RE: Request for Review of Proponent Responses to IRs for West Flemish Pass Exploration Project

Hi Brent,

We’ve reviewed the Proponent’s IR responses for the West Flemish Pass Exploration Drilling Project and offer the following comments for your review and consideration. 

IR-03

• Regarding, “localized area of sediment thicknesses above 1.5 mm may be affected by the deposition of drilling waste to a cumulative area not exceeding 0.30 km²”, does the cumulative area take into account all scenarios (depth, season)?  It would be useful to know the cumulative area for each scenario, as well as the maximum extent from release site.  The Proponent focused on 1 mm deposition thickness.  If the Proponent is able to illustrate dispersion plumes for >1mm thickness, this threshold would be sufficient for DFO to review the coral/sponge survey plan.
• It is stated that, “the survey will be carried out prior to drilling and will encompass an area within a 500-m radius from the well site”; however, the cumulative spring maximum extent from release site is 0.98 km for West Flemish 2 (Table 1).  Consequently, it is recommended that surveys extend beyond 500 m.  Decision Statements issued for recent exploration drilling projects have required that survey transect length and pattern around well sites be based on applicable drill cutting dispersion model results.

IR-05

• It is noted, “currents were predominantly to the east at both release locations with seasonal variations in speed, rather than direction”, but it later states, “currents are consistent throughout the year, no changes are anticipated for winter and fall dispersion scenarios as compared to the spring and summer dispersion that was simulated”.  Given that there are seasonal variations in speed, further justification should be provided as to why winter and fall dispersion scenarios would be similar to spring and summer.
• A similar comment pertaining to seasonality of currents was made in our review of the drill release risk assessment.

Please feel free to contact me if you have any questions or concerns.

Kim

Good afternoon,

The Agency has received responses from the proponent for the West Flemish Pass Exploration Drilling Project to the Information Requirements (IRs) issued by the Agency on April 28 ( https://iaac-aeic.gc.ca/050/documents/p80161/134673E.pdf (https://iaac-aeic.gc.ca/050/documents/p80161/134673E.pdf) ). The Agency has undertaken a conformity review of the proponent’s responses and has determined that the responses contain adequate information to inform a technical review.  The Agency will proceed with technical review of the IR responses, which can be found in the document attached for your review.

Technical comments on the attached response submission, including any follow-up information requirements, are requested no later than June 12, 2020.

If your department is satisfied with the additional information provided by the proponent, and has no follow-up questions, please confirm in your response that the information provided in the proponent’s EIS and IR responses is sufficient to inform your department’s advice on the effects analysis and conclusions, as well as required mitigation and follow-up programs.

If you would like to discuss or have any questions, please do not hesitate to contact me at 709-727-9065

Important Note
In accordance with CEAA 2012, comments received and other documents submitted or generated to inform the environmental assessment are part of the project file. Accordingly, information submitted to the Agency that is relevant to the environmental assessment of the project is available to the public upon request and may also be posted on the online public registry under reference number 80161. The Agency will remove information, such as signatures, prior to public disclosure. Should you provide any documents that contain confidential or sensitive information that you believe should not be made public, please contact me.

Regards,

Brent

Brent Keeping

Project Manager, Newfoundland and Labrador Satellite Office
Impact Assessment Agency of Canada/ Government of Canada