white rose asset life extension - c-nlopb

White Rose Asset Life Extension Environmental Assessment Revalidation

AR-HSE-RP-1645, Rev 3 of 3

Table of Contents

1.0 INTRODUCTION .............................................................................................................. 6

1.1 Regulatory Context.................................................................................................. 6 1.1.1 Environmental Assessment Revalidation.................................................................... 6 1.1.2 Regulatory Changes....................................................................................................... 8

1.2 Proponent Contact..................................................................................................11

2.0 PROJECT DESCRIPTION ..............................................................................................12

2.1 Temporal and Spatial Boundaries .........................................................................12

2.2 Project Rationale and Objectives ..........................................................................13

2.3 White Rose Asset Life Extension ..........................................................................14

2.4 Logistics (Supply and Servicing)...........................................................................15

2.5 Waste Management ................................................................................................16

2.6 Air Emissions..........................................................................................................16

2.7 Environmental Updates and Improvements..........................................................18 2.7.1 Project Improvements in Environmental Performance ............................................18 2.7.2 Mitigation and Monitoring Program Updates ............................................................ 23 2.7.3 Studies Conducted Since the Original White Rose Comprehensive Study...........23

3.0 STAKEHOLDER CONSULTATION AND ENGAGEMENT..............................................25

4.0 ENVIRONMENTAL EFFECTS ASSESSMENT REVALIDATION....................................25

4.1 Overall Approach....................................................................................................25

4.2 Fish and Fish Habitat..............................................................................................27 4.2.1 Summary of Key Updates for Fish and Fish Habitat ................................................27 4.2.2 Summary of Effects Analysis from Previous EAs ....................................................28 4.2.3 Verification of EA Predictions..................................................................................... 30 4.2.4 Implications of Project Extension............................................................................... 34

4.3 Marine Birds............................................................................................................34 4.3.1 Summary of Key Updates for Marine Birds ............................................................... 35 4.3.2 Summary of Effects Analysis from Previous EAs ....................................................37 4.3.3 Verification of EA Predictions..................................................................................... 40 4.3.4 Implications of Project Extension............................................................................... 40

4.4 Marine Mammals and Sea Turtles..........................................................................40 4.4.1 Summary of Key Updates for Marine Mammals and Sea Turtles............................44 4.4.2 Summary of Effects Analysis from Previous EAs ....................................................45 4.4.3 Verification of EA Predictions..................................................................................... 48



4.4.4 Implications of Project Extension............................................................................... 48

4.5 Fisheries..................................................................................................................48 4.5.1 Summary of Key Updates for Fisheries ..................................................................... 49 4.5.2 Summary of Effects Analysis from Previous EAs ....................................................53 4.5.3 Verification of EA Predictions..................................................................................... 55 4.5.4 Implications of Project Extension............................................................................... 56

4.6 Special Areas ..........................................................................................................57 4.6.1 Summary of Key Updates for Special Areas ............................................................. 57 4.6.2 Summary of Effects Analysis from Previous EAs ....................................................59 4.6.3 Verification of EA Predictions..................................................................................... 60 4.6.4 Implications of Project Extension............................................................................... 60

4.7 Species at Risk .......................................................................................................60 4.7.1 Summary of Key Updates for Species at Risk .......................................................... 61 4.7.2 Summary of Effects Analysis from Previous EAs ....................................................63 4.7.3 Verification of EA Predictions..................................................................................... 63 4.7.4 Implications of Project Extension............................................................................... 63

5.0 ACCIDENTAL EVENTS ..................................................................................................64

5.1 Summary of Effects Analysis from Previous EAs ................................................66

5.2 Summary of Key Updates and Verification of Predictions...................................68

5.3 Implications of Project Extension..........................................................................70

6.0 CUMULATIVE EFFECTS ................................................................................................71

7.0 CONCLUSIONS ..............................................................................................................72

8.0 REFERENCES ................................................................................................................73

8.1 Relevant Environmental Assessment Documents ...............................................73

8.2 Cited References ....................................................................................................73



