Newfoundland Orphan Basin Exploration Drilling Project

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Attachment NunatuKavut Community Council comments - Orphan Basin - Draft EA Report

  • Newfoundland Orphan Basin Exploration Drilling Project
  • Author: Administrator on behalf of NunatuKavut Community Council
  • Reference number: 43
  • Submitted: 2019-12-11
  • Project phase: Environmental Assessment Report
  • Participation notice: Public Notice - Public Comments Invited on the Draft Environmental Assessment Report
  • Dear IAAC staff,   Please accept the attached comments sent on behalf of the NunatuKavut Community Council.
  • Attachment included
  • Comments on the DRAFT ENVIRONMENTAL ASSESSMENT REPORT ON THE NEWFOUNDLAND ORPHAN BASIN EXPLORATION DRILLING PROJECT December 2019 By the NunatuKavut Community Council 200 Kelland Drive, PO Box 460, Stn. C Happy Valley-Goose Bay, NL A0P1C0 http://www.nunatukavut.ca http://www.nunatukavut.ca/ 1 INTRODUCTION The NunatuKavut Community Council (“NCC”) is pleased to present its comments on both the Draft Environmental Assessment Report (“Draft EA Report”) and the Potential Conditions under CEAA 2012 document (“Potential Conditions document”) prepared by IAAC for the Newfoundland Orphan Basin Exploration Drilling Project (“Project”). NunatuKavut means "Our Ancient Land." It is the territory of the Inuit of NunatuKavut, the Inuit residing primarily in southern and central Labrador. Our people lived in Labrador long before Europeans set foot on North American soil. As it was in times of old, and still today, we are deeply connected to the land, sea and ice that make up NunatuKavut, our home. Today, our people continue to hunt and fish to harvest country food that is important for health and well-being and which connects us to our culture and traditions of the past. Salmon, turrs (Common and Thick-billed murres) and eider ducks (Common eiders) are among the key species that we harvest for these purposes, and which may well be affected by offshore exploratory drilling in the Project area. Additionally, and as is described below, NCC’s communal commercial fishery, which harvests in the Project area, plays a central role in the life and economy of NunatuKavut communities. NCC serves as the representative governing body for more than ...

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Attachment Newfoundland Orphan Basin Exploration Drilling Project - Invitation to Comment - KMKNO

  • Newfoundland Orphan Basin Exploration Drilling Project
  • Author: Administrator on behalf of Kwilmu'kw Maw-klusuaqn Negotiation Office (KMKNO)
  • Reference number: 38
  • Submitted: 2019-12-10
  • Project phase: Environmental Assessment Report
  • Participation notice: Public Notice - Public Comments Invited on the Draft Environmental Assessment Report
  • Please see attached a letter and a review for the Draft Environmental Assessment Report and potential conditions of the Newfoundland Orphan Basin Exploration Drilling Project.  
  • Attachment included
  • Page 1 of 2 December 7, 2019 Kathryn MacCarthy Project Manager – Atlantic Regional Office Impact Assessment Agency of Canada 1801 Hollis Street, Suite 200 Halifax, NS B3J 3N4 Fax: 902-426-6550 Kathryn.MacCarthy@canada.ca Re: Review of the Draft Environmental Assessment Report and Potential Conditions for the Newfoundland Orphan Basin Exploration Drilling Project Ms. MacCarthy, KMKNO has reviewed the Draft Environmental Assessment Report and Potential Conditions for the Newfoundland Orphan Basin Exploration Drilling Project. I wish to provide you with our comments, concerns and recommendations. KMKNO has contracted AECOM to conduct a review of the draft EA report and potential conditions and we have submitted the report to the Impact Assessment Agency of Canada (IAAC). The Mi’kmaq are the holders of constitutionally protected Aboriginal and treaty rights, which include the Aboriginal right to fish for food and the treaty right to fish for a moderate livelihood. Any impacts to fish and fish habitat are impacts to Mi’kmaq rights. Therefore, it is our expectation the Mi’kmaq will be compensated for any infringement on fishing rights. We wish to reiterate our concern that this exploration project, as well as the other concurrent offshore oil and gas developments in Newfoundland, may impact both Atlantic salmon and American eel. The timing, location, and design of the project activities will be important to reduce potential impact to migrating fish as well as those overwintering. We have already provided IAAC with a copy of the UINR report on Atlantic salmon that indicates drilling activities between the months of January to August pose a greater impact Atlantic ...

