To: Rt. Hon. Justin Trudeau, Prime Minister and Minister of Intergovernmental Affairs and Youth Cc: Hon. Catherine McKenna, Minister of Environment and Climate Change; Hon. Marc Garneau, Minister of Transport; Hon. Dominic LeBlanc, Minister of Fisheries, Oceans, and Canadian Coast Guard; Hon. Carolyn Bennett, Minister of Indigenous Affairs and Northern Development; Hon. Jim Carr, Minister of Natural Resources; Hon. Kirsty Duncan, Minister of Science 15 November 2016 Dear Prime Minister Trudeau, It is an exciting time to be a scientist in Canada. We celebrated when you restored the long-form census, increased basic research funding, and encouraged federal scientists to speak freely. Your commitment to “a higher bar for openness and transparency”, the expectation for “Canadians to hold [government] accountable”, and to make “government and its information…open by default”1 rang true to emerging standards in the scientific community. Yet, we are concerned that current environmental assessments and regulatory decision-making processes lack scientific rigour, with significant consequences for the health and environment of all Canadians. As the next generation of Canadian scientists, we are professionally and personally affected by such decisions, especially regarding large-scale and long-term projects. Not only might our expertise be required to mitigate problems, but we have longer to live with the impacts, including a planet profoundly affected by climate change. Canadians invest deeply in our training, and in turn, we take seriously the responsibility of collecting, analyzing, and disseminating scientific information that serves society. Science thrives by upholding strong standards of integrity. Carefully conducted and independent science is crucial to evaluating the consequences of actions: objectivity and transparency are essential, and inconvenient information cannot be dismissed. Since limited or biased science will not fully reflect the benefits and risks of a project, it cannot accurately inform decision-making. Hundreds of scholars have decried weak Canadian environmental assessments and regulatory reviews2,3,4,5 and cautioned about the risks involved in large-scale energy projects.6,7,8 Environmental and health tragedies (e.g., Calgary floods;9 Mount Polley dam;10 asbestos11) show that incompletely evaluated or mitigated risks have real consequences for Canadians, our environment, and the legacy we leave future generations. We recognize that science is not the only basis upon which project decisions are made; Indigenous knowledge, values, and socioeconomic considerations play critical roles. Nevertheless, input from and engagement with Canadian researchers could significantly improve the scientific standards and process used to assess proposed and existing projects. To aid your government’s commitment to strengthening environmental and regulatory compliance and review processes, 12 we suggest the following five actions to help rebuild public trust in robust, open, and fair decision-making: 1. Seek and act on the best available evidence. Making defensible and credible inferences supported by the best available evidence includes incorporating knowledge from experiments, theory, observations, and/or modeling from multiple disciplines,13,14,15 collected and interpreted without influence from those who stand to gain or lose from the conclusions. We recommend that existing and potential environmental impacts of projects be assessed – with methods, results, and interpretations rigorously peer-reviewed – by parties with arms-length relationships from proponents. Where knowledge gaps impede adequately assessing risk or effects, information should be generated rather than extrapolated from limited and/or lower quality information; decisions can be adapted considering new, robust evidence. 2. Make all information from environmental assessments permanently and publicly available. Making raw data, reproducible analyses, and/or results readily available have rapidly become scientific best practices (subject to privacy and intellectual property laws), including by Canada’s three federal research granting agencies,16 the European Commission,17 and top peer-reviewed scientific journals.18,19,20,21 Barring certain private and community-held knowledge, or national security implications, we recommend that publicly and permanently sharing such information in a free, searchable federal registry22 become a condition of environmental assessment and review processes. This will help ensure Page 1 of 3 that conclusions can be verified and that data can serve as benchmarks for future studies. 