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Fish & their habitats

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Context

The Project Area and its surroundings harbor many fish and invertebrates of
commercial, cultural, and/or ecological significance. 

 

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Within the Project Area, two important areas are present:

  • Shelf and slope areas of the Northeast Grand Bank: used as transition regions, they support marine productivity and biodiversity

    • Designated as Ecologically or Biologically Sig Area (EBSA) due to finfish abundance, biomass, and richness 

  • Abyssal areas of the Orphan Basin: they support fish habitat and various deep-sea fishes

 

Within the Regional Assessment Area (RAA), At least 56 species of corals and 60 species of sponges reside on the seafloor. They provide habitat, refuge, spawning and foraging areas for marine life. Due to their high vulnerability to disturbance, they are often part of designated Vulnerable Marine Ecosystems (VMEs).

 

In the Project Area, many species of finfish of socio-ecological values are found. The American eel, Atlantic bluefin tuna, and Atlantic salmon have been identified as key species to Indigenous communities and specifically to Mi’kmaq peoples.

 

There is a fluctuation in species distribution such as large pelagic fish (tuna, swordfish), capelin, Atlantic Cod, redfish, and Greenland Halibut. During warmer months, plankton bloom occurs within potential Project support vessel (PSV) routes and Local Assessment Area (LAA). This event attracts many fish species for breeding as well as their pelagic predators.

 

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Species at Risk (table summary p.53-54)

  • 30 species with conservation designation are potentially overlapping with the RAA

  • American eel is listed as vulnerable under the NL ESA

  • Atlantic wolffish, northern wolffish, spotted wolffish, and white shark are all listed under the SARA, their status ranging from special concern to endangered

  • The 3 wolffish species have overlapping ranges with the LAA

    • A critical habitat is present for the spotted and northern wolffish within the RAA and some of the LAA

Agency Decision

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The Project is not likely to cause significant adverse environmental effects on fish and fish habitat (with mitigation measures in place)
 

Adverse effects would be:

  • reversible

  • low in magnitude

  • within established thresholds/guidelines

  • localized cuttings deposition

Predicted Effects

  • STRENGHTS
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Critique

  • The EIS has proposed to support research on presence and distribution of Atlantic salmon and to annually update Indigenous groups on those activities. Such steps are essential to conduct as many Indigenous communities could be affected.

   STRENGTHS   

  • The EIS has based its assessment on outdated, incomplete, or inaccurate scientific research as some referenced sources have been reviewed as such by the Canadian Science Advisory Secretariat (CSAS). This put into question the ability of the EIS to accurately determine adverse impacts. In its significance determination, the EIS recognizes the level of prediction confidence to be moderate given the general lack of information on certain fish species. However, caution is not reflected in the rest of the EIS. Consequently, the conclusion of the EIS, and subsequently the Agency, that adverse impacts are unlikely is overstated. 
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  • The EIS has recognized the lack of baseline information on migratory fishes, which are of strong cultural significance to Indigenous peoples. However, through the proposed mitigations, the EIS fails to appropriately address the concerns raised by many, specifically about the Atlantic salmon. The scarce documentation on the migratory routes, habitat, and seasonal vulnerability of this species makes it challenging to accurately measure the type and magnitude of the effects the project will have on it.
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  • Although the EIS has agreed to fund more research, the Agency has allowed for the project to move forward before they are conducted. This means that any findings that may arise, will be ineffectual as mitigations for this project as effects will already be occurring. The impacts on fish and fish habitat are directly linked to the well-being and rights of Indigenous peoples nearby. The EIS and the Agency have ignored the precautionary principle that should be respected when Indigenous peoples are involved.
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  • The EIS and the Agency dismissed restrictions of drilling activities during parts of the year. This decision is alarming considering that most of the species at risk identified within or around the Project Area have been found to be present during the warmer months. They use those waters as breeding and feeding grounds. Thus, it seems unlikely that the potential effects should be considered low. 

  Weaknesses  

Pre-drill seabed investigation plan

Mitigations

Presence & Operation of a modu

  • Survey for each well site to confirm presence or absence of sensitive environmental features, shipwrecks, and debris

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  • If environmental sensitive features are identified:

    • relocate well or redirect cutting discharges ​if feasible

    • or consult with DFO & conduct an assessment of potentially-affected benthic habitat
       

  • Limit lighting without compromising worker safety & avoid unnecessary:

    • lighting

    • shading

    • directing lights towards the deck

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  • Discharge ballast water according to the regulations

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  • Carry out ballast tank flushing prior to arriving in Canadian waters

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