Submission by Dr. Piotr Trela, Climate Change and Energy Coordinator for Sierra Club Canada, Atlantic Chapter, in response to the Government of Newfoundland and Labrador public discussion document: "Coastal and Ocean Management Strategy and Policy Framework for Newfoundland and Labrador".
Main points: the Discussion Document is an important step, but it has a serious structural weakness – it considers the health of the coastal zone and ocean ecosystem only as an afterthought, while it should have been the very core of the paper: without healthy ecosystem all the other issues: jobs, economy, industry, culture, will collapse, or at best, be reduced to a stump of the former self (see the devastation wrought upon this province by the cod collapse). Coastal and Ocean management policies should recognize in much more comprehensive way the effects of climate change on the oceans, complexity of ocean food webs and should use the "precautionary principle” as a guiding strategy. We have to admit that some fishing methods are inherently more destructive than others, and more costly, both economically and socially. We should learn from our mistakes and mistakes of others - learn the lessons from oil spill in the Gulf of Mexico and implement them in our regulatory system for our offshore oil. We need to put the health of the ecosystem at the centre of all coastal and ocean policies; have a dedicated body within the government to coordinate the ocean management; involve the public (e.g. through an advisory council). The province needs to lobby the federal governemnt and commit also its own resources to fund scientific research and the work of environmental non-governmental organizations (NGO), which provide research, education and stimulate public engagement. If new project and core funding for ENGOs' is not provided, ENGOs' expertise and delivery capacity in this area will be lost. The failure to provide such (very modest) funding would not only narrow the public discourse, but also would cost taxpayer much more in the long run - the replacement of ENGO's educational and research capacity by the government, if doable at all, would be much more expensive.
Response to the Government of Newfoundland and Labrador public discussion document:
" Coastal and Ocean Management Strategy and Policy Framework for Newfoundland and Labrador”
[the discussion document is available at: http://www.fishaq.gov.nl.ca/publications/OceansDiscussionPaper.pdf]
The overall opinion:
the Discussion Document is an important step, but it has a serious structural weakness – it puts the cart ahead of the horse: it considers the health of the coastal zone and ocean ecosystem only as an afterthought, while it should have been the very core of the paper: without healthy ecosystem all the other issues: jobs, economy, industry, culture, will collapse, or at best, be reduced to a stump of the former self (see the devastation wrought upon this province by the cod collapse).
This under-appreciation of the central role the environment plays is demonstrated throughout the document, for instance:
environment is ignored in the discussion of the Competing Needs (p.15);
it is left out of consideration when the Document asks about issues needed to be “brought into the decision making process” (Question 1);
the proposed Coastal Management Area Planning (p. 25) is a hostage to the veto from the fishery industry, that it , the very interests that exploit and damage the environment in pursuit of their income and which,often by economic necessity, cannot afford to have a long-term perspective needed here.
The specific issues of concern:
[numbers in brackets correspond to sections in the main text]
(3.1) Incomplete description of effects of climate change on the oceans:
No mention of ocean acidification
Not enough information on other ways in which the climate change will affect the fisheries:
warming of surface waters;
even though they might be responsible for the recently published dramatic decrease in the biomass of phytoplankton, the odd basis for the life in the oceans (a decline of 40% since1950).
Not enough information on the effect of climate change on coastal communities (see my Appendix 1).
(3.2) No “precautionary principle” mentioned in coastal and oceans policies and management.
(3.3) No recognition of the ocean food web, despite widespread public misunderstanding of how the ocean ecosystem works and simplistic “solution” for its repair based on this misconception.
(3.4) Some fishing methods are inherently more destructive than others(more by-catch, more collateral destruction of habitat and non-targeted species).This has to be studied and included in the process of fish quota allocation among different fishing gears.
(3.5) Some fishing methods are more costly, economically and socially, than others. Often these are the same as in (3.4), i.e. methods of “active” fishing (e.g. bottom trawling as opposed to more passive,and selective, hook-and-line; traps). Typically they require bigger boats and much more fuel, which means that:
more of the money from the caught fish flows out of the province (to pay for higher bank loans, more fuel, and more equipment);
much more greenhouse gasses is emitted per unit fish caught.
Therefore, the economic and environmental footprint of different fishing methods should be studied and included in the decisions on fish quota allocation between different fishing gears.
(3.6) The offshore oil
did not get enough coverage in the Document. The oil spill in the Gulf of Mexico has demonstrated that offshore spills may have a profound effect on the ocean and coastal ecosystem and all aspects of economy. The province has a direct influence on this part of ocean management through C-NLOPB, and should use its power to reform C-NLOPB to address the internal conflict of interest; the underweighting of environmental issues; the insufficient public access to information; the inadequate supervision of platform operation and spills; and inadequate spill response structure (for details – see my Appendix 2).
(3.7) What to do ?
Put the health of the ecosystem at the centre of all coastal and ocean policies as without it any attempts to manage coastal economy, jobs and culture become moot.
Commit to support the three pillars of good management:
a) scientific research;
c) involvement of the public.
(3.8) How to do it ?
To implement (3.7), we need:
a) Effective structure: it could include a dedicated agency within the provincial government, and an advisory body representing stakeholders and general public.
b) Sufficient funding: “you get what you pay for”.
(3.9) Two specific areas of funding needed:
the fishery research has already obtained some boost (the $14 million program announced in early July by premier Williams);
the other areas of research, like the impact of climate change on the coastal areas, remain under-funded, and undermined by federal cuts;
b) environmental non-governmental organizations (ENGOs):
they provide research, education and public engagement capacities identified in (3.7).Practically all ENGOs in this province have suffered severe cutbacks recently.
If nothing is done, ENGOs' expertise and delivery capacity will be lost. The government currently is not able to replace these services by its own operations, at least not without a major effort and cost. Furthermore, bad decisions cost: with fewer viewpoints considered, the likelihood that we overlook something critical (and costly) increases. So if the provincial government does not increase its funding to NGOs, it may cost it more in the long run. A dime saved today may cost a dollar tomorrow.
Therefore, the provincial government should provide both the core (operational) and specific project funding to the NGOs involved in coastal and ocean issues and should lobby the federal government to reverse its cuts.
(3.10) Other issues.
3.10.1 Coastal land use (p.13) - the 15m buffer is not effectively enforced. This results in creeping privatization of the coastline, which affects the common heritage and other users of coastal waters.
3.10.2 Coastal community-based renewable energy generation: may revive the fortunes of the struggling communities, provide good jobs to its citizens, generate income, and build up green-economy expertise, by developing locally owned and operated wind turbines, and, in the future, tidal and wave power. The province should be actively promoting this development.
2. The Central Weakness of the Discussion Document
The time for public discussion of the Coastal and Ocean Management has been long overdue and the Discussion Document is an important, if early, step in this direction. If there is one overriding weakness in the current approach it is that:
In the Discussion Document, the environment is treated as an afterthought, an issue of secondary importance, one cnsideration of the many, given less consideration than most: well behind the jobs, the economy, the industry, and the traditional uses.
By doing this we set ourselves up for failure: we are putting the cart in front of the horse – it is the healthy coastal and ocean environment that makes all these other considerations even possible. One would think that after the devastation to our jobs, economy, industry, and culture by the cod collapse this would self-evident. Apparently, it is not.
To prove the point that environment is not given its due, here are a few examples:
- In the section "Competing Needs" (p.15) : the Document lists many areas in which various needs compete against each other: oil&gas vs. fishing; industrial development vs. traditional users; aquaculture vs. marine users. None of these areas recognizes "protection of environment" as one of the "needs", despite the fact that all listed needs have an impact on environment, and, at the same time, cannot be successfully realized without protecting the environment.
Question Q1 on p.13 asks “Is there opportunity in your region to bring social, cultural and economic issues into the decision making process?” The absence of “environmental issues”in this question is rather telling.
