Response to Indigenous Impact Assessment Co-Administration Agreements Discussion Paper

The Impact Assessment Agency of Canada has introduced a potential new mechanism under the Impact Assessment Act entitled Indigenous co-administration agreements. Such agreements would seek to enable Canada and Indigenous governing bodies or other eligible entities to formally share decision-making at key points throughout the federal impact assessment process.

PDAC recognizes the significant efforts from IAAC and the Circle of Experts in developing this discussion paper, and greatly appreciates the opportunity to provide comment through the lens of industry’s decades of project development experience and close collaboration with Indigenous Peoples.

There are several fundamental issues which will impede the successful application of co-administration agreements as they are outlined in the discussion paper, including overlapping territories, inconsistent and unpredictable processes, isolation of other jurisdictions, and lack of capacity. PDAC recommends careful consideration of these challenges in the creation of a co-administration agreement framework. The primary role and goal of the federal government should be to support the direct engagement that has been and will continue to occur between Indigenous groups and proponents collaborating on impact and environmental project assessments.