrations;
- assess impacts on the health of Indigenous Peoples from likely biophysical effect pathways considering:
- air quality from project-related air emissions including based on a comparison with Canadian Ambient Air Quality Standards established by the Canadian Council of Ministers of the Environment, National Ambient Air Quality Objectives and relevant provincial standards. The proponent is encouraged to refer to Health Canada’s Guidance for Evaluating Human Health Effects in Impact Assessment: Air Quality,
- for non-threshold air pollutants (e.g. PM2.5 and NO2), air quality criteria and guidelines must not be used as 'pollute-up-to levels’, since any increase in exposure will result in an incremental population risk. When pollutant levels approach or exceed applicable Canadian or provincial standards, the proponent is encouraged to compare against solely health-based guidelines (e.g. World Health Organization Global Air Quality Guidelines),
- quality (including perceived quality) of country foods (traditional foods), and water for drinking, recreation and cultural use, including project-related contaminants that may affect country foods through absorption via water, air or soil, including chemicals with the potential to bioaccumulate (e.g. arsenic, cadmium, lead, mercury),
- groundwater or surface water quality for domestic purposes, based on the Guidelines for Canadian Drinking Water Quality (GCDWQ) and relevant provincial water quality standards or guidelines,
- [when diesel engines are a source of air pollutant emissions: carcinogenicity of diesel exhaust gases and the cancer risks from human exposure to potentially carcinogenic polycyclic aromatic hydrocarbons in the diesel mixture, as well as non-cancer risks using established guidance values in Human Health Risk Assessment for Diesel Exhaust],
- ambient vibration and sound levels, including frequency and timing, at receptor locations. The proponent is encouraged to refer to Health Canada’s Guidance for Evaluation Human Health Effects in Impact Assessment: Noise, and
- [night-time light levels, including frequency, timing, duration, distribution and character of light emissions, at receptor locations taking into consideration Indigenous Peoples’ expectations on landscape preservation, particularly landscapes at night and, if relevant, existing regulations around light pollution];
- using a social determinants of health approach, assess impacts on the health of Indigenous Peoples from key social determinants of health, including psychosocial stress factors such as:
- perceived risks to human health,
- the resilience and well-being of Indigenous groups,
- public health and safety concerns (e.g. risk of malfunctions or accidents related to project operations; risks to the health and safety of Indigenous women and girls such as gender-based violence),
- disturbance of daily activities, and
- avoidance of certain country food sources or of drinking or recreational water sources due to the perception of contamination;
Effects on social conditions of Indigenous Peoples
- assess effects on community well-being, considering:
- changes to food security and food sovereignty, income inequity, cost of living, population changes, and shifts in local economic activity,
- temporary or permanent population increase, such as in-and out-migration effects,
- effects on the non-commercial/trade economy, and
- risks to community, family and household cohesion, such as increased substance use, greater reliance on women’s shelters, substance abuse, and involvement in illegal or disruptive activities;
- describe workforce interactions with Indigenous groups and their differential impacts, particularly on women and girls, in the context of the National Inquiry into Missing and Murdered Indigenous Women and Girls (Calls for Justice 13.1-13.5);
- evaluate effects on access, ownership and use of resources (e.g. land tenure, minerals, food, water, social infrastructure);
- describe effects on local and regional infrastructure, facilities and services, including any need for government or proponent expenditures on new or expanded services, facilities, or infrastructure due to project activity-related effects;
Effects on economic conditions of Indigenous Peoples
- describe the changes in employment for Indigenous groups, including as resulting from:
- ability of the local labour market to meet demand,
- training programs, initiatives and measures to improve employment opportunities for Indigenous Peoples, as well as workforce diversity and inclusion, and
- potential for labour shortages and how they would be addressed;
- if relevant and where concerned Indigenous groups agree with including this information, describe benefit agreement being considered or discussed;
- provide an estimate of the levels of economic participation for Indigenous groups in comparison to the total project requirements (e.g. employment, total dollar value of contracts);
- describe the situations where the project’s activities may directly or indirectly create economic hardship or opportunities, or displace businesses; and
- describe effects on the economic conditions of Indigenous groups resulting from environmental changes, as identified by Indigenous groups.
