As a leading Canadian environmental consultancy, Hemmera can be found evaluating the ecological impact of some of the highest-profile projects in the country -- from wind farms in British Columbia to electricity projects in the Yukon.
A wholly owned subsidiary of Ausenco, Hemmera is valued for its technical excellence and for leveraging technology at all levels of the organization to create efficiencies for clients and citizens. SmartComment recently spoke with the head of Hemmera's Environmental Impact Assessment practice, Charlie Palmer, and with Senior Project Manager Norma Powell about the ever-evolving environmental process in Canada, the company's approach to innovation, and how they're transforming their engagement process with SmartComment's all-digital platform.
SMARTCOMMENT: What kind of work does Hemmera do? Who are your primary clients?
NORMA POWELL: Our clients range from large infrastructure developers -- which tend to be private or government -- all the way to smaller companies and individuals who need help managing the regulatory process. A large part of the regulatory process is public consultation, which consists of reaching out to citizens through a public comment period, obtaining their input on a proposed project, providing relevant responses to that input -- and working with our clients to use the public input to improve the projects.
SC: Speaking generally, what are some of the differences between environmental laws in the United States and Canada?
NORMA: Both countries have a long history of environmental assessment (since 1969 in the USA and 1973 in Canada) and have pretty similar processes. Federal, provincial or state, and municipal legislation all go through an environmental assessment or permitting process whereby a project or activity is examined in terms of any environmental effects and mitigation is developed to improve the project -- all before a decision on the project is made. Both countries also have a well-defined mandate to share information with their citizens, both during the process and when a decision on the project is made.
SC: Could you walk me through the steps of a typical public comment period related to environmental requirements? What are some of the immediate and long-term tasks you're responsible for in the environmental process in Canada?
NORMA: It would depend on the specific regulatory process the project is going through, but generally you'd invite the public to an open house to view information about the project and then have a regulated comment period. Those two activities can generally be managed through SmartComment, for example by setting up an online input page that runs for the duration of the comment period. SmartComment works for hard-copy documents, too: if people send letters or submit comments on paper at a public event, Hemmera and the clients can upload those comments into the SmartComment system so we can formulate responses to the hard-copy comments.
On the other hand, if we're working with a regulator who wants to handle the comments themselves, they set up their own input page. Then at the end of the comment period -- or at certain intervals during it -- they'll send us those comments, which we can then upload into SmartComment and start managing there. And at the end of the public or Indigenous consultation process, there's a requirement to report out in a summary document what was said and what the concerns are. It's infinitely easier to do that using a platform like SmartComment.
SC: How many comment periods does your office manage per year?
NORMA: It varies from year to year, but I would say that we probably do a half dozen official comment periods each year. We use SmartComment for these, but we find the software just as helpful outside the official environmental assessment process. For example, we'll use it during the construction phase of a project to take in concerns from residents, neighbors, or stakeholders. So, it's not just for managing the comments related to the official planning and public consultation process; it's perfect for managing public input on smaller projects that aren't part of an official environmental assessment. We use it to manage the ongoing interactions we have with First Nations communities, whom we involve in planning, document review, decision making, and permitting related to projects that might affect their surroundings. Whether we receive a letter, convene a working group that yields some written comments, or receive comments from a regulatory agency, we can input all that information into SmartComment and stay on top of the process on an ongoing basis.
CHARLIE PALMER: I think it's also interesting that our official comment periods can be really unpredictable in terms of the intensity of the public interest. We very often have a relatively small project with a very big response. So, the benefit of having a versatile and scalable software platform to manage the comments is hugely important.
SC: How much would you say that technology related to public engagement has changed in the time you've been in environmental consulting? Is managing the public engagement process with spreadsheets or Word documents a viable method for this kind of work?
CHARLIE: Not for us. Three years ago, we recognized the many inefficiencies that resulted from trying to manage reams of comments using Excel or Word-based tables. We tried some other forms of engagement management software and even built our own Access-based system that won an innovation competition and grant. We piloted that in-house system on a project that had a few hundred comments and the regulator we were working with was really interested in using it going forward. But after being shown SmartComment, we realized it didn't make sense to spend time and money developing functionality that was available in an already-developed tool that had the ability to do everything we needed: allocate comments to a specific discipline lead, track the responses through iterations, review the responses through senior reviewers and the client, and publish them.
Because SmartComment frees us from the manual work of managing the comments back and forth between different formats, we have the capacity to provide regulators and clients much better responses and better-quality control over the process, and that improves outcomes for everyone -- the agencies, consultants, and citizens. Without question, you're going to get a better project by focusing your efforts on its design and execution, rather than poring over Excel tables and trying to work out who's got the right answer to a question, and which answer you need to copy over into the final document.
SC: One criticism you hear about the environmental assessment process is that regulators aren't really listening and will just follow through on their plans no matter what the public input is. Is this a misconception?
CHARLIE: One thing that I think people underestimate in the environmental assessment process is the level of planning that has gone into a project by the time the public sees the proposal. The point of the environmental assessment process is not to get a yes or no from the public as much as it is to hopefully get their help in refining the project and making it a better project than the one that went in at the start. The process is designed to weed out bad projects before they ever even make it to a comment period. In fact, the attrition rate for proposed projects is very high, meaning that many projects don't actually get in front of the public. Most proposed projects fall off during the planning phase, which is why not many fall off during the environmental assessment process and the decision. So, while the public's expectations are sometimes very high about their ability to say no to a project, what they really should be focused on is shaping the project and providing improvements to refine it.
SC: So what are the tenets of running an above-board public engagement campaign that people recognize as genuinely above-board?
CHARLIE: I think it's important to have an open mind about what the parties involved are saying and to look for solutions that respect the needs and concerns everybody involved -- client, regulator, Indigenous groups, stakeholders, affected individuals -- regarding what you might be able to accomplish in refining the project. We must truly listen to the public concerns and suggestions and do our best to provide a practical resolution or project refinement to address their needs.
SC: Do you find that regulators are eager for consultants to bring innovation to the process? Is that something they value?
CHARLIE: Most agencies do value innovation in that it represents efficiency and quality. What I like most about SmartComment is that it offers us the ability to spend time making quality responses and giving regulators and the public better answers and assurances than we did in the past because we had to spend so much time managing the response process.
SC: What are your long-term plans for the SmartComment platform? Are there some things you're looking at having the software do for you that maybe it doesn't do now or that you think would be a natural evolution of its capabilities?
CHARLIE: We've been using the system for about a year and are thrilled with the value and efficiencies it brings to the public comment process. But we've also begun using it internally to communicate with staff in place of some of the other survey platforms. I'd like to see us keep taking advantage of the power of SmartComment both internally and externally.
NORMA: And besides simply handling public comments in the official register, I also use SmartComment for more informal engagement with Indigenous communities and regulators. For a recent project, we might have had 40 comments come in during the official public comment period, but we had literally hundreds of distinct questions and answers from the First Nations communities via some of the working group meetings where we discussed the project and construction options, and where we reviewed draft documents. I would like to see us keep using SmartComment for informal engagement in addition to using it for regulated environmental processes.
SC: When it comes to getting hired for a project, does having SmartComment in your arsenal allow you to differentiate yourself from a competitor who doesn't have access to such a tool?
CHARLIE: I think SmartComment really does provide huge value to our clients, and we definitely promote it to the agencies that hire us. But we've also been marketing it to other consultants and partners who might be struggling with managing comments for their own projects, which opens a whole new class of opportunities for us.