List of Figures

Figure 2-1 Project and Study Area.........................................................................................13

Figure 2-2 SeaRose FPSO Produced Water Discharge ........................................................21

Figure 4-1 Measured Environmental Variables, or Tests, within EEM Program Components (from Husky Energy 2017b) ............................................................30

Figure 4-2 EEM Results Summary .........................................................................................32

Figure 4-3 Seasonal Presence of Seabirds in Eastern Newfoundland Offshore Area........35

Figure 4-4 : Baleen Whale Observations ...............................................................................41

Figure 4-5 Toothed Whale Observations...............................................................................42

Figure 4-6 Seal Observations.................................................................................................43

Figure 4-7 Sea Turtle Observations .......................................................................................44

Figure 4-8 NAFO Unit Area Within and Adjacent to the Study Area....................................49

Figure 4-9 Fishing Activity within and adjacent to the Project Area ...................................51

Figure 4-10 NAFO Fisheries Footprint...................................................................................52

Figure 4-11 Crab/Halibut Survey Locations ..........................................................................53

Figure 4-12 Special Areas.......................................................................................................59

List of Tables

Table 1-1 C-NLOPB Information Requirements for Environmental Assessment Revalidation ............................................................................................................ 7

Table 1-2 Relevant Environmental Guidelines Updates Since 2006....................................10

Table 2-1 Study Area Coordinates.........................................................................................13

Table 2-2 White Rose Project Criteria Air Contaminant Emissions (NPRI Reporting) for 2011 to 2018 ...........................................................................................................16

Table 2-3 White Rose (SeaRose FPSO) Historical GHG Emissions Relative to NL Large Industry Facility GHG Emissions (2004-2017) (kt CO2e) based on ECCC Greenhouse Gas Emissions Reporting Program Data........................................17

Table 2-4 Greenhouse Gas Emissions from White Rose (SeaRose FPSO) Reported for 2018 under the Provincial Management of Greenhouse Gas Act.......................17

Table 4-1 VEC Effects Assessment Summary, Fish and Fish Habitat (Production Phase); modified from Husky Oil Operations Limited (2000) and LGL (2006).................29

Table 4-2 VEC Effects Assessment Summary, Marine Birds (Production Phase); modified from Husky Oil Operations Limited (2000) and LGL (2006) ................................38

Table 4-3 VEC Effects Assessment Summary, Marine Mammals and Sea Turtles (Production Phase); modified from Husky Oil Operations Limited (2000) and LGL (2006)..............................................................................................................46



Table 4-4 VEC Effects Assessment Summary, Fisheries; modified from Husky Oil Operations Limited (2000) and LGL (2006) ..........................................................54

Table 4-5 Special Areas within the Study Area .....................................................................57

Table 4-6 Species at Risk or Otherwise of Special Conservation Concern ........................61

Table 5-1 Spill Frequencies (Spills/Wells) Associated with Blowouts for Development Drilling....................................................................................................................64

Table 5-2 Spill Frequencies for Blowouts/Well-year associated with Production/Workover Activities ................................................................................................................65

Table 5-3 Spill Frequencies (Spills/Well-year) Associated with Platform Activities...........65

Table 5-4 VEC Assessment Table for Accidental Events; modified from Husky Oil Operations Limited (2000) and LGL (2006) ..........................................................66



1.0 INTRODUCTION

Husky Energy (Husky), with its joint venture partner Suncor Energy (Suncor), is developing and operating the White Rose Field on the Grand Banks, approximately 360 km east-southeast of St. John’s, Newfoundland and Labrador. Development of the White Rose field underwent an environmental assessment (EA) in 2000 pursuant to the Canadian Environmental Assessment Act (CEAA) (S.C. 1992, c. 37) as a comprehensive study (Husky Oil Operations Limited 2000). The scope of the original White Rose Project included up to four subsea drill centres with flowlines bringing product to a centralized floating, production, storage and offloading (FPSO) platform and an end of production life of 2020. In 2006, a further EA was undertaken on activities associated with construction of up to five additional subsea drill centres and associated flowlines (Husky White Rose Development Project: New Drill Centre Construction and Operations Program Environmental Assessment (LGL 2006)), thereby extending the spatial scope of the project assessed in 2000. Since then, several EA reviews, updates and/or amendments have been submitted to ensure that EA documentation remains valid and current. However, until now, the temporal scope of the activities assessed has extended only to the end of 2020.

