January 25, 2016
Hon. James Gordon Carr Minister of Natural Resources
Ottawa, Ontario K1A 0E4
Hon. Siobhan Coady Minister of Natural Resources PO Box 8700
St. John’s NL A1B 4J6
Re: Canada-Newfoundland and Labrador Offshore Petroleum Board and the Gulf of St. Lawrence
I am writing of behalf of the Prince Edward Island chapter of Save Our Seas and Shores (SOSS PEI). SOSS is a coalition of fishing organizations, environmental and tourism groups, coastal landowners, First Nations organizations, and individuals who are concerned that the ecologically rich and diverse Gulf of St. Lawrence, home to over 4,000 marine species, is particularly sensitive to any disturbance caused by seismic surveys, exploration and drilling for oil and gas.
As you know, for the third time in the past four years, the Canada-Newfoundland and Labrador Offshore Petroleum Board (the NL Board) has granted a one-year extension to Corridor Resources exploration licence on the Old Harry prospect in the Gulf of St. Lawrence, located mid-way between the Magdalen Islands and the west coast of Newfoundland. Citing regulatory factors as its reason, the NL Board also waived, for the third time in four years, the $1 million deposit required for a licence extension. The “regulatory factors” the NL Board referred to is the requirement for public and Aboriginal consultations which the Board must hold as part of the environmental assessment for this project.
In August 2011, the NL Board contracted with former New Brunswick Ombudsman Bernard Richard to carry out an independent review of the Old Harry project, then in February 2012 terminated his contract, without justification, before any public consultations were held. Since then, the NL Board has dragged its heels despite numerous inquiries asking when and how these consultations will be carried out. Even now, the NL Board in its January 15, 2016 news release, says it will announce plans for consultations with Aboriginal groups and the public “at a later date”, not sometime soon. Does the Board intend to keep on delaying the consultations indefinitely and continue to give Corridor Resources free licence extensions?
The current licence extension for Corridor Resources is just one in a series of irresponsible, biased actions and decisions on the part of the NL Board. In 2012, the Board contracted with AMEC Environment and Infrastructure to update the Strategic Environmental Assessment (SEA) of the Newfoundland portion of the Gulf of St. Lawrence. The purpose of the SEA was to assist the Board “in determining whether further exploration rights should be offered in whole or in part for the Western NL Offshore Area.” During the time the SEA was being conducted, the NL Board issued a call for bids for licences, including licences within the Gulf. Clearly, the Board assumed that further exploration rights would be offered in the Gulf, regardless of the findings of the SEA.
The SEA update report from AMEC discussed: numerous risks to marine species and the fisheries and tourism industries, the presence of many sensitive areas and endangered species, important data gaps, and the complex and deteriorating state of the Gulf. The lack of social acceptability was apparent from the results of the public consultations held in the five Gulf provinces. Of 597 written submissions and verbal comments, 582 expressed concerns regarding continued petroleum exploration in the Gulf. The logical conclusion, based on the findings in the report, would have been that the known risks outweigh the potential benefits. Instead of the normal procedure in which the authors of a report write the conclusions, the NL Board made the bizarre decision to write the conclusions itself. (This fact is no longer obvious in the final report on the Board’s website, perhaps due to criticism the Board received for writing its own conclusions.) Predictably, the NL Board concluded that “petroleum exploration activities generally can be undertaken in the Western NL area using the mitigation measures identified in the document.”
In addition, the Board concluded that suggestions that petroleum exploration activities in the Gulf should cease were policy decisions not within its mandate, despite the fact that the purpose of the report was, as noted above, to assist the Board in deciding whether to continue offering exploration rights in the NL portion of the Gulf.
As you know, to date only two of the five Gulf provinces have set up Offshore Petroleum Boards: Nova Scotia and Newfoundland and Labrador. The Nova Scotia Board ceased any activity in the Gulf after a public review panel responded to public and Aboriginal concerns in 1999. If the NL Board did not have a pro-petroleum industry bias, it would also cease all activity in the Gulf.
