Re: Proposed Issuance of New Licence (Exploration License 1105-Old Harry to Corridor Resources by Canada-Newfoundland and Labrador Offshore Petroleum Board (c-nlopb)

September 28, 2016

Hon. James Gordon Carr

Minister of Natural Resources

Ottawa, Ontario K1A 0E4

Hon. Siobhan Coady

Minister of Natural Resources

PO Box 8700

St. John’s NL A1B 4J6

Dear Ministers Carr and Coady:

Save Our Seas and Shores (SOSS) is a coalition of fishermen, First Nations, coastal landowners, NGOs and environmentalists formed in the late 90’s to protect the Gulf of St Lawrence from offshore oil and gas development.

Gulf NS Herring Federation represents over 400 licensed fish harvesters in Gulf Nova Scotia.

We have been volunteering to protect this highly sensitive marine region for 20 years due to its high sensitivity and because it provides approx 50,000 sustainable jobs and multi-billion dollar fishery and tourism industries to five provinces in Canada. Six and a half times smaller than the Gulf of Mexico, the Gulf of St. Lawrence is a fragile, landlocked, semi-enclosed body of water that completely exchanges its water with the Atlantic Ocean only once a year. In 1973, Dr. Loutfi of McGill University described it as the most productive marine region in Canada that should never be placed in harm's way. According to him, because of its circular, counter clockwise currents, any oil and gas contamination would be widespread along the Gulf coastlines of Nova Scotia, New Brunswick, Prince Edward Island, Quebec and Newfoundland and Labrador.

This exploration Licence No. 1105 was issued on January 15, 2008 for the Old Harry prospect in the Gulf of St. Lawrence, located mid-way between the Magdalen Islands and the west coast of Newfoundland. This four-year licence was extended in 2011, 2013 and most recently on January 4, 2016. In January 2017, Licence No. 1105 will reach the maximum non-renewable term of nine years. Please note that the C-NLOPB waived the $1 million deposit required for a licence extension each and every time until it exhausted all legal extensions.

The attempt by the C-NLOPB to start this process all over again by issuing a brand new license confirms what SOSS has been saying for decades, which is, that Canada’s offshore regulatory structure needs to be reviewed. As it stands now, it has become an abuse of the public interest that is neither, protecting worker safety or the environment.

Further, we are very disappointed that the recently announced environmental review of Canada’s environmental processes do not yet include a review of Canada’s Offshore Accords Acts. Especially since the current offshore regulatory structure in the Gulf of St. Lawrence does NOT protect the public interest.

 

1. As it exists right now, five Gulf provinces have or will draw on man-made maps that provide artificial jurisdictional boundaries for undersea hydrocarbon exploitation, as if our Gulf were five separate bodies of water. Of course, it is not and the problem is, fish and oil do not recognize provincial boundaries.

Canada’s Gulf is one natural, irreplaceable ecosystem of magnificent beauty with spawning, nursery and migratory areas for over 4,000 different marine species - lobster, herring, mackerel, crab, to name a few. The Laurentian Channel is home to the largest concentration of krill in the North Atlantic. Our five provinces have shared these same fish stocks that have sustained First Nations, Gaelic and Acadian coastal communities for centuries. We hope to continue to do so for future generations and we trust you agree. Our children deserve no less.

 

May we remind you that these same fish swim across all provincial boundaries. As it stands now, the Right whale, Blue whale, leatherback turtle, piping plover and harlequin duck are endangered; while Atlantic salmon, cod, fin whale, and humpback whale are in trouble - a disgraceful indicator that in only fifty years, our generation has taken for granted and degraded our Gulf's natural, renewable resources. We have allowed unfettered industrial development and pollution with little regard for the precautionary principle and ecosystem approaches demanded by the United Nations Convention on Biodiversity and a fundamental element of Canada’s Environmental Act and Fisheries Act.

This brings us back to the unworkable jurisdictional quagmire we find ourselves in. With all due respect, nothing exists in isolation. It is neither workable nor acceptable for our five Gulf provinces to be functioning through the National Energy Board and potentially, five separate offshore petroleum boards.

These separate bodies fail to consider the ecological, economic and social impact these deepwater wells could pose on all our shores. Furthermore, for citizens and stakeholders to have to deal with potentially 5 separate Boards for this same body of water is ridiculous and an abuse of the public trust.

As well, the current regulatory structure permits offshore petroleum boards to undermine federal and international obligations to protect wildlife threatened or endangered with extinction. This must not continue.

Volunteers, individual citizens and First Nations should not be required to unilaterally protect this precious body of water indefinitely, without support from federal agencies such as EC and DFO.  Yet, this is exactly what has transpired for decades because of Memorandums of Understanding signed by DFO and EC deferring their powers of protection to unelected provincial petroleum Boards.

     3.  Mi’gmaq, Innu and Maliseet have called repeatedly for a moratorium on offshore oil and gas development in the Gulf of St Lawrence, in July 2014 at the AFN annual assembly in Halifax and at the Mi’gmaq Water Ceremony in October 2015 (See link to video below).

Therefore, we respectfully request, that you do NOT approve this new license for Corridor and that you exercise your federally-legislated powers to impose an immediate moratorium on any and all oil and gas exploration in the Gulf of St. Lawrence for now and in the foreseeable future.

We request that you restore vital federal powers to the Environment Act and Fisheries Act to protect Canada’s vulnerable oceans and especially, the Gulf of St Lawrence from offshore oil and gas development.

Mary Gorman

P.O. Box 47

Merigomish, NS BOK 1GO

Tel: 902.926.2128

Chairman - Gulf NS Herring Federation

PO Box 1803

Pictou Nova Scotia

B0K 1H0

902.485.1729

Dominic LeBlanc

Sean Fraser

Mark Eyking

Rodger Cuzner

Andy Filmore

Bill Casey

Wayne Easter

Lawrence MacAulay

Sean Casey

Carolyn Bennett

Premier Dwight Ball

Elizabeth May

Linda Duncan