Husky is now planning the White Rose Asset Life Extension Project (WR ALE) to extend the temporal scope of the White Rose Project. The WR ALE project will allow the SeaRose FPSO to continue production operations from the existing White Rose and North Amethyst fields. The SeaRose FPSO will also serve as the processing, storage and offloading facility for the West White Rose Platform with the West White Rose field having a projected field life until 2036. The WR ALE represents a business opportunity for Husky as the field operator, and its co-venturer, Suncor allowing further development of White Rose resources, increasing the ultimate recoverable oil of the field, and extending the field life.

As part of this process, the Canada-Newfoundland and Labrador Offshore Petroleum Board (C-NLOPB) has determined that Husky must provide a concise EA revalidation report to confirm that the ongoing environmental mitigations remain valid and current. This EA revalidation report assesses the effects of extending the temporal scope of the Project as assessed in the White Rose Comprehensive Study (Husky Oil Operations Limited 2000) and the New Drill Centre EA (LGL 2006, 2007).

This report describes the proposed asset life extension and examines the implications of a project timeline extension in terms of environmental effects and mitigation. Changes to the existing environment and updates to mitigation, technology and best management practices are discussed in the context of the overall findings and conclusions of previous EA reviews for the White Rose Project.

1.1 Regulatory Context

1.1.1 Environmental Assessment Revalidation

The White Rose Development Project underwent an EA in 2000 pursuant to the CEAA as a comprehensive study (Husky Oil Operations Limited 2000) (White Rose Comprehensive Study). The White Rose Development Project also required authorization from the C-NLOPB under the Canada-Newfoundland and Labrador Atlantic Accord Implementation Act and the Canada-Newfoundland and Labrador Atlantic Accord Implementation



Newfoundland and Labrador Act (referred to as the Accord Acts). In 2006, when Husky proposed expansion of the White Rose Development Project with additional drill centres and associated subsea infrastructure, a screening level EA and C-NLOPB authorization updates were required to address the increased scope of planned activities (New Drill Centres EA (LGL 2006, 2007)). Since then, Husky has conducted environmental effects monitoring (EEM) programs and submitted regular EA reviews and updates to the C-NLOPB to ensure EA documentation remains current and valid.

The WR ALE project will allow the SeaRose FPSO to continue production operations fromthe existing White Rose and North Amethyst fields. The SeaRose FPSO will also serve as the processing, storage and offloading facility for the West White Rose Platform with the West White Rose field having a projected field life until 2036. However, current EA approvals and C-NLOPB authorizations are only valid to the end of 2020. The C-NLOPB has informed Husky that it must provide a concise EA revalidation report to confirm that the ongoing environmental mitigations remain valid and current given the proposed temporal extension (to 2036) of project activities.

Section 82(a) of the Impact Assessment Act requires the C-NLOPB, as the federal authority, determine if the WR ALE project is not likely to cause significant adverse environmental effects. The C-NLOPB therefore requires this EA revalidation to confirm that the WR ALE remains with scope of the original EAs, that predictions made within the original EAs remain valid, and to address any relevant changes to legislation, operations or mitigations. Scoping guidance for this EA revalidation was provided by the C-NLOPB and is presented in a concordance table below (Table 1-1), indicating where this EA Revalidation Report addresses the C-NLOPB information requirements.

Table 1-1 C-NLOPB Information Requirements for Environmental Assessment Revalidation

Subject DescriptionCorresponding EA

Revalidation Report Section(s)

Project description A description of current and planned project activities and confirmation that they remain within the scope of the original EA

2.0

EEM program findings Re-statement of the EA predictions and confirmation of the validity of the EA predictions has been confirmed by the EEM program

4.2.34.5.3

Validation of EA predictions Confirmation that the EA predictions remain valid, including for the proposed future extension of the project and related activities

(Assessed by each VEC)4.2.34.3.34.4.34.5.34.6.34.7.3

New technologies An evaluation of technologies to reduce or eliminate releases to the environmental for technical implementation and feasibility

2.7

Species at Risk An evaluation of how the adaptive management of requirements of the Species at Risk Act into program activities has been considered

4.7

Regulatory context A review of currently applicable regulations, identification of any changes relevant to the regulatory context of the 2000 White Rose Environmental Impact Statement, and discussion of the potential impact of those regulatory changes to the validity of the EA

1.1

New mitigations A description of any additional environmental mitigations that have been implemented since the original EA approval

2.7.2



Consistent with existing EAs for long-term projects under C-NLOPB jurisdiction, regular EA revalidation will be required for the WR ALE. Decommissioning and abandonment will be conducted under the regulations and requirements at the time of decommissioning. Under the current Drilling and Production Guidelines (C-NLOPB and CNSOPB 2017) a Decommissioning and Abandonment Plan must be submitted to the C-NLOPB. Additionally, the Physical Activities Regulations of the federal Impact Assessment Act,identify decommissioning and abandonment of an existing offshore floating or fixed platform as an activity that may require assessment under the Act.

1.1.2 Regulatory Changes

In addition to understanding the regulatory context of past White Rose Development Project EA requirements and existing EA documentation, the WR ALE EA revalidation requires a review of regulatory changes that have occurred since the White Rose Development Project was initially assessed in 2000. Since the New Drill Centre EA (LGL 2006) considered regulatory updates that have occurred since the White Rose Comprehensive Study (Husky Oil Operations Limited 2000), this review focuses on key changes that have occurred since 2006. These updates represent more stringent requirements, which, with Husky compliance in operations, will further reduce environmental effects as previously predicted.

Since the previous EAs were conducted under the Canadian Environmental Assessment Act (CEAA), 1992, there have been several changes to federal environmental assessment legislation, including the promulgation of CEAA, 2012 which, in 2019, was superseded by the Impact Assessment Act. The Physical Activities Regulations of the Impact Assessment Act identify clear criteria for when a project may be subject to a federal impact assessment. The “construction, installation and operation of a new offshore floating or fixed platform, vessel or artificial island used for the production of oil or gas” and the “decommissioning and abandonment of an existing offshore floating or fixed platform, vessel or artificial island used for the production of oil or gas” are relevant activities that may require assessment under the Impact Assessment Act.

In addition to changes in federal EA legislation, there have been considerable legislative changes related to air quality and greenhouse gases (GHGs), which aim to reduce atmospheric emissions. Key relevant legislation pertaining to atmospheric emissions include but are not limited to the following regulations under the Canadian Environmental Protection Act, 1999:

Multi-sector Air Pollutants Regulations;

Regulations Respecting Reduction in the Release of Methane and Certain Volatile Organic Compounds (Upstream Oi land Gas Sector); and,

Regulations Amending the Ozone-depleting Substances and Halocarbon Alternatives Regulations.

The Pan-Canadian Framework on Clean Growth and Climate Change (ECCC 2016) was developed by the federal government in collaboration with provinces and territories to helpCanada meet national and international commitments to address climate change in an economically sustainable manner. Through this Pan-Canadian Framework, the Province



of Newfoundland and Labrador has committed to reduce GHG emissions in a manner which meets the unique circumstances of the province.

In 2016, the Government of Newfoundland and Labrador passed the Management of Greenhouse Gas Act to establish a legislative basis for regulating GHG emissions from large emitters operating in the province. The Management of Greenhouse Gas Reporting Regulations sets out reporting requirements under the Act. In 2019, the Province released its new climate change action plan (Government of NL 2019) which sets out the province’s approach to reduce GHG emissions by 30% below its 2005 level by 2030. As part of this Plan, a “hybrid” carbon program comprising carbon pricing and a performance standard system was introduced. With particular relevