Backgrounder on Environmental Assessment

What applicants need to know about NSERC's requirement for environmental assessment

The  Canadian Environmental Assessment Act (the Act) requires that an environmental assessment (EA) be carried out before a federal department or agency exercises certain powers with respect to a "project" (defined below), such as undertaking the project itself, issuing a permit or, as in the case of NSERC, providing financial assistance for the purpose of enabling a project to be carried out in whole or in part.

A project is defined in the Act as:

• any kind of undertaking (including any proposed construction, operation, modification, decommissioning, abandonment, or other undertaking) in respect of a physical work; or
• any physical activity, not relating to a physical work, that is described in the Act's Inclusion List Regulations.

In the context of this document, "environmental assessment" (EA) refers to NSERC's environmental assessment process, which includes:

• the Environmental Impact Statement (Appendix A);
• the two-page Pre-Screening Checklist under the Act (Appendix B); and
• if required, an environmental assessment (screening report) under either the Canadian Environmental Assessment Act or the NSERC Policy on Environmental Assessment.

1. When do I fill out an EA form?

The applicant must fill out Appendices A and B of the Application for a Grant (Form 101) if:

• any phase of the research described in the proposal takes place outside an office or a laboratory, whether the work is done by the applicant, co-applicants, technicians, graduate students, postdoctoral fellows, or others; or
• the equipment requested in a Research Tools and Instruments grant application is being built or has a fixed location (for example, experimental greenhouses or aquaculture installations), or will be used outdoors.

Completed appendices are also required for research activities conducted abroad or with researchers in other countries.

Some research activities are more likely than others to trigger an assessment under the Act. In general, proposals dealing exclusively with the following will not likely constitute a "project" and will therefore not likely trigger an assessment process under the Act:

• Research Tools and Instruments grants: Requests for equipment that can be transported (i.e., that will not have a fixed location even though it might be difficult to transport, such as a mass spectrometer); or
• Grant applications that propose work to be carried out exclusively in a laboratory or office, and which does not contribute to the construction, operation, modification, decommissioning, abandonment, or other undertaking in relation to a physical work that is constructed and fixed in place, or that is set out in the Act's Inclusion List Regulations.

Scholarships and fellowships are not subject to the Act.

2. How do I fill out an EA form?

Follow these three steps:

Step 1 – Answer the EA question on Form 101

To identify proposals that might have an impact on the environment or that might require an assessment under the Act, the applicant must check one of the two boxes (no or yes) in the second block under Certification Requirements (on the first page of Form 101).

Applicants whose research is conducted exclusively indoors should check the "no" box. No additional steps are required.

Applicants whose research involves at least one phase of work that takes place outdoors, or that involves the construction, operation, modification, decommissioning, abandonment, or other activity in relation to a built structure in a fixed location and which is not intended to be moved frequently, must check the "yes" box and proceed to Steps 2 and 3.

Step 2 – Complete Appendix A (Form 101)

Applicants must provide information on:

• their research activities;
• the possible environmental effects of their research activities; and
• the mitigation measures that will be undertaken to alleviate potential environmental effects.

This applies to all research activities conducted outdoors, not only those that trigger an assessment under the Act. NSERC staff will use this information to determine if potential environmental impacts were properly identified and if the proposed mitigating measures are appropriate.

Step 3 – Complete Appendix B (Form 101)

Appendix B is a two-page pre-screening checklist that serves two purposes:

1. Page 1 identifies activities that might be subject to a screening under the Act.
2. Page 2 enables NSERC staff to identify proposals that may trigger an assessment by reason of another federal department's grant of a licence or permit. This allows NSERC staff to coordinate the EA process with other federal government departments to avoid duplication.

Only permits that are, or will be, required by the researcher for the conduct of the research and that are not already held or managed by the university should be listed in Appendix B. The following are examples of activities for which universities, in general, hold permits:

• Disposal or storage of hazardous wastes;
• Disposal or storage of radioactive materials;
• Use, disposal or storage of biohazardous materials; and/or
• Occupational health and safety regulations.

Applicants who are unsure of whether a permit is required should contact a member of NSERC's EA unit.

3. What happens next?

The information provided in the proposal and the appendices should contain enough detail to enable NSERC staff to determine if:

• the application is not subject to a screening under the  Act or the NSERC Policy on Environmental Assessment, in which case no further action will be required; or
• the application is subject to a screening under the  Act or the NSERC Policy on Environmental Assessment, in which case NSERC staff will contact the applicant and guide him/her through the screening process.

If the applicant has not provided sufficient information to enable NSERC staff to make the above determination, NSERC staff will contact the applicant to request additional information or clarification.

Frequently Asked Questions

1. What is an environmental assessment (EA)?

Simply put, an environmental assessment is a method used to identify the environmental effects of a proposed project and to identify ways of lessening or eliminating any negative effect (referred to as mitigation measures). The project's proponent can then modify the proposal so that the negative effects can be minimized or eliminated.

2. What process will NSERC follow in reviewing its EAs?

The two-page Pre-Screening Checklist (Appendix B of Form 101) helps identify potential environmental effects of the proposed project. Information provided in this appendix assists NSERC staff in determining whether an environmental assessment is required under the Canadian Environmental Assessment Act.

NSERC's EA review process is conducted separate from and, when possible, parallel to the peer review process of research proposals. NSERC staff review the pre-screening forms and the proposals in the context of EA, while research proposals make their way through the regular peer review process to determine funding recommendations. The EA review process does not affect the peer review of proposals.

If, as a result of the examination of the pre-screening forms, NSERC determines that the proposal is subject to the Act and requires further study (usually a screening), the applicant will be informed and advised of the next steps. The Research Grants Office may also need to be informed in cases where the release of funding has been made conditional due to outstanding EA issues.

