legislation is used to govern development and approval process, this system is a mixture of the Environmental Management and Pollution Control Act 1994 (Tas) (EMPC Act), Land Use Planning and Approvals Act 1993 (Tas) (LUPA Act), State Policies and Projects Act 1993 (Tas) (SPPA), and Resource Management and Planning Appeals Tribunal Act 1993 (Tas). Victoria (VIC) The EIA process in Victoria is intertwined with the Environment Effects Act 1978 (Vic) and the Ministerial Guidelines for Assessment of Environmental Effects (made under the s 10 of the EE Act). Western Australia (WA) Part 4 of the Environmental Protection Act 1986 (WA) provides the legislative framework for the EIA process in Western Australia. The EPA Act oversees the planning and development proposals and assesses their likely impacts on the environment. Canada In Friends of the Oldman River Society v. Canada (Minister of Transportation), La Forest J of the Supreme Court of Canada described environmental impact assessment in terms of the proper scope of federal jurisdiction with respect to environments matters, Supreme Court Justice La Forest cited , "The basic concepts behind environmental assessment are simply stated: (1) early identification and evaluation of all potential environmental consequences of a proposed undertaking; (2) decision making that both guarantees the adequacy of this process and reconciles, to the greatest extent possible, the proponent’s development desires with environmental protection and preservation." La Forest referred to and who described "...environmental assessments as a planning tool with both an information-gathering and a decision-making component" that provide "...an objective basis for granting or denying approval for a proposed development." Justice La Forest addressed his concerns about the implications of Bill C-45 regarding public navigation rights on lakes and rivers that would contradict previous cases. The Canadian Environmental Assessment Act 2012 (CEAA 2012) "and its regulations establish the legislative basis for the federal practice of environmental assessment in most regions of Canada." CEAA 2012 came into force July 6, 2012 and replaces the former Canadian Environmental Assessment Act (1995). EA is defined as a planning tool to identify, understand, assess and mitigate, where possible, the environmental effects of a project. Opposition Environmental Lawyer Dianne Saxe argued that the CEAA 2012 "allows the federal government to create mandatory timelines for assessments of even the largest and most important projects, regardless of public opposition." On 3 August 2012 the Canadian Environmental Assessment Agency designated nine projects: Enbridge Northern Gateway Pipeline Joint Review