Whale Research Collective Comments on the Regional Assessment Report for Offshore Wind Development in Nova Scotia

These comments are submitted on behalf of the Whale Research Collective (WRC). WRC is a Canadian non-profit organisation dedicated to marine mammal research and conservation using a science-based, collaborative approach. Our areas of expertise include bioacoustics, telemetry and aerial imagery, and population assessments based on photographic and genetic sampling of individuals. WRC’s biologists have extensive research experience working along the Atlantic Coast of Canada and in the Gulf of St. Lawrence.

As an organization committed to minimizing the carbon footprint of our field operations, we support the development of renewable energy in Nova Scotia. However, we recognize the necessity of establishing a thorough environmental baseline assessment prior to any development of this activity off Nova Scotia (NS). As stated in the regional assessment, the NS marine mammal community is quite different from those in European areas where offshore wind has a long history. There is little insight that can therefore be drawn from these areas regarding the potential effects of offshore wind operations on marine mammals. NS is much more similar to areas off the Northeast US where offshore wind projects are currently under development. However, these projects are too recent to draw any conclusions about their effects on marine mammals and NS-based projects warrant NS-focused baseline studies.

Detecting potential changes in marine mammal occurrence due to offshore wind is further complicated by the effects of climate change, which are likely to induce shifts in spatio-temporal distribution. One of the keys to circumvent these challenges is to conduct baseline studies with the sufficient duration to capture the (presumably increasing) natural variability in oceanographic conditions and associated responses by marine mammals. We suggest a minimum of three years, and preferably up to five, to provide a comprehensive understanding of marine mammals’ habitat use on the Scotian Shelf. With construction of any approved project not expected to begin before 2031, there is ample time to do things right.

It should be noted that systematic visual monitoring effort for marine mammals remains limited on the Scotian Shelf. While passive acoustic monitoring (PAM) has been conducted off Nova Scotia since the early 2010s, the effort has been biased towards the continental slope and information on marine mammal occurrence on the Scotian Shelf, where most offshore wind farms would be developed, remains limited in comparison. This is particularly true for the eastern part of the Scotian Shelf and the proposed lease areas which have drawn most interest from developers.

We would like to reiterate that the Scotian Shelf is used by several at-risk marine mammal species, most notably fin and blue whales. But precise information regarding their abundance and distribution is lacking and dedicated effort is needed to ensure offshore wind farms do not interfere with federal recovery objectives for these species and to design effective mitigation measures.

We strongly support section T1-6 in the regional assessment, specifically “the development of a multi-year plan to increase the knowledge of marine mammal behaviour and habitat use in the RA Study Area”. Although PAM can tell us when a species is present, it is difficult to assess the residency of individual whales without dedicated visual monitoring. This information is critical to evaluate the potential effects of offshore wind development. Indeed, the determination of persistent occurrence in an area based on PAM may originate from numerous individuals transiting through the area or a handful of animals with extended residency. Both scenarios have very different consequences for the individuals and populations involved.

We believe that dedicated vessel-based efforts to better understand species composition, abundance, distribution, and habitat use are critical for filling current knowledge gaps and supporting sustainable, responsible wind energy development in Nova Scotia. While PAM is invaluable in assessing species presence when aerial or boat-based surveys are not possible (e.g. nighttime, winter), non-vocalizing animals cannot be detected.  Baleen whales show pronounced seasonal variations in vocal behavior, with low calling rates in spring and summer when construction activities may be concentrated. We therefore strongly encourage any regulating agencies, be it the CNSOER or a Scotian Shelf Collaborative Research Initiative (SSCRI), to provide the funding needed to support research efforts required to properly assess offshore wind development in Nova Scotia.

WRC would appreciate the opportunity to provide input on the development of research objectives and the design of baseline studies and to contribute our expertise to make offshore wind in NS a model of marine planning and resource management.