West Flemish Pass Exploration Drilling Project Comments from the Balaena Institute for Cetacean Conservation Studies (BICCS) and Colleagues

We are writing to express concerns regarding the conclusions on the potential impacts of underwater noise emissions associated with the West Flemish Pass Exploration Drilling Project on marine mammals presented in the Draft Environmental Assessment (EA) Report. Our major concerns are as follows:

1. Mitigation measures are too focused around vertical seismic profiling (VSP) operations and auditory injuries.
2. The Impact Assessment Agency (Agency) minimizes the actual duration of proposed operations and potential spatio-temporal overlap with other concurrent projects.  
3. The Agency fails to consider the impacts of anticipated drilling-noise induced displacements of individual animals and their population-level consequences.
4. The Agency minimizes the importance of the project area for marine mammals
5. The assessment of cumulative effects is incomplete and ignores available tools to improve its evaluation
6. The Agency fails to appreciate the importance of underwater noise in its assessment of habitat quality
7. The assessment of impacts does not align with the government of Canada’s upcoming Ocean Noise Strategy for Canada
8. The Agency fails to propose concrete actions to minimize and understand the cumulative effects of the proposed activities

Please see attached PDF for more detailed discussion on these concerns.