Cumulative Effects Assessment and Sustainability Diamond Mining in the Slave Geological Pro
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Cumulative Effects Assessment and Sustainability: Diamond Mining in the Slave Geological Province
by
Kaarina Stiff
A thesis
presented to the University of Waterloo
in fulfillment of the
thesis requirement for the degree of
Master of Environmental Studies
in
Environment and Resource Studies
Waterloo, Ontario, Canada, 2001
? Kaarina Stiff 2001
I hereby declare that I am the sole author of this thesis. This is a true copy of the thesis, including any required final revisions, as accepted by my examiners.
I understand that my thesis may be made electronically available to the public.
ii
ACKNOWLEDGEMENTS
This thesis could not have been completed without the assistance and support of many people. In particular, I would like to thank Bob Gibson for his patience and insightful analysis, and Mary Louise McAllister for her guidance and motivation, and for making me believe that I could do this.
As well, I would like to thank Paula Caldwell and Carey Ogilvie of Environment Canada for facilitating my research in Yellowknife, and my colleagues at the Canadian Environmental Assessment Agency for their ongoing support. I would also like to thank the Northern Scientific Training Program for their financial assistance. I also owe much thanks to the many people who gave generously of their time and expertise during my research.
Finally, I must express my profound appreciation to my ‘significant other’ Geoff, whose unwavering support and encouragement played an enormous role in the success of my graduate studies.
iii
ABSTRACT
The pace of development in Canada’s North has renewed concerns about the potential cumulative effects of increasing industrial growth on fragile northern ecosystems. Recent developments in the diamond industry in the Slave Geological Province have highlighted the potential additive and synergistic effects of such development. For example, Aboriginal communities are worried about the health of the Bathurst caribou herd, which is considered central to their way of life. This concern is compounded by the lack of integration of environmental assessment and planning efforts, which could serve to better protect the environment.
This research considers the challenges associated with the assessment of cumulative effects, and various approaches to meet these challenges. Diamond mining in the Slave Geological Province, including the BHP and Diavik diamond mines, is used as a case study. Four sustainability-based criteria are developed to evaluate the past and existing situation in the diamond region, and to form the basis for recommendations that would contribute to a more holistic approach to integrating cumulative effects considerations into environmental assessment and regional planning.
The analysis demonstrates that although several mechanisms are currently in place to assess cumulative environmental effects, no single initiative fully meets each of the four criteria. However, existing tools can be used and supplemented to identify appropriate response options. The sustainability-based criteria developed here can contribute to further research on cumulative effects assessment and sustainability.
The sustainability-based criteria developed here can be adopted for other case studies, to identify strengths and weaknesses, and to develop case specific recommendations for a more holistic approach to integrating cumulative effects considerations into environmental assessment and regional planning. This examination of how cumulative effects assessment has been approached in the Slave Geological Province also provides insight into the broader implications of regional cumulative effects management.
iv
ACRONYMS
Agency Canadian Environmental Assessment Agency
AWA Alberta Wilderness Association
BHP Broken Hills Proprietary Inc.
CARC Canadian Arctic Resources Committee
CEA Cumulative effects assessment
CEAA Canadian Environmental Assessment Act
CEAMF Cumulative Effects Assessment and Management Framework CEARC Canadian Environmental Assessment Research Council CSR Comprehensive study report
DIAND Department of Indian Affairs and Northern Development
assessment
EA Environmental
EARP Environmental Assessment Review Process
