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
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:
Victoria-by-the-Sea (moratorium)
North Rustico (permanent ban)
Cavendish
Miltonvale Park
Murray Harbour
Murray River (both options)
Breadalbane
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!
Pictou Advocate
July 17, 2013
Green Heroes: Well loved author and conservationist Farley Mowat with local resident Mary Gorman, Save Our Seas and Shores Coalition. (Photo courtesy of Cinefocus Canada)
MERIGOMISH – The oceans dominate our blue planet yet marine species are some of the first to go. Called into action, Green Heroes are defending marine life with every means necessary, from the written word to waging battles at sea. Green Heroes™ is back for a second season. This time there is a new group of heroes in this smart, sexy and green Web/TV crossover and a local woman, Mary Gorman, is one of them.
Produced by CineFocus Canada in association with TVO, the six 30-minute series (www.greenheroes.tv/tv-episodes) tells stories of people who acted on their ideas and “ventured forth” to protect the planet. From the celebrity to the everyday person, each story details the different paths and interests the Green Heroes have taken in their quests to help save the world.
The story arch of each episode begins with the tipping point event of Green Heroes – the moment that moved them from apathy to action. It then tells of the obstacles and challenges they overcame, ending on the impact their action had on the environment. The goal is to show how a change was made and a community inspired, and to surprise people by including Green Heroes who are not your status quo, but whose story speaks to a mainstream audience. By shining a light on real people who have become Green Heroes through their actions and dedication, the aim is to give everyday people the nudge they need to also become passionate green participants.
Mary Gorman of Merigomish is trying to stop a disaster before it starts: Canada’s own Gulf Oil Spill. Twelve years ago, she turned from fisherman’s wife to Green Hero after two leases were issued for oil and gas development on the shores of her home. Knowing spills were likely and would impact 2,000 marine species including endangered ones, Gorman decided to prevent a disaster instead of reacting later. Today, she has formed a growing movement – Save Our Seas and Shores Coalition – with support from celebrities like Ethan Hawke and Jason Priestley. Her struggle and resulting victory led to her winning the inaugural Green Heroes award, as selected by fans of the web channel and a jury of esteemed environmental and broadcast judges.
Farley Mowat is one of Canada’s most widely read authors and best-known conservationists. His books, such as Never Cry Wolf, have reached more than 14 million readers. After Mowat’s war service in 1946, he trekked in Canada’s Great North where he witnessed the demise of indigenous culture and animals by industrial colonialism. Today, he is one of Canada’s most vocal conservationists, using his books and voice to shed light on the loss of nature and the need to protect it. He is an active supporter of such groups as Sea Shepherd and Mary Gorman’s mission to protect the Gulf of St. Lawrence.
Gorman says of Mowat: “Not only did Farley fight for Canada in World War 2, he has been fighting ever since to protect our world’s vast oceans that were once brimming with wildlife. He will go down in history not only as a literary icon but as one of the world’s earliest and bravest environmentalists, who understands how dependent we are on healthy oceans”.
Alexandra Cousteau is another Green Hero. Through her Blue Legacy project and as a filmmaker and TV host, Cousteau continues the work of her renowned grandfather Jacques-Yves Cousteau and her father Philippe Cousteau Sr.
Green Heroes aired Tuesday night and will air again Sunday at 8:30 p.m. on TVO.
The Nova Scotia Commission on Building our New Economy is examining the province’s rural economic prospects in a series of community meetings held around the province.
Acadia University president and commission chair Ray Ivany, called the commission’s work a chance for Nova Scotians to discuss potential future prosperity for rural areas in NS.
“Nova Scotia is on the brink of its greatest opportunity in generations. We’ve got the shipbuilding contracts, offshore exploration and construction of the Maritime Link… It’s exciting. But I believe that our local economies throughout Nova Scotia – not just in HRM – can thrive, not simply survive, by understanding these opportunities, and sharing ideas about building a better future.”
One wonders what planet Mr. Ivany lives on to suggest that offshore oil exploration can build a better future for Nova Scotians. Not everyone agrees with him.
The Pictou Advocate covered the meeting in Stellarton, NS. In the April 3, 2013 edition, the article notes:
“Some residents have been skeptical of the exercise due to growing concern over oil and gas exploration, such as hydraulic fracturing, or fracking, proposed to extract possibly viable underground natural gas supplies inland, as well as exploratory drilling in the Gulf of St. Lawrence that stakeholders fear would harm the gulf’s fishery.”
The article goes on to quote a local resident, Trudy Watts, who is president of a community development cooperative in the area who stated:
“The blowout of the Deepwater exploratory oil well in the Gulf of Mexico – and the resulting damage to tourism, fishery and restaurant industries – should be enough to bump offshore exploration off Mr. Ivany’s Top 3 list,” she said. “I hope that the commission is truly open to a diversity of ideas that will no doubt include enhancing our fishery and tourism sectors, as part of the way we build a smart, sustainable economy that includes rural Nova Scotians.”