3. Assess cumulative environmental effects from past, present, and future projects and activities across multiple scales. Few things in society or nature occur in isolation. Although regulatory reviews consider a project’s potential effects, in many cases they do not adequately consider cumulative effects (e.g., greenhouse gas emissions from product transportation and use, not just project construction and operation; interactive effects of past and future projects on human and environmental health and wellbeing)23. We recommend that cumulative effects be comprehensively evaluated across multiple temporal and spatial scales to inform project-level assessment, including areas under all jurisdictions and globallevel effects where appropriate, and to align decision-making with provincial, national and international commitments to control carbon emissions and protect biodiversity.24,25 4. Work to prevent and eliminate real, apparent, or potential conflicts-of-interest by requiring public disclosure. A key component of scientific integrity includes protecting decision-making from undue influence and actual or perceived individual or institutional bias. Accordingly, we recommend that, in addition to independently conducted and reviewed assessments, all meetings among interested individuals, organizations, stakeholders, and members of the decision-making process be made public, and that all parties publicly disclose any real, apparent, or potential conflicts-of-interest.26 Greater transparency will elevate public trust that decisions are based on evidence, knowledge, and values. 5. Develop explicit decision-making criteria and provide full, transparent rationale of factors considered. Explicit decision-making criteria27 are necessary to “ensure that decisions are based on science, facts, and evidence, and serve the public’s interest”.28 Furthermore, providing a full, transparent, and cogent accounting of all the evidence presented, risks weighed, and alternatives considered would enable experts, stakeholders, and the public to evaluate the legitimacy of such decisions29. When other factors are prioritized over scientific evidence (e.g., economic gains justifying environmental impacts),30 the metrics and rationale for these trade-offs ought to be thoroughly and openly explained, including the spatial and temporal scales considered. We are passionate about using our scientific knowledge and training to serve the public good. We commit to working with you to incorporate the actions outlined above to help strengthen Canada’s environmental and regulatory compliance and review processes31 for existing and proposed projects. Sincerely, Aerin Jacob, PhD Liber Ero & Mitacs Fellow University of Victoria Caroline Fox, PhD Travis G. Gerwing, PhD Killam Fellow Mitacs & Hakai Fellow Dalhousie University University of Northern British Columbia Raincoast Conservation Foundation Nicolas Muñoz, MSc PhD Student Western University Kara Pitman, MSc PhD Candidate Simon Fraser University Michael Price, MSc PhD Candidate Simon Fraser University *Co-authors and co-signatories in alphabetical order. Institutional affiliation for identification only. Co-signed, [List will be updated on Tuesday, 15 November via www.youngresearchersopenletter.org] 1 Trudeau (13 Nov 2015) Ministerial mandate letters. http://pm.gc.ca/eng/mandate-letters Chan et al. (26 May 2014) Open Letter on the Joint Review Panel report regarding the Northern Gateway Project. http://chanslab.ires.ubc.ca/files/2014/05/JRP-Letter-to-Federal-Govt_May28_all-signaturesKCASET.pdf 2 Page 2 of 3 3 Schindler et al. (24 May 2016) Statement of Concerned Scholars on the Site C dam project, Peace River, British Columbia. https://sitecstatement.org 4 Moore et al. (9 Mar 2016) Scientific flaws in assessment of environmental risks from the proposed Pacific NorthWest Liquified Natural Gas facility at Lelu Island, Skeena River estuary. https://www.watershed-watch.org/wordpress/wpcontent/uploads/2016/03/Letter-ScientificFlaws-PNWLNG.pdf 5 Lassonde (19 May 2016) Letter from the Royal Society of Canada regarding Site C dam projec t. https://rsc-src.ca/en/about-us/ourpeople/our-priorities/over-200-leading-scholars-call-government-to-suspend-site-c-dam 6 Palen et al. (2014). Consider the