5.4 Rights of Indigenous Peoples
The IAA affirms the Government of Canada’s commitment to ensure respect for the rights of Indigenous Peoples of Canada recognized and affirmed by section 35 of the Constitution Act, 1982. The proponent is encouraged to refer to IAAC’s Guidance: Assessment of Potential Impacts on the Rights of Indigenous Peoples, Policy Context: Assessment of Potential Impacts on the Rights of Indigenous Peoples and IAAC’s Indigenous Advisory Committee Principles to Guide the Assessment of Impacts to Indigenous Inherent and Treaty Rights.
5.4.1 Baseline conditions
The Impact Statement must:
- describe the rights of Indigenous Peoples impacted by the project, including historical context and the importance of the rights to the rights-bearing communities (e.g. the connection of rights to practices, customs, beliefs, worldviews, and livelihoods);
- include information on how rights have already been impacted by cumulative effects, and how existing and reasonably foreseeable future activities could affect the conditions that support or limit the Indigenous groups’ meaningful exercise of their rights;
- document the nature and extent of the exercise of rights of Indigenous Peoples, impacted by the project, as identified by the Indigenous group(s); and
- consider how the information requirements related to physical and cultural heritage, use of lands, Indigenous health, social, and economic conditions, are applicable to the nature and extent of the exercise of rights.
Indigenous groups must be involved in the baseline characterization of their rights.
5.4.2 Impacts on rights of Indigenous Peoples
The proponent must share studies and information about the project and its potential impacts with Indigenous groups prior to assessing the impact of the project on their rights, and collaborate with Indigenous groups in assessing impacts on those rights.
The Impact Statement must:
- document the project’s impacts on the rights of Indigenous Peoples and their severity, considering links between resources, access, and experience, including:
- residual impacts on the exercise of rights,
- interference with the quality and quantity of resources available for the exercise of rights (including preferred species),
- changes to the ability to travel freely in the territory and to access areas important to the exercise of rights,
- changes to the experience associated with the exercise of rights, including in connection to land, well-being, knowledge of the landscape, air quality, noise exposure, effects of vibrations, artificial light, fragmentation, visual aesthetics and safety,
- impacts on Indigenous traditions, laws and governance,
- impacts on stewardship of traditional lands and resources by Indigenous groups,
- changes to the ability of Indigenous groups to derive future economic benefits from the land or water,
- changes to the ability to maintain an ongoing relationship with the land or water,
- alignment with the values, political direction and/or objectives of Indigenous groups’ actions to mitigate or to adapt to a changing climate,
- changes to the authority of Indigenous groups on their territory, and
- all other elements of significance identified by Indigenous groups;
- describe solutions to concerns raised about impacts on the exercise of rights, as agreed to by Indigenous groups;
- describe how the assessments of impacts on Indigenous Peoples (including impacts on physical and cultural heritage, current use of lands and resources for traditional purposes, and the health, social, and economic conditions of Indigenous Peoples) were integrated into the assessment of impacts on Indigenous rights and considered in determining residual and cumulative impacts and their severity;
- describe the methodology used and agreed to by Indigenous groups for assessing impacts on their rights, and include any Indigenous-led studies that were provided if permission has been obtained from the Indigenous group to include them; and
- where an Indigenous group has not provided its views on the impact of the project on their rights to the proponent, or where the proponent and an Indigenous group, in consultation with IAAC, agree that the Indigenous group will provide information on impacts on their rights directly to IAAC [or the review panel], provide an explanation.
