Submitter Statement & Perspective

I am submitting this comment as a resident of Nova Scotia, a graduate student in resources and environmental management, and a former industrial professional with a background in chemical engineering and law. Having worked inside heavy industry and energy infrastructure, I understand firsthand that operational safety and risk mitigation cannot be improvised on the fly or deferred to administrative discretion once capital is deployed. Having made Nova Scotia the long-term home for my family, I am deeply committed to ensuring that the coastal ecosystems and fisheries sustaining our province are protected by hypothesis-driven baseline science, rather than sacrificed to statutory compression.

1. The Issue: Streamlining Toward Premature Project Exemptions

This Regional Assessment’s accelerated pace poses a risk of treating regional reviews as a mere administrative tool to circumvent project-level scrutiny. I’m deeply concerned that this process is being designed to mirror the Newfoundland and Labrador 2020 regulation.  It involves using a high-level regional overview to implement sweeping statutory exemptions for future exploratory wells under the Impact Assessment Act.

2. The Evidence: Procedural Compression and Data Deficits

An assessment timeline compressed to under twelve months—initiated only in February 2026—cannot capture the seasonal dynamics, deep-water benthic ecology, and oceanographic variability of the Scotian Shelf and Slope. Stakeholder engagement has been restricted primarily to closed departmental bilateral meetings and two remote virtual sessions, denying coastal communities, commercial fishers, and independent scientists an evidentiary forum. In industrial risk engineering, bypassing multi-season physical baselines introduces structural blind spots into accident modeling and spill trajectories.

3. The Relevance: Irrevocable Decisions and Democratic Integrity

In impact assessment governance, public participation is meaningless once an irrevocable decision has been made (Sinclair, Burdett & Downs, 2025). If this Regional Assessment is utilized to enact an exploratory drilling exemption regulation, affected coastal communities, commercial fishers, and Mi'kmaw rights-holders will be permanently stripped of statutory notice-and-comment rights for every subsequent drilling program. Moving regulatory oversight into post-licensing administrative siloes creates an unmonitored "black box" that erodes civic trust. Efficiency must not override biophysical verification.

4. The Actionable Remedy (The Ask)

I urge the Impact Assessment Agency of Canada and the Review Committee to integrate the following enforceable determinations into the final report:

1. Mandate Project-Level Impact Assessments: Explicitly advise the Minister that this regional study shall not be used to exempt exploratory drilling from mandatory, project-specific impact assessments under the Impact Assessment Act.
2. Establish Binding Exclusion Zones: Impose strict, non-negotiable Class A exclusion buffers prohibiting exploratory activity within 25 km of coastal shorelines, around Sable Island, and across ecologically vulnerable areas such as the Western/Emerald Bank Marine Protected Area.
3. Conduct Multi-Season Oceanographic Baselines: Require comprehensive, empirical benthic and water-column baseline monitoring—independent of proponent control—before any regional parcel is opened to exploratory licensing.