Comments on the CEAA Regional Assessment of Offshore Oil and Gas Exploratory Drilling East of Newfoundland and Labrador 80156

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Comments on the CEAA Regional Assessment of Offshore Oil and Gas Exploratory Drilling East of Newfoundland and Labrador 80156

The Regional Assessment Committee has assessed the environmental implications and possible consequences of further exploratory drilling in the C-NLOPB designated study area east of Newfoundland and Labrador.  The stated objective  was “to facilitate a more effective and efficient assessment process for exploratory drilling projects in the defined offshore Study Area, while also ensuring that the highest levels of environmental protection continued to be applied and maintained.“  

The Committee aimed to include in its consultations “everyone with an interest in offshore oil and gas exploration in the Study Area and its potential effects.” The Committee has made considerable effort to “meaningfully engage” with Indigenous communities toward their participation in the Regional Assessment process and ongoing reviews, recognizing that they may have a different but valid perspective on the offshore environment and its management.

Operating with limited time, (and it seems with little support from government scientific and technical staff), they have produced a draft regional assessment that considers the potential risks, impacts and necessary mitigation associated with exploratory drilling in the Newfoundland and Labrador offshore.

Following are my observations and recommendations with respect to draft assessment.

  1. No “green light” for drilling   The Regional Assessment should not be seen by government and industry as giving approval for multiple exploratory wells, now or in the foreseeable future. Project-specific assessments should still be carried out where there is uncertainty about risk
  1. Publicly accessible GIS decision-support system    The Committee has made use of a GIS contractor to facilitate management and analysis of spatial and textual information. The Committee sees the creation of a “publicly accessible” GIS decision-support system as an integral part of the regulatory system that is expected to follow from the Regional Assessment. A publicly accessible GIS decision-support system should be a requirement.
  1. Need for a Regional Oversight Committee    The Regional Assessment Committee indicates a need for an Oversight Committee to ensure “a continued, coordinated focus on the objectives...and continued public scrutiny of the evolving Regional Assessment process.” This process will require ”…firm commitments from other government agencies to provide ongoing support to the future updates to, and evolution and use of, the Regional Assessment.” Commitments to ongoing support from other government agencies and the establishment of the Regional Oversight Committee should precede approval of any projects under this  Regional Assessment.
  1. Protected Areas          The Committee found that there are a number of important defined “special areas” in the Study Area, including Marine Refuges that currently prohibit certain types of commercial fishing activities.   As yet there are no requirements for enhanced protective measures within these areas with respect to exploratory drilling activities.  Moreover, there is no recommendation that any part of the Study Area be excluded from exploratory drilling at this time.  Before any more exploratory drilling projects are considered, a panel of experts should be convened to review potential areas of special ecological importance in the Study Area and assess the need for their protection.
  1. Contribution to greenhouse gas emissions     Acknowledging that we are in a time of climate crisis and referencing Canada’s obligations under the 2015 Paris Agreement, the Committee has calculated greenhouse gas emissions (GHG) from an exploratory drilling scenario of 100 wells over 10-12 years and concluded, perhaps disingenuously, this would contribute to less than one-tenth of one percent of the federal 2030 emissions targets.  Recognizing that this does not account for the greater emissions that will result if oil production follows, the Committee refers the broader question of GHG emissions and associated climate change to “other, more appropriate venues”.  However, at the public policy level, it will be irresponsible to ignore the inevitably large “downstream” emissions that will occur if even a fraction of the over 37 billion barrels of oil and 130 trillion cubic feet of natural gas estimated  to lie in two of the basins in the Study Area are produced and consumed.  No further offshore oil and gas development should be considered without an informed public debate (public inquiry) on the regional, national and global consequences for climate heating and its impacts.
  1. Socio-economic outcomes      The Assessment observes that the socioeconomic benefits of the offshore petroleum industry have been “significant and long-term in nature.”. Yet, “ …there have also been concerns raised at times about the potential negative implications of increased affluence and other social outcomes for individuals, families and communities and their overall well-being” (Section 7.1.2). While the projections given indicate more well-paying employment to come in the industry, as well as “spin-offs”, one has to ask why now, when this industry  is approaching “maturity”, so many of our people do not have job security or a living wage, and, according to CBC NL reports, many are facing food insecurity. One industrial sector - certainly can’t provide for everyone in the province, but there must be a better way to share the benefits of the exploitation of our resources, particularly from what must ultimately be a “sunset” industry, as the planet warms.  Coupled with any government policy proposals to extend our offshore oil and gas development beyond the existing discoveries, there needs to be a full public debate on alternative futures that are sustainable and fair for all.

John D. Jacobs, PhD.

(Retired) Professor of Geography,

Memorial University of Newfoundland

20 February 2020


Submitted by
John Jacobs
Public Notice
Date Submitted
2020-02-20 - 9:08 AM
Date modified: