July 22, 2015 John McCauley, CPA CMA Director, Legislative and Regulatory Affairs Canadian Environmental Assessment Agency 160 Elgin Street, 22nd Floor Ottawa ON K1A 0H3 Tel.: 613-948-1785 Fax: 613-957-0897
Email: Regulations@ceaa-acee.gc.ca
Dear Mr. McCauley,
Save Our Seas and Shores Coalition, a coalition of fishermen, First Nations, environmental organizations, and concerned citizens has been advocating protection of the Gulf of St Lawrence from offshore oil and gas development for over fifteen years.
We are advocating this protection due to our Gulf’s extremely sensitive nature, counter-clockwise currents that only empty into the Atlantic once a year, winter ice cover and prime breeding grounds for over 2,200 marine species that spawn, nurse and migrate year round.
Given that the offshore oil and gas industry already has unfettered access to approx. 88% of East Coast waters, with only Georges Bank under moratorium, the fact that we are still fighting for the Gulf’s protection after all this time indicates the disrespect we feel our federal government has for the hundreds of coastal communities and multi-billion dollar renewable fishery and tourism industries in Nova Scotia, New Brunswick, Prince Edward Island, Quebec and Newfoundland and Labrador, who rely on our Gulf for its sustenance. We are growing tired of this disrespect, given that our livelihoods go directly back into our coastal communities and into municipal, provincial and federal coffers.
At this time, we are writing to comment on the proposed regulations that would make the Canada–Nova Scotia Offshore Petroleum Board (the Nova Scotia Board) a responsible authority under the Canadian Environmental Assessment Act, 2012 (CEAA 2012).
In our opinion, entrenching powers for industry controlled offshore petroleum boards into Canada’s Environmental Assessment Act is NOT responsible conduct and will NOT LEAD to a responsible authority. Rather, we consider this a dangerous precedent.
We are profoundly discouraged that CEAA, a federal agency whose legislated mandate is to protect Canada’s environment (and the public interest) would consider such an ill-conceived notion. It is a step backwards. We urge you to reconsider these proposed regulations.
Do you remember the 2010 BP Deepwater Horizon disaster? Allow us to stir your memory:
Five Years After BP Spill, New Rules to Boost Safety -LA Times April 20, 2015: “On April 20, 2010, the Deepwater Horizon oil rig exploded in the Gulf of Mexico, killing 11 people in one of the nation’s worst environmental disasters. For 87 days, the country was transfixed by images of millions of barrels of oil gushing from the seafloor, coating marine life and soiling more than a thousand miles of coast from Texas to Florida. The spill of 3.19 million barrels of oil into the gulf, an amount determined by a federal judge, upended how the federal government regulates offshore drilling… According to a study prepared by the Natural Resources Defense Council, more than $11.6 billion has been paid to individuals. Commercial fisherman could lose $8.7 billion by 2020 along with 22,000 jobs, and lost tourism dollars are more than $22.7 billion. “As many as 5,000 marine mammals may have been killed along with 1,000 sea turtles and nearly 1 million coastal and offshore seabirds, the environmental group said.” “Before the disaster, the Minerals Management Service, part of the Department of the Interior, was the one-stop federal agency handling all issues related to natural gas and oil production on the continental shelf. It awarded leases, collected royalties, conducted environmental impact studies and carried out safety inspections — prompting complaints that its mission created CONFLICTS OF INTEREST. For example, how could the same agency seeking to increase oil revenue be trusted to strictly regulate safety, which could cut income? A month after the disaster, US Interior Secretary Ken Salazar ordered that the agency be split into the Bureau of Ocean Energy Management, the Bureau of Safety and Environmental Enforcement and the Office of Natural Resources Revenue. Each arm focused on a different task, separating revenue from safety and both from leasing issues.
Separation is good for all of the agencies, said Eileen P. Angelico, a spokeswoman for the Bureau of Safety and Environmental Enforcement. “I think it allows us to focus on our mission and to do it more effectively than before.””
Mr. McCauley, it is clear from these comments that separating its environmental protection from the same agency that promotes offshore oil and gas development has been good for the US.
Why won’t Canada do this? A separate safety regulator was recommended by the Offshore Helicopter Safety Inquiry in Newfoundland so why is CEAA apparently choosing to ignore Recommendation 29 of the Wells Inquiry?
It is our position that the proposed effort to entrench industry controlled boards into Canada’s Environmental Assessment agency is an initiative that will take us backwards, further weakening Canada’s environmental protection. Further, it will deepen and will make even worse the conflict of interest that the C-NSOPB and the Newfoundland Board (C-NLOPB) are already in.
We strongly oppose these proposed regulations.
Sincerely, Mary Gorman
Save Our Seas and Shores Coalition