2004 Submission regarding the Scott Islands Marine Wildlife Area Initiative

From: Gerald Graham

Sent: February 2, 2004 12:41 PM

To: Greg Mallette, Environment Canada

Subject: Comments on the Proposed Scott Islands Marine Wildlife Area ( SIMWA ) from Dr. Gerald Graham

Hello, Mr. Mallette! Having attended the Victoria Scott Islands MWA ( SIMWA ) session last week in Victoria, I have some comments regarding schedule, process, and substance of the proposal.

While I think the idea of establishing the first MWA in Canada around the breathtaking-beautiful Scott Islands is commendable, I also believe it has to be done right. For one thing, as this is apparently the first MWA in Canada, a precedent will be set for all the others yet to come. Moreover, if this one is botched, there may not be any others.

One of my concerns revolves around your agenda and schedule, which looks to me to be overly-ambitious. I fail to see how all your studies, plus the consultative phase, can be completed by June of 2004. What’s the big rush? The offshore oil and gas moratorium dossier is probably going to go on for many years, and seismic and/or exploratory drilling would be unlikely to occur in the region for at least three or four years. In my view, we should take the time to line up all our ducks, get our facts straight, and reach a consensus before moving forward. This is the only way to build trust.

It was a great idea to schedule the preliminary meetings, and I found the Victoria session very informative, but it also left a lot of questions unanswered for me. To start with, the emphasis seemed to be more on process than on substance. As to the latter, I have the following concerns:

1. What exactly is an MWA, or, for that matter, a wildlife area ( WA ) in general? Are there successful examples of MWAs from other countries?
2. What’s the difference between an MWA and an MPA?
3. Just what are the threats to seabirds in the proposed area? We now from studies of the Grand Banks that hundreds of thousands of seabirds die each year, partly as a result of spills from marine shipping traffic, and partly from the Hibernia development, but do we know for sure that the same phenomenon occurs around the Scott Islands? Can this be ascertained in the short space of the next few months?
4. How do you plan to “…minimize, wherever possible, human threats or interactions that would have an impact…” on seabirds in the area, as the background paper distributed at the meeting suggests?
5. What kinds of activities can generally occur within a WA, or, in our case, a MWA?
   1. Fishing?
   2. Shipping?
   3. Seismic activity?
   4. Oil and gas drilling?
   5. Tanker traffic?
   6. Oil and Gas pipelines?
   7. Marine minerals activity?
6. Would a SIMWA rule out any and all offshore oil and gas exploration and development, for instance?
7. Would the TAPS tankers be excluded? How about the tankers that might transport oil from the proposed Enbridge pipeline slated for either Kitimat or Prince Rupert, or Statia Terminals’ proposed tanker terminal for Prince Rupert? If such activities were banned from the SIMWA area, might this not simply shift the traffic to some other nearby area?
8. Would the creation of the SIMWA result in better monitoring, control and surveillance of existing activities such as shipping? I ask this because with all the cuts to the Canadian Coast Guard’s budgets and staffing levels, it is hard to see how they, as well as DFO and Dept. of Justice, are going to take on yet another coastal responsibility. My fear is that without adequate, long-term funding for enforcement, the establishment of such a zone could end up being a hollow gesture.

In short, while the proposal to establish a Scott Islands Marine Wildlife Area appears to be highly-laudable in principle, the initiative would seem to require a great deal more thought before it moves forward. Unless questions such as the ones I have posed above are answered and made public, some people will continue to be suspicious as to motive. This would be unfortunate.

At the very least, before the next phase of the consultation process commences, CWS should clarify what an MWA does and does not do, what is allowed in it and what is proscribed.

Thank you in advance for your consideration.

Sincerely,

Gerald Graham, Ph. D., Worldocean Consulting Ltd, Victoria, BC, Canada

PS As I read my own comments, I see that they could be taken to imply that I am concerned an MWA would impinge upon offshore oil and gas activity. In fact, the opposite is true: I somehow doubt that the status of MWA would really prohibit much of anything. All I really want is for CWS to make it clear what an MWA is all about, and perhaps not get people overly-excited about the implications ( one way or the other ).