Letter to Cabinet: Reject Bay du Nord and focus on a fair transition for Newfoundland and Labrador
By 126 environmental and citizen’s groups and academics from NL and the rest of Canada on rejecting Bay du Nord and climate impacts — March 2, 2022
To: The Right Honourable Justin Trudeau, Prime Minister
The Honourable Steven Guilbeault, Minister of Environment and Climate Change
The Honourable Joyce Murray, Ministers of Fisheries, Oceans and the Canadian Coast Guard
The Honourable Jonathan Wilkinson, Minister of Natural Resources Canada
The Honourable Chrystia Freeland, Deputy Prime Minister, Minister of Finance
C.c. Federal Cabinet
Re: Reject Bay du Nord and focus on a fair transition for Newfoundland and Labrador
We write to you today with grave concern over the proposed Bay du Nord (BdN) offshore oil project, owned by Equinor and Husky Energy, and currently under review by Cabinet. This project is incompatible with Canada’s domestic and global climate commitments, contradicts Canada’s commitment to capping emissions from the oil and gas sector, is based on a seriously flawed Environmental Impact Statement (EIS), and does not provide Newfoundland and Labrador the support needed to transition workers to a prosperous, clean economy.
We ask that the Federal Government of Canada reject this project and immediately work with the province of Newfoundland and Labrador to build a fair and just transition away from fossil fuels.
[ Bay du Nord ] Incompatible with Canada’s Climate Commitments
The Bay du Nord (BdN) project, if built, will produce up to 73 million barrels per year for 30 years. Scope 1, 2, and 3 greenhouse gas emissions would be equivalent to adding 7-10 million fossil fuel cars to the road or building 8-10 new coal power plants. This is in direct opposition to recommendations in the International Energy Agency’s (IEA) groundbreaking Roadmap to Net Zero(link is external) and 1.5°C World Energy Outlook scenario to stop the expansion of oil, gas and coal production and infrastructure and escalate the global transition away from fossil fuel dependence and toward renewable energy.
Canada has committed to reducing emissions by 40-45% below 2005 levels by 2030 and getting to net zero by 2050. We often hear the challenges the government is having in meeting these targets. Approving BdN, which is expected to operate well beyond 2050, will only set Canada back in its attempts to reach net zero. Canada is not in a meaningful transition if we continue to grow the problem.
The time to stop the expansion of oil and gas production is now. Eleven countries and subnational governments have launched Beyond Oil and Gas Alliance, committing to no new expansion of oil and gas. In addition, 2800 scientists, 101 Nobel Laureates as well as 170 parliamentarians from 33 countries, including many from Canada, have endorsed the principles of a Fossil Fuel Non-Proliferation Treaty. And at COP 26, Canada joined almost 40 countries in committing to end international public financing for fossil fuels, putting the future of the industry further at risk.
[ Bay du Nord ] Inconsistent with the Government of Canada’s commitment to cap emissions
In 2021, the Government of Canada stood on the world stage at COP26 and committed to capping emissions from the oil and gas sector at today’s level and decreasing to net zero by 2050. This is an admirable climate commitment and Canada will be the first country in the world to use this policy tool.
Approving a project that will increase emissions at the exact time when a policy is being created to ensure emissions go down calls into question the stringency, ambition, and effectiveness of the emissions cap – a contradiction to the promise made in Glasgow.
Flaws in the Environmental Assessment Process
This project was reviewed under the Canadian Environmental Assessment Act 2012 and not the updated Impact Assessment Act (IAA). While the IAA process has flaws, it requires all projects to assess how they impact Canada’s climate commitments. As noted above, this project seriously hampers Canada’s climate commitments, but those were not taken into account in the Environmental Assessment (EA).
The EA for BdN was conducted for an estimated production of 300 million barrels of oil: more recent estimates are over triple this value, with projections ballooning to 1-1.3 billion barrels. This increase will affect upstream and downstream GHG emissions associated with the project, and will also change the scale of predicted impacts on marine life from the project.
The Environmental Assessment for the BdN project states that it will achieve a 50 per cent reduction in operating emissions compared with the four other drilling rigs offshore of NL. However, no evidence was provided to support this claim beyond standard measures for offshore drilling rigs (flaring, high efficiency burners, etc.).
Downstream emissions, which can increase a project’s total GHG output by up to ten times when the oil is actually burned, are not included in the EA.
The EA report incorrectly states Canada’s climate target as “a 30 percent reduction below 2005 emission levels by 2030”, whereas in July of 2021, the government increased its target to a 40-45 per cent reduction below 2005 levels by 2030.
The Impact Assessment Agency compared the project’s emissions to Canada’s total emissions in 2018. A more relevant metric would be for the Agency to consider the project’s emissions (upstream and downstream) compared with Canada’s total estimated emissions in 2050, assuming that the country’s net zero targets are reached.
In January 2022, the Canadian Science Advisory Secretariat (CSAS) issued Science Response 2022/003, which reviewed specific sections of Bay du Nord’s Draft Environmental Impact Statement (EIA). The report found that Equinor’s EIA was biased, had inappropriate conclusions, and was therefore unreliable for decision making. The issues raised were not resolved in the final EIS including (but not limited to):
- Equinor failed to consider lessons learned from the Gulf of Mexico’s Deepwater Horizon blowout including the behavior of deepwater blowouts.
- Equinor used oversimplified information when modeling the impact of a deep water blowout and consequently failed to adequately project oil deposits in ecologically sensitive areas.
While DFO released a letter on February 2, 2022 stating that all science concerns had been resolved, there is no publicly available document that shows how these concerns have been addressed and it is clear from the final EIS that the majority of concerns have not been addressed. It is also of concern that DFO’s comments were not available during the assessment process, diminishing the ability of participants to effectively engage in the environmental assessment.
Current production rigs off Newfoundland are drilling in waters 100 m or less. Given the increased risks associated with drilling at a depth of 1200 m located beyond the 200- mile limit, the lack of credible plan to deal with accidents and spills places ocean life and fisheries at unacceptable risk. There is no requirement to drill a same season relief well and no capping stack located in Newfoundland. Husky Energy is currently charged by ECCC and the Canada-Newfoundland and Labrador Offshore Petroleum Board for spilling an estimated 250,000 L of oil in 2018.
Failure to Support a Just Transition
People in Newfoundland and Labrador have been calling for a just transition for the province. Thousands in NL have marched in the streets for climate action and recent polls have shown strong majority support in NL for a just transition and shift to renewables.
According to the IEA, in a world moving towards net zero in 2050, global oil demand will peak in 2025, calling into question the long term viability of this project. The transition of communities that currently depend on oil and gas development must be done with respect and in a timely manner. It must be a planned transition, not an ad hoc response when demand slows and prices fall. The time to start this transition is now.
Your government promised comprehensive action to bring about a just transition – a Just Transition Act and a $2 billion “Futures Fund” for Alberta, Saskatchewan, and Newfoundland and Labrador for “local and regional economic diversification.” Honouring this promise requires rejecting BdN, and working in close collaboration with the Province, rights holders, trade unions and all stakeholders to bring about economic diversification, job creation, income support and upskilling and retraining programs.
There is strong interest within the province of NL for a just green transition but investing in an oil project like this one will only lead to an increase in provincial economic reliance on the fossil fuel industry. More to the point, it will be tying the future growth of NL’s economy to a project that will fail to succeed if we meet our climate targets. Rejecting Bay du Nord is an opportunity for Ottawa to demonstrate a clear vision for protecting workers, communities, and our climate, and must come with adequate support and scaled up funding.
For decades, economists have been warning that climate action delay increases the cost of the transition. On the heels of a year characterized by unprecedented flooding and heat waves in Canada we must ensure that our financial and political capital is deployed to further electrification and low carbon economic development and not the expansion of the fossil fuel industry.
Approval of the Bay du Nord offshore oil project is squarely in federal jurisdiction. We respectfully request that you reject Equinor’s application for the Bay du Nord offshore oil production project.