The roles of the NL Board are to facilitate the exploration and development of hydrocarbon resources in the NL Offshore and to protect the environment and worker safety. As noted in the Wells Report of 2010, these are conflicting roles. Clearly, the NL Board shows by its actions and decisions that protecting the Gulf ecosystem is not a priority.
We believe that the federal and NL governments have abrogated their responsibilities to oversee the decisions of this appointed body. Decisions, including the recent free extension of Corridor Resources licence, appear to have been rubber-stamped by the federal and NL Ministers of Natural Resources. Only NL benefits from oil and gas exploration and development in the Gulf, while the other four Gulf provinces share the risks. The protection of marine species and the rights of the First Nations, fishers, and other residents of the Gulf provinces to protect the Gulf ecosystem and pursue their livelihoods are being ignored.
In light of the failure of the Canada-Newfoundland and Labrador Offshore Petroleum Board to act in a responsible manner, SOSS PEI is calling on the federal and Newfoundland and Labrador governments to remove the Board’s mandate pertaining to offshore oil and gas exploration and development activities in the Gulf of St. Lawrence.
Sincerely, Ellie Reddin
Past-Chair, Save Our Seas and Shores-PEI Chapter (SOSS PEI)
c. Hon. Lawrence MacAulay, MP Hon. Wayne Easter, MP Sean Casey, MP Robert Morrissey, MP Hon. H. Wade MacLauchlan, Premier of Prince Edward Island Hon. Robert Mitchell, Minister of Communities, Land and Environment Hon. Paula Biggar, Minister of Transportation, Infrastructure and Energy Hon. Alan McIsaac, Minister of Agriculture and Fisheries
Greg Wilson, Manager, Environmental Land Management
Defenders of the Gulf of St. Lawrence who live on Prince Edward Island are telling James Carr, Canada’s Minister of Natural Resources, and his provincial counterpart in Newfoundland and Labrador Siobhan Coady that it is time to pull the plug on the C-NLOPB.
This action follows the publication of Ellie Reddin’s Jan 27th article in the Journal Pioneer and PEI’s The Guardian, which pointed out a series of irresponsible, biased decisions made by the C-NLOPB over the past several years, including their recent decision to provide Corridor Resources a third extension on their exploration license for the Old Harry prospect in the Gulf of St. Lawrence. In her followup letter to the Ministers, Reddin wrote: “Citing regulatory factors as its reason, the [C-NLOPB] also waived, for the third time in four years, the $1 million deposit required for a licence extension. The “regulatory factors” the Board referred to is the requirement for public and Aboriginal consultations which the Board must hold as part of the environmental assessment for this project.”
“Decisions, including the recent free extension of Corridor Resources licence, appear to have been rubber-stamped by the federal and NL Ministers of Natural Resources. Only NL benefits from oil and gas exploration and development in the Gulf, while the other four Gulf provinces share the risks. The protection of marine species and the rights of the First Nations, fishers, and other residents of the Gulf provinces to protect the Gulf ecosystem and pursue their livelihoods are being ignored.”
In light of the failure of the Canada-Newfoundland and Labrador Offshore Petroleum Board to act in a responsible manner, SOSS PEI is calling on it’s members to write to the Ministers to demand that the federal and Newfoundland and Labrador governments to remove the Board’s mandate pertaining to offshore oil and gas exploration and development activities in the Gulf of St. Lawrence.
See SOSS PEI full letter to federal Minister James Carr, and NL Minister of Natural Resources Siobhan Coady here.
The Gulf needs your support. Add your voice to SOSS PEI’s by sending a short email message to the Ministers – here’s is a sample message you could copy and paste, or personalize as you wish:
I am writing to express my support for the letter you recently received from SOSS PEI regarding the Canada-Newfoundland and Labrador Offshore Petroleum Board (C-NLOPB) and the Gulf of St. Lawrence. As outlined in the letter, the C-NLOPB has shown by its actions and decisions over the past several years that it is failing to carry out its responsibility to protect the Gulf environment. As Ministers responsible for the C-NLOPB, please act to remove the Board’s mandate pertaining to oil and gas exploration and development activities in the Gulf of St. Lawrence.
(Your home community and province)
Email addresses for the two Ministers are:
Minister.Ministre@nrcan-rncan.gc.ca and firstname.lastname@example.org
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
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
On Saturday, November 1st, the Prince Edward Island Preserve Co. in New Glasgow, PEI hosted a fundraising dinner in support of the Sierra Club Atlantic Chapter’s Blue Whale Campaign to protect the Gulf of Saint Lawrence. Save Our Seas and Shores PEI and Sierra Club member, Colin Jeffery, spoke to those in attendance, highlighting and expanding upon some of the more notable threats that have already begun to impact the health of the Gulf, such as: climate change, excess nutrients and invasive species. Jeffery then focused his talk on the perils of oil and gas explorations that further threaten the hypersensitive and already fragile ecosystem within Gulf waters.
The Blue Whale Dinner was a successful fundraising event, but equally, and perhaps more so, it raised public awareness on the issues that directly impact the overall health and sustainability of life in the five provinces that border the Gulf, as well as the Gulf’s role as an integral part of a greater ecosystem far beyond our shores. As past-chair of the Save Our Seas and Shores PEI, Ellie Reddin stated, “It was a lovely evening…[and] it would make a fine annual event!”.
The Blue Whale Campaign is building public support for increased protection of our threatened Gulf ecosystem and a moratorium on oil and gas development in these waters.Read a more in depth account of the Blue Whale Dinner on the PEI Preserve company Blog post here.
Over the past number of months, all municipalities in Prince Edward Island were provided information by PEI SOSS in the form of a Resolution on Oil and Gas Exploration in the Gulf of St. Lawrence . The proposed resolution provided two options for municipalities: Moratorium until Review/Public Consultation Occurs and Moratorium Leading to Ban.
Since then, the following municipalities have informed us that they have discussed and approved a resolution with one or both of the two options presented, and have sent a letter to the Premier to indicate their respective councils’ positions. Those municipal councils who have passed the resolution are as follows:
North Rustico (permanent ban)
Murray River (both options)
Bonshaw Community Council will present an updated Resolution to the Federation of PEI Municipalities at their AGM on April 28th. Many thanks to all who have taken initiative in their respective areas to further this cause & protect of the Gulf!
On November 26th, 2013, that Standing Committee on Fisheries, Transportation and Rural Development recommended in its recent report to the Legislature that the government act on the requests that PEI Save Our Seas and Shores put forward in our petition calling for, “a moratorium on all oil and gas exploration and development in the Gulf of St. Lawrence”. See recommendation 5 and the related discussion here.
The transcript of Sylvain Archambault’s presentation to the Standing Committee on Fisheries, Transportation and Rural Development is now available here.
Similarly, in Prince Edward Island’s Legislative Assembly, the Standing Committee on Agriculture, Environment, Energy and Forestry presented their recommendations to the government. The entire report is of interest and, like the Standing Committee on Fisheries, Transportation and Rural Development (the report I sent you yesterday), the Standing Committee on Agriculture, Environment, Energy and Forestry recommends the requests of PEI SOSS petition be adopted.
See the video and skip forward to 88 minutes.
The written report of the Standing Committee on Agriculture, Environment, Energy and Forestry (which includes a more detailed discussion) is available here.
Let’s hope the government gives adequate weight to the recommendations of the two standing committees!
Elizabeth Young Environmental Assessment Officer Canada-Newfoundland and Labrador Offshore Petroleum Board Fifth Floor, TD Place 140 Water St.
St. John’s, NL A1C 6H6
Dear Ms Young,
I am writing to respond to the publicly released draft of the Western Newfoundland and Labrador Offshore Area Strategic Environmental Assessment (SEA) Update report. I would like to thank you for providing an opportunity to respond to this important and influential document.
The SEA Update report provides a clear picture of the current offshore oil and gas industry in Newfoundland/ Labrador and some of the potential impacts of an expansion in offshore drilling along Newfoundland’s west coast. However, this report continuously downplays the actual risks of offshore drilling in the Gulf of Saint Lawrence and contains several omissions including no discussion of the environmental impacts of dispersants or the impacts of sea ice and high winds on oil spill response effectiveness.
Regarding the environmental impacts of chemical dispersants, particularly Corexit, the SEA Update report does not discuss these despite its claim to do so and despite the fact that new research suggests when Corexit becomes mixed with oil the toxicity of the mixture increases up to 52-fold (see http://www.huffingtonpost.com/2013/04/23/corexit-oil-spill-gulf_n_3134963.html).
Regarding responses to large and small spills of oil and other contaminants in the Gulf of Saint Lawrence, the SEA Update report does not discuss factors limiting these responses including seasonal high winds, waves and sea ice. In particular, the unusual obstacle of seasonal sea ice to offshore spill clean-up activities is not addressed. Research on the effectiveness of oil spill clean-up activities suggests that under even under ideal weather conditions only a small percentage of the spilled oil can actually be removed from the water. With this caveat in mind it is by no means clear that offshore operators have the means to effectively clean up an oil spill when high winds or sea ice are present. The failure of the SEA Update report to address this issue is a large oversight and should be rectified.
Public comments in the SEA Update report are not clearly presented, obscuring the fact that public concerns around offshore development in the Gulf are widespread. Of the 516 comments from the consultation sessions in the draft Consultation Report (Appendix A), only eight (8) could be considered to be supportive of offshore development in the Gulf. Surprisingly, this lack of social license to drill in the Gulf is not addressed and does not appear to be taken into consideration in the draft SEA Update report.
Finally, the omission of a conclusion gives the public no opportunity to comment on AMEC’s recommendations on future offshore drilling activities in the western Newfoundland region before they are finalized. This appears to be a clear attempt to limit meaningful public comments (including those from knowledgeable academics and scientists) on the most important segment of the SEA Update report; namely, AMEC’s recommendations on future offshore activity after a comprehensive review of the facts.
I thank you for the opportunity to comment on the draft SEA Update report and hope that AMEC and the NLOPB consider seriously the oversights and omissions pointed out by myself and others.
Sincerely, Colin Jeffrey
York, PE C0A 1P0
Read here what The Guardian news of PEI says about the issue and these public talks.
Submission from Save Our Seas and Shores PEI to the Canada-Newfoundland and Labrador Offshore Petroleum Board
At its meeting on September 10, 2013, members of the Prince Edward Island Chapter of Save Our Seas and Shores decided to make the following submission in response to the draft Western Newfoundland Offshore Area Strategic Environmental Assessment (SEA) update report.
WHEREAS the Western Newfoundland Offshore SEA draft report clearly acknowledges the following:
- The biological importance and sensitivity of Newfoundland’s offshore area in the Gulf of St. Lawrence;
- The importance of fisheries and tourism to the regional economy;
- Not enough is known about the biology of the Gulf and the impact of oil and gas activities on it;
- Uncertainties about the efficiency of mitigation measures;
- The enormous impact that any oil spill in the Gulf would have;
- The lack of social acceptance, in any of the five provinces bordering on the Gulf, of the idea of oil exploration in the Gulf.
WHEREAS intervention capacity in the Gulf of St. Lawrence is inadequate (as has been shown by the Commissioner of the Environment and Sustainable Development);
WHEREAS in the early 2000s, the Fisheries Resource Conservation Council (FRCC) and the Senate Standing Committee on Fisheries both recommended a moratorium on petroleum exploration in the Gulf;
WHEREAS liability for oil companies is still limited to $30 million, and even if increased to $1 billion as currently proposed, would remain inadequate considering the potential costs associated with a major spill;
WHEREAS any major spill could negatively affect all five Gulf provinces; and
WHEREAS an integrated environmental review of polluting industrial activities and climate change and their cumulative impact in the entire Gulf of St. Lawrence has still not been performed;
The PEI Chapter of Save Our Seas and Shores recommends that the Canada-Newfoundland and Labrador Offshore Petroleum Board :
- Put a moratorium on the issuing of any new exploration licenses in the Western Newfoundland offshore area;
- Cancel the call for bids issued on May 16th 2013 for four parcels in the Western Newfoundland offshore area;
- Refrain from giving authorization to projects currently submitted in the Gulf of St. Lawrence, including Corridor Resources’ Old Harry project and Shoal Point Energy and Black Spruce Exploration’s Western Newfoundland drilling program.
Prince Edward Islanders are also responding!
Here is Ellie Reddin’s submission to the Canada Newfoundland and Labrador Offshore Petroleum Board.
August 6, 2013
Elizabeth Young Environmental Assessment Officer Canada-Newfoundland and Labrador Offshore Petroleum Board Fifth Floor, TD Place 140 Water St.
St. John’s, NL A1C 6H6
Dear Ms. Young:
Thank you for sending me a copy of the draft Western Newfoundland and Labrador Offshore Area Strategic Environmental Assessment (SEA) Update report and inviting me to provide comments. I found the report to be informative and extensive. These are my comments:
Throughout the draft report, references to feedback from the consultation sessions refer to wide-ranging and diverse comments, but do not indicate that comments urging protection of the Gulf of St. Lawrence from oil and gas exploration and development were much more frequent than those promoting such activity. Of 81 written submissions included on the C-NLOPB website, only seven were in favour of exploration and development. In addition, I counted 516 comments from the consultation sessions in the draft Consultation Report (Appendix A). Only eight of these comments were in support of oil and gas exploration and development in the Gulf and two of those eight comments included caveats regarding environmental issues. If one were to read the draft report without reading the detailed consultation results, one would be led to believe pro-development comments were as frequent as cautionary comments. That is simply not the case. The final report should more accurately reflect the fact that the great preponderance of comments opposed oil and gas exploration and development in the Gulf.
The draft report repeatedly states that accidental oil spills and blowouts are “unlikely” or “rare”. This repetition serves to downplay the eventuality of spills.
One of the studies noted in the draft report (p. 57) estimated blowout frequency during exploration drilling at 1 in 267 wells, based on US data from 1980-2010. A second estimate (1 in 6,250), also mentioned on page 57, is said to be “based on more recent data”, but it covers 1988-2009 so it is not based on more recent data, just a shorter time period. Also, it is clear that the 1 in 267 wells estimate is based on approximately 12,000 US offshore exploration wells, but no information is provided about the number, type or location of wells included in the lower estimate.
The above-noted estimates are for blowouts only. Spills not constituting blowouts are much more common.
In the NL Offshore Area, using C-NLOPB data, the draft report (pp. 58-59) indicates there were 238 spills greater than one liter in sixteen years with a total spill volume (including smaller spills) of 469,144 liters and an average of 29,322 liters of oil spilled per year. Spills have occurred in every year. Clearly, spills are not “unlikely”. The statistical probability of catastrophic blowouts might be low, but minor spills are apparently inevitable.
Given the much longer history of oil and gas exploration and development off the east coast of Newfoundland, one would assume that the spill data is from that area, although that is not explicitly stated in the draft report. The cumulative effects over time of minor spills in the sensitive, semi-enclosed Gulf of St. Lawrence ecosystem would be much more serious than in the Atlantic Ocean and the effect of even one large spill or blowout could be devastating. The final report should avoid minimizing the serious risks posed by oil spills in the Gulf by removing the frequently repeated statements that they are unlikely.
Use of Dispersants:
In Table 2.2 (p. 19) it is stated that the topic of “use of oil dispersants and their potential effects” is addressed in Sections 3.1, 3.2, 5.1, 5.2, 5.3, 5.4, and 5.5, but in fact this issue is not addressed at all. I could find no information in the draft report about the use of dispersants, in particular Corexit, to clean up oil spills. Recent research from the Georgia Institute of Technology and Universidad Autonoma de Aguascalientes (UAA), Mexico, found that mixing Corexit with oil increased toxicity of the mixture up to 52-fold over the oil alone. [See http://phys.org/news/2012-11-gulf-mexico-clean-up-times-toxic.html and http://www.huffingtonpost.com/2013/04/23/corexit-oil-spill-gulf_n_3134963.html , as well as the video link in the next paragraph. The final report should indicate whether dispersants are being used in the NL Offshore and, if so, should discuss the potential harm caused by dispersants and recommend alternative methods for dealing with oil spills.
Long-term Impact of the 2010 Gulf of Mexico Blowout:
Table 5.1 on page 392 includes the following statement regarding the Gulf of Mexico blowout: “There is no clear picture yet concerning short-and-long-term effects on habitats and marine organisms.” This 37 minute video documents some of the short-term and long-term impacts.
On pp. 429-430, the draft report mentions some research on the possible contamination of drinking water arising from hydraulic fracturing. The following article discusses a study which found contamination of drinking water with methane, ethane and propane near shale gas wells in Pennsylvania.
Fall 2012 Report of the Commissioner of the Environment and Sustainable Development:
The Commissioner’s report is mentioned in passing on page 70. In addition, several references throughout the draft SEA update report are made to C-NLOPB’s commitment to follow up on one of the Commissioner’s recommendations by completing a review of the spill response capability of operators under its jurisdiction. The Commissioner’s report ought to be taken very seriously. All of the recommendations and C-NLOPB’s response to each should be set out more fully in the final SEA update report.
Use of Acronyms:
Acronyms are used throughout the draft report and it is difficult for the reader to always remember what they represent. All acronyms used and the full titles they represent should be listed at the front of the final report for reference. This is a minor point, but it would make the report easier to read.
As stated on page 5 of the draft report, “The specific ‘strategic decision’ that the SEA Update is intended to inform is therefore whether to issue further exploration licenses in the Western NL Offshore Area, and if so, to identify any environmental components and issues which should be considered in taking these future decisions and actions.”
The draft report delineates the potential harmful effects of various components of oil and gas exploration in the Gulf, including seismic surveys, traffic, structures, lights, routine discharges, drill muds, other disturbances, well abandonment, and accidental spills. It discusses the risks to fish and fish habitat, plankton, shell fish, water birds, marine mammals, turtles, endangered species and species at risk, protected and sensitive areas, fisheries, and tourism, as well as noting important data gaps. The draft report also discusses the dynamic and complex Gulf ecosystem and the effects of factors such as climate change and aquatic invasive species, and includes statements such as “it is generally agreed that there has been a trophic shift over the last 30 years that may not yet be stabilized, and consequently, the ecosystem may have somewhat less of a buffering capacity to potential stressors” (page 399).
The logical conclusion, based on the information in the draft report, is that the possible benefits of additional exploration licences and, potentially, production licences are outweighed by the known risks. Unfortunately, the solid and well-documented information about risks and impacts is undermined by weak suggested mitigations, repeated assertions that the identified issues will be dealt with by project-specific environmental assessments, and a tendency to minimize potential impacts. Some examples of this tendency to minimize are noted in this letter.
I sincerely hope the final SEA Update report will recommend, and C-NLOPB will make, strategic decisions to: • cancel the current Call for Bids; • put a moratorium on issuing any further licences; and
• be extremely diligent, using a precautionary approach and rigorous project-specific environmental assessments, before approving any further activities under current licences in the Western Newfoundland and Labrador Offshore Area.
Thank you for the opportunity to respond.
cc Steve Bonnell, AMEC Environment and Infrastructure
Greg Wilson, Manager of Environmental Land Management