Lack of information, good process, and foresight

In general, there is neither appropriate and adequate information nor good process here to support a regulatory decision regarding project-specific exploratory drilling on behalf of the Minister. It is discouraging and short-sighted that this process has failed to consider the broader implications of exploratory drilling and presumed future oil and gas extraction in relation to Canada's climate goals and the climate crisis. While perhaps understandably beyond the scope of this assessment, the broad implications of this assessment for industry expansion in Newfoundland's offshore is important and concerning for reducing Canada's GHG contributions to the global carbon budget. It is also discouraging and concerning that this assessment has essentially failed to adequately consider cumulative effects on industrial activities, including and beyond oil and gas development. Poor choices regarding the management of oceans and ocean resources has been exacerbated by the poor abilities of governments and industries to consider and act on cumulative effects across activities, and this assessment provides no guidance on how these might be meaningfully considered in Newfoundland's offshore related to oil and gas development. Specific comments regarding commendations (Section 8.1/8.2) from the Committee are below. 

- Regarding Section 8.1.1, Recommendation 8: If Marine Refuges are to contribute to Canada's marine protected area/conservation targets under the Convention on Biological Diversity as "other effective area-based conservation measures", it is inappropriate that any exploratory drilling activities be allowable within these areas. Any exploration implies potential for extraction, which directly contradicts the purpose of OECMs in protecting biodiversity and ecological integrity, regardless of efforts to minimize and mitigate risk. This implication means that exploratory drilling activities would and should be considered obscolete within Marine Refuges. 

-Regarding Section 8.2 Recommendation 15: a comment in support of this recommendation, as it is critical that the efforts invested in developed the GIS decision-support tool not be wasted, and actions be taken within four months to use this tool appropriately and transparently to inform decision-making surrounding explorating drilling activities in the study area.