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Attachment Comments on Draft Environmental Assessment Report and Potential Federal Environmental Assessment Conditions for the Newfoundland Orphan Basin Exploration Drilling Project

  • Newfoundland Orphan Basin Exploration Drilling Project
  • Author: Administrator on behalf of Nunatsiavut Government
  • Reference number: 42
  • Submitted: 2019-12-10
  • Project phase: Environmental Assessment Report
  • Participation notice: Public Notice - Public Comments Invited on the Draft Environmental Assessment Report
  • Please accept Nunatsiavut Governments comments on Draft Environmental Assessment Report and Potential Federal Environmental Assessment Conditions for the Newfoundland Orphan Basin Exploration Drilling Project.
  • Attachment included
  • Kathryn MacCarthy Project Manager, Atlantic Region Impact Assessment Agency of Canada 200-1801 Hollis Street Halifax, Nova Scotia B3J 3N4 Telephone: 902-426-0564 Email: CEAA.OrphanBasin-BassinOrphan.ACEE@ceaa-acee.gc.ca December 10, 2019 Subject: Comments on Draft Environmental Assessment Report and Potential Federal Environmental Assessment Conditions for the Newfoundland Orphan Basin Exploration Drilling Project Dear Ms. MacCarthy, This letter is a response to the request for comments on the Draft Environmental Assessment Report and Potential Federal Environmental Assessment Conditions for the Newfoundland Orphan Basin Exploration Drilling Project submitted by BP. The Nunatsiavut Government previously provided comments on this project description. The comments centered around the potential impacts of the project on three Nunatsiavut commercial fishing enterprises (Federal Licenses) in NAFO areas 2GHJ3KL and potential impacts to subsistence/commercial species including cod, and the populations of SARA listed species (including the Atlantic Blue whale and North Atlantic Right Whale) that may migrate through any potentially impacted area within the Marine Zone identified in the Labrador Inuit Land Claim Agreement. The Proposed Conditions suggest details of a Fisheries Communication Plan that the Nunatsiavut Government is in agreement with. The Nunatsiavut Government would like to be included in the Fisheries Communication Plan. The Nunatsiavut Government also raised concerns around impacts of an underwater blowout and notes that modelling of a blowout was included in the EIS. The NG’s concerns centered around impacts to seasonal or ...

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Attachment Response Letter

  • Newfoundland Orphan Basin Exploration Drilling Project
  • Author: Administrator on behalf of The Mi'gmawei Mawiomi Secretariat (MMS)
  • Reference number: 40
  • Submitted: 2019-12-09
  • Project phase: Environmental Assessment Report
  • Participation notice: Public Notice - Public Comments Invited on the Draft Environmental Assessment Report
  • Please find attached our response letter regarding the draft environmental assessment for the Orphan Basin project.  
  • Attachment included
  • 1/2 VIA EMAIL November 29, 2019 Our File No: 200-0031 Impact Assessment Agency of Canada 200-1801 Hollis Street Halifax, Nova Scotia B3J 3N4 RE: Orphan Basin Project Dear Robin Boychuk, I write in response to your correspondence dated November 6th, 2019. The Mi’gmawei Mawiomi Secretariat (MMS) has reviewed the Draft Environmental Assessment Report (the “EAR”) and has concerns regarding how the project may affect traditional aboriginal rights & practices, aboriginal commercial fishing, and the Atlantic Salmon population and their habitat. Further, the MMS would like to reiterate that our position regarding offshore exploration and drilling, is that any potential benefits to not outweigh the potential environmental impacts, therefore we do not support such activities. The EAR does identify possible negative effects on fish habitat, marine wildlife, migratory birds, and interference with commercial fishing, due to routine operations; however, the total extent, long term, and cumulative effects of which are unknown. Additionally, accidents and malfunctions could occur during exploration and drilling causing further adverse environmental damages. While the probability of accidents or malfunctions may be low, when either occur the results are catastrophic and immeasurable; for example, Husky Energy’s SeaRose spill lead to a 250,000 litre spill the complete effects of which are not yet known. The EAR does not consider aboriginal and treaty rights, however, it does consider the Atlantic Salmon population, we agree that newer studies must be completed to identify data-gaps, specifically with regards to Salmon, as any negative ...

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Attachment Mekap'sk Mi'kmaq Band Comments: Orphan Basin EA Report & Conditions

  • Newfoundland Orphan Basin Exploration Drilling Project
  • Author: Administrator on behalf of Northern Peninsula (Mekap'sk) Mekap'sk Mi'kmaq Band's
  • Reference number: 32
  • Submitted: 2019-12-06
  • Project phase: Environmental Assessment Report
  • Participation notice: Public Notice - Public Comments Invited on the Draft Environmental Assessment Report
  • To the Impact Assessment Agency of Canada: Please find attached, the Northern Peninsula (Mekap’sk) Mekap’sk Mi’kmaq Band’s Comments on the Draft Environmental Assessment Report and Potential Conditions for the Proposed Newfoundland Orphan Basin Exploration Drilling Project. Thank you, Rachel Speiran
  • Attachment included
  • December 6, 2019 Attention: Kathryn MacCarthy, Impact Assessment Agency of Canada, IAAC.OrphanBasin- BassinOrphan.AEIC@canada.ca Mike Atkinson, Impact Assessment Agency of Canada, mike.atkinson@canada.ca Anita Perry, BP Canada, anita.perry@bp.com Heather Giddens, BP Canada, heather.giddens@bp.com Jay Hartling, BP Canada, jay.hartling@gmail.com Re: Mekap’sk Mi’kmaq Band Comments on the Draft Environmental Assessment Report and Potential Conditions for the Proposed Newfoundland Orphan Basin Exploration Drilling Project Preamble The Impact Assessment Agency of Canada (the Agency; IAAC; formerly IAAC) has initiated a public comment period on the Draft Environmental Assessment Report (the EA Report) and Potential Conditions for the BP Canada Energy Group ULC (“the Proponent) Newfoundland Orphan Basin Exploration Drilling Project (“the Project”). The Northern Peninsula (Mekap’sk) Mi’kmaq Band is committed to representing the approximately 1,200 Mi’kmaq people of the Northern Peninsula with a united voice and to have the rights and interests of our people represented fairly in any process where the Crown considers a decision that stands to affecting our rights and our way of life. Mekap’sk Mi’kmaq Band Aboriginal Rights and Interests Canada, as the Crown, has a legal obligation to consult with Aboriginal peoples where it contemplates decisions or actions that may adversely impact asserted or established Aboriginal or treaty rights. The Mekap’sk Mi’kmaq Band asserts Aboriginal and inherent rights which our peoples have practiced and enjoyed since before European contact. Mekap’sk Mi’kmaq Band rights include, but are not limited to, rights to the land and waters, rights to ...

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Attachment Rapport provisoire d'évaluation environnementale de l'évaluation environnementale du projet de forage exploratoire dans le bassin Orphan de Terre-Neuve - BP Canada Energy Group ULC - Réponse et commentaires des Innu de Ekuanitshit ; N/d 7550-036

  • Newfoundland Orphan Basin Exploration Drilling Project
  • Author: Administrator on behalf of Conseil des Innus d'Ekuanitshit
  • Reference number: 35
  • Submitted: 2019-12-06
  • Project phase: Environmental Assessment Report
  • Participation notice: Public Notice - Public Comments Invited on the Draft Environmental Assessment Report
  • Veuillez trouver ci-joint une lettre de ce jour avec sa pièce jointe, concernant le sujet mentionné en rubrique, que nous vous transmettons au nom de notre client le Conseil des Innus d’Ekuanitshit, représenté par son Chef, M. Jean-Charles Piétacho.
  • Attachment included
  • Conseil des Innu de Ekuanitshit 35, rue Manitou Ekuanitshit (Québec) G0G 1V0 Tél. : (418) 949-2234 fax : (418) 949-2085 Le 6 décembre 2019 PAR COURRIEL : iaac.orphanbasin-bassinorphan.aeic@canada.ca Projet de forage exploratoire dans le bassin Orphan de Terre-Neuve Agence d’évaluation d’impact du Canada 200-1801 rue Hollis Halifax, Nouvelle-Écosse B3J 3N4 Objet : Rapport provisoire d’évaluation environnementale et conditions fédérales potentielles de l’évaluation environnementale du projet de forage exploratoire dans le bassin Orphan de Terre-Neuve – BP Canada Energy Group ULC Réponse et commentaires des Innu de Ekuanitshit Madame MacCarthy, La présente fait suite à votre courriel du 6 novembre 2019, par lequel vous nous demandiez de fournir nos commentaires à l’égard du Rapport provisoire et des conditions fédérales potentielles mentionnés en rubrique, et ce, d’ici le 6 décembre 2019. Nous soulignons que nos ressources sont limitées et que le grand nombre de demandes de commentaires provenant de votre Agence au sujet des divers projets de forage au large de Terre-Neuve qui sont en cours d’évaluation environnementale, ainsi qu’au sujet de l’évaluation régionale du forage exploratoire extracôtier pétrolier et gazier à l'est de Terre-Neuve-et-Labrador, combiné aux courts délais accordés pour répondre à chacune de vos requêtes, rend notre participation au processus de consultation pour le moins difficile. Nous avons pris connaissance des documents pertinents et vous faisons parvenir par la présente nos commentaires. Dans la paix et l’amitié, ________________________ Jean-Charles Piétacho Chef des Innu de Ekuanitshit <Original signé par> 1 Soumissions des Innu de ...