global impacts of oil pipelines. Nature, 510: 465-467. DOI: 10.1038/510465a 7 Bryne et al. (1 Mar 2016) Open letter to the Prime Minister and the Premiers of the Provinces of Canada from Sustainable Canada Dialogues. http://sustainablecanadadialogues.ca/pdf_2015/SCD_Open_Letter_Canada_03012016_signatures.pdf 8 Schartup et al. (2015) Freshwater discharges drive high levels of methylmercury in Arctic marine biota. PNAS 112: 11789-11794. DOI:10.1073/pnas.1505541112 9 Groeneveld (10 Nov 2006) Provincial Flood Mitigation Report: Consultation and Recommendations. www.aema.alberta.ca/images/.../Provincial_Flood_Mitigation_Report.pdf 10 Province of BC (30 Jan 2015) Report on Mount Polley Tailings Storage Facility Breach: Independent Expert Engineering Investigation and Review Panel. Province of BC. https://www.mountpolleyreviewpanel.ca/final-report 11 The Globe and Mail (1 Jul 2015) Ottawa reverses stand on health risks of asbestos in ‘landmark shift’. http://www.theglobeandmail.com/news/national/ottawa-reverses-stance-on-health-risks-of-asbestos-in-landmarkshift/article25224035/ 12 Government of Canada (Accessed 6 Nov 2016) Review of Environmental and Regulatory Processes. https://www.canada.ca/en/services/environment/conservation/assessments/environmental-reviews.html 13 Science Integrity Project (2015) Statement of Principles for Sound Decision-Making in Canada. http://www.zoology.ubc.ca/~otto/SIP2015/documents/SIP_Statement_of_Principles.pdf 14 InterAcademy Council (2012) Responsible Conduct in the Global Research Enterprise: A Policy Report. http://www.interacademies.net/file.aspx?id=19789 15 Sutcliffe and Court (2005) Evidence-Based Policymaking: What is it? How does it work? What relevance for developing countries? https://www.odi.org/publications/2804-evidence-based-policymaking-work-relevance-developing-countries 16 Tri-Agency Open Access Policy on Publications. http://www.science.gc.ca/default.asp?lang=En&n=F6765465-1 17 European Commission (17 Jul 2012) Commission recommendation on access to and preservation of scientific information https://ec.europa.eu/programmes/horizon2020/en/h2020-section/open-science-open-access 18 Center for Open Science (Accessed 10 Oct 2016) The Transparency and Openness Promotion Guidelines. https://cos.io/top/#summary 19 McNutt (2014) Reproducibility. Science, 334: 229. DOI: 10.1126/science.1250475 20 Miguel et al. (2014) Promoting transparency in social science research. Science, 343: 30. DOI: 10.1126/science.1245317 21 Nature (2016) Availability of data, material and methods. http://www.nature.com/authors/policies/availability.html 22 Here we specifically refer to raw data, reproducible analyses (e.g., code), results, and reports, beyond what currently exists in the Canadian Environmental Assessment Registry. http://www.ceaa-acee.gc.ca/050/index-eng.cfm 23 Section 19.1 Canadian Environmental Assessment Act. (2012) http://laws-lois.justice.gc.ca/eng/acts/c-15.21/page-3.html#h-13 24 Convention on Biological Diversity (1992) https://www.cbd.int/convention/text/default.shtml 25 Canada’s Intended Nationally Determined Contribution Submission to the United Nations Framework Convention on Climate Change (2015) http://www4.unfccc.int/submissions/INDC/Published%20Documents/Canada/1/INDC%20-%20Canada%20%20English.pdf 26 US Occupational Safety and Health Administration (12 Sep 2013) Occupational Exposure to Respirable Crystalline Silica, Document 78 FR 56273. https://www.gpo.gov/fdsys/pkg/FR-2013-09-12/pdf/2013-20997.pdf 27 Gibson et al. (2015) Fulfilling the Promise: Basic Components of Next Generation Environmental Assessment. Journal of Environmental Law & Practice. https://ssrn.com/abstract=2670009 28 Trudeau (13 Nov 2015) Mandate letters to the Minister of Natural Resources, the Minister of Environment and Climate Change, and the Minister of Fisheries, Oceans, and the Canadian Coast Guard. http://pm.gc.ca/eng/mandate-letters 29 Doelle (2014) The Lower Churchill Panel Review: Sustainability Assessment Under Legislative Constraints. https://ssrn.com/abstract=2480368 30 CBC News (7 Oct 2016) Economic benefits of LNG project outweighed 'significant adverse' effects, cabinet decided http://www.cbc.ca/news/politics/cabinet-decision-pacific-northwest-lng-1.3796552 31 Government of Canada (Accessed 6 Nov 2016) Review of Environmental and Regulatory Processes. https://www.canada.ca/en/services/environment/conservation/assessments/environmental-reviews.html Page 3 of 3