Signed,
Dr. Angela Carter, Associate Professor, Department of Political Science & Balsillie School of International Affairs, University of Waterloo, and member of the Government of Newfoundland and Labrador’s Net-Zero Advisory Council
Dr. Lori Lee Oates, Faculty of Humanities and Social Sciences, Memorial University
Dr. Nicholas Mercer, Postdoctoral Research Scholar, Dalhousie University, and member of the Government of Newfoundland and Labrador’s Net-Zero Advisory Council
Dr. Dean Bavington, Associate Professor of Geography, Memorial University of Newfoundland
Dr. JP Sapinski, Assistant Professor of Environmental Studies, Université de Moncton
Dr. Bradley B. Walters, Professor of Geography & Environment, Mount Allison University
Dr. Eric Pineault, Professor, President of the Scientific Commitee, Institute of Environmental Sciences, UQAM
Dr. Gail Fraser, Professor, Faculty of Environmental and Urban Change, York University
Dr. Atanu Sarkar, Associate Professor of Environmental and Occupational Health, Memorial University
Dr. Ian L. Jones, Professor, Department of Biology, Memorial University
The Social Justice Co-operative of Newfoundland and Labrador
Decarbonize NL
Sisters of Mercy of NL
Grand Riverkeeper Labrador
Council of Canadians – Avalon Chapter
Canadian Association of Physicians for the Environment – NL
Sierra Club Canada Foundation – Atlantic Chapter
Canadian Association of Physicians for the Environment
Climate Action Network – Réseau action climat Canada
East Coast Environmental Law Association
Stand.earth
Wolastoq Grand Council
WWF-Canada
Climate Emergency Unit
Conservation Council of New Brunswick
Clean Ocean Action Committee
Communities Protecting Our Coasts
Coalition for Responsible Energy Development in New Brunswick
Fédération des travailleurs et des travailleuses du Québec
Sacred Earth Solar
Keepers of the Water Society
Équiterre
Greenpeace Canada
Ecology Action Centre
Environmental Defence
David Suzuki Foundation
Leadnow
Council of Canadians
Council of Canadians – Saint John Chapter
Don’t Frack PEI
Penniac Anti-Shale-Gas Organization
Association québécoise des médecins pour l’environnement
Citizens Climate Lobby Canada
ENvironnement JEUnesse
Seventh Generation Initiative
Nature Québec
New Brunswick Anti-Shale Gas Alliance
Red Head Anthony’s Cove Préservation Association
Women’s Healthy Environments Network
Shift: Action for Pension Wealth & Planet Health
The Climate Reality Project Canada
Wilderness Committee
Action Climat Outaouais
Action Environnement Basses-Laurentides
AmiEs de la Terre de Québec
Association québécoise de lutte contre la pollution atmosphérique
Below2C
My Sea to Sky
Canadian Health Association for Sustainability and Equity (CHASE)
Centre de services scolaires des Affluents
Citizen’s Oil & Gas Council
Climate Action for Lifelong Learners
Climate Action Parry Sound
Sierra Club BC
Climate Emergency Institute
Climate Justice Saskatoon
Coalition climat Montréal
Comité des Citoyens et Citoyennes pour la Protection de l’Environnement Maskoutain
Community Matters Toronto
Council of Canadians – Edmonton chapter
Council of Canadians – Fredericton Chapter
Council of Canadians – Kent County Chapter
Council of Canadians – Medicine Hat Chapter
Council of Canadians – North Shore NS Chapter
Council of Canadians – Peterborough and Kawarthas
Council of Canadians – South Shore Chapter
Crooked Creek Conservancy Society of Athabasca
Grand(m)others Act to Save the Planet
Eau Secours
Gaia-Tree I.S.
Environnement Vert Plus
Extinction Rebellion New Brunswick
Extinction Rebellion Québec
Foire ÉCOSPHÈRE
Fondation Rivières
Glasswaters Foundation
Fridays For Future Greater Sudbury
GMob (GroupMobilisation)
Front étudiant d’action climatique
La Pêche Coalition for a Green New Deal
Laval en transition
Les Amis de la Chicot de Saint-Cuthbert
Lotbinière en transition
Mères au front
Mobilisation Environnementale Ahuntsic Cartierville Montréal
Mouvement écocitoyen UNEplanète
NON à une marée noire dans le Saint-Laurent
Pétroliques Anonymes
Prospérité sans Pétrole
Rapid Decarbonization Group
Regroupement écocitoyen de Sainte-Marthe-sur-le-Lac
Regroupement national des conseils régionaux de l’environnement du Québec
STU Sustainability
Regroupement Vigilance Hydrocarbures Québec
Réseau québécois des groupes écologistes
Salisbury Farmers Market
Science for Peace
Société pour vaincre la pollution – Montréal
Solidarité pour l’environnement Sutton
SOS Forêt du lac Jérôme
Tantramar Alliance Against Hydrofracking
TerraVie
Tofino Natural Heritage
Toronto Raging Grannies
Transition Capitale-Nationale
Zerofootprint
People’s Climate Movement
La CEVES
Toronto350
Indigenous Climate Action
Nature Canada
West Coast Environmental Law Association
Front commun pour la transition énergétique
Canadian Unitarians for Social Justice
Association québécoise pour la Taxation des Transactions financières et pour l’Action Citoyenne
Climate Justice Montreal
Sierra Club Canada’s