Tilt Cove Exploration Drilling Project

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Attachment RE: Request for Technical Review -Tilt Cove Exploration Drilling Project

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of Fisheries and Oceans Canada
  • Reference number: 35
  • Submitted: 2023-06-07 - 2:41 PM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached submission. 
  • Attachment included
  • Annexes – Page 1/38 ANNEX 1: Advice to the Agency Table 1: Please use the table below to provide advice for the Agency’s consideration in its recommendation to the Minister of Environment and Climate Change and preparation of draft conditions Questions Responses/Comments • Has the proponent described all project components and activities in sufficient detail to understand all relevant project-environment interactions? If not, identify what additional information is needed. • Yes • Were the study areas sufficient to predict potential effects from all relevant project- environment interactions, and to consider the effects within a local and regional context? • Is the baseline information sufficient to characterize the existing environment, predict potential effects and obtain monitoring objectives? If not, identify what additional information is needed. • Yes • Yes Alternatives Assessment • Has the proponent adequately described the criteria it used to determine the technically and economically feasible alternative means? • Has the proponent listed the potential effects to valued components (VCs) within your mandate that could be affected by the technically and economically feasible alternative means? • Has the proponent adequately described why it chose each preferred alternative means? • Are there other alternative means that could have been presented? If so, please describe. • Yes, alternatives have been adequately described. • Yes • Yes • There are no other recommended alternative means. Environmental Effects Assessment • Has the proponent clearly described all relevant pathways of effects to be taken into account under section 5 of CEAA 2012? • Has ...

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Attachment Tilt Cove Technical Review Submission

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of Mi'gmawe'l Tplu'tagnn Inc.
  • Reference number: 34
  • Submitted: 2023-07-05 - 7:17 PM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached submission. 
  • Attachment included
  • July 5, 2023 VIAEMAIL: tiltcove@iaac-aeic.gc.ca Impact Agency of Canada 200 – 1801 Hollis Street Halifax NS B3J 3N4 Dear Sir/Madam, Re: Technical Review & Assessment of the Summary of the Environmental Impact Statement for Tilt Cove Exploration Drilling Project On behalf of Mi’gmawe’l Tplu’tagnn Inc., please accept our technical review of the Environmental Impact Statement Summary for the Suncor Tilt Cove Exploration Drilling Project. As a L’nuey leadership body with the inherent responsibilities to protect our member First Nations— Amlamgog (Fort Folly) First Nation, Natoaganeg (Eel Ground) First Nation, Elsipogtog First Nation (Big Cove), Oinpegitjoig (Pabineau) First Nation, Esgenoôpetitj (Burnt Church) First Nation, Tjipõgtõtjg (Buctouche) First Nation, L’nui Menikuk (Indian Island) First Nation, Ugpi’ganjig (Eel River Bar) First Nation and Metepenagiag Mi’kmaq Nation— by asserting and implementing our inherent Aboriginal and Treaty Rights throughout Mi’gma’gi, we have undertaken a thorough analysis of the Environmental Impact Statement Summary, identifying several significant issues pertaining to the proposed project’s potential impacts. Our technical review of the Environmental Impact Statement Summary highlights the following key issues that warrant immediate attention: • Assessment Scope and Methods: Suncor has failed to meet expectations through all aspects of the assessment process. The technical review demonstrates that Suncor has failed to meaningfully characterize the existing environment, providing only general overview of baseline conditions that are left largely unsupported by evidence and existing or novel study. Further, the ...
  • Attachment included
  • Mark MacDougall 226 706 8888 ext. 802 mark.macdougall@sharedvaluesolutions.com sharedvaluesolutions.com 62 Baker Street Guelph Ontario Canada N1H 4G1 Prepared for: Mi’gmawe’l Tplu’taqnn Incorporated July 5, 2023 TECHNICAL REVIEW FOR THE TILT COVE EXPLORATION DRILLING PROJECT MI’GMAWE’L TPLU’TAQNN INCORPORATED Tilt Cove Offshore Exploration Project – Environmental Impact Statement (EIS) Review 1 Mi’gmawe’l Tplu’taqnn Incorporated c/o Erica Ward 40 MicMac Road Eel Ground, New Brunswick E1V 4B1 July 5, 2023 Dear Erica, It is our pleasure to provide you with our technical review of the Suncor Tilt Cove Environmental Impact Statement. This review was completed by Marnie Benson, Morgan Edwards, Robin Heavens, Emily Stairs, Mike VanEgmond, and Alley Amos of Shared Value Solutions, covering the breadth of the Environmental Impact Statement chapters and focusing on potential interactions of project activities with your rights, interests, and values. We look forward to continuing to serve you in consultation and resources protection matters. Please do not hesitate to get in touch with us if you have any questions or concerns with the enclosed report. With best regards, Mark MacDougall, M.Sc., C.E.T., P.M.P Senior Regulatory Consultant, Shared Value Solutions <Original signed by> MI’GMAWE’L TPLU’TAQNN INCORPORATED Tilt Cove Offshore Exploration Project – Environmental Impact Statement (EIS) Review 2 CONTENTS Introduction ............................................................................................................................................ 3 M’igmawe’l Tplu’taqnn Incorporated Rights and INterests Relative to ...

