Comments on Export Development Canada's Environmental Review Directive

Overall, we believe that the ERD must be strengthened in order for it to meaningfully reflect the EDC's commitment to ensuring its activities are conducted in an environmentally responsible manner. Currently, the ERD is replete with phrases and terminology that virtually guarantee that its application is almost completely subjective. Second, we have real concerns about the consultation, or comment process around the ERD. We have been asked to provide comments on a Directive that has already become operative. This offends a fundamental principle of public consultation, which is that opportunities for input are to be made prior to final decision-making.