Engineers Canada has submitted comments to the Minister of Environment and Climate Change regarding concerns with the Decision Statements under the Canadian Environmental Assessment Act that approved three offshore exploration drilling projects off the coast of Newfoundland and Labrador.
In its letter to Minister Jonathan Wilkinson dated February 12, 2021, Engineers Canada noted that its concerns are not with the approval of the projects per se, but rather with the statement of the conditions expressed in the Decision Statements for the BHP Canada Exploration Drilling Project, Central Ridge Exploration Drilling Project, and West Flemish Pass Exploration Drilling Project. Engineers Canada believes that the Decision Statements and other documentation filed in the course of environmental assessment of these projects should have more clearly expressed the requirement for engineering expertise, with due professional accountability and professional regulation in accordance with Canadian provincial and territorial legislative requirements.
While the Decision Statements do state that the conditions expressed do not relieve the Proponent from any obligations to comply with other legislative or legal requirements, Engineers Canada believes that this qualifying language does not sufficiently express a positive requirement that engineering expertise be included throughout the lifecycle of offshore exploration drilling projects.
For example, the West Flemish Pass Exploration Drilling Project’s Environmental Impact Statement explicitly mentions “Canadian regulations for engineering design,” but in Engineers Canada’s view, the general language used in the project’s supporting documents does not clearly acknowledge the need for individuals providing engineering services to be licensed in the province or territory where that work is being completed. The publicly available documents for the BHP Canada Exploration Drilling Project, and the Central Ridge Exploration Drilling Project do not include the requirement for duly licensed engineers to be involved in the lifecycle of the project, nor the need for engineering regulations to be included in offshore exploration activities.
Engineers Canada’s letter to the Minister points out that environmental, social, and economic impacts are at risk of not being adequately addressed when duly licensed engineers are not directly involved in the design, implementation, maintenance, rehabilitation, and decommissioning of offshore projects that require the application of engineering principles. The letter added that Engineers Canada and the 12 Canadian engineering regulators believe that it is in the public interest that all infrastructure designed, built, or used within Canada—including in its offshore areas—be regulated in a manner similar to that which is currently done by the engineering regulators for engineering work on land.
The letter requested that the Minister continue to engage with the engineering regulators to consider together due regulation for activities with engineering components performed outside of provincial jurisdiction but within federal control.
Read Engineers Canada’s full letter to the Minister of Environment and Climate Change here.