We can only hope that the commission’s interim report, due to come out later in April, will showcase the ideas for a healthy sustainable future which include an oil free Gulf of St. Lawrence.
Minister makes “inaccurate” comments in meeting March 20, 2013
Advocate (Pictou, NS)
To the Editor re: “Oil spill, clean up report raises Gulf group’s fears” (Advocate March 6, 2013), I want to correct inaccurate comments made by Energy Minister Charlie Parker.
1) “Parker acknowledges that Gorman was given considerable time to discuss the moratorium.” For the record, my first question was not about the Gulf of St. Lawrence moratorium. I asked Parker what he intends to do about the billion dollar Shell lease he has approved on NS’s Scotian Shelf. The seismic program for this lease, beginning next month, is for four to six months from April to September each year for the next six years, during fishing seasons, spawning, bluefin tuna migration etc. It covers over a million hectares of ocean bottom. We’ve been told that in a few years, there will only be two populations left on the Scotian Shelf – gray seals and oil rigs. (WARNING: Our Gulf could be next).
2) The ‘considerable time’ Parker refers to, was three minutes. So I guess Gulf NS’s inshore breeding grounds are only worth three minutes of discussion at NDP gov’t public meetings. To be fair, our coalition did meet privately for 25 minutes with the county’s three NDP MLA’s about protecting our Gulf. But we were only able to cover one page of our presentation because these MLAs are not good listeners. In contrast, MP Peter MacKay met with us for one hour and 20 minutes, listened intently, asked intelligent questions, acknowledged the danger of risking sensitive breeding areas and renewable multi-billion dollar fishery and tourism industries, only to access short term fossil fuels. He agreed to follow up on it.
3) “‘Parker also said the province has made no decision on a moratorium in the Gulf.’ “In reality, we don’t have a position,” he said.’ We’re relieved he is backtracking. But at the Antigonish meeting Parker, Deputy Minister Coolican and MLA Maurice Smith were asked if the NDP would support a moratorium in Gulf NS. All 3 said “NO”. (It’s on the public record).
In ‘reality’, Parker signed a petition a decade ago for a moratorium in our Gulf when we were fighting shoreline leases on Cape Breton Island. Perhaps, because he knows the Gulf of St. Lawrence has the largest lobster production in the world. But “little or no information is available… on lobster larval distribution and settlement” * according to DFO scientists.
Gulf fishers are also worried about herring if oil and gas proceeds. Since 20 years after the Exxon Valdez disaster, there is still no herring fishery where that oil spill happened in Alaska. DFO scientists have stated “every month of the year molting, spawning, egg hatching, larvae, feeding, migration, juveniles, adults, and planktonic stages are happening”.*
This is why Canada’s Standing Committee on Fisheries and Oceans in their report on Canada’s Oceans Act (October 2001) stated “it may be prudent to consider placing this region under an oil and gas moratorium similar to that on the Georges Bank region”.
So why are we fighting this same battle 10 years later?
It is ironic that before Parker was elected, he supported a moratorium. But now that he has the power as Energy Minister to implement one, he chooses to squander this privilege and unique opportunity to protect those who put their faith in him. What a kick in the head to Gulf inshore fishers who have a long history as leaders in conservation of their own stocks. They do so, knowing that if they protect their fish, we will continue to have a fishery sustaining hundreds of coastal communities and tens of thousands of jobs in the Gulf of St. Lawrence. Unless, of course, it is destroyed by others.
*DFO Maritime Provinces Regional Habitat Status Report 2001
Mary Gorman, Save Our Seas and Shores Coalition , Merigomish
Mary Gorman
September 27, 2011
This blog post first appeared on blog.greenheroes.tv
Mother Nature will have the final word
Canada’s national media has been ignoring our struggle against unnecessary fossil fuel development on our East Coast. Obviously unnecessary, since even Natural Resources Minister Joe Oliver concedes an ‘excess’ of supply is coming out of the Tar Sands. A coalition of fishermen, First Nations, environmentalists, scientists, teachers etc have been struggling for over a year to have our voices heard in an effort to protect Canada’s Gulf of St. Lawrence, home to over 2,000 marine species, from offshore oil and gas development.
With the nuclear fallout in the Japan Sea and the ongoing Gulf of Mexico crisis, it seems that more and more of our earth’s natural renewable marine food supply is in peril. According to DFO scientists, ‘over one million ton of fish migrate through the Gulf of St. Lawrence annually’. Does anyone with any common sense honestly believe this is sustainable without identifying and protecting this sensitive marine breeding ground that is our Gulf?
It is incomprehensible to me that at a point in history when scientists, from all over the world, are warning us to ease up on fossil fuels, to give Mother Nature a chance to heal, that in NL, NS and all of Canada, we are full throttle ahead with fossil fuel development.
What right does our generation have to suck every last drop of fossil fuels out of this earth? These precious nonrenewable fuels may well be needed by future generations.
And to Mr. Harper’s government who called climate change protesters ‘extremists’ in the House of Commons, let me assure you, the extremists are those in denial of climate change, wilfully blinded by greed.
Mother Nature doesn’t give one hoot whether or not you believe in climate change. She will rebalance this earth from the rapacious ‘excesses’ of the industrial revolution. Mother Nature will have the final word on this battle.
Mary Gorman of Merigomish, N.S., is a writer and unwaged activist, and is a co-founder of the Save Our Seas and Shores Coalition.
Mary Gorman
July 19, 2011
This blog post first appeared as a Commentary in the Guardian PEI.
Protecting our gulf for future generations
The Tar Sands is not our only ecological struggle in Canada. A coalition of environmentalists, First Nations, inshore fishers, scientists, tourism operators, artists, teachers and municipalities from the Maritimes and Quebec are uniting to fight a preventive battle – to protect the Gulf of St. Lawrence from offshore oil development.
A company has applied to drill an exploratory well in ‘Old Harry’, located in the Laurentian Channel, which is the main artery in and out of our Gulf for over 2,000 marine species who spawn, nurse and migrate year around. Dr. David Suzuki calls it “one of the most precious ecosystems on our planet”. It is divinely beautiful.
The offshore oil industry likes to talk about co-existence and mitigation. But how can there be co-existence if spawning, nursery and migratory areas are up for grabs? The science on these 2,000 marine species is so limited, mitigation becomes just another ‘spin’ word. How does one mitigate the unknown?
Our Gulf is six times smaller than the Gulf of Mexico. The magnitude of last year’s BP spill would have covered completely the coastlines of half the provinces in the country. With counterclockwise currents, it only empties into the Atlantic once a year. It is one of the windiest regions in North America with winter ice cover. (How do you clean up spills under ice?)
Canada’s offshore regulatory structure is a disaster waiting to happen. Run by unelected, oil friendly provincial offshore boards, there are five different jurisdictional boundaries in our gulf, a single moving body of water. Trouble is, fish don’t recognize provincial boundaries; they swim though them. These boards allow the oil companies to monitor their own environmental requirements. Last fall, the Canada Newfoundland Board allowed seismic to proceed while endangered blue whale were migrating.
After the BP spill last year, I couldn’t sleep for a week. I felt a connection with people all over the world who were grieving, as I was, over how shamefully we have protected the essentials of life – air, water, soil and food – for those to come. For 50 years, our oceans have been one big dumping ground of industrial effluent globally. Our oceans are more acidic now. We are disrupting the fragile ecological balance between our oceans and atmosphere that create the oxygen levels that sustain life on earth. The BP spill didn’t help. Nor is the nuclear fallout in the Japan Sea.
Is it worth risking multi-billion dollar renewable fishery and tourism industries in Acadian, Gaelic, Mi’kmaq and Maliseet coastal communities, who have historic precedence in these waters that have sustained us for centuries?
Do we want the Gulf of St. Lawrence to become the next Gulf of Mexico?
Please, email Canada’s Environment Minister Peter Kent at kent.p@parl.gc.ca and demand a moratorium on offshore oil and gas development in Canada’s Gulf of St. Lawrence. The endangered blue whale will thank you. So will your grandchildren.
Mary Gorman of Merigomish, N.S., is a writer and unwaged activist, and co-founder of the Save Our Seas and Shores Coalition.
By Irene Novaczek
Save Our Seas and Shores Coalition
A small group of Prince Edward Islanders, ventured to the Magdalene Islands to join other concerned citizens at a forum to explore the costs and benefits of drilling a deep oil well, in the area dubbed “Old Harry”, in the Laurentian Trench between the Maggies and western Nfld. Corridor Resources owns the exploration permit and they want to proceed through a screening level environmental assessment and drill as soon as possible (2012 – 2014). After hearing of the risks and meager to non-existent benefits for rural coastal communities who will be affected by the pollution that accompanies such activities, the forum participants called for the full panel review of the project, as well as a strategic environmental assessment to consider the wider implications. However, even before going this route it is clear to many of us that the existing framework for decision-making is gravely flawed. Therefore, we first need a moratorium on all further exploration in the gulf, to give time for research, reflection and extensive public consultation leading to the reform of the petroleum board and environmental assessment systems.
[Check out the link to the forum to view various presentations given by scientists, oil industry etc.]
Small boat harbour, Magdalene Islands (Credit: Irene Novaczek) 
Heading into the village of Old Harry – the nearest Magdalene landfall to the proposed oil field. (Credit: Irene Novaczek) 
Old Harry Beach (Credit: Irene Novaczek)
View from the youth hostel (Credit: Irene Novaczek) 
Supporters arriving to demonstrate outside forum. Nice and noisy! (Credit: Irene Novaczek) 
Random notes to self (Credit: Irene Novaczek)
Lots of media covering the event, including independent media. (Credit: Irene Novaczek) 
Line-ups at the mike clearly showed the depth of concern and by times, anger and disgust in the room. Here are folk lined up for the 10 minute question period with Corridor, after listening politely to their 50 minutes of “how to drill an oil well”, promises and reassurances… Perhaps one third of those who immediately sprang to the mike managed to get a question answered. (Credit: Irene Novaczek) 
Fishing coop (Credit: Irene Novaczek)
From the perspective of bureaucrats in St Johns and Ottawa, our inshore fleets look mighty small and insignificant. But they are in fact the basis for coastal cultures, regional cuisines and tourism, among other values. (Credit: Irene Novaczek) 
Marilyn Clark was born in Old Harry. The only reason anyone outside of Nfld now knows about plans to drill in the Gulf is that she’s a student at Memorial and her eye was drawn to the press release about the project because they used the name of her village as the name of the oil field. (Credit: Irene Novaczek) 
Crab pots – lots of crab in the Old harry prospect area (Credit: Irene Novaczek)
Just say no to Old Harry development
By MARY GORMAN, Freelance Montreal Gazette
July 27, 2010
I could barely read “Boundary feuds thwarting attempts to drill promising prospects in the St. Lawrence” (Gazette, July 20). Surreal, it referred to the huge stakes involved in the “29-km long field of undersea hydrocarbons” as if “Old Harry” is all that exists in our precious Gulf of St. Lawrence. No mention of the 50,000 jobs created annually by the Gulf’s multibillion-dollar fishery and tourism industries. Or the economic, ecological, and social impact this deepwater well could pose. It takes only one blown well, as we know from the Gulf of Mexico disaster. No mention of spawning, nursery, and migratory areas for lobster, herring, snow crab, mackerel, whales, and dolphins, to name a few. Fragile Atlantic salmon, cod, and wolfish, fin whale and humpback whale are in trouble. The right whale, bluefin tuna, piping plover, and leatherback turtle are endangered. Time and again, offshore oil industry giants have proven they cannot prevent, stop, or clean up spills before damage occurs for decades, if not centuries. Twenty years later, only four per cent of the oil spilled from the Exxon Valdez has been recovered. For 40 years, scientists have been calling for a moratorium on exploration and drilling in the Gulf of St. Lawrence. In 1973, a McGill University professor called for a ban, describing it as “the most productive marine region in Canada that should never be placed in harm’s way.” Because of the counterclockwise circulatory currents, he said, oil and gas contamination would be widespread along the Gulf shorelines of all five east coast provinces. Ten years ago, after exploration leases were issued along Cape Breton’s shoreline by Nova Scotia’s petroleum board, scientists from the Department of Fisheries and Oceans referred to the Gulf’s semi-landlocked nature and winter ice cover (How do you clean up spills under ice?) stating, “This is a biologically diverse area where sensitive life stages of marine organisms are present throughout the year.” Meaning, there is no safe time to proceed with seismic blasting. As well, the Standing Committee of Fisheries and Oceans and the Fisheries Resource Conservation Council called for a moratorium. At a public review about the Cape Breton leases, even the Canadian Association of Petroleum Producers testified its industry wants sensitive marine areas identified and placed out of bounds. So how can it be, a decade later, we’re back on this wretched road again? Where ordinary citizens have to step up to fill the void left by oblivious federal and provincial politicians? Tourism ministers are asleep at the switch. Only one environment minister, P.E.I.’s Richard Brown, has called for a Summit on Offshore Oil and Gas, after visiting Louisiana. The hypocrisy is that, under Canada’s Oceans Act, inshore fishermen have been under precautionary quotas for 20 years. Yet when it comes to oil and gas, the DFO and Environment Canada have signed off on their legislated mandates to protect marine habitat to petroleum boards that allow the oil industry to monitor their environmental requirements. This is eerily similar to the lack of oversight that caused the BP ecological nightmare. Who made the decision to place the protection of marine habitat in the hands of the petroleum industry? Rather than embracing renewable energy, our governments have betrayed the public interest by pandering to the offshore petroleum industry. They are risking the survival of historic coastal communities, ancestral Gaelic, Acadian, and First Nation fishing grounds and the oceans that sustain life on Earth. The fish that have been the source of livelihoods for centuries (and will continue for future generations if we stop this disrespect) don’t recognize provincial boundaries. They swim through them.
The solution to the jurisdictional bickering over who gets Old Harry is simple: No one should.
Mary Gorman is a Nova Scotia writer and activist, and a founding member of the Save Our Seas and Shores Coalition.