Premier Danny Williams of Newfoundland and Labrador
Federal Fisheries Minister Gail Shea
Federal Environment Minister Jim Prentice
September 14, 2010
Re: Gulf of St. Lawrence Oil and Gas regulatory regime
Dear Mr. Williams, Mr. Prentice and Ms. Shea:
Recently, an exploration license was issued by the Canada Newfoundland Offshore Petroleum Board for the ‘Old Harry’ oil and gas prospect in the Gulf of St. Lawrence. This has caused anxiety and despair, but also mobilization of citizens from Nova Scotia, New Brunswick, Prince Edward Island, Newfoundland, Quebec and the Magdalen Islands.
Six and a half times smaller than the Gulf of Mexico, the Gulf of St. Lawrence is a fragile, landlocked, semi-enclosed body of water that completely exchanges its water with the Atlantic Ocean only once a year. In 1973, Dr. Loutfi of McGill University described it as the most productive marine region in Canada that should never be placed in harm’s way. According to him, because of its circular, counterclockwise currents, any oil and gas contamination would be widespread along the Gulf coastlines of Nova Scotia, New Brunswick, Prince Edward Island, Quebec and Newfoundland and Labrador.
As it stands now, the Right whale, Blue whale, leatherback turtle, piping plover and harlequin duck are endangered; while Atlantic salmon, cod, fin whale, and humpback whale are in trouble – a disgraceful indicator that in only fifty years, our generation has taken for granted and degraded our Gulf’s natural, renewable resources. We have allowed unfettered industrial development and pollution with little regard for the precautionary principle and ecosystem approaches demanded by the United Nations Convention on Biodiversity.
The problem stems, in part, from the existing offshore regulatory structure which, in our opinion, is fundamentally flawed.
1. As it exists right now, five Gulf provinces have or will draw on man-made maps that provide artificial jurisdictional boundaries for undersea hydrocarbon exploitation, as if our Gulf were five separate bodies of water. Of course, it is not.
It is one natural, irreplaceable ecosystem of magnificent beauty with spawning, nursery and migratory areas for over two thousand different marine species – lobster, herring, mackerel, crab, to name a few. Our five provinces have shared these same fish stocks that have sustained historic Gaelic, Acadian and First Nations coastal communities for centuries. We hope to continue to do so for future generations and we trust you agree. Our children deserve no less.
May we also remind you that these same fish swim across all the Gulf’s provincial boundaries. This brings us back to the unworkable jurisdictional quagmire we find ourselves in. With all due respect, Mr. Premier and Honourable Ministers, nothing exists in isolation. It is neither workable nor acceptable for our five Gulf provinces to be functioning through the National Energy Board and potentially, five separate offshore petroleum boards.
These separate bodies fail to consider the ecological, economic and social impact these deepwater wells could pose on all our shores and the at least 50,000 jobs created annually by our Gulf’s multi-billion dollar fisheries and tourism industries. As well, the current regulatory structure permits offshore petroleum boards to undermine federal and international obligations to protect wildlife threatened or endangered with extinction. This must not continue.
2. These petroleum boards have irreconcilable mandates as both promoters of extraction and protectors of our environment. After the BP oil spill, the US government finally recognized this inherent conflict and has separated these two functions. Surely we don’t want to wait until after the fact.
3. Furthermore, current Canadian legislation limits driller liability in case of spill/damages to $40 million dollars. We hardly think $40 million dollars is adequate. So far, BP has spent $8 billion dollars and has set aside a total of $20 billion. In the event of an oil spill or well blow-out in our Gulf, who will pick up the rest of the multi-billion dollar tab? The Canadian taxpayer?
Clearly, the public interest is not protected on any level under the current offshore regulatory regime. The Gulf of Mexico BP disaster affected an area almost as large as our entire Gulf and scientists report that the oil released has already entered the food chain. In light of this, we respectfully request, Premier Williams, that you remove the ‘Old Harry’ license immediately and deny any request for seismic testing of the area.
We respectfully request, Minister Shea and Minister Prentice, that you both exercise your federally-legislated powers to impose an immediate moratorium on any and all oil and gas exploration in the Gulf of St. Lawrence for now and in the foreseeable future. The benefits of 1 or 2 decades of non-renewable oil revenue could never come even close to justifying the enormous risks to the centuries-old renewable resources of our priceless Gulf.
Simply put, the Gulf of St. Lawrence is not worth risking.
In closing, ‘No generation has the right to live for itself alone. But rather, if there is such a thing as a natural, moral law, each generation must pay to the future the debt it owes to the past.’
We look forward to hearing from you at your earliest convenience.
Save Our Seas and Shores Coalition
Merigomish, NS BOK1GO
Albert D Marshall, Chair, Unama’ki Elders Senate, Eskasoni, NS
Association of Inshore Fishermen of the Magdalen Islands, QC (AIFMI)
Andre Stainier, President, Les Amis de la valée du Saint Laurent, QC
Atlantic Salmon Federation, NB
Attention FragÎles, Magdalen Islands, QC
Conservation Council of New Brunswick (CCNB)
Canadian Parks and Wilderness Society, Nova Scotia Chapter (CPAWS- NS)
Canadian Parks and Wilderness Society, Newfoundland Chapter (CPAWS- NL)
Canadian Parks and Wilderness Society, Quebec Chapter (CPAWS- QC)
David Suzuki Foundation, Fondation David Suzuki
Dr. Irene Novaczek, Earth Action, PEI
Dr Peter G. Wells, Chair, Bay of Fundy Ecosystem Partnership (BoFEP)
Ecology Action Centre, Halifax, NS
Environmental Health Association of Nova Scotia (EHANS), NS
Executive of the Natural History Society of Newfoundland and Labrador
Friends of Covehead and Brackley Bays Watershed Group of PEI
Friends of the Pugwash Estuary, NS
Gulf Nova Scotia Bonafide Fishermen’s Organization, NS
Gulf Nova Scotia Fishermen’s Coalition, NS
Gulf NS Herring Federation, NS
Harvey Area Water and Air Quality Committee, NB
Hillsborough River Association, PEI
Ingrid Cottenden, Program Secretary, College of Sustainability, Dalhousie Univ., Hfx, NS
Maliseet Nations Conservation Council, NB
Margaree Environmental Assn, Cape Breton, NS
Maritime Fishermen’s Union (MFU),Union des Pecheurs des Maritimes (UPM), NB
Mike McGeoghegan, President, PEI Fishermen’s Ass’n (PEIFA), PEI
Northumberland Fishermen’s Association, NS
Patty Donovan,Campaign Pesticide Reduction, NB
Petitcodiac Watershed Alliance/Alliance du Bassin Versant Petitcodiac, NB
Pictou County Watershed Coalition, NS
Pisquid River Enhancement Project, PEI
Regroupement des Pecheurs Professionelle des Iles (RPPIM), QC
Regroupent des pecheurs Palangrier Unique des Iles de la Madeleine (RPPUM), QC
Sierra Club Canada – Atlantic Canada Chapter (NS, NB, PEI, and NL)
Sierra Club, Montreal Chapter, QC
Strategies Saint-Laurent, umbrella organisation for the ZIP committees of Quebec
Sunrise Trail Community Development Coop, NS
Victoria Reed, College of Sustainability, Dalhousie University, NS
Wheatley River (watershed) Improvement Coalition (WRIG), PEI
Laura Lambie,Young Naturalists Club of Nova Scotia