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Attachment BP Orphan Basin Draft Environmental Assessment Report and Potential Conditions Technical Review

  • Newfoundland Orphan Basin Exploration Drilling Project
  • Author: Administrator on behalf of Marcy Cloud
  • Reference number: 48
  • Submitted: 2019-12-06
  • Project phase: Environmental Assessment Decision
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please find attached Mi'gmawe'l Tplu'taqnn Inc.'s Cover Letter and Technical Review of the Draft Environmental Assessment Report and Potential Conditions for BP's Orphan Basin Exploration Drilling Project.
  • Attachment included
  • s h a r e d v a l u e s o l u t i o n s . c o m BP Canada Energy Group ULC Newfoundland Orphan Basin Exploration Drilling Project Review of Draft Environmental Assessment and Draft Potential Conditions Prepared for: Mi’gmawe’l Tplu’taqnn Incorporated Rachel Speiran, M.A. Project Director (226) 706-8888 ext. 120 rachel.speiran@sharedvaluesolutions.com 62 Baker Street Guelph, ON, Canada N1H 4G1 Mi’gmawe’l Tplu’taqnn Incorporated Chief George Ginnish Chief Rebecca Knockwood 38 Micmac Road Eel Ground, NB E1V 4A7 December 2, 2019 Dear Chief George Ginnish and Chief Rebecca Knockwood: It is our pleasure to provide you with the review of the Draft Environmental Assessment Report for the BP Canada Energy Group ULC Newfoundland Orphan Basin Exploration Drilling Project. This review was completed by Rachel Speiran, MA; Allie Mayberry, BSc, MA, Levi Snook, BSc, and Meaghan Langille, BSc; EPt, of Shared Value Solutions Ltd. We look forward to continuing to serve you in consultation and lands and resources protection matters. Please do not hesitate to get in touch with us if you have any questions or concerns with the enclosed report. With best regards, Rachel Speiran Senior Community Development Consultant Project Director Regulatory, Negotiations and Regional Development Practice Area Team Lead Shared Value Solutions Ltd. <Original signed by> MI’GMAWE’L TPLU’TAQNN INCORPORATED – REVIEW OF BP CANADA ENERGY ULC NEWFOUNDLAND ORPHAN BASIN EXPLORATION DRILLING PROJECT – DRAFT ENVIRONMENTAL ASSESSMENT REPORT | i Contents 1.0 Review Objectives ...
  • Attachment included
  • Mi’gmawe’l Tplu’taqnn Incorporated 40 Micmac Road Phone: 506.627.4696 Eel Ground, NB E1V 4B1 Fax: 506.627.4605 December 6, 2019 VIAEMAIL: iaac.orphanbasin-bassinorphan.aeic@canada.ca Canadian Environmental Assessment Agency 200 – 1801 Hollis Street Halifax NS B3J 3N4 Dear Sir/Madam, Re: Technical Review & Assessment of the Draft Environmental Assessment Report and potential EA conditions for BP’s Orphan Basin Exploration Drilling Project On behalf of Mi’gmawe’l Tplu’taqnn, we are responding to the Draft Environmental Assessment Report for the above project, dated September 2019. Mi’gmawe’l Tplu’taqnn’s primary concern remains how the projects impact migratory species that are of great cultural significance to the Mi’gmaq, including salmon, swordfish, Bluefin tuna, Atlantic right whales, and migratory birds. Please find enclosed a report from Shared Value Solutions that we are submitting on behalf of Mi’gmawe’l Tplu’taqnn. Based on the report, we highlight the following recommendations in particular: 1) The Agency and/or the Proponents should engage MTI and Anqotum Fisheries Resource Centre in designing and conducting a focused Atlantic Salmon research project that seeks to fill data gaps related to Atlantic Salmon use and existence in the Project Area. This should happen before any project approvals and will require dedicated proponent funding. 2) Establish a forum and process where Mi’gmawe’l Tplu’taqnn can meet with BP Canada whereby issues and follow-up program decision making regarding the Projects can be brought forward, discussed, and addressed throughout the life of the Projects. 3) The Proponents ...

