Response to invitation for public comment on the draft “Strategic Environmental Assessment (SEA) for the Southern Newfoundland area of the NL Offshore

September 16, 2009

Canada-Newfoundland and Labrador Offshore Petroleum Board

5th Floor, TD Place

140 Water Street

St. John's NL, A1C 6H6

Re: Response to invitation for public comment on the draft “Strategic Environmental Assessment (SEA) for the Southern Newfoundland area of the Newfoundland and Labrador Offshore Area”..

The draft “Strategic Environmental Assessment (SEA) for the Southern Newfoundland area of the Newfoundland and Labrador Offshore Area”. states that one of its prime objectives is to “determine whether or not an Exploration Licence should be offered in whole or in part within the SEA Area.” However, there are already five Exploration Licences existing within the SEA area and according to your Press Release “the Southern Newfoundland area is included in the C-NLOPB’s Call for Bids, and the bids for this area close on November 19. The results of the SEA will be considered in decisions relating to the potential issuance of exploration licences.” In light of the above it is difficult to take the application of this SEA as a planning tool seriously.

While the development of Strategic Environmental Assessments is a welcome undertaking we request that a moratorium be placed on any further exploration activities in the area and no further lands be offered for bid until a more complete and thorough SEA has been completed and been subjected to a significant period of public review combined with funding to facilitate meaningful public participation.

A systematic independent scientifically defensible program of Environmental and Biological Study should be undertaken and sponsored by the Government of Canada as a prerequisite to any further land use decisions in this area. Among the possible land use decisions under consideration should be the designation of the area or portions of it as Protected Areas.

We thank-you for this opportunity for input. We look forward to receiving a copy of the final SEA for review. We expect this to precede any Call for Bids on Lands within the SEA area by an amount of time that would realistically allow for the development of a plan for the area based on the application of the Precautionary Principle and with a view to minimizing the risks posed to the environment by the pursuit of offshore oil and gas activities.

Sincerely,

Janet Russell

Director