6 Contributions to inform decision making
At the decision-making phase of the IAA, should the decision maker determine that the adverse federal effects that are likely to be caused by the project are likely to be, to some extent, significant, the decision maker will decide whether they are justified in the public interest in light of the extent to which they are significant and of the factors set out in section 63 of the IAA. The requirements in this section of the Guidelines may inform the analysis of these factors.
6.1 Canada’s environmental obligations and climate change commitments
IAAC, with the support of federal authorities, will analyze the project’s likely effects in the context of Canada’s environmental obligations relevant to this project, as well as the project’s GHG emissions in the context of Canada’s emissions targets and forecasts. [Tailor if applicable: The information gathered during the Planning phase suggests that the project would result in biodiversity loss [and/or] GHG emissions [and/or list identified hindering of environmental obligations or climate change commitments] through [add short rationale]]. Where the proponent is of the view that the likely effects of the project contribute to the Government of Canada’s ability to meet its environmental obligations and/or its commitments in respect of climate change, the proponent is encouraged to substantiate this view in the Impact Statement by describing these likely effects and the extent of their contribution (e.g. net increase in biodiversity through habitat restoration; net GHG reductions domestically through carbon capture).
6.1.1 Environmental obligations
Federal environmental obligations relevant to this project include those set out in the following instruments:
Biodiversity
- Convention on Biological Diversity and Kunming-Montreal Global Biodiversity Framework and its domestic framework: Canada’s 2030 Nature Strategy, as well legislations supporting its implementation including SARA and recovery strategies and action plans developed under SARA for species at risk likely affected by the project available on the species at risk public registry;
- [for projects with onshore components and activities with pathway of effects to wetlands: Convention on Wetlands of International Importance Especially as Waterfowl Habitat (Ramsar), as implemented in part under the Federal Policy on Wetland Conservation and the North American Waterfowl Management Plan];
- Convention for the Protection of Migratory Birds in the United States and Canada, as implemented in part under the Migratory Birds Convention Act (1994), and supporting conservation objectives from ECCC’s bird conservation regions and strategies;
[insert if applicable: Air pollution]
- [for projects with pathway of effects to transboundary air pollutant emissions: the Canada-United States Air Quality Agreement, as implemented under the Air Quality Management System];
[insert if applicable: Water quality and quantity]
- [for projects with pathway of effects to transboundary water pollution: the Canada-US Boundary Waters Treaty, as implemented by the International Joint Commission]; and
- [if applicable, list other relevant environmental obligations].
The Impact Statement must:
- list likely effects on species listed in Schedule 1 of SARA and their critical habitat, as well as identify the measures that will be taken to avoid or lessen those effects and to monitor them, including measures from any applicable provincial framework. Where applicable, refer to descriptions of effects already provided for VCs elsewhere in the Impact Statement. The proponent is also encouraged to include additional species that the Committee on the Status of Endangered Wildlife in Canada has recommended for listing as extirpated, endangered, threatened or of special concern.
Where the proponent is of the view that the likely effects of the project contribute to environmental obligations, the proponent is encouraged to:
- describe plans and commitments that contribute to the above-listed environmental obligations; and
- with respect to the biodiversityFootnote 5 obligations:
- describe and, where possible, quantify likely changes in biodiversity resulting from the project referring to relevant guidance such as the Convention on Biological Diversity’s Voluntary Guidelines on Biodiversity-Inclusive Impact Assessment,
- describe whether, applying the mitigation hierarchy, the project would result in no net loss or in net positive impacts on biodiversity, and
- describe whether and how the project’s likely effects will contribute to the targets identified in Canada’s 2030 Nature Strategy such as Target 2 (ecosystem restoration), Target 3 (protected and conserved areas), Target 4 (species recovery), Target 6 (invasive alien species), Target 7 (pollution and biodiversity, focusing on chemicals and air pollutants), Target 11 (ecosystem services and functions), Target 14 (mainstreaming of biodiversity values), Target 21 (knowledge sharing), and Target 22 (inclusion of Indigenous Peoples, women/girls, youth/children, persons with disabilities, and environmental human rights defenders in decision making).