Section on Coastal Management Area (CMA) Planning (p. 25) by stating:
"The CMA must be supported by the regional fishing industry representatives and local fish harvesters".
in effect hands the power of veto over the CMAs to the very interests that exploit and damage the living things in the sea, and, which, through no fault of their own, cannot afford to have a long-term perspective so needed here (if you have to put the food on your table and make the payments to the banks on your boat loan – you can only think of what is good for you now, and not whether by overfishing now, you will forcing your children to go to Alberta in the future).
If we applied the same logic on land, the statement would have read: "The land use must be supported by the regional logging industry representatives and local tree harvesters and hunters”, which would have meant that Gros Morne National Park would have never been established.
Further examples of other environmental issues that have not get enough attention in the document are discussed in detail in the next section.
3. Specific issues
3.1 Very incomplete description of effects of climate change on the oceans:
- No mention of ocean acidification, caused by our emissions of CO2[see: Doney et al., 2009], which may already be affecting various marine organisms, particularly in cold waters, like those off our province;
Not enough information on other ways in which the climate change will affect the fisheries – warming of surface waters and increased stratification, which limit the supply of nutrients and, thus, productivity of oceans. An article published in July Nature suggests that phytoplankton, the basis of life in the oceans, decreased by 40% since1950 [Boyce et al. 2010].
Need more information on effects of climate change on coastal communities (as an example fro those, I offer my Appendix 1).
3.2 No “precautionary principle” mentioned as the basis of coastal and ocean policy and management.
Thus, the onus of proof is not placed on those who alter the coastal and ocean ecosystems, but on those who voice the caution. This is a recipe for an environmental and economic disaster. One like the collapse of cod.
3.3 No recognition of the ocean food web.
This is an important omission, because of the widespread confusion among the public, and some politicians, who imagine ecosystems as straightforward food chains, where A eats B which eats C, so the way to increase B is to cull A. The real ecosystem works as a food web, in which A could be also eating D, E, F, … which all may compete with B for C, and as a result culling A may have the opposite effect from the expected [Begon at al. 2005].
3.4 Some fishing methods are more destructive than others
- It is often claimed that “no fishing method is without impacts”. This is a half-truth, used to obscure the more important fact that fishing methods are not created equal: some are inherently more destructive than others. For instance, bottom trawling causes more damage to the ecosystem per unit of seafood caught than many other methods. The passive fishing gears, like traps or hook and line, are to some extent self-regulating – if a species is overfished these gears become less effective, which in turn reduces their fishing pressure. On the other hand, the active fishing methods, like seine fishing or trawling, continue intensive catches for as long as there are any schools of fish remaining, even if the overall population sizes of the species plummeted. With the recent advances in fish location – they can find and clean out the very last schools of the fish.
3.5 Some fishing methods are more costly, economically and socially, than others
The active fishing methods discussed in 3.4.do require bigger boats and much more fuel:
Economically, this means that it takes much more fish to catch just to cover the operating costs. And since most of these costs are for things and services from outside of the province (bank loans, fuel, equipment) - it means that this type of fishing removes more of our money to the mainland than the more traditional, passive, methods.
Environmentally, the active fishing produces much more greenhouse gasses per unit fish caught, and, through this, contribute disproportionally high to the climate change, which may ruin future fishery, not only for them, but for everybody.
Therefore, the economic and environmental footprint of different fishing methods should be studied and included in the decisions on fish quota allocation between different fishing gears.
3.6 The offshore oil – not enough attention paid
the events in the Gulf of Mexico has proved that offshore oil spills may have a profound effect on the ocean and coastal ecosystem and all aspects economy.
unlike most of the open ocean, which is under the federal jurisdiction, in the offshore oil our province actually has a direct voice, because it shares its management through province's representatives on the C-NLOPB board.
the mandate of C-NLOPB should be re-evaluated to address:
- potential conflicts of interest (C-NLOPB is tasked with both promotion of offshore oil industry and enforcing the environmental regulation which affect financially oil industry);
- under-weighting of environmental issues - most of C-NLOPB expertise is in oil industry operations, not in the environment protection. Tellingly, the 7 members of the Board have extensive corporate and economics background, but not one has any obvious biological/environmental credentials.
