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Report of the Terra Nova Development Project Environmental Assessment Panel

6.0 Monitoring

6.1 Overview

Monitoring of the environmental effects of the Project was repeatedly raised as an important issue during the public review. The role of monitoring in respect of the Panel's recommendation that the Project be allowed to proceed is fundamental. A good monitoring program will identify potential sources of environmental effects; will determine to the satisfaction of the Proponents and of relevant departments and agencies if mitigative actions are effective; and, will provide a foundation for sound adaptive management decisions.

Offshore petroleum developments provide jobs and wealth but inevitably involve some risk to the environment from identified and unidentified impacts, and from cumulative impacts. Examining for such possible effects is done through an environmental assessment process. Potential impacts are identified, assessed and mitigated as necessary. Regulated standards are implemented and steps are taken to ensure compliance. Monitoring measures the impact and is the mechanism that protects all concerned from surprises and unintended consequences.

The Proponents, government departments and agencies and participants have expressed a range of opinions about the threat to the environment from the Project and the measures proposed to ensure environmental protection. These opinions range across a spectrum from satisfaction with existing regulations to nearly complete dissatisfaction. The preponderance of opinion, however, seems to be that standards for drilling and production discharges must be strengthened, and, that provision for monitoring must be enhanced. Further, there appears to be general agreement that prevention is the best approach to dealing with potential environmental impacts; that prevention demands a precautionary approach that identifies harmful impacts, mitigates them and then monitors to ensure their absence; that the monitoring program must be one of sufficient precision and sensitivity to measure impacts; and, that when undesirable or unwarranted effects are detected, adaptive management action is taken. The Panel is in complete agreement with this assessment of the critical role of monitoring and adaptive management.

6.2 Design

In the literature cited by the Proponents and participants, case after case indicated that monitoring programs had often been ineffective in preventing surprises. This appears to have resulted from a variety of causes including inadequate monitoring design; failure to identify and incorporate key environmental components; lack of standardization of measurement or problems with data quality; lack of statistical power; and, an inability to isolate anthropomorphic impacts from natural events or variation.

The Panel is reluctant to specify the individual elements that ought to be incorporated in a monitoring program. Rather, the Panel believes, such a program should be developed by the Proponents in collaboration with the Board, relevant government departments and agencies as well as interested, qualified experts. To this end, a workshop should be convened by the Board to identify critical monitoring program details, including baseline studies, and to review the final proposed program before it is approved by the Board. The process used to design the monitoring program, as well as the program itself, should be available for a full scientific peer review.

Environmental monitoring at the Hibernia site has been planned and will begin prior to much of the Terra Nova offshore activity. The Panel believes that synergistic integration with monitoring at the Hibernia site is desirable. This would require standardization of measurement protocols including baseline studies that establish parameters and variation of key ecosystem components, including chemical attributes of the substrate, water column, and biological communities.

The Panel recognizes that the Hibernia operators are under no obligation to accommodate on their facilities monitoring for the Terra Nova Development. However, the Board has a responsibility to ensure that the best monitoring is carried out and should urge a co-operative, synergistic approach to monitoring where benefits would accrue to all parties.

Recommendation 71:

The Panel recommends that the Board convene a workshop to identify critical monitoring program details, including baseline studies, and to review the final proposed program before it is approved by the Board.

Recommendation 72:

The Panel recommends that the Board urge the Proponents to seek a synergistic relationship with the Hibernia project to the end of devising the best possible monitoring programs.

6.3 Seabirds

The Grand Banks is an area that attracts very large numbers of seabirds of a variety of species. In summer it attracts millions of shearwaters, for example, from the south Atlantic and the Antarctic Ocean, as well as foragers from colonies on the Newfoundland coast; in winter it draws equal numbers of murrs and dovekies, for example, from far northern colonies. The Banks have been described as a "crossroads" and there is no season in which birds are not present in great abundance. Thus, as several participants noted, there is no season in which an oil spill would not represent potentially disastrous consequences. Seabirds are, in fact, the fauna that are often most immediately and most visibly affected by oil released or spilled into the marine environment.

During the hearings it was noted that previous studies of the sensitivity of marine birds to oil spills and releases have shown that there are major gaps in the understanding of their potential impacts on colonies of breeding marine birds; and it is unlikely that significant, long-term biological impacts of most major spills can be identified. There were, for example, dramatic, well-documented short-term effects of the l989 Exxon Valdez oil spill in Alaska where an estimated 250,000 birds were killed. However, scientists have since concluded that the available data are inadequate to distinguish between long-term impacts of the spill and natural variation in the marine environment. Paradoxically, that spill may have had one positive result in that it encouraged scientists to gather more and better data on seabirds and to establish a knowledge base that may make it possible to better assess the effects of future spills.

Baseline information ought to provide a means of assessing the impacts of a project, but as was noted by the Natural History Society, the complexity and interactive nature of the marine ecosystem, natural variation, insensitivity of population-based measures and inadequate data bases make this extremely difficult. Complicating this further is the lack of correlation between the size of the spill and its short-term impacts and the difficulty of obtaining measurements in winter conditions when impacts might be more severe.

While short-term impacts, readily detectable in the form of dead and dying birds, are distressing and of concern, it is the long-term impacts on populations that may be more serious. But given the weakness of our basic knowledge, the typically deficient baseline information and the usual monitoring in place for petroleum projects, these are much less detectable.

Literature cited in the EIS, and by other participants, suggests that the information required to evaluate oil release impacts includes foraging costs, population sizes, reproductive successes, survivor rates and specific responses of the birds to released oil. Such basic information is typically not part of monitoring programs nor is it expected to be required in this case. Nevertheless, assessing longer-term impacts of spills will require information on population dynamics and behavioural ecology of the birds, which goes well beyond the distribution and abundance surveys from platforms of opportunity that are typical and affordable but which almost inevitably are unable to demonstrate significant biological impacts. But even if the kind of research that is required falls outside the reasonable scope of a Terra Nova monitoring program, the Panel believes that the design of a sound program offers very exciting opportunities for collaboration with university and government researchers who should be eager to avail of synergistic co-operation. The Atlantic Accord provides for funding to support such arrangements and the Panel believes that the Board should be active in expediting them.

Recommendation 73:

The Panel recommends that the Board use every reasonable opportunity, including the provision of funding as appropriate, to promote collaborative research among the Proponents, other petroleum projects, and university and government researchers.

A contingency plan specifically designed to measure the impact of an oil spill on seabirds is necessary. Oiled birds recovered at sea and onshore must be counted. The release of a known number of drifters at the time of any spill, and their subsequent recovery along with affected birds, will provide a measure of recovery effectiveness in the conditions prevalent at the time and by extrapolation will provide an estimation of the spill's total impact.

Recommendation 74:

The Panel recommends that the Board ensure that preparations to evaluate the effects of oil spills be done in advance of actual events. Planning should include preparedness to release drifters in the area of the spill and to provide for their collection at sea and on beaches. In the event of a spill, evaluation of the impact must begin with dispersal of drifters and the careful collection of all oiled seabirds and drifters in the area of the spill and on beaches.

6.4 Fish

Participants did not appear much concerned with fish largely because there is at present little commercial fishing in the Terra Nova area. However, many examples of natural variability have come recently to notice, and it is recognized that environmental conditions on the Grand Banks may change during the life of the Project. During that time, the area may well become attractive to any one of several possible marine species; or, species not now considered commercially viable may become so.

Fisheries are such a critical element of the culture and economy of Newfoundland and Labrador that the possibility of any negative effects arising from the Project must be considered. Offshore oil development in other areas has not generally shown impacts on fish populations. However, the Department of Fisheries and Oceans noted recent reports detecting sub-lethal effects as far as 20 km from oil platforms. They also indicated their concern that a variety of chemicals released into the marine environment from oil production facilities may have impacts on fish larvae and that even short-term, local effects at specific times of year could have important consequences for some fish populations. Such consequences would only be likely if a large oil spill occurred, and, in such an event, the possibility of fish tainting would also be high. The consequence of even one fish tasting of oil might be a serious problem in a sensitive and highly competitive market. It would, therefore, seem appropriate that monitoring for tainting could be included in the well conceived monitoring that is proposed for the Terra Nova Development site. In any event, monitoring for tainting should be a low cost, low technology enterprise.

Recommendation 75:

The Panel recommends that the Department of Fisheries and Oceans, in collaboration with the Proponents and the Board, design a program to measure possible larval effects and fish tainting, which result from released oil, and that such measures be incorporated in the Project's monitoring program.

6.5 Follow-up

It is difficult to muster sufficient wisdom at the beginning of an 18-year project to ensure that an optimum development will occur and that minimum environmental impact will result. Adaptive changes in management incorporating new technologies, standards, and practices will undoubtedly be required to ensure the on-going acceptability of the Project. A first-rate monitoring program is absolutely essential, and this program, too, the Panel believes, should be the subject of periodic reviews over the life of the Project.