3. What happens if I send in the proposal but I don't complete the EA forms?

Incomplete applications may be rejected or may be at a disadvantage in comparison with those that are complete.

4. What happens if a proposal is recommended for funding but the EA process is not complete?

If the proposal is recommended for funding and the EA process has not been completed, the award will be marked as "conditional" and the funding will not be released by NSERC until the completion of the EA process. The university's Research Grants Office will be notified.

NSERC staff will make every effort to complete the EA process to correspond to the timing of the release of funding. To help achieve this goal, applicants are asked to consider any and all environmental implications of the research activities outlined in their research proposals and to include sufficiently detailed information in Appendices A and B of the Application for a Grant (Form 101).

5. Who pays for the preparation of EAs?

The applicant bears the cost of the preparation of an environmental assessment. Unfortunately, the costs cannot be charged to an NSERC grant.

However, the cost of mitigating negative environmental effects and monitoring residual effects are eligible expenditures and should be included in the proposed budget pages of the Application for a Grant (Form 101).

NSERC will not charge for the review and approval of an EA.

6. What if I change the direction of my research after I get my grant?

If the change in direction results in fieldwork activities not described in the original proposal, you must complete Appendices A and B (Form 101) and send them to the EA Unit at NSERC. The university's Research Grants Office should also be informed.

NSERC staff will review the information to determine if the change in direction of the research warrants further action (usually a screening) under the Act or the NSERC Policy on Environmental Assessment.

7. What happens if my proposal is subject to a screening?

NSERC has found that relatively few proposals are subject to a screening under the Act or the NSERC Policy on Environmental Assessment. In the event that they are, the screenings are, for the most part, simple and straightforward.

If NSERC determines that the project must undergo a screening, an NSERC staff member will inform the applicant and guide him/her through the process.

It should be noted that, in the context of the Act, it is the research activity itself and the associated environmental impacts that are assessed. The outcome of the research project (e.g., the resulting process or technology) is not subject to environmental assessment, unless it becomes the subject of a funding request in the future.

A document called a Screening Report on the project will be required. Factors that must be considered in a screening are:

• the environmental effects* of the project, including the environmental effects of malfunctions or accidents that may occur in connection with the project, and any cumulative environmental effects of the project in combination with other projects or activities;
• the significance of the effects referred to in the previous paragraph;
• where relevant, comments from the public that are received in accordance with the Act and its regulations;
• measures that are technically and economically feasible and that would mitigate any of the project's significant adverse environmental effects;
• consultations with relevant expert federal departments, which will be given an opportunity to provide specialist information and expertise during the screening or to comment on the scientific and technical accuracy of the Screening Report. Please note that this expert comment is not related in any way to the peer review carried out for grant applications; and
• any other matters relevant to the project, such as the need for the project or alternatives to the project, that NSERC may consider in its evaluation of the Screening Report.

* Environmental effects include effects that flow directly from those changes, including effects on human health, socio-economic conditions, physical and cultural heritage (including effects on things of archaeological, paleontological, or architectural significance), and the current use of lands and resources for traditional purposes by Aboriginal persons.

8. What is meant by a "follow-up program" and "implementation of mitigation measures?"

Under the revised Canadian Environmental Assessment Act, which came into force October 30, 2003, the responsible authority (in this case NSERC) is required to determine if follow-up action is appropriate after a screening has taken place under the Act. The design and implementation of a potential follow-up program must be proposed by the applicant and included in the Screening Report. The purpose of the follow-up is to determine the effectiveness of any measures that have been put in place to mitigate any identified potential adverse environmental effects of the project. NSERC must ensure the implementation of the follow-up program, if applicable.

In the case of a comprehensive study, mediation, or assessment by a review panel, follow-up is mandatory.

9. What information is available to the public?

The Canadian Environmental Assessment Registry (CEAR) was created to provide Canadians with information on the environmental assessment of certain projects and to provide notice in a timely manner. In the event of a screening, the responsible authority (NSERC) contributes records (under the National Archives of Canada Act, a record can include any documentary material regardless of physical form or characteristics, or any copy thereof) relating to the environmental assessment, including comments from the public on the project.

The public can access the CEAR at  http://www.ceaa.gc.ca/050/index_e.cfm.

10. How can I help improve NSERC's EA process?

Researchers or administrators who wish to provide comments or suggestions on improving NSERC's EA process should contact Marie Emond, NSERC EA Coordinator (see below).

11. Who can I contact if I have any questions or need more information?

Please contact:

Diane Fraser
Senior Environmental Assessment Officer
NSERC Secretariat
Tel.: 613-995-8079
Fax: 613-943-1222
E-mail: diane.fraser@nserc-crsng.gc.ca

Patricia Pelletier
Environmental Assessment Officer
NSERC Secretariat
Tel.: 613-992-3612
Fax: 613-943-1222
E-mail: patricia.pelletier@nserc-crsng.gc.ca

Céline Monfils
Environmental Assessment Secretariat Officer
NSERC Secretariat
Tel.: 613-996-7559
Fax: 613-943-1222
E-mail: celine.monfils@nserc-crsng.gc.ca

Marie Emond
Research Ethics and Environmental Assessment Coordinator
NSERC Secretariat
Tel.: 613-992-0842
Fax: 613-943-1222
E-mail: marie.emond@nserc-crsng.gc.ca

12. Where can I read more about environmental assessment?

An introduction to, and highlights of, the revised Canadian Environmental Assessment Act can be found at  http://www.ceaa.gc.ca/013/intro_e.htm.

The legal text of the Act itself can be found at  http://laws.justice.gc.ca/en/C-15.2/index.html.