Regional assessment comment

My main concern with the Regional Assessment is how it addresses climate change and both NL and Canada’s ability to meet climate change commitments. The NL government has stated its goals of drilling 100 new wells in the next 10 years and essentially doubling oil production. I recognize that the scope of the regional assessment is to look at drilling only and not activities that follow drilling; however if the impacts of exploration within the broader and longer term context of oil development are not addressed early, when will they be fully considered? Separating assessments of exploration from production reinforces short-term analysis of potential environmental problems and risks rather than an examination of the whole life cycle of the project, cumulative impacts, and most importantly considerations of climate change. Examining the impacts of specific projects on Canada’s ability to meet climate change commitments will be meaningless in many cases (like exploratory drilling) if we don’t have opportunities or procedural spaces where these questions can be examined. Strategic assessments have this potential as they take place before specific projects are proposed, but so far have completely failed in this respect in NL. My concern is that with this Regional Assessment being the first of its kind it will not only provide exemptions for specific projects thereby foreclosing the opportunity to discuss climate change even within the limited space of an impact assessment but also that it will set a precedent for how these kinds of broad assessments will be used in other places. The new Impact Assessment Act requires that Canada’s ability to meet its climate change commitments be considered but there are currently no places or opportunities to do this in any meaningful, long term, or cumulative way (in other words, in ways that would actually address whether Canada can meet its commitments).