Final Report and Recommendations are Insufficient

Dear Regional Assessment Committee,

I want to express that I have serious concerns about the Regional Assessment (RA) process, timelines, the final report, and its implications for our marine environment and known habitats set aside for biodiversity protection. Considering the complexity of this large Study Area, the trans-boundary concerns, and the potential to circumvent project-specific assessments for exploratory drilling, the RA process should have had at least the same timeline as strategic and site-specific assessments. There are numerous data deficiencies, omissions, and oversights in the report as discussed below. As such, this report must be considered incomplete and its proposed recommendations insufficient at addressing impacts to the natural environment.

The cumulative effects assessment largely consisted of an incomplete collection (“data dump”) of spatial data layers. The recommendation that the government assumes responsibility for offshore-related cumulative effects assessment, despite their mention in the Terms of Reference for the Committee and the Impact Assessment Act, is unacceptable. A thorough and complete assessment must be completed prior to the development (or exclusion) of any cumulative effects recommendations.

There is no recommendation for adequate protection of ecologically sensitive areas, such as Ecologically and Biologically Significant Areas, Fisheries Closure Areas, Marine Refuges, Sensitive Benthic Areas, and internationally-recognized Vulnerable Marine Ecosystems. Yet, the report states “the potential for future drilling activities to adversely affect the important and defining ecological features, processes and integrity of any marine or coastal locations that are designated as special areas, including their associated human use and value.” This is wholly unacceptable. The suggestion that exploratory drilling can take place in these sensitive areas undermines the conservation measures for which they were designated.

There is no recommendation on greenhouse gas emissions or climate change, despite the obvious implications for increased atmospheric emissions. The reason provided in the report is that “downstream emissions would occur only after oil is discovered.” This is false, as emissions occur throughout the entire production life cycle – including drilling, transport, and most supporting activities. Furthermore, any exploration is done with the intention of downstream activity, including extraction and combustion, and therefore, those significant impacts must also be considered. This is especially true when considering the regional scope of this report, not to mention the Government of Canada’s renewed commitment to mitigating climate change impacts and its goal of net-zero emissions by 2050.

As this is the first RA to be conducted in Canada, it is of special importance that this RA adequately addresses impacts to the natural environment. This RA offers an important opportunity to look at important issues related to cumulative environmental disturbances, marine protections, and climate change within their regional context. However, this has not been done and the final report is, therefore, inadequate for developing recommendations with far-reaching implications for offshore activity and marine environments. Furthermore, holding a public comment period during the COVID-19 global pandemic, even with a short-term extension, is highly objectionable.

The recent collapse in oil prices around the world has highlighted the vulnerabilities we face with dependence on petroleum development. There is an enormous cost to oil and gas exploration and production, from climate change mitigation and international relations to the future cleanup costs. This government has committed to curbing emissions and ending “inefficient” fossil fuel subsidies. The reality is that this industry continues to receive enormous subsidies whilst aggressively pursuing environmental deregulation.  With oil prices at record lows, layoffs, and billions cut from budgets, we cannot continue to create sweeping, long-term changes to environmental regulations at the request of industry associations. I urge the Minister to re-evaluate the regulations and policies that promote extracting hydrocarbons during a climate crisis.

The primary focus of an environmental assessment must be the environment. The rapid speed at which this RA process has been pursued suggests that the Committee has not given careful consideration for our marine environment and known habitats set aside for biodiversity protection in this study area. The final report was developed and submitted immediately after the last public comment period, suggesting that comments were not reviewed or addressed at all. The entire RA process seeks to fast-track offshore assessment without adequate consideration for the Impact Assessment Act, sensitive habitats and marine environments, or Canada’s commitments to the environment.

In conclusion, the Regional Assessment Final Report is incomplete and insufficient to inform regulatory decisions that have long-term implications for our marine environment and conservation measures.

Sincerely,

Nick White

St. John's NL