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Attachment Public Comment Period/Période de commentaire public - Newfoundland Orphan Basin Exploration Drilling Project

  • Newfoundland Orphan Basin Exploration Drilling Project
  • Author: Administrator on behalf of Fish, Food and Allied Workers' Union (FFAW-Unifor)
  • Reference number: 36
  • Submitted: 2019-12-06
  • Project phase: Environmental Assessment Report
  • Participation notice: Public Notice - Public Comments Invited on the Draft Environmental Assessment Report
  • Please find attached comments from FFAW-Unifor on the draft EA for the Orphan Basin drilling project.
  • Attachment included
  • 1 Friday, December 6, 2019 Newfoundland Orphan Basin Exploration Drilling Project Impact Assessment Agency of Canada 200 - 1801 Hollis Street Halifax, Nova Scotia B3J 3N4 Re: Newfoundland Orphan Basin Exploration Drilling Project – Public Comments on Draft EA Report and Potential Conditions To Whom It May Concern, Please accept the Fish, Food and Allied Workers’ Union (FFAW-Unifor) comments on the BP Newfoundland Orphan Basin Exploration Drilling Project’s Draft Environmental Assessment Report and Potential Conditions in relation to the project. FFAW-Unifor submitted comments on the Draft EIS documentation last year. FFAW-Unifor represents approximately 15,000 working women and men throughout Newfoundland and Labrador, most of whom are employed in the fishing industry. The inshore fishery is prosecuted by small boats up to 45 feet in length while 45 to 90 foot vessels fish out to, or just beyond, the 200 mile limit. The fishing vessels in the inshore fleet are owner-operated enterprises. Most targeted species have set Total Allowable Catches (TACs) while trip limits and enterprise caps may also be designated depending on season and/or area. As we have commented previously, activities associated with the exploration, development and production of offshore oil and gas are very concerning to fish harvesters who see the cumulative effects of oil and gas activities on the water over time. Three of the four areas that are being proposed for exploratory drilling in this project are within the Northeast Slope Marine Refuge. Harvesters are not allowed to fish in this refuge, but oil and gas exploration continues. It remains our position that ...

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Attachment Miawpukek FN Comments on BP EA Report and Conditions (CEAR 80147)

  • Newfoundland Orphan Basin Exploration Drilling Project
  • Author: Administrator on behalf of Miawpukek First Nation
  • Reference number: 47
  • Submitted: 2019-12-06
  • Project phase: Environmental Assessment Decision
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached comments on the Environmental Assessment Report and potential Conditions for the BP Orphan Basin Exploration Project (CEAR 80147).
  • Attachment included
  • Newfoundland Orphan Basin Exploration Drilling Project Comments on the Draft Environmental Assessment Report and Draft Conditions of Approval Prepared by Miawpukek First Nation and Shared Value Solutions December 6, 2019 NEWFOUNDLAND ORPHAN BASIN EXPLORATION DRILLING | i Contents 1.0 Introduction ...................................................................................................................................... 1 2.0 Miawpukek First Nation .................................................................................................................... 2 2.1 Historic Overview .......................................................................................................................... 2 2.2 Rights and Interests ...................................................................................................................... 4 3.0 Comments on the Project, EA and Potential Conditions .................................................................. 5 4.0 Conclusion ....................................................................................................................................... 12 5.0 References ...................................................................................................................................... 17 NEWFOUNDLAND ORPHAN BASIN EXPLORATION DRILLING | 1 1.0 Introduction BP Canada Energy Group ULC (the Proponent) is proposing to conduct exploratory offshore drilling in the Orphan Basin (the Project). Drilling of up to 20 offshore wells would take place between 2021 and 2026 in areas covered by exploration licences (EL) 1145, 1146, 1148, and 1149. The ELs have ...