- insufficient public access to information;
- inadequate supervision of platform operations and possible oil spills;
- questions about authority and capacity to lead the response to an oil spill - the strategic decisions on how to proceed would likely be in hands of the oil company that caused oil spill in the first place. As the disaster in the Gulf of Mexico - this may lead to questionable decision on the spill containment (for details - see Appendix 2).
3.7 What to do?
(answer the question 1 in the Document (p.13)):
- - include the environmental angle in all policy document for the reasons discussed above;
- - reform the C-NLOPB;
- - commit to support the three pillars of good management:
- a) scientific research, identifying problems and proposing solutions;
- b) education of both the government and the general public on the issues from point a)
- c) involvement of the general public in the open process, at the end of which the decisions would be informed by a) and b).
3.8 How to do it ?
To implement 3.7 , we need an effective structure and sufficient funding:
a) Structure: may include a dedicated body, or agency, within the provincial government, and an advisory body to represent the stakeholders and the general public.
b) Funding: “you get what you pay for”. This applies to the scope and quality of the research, to the quality of education, and to the public involvement. One can only do so much on a voluntary, un-paid, basis.
3.9 Two specific areas of funding needed:
- to support research: the fishery research has recently obtained a much needed boost from the provincial government, in form of the $14 million program announced in early July by premier Williams. The other areas of research, like the impact of climate change on the coastal areas remain under-funded, particularly in view of cuts to the climate change research, announced recently by the federal government.
- to support research and education capacity of environmental nongovernmental organizations (Env. NGOs) Env. NGOs are severely underfunded and the situation is getting worse as result of federal cuts to programs – out of several local Env.. NGOs involved in coastal and ocean issues in this province – virtually all have suffered cutbacks recently, The main provincial source of project funding, the Green Fund, stopped accepting new applications in June 2009, with no comparable replacement on the horizon.
If nothing is done to reverse this trend, the people involved today in these organizations will move to other lines of work and/or out of the province, and their expertise and their capacity to deliver educational programs, contribute to research and to participate in the public discourse on the critical issues for our future, will be lost. Therefore, the provincial government should lobby the federal government to reverse its cuts to the environmental funding, and provide own funding in the meantime. This funding must include both the base (operational) and specific project funding.
Failing to do so would cost this province much more in the long term: it is cheaper to maintain the existing expertise and program delivery capacity than letting it fall and then try rebuilding it from scratch. Furthermore, bad decisions cost: without the contribution to the public discourse from environmental NGOs, fewer viewpoint will be considered, increasing the likelihood that we overlook something critical. A dime today may save a dollar tomorrow.
3.10 Other issues.
3.10.1 Coastal land use (page13) - the 15m meter buffer is not effectively enforced by the province, as anybody traveling along the coast can attest, there are many new cabins built recently within this buffer. This is a creeping privatization of the coastline, which affects the common heritage and other users of coastal waters: seakayakers, recreational boaters etc. We have a long coastline, but very few places with safe landing, freshwater and camping space - and these are exactly the places that the illegal cabin builders target.
3.10.2 Coastal community-based renewable energy generation: may revive the fortunes of the struggling communities, provide good jobs to its citizens, generate income, and build up green-economy expertise, by developing locally owned and operated wind turbines, and, in the future, tidal and wave power. The province should be actively promoting this development [Trela, 2010 a].
I would like to applaud the government for this initiative and I am interested in becoming involved in future discussions concerning healthy coastal areas and oceans. Such consultations need to be based on the review of the best scientific information available.
The lack of recognition of the role of scientific research in making decisions in the coastal zone and open ocean, and the troubling under-appreciation of the environment in the management priorities are the main weaknesses of the current Discussion Document. The environment seems to be last in the order of importance – being taken care of only to the extent that it does not inconvenience all other stakeholders - offshore oil, fishery, aquaculture, shipping, oil refining, harbour users, cabin owners etc. We need to change it. Yes, we can.
Battisti, D. and Naylor, R. 2009. Historical warnings of future food insecurity with unprecedented seasonal heat. Science 323: 240–244.
Begon, M., C. Townsend and J. L. Harper, 2005. “Ecology. From Individuals to Ecosystems.” 4th Ed. Wiley-Blackwell.