6.1.2 Climate change commitments
Where the proponent is of the view that the likely effects of the project contribute to Canada’s climate change commitments, the proponent is encouraged to describe its plans and commitments accordingly.
Greenhouse gases emissions
The proponent [if the project, as a whole, is a federal work or undertaking or on federal lands: must; otherwise: may] assess the project’s GHG emissions following the Strategic Assessment of Climate Change (SACC) and the technical guides related to the SACC, developed by ECCC, including the Guidance on quantification of net GHG emissions, impact on carbon sinks, mitigation measures, net-zero plan and upstream GHG assessment (Technical Guide). [If component(s) of the project federal work or undertaking or on federal lands: At minimum, the proponent is required to provide the information as it relates to [insert name of the project component(s)].] The proponent is encouraged to keep apprised of updates to the SACC and related technical guides published by ECCC.
6.2 Sustainability
Sustainability is the ability to protect the environment, contribute to the social and economic well-being of the people of Canada and preserve their health in a manner that benefits present and future generations. Information throughout the Guidelines can be used to support the analysis of the extent to which the likely effects of the project contribute to sustainability.
6.2.1 Social and economic well-being of communities
[Include the below information where social and economic well-being of communities has been selected by IAAC in section 1.2 Selection of Valued Components. If IAAC selected other VC(s) likely contributing to sustainability in section 1.2 Selection of Valued Components, the VC(s) and associated information should be included as additional subsections here.]
- likely effects on the project’s contribution to components of the Community Well-Being Index for non-Indigenous peoples located in the LSA identified as of importance through public consultations (education, labour force activity, income and/or housing);
- workforce and economic development opportunities informed by local and regional economic activities and workforce capacity, including:
- opportunities for employment including the anticipated number and timeline of full-time and part-time positions to be created. Positions should be presented using the National Occupational Classification system,
- anticipated workforce region of origin (i.e. local, regional, out-of-province or international employees),
- skill and education levels required for the positions,
- anticipated hiring policies and programs,
- investment in training opportunities,
- [anticipated work scheduling for construction and operation (e.g. fly-in/fly-out)],
- [for remote project sites: anticipated transportation options for employees to commute to and from the project site],
- [for remote project sites: accommodation and lodging requirements for the workforce during each project phase],
- workplace policies and programs,
- workplace policies and programs for Indigenous employment and employment of diverse population groups, codes of conduct, workplace safety, and cultural training, and
- employee assistance programs and benefits programs;
- likely effects of the project on the local and regional infrastructure and services and their capacity; and
- economic benefits for Canadians, including Gross Domestic Product growth, tax revenue, as well as indirect benefits such as investments in the development and adoption of clean technologies and growth of innovative Canadian firms, clusters, and supply chains (e.g. by providing the critical minerals necessary for the global transition to the net zero economy).
6.2.2 Extent to which the likely effects of the project contribute to sustainability
The Impact Statement must:
- provide an analysis of the extent to which the project’s likely positive effects and adverse federal effects contribute to sustainability according to the following steps:
- identify the four to six key VCs from section 1.2 Selection of Valued Components relevant to long-term well-being to be included in the sustainability analysis, informed by Indigenous Knowledge and the project context [including [list relevant Valued Component(s)]],
- establish temporal boundaries, considering how long-term effects on the identified VCs could affect future generations including beyond the project lifecycle, and
- apply the following sustainability principles to determine whether and the extent to which the project’s likely positive effects and adverse federal effects result in a net positive contribution to sustainability (based on the criteria of no contribution, to low, moderate or high contribution):
- consider interconnectedness and interdependence of human-ecological systems,
- consider well-being of present and future generations,
- consider positive effects and reduce adverse federal effects of the designated project, and
- apply the precautionary principle and consider the uncertainty and risk of irreversible harm.