ALEC BY SILAS Ma Aenbd Nangmautag Ciyde River Hunters & Trappers Organization P.O, Box 149 ~ Clyde River ~ Nunavut ~ XOA OE0 Phone: (867) 924 - 6202 ~ Fax: (867) 924 - 6197 November 26, 2018 Nunavut Impact Review Board 29 Mitik St. P.O. Box 1360 Cambridge Bay NU X08 0CO info@nirb.ca Re: Comments on the NIRB’s Strategic Environmental Assessment in Baffin Bay and Davis Strait This is a response to the request for input from the Nunavut Impacts Review Board (NIRB) into the Strategic Environmental Assessment (SEA) of offshore oil and gas in Baffin Bay and Davis Strait. The Clyde River Hunters and Trappers Organization consists of 8 Board members and represents many more individuals in the community. We have the following comments and questions about the SEA process, the Preliminary Findings report, and the potential for offshore oil and gas in the region. We request that these comments and questions be officially noted and addressed in the NIRB’s public engagement ‘summary report and the final SEA report. For reasons outlined below, the Clyde River Hunters and Trappers Organization is stating for the record that we would lke to see the federal government's moratorium on new offshore cil and gas licenses in the Arctic extended for another five vears (until 2026). Our community needs jobs and we are not ‘opposed to development; however, we believe that certain conditions must be met before we can support oll and gas activities in Baffin Bay and Davis Strait. Until the following conditions are met, our HTO believes the moratorium should remain in place. 1. Guaranteed Financial Benefits and Employment - Oil and gas activities in the Arctic pose significant risks to our community and therefore Clyde River benefit must be a partner in any cil and gas project that takes place near our community, whether it is within the Nunavut Settlement Area or outside in waters of Canadian jurisdiction. The NIRB's Preliminary Findings report does not provide adequate information on projected financial benefits or job ‘opportunities for communities. NIRB officials have stated that they can’t assess benefits and royalties for Inuit in the SEA, as itis the federal government's responsibility, yet ths isa critical consideration for us. It is therefore imperative that our community form a partnership with industry on offshore oil and gas projects in order to ensure that we are assured financial benefits and royalties on an ongoing basis for the entire project lifecycle (from exploration through to decommissioning). (Our community relies on hunting and fishing for our livelihoods and survival. We would like to know what level of compensation would oil companies provide to communities if wildlife were impacted by oll and gas activities. That being said, no amount of financial compensation is worth losing our food security and therefore more data are needed on the possible impacts of oll and {gas activities, such as oil spills and noise, on our food security.‘The final SEA report should also note the need for training opportunities so local Inuit can fully Participate in oil and gas development. As of now, we are not prepared to take advantage of any opportunities that may arise and therefore we are not yet convinced of the benefits of oll and gas for our community. 2. Research and Baseline Data — As acknowledged in the NIRB's Preliminary Findings report and during community engagement meetings in Clyde River, there remain significant gaps baseline data that are critical to fully understanding the risks and opportunities of offshore oi and gas. We are not necessarily opposed to oil and gas, but it must be done properly and not threaten our livelihoods in order for us to support it. This includes doing more research and collecting more data on the following subject areas: * Marine wildlife populations and locations (e.g. narwhal, seal, walrus, bowhead whales, etc.) need to be better understood in order to know what the potential impacts of and gas activities might be on these animals, including the sensitivity of Arctic wildlife and ecosystems to pollution, and information on habitat, migration patterns, diet and distribution. in particular, more information is needed on populations, locations and the potential impacts of oil and gas on sea-bottom dwelling organisms and plants (e.g. Phytoplankton, capelin, clams, shrimp, coral). ‘© Any oil and gas activities in the future will result in increases in shipping and ocean noise in addition to other activities already taking place such as tourism, cruise ships, cargo shipping and fishing, We are already seeing the impacts of these activities on the marine environment. We note the conclusion of the Preliminary Findings report that “it is generally not expected that the effects to the physical environment from the possible oil and gas activities included in the Oil and Gas Scenarios would interact with other activities to cause cumulative effects” (page 74); however, we would like to see more research conducted to validate this claim, ¢ Likewise, the impacts of seismic testing on marine wildlife, including narwhals, whales, seals, fish, must be better understood before a seismic program takes place. For example, the Preliminary Findings report confirms that “more research needs to be done to understand the potential effects of marine seismic surveys on sea bottom- dwelling organisms” (page 78) and "marine mammals (for example, seals, whales, and Polar Bears) may be affected by in-air and underwater noise from seismic surveys, drilling activities, and vessel traffic associated with possible marine-based oil and gas development in Baffin Bay and Davis Strait” (page 81). |s the NIRB aware of the study published in Nature Ecology (June 2017) that found that air guns used in seismic surveys to find oil and gas could kill zooplankton, which is a critical organism and the base of the Arctic food chain, at a distance of at least 1.2 kilometres, possibly farther?" More research is needed to confirm the findings of this study, as well as the possible impacts of seismic on other marine animals. * hws: 9.017 019Smauthor Informa‘* Before potentially introducing more oil into the Arctic offshore environment, we would like to see more research done on underwater oil seeps including the amount of oil being leaked, impacts, and management strategies. ‘© More information is required on the effectiveness of oil spill response in the Arctic and spill response capacity, particularly when sea ice is involved. There is always a possibility (of major incidents in the form of oil well blowouts and shipping accidents. Extreme weather, winds and icebergs make the Arctic an extremely challenging environment to effectively respond to and clean up oil spills. What infrastructure, equipment and technologies are needed before oil exploration and drilling take place? if adequate and effective oil spill response is not currently possible, what impact would an oil spill have ‘on marine animals and the fishery, which is an important part of the northern economy? {An oil spill could also threaten our enjoyment and use of the environment, as well as other industries such as tourism and many heritage and cultural sites could be negatively impacted. '* We would also like to know the possible location of required onshore facilities and infrastructure such as pipelines, artificial islands for drilling, and the storage location of. response equipment such as capping stacks and same season relief well drilling rigs. 3. Oil Spill Response As noted above, we do not fee! that spill response capacity in the Arctic is adequate to handle any serious spills or accidents and in Clyde River we don’t have the resources, equipment and training to respond to a major spill. A robust and effective spill response regime that includes notification to ‘communities, spill prevention, spill response capacity, related infrastructure, equipment and technology must be in place before oil and gas exploration and drilling activities take place. Extreme weather, winds and ice make the Arctic an extremely challenging environment to effectively respond to and clean up oil spills. 4. Free, Prior and Informed Consent il and gas activity should not be allowed in the Qikiqtani region unless Qikigtani Inuit consent to it. Oi and gas is very controversial in our region. All parties must respect the Inuit value of consensus decision- making. We believe the moratorium should stay in place unless all communities in the region support oi and gas through community plebiscites. 5. Climate Change il and gas activity should not be allowed until government considers how it might drive climate change. While we support development we are also very concerned about climate change. We understand that this Strategic Environmental Assessment does not consider how opening our region to oil and gas might drive further climate change. We believe the moratorium should remain in place until there is an assessment that considers how opening out region to oil and gas might drive climate change.