Cumulative

environmental

effects

Context

This project is not the only project in this area and in addition to other projects, there can be environmental effects on valued components within and out of the scope fo this project. Effects from different projects and activities can overlap and interact with each other resulting in cumulative effects. It’s important to consider other projects and activities that have occurred, are ongoing or are expected to occur in the future to mitigate permanent environmental effects.

Cumulative Effects

Definition: a change in the environment caused by multiple interactions among human activities and natural processes that accumulate across time and space

Additive

Effects

Definition: Where the total effect is equal to the sum of those that have contributed to it (eg, incremental loss of habitat, the combined area of fisheries exclusion due to multiple rigs and safety zones)

Interactive Effects

Definition: Where the total effect is different in nature or degree from the sum of the individual effects that have contributed to it (eg, biomagnification of toxins, exceedance of ecological thresholds)

Interacting Players

STRENGHTS

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WEAKNESSES

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Context

Agency Decision

The project is not likely to result in significant adverse cumulative environmental effects taking into account the implementation of mitigations in combination with existing, approved and reasonably foreseeable projects.

Predicted Effects

The Agency considered the Proponent's analysis, expert advice from federal authorities and comments form Indigenous groups and the public, and identified the following key cumulative effects this project could cause:

potential cumulative loss of fish habitat and associated mortality and health effects on fish and benthic organisms resulting from drill wastes discharges at multiple wells

potential injury and behavioural effects on marine mammals and sea turtles resulting from cumulative effects of sound emissions from the Project, other offshore exploration and production activities and vessel traffic

potential injury or mortality of migratory birds resulting from cumulative effects of light emissions from multiple offshore sources

potential reduction of access to fishing grounds resulting from cumulative effects of multiple safety exclusion zones associated with the Project and other offshore exploration and production activities.

Mitigations

Effects

Mitigations

Follow-up and monitoring for this Project relating to every individual aspect will contribute to the mitigation or monitoring of cumulative environmental effects.

Strenghts

Critique

Strenghts

The proponents looked at data involving past, current and future projects to assess the effects on fish, fish habitat, manie and migratory birds, marine mammals and tea turtles including population and ecological health.

The mitigations, protocoles and plans put in place for each other the individual valued components included relevant data to be used in the cumulative environmental effects.

Regional Assessment included the development of a GIS Decision-Support Tool that consolidates available environmental data for the eastern Newfoundland offshore area; this tool will be reviewed and updated as new information becomes available, and can be used to inform the required project-specific mitigation and monitoring and programs for offshore exploratory drilling projects

Weaknesses

The proponent assumed that the effects will be geographically restricted and short-term yet, if all proposed wells were drilled for this project and the West Flemish Pass Exploration Project, it would result in near constant drilling from 2021-2025, meaning that impacts could be both widespread and long term. They did not consider the added effects of different projects and how over time, cumulative effects could have negative impacts on commercial fisheries resulting from avoidance of high vessel traffic areas where abandoned wellheads are left in place due to concern for damages to fishing gear.

They did not use complete data to evaluate the cumulative effects of seismic programs, drilling, produced water and oil spills on fish and fish habitat for projects as they did not fully examine the last 60 years of offshore exploration and development.

There is insufficient data resulting in uncertainty with respect to attraction distances to lighting and flares. More research should be done as a MODU in either exploration licence 1157 or 1158 may, if drilling were to occur at the same time, have light effects which overlap with the proposed Chevron Canada Limited West Flemish Pass Exploration Drilling Project which is located adjacent to exploration licences 1157 and 1158.

When the Proponent stated that “Given that the zone of influence of the Project at one time or location will likely be a small proportion of the feeding, breeding, or migration area of species, marine mammals and sea turtles will not be displaced from important habitats or during important activities or be affected in a manner that causes adverse effects to overall populations in the region”, they did not validate with respect to the North Atlantic right whales as the status of this species requires thoughtful and effective consideration.

The Agency’s strong reliance on the NL Regional Assessment findings for its information and determinations on the potential cumulative impacts has led to inaccurate and insufficient determinations. The NL RA's analysis of cummulative effects largely ignores the interaction between oil and gas exploration and the impact of climate change on already stressed salmon populations.

Critique