Request for Review of Proponent Responses to IRs for BHP Canada Exploration Project

Reference Number
Date Submitted
2020-07-13 12:00:00 AM

Hi Joe, 

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

2.1.1 IR-01 – This comment has not been adequately addressed.

  • Recommend that the Proponent describe worst-case scenario for simultaneous and batch drilling (e.g., proximity of wells, temporal overlap of project activities).
  • DFO is not in agreement with the statement, “whether the second mobile offshore drilling unit (MODU) is on an adjacent BHP licence, or on the licence of another operator will not change the cumulative effects assessment.” Generally, one would expect greater potential for cumulative effects within an EL due to the confined spatial scale of activities.
  • Revision is recommended to address the discrepancy in the statements, “the specific location of individual wellsites and the specific nature and duration of any individual drilling activity carried out as part of the Project cannot currently be defined” and “there is little or no potential for interaction between the environmental zones of influence of each individual and simultaneous drilling campaign, and thus, for resulting combined environmental effects upon any VC”. If it is anticipated that zones of influence will not overlap, justification must be provided.
  • It is not clear how drill cuttings and noise from simultaneous and batch drilling could affect marine fish and fish habitat and marine mammals and sea turtles (i.e., Sections 8.0 and 10.0). This analysis should be separate from the cumulative effects assessment (i.e., Section 14.0) and include worst-case scenarios in terms of temporal and spatial overlap.
  • Provide justification as to why modelling was not updated in Appendices D and E.
  • If batch drilling or simultaneous drilling are considered in the future, DFO recommends that an effects assessment be incorporated into a future EA update. 

2.1.3 IR-03 – This comment has been partially addressed.

  • The Proponent states, “the use of a >100 km buffer does not fit within the bounds of the LAA definition as effects extending to this distance are not reasonably expected to occur”. The Proponent notes that such distances are unreasonable for avoidance by odontocetes and seals. What distance of avoidance is anticipated for baleen whales?  

2.3.1 IR-05 – This comment has been partially addressed.

  • The proposed and finalized critical habitat for northern wolffish also did not change. This should be updated in the response.
  • It should be noted whether or not the information on overlap and distances from spatial boundaries is accurate. 

2.3.2 IR-06 - This comment has been partially addressed.

  • The Proponent describes why wolffish are not likely to be found in the ELs, but does not provide justification for the Project Area in its entirety. As Figures 6-17 and 6-18 show wolffish in the Project Area, it is recommended that the Proponent revise statements pertaining to the likelihood of wolffish in the Project Area. 

2.3.3 IR-07 – This comment has been partially addressed.

  • The Proponent should describe how mitigation measures are specifically applicable to wolffish and their habitat.
  • Critical habitat for Northern and Spotted Wolffish also overlaps the Project Area, which should be noted. 

3.1.2 CL-02 – It should be clarified that critical habitat for Northern and Spotted Wolffish has been finalized. 

4.0 Request for Additional Information – This comment has been partially addressed.

  • Bullet 2 – How is the vertical structure adequate for the ocean conditions within the Project Area?
  • Bullet 5 – The rationale provided for the particle size distribution is weak, as it’s based only on Statoil’s Bay de Verde F-67 well in 2014. How would modelling results be influenced if multiple representative size distributions were utilized instead of one? 

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


From: BHPCanada (IAAC/AEIC)
Sent: Monday, June 29, 2020 5:31 PM
Subject: Request for Review of Proponent Responses to IRs for BHP Canada Exploration Project  

Good afternoon: 

As I mentioned to some of you last week, the Agency has received responses from the proponent to the Information Requirements (IRs), required clarifications, and the request for information issued in relation to the BHP Canada Exploration Drilling Project. The Agency has undertaken a conformity review of the responses and has determined that they contain adequate information to inform a technical review, which will include input from expert federal departments. 

Please find attached the proponent’s responses for your review. The document will also be posted on the Canadian Impact Assessment Registry ( 

Technical comments on the attached responses, including any follow-up information requirements, are requested by July 8, 2020. 

Although your review of the entire document is requested, certain responses may be more directly related to your individual mandates:

DFO: IRs-01, 02, 03, 05, 06, 07, and the response to the request for additional information

ECCC: IRs-04 and 09

C-NLOPB: IRs-01, 02, 10, 11, 12, and CL-03 

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.  

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 80174. 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. 


Joe Vigder, MREM
Project Manager, Atlantic Region

Impact Assessment Agency of Canada / Government of Canada 

Gestionnaire de projets, région atlantique
Agence d’évaluation d’impact du Canada / Gouvernement du Canada

Submitted by
Administrator on behalf of Fisheries and Oceans
Public Notice
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