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Attachment Noia Submission

  • Newfoundland Orphan Basin Exploration Drilling Project
  • Author: Administrator on behalf of Noia (Newfoundland & Labrador Oil & Gas Industries Association)
  • Reference number: 33
  • Submitted: 2019-12-06
  • Project phase: Environmental Assessment Report
  • Participation notice: Public Notice - Public Comments Invited on the Draft Environmental Assessment Report
  • Good Afternoon: Please find attached Noia’s submission regarding the Draft Environmental Assessment Report for the Newfoundland Orphan Basin Exploration Drilling Project (Reference # 80147). Thank you, Ken
  • Attachment included
  • Newfoundland & Labrador Oil & Gas Industries Association Box 44, Suite 606, Atlantic Place, 215 Water Street, St. John’s, NL, Canada A1C 6C9 T: 709-758-6610 F: 709-758-6611 www.noia.ca @NoiaNL Noia Submission to the Impact Assessment Agency Re: Draft Environmental Assessment Report for the Newfoundland Orphan Basin Exploration Drilling Project (Reference # 80147) December 2019 The Newfoundland and Labrador Oil and Gas Industries Association (Noia) was founded in 1977 to represent the supply and service sector of the offshore oil and gas industry. Today Noia represents over 500 member organizations worldwide which are involved in, or benefit from, the oil and gas industry of Newfoundland and Labrador. Noia members are a diverse representation of businesses that range from offshore supply boats and helicopters to health and safety equipment and training, engineering solutions and fabricators to local bakeries. Noia is pleased to have the opportunity to comment on the draft environmental assessment report for the proposed BP Canada Energy Group ULC Newfoundland Exploration Drilling Project in the Orphan Basin in exploration licence areas 1145, 1146, 1148 and 1149. The project may include up to 20 exploration wells drilled as part of the program which could occur between 2021 to 2026. Noia has previously commented on the Environmental Impact Statement submission of BP Canada and supported the project. Value of the Newfoundland and Labrador Offshore The offshore oil and gas industry is one of tremendous importance to Newfoundland and Labrador. To quantify that importance, Noia recently engaged Mr. David Campbell of Jupia Consultants to undertake a study on the value of ...

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Attachment BP Comments on Draft EA Report and Proposed Conditions

  • Newfoundland Orphan Basin Exploration Drilling Project
  • Author: Administrator on behalf of BP Canada Energy Group ULC
  • Reference number: 31
  • Submitted: 2019-12-02
  • Project phase: Environmental Assessment Report
  • Participation notice: Public Notice - Public Comments Invited on the Draft Environmental Assessment Report
  • Thanks very much for the opportunity to comment on the draft EA Report and proposed conditions for the NL Orphan Basin Exploration Drilling Project. Please see the attached submission from BP Canada Energy Group ULC and let us know if you have any questions or concerns. Thanks Heather Heather Giddens Environmental Impact Advisor BP Canada Energy Group ULC (587) 880-0781 | Email: heather.giddens@bp.com (mailto:heather.giddens@bp.com)
  • Attachment included
  • BP Canada Energy Group ULC 240-4th Avenue SW Calgary, AB T2P 4H4 Canada Phone: (403) 233-1509 Email: john.drinkwater@bp.com December 2, 2019 Kathryn MacCarthy Project Manager, Atlantic Regional Office Impact Assessment Agency of Canada 200-1801 Hollis Street Halifax, NS B3J 3N4 Dear Ms. MacCarthy, As the proponent for the Newfoundland Orphan Basin Exploration Drilling Program, BP Canada Energy Group ULC (BP) appreciates the opportunity to review and comment on the Newfoundland Orphan Basin Exploration Drilling Project Draft Environmental Assessment (EA) Report and associated Potential Conditions under the Canadian Environmental Assessment Act, 2012. In general, the draft Environmental Assessment Report is an accurate representation of the Environmental Impact Statement (EIS) and the EA review process to date. However, we would like to take this opportunity to propose some corrections and clarifications on the report as presented in Table 1. Table 1 Proposed Edits to Draft EA Report Draft EA Report Reference Draft EA Report Reference Text BP Comment/Recommended Revision 3 Alternative Means of Carrying Out the Project Drilling Rig Selection (p. 14) Floating semi-submersible drill rigs and drill rigs were both considered to be technically and economically feasible options and would have comparable environmental effects. “Floating semi-submersible drill rigs and drill rigs ships were both considered to be technically and economically feasible options and would have comparable environmental effects.” 6.1.1 Predicted Effect Change in Risk of Mortality or Physical Injury (p. 28) Deposition thickness above the burial depth threshold may extend up to 128 metres from ...

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