April 11, 2019 Dear Senators, I Want to Thank You for the Opportunity To

April 11, 2019 Dear Senators, I want to thank you for the opportunity to provide input into your Committee's deliberations on the merits of Bill C-69. I regret that my duties as the MLA for Wolseley at the Manitoba Legislature prevent me from making this presentation in person, but I am pleased to offer this short written submission instead. I have two brief points to make: 1. My general comment is that Bill C-69 makes some important improvements to the flawed approach implemented by the previous federal government under Stephen Harper. I also note that reform of this legislation was a key campaign promise made by the current federal government in the last federal election. That said, Bill C-69 needs to be strengthened in several key areas to properly live up to that promise. For instance, it does not come close to restoring proper protections for Canada's waterways. It also fails to provide sufficient direction to prevent situations where important issues of process are undermined by too much discretionary power left in the hands of decision- makers (i.e. politicians like me). As an elected official I fully appreciate the nuances of the legislative process, and the constant lobbying - from all directions - that necessarily surrounds important policy discussions such as this one. On balance, Bill C-69 makes some progress, and I would encourage you to facilitate its passage in its current form if the other option is for the Bill to die on the order paper. 2. My specific comment concerns the lack of any connection between Bill C-69 and SEDAR, the System for Electronic Document Analysis and Retrieval (https://sedar.com/homepage_en.htm). Simply put, SEDAR is where publicly traded companies in Canada are legally required to file documents (such as a prospectus) so that the general public and shareholders alike can have access to essential information. Yet, while a company is legally required to file their documents with SEDAR, and must ensure those filings contain accurate information, there is no similar requirement under existing environmental assessment law or in Bill C-69. This means a company can provide one set of (accurate) information to SEDAR, and yet also file completely different or incomplete information for the purposes of an environmental assessment. This policy gap has come to my attention in recent months due to an on-going and very controversial attempt by Canadian Premium Sand Inc. (CPS) to build a large-scale "frac sand" mine on the traditional territory of Hollow Water First Nation, just north of Winnipeg. CPS had previously filed the required information with SEDAR, and then applied for an environmental license from the Manitoba government. However, after submitting their licence application, CPS issued a public statement saying its filing under SEDAR is no longer accurate, and that they will provide new information many months from now - long after the provincial government is likely to have made its decision on CPS's environmental licence application. This gives CPS the opportunity to receive an environmental licence, and then dramatically change the nature and/or scale of the project that is ultimately built, even though there will have been no opportunity to properly evaluate the impacts of the true project. I would therefore suggest an amendment to Bill C-69 requiring any proponent of a project that falls under CEAA rules to provide the same information in their environmental license application / environmental assessment report as they have provided to SEDAR. This will ensure both shareholders and decision- makers have accurate information and a consistent understanding of a company's proposal, leading to better accountability and outcomes for our communities, country and planet. Thank you for your kind consideration. Rob Altemeyer, B.A., M.N.R.M. MLA – Wolseley Official Oppositon Critic for the Environment & Green Jobs NDP .

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