Boyce D.G. M.R. Lewis and B. Worm, 2010. Global phytoplankton decline over the past century. Nature, 466, 591–596.
Doney. S. C., V.J. Fabry, R. A. Feely, and J. A. Kleypas, 2009. “ Ocean Acidification: The Other CO2 Problem”. Annu. Rev. Marine. Sci. 1:169-192.
IPCC, 2007. Intergovernmental Panel on Climate Change: Fourth Assessment Report: Climate Change 2007 (AR4) http://www.ipcc.ch/publications_and_data/publications_and_data_reports.htm
Jones, I. 2010. The Terra Nova oil spill - protected from scrutiny. http://www.mun.ca/serg/acwern/TerraNova.html
Lenton, T. M., H. Held, E, Kriegler, J.W. Hall, W. Lucht, S. Rahmstorf, and H. J. Schellnhuber, 2008. Tipping elements in the Earth’s climate system. PNAS, vol. 105 no. 6: 1786–1793.
Trela P. 2010 a. “Response to Newfoundland & Labrador Public Discussion Document: “Responding to Climate Change in Newfoundland & Labrador”, Public submission, July 31, 2010. http://www.sierraclub.ca/en/node/2870
Trela P. 2010 b. Lessons from the Gulf. Globe and Mail, Aug 20. http://www.theglobeandmail.com/news/opinions/aug-20-letters-to-the-editor/article1679026/
Appendix 1. Impacts of climate change on Newfoundland and Labrador coastal communities.
Because of our cold climate, the negative implications of climate change are often unrecognized or underestimated by the public. Here are some of the potential impacts:
intensity of storms will increase: the warmer waters – the more energy to create and sustain violent weather systems;
it is likely to affect disproportionally the island of Newfoundland – at the moment we are sheltered from the worst of the hurricanes by a belt of cold water “sucking” energy from the approaching hurricanes and downgrading them before they reach our shores. But if the surface waters warm as result of the climate change – this cold-water buffer will weaken, and with it, our safety;
stronger storms will affect the safety of anybody depending on the sea for livelihood (fishing boats, ferries, oil platforms)
stronger storms, coupled with increased sea-level, will damage coastal infrastructure (wharfs) and cause coastal erosion in all areas that are not protected by rock cliffs (e.g., CBS, Placentia, any place with sand or gravel beaches)
increased sea level + increased storm surges + increased storm precipitation = more catastrophic flooding of low-lying areas and estuaries (for instance: Waterford River – overflowing with water from a torrential rain and having at the same time outflow to the Narrows blocked by both the increased sea-level and higher storm surge)
changes in marine ecosystems caused by warming, increased stratification, changes in currents and acidification of the ocean by the CO2 – the recent study by Boyce et al.  suggests that phytoplankton, the basis of life in the oceans, decreased by 40% since1950;
changes in coastal terrestrial ecosystems – changes in temperature and precipitation; possibility of catastrophic pest invasion (see the crisis in B.C. forestry caused by pine beetle infestation as the beetle population is no longer controlled by cold winters)
increased importance of local sea food production by fisheries and aquaculture given that this province imports 90% of its food, and the food may become scarce and/or very expensive, as a result of the increasing global population and the decreasing food production (disruption of food production by climate change – see Battisti and Naylor, 2009).
There is still a large uncertainty about the timing and extent of these changes, but it is hardly any consolation – the uncertainty goes both ways: things may not be as bad as predicted, but equally likely, things may got worse than predicted. Particularly, if we move past one of many possible tipping points [Lenton et al., 2008], beyond which the climate changes will proceed on their own, regardless of what we do afterwards (“a runaway climate change”).
Appendix 2. Regulating Offshore Oil: implication for Coastal and Ocean Management.
The offshore oil industry is the only major open ocean management area on which the province has a direct voice through its representatives sitting on the board of C-NLOPB. This institution is in a dire need of reform. Some of the issues that have to be addressed are:
potential conflicts of interest:
a) at the institutional level: C-NLOPB is supposed to both promote offshore oil industry and set environmental condition that affect financially the industry it promotes;
b) at the personnel level: many employees have worked in the past, or may hope to work in the future, for the oil companies.
too much secrecy on issues that may affect the public (environmental reports treated as confidential information);
not enough supervision of the oil platforms, especially of the spills and their impacts on wildlife: after the 2004 spill from Terra Nova FPSO it took 6 days before any government biologists could collect samples – by this time most of the damage to seabirds has been already done and the data collected were of little use to measure the impact on wildlife - see the detailed description by Jones ;
offshore flaring has not been effectively addressed by the Board: this is the practice of burning gas that accompanies crude oil: not only is this an indefensible waste of our non-renewable resources, but also a major source of greenhouse emissions in the province, toxic pollution and mortality of marine birds (nocturnal birds are often attracted to intense light). In many jurisdictions flaring is banned, so the gas is collected and used as a fuel, or re-injected into the seabed. Not so here.
the liability limit for the damage caused by spill - ridiculously low ($30 million) – 700 times less than what BP has set aside as result of the Deepwater Horizon spill;
making decisions on the oil spill response – C-NLOPB has no ability to direct the response to major oil spills: instead the strategic decisions on how to proceed will be left in hands of the oil company that caused oil spill in the first place. That’s akin to designating an arsonist to be in charge of putting down the fire. Instead, it should be the oversight government body that make decisions which are then implemented by oil companies.
To prove that the last point is a critical issue – I would like to present
------------------ Two lessons from the Gulf: ---------------------------------------------
Lesson 1. Who should call the shots ?
In its response to the blowout, BP chose to add large amount of dispersant at depth, thus reducing the amount of oil at the surface, at the cost of keeping it in the water column. Suspending oil in the water column made practically all processes degrading oil either much less effective or outright impossible:
burning of oil (impossible below the surface);
collection by skimmers (impossible below the surface);
evaporation (impossible below the surface);
physical breaking down by waves (extremely limited below the surface – only long internal waves in the water column);
chemical breakup by oxygenation (limited amount of oxygen in water without contact with atmosphere);
breakup by UV rays (UV absorbed in the top few meters of water);
bacterial respiration (slowed down: low temperatures at depth slow down metabolism of bacteria, the oxygen may be quickly used up and without it many bacteria cannot function);
concentrations of bacteria at large depths often lower than at the surface.
Furthermore, the dispersant itself is not a chemically and biologically benign substance.
For all these reasons, most likely the BP strategy made things worse for the environment – reduced the amount of oil collected, increased the number and types of organisms exposed to oil (all marine organisms staying in the water column instead of only those at the surface) and assured that the oil will be around for much longer, affecting more generations of organisms and having more time to spread to other ecosystems. There was only one benefit – although the dispersants didn’t reduce the amount of oil spilled, but they reduced amount of oil which got to the surface. Out of view (and TV cameras), out of mind and out of litigation. Which points to the inherent problem of oil company in charge of cleaning up the mess it created – its decisions have more to do with containing the bad PR and legal liability than with containing the impact of oil on marine creatures.
Lesson 2: Can this happen here?
The short answer is: yes
depth: The water depth could have been one of the reasons why the blow-out safety did not prevent explosion at the Deepwater Horizon, and, without a doubt, made the containment of the spill much more difficult, Chevron’s well in the Orphan’s Basin off Newfoundland is almost twice as deep as that in the Gulf of Mexico. The early attempts to plug the well in the Gulf failed because of the methane crystals, which formed in the “top hat”. They form in low temperature and high pressures. The temperature at the bottom of Orphan basin is lower than one in the Gulf, and the pressure is almost twice as high.
There are no rigs in our area that could drill a relief well – one would have to be brought from the Gulf of Mexico. And even after they are brought on site – it is taking several month to drill them – and that’s in much more forgiving conditions of the Gulf of Mexico. The savage waters of North Atlantic (remember the Ocean Ranger) could make the plugging of the hole in the Gulf look like a picnic. The same Atlantic weather would make the removal of spilled oil virtually impossible.
The main cleanup strategy of our oil industry seems to be: let us hope that the wind and currents will move the oil away from our shores. See also: Trela [2010 b].