FFAW-Unifor public comments on draft Agreement of TOR

Please accept the Fish, Food and Allied Workers’ Union (FFAW-Unifor) comments regarding the Draft Agreement and Terms of Reference for the Regional Assessment of Offshore Wind Development (RAOWD) in Newfoundland and Labrador.?? 

We are pleased to see an emphasis on addressing challenges posed by climate change through sustainable economic development. While there is language reiterating the need for balance amongst ecological, economic, and social impacts due to increased activity in shared ocean spaces, the assessment process of new offshore wind developments must include strong considerations to its impact on the fishing industry. The inshore fishery in Newfoundland and Labrador (NL) contributes over $1 billion to the provincial economy annually from a renewable biological resource. Meaningful inclusion throughout this planning process will reduce the economic threats imposed on our fishing sector.? 

Offshore wind energy expansion has a direct impact on fish harvesters who will compete for space and hence be affected by new infrastructure. Co-location and coexistence of the commercial fishery and new offshore wind energy represents a major concern for fish harvesters.?? 

The installation of turbines and their placements along fishing routes will disrupt well established fishing areas. Harvesters will be forced to spend valuable time and fuel encroaching on the fishing grounds of other harvesters or venturing to remote areas with lower catch rates. Leases for and acquired by the energy industry cannot jeopardize the economic success of our fishery or our harvesters’ livelihood. Comprehensive temporal and spatial mitigation measures must be clearly communicated and properly implemented to maximize opportunities for mutually positive effects within our industries – this would include but not be limited to exclusion zones where no infrastructure would be put in place. 

We are cautiously optimistic about the established Advisory Groups and their role in the necessary informed decision-making processes. Nonetheless, at this stage it is unclear how significant or impactful the recommendations provided by these groups will ultimately be. Insights provided by fish harvesters about the shared ocean areas of interest serve as an invaluable resource throughout the planning process to mitigate risk and ensure sound implementation. Protection of biologically significant areas and habitats for key life-stages of commercially fished species that NL’s inshore fishery depend on is critical.  

The extent to which fish harvesters will be affected by potential offshore developments cannot be understated. Consequently, we expect our perspectives to take precedence in upcoming consultations. Fish harvesters must have an elevated position in these conversations to ensure the immediate and cumulative adverse effects we fear can be addressed. Inclusion of fish harvesters in consultations for the RAOWD demonstrates that the Impact Assessment Agency of Canada (IAAC) recognizes the importance of our industries to co-exist, and we look forward to continuing to engage membership.?Transparency in deliberations with respect to these recommendations is expected, to ensure meaningful contributions are made and collaborative consultations occur.? 

We recommend a neutral, inter-industry liaison be established to serve as a facilitator for effective communication and information exchange amongst ocean-user industries. A similar organization, One Ocean, has shown some success as an intermediary between our fishery and the offshore oil and gas industry that has facilitated understanding and awareness within the technical, environmental, and operational activities of each industry.? 

However, as we are still in the early stages of?RAOWD, there is a perception that the importance of the fishery in NL is not being considered as it should. There are three advisory groups, none of which are explicit consideration of the socio-economic importance of the industry, or how additional industrial infrastructure will negatively impact the fishing industry. Further, the applied science that?inshore fish harvesters bring from the sea and into consultative processes?presents a significant opportunity for contributing valuable local knowledge and expertise. Thereby?shaping a better?understanding of our oceans and promoting sustainability measures is necessary to ensure neither industry is over-exploiting natural resources.? 

It is important to note that Newfoundland and Labrador and Nova Scotia share Terms of Reference despite vast differences in seascapes and overall readiness for offshore wind developments. FFAW’s membership have expressed apprehensions about this decision and the implication it will have on the assessment process moving forward. The fisheries in NL and NS are managed very differently both provincially and federally, and have to be consulted differently and distinctly.? 

On behalf of FFAW-Unifor membership, our organization supports a continuous advisory program that allows for the consideration and incorporation of new and updated information in the event of adverse cumulative effects and unseen malfunctions. We anticipate full transparency in the mitigation plans for interactions with other ocean users that may occur and expect due diligence in providing monthly status reports that will be accessible to the public. ? 

We hope our industries can be mutually dependent on a shared ecosystem and look forward to the effective communication and engagement opportunities to come with the IAAC.? 

If you have any questions or comments please feel free to contact the undersigned. 

Best regards, 

Keith Sullivan 
President