EARPGO Environmental Assessment Review Process Guidelines Order EIS Environmental impact statement
LKFDN Lutsel K’e Dene First Nation
MVCIMP Mackenzie Valley Cumulative Impact Monitoring Program MVEIRB Mackenzie Valley Environmental Impact Review Board MVRMA Mackenzie Valley Resource Management Act
NEI Northern Ecosystems Initiative
NEPA National Environmental Policy Act
NIRB Nunavut Impact Review Board
NLCA Nunavut Land Claim Agreement
NPC Nunavut Planning Commission
NWT Northwest Territories
PPP Policies, plans and programs
authority
RA Responsible
SEA Strategic environmental assessment
VEC Valued ecosystem component
WKSS West Kitikmeot Slave Study
v
TABLE OF CONTENTS
1.INTRODUCTION (1)
1.1T HE T OPIC AND ITS S IGNIFICANCE (3)
1.2M ETHODOLOGY (6)
1.2.1Research Objectives (7)
1.2.2Methods (7)
1.3O UTLINE (8)
1.4C HAPTER S UMMARY (10)
2.SUSTAINABILITY AND CUMULATIVE EFFECTS (12)
2.1S USTAINABILITY (12)
2.1.1Ecosystem Approach (18)
2.1.2Sustainability in a northern context (22)
2.2C UMULATIVE E FFECTS (27)
2.3C UMULATIVE E FFECTS A SSESSMENT (29)
2.4S USTAINABILITY AND C UMULATIVE E FFECTS A SSESSMENT (31)
2.5Sustainability Based Criteria for Cumulative Effects Assessment (33)
2.6C HAPTER S UMMARY (38)
3.CUMULATIVE EFFECTS AND DIAMONDS IN THE SLAVE GEOLOGICAL PROVINCE.40 3.1H ISTORY OF D IAMOND A CTIVITY IN THE S LAVE G EOLOGICAL P ROVINCE (40)
3.2T HE A REA I NVOLVED (42)
3.3D IAMOND MINING IN THE N ORTHWEST T ERRITORIES (43)
3.3.1What is being mined? (43)
vi
3.3.2Who is mining? (44)
3.4C HAPTER S UMMARY (51)
4.TOOLS FOR CEA IN THE SLAVE GEOLOGICAL PROVINCE (53)
4.1EA AND CEA IN THE F EDERAL C ONTEXT (53)
4.1.1Environmental Assessment Review Process Guidelines Order (55)
4.1.2Canadian Environmental Assessment Act (59)
4.1.3Litigation (63)
4.2CEA IN O THER N ORTHERN EA P ROCESSES (65)
4.2.1Mackenzie Valley Environmental Impact Review Board (65)
4.2.2Nunavut Impact Review Board (66)
4.2.3CEA in Regional Planning in the Slave Geological Province (67)
4.3C HAPTER S UMMARY (68)
5.AN EVALUATION OF CEA IN THE SLAVE GEOLOGICAL PROVINCE (70)
5.1C URRENT APPROACHES TO CUMULATIVE EFFECTS ASSESSMENT (70)
5.2H OW CEA HAS BEEN HANDLED (77)
5.3S TAKEHOLDER CONCERNS (78)
5.3.1Cumulative effects concerns (80)
5.4E VALUATION USING SUSTAINABILITY-BASED CRITERIA (84)
5.4.1Integrated approach (85)
5.4.2Comprehensive approach (86)
5.4.3Participative (88)
5.4.4Enforceable (89)
5.5I MPLICATIONS FOR S USTAINABILITY (91)
5.6C HAPTER S UMMARY (93)
vii
6.RESPONSE OPTIONS FOR BETTER CEA IN THE SLAVE GEOLOGICAL PROVINCE (95)
6.1O UTLINE OF O PTIONS (95)
6.1.1Legislative and regulatory options (95)
6.1.2Multi-stakeholder approaches (100)
6.2E VALUATION USING SUSTAINABILITY-BASED CRITERIA (104)
6.2.1Integrated approach (105)
6.2.2Comprehensive approach (107)
6.2.3Enforceable (109)
6.2.4Participative (111)
6.3I MPLICATIONS FOR S USTAINABILITY (112)
6.4C HAPTER S UMMARY (114)
7.CONCLUSIONS AND RECOMMENDATIONS (116)
7.1S UMMARY (116)
7.2R ECOMMENDATIONS (122)
7.2.1Status quo (122)
7.2.2Policy options (123)
7.2.3Legislative changes (125)
7.2.4Preferred option (127)
7.3I MPLICATIONS OF THE C ASE S TUDY (128)
7.4C ONCLUSION (129)
viii
T ABLE OF FIGURES
F IGURE 1: M AP OF THE S LAVE G EOLOGICAL P ROVINCE (D IAVIK C OMPREHENSIVE S TUDY R EPORT) (11)
F IGURE 2: P RINCIPLES OF S USTAINABILITY (A DAPTED FROM R OBINSON ET AL.) (14)
F IGURE 3: A SSESSMENT F RAMEWORK (C ANADIAN E NVIRONMENTAL A SSESSMENT A GENCY) (31)
F IGURE 4: D EFININ
G F UTURE A CTIONS (ADAPTED FROM THE C UMULATIVE E FFECTS A SSESSMENT
P RACTITIONER’S G UIDE) (62)
ix
1 1. Introduction
In a critique of the environmental assessment of Canada’s first diamond mine, Susan Wismer said:
“A beautiful jewel is a delight and luxury, but not a necessity. A good and happy life can be lived without the gem diamonds lying underneath Lac de Gras.”1
Many people in the Canadian north would probably agree, particularly those concerned about the impact of the diamond mines on the Bathurst caribou herd, which northern Aboriginal communities rely on for their survival. The migration route of an estimated 350,000 caribou in the Bathurst herd passes directly through the diamond region.2 However, there are a good many more people – in the north and elsewhere – whose happiness is directly connected to the success of that first mine, and the mines that are sure to follow.
