Letter to CNLOPB Jan 13, 2006 to accompany comments on the Draft Orphan Basin Exploration Drilling Program Environmental Assessment

Kim Coady

Canada-Newfoundland and Labrador Offshore Petroleum Board

Fifth Floor, TD Place

140 Water Street, St. John’s, NL

A1C 6H6

January 13, 2006

Dear Ms. Cody,

On behalf of the Alder Institute and our Associate Researchers Amy Williams, Dr. Gail Fraser, Dr. Joanne Ellis, Dr. Ron Pelot and Dr. John Roff, I attach our comments on the Draft Orphan Basin Exploration Drilling Program Environmental Assessment (LGL Limited, 2005).

In summary I would simply like to point out the following:

1. The level of ignorance about the Orphan Basin area is such that to have put it up for bid in the first place was an unacceptably premature decision and we request that the Board review this decision and reverse it. Following reversal we request that a systematic independent scientifically defensible program of Environmental and Biological Study be undertaken and sponsored by the Government of Canada as a prerequisite to any land use decision such as would include the allowance of the project reviewed here. Among the possible land use decisions under consideration should be the designation of the area as a Protected Area.
   
   
2. A review of the new Migratory Bird Act be made taking in to consideration it’s effect on present practices in the Offshore. Such a review should be done with the intent of tightening up the OWTG and allowable waste treatment practices which rely on the ocean as a waste treatment facility.
   
   
3. We request a review of the respective roles of various Government Agencies with respect to environmental protection in the offshore. In particular we wish a clarification on the role of the Canadian Wildlife Service and an explanation for their delayed response to the November 2004 spill at Terra Nova
   
   

4. The persistent level of ignorance throughout our offshore area regarding the distribution and abundance of marine birds coupled with their identification in Environmental Assessment after Enviornmental Assessment as the species most at risk from offshore oil and gas activities leads us to request a moratorium on the licensing of any further Offshore Oil and Gas activity under the jurisdiction of the C-NLOPB.
   
   

We hope you will find everything in order and we thank-you for this opportunity for input.

Sincerely,

Janet Russell

Director