ECO-PEI reviews the draft Strategic Environmental Assessment

September 27, 2013.
The Environmental Coalition of Prince Edward Island,
81 Prince St.,
Charlottetown, PEI C1A 4R3

To whom it may concern,

Re:  Public Review of Draft Western Newfoundland and Labrador Offshore Area
Strategic Environmental Assessment Update Report (2013)

Thank you for the opportunity to comment on the SEA Update Report.

We have seen nothing in this update to allay any of the very serious concerns and objections we have stated in previous submissions and re-state below. The update seems to be an attempt to show that consultation requirements have been fulfilled and development should proceed. This is not surprising, given the history of environmental assessments in our region (only once has there been a recommendation to stop development), and the inappropriate mandate of the CNLOPB as both regulator and development facilitator.

In addition, there are several weaknesses in the Update Report that we know have been brought to your attention with detailed criticism so we simply state those issues:

1. inadequate consideration of sensitive or biologically important zones

2. contrary to the intention of these assessments, CNLOPB is presently facilitating oil and gas exploration and development by allowing seismic testing, issuing licenses, and making land ownership and control agreements with oil companies

3. an Oil Spill Response Gap study needs to be done to address this profound discrepancy of oil spill preparedness in the Gulf of St. Lawrence

4. flaws in the consultation process, and understating of comments to the draft Report which stated opposition to oil and gas development in the Gulf, as well as downplaying other independent reports which recommended protection of the ecology of the Gulf.

5. the narrow, inadequate terms of reference for this SEA Update Report

6. downplaying the eventuality of spills, the environmental effects of dispersents that would be used, and the catastrophic consequences of any single ‘blow-out’

7  the dangers and possible contamination of drinking water from hydraulic fracturing

8. although the Update Report describes many of the potential harmful effects of various components of oil and gas exploration in the Gulf, it does not address the ecological fragility of the Gulf of St. Lawrence, and there is no corresponding statement that the Precautionary Principle would dictate stopping oil and gas exploration

9. lack of consideration of liability and compensation to stakeholders negatively impacted by an oil spill

In addition, our previously stated concerns remain:

A. The most important consideration in this assessment is the risk and implications of a drilling rig blow-out.

The BP oil spill catastrophe on April 20, 2010 in the Gulf of Mexico shows the extreme risk of deep water oil development. Ecological destruction continues there, as is reported in http://www.nola.com/news/gulf-oil-spill/ including a story Dec.14, 2011 on “BP well blowout showed oil industry is not set up for safety, scientist panel finds”.
The capacity to contain or respond to an oil spill in the Gulf of St. Lawrence is known to be completely inadequate. Any similar oil spill in the Gulf of St. Lawrence would ruin fish stocks, beaches and coastal communities on PEI and in the rest of the Gulf region.

B. The Terms of Reference for the ‘Independent Review of Environmental Assessment’ stated:  under ‘4. Limitation’ :
“The Independent Reviewer’s mandate shall not include an examination of questions of energy policy, jurisdiction, … or generally matters which go beyond those described in the Scoping Document or as are required pursuant to the CEA Act.”

To exclude questions of energy policy is to avoid the critical issue of whether it is sensible for our governments to choose development of fossil fuel extraction over development of renewable solar energy options. Government policy can determine to which option capital and resources will more readily be directed.

To exclude questions of jurisdiction also ignores a critical difficulty with this process, that is, that ultimately the C-NLOPB holds the power to make decisions that have an great potential to affect other provinces. Current government policy gives full control of offshore drilling activities to Petroleum Boards that are not managed by elected representatives, and that have the conflicting mandates of promoting oil and gas development, and protecting the marine environment.

Both energy policy and jurisdiction should have been included in the Terms of Reference.

THEREFORE:

We join aboriginal, fishing, tourism and other public interest organizations in the Gulf region in stating that the ecology of the Gulf of St. Lawrence must take precedence over fossil fuel exploration and development. For all of the Atlantic Provinces and Quebec, the Gulf is an important long-term sustainable food source, and protecting it is vital for Canada’s social, economic and ecological future.

We must have strong federal laws that are enforced to protect fish habitat and marine resources, including the establishment of more Marine Protected Areas in sensitive zones of the Gulf of St. Lawrence.

We call for an immediate moratorium on offshore exploration and drilling for the entire Gulf of St. Lawrence, so that the provinces and the federal government can work together to protect these critical marine environments, as well as the communities that rely on this important area.

And we must all take part in the immediate transition of our economy away from fossil fuels. That transition will eventually happen as fossil fuels are depleted. It will be much less painful now, while we have the resources needed to build the necessary renewable energy systems and infrastructure. We can avoid more catastrophes.

We would appreciate acknowledgement of our submission.
Thank you,

Tony Reddin, ECO-P.E.I. Energy Project Coordinator,
81 Prince St.,
Charlottetown, PEI C1A 4R3
ecopei.project@gmail.com
Phone: 902.368.7337 or 902. 675.4093
The Environmental Coalition of Prince Edward Island (ECO-P.E.I.) is a community-based action group formed in 1988. ECO-P.E.I.’s goal is to work in partnership with others and the land itself in order to understand and improve the Island environment. Our work centers on education, advocacy and action. On-going projects include The Macphail Woods Ecological Forestry Project and the ECO-P.E.I. Energy Project www.ecopei.ca

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