The concern about caribou is not simply about the impact of this diamond mine on the herd. Arguably, the total land occupied by the mine site is insignificant compared to the total range of the caribou, which covers some 250,000 square kilometres. As the operator of Canada’s first diamond mine, Broken Hills Proprietary Inc. (BHP) has suggested that the project site only covers 0.03% of that space. The concern pertains to the additive and synergistic effects of development throughout the North, which is slowly nibbling away at the land available to the caribou, and threatening other negative cumulative effects on northern ecosystems and communities.
At the same time, the mine is worth a significant amount of money. BHP is expecting to extract some $12 billion worth of diamonds from five kimberlite pipes over the expected 25-year life of its project, which will also contribute $2.5 billion to the gross domestic product of the governments of Canada and the Northwest Territories.3 In addition, at least three other projects are at an advanced stage of exploration at Lac de Gras,
1 Susan Wismer, “The Nasty Game: How Environmental Assessment is Failing Aboriginal Communities in Canada’s North,”Alternatives Journal 22:4 (October/November 1996).
2 Canadian Arctic Resources Committee, “Critique of the BHP Environmental Assessment: Purpose, Structure and Process,”Northern Perspectives 24 (Fall / Winter 1996).
3 For more details, see NWT Diamonds Project Environmental Impact Statement: Summary. BHP Diamonds Inc. and DIA MET Minerals Ltd. Vancouver: 1995.
2 including the recently approved Diavik project, and explorations are also underway on several new diamond projects.4
As so often happens in the north, the interests of economic development have clashed with the interests of people whose livelihoods depend on safeguarding the land and water under which the diamonds are buried. The conflict between these perspectives is at the core of how the mining industry has historically crossed paths with environmental and Aboriginal interests, and how the rest of the country has considered industry’s relationship to the environment.
The conflict has been highlighted over the past few decades as environmental concerns have become increasingly prevalent. Large-scale disasters such as the tailings dam failures at the Boliden mine in Spain and the Baia Mare mine in Romania have attracted public attention. As more attention has been drawn to the perceived contribution of mining to environmental distress, demands for regulatory controls to protect the environment have increased. Typically, the mining industry is portrayed as the villain.
In recent years, we have developed a greater appreciation for the complexity of environmental issues. We have also recognized the importance of reconciling environmental protection with the needs of the mining industry for a regulatory environment that can still attract investment and provide valued opportunities for community gains. Indeed, northern communities are increasingly interested in economic development, to the extent that it can be compatible with their traditional culture and economy. Similarly, the mining industry has expressed a commitment to pursuing sustainable mining strategies, through its participation in roundtable agreements such as the Whitehorse Mining Initiative.
That being said, we are left to wonder whether the North can have both the caribou and the diamonds. Over the past several years, many northerners have started asking whether the cumulative impacts of development will compromise the ability of northern ecosystems to adapt to change. Or as Wismer asked, can mining make a contribution to the longer-term health and sustainability of northern communities? The answer to
4 Government of the Northwest Territories, A Guide to Mineral Deposits of the Northwest Territories. 1996.
3 this question is based, in part, on a thorough analysis of the real impacts of development on the northern environment. In the context of diamonds, we do need to know how much the BHP mine will affect the Bathurst caribou herd; but arguably, it is more important to know what effects the herd is experiencing from all kinds of development, because the cumulative effects are what carry the consequences – for the caribou, for the environment, and for the people who depend on the land to survive.
1.1 The Topic and its Significance
This research is concerned with the challenges associated with the assessment of cumulative effects, and various approaches to meeting these challenges. My interest is process, including the mechanisms that are in place to facilitate the assessment of cumulative effects, and how these mechanisms can be enhanced to address the needs of the environment and industry at the same time. This is important from a pragmatic legal perspective, since the consideration of cumulative effects is required under environmental assessment legislation, but also because it also makes sense from an ecosystem perspective, because the environment experiences impacts in a cumulative way.
The assessment of cumulative environmental effects can be approached in various ways. Most frequently, cumulative effects are considered in conventional project-specific environmental assessments, such as those considered under the Canadian Environmental Assessment Act. Cumulative effects can also be considered in regional or area assessments, or through the strategic assessment of policies or programs. As well, the cumulative effects of development can also be considered through land-use planning exercises. Each of these options will be considered in this research.
In this regard, this research will contribute to a more holistic approach to integrating cumulative effects considerations into environmental assessment and regional planning. More particularly, this research will consider the cumulative effects of diamond mining in the Slave Geological Province, in the context of the BHP and Diavik mining developments, and anticipated additional projects. This research will be conducted in the overall context of sustainability, which is arguably the ultimate goal for northern communities and the
4 mining industry alike.
Since no holistic framework is presently in place, the results of this research would make a significant contribution to policy development in this area. In this regard, this research is both timely and necessary. While the consideration of cumulative effects is required under the Canadian Environmental Assessment Act (CEAA), it has not played a significant role in the evaluation and decision-making processes for Canadian diamond mining so far. Perhaps, the significant short and long-term considerations that arise from multiple mining projects and associated developments cannot be addressed adequately by individual assessments or through processes of adaptive management of individual undertakings. In the Northern diamond mining cases, the cumulative effects to be considered include, for example, water quality degradation, and the disruption of caribou by multiple projects over time.
This suggests that regional planning might offer a better vehicle for attention to cumulative effects. However, this too has not yet been well used in the Slave Geological Province. Federal and territorial authorities have largely delayed the development of a formal planning approach until outstanding Aboriginal land claims have been settled. Meanwhile, industry and government continue to develop various plans for infrastructure components intended to facilitate diamond mining in the region. Because the industry and government planning process is fragmented and largely closed, it is unlikely to result in a well-integrated, broadly assessed and environmentally sensitive path for maximizing long-term benefits.
A substantial body of current literature regarding strategic and cumulative impact assessment and regional planning programs provides a solid base for developing a holistic approach to integrating the existing assessment and planning processes.
The subject of cumulative effects assessment developed rapidly beginning in the 1980s, with the work of the Canadian Environmental Assessment Research Council (CEARC). There is now an established body of literature on conceptual frameworks and methodologies, and the need to integrate environmental assessment with regional planning exercises.
5 There is an increasing amount of research that concludes that CEA is not getting done properly through EA. For instance, in a U.S. study in 1997, Burris and Canter reported that the “systematic consideration and assessment of cumulative impacts was typically not found”. They concluded that “if EAs are to continue to serve their original purpose … the analysis of cumulative impacts must be more thorough and documented.”5
Recent literature also supports the need for better integration of CEA at the project level and on a regional planning basis. In this regard, Conacher argues that environmental impact assessment on its own is an inadequate means of maintaining and improving environmental quality, and suggests a need for closer integration of environmental protection with regional land use planning and management.6
A growing number of case studies have been used to demonstrate some of the inherent difficulties in conducting cumulative effects assessment. For example, Ross has identified key barriers to conducting cumulative effects assessment, including the rising expectations that people have of the information to be considered in CEA, and the administrative difficulties associated with obtaining this information.7 Sadler suggests that strategic environmental assessment might be one way in which CEA could be addressed.8 Although there is an increasing amount of research on the challenges in CEA, and researchers support the need for integrating cumulative effects considerations into planning processes, the vast majority of the current literature focuses on why this integration is desirable. Less attention has been devoted to the criteria and the means necessary for achieving this integration. This research hopes to contribute to filling that gap. In this research, key elements of a holistic approach will be developed and elaborated for application in the Slave Geological Province. The research will consider what should be done from a sustainability
5 R.K. Burris and Larry W. Canter, “Cumulative Impacts Are Not Properly Addressed in Environmental Assessments,” in Environmental Impact Assessment Review. 1997. 17:5-18.
6 Arthur Conacher, “Integration of Land use Planning and Management with Environmental Impact Assessment: Some Australian and Canadian Perspectives,” in Impact Assessment. Vol. 12, Winter 1994-95.
7 William A. Ross, “Assessing Cumulative Environmental Effects: Both Impossible and Essential,” in Cumulative Effects Assessment in Canada: From Concept to Practice. Alan J. Kennedy, ed. Alberta: 1994.
8 Barry Sadler, “International Study of the Effectiveness of Environmental Assessment, Final Report. Environmental Assessment in a Changing World - Evaluating Practice to Improve Performance. Ottawa: 1996.
6 perspective, but it will also endeavour to design an approach that can be implemented, given the current political and economic climate.
1.2 Methodology
This research has adopted a case study approach to investigate issues surrounding the assessment of cumulative impacts from multiple developments. An examination of how cumulative effects assessment has been approached in the Slave Geological Province can provide insight into the broader implications of regional cumulative effects management. The challenges associated with cumulative effects assessment has been recognized as a national issue. The Commissioner of the Environment and Sustainable Development noted in his 1998 report to the House of Commons that, “… the assessment of cumulative environmental effects presents some difficulties due to the complexity of the issue and to disagreements on how such effects should be assessed.” In fact, concerns are being raised in regions throughout Canada about the cumulative impacts of various types of development, such as ongoing development in the Athabasca Oil Sands region of Alberta, and continuing offshore oil and gas development in the coastal waters of Newfoundland and Nova Scotia. Similar issues are raised in each region, including how cumulative effects should be considered in environmental assessments conducted under the Canadian Environmental Assessment Act, how to overcome jurisdictional and administrative barriers, and how to ensure that cumulative effects issues are being properly addressed. An examination of cumulative effects issues in the Slave Geological Province can explore two broader questions, which can be applied to other regions: Can a holistic approach to cumulative effects assessment contribute to sustainable development by improving environmental decision-making? Furthermore, can such an approach successfully integrate various components of regional assessment, such as land use planning and project-specific assessments?
Diamond mining in the Slave Geological Province is also a timely case study because diamond mining is a comparatively new industry in Canada, and the likelihood of increased development is extremely high. In addition, the Canadian North is presently in the midst of tremendous legislative and regulatory change,
7 including Aboriginal land claims and treaty negotiations, the creation of Nunavut, and the devolution of power from the federal to the territorial governments. This effectively creates a void in which development is taking place in the absence of a coherent long-term vision. This presents a unique opportunity to develop a process for assessing cumulative environmental effects that will improve environmental protection, at the same time as enhance industry's ability to contribute to sustainable northern communities.
Objectives
1.2.1 Research
The goal of this research is to explore the issues associated with a holistic approach to cumulative effects assessment, using the Slave Geological Province as a case study. In this regard, the following research objectives have been identified:
? To develop sustainability-based criteria that can be used to measure the success of cumulative effects assessment approaches;
? To review the current approaches to assessing cumulative environmental effects in the Slave Geological Province, in order to evaluate the degree to which a holistic approach to
cumulative effects assessment is already established; and
? To identify barriers and challenges to the successful implementation of a holistic approach to cumulative effects assessment, and to suggest how these challenges can be met.
In addition, this research will investigate what lessons can be extracted from the case study for broader application.
1.2.2 Methods
In the context of a case study approach, this research employed the following methods:
? A review of existing literature on sustainable development, cumulative effects and strategic assessment, and regional planning programs relevant to Western Arctic applications;
8
? A review of the environmental assessments and reviews of the BHP and Diavik mining developments, with particular attention to cumulative effects issues; and
? Development of sustainability based criteria to assess and evaluate CEA efforts and options. Field research involved:
? Key informant interviews with a range of stakeholders from government, industry, Aboriginal organizations, and environmental groups;
? Collection of documentary information with respect to past and current experience in Western Arctic assessment and planning; and
? Examination of selected central cumulative effects issues related to the diamond mining and associated developments, including review and analysis of baseline data from the BHP and
Diavik environmental assessments.
In addition, this research draws on the personal experience of the researcher as a Project Assessment Analyst at the Canadian Environmental Assessment Agency.
1.3 Outline
Various aspects of cumulative effects assessment are addressed throughout this thesis. This first chapter introduces the topic of cumulative effects assessment, and establishes its relevance in a policy context. This chapter also establishes the goal and related objectives of this thesis, and sets out the problem statements to be explored. Further, this chapter describes the methodology used to conduct this research, and establishes a set of criteria that will guide the analysis that follows in later chapters.
Chapter two addresses the discourse of sustainability, and its particular relevancy to the Canadian North. It reviews the fundamentals of cumulative environmental effects and cumulative effects assessment, and the contribution of CEA to sustainable development. It also establishes the theoretical framework on which this
9 research is based. One of the foremost challenges in pursuing sustainable development is the integration of social and cultural as well as biophysical factors into decision-making.
Chapter three provides an overview of activity in the diamond region of the Slave Geological Province, and the surrounding political and social context. It more thoroughly describes the BHP and Diavik projects, as well as other advanced projects, in order to provide the context for understanding cumulative effects concerns. The pace of development in a comparably pristine landscape underscores the need to take swift action to address cumulative effects issues.
Chapter four reviews the legislative regime for assessing cumulative effects in the Canadian North. It describes the development of cumulative effects assessment within the Canadian federal system, including the relevant provisions of the Canadian Environmental Assessment Act, the Mackenzie Valley Resource Management Act, and selected Aboriginal land claim agreements. Although the legal requirements for CEA have been strengthened since EA was first introduced, there are still clear gaps that need to be addressed. Chapter five provides an evaluation of cumulative effects assessment in the Slave Geological Province, to the extent that it has occurred thus far. It examines the key concerns raised by stakeholders in the BHP and Diavik reviews by applying the sustainability-based criteria developed in Chapter one. Innovative solutions are being developed, but there are still significant operational and administrative barriers to implementing effective CEA.
Chapter six explores alternative response options to CEA in the Slave Geological Province. It discusses multi-stakeholder approaches to CEA, with particular emphasis on recent new initiatives aimed at ameliorating the cumulative effects situation in the region. The current initiatives have great potential, but there are key considerations that must be borne in mind if they are to be successful.
Finally, Chapter seven offers some concluding recommendations that should inform the implementation of a cumulative effects assessment and management framework for the Slave Geological Province. The partnership approach could serve as a useful model for other areas, in the North and elsewhere.
10
Summary
1.4 Chapter
This thesis presents an analysis of issues surrounding cumulative effects assessment, using diamond mining in the Slave Geological Province as a case example. The research is guided by the principles of sustainable development, which were used to develop a set of criteria that can be applied to evaluate the state of the practice of cumulative effects assessment and potential response options. The analysis and recommendations are accomplished by providing:
? A review of literature related to sustainable development and cumulative effects assessment;
? An overview of diamond activity in the Slave Geological Province;
? A description of the current legislative process for environmental assessment in the Canadian North;
? An analysis of the current approaches to cumulative effects assessment;
? An exploration of potential alternative approaches to CEA; and
? Recommendations that could inform the development of a framework to address cumulative environmental effects in the diamond region of the Slave Geological Province.
11
Figure 1: Map of the Slave Geological Province (Diavik Comprehensive Study Report)
Excerpt from the Comprehensive Study Report for the Diavik Diamonds Project. Department of Indian Affairs and Northern Development, June 1999.
12 2. Sustainability and Cumulative Effects
Years from now, the historical record will likely show that sustainable development was one of the most popular “buzzwords” of the late twentieth century. The phrase, in all of its varied forms – sustainable development, sustainability, and sustainable societies – has certainly dominated the environmental literature for much of the last three decades.9 This chapter traces the history and key themes of the sustainable development discourse, in order to establish the analytical framework for this research.
This thesis argues that sustainable development is an appropriate analytical approach for the analysis of cumulative effects assessment because it provides a framework for integrating environmental considerations into the decision-making process. Moreover, sustainable development has recently become an objective of the environmental legislation that governs the diamond region of the NWT and Nunavut, and so the results of this research will be applied within the legislative and regulatory regime.
Through a discussion of arctic ecosystems and Aboriginal values, this chapter considers the particular importance of effective cumulative effects assessment in the North. It also provides an operational definition of cumulative effects and describes the key tasks in conducting cumulative effects assessment, in order to provide the necessary context for understanding the strengths and weaknesses of the current approaches to CEA, which will be discussed in Chapter five.
2.1 Sustainability
Much as democracy is considered the only political game in town, sustainable development has become the dominant discourse in the environmental arena. As with democracy, sustainable development has been defined and interpreted in many different ways. In explaining the sustainability discourse, John Dryzek states:
9 For the purpose of this research, these terms will be used interchangeably.
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