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Attachment Projet de forage exploratoire Tilt Cove - Conseil des Innu Ekuanitshit

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of Conseil des Innu Ekuanitshit
  • Reference number: 39
  • Submitted: 2023-06-30 - 12:09 PM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Veuillez consulter la pièce jointe.
  • Attachment included
  • Conseil des Innu de Ekuanitshit 35, rue Manitou Ekuanitshit (Québec) G0G 1V0 Tél. : (418) 949-2234 fax : (418) 949-2085 Le 30 juin 2023 PAR COURRIEL : <Trevor.Ford@iaac-aeic.gc.ca > Monsieur Trevor Ford Gestionnaire de projets Bureau régional de l’Atlantique Agence d’évaluation d’impact du Canada 200-1801 rue Hollis Halifax, Nouvelle-Écosse BJ3 3N4 Objet : Projet de forage exploratoire Tilt Cove, RCÉI nº de réf. 80177; notre dossier no 7550-044 Monsieur Ford, La présente fait suite à l’appel du 16 juin dernier que vous avez eu avec notre représentante, Me Sara Andrade, durant lequel vous nous avez invités à transmettre nos commentaires à l’égard de l’évaluation d’impact environnemental du projet Tilt Cove, malgré la fin de la période de consultation publique et ce, au plus tard le 30 juin 2023. Nous avons pris connaissance du document pertinent soumis à l’Agence par Suncor Energy, intitulé « Programme de forage exploratoire de Tilt Cove – Résumé d’EIE » et nous vous faisons parvenir par la présente nos commentaires, qui concernent particulièrement les risques du projet pour le saumon atlantique. Les Innu de Ekuanitshit Comme vous le savez, depuis des temps immémoriaux, les Innu utilisent et occupent l’estuaire et le golfe du Saint-Laurent ainsi que leur rive nord, qui fait partie du territoire traditionnel appelé « Nitassinan » (notre terre). Encore aujourd’hui, les Innu de Ekuanitshit continuent à utiliser les ressources du Saint-Laurent à des fins alimentaires et communautaires, incluant le saumon atlantique (« ushashameku »). Le saumon de l’Atlantique et le manque de données Le Résumé d’évaluation d’impact environnemental préparé pour Suncor ...

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Attachment Tilt Cove Response-WNNB

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of Wolastoqey Nation in New Brunswick
  • Reference number: 25
  • Submitted: 2023-06-27 - 12:39 PM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached submission. 
  • Attachment included
  • WOLASTOQEY NATION CONSULTATION OFFICE Unit 3-35 Dedham Street, Suite 202 FREDERICTON, NB | E3A 2V2 t 506.459.6341 | f 506.459.0974 [DELIVERED VIA EMAIL] June 21st, 2023 Joanna Tombs Senior Consultation Analyst, Atlantic Region Re: Tilt Cove Exploration Drilling EIS The Wolastoqey Nation in New Brunswick (“WNNB”) is a not-for-profit organization that provides technical support and advice to New Brunswick’s six Wolastoqey Communities on matters that relate to their constitutionally protected Aboriginal and Treaty Rights. WNNB facilitates consultation and communication between Wolastoqey Communities, project proponents, and The Crown, but is not the rights holder, nor the body to which the duty to consult is owed. We are writing in response to the Tilt Cove Exploration Drilling Environmental Impact Statement (“The Project”). The Project is one of several that have been proposed or are currently underway that are similar in nature, both spatiotemporally, and in prospective objectives. With several new exploration projects underway, and the addition of a new Regional Assessment examining the potential for offshore wind development, serious concerns surround compounding and cumulative effects for all environmental resources in offshore Newfoundland. While projects and conditions may be similar, each carries the potential to cause adverse affects and would benefit from specific monitoring and mitigation measures. Though the EIS Summary states that any adverse effects to fishes, marine mammals, and birds are predicted to be short-term, localized, and reversible (Section 6.8), even small residuals can accumulate and produce incremental, but damaging, cumulative impacts. For that reason, WNNB ...

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Attachment RE: Tilt Cove Exploration Drilling Project - Invitation to Comment - Nunatsiavut Government

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of Nunatsiavut Government
  • Reference number: 28
  • Submitted: 2023-06-15 - 7:33 AM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached submission. 
  • Attachment included
  • Optional Comments Tracking Form Comment Number Reference to EIS (Section and page) Context and Rationale Specific Question/ Request for Information e.g. #1 Identify which section(s) of the EIS Summary and appendices are related to the comment (Volume, section, page number). e.g. page 78, section 6.6.1 fish and fish habitat Provide applicable background or rationale for requesting the information and why it is important for understanding the effects of the Project or for developing a follow-up program to verify the accuracy of EA predictions or the effectiveness of mitigation measures e.g. Seasonal fishing practices are both an important source of country foods and an important cultural practice. Although the potential effects to fish species during the operation of the Project have been adequately described, the potential long-term effects to fish species during and following well abandonment is not clear. Ask a specific question, or request specific additional information or clarification. e.g. Describe the long-term effects to fish and fish habitat during and after well abandonment. Consider how fish use of the area might change, as well as potential tainting of the country food. Update any associated conclusions accordingly. 1 -Section 2.3 Accidental Events. -Chapter 6, in general. The EIS Summary acknowledges a high probability of batch spills (0.42 per well-year). The assessment of potential impacts on VEC, however, seems to be focused on acute, short- term impacts of these events, and do not properly address (at least in the summary) potential chronic and/or sub-lethal effects on VECs resulting from multiple releases either associated ...

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Attachment Re: NunatuKavut Community Council comments on Summary EIS

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of NunatuKavut Community Council
  • Reference number: 29
  • Submitted: 2023-06-14 - 11:57 PM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached submission. 
  • Attachment included
  • Comments on the Summary of the Environmental Impact Statement for the Tilt Cove Exploration Drilling Project Proposed by Suncor Energy Inc. June 14, 2023 By the NunatuKavut Community Council 200 Kelland Drive, PO Box 460, Stn. C Happy Valley-Goose Bay, NL A0P1C0 http://www.nunatukavut.ca about:blank 1 1. Introduction The NunatuKavut Community Council (“NCC”) is pleased to present its comments to the Impact Assessment Agency of Canada on the Environmental Impact Statement Summary for the Tilt Cove Exploration Drilling Project (“Summary EIS”). NCC has previously submitted comments on a number of offshore oil and gas projects and also participated in the Regional Assessment of Offshore Oil and Gas Exploratory Drilling East of Newfoundland and Labrador. As such, our comments on Tilt Cove reflect substantial experience reviewing offshore oil and gas exploratory and development projects. Our key concerns as to the content of the Summary EIS for the Tilt Cove project is found in Section 2 of these comments. The remainder of Section 1, however, which provides background on NCC and NunatuKavut Inuit, serves as essential context for our substantive comments on the Summary EIS. Background on NCC and NunatuKavut Inuit NCC is the representative governing body for more than 6,000 Inuit primarily residing in south and central Labrador. Translated from Inuttitut, NunatuKavut means "Our Ancient Land” and refers to our territory. NunatuKavut Inuit are beneficiaries of the British-Inuit Treaty of 1765, entered into at Chateau Bay, Labrador in 1764-1765 between the southern Inuit and the British Crown. Today, ...

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Attachment Deny Approval of Suncor Energy's Tilt Cove Exploratory Drilling Project

  • Tilt Cove Exploration Drilling Project
  • Author: Extinction Rebellion Ottawa
  • Reference number: 24
  • Submitted: 2023-06-14 - 11:48 PM
  • The Canadian Impact Assessment Agency is respnsible for assessing the environmental, economic social and health impacts of potential projects. Suncor's proposed project will hinder the Federal Government's ability to meet it's Climate Change committments as a signatory to the Paris Agreement.  In this agreement, Canada has committed to reducing its GHG emissions to 40-45% of its 2005 emissions.  This proposed project will increase the amount of GHGs emitted, for the life of the exploratory project, and far into the future if exploited.  At the present time the Global Carbon Budget is less than 300GT, if we are to have a 50% chance of maintaining the 1.5 degrees Celsius of Global Average Temperature increase over pre-industrial times. The Federal Government cannot approve new oil and gas projects if we are to have any hope of protecting the health of present and future Canadian generations. You have a responsibility to protect the environment, and exposing the marine biota, fish, whales and seabirds, to Vertical Seismec Profiling, the effluent from Riserless Drilling; and risks of spills, leaks and explosions is too high a price to pay. The oil and gas sector in Canada has contributed to the climate disasters, such as wildfires, flooding, droughts, extreme weather events and heatwaves across Canada.  The economic and health burden that Canadians have to bear is extremely high, due to the oil sector emissions. If the Federal Government is to protect it's citizens from the increasing dangers of climate change, then it must not approve the project for new oil production.    

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Attachment FFAW-Unifor Comments on the EIS Summary for the Tilt Cove Exploration Drilling Project

  • Tilt Cove Exploration Drilling Project
  • Author: FFAW-Unifor
  • Reference number: 23
  • Submitted: 2023-06-14 - 7:58 PM
  • Please accept the attached comments in connection with the Environmental Impact Statement (EIS) Summary for the Tilt Cove Exploration Drilling Project on behalf of the Fish, Food and Allied Workers’ Union (FFAW-Unifor) and prepared for Suncor Energy (Suncor).
  • Attachment included
  • PO Box 10, Station C 368 Hamilton Ave, Second Floor St. John’s, NL A1C 5H5 Phone: 709.576.7276 Fax: 709.576.1962 Web: ffaw.ca June 14, 2023 Re: Impact Assessment Agency of Canada Public Comment Period on the Environmental Impact Statement Summary for the Tilt Cove Exploration Drilling Project To Whom It May Concern, Please accept the following comments in connection with the Environmental Impact Statement (EIS) Summary for the Tilt Cove Exploration Drilling Project on behalf of the Fish, Food and Allied Workers’ Union (FFAW-Unifor) and prepared for Suncor Energy (Suncor). The sheer magnitude of the project scope covered by this EIS warrants significant concern for fish harvesters. The proposed temporal scope initiates drilling in Q2 2024 and extends to the end of 2029, potentially drilling 12 to 16 wells, with exact design and locations of these wells not yet determined. The estimated 7 km² that will be inaccessible to fishing vessels for periods up to 120 days per well is worrisome and it is challenging to fully understand the collective impact without all relevant details. We would request further clarification on the spatial scope of this project as soon as it becomes available. This EIS discusses ongoing, year-round drilling operations and movement of equipment and personnel from the Mobile Offshore Drilling Unit (MODU) to land. Year-round drilling and the associated vessel traffic from the project site to land will interfere with numerous active fisheries and may impede fishing vessels from their usual routes. Fishing alternate routes and consequently alternate grounds generally means harvesters infringe on another harvester’s “territory” and/or ...

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Attachment Energy NL Submission

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of Energy NL
  • Reference number: 26
  • Submitted: 2023-06-14 - 3:09 PM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached submission. 
  • Attachment included
  • Energy NL 100 New Gower Street, Cabot Place, Suite 902, St. John’s, NL, Canada A1C 6K3 T: 709-758-6610 F: 709-758-6611 www.energynl.ca @WeAreEnergyNL Energy NL Submission to the Impact Assessment Agency of Canada Re: Environmental Impact Statement for the Tilt Cove Exploration Program (Reference Number 80177) tiltcove@iaac-aeic.gc.ca Introduction Energy NL represents approximately 500 member organizations worldwide which are involved in the energy sector. Members are active in all areas of the supply and service sector and include a diverse representation of businesses that range from offshore supply vessels and helicopters, carbon reduction and sustainable technologies, health and safety equipment and training, engineering solutions and fabricators to law firms and human resource agencies. Energy NL is pleased to once again have the opportunity to comment to the Impact Assessment Agency of Canada (IAAC) on the proposed Suncor Energy (Suncor) Exploration Drilling Project (2019-2028) in the Jeanne d’Arc Basin, specifically in exploration licence 1161. As required by the Impact Assessment Agency of Canada, Suncor has submitted an Environmental Impact Statement (EIS) Summary for the program which proposes to drill up to 12 wells in total. The location for drilling is approximately 300 kilometres from St. John’s in the Jeanne d’Arc Basin which has seen numerous exploration drilling programs in the past, along with production facilities. Seven wells have been drilled within the geographic boundaries of EL 1161 between 1973 and 2000. This is the first well in the EL since it has been held by Suncor. Newfoundland and Labrador Exploration Programs Energy NL submits that ...

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Attachment MFN Tilt Cove EIS Comments

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of Miawpukek First Nation
  • Reference number: 27
  • Submitted: 2023-06-14 - 2:09 PM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached submission. 
  • Attachment included
  • Photo by Angelina McDonald Tilt Cove Offshore Exploration Project Review and Comments on the Environmental Impact Statement Prepared by Miawpukek First Nation June 14, 2023 MIAWPUKEK FIRST NATION Technical Review of the Tilt Cove Environmental Impact Statement 2 TABLE OF CONTENTS Introduction .......................................................................................................................... 3 Miawpukek First Nation ........................................................................................................ 5 Historic Overview ........................................................................................................................ 5 Rights and Interests ..................................................................................................................... 7 Review Findings..................................................................................................................... 8 Conclusion ........................................................................................................................... 12 References .......................................................................................................................... 13 MIAWPUKEK FIRST NATION Technical Review of the Tilt Cove Environmental Impact Statement 3 INTRODUCTION Suncor Energy Inc. (Suncor or the Proponent) is seeking an approval for the Tilt Cove Exploration Drilling Project (the Project) from the Impact Assessment Agency of Canada (IAAC) and the Government of Newfoundland and Labrador. Suncor is proposing to conduct an exploration drilling project within an offshore exploration licence in the ...

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Attachment Do not approve Tilt Cove

  • Tilt Cove Exploration Drilling Project
  • Author: Meaghan Caves
  • Reference number: 21
  • Submitted: 2023-06-13 - 1:13 PM
  • The simple truth that scientists have repeatedly stressed and urged for years, even decades, is that fossil fuels are damaging to our planet. As the latest IPPC reports say and as was stated at COP 27, we need to stop fossil fuel extraction to avoid planetary catastrophe immediately. In 2015, Canada and almost every nation signed the Paris Agreement and pledged to reduce emissions. Yet, since signing the Paris Agreement, no country has been on track to meet its goals. Worldwide emissions have gone up, not down as they should be, and now we are on track to surpass, not limit, our global temperature to 1.5 Cº like we are supposed to.  Suncor sees life for fossil fuels beyond 2030, the year Canada has pledged to reduce its emissions by 40-45% below 2005 levels. How is the Tilt Cove project compatible with this? The Tilt Cove project cannot be approved. Fossil fuel extraction will never be clean and safe as much as some like to claim they can extract fossil fuels without risk or damage, and the carbon capture technology and carbon offsets that big polluters champion will not fix things and should not be a reason to allow big polluters to continue polluting. We need to move towards regeneration, not degeneration, and we need to act in ways that will heal the earth from its sickness, and we must not act in ways that will imperil our future. No project that will harm the earth and its inhabitants should ever be approved, even if there is just a potential that harm could be caused. How can a project be approved for a company that has had 13 employees die since 2014 from workplace accidents? Including one that occurred at an offshore drilling site like Tilt Cove? And a company ...

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Attachment FW: Request for Technical Review -Tilt Cove Exploration Drilling Project

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of First Nations and Inuit Health
  • Reference number: 31
  • Submitted: 2023-06-13 - 12:53 PM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached submission. 
  • Attachment included
  • Annexes – Page 1/8 ANNEX 1: Advice to the Agency Table 1: Please use the table below to provide advice for the Agency’s consideration in its recommendation to the Minister of Environment and Climate Change and preparation of draft conditions Questions Responses/Comments  Has the proponent described all project components and activities in sufficient detail to understand all relevant project-environment interactions? If not, identify what additional information is needed.  Were the study areas sufficient to predict potential effects from all relevant project- environment interactions, and to consider the effects within a local and regional context?  Is the baseline information sufficient to characterize the existing environment, predict potential effects and obtain monitoring objectives? If not, identify what additional information is needed. Alternatives Assessment  Has the proponent adequately described the criteria it used to determine the technically and economically feasible alternative means?  Has the proponent listed the potential effects to valued components (VCs) within your mandate that could be affected by the technically and economically feasible alternative means?  Has the proponent adequately described why it chose each preferred alternative means?  Are there other alternative means that could have been presented? If so, please describe. Environmental Effects Assessment  Has the proponent clearly described all relevant pathways of effects to be taken into account under section 5 of CEAA 2012?  Has the proponent identified all potential effects to VCs, including species at risk, within your mandate?  Were all potential receptors ...

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Attachment EIS Technical review comment from ISC

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of Indigenous Services Canada
  • Reference number: 30
  • Submitted: 2023-06-12 - 11:17 AM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached submission. 
  • Attachment included
  • Annexes – Page 1/6 ANNEX 1: Advice to the Agency Comments provided by Indigenous Services Canada. Departmental contact: julia.gregory@sac-isc.gc.ca; SAC.EvaluationImpacts-ImpactsAssessment.ISC@sac-isc.gc.ca Table 1: Please use the table below to provide advice for the Agency’s consideration in its recommendation to the Minister of Environment and Climate Change and preparation of draft conditions Questions Responses/Comments  Has the proponent described all project components and activities in sufficient detail to understand all relevant project-environment interactions? If not, identify what additional information is needed.  Were the study areas sufficient to predict potential effects from all relevant project- environment interactions, and to consider the effects within a local and regional context?  Is the baseline information sufficient to characterize the existing environment, predict potential effects and obtain monitoring objectives? If not, identify what additional information is needed. Alternatives Assessment  Has the proponent adequately described the criteria it used to determine the technically and economically feasible alternative means?  Has the proponent listed the potential effects to valued components (VCs) within your mandate that could be affected by the technically and economically feasible alternative means?  Has the proponent adequately described why it chose each preferred alternative means?  Are there other alternative means that could have been presented? If so, please describe. Environmental Effects Assessment  Has the proponent clearly described all relevant pathways of effects to be taken into account under section 5 of CEAA ...

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Attachment RE: Tilt Cove Technical Review Meeting

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of Canada-Newfoundland and Labrador Offshore Petroleum Board
  • Reference number: 38
  • Submitted: 2023-06-09 - 1:48 PM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached submission. 
  • Attachment included
  • Annexes – Page 1/12 ANNEX 1: Advice to the Agency Table 1: Please use the table below to provide advice for the Agency’s consideration in its recommendation to the Minister of Environment and Climate Change and preparation of draft conditions Questions Responses/Comments  Has the proponent described all project components and activities in sufficient detail to understand all relevant project-environment interactions? If not, identify what additional information is needed. Yes  Were the study areas sufficient to predict potential effects from all relevant project- environment interactions, and to consider the effects within a local and regional context?  Is the baseline information sufficient to characterize the existing environment, predict potential effects and obtain monitoring objectives? If not, identify what additional information is needed. Generally, yes. One comment on spatial considerations used for cumulative effects of atmospheric emissions. Alternatives Assessment  Has the proponent adequately described the criteria it used to determine the technically and economically feasible alternative means?  Has the proponent listed the potential effects to valued components (VCs) within your mandate that could be affected by the technically and economically feasible alternative means?  Has the proponent adequately described why it chose each preferred alternative means?  Are there other alternative means that could have been presented? If so, please describe. Yes Environmental Effects Assessment  Has the proponent clearly described all relevant pathways of effects to be taken into account under section 5 of CEAA 2012?  Has the proponent identified all ...

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Attachment NRCan Tilt Cove comments

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of Natural Resources Canada
  • Reference number: 33
  • Submitted: 2023-06-08 - 5:17 PM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached submission. 
  • Attachment included
  • 7 June 2023 Trevor Ford Project Manager, Atlantic Regional Office Impact Assessment Agency of Canada / Government of Canada Trevor.Ford@iaac-aeic.gc.ca / Tel: 902-476-7635 SENT BY EMAIL Subject: Natural Resources Canada’s Technical Review Comments of the Environmental Impact Statement for the Tilt Cove Project ____________________________________________________________________________________ Dear Trevor, In response to IAAC’s May 15, 2023 request for review of the proponent’s Environmental Impact Statement, Natural Resources Canada is providing the attached comments in relation to its mandate and areas of expertise in the area of oil behaviour in water. If you have any questions regarding our submission, please do not hesitate to contact me at peter.unger@nrcan-rncan.gc.ca. Sincerely, Peter Unger A/Director Impact Assessment Division Office of the Chief Scientists Cc: Heather Dettman mailto:Trevor.Ford@iaac-aeic.gc.ca file:///C:/Users/punger/AppData/Local/Microsoft/Windows/INetCache/Content.Outlook/EA0IWNX8/peter.unger@nrcan-rncan.gc.ca NRCan Review Comments on the Environmental Impact Statement for the Tilt Cove Project Section Page Written Text NRCan Comments 16.3.4.2 16-21 Deterministic results It is NRCan’s view that the marine diesel results look appropriate. However, the waxy (Nova Terra) oil is not likely to behave and biodegrade as described. (See Nova Terra results in "ESRF084-SL-Ross-and-D-Mackay-Environmenta- Research (1).pdf" and Lee and Levy (1991) Bioremediation: Waxy Crude Oils Stranded on Low-Energy Shorelines https://doi.org/10.7901/2169-3358-1991-1-541. 16.3.5 16-31 In addition, one must consider ...

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Attachment FW: Request for Technical Review -Tilt Cove Exploration Drilling Project

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of Environment and Climate Change Canada
  • Reference number: 36
  • Submitted: 2023-06-06 - 11:09 AM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached submissions. 
  • Attachment included
  • Annexes – Page 1/12 ANNEX 1: Advice to the Agency Table 1: Please use the table below to provide advice for the Agency’s consideration in its recommendation to the Minister of Environment and Climate Change and preparation of draft conditions Questions Responses/Comments  Has the proponent described all project components and activities in sufficient detail to understand all relevant project-environment interactions? If not, identify what additional information is needed. No, the proponent has provided very little information on potential impacts on landbirds that might be impacted by the facility. Please see ECCC-001 in Annex 2 for further details.  Were the study areas sufficient to predict potential effects from all relevant project- environment interactions, and to consider the effects within a local and regional context?  Is the baseline information sufficient to characterize the existing environment, predict potential effects and obtain monitoring objectives? If not, identify what additional information is needed. Yes Alternatives Assessment  Has the proponent adequately described the criteria it used to determine the technically and economically feasible alternative means?  Has the proponent listed the potential effects to valued components (VCs) within your mandate that could be affected by the technically and economically feasible alternative means?  Has the proponent adequately described why it chose each preferred alternative means?  Are there other alternative means that could have been presented? If so, please describe. Yes Environmental Effects Assessment  Has the proponent clearly described all relevant pathways of effects to be taken into account ...
  • Attachment included
  • Annexes – Page 1/35 ANNEX 1: Advice to the Agency Table 1: Please use the table below to provide advice for the Agency’s consideration in its recommendation to the Minister of Environment and Climate Change and preparation of draft conditions Questions Responses/Comments  Has the proponent described all project components and activities in sufficient detail to understand all relevant project-environment interactions? If not, identify what additional information is needed.  Were the study areas sufficient to predict potential effects from all relevant project- environment interactions, and to consider the effects within a local and regional context?  Is the baseline information sufficient to characterize the existing environment, predict potential effects and obtain monitoring objectives? If not, identify what additional information is needed. Alternatives Assessment  Has the proponent adequately described the criteria it used to determine the technically and economically feasible alternative means?  Has the proponent listed the potential effects to valued components (VCs) within your mandate that could be affected by the technically and economically feasible alternative means?  Has the proponent adequately described why it chose each preferred alternative means?  Are there other alternative means that could have been presented? If so, please describe. Environmental Effects Assessment  Has the proponent clearly described all relevant pathways of effects to be taken into account under section 5 of CEAA 2012?  Has the proponent identified all potential effects to VCs, including species at risk, within your mandate?  Were all potential receptors considered? ...

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Attachment TC response: Request for Technical Review -Tilt Cove Exploration Drilling Project

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of Transport Canada
  • Reference number: 32
  • Submitted: 2023-06-05 - 5:03 PM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached submission. 
  • Attachment included
  • Annexes – Page 1/7 UNCLASSIFIED / NON CLASSIFIÉ ANNEX 1: Advice to the Agency Table 1: Please use the table below to provide advice for the Agency’s consideration in its recommendation to the Minister of Environment and Climate Change and preparation of draft conditions Questions Responses/Comments  Has the proponent described all project components and activities in sufficient detail to understand all relevant project-environment interactions? If not, identify what additional information is needed. Transport Canada (TC) determined that it is not likely to exercise any power, or perform any duty or function that will permit the project to proceed. The potential project-environment interactions that may relate to TC’s mandate have been sufficiently described by the Proponent. No additional information is required at this time.  Were the study areas sufficient to predict potential effects from all relevant project- environment interactions, and to consider the effects within a local and regional context?  Is the baseline information sufficient to characterize the existing environment, predict potential effects and obtain monitoring objectives? If not, identify what additional information is needed. As it relates to Transport Canada’s mandate and similar to other Offshore Exploration Drilling (OED) project reviews, it would appear the study areas chosen (local and regional) and the baseline information are sufficient to account for potential project-environment interactions and effects. Alternatives Assessment  Has the proponent adequately described the criteria it used to determine the technically and economically feasible alternative means?  Has the proponent ...

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Attachment Health Canada's technical review of the EIS for the Tilt Cove Exploration Drilling Project

  • Tilt Cove Exploration Drilling Project
  • Author: Administrator on behalf of Health Canada
  • Reference number: 37
  • Submitted: 2023-06-05 - 10:05 AM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached submission. 
  • Attachment included
  • Sent by email to: tiltcove@iaac-aeic.gc.ca and Trevor.Ford@iaac-aeic.gc.ca Environmental Health Program (EHP) Atlantic Region Regulatory Operations and Enforcement Branch Suite 1625, 1505 Barrington Street Halifax, NS B3J 3Y6 June 5, 2023 Trevor Ford Impact Assessment Agency of Canada (IAAC) 200-1801 Hollis Street Halifax, Nova Scotia, B3J 3N4 Subject:    review of the Environmental Impact Statement (EIS) for the Tilt Cove Exploration Drilling Project Dear Trevor Ford: Health Canada (HC) is participating in the environmental assessment review of the Tilt Cove Exploration Drilling Project as a Federal Authority under the Canadian Environmental Assessment Act, 2012. As requested on May 1, 2023, HC has undertaken a technical review of the Tilt Cove Exploration Drilling Project (Project) related to HC llowing areas of expertise:  Human health risk assessment,  Human health impacts from noise,  Contamination of country foods, and  Air quality health effects. Suncor  identifies potential risks to human health in relation to the consumption of marine organisms potentially impacted by oil spills, including impact of mitigation measures (e.g.: use of dispersants), and the need for monitoring: Specific environmental effects monitoring and follow-up programs may be required in the unlikely event of spill. These monitoring programs will be developed in consultation with applicable regulatory agencies, Indigenous communities, and fisheries stakeholders, as applicable (Section 16.6.5.2). As discussed during the Tilt Cove Technical Review meeting with the IAAC and the federal authorities held on May 24, 2023, ...

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Attachment STOP Tilt Cove Exploration Drilling Project and all other fossil fuel development projects

  • Tilt Cove Exploration Drilling Project
  • Author: Kevin Prinoski
  • Reference number: 19
  • Submitted: 2023-05-19 - 7:45 PM
  • Despite declaration of a climate emergency in 2019, Canada persists in increasing the severity of that emergency through the continued promotion and production of fossil fuels. The steadily increasing manifestations of anthropogenic global warming (AGW) are evident in Canada (2021 Pacific heat dome & current Alberta wildfires) and globally (receding cryosphere, ocean acidification, sea level rise, enhanced droughts, extreme weather events, etc.) as documented by various science agencies (NASA, NOAA, IPCC, WMO, etc.). Recent IPCC reports (ie. AR6) and National Climate Assessments (NCA1-4 USA, NCA5 pending later 2023), tell us to decrease fossil fuel combustion immediately in order to minimize the effects of the radical alteration of our biosphere currently in progress. Additional fossil fuel developments such as the Tilt Cove Exploration Drilling Project will only make AGW worse and futher consume our atmospheric CO2 budget to push global warming past the tolerance level of 1.5C. Globally, we are currently at about 1.1C warming, will likely hit 1.5C by 2040, and reach about 3C by 2100 which will be catastrophic. Comparable to the tobacco industry, fossil fuel companies have known for decades the long-term consequences of use of their products but continued onwards for the sake of short-term profits at the expense of widespread and long-term harm. You cannot argue profits and economics with atmospheric physics and ecology - they don't care. Science can be ignored for only so long before willful ignorance and denial are no longer possible, such as in the early 1990s on Canada's east coast when DFO recommended codfish catch limits were ignored - the fishery collapsed shortly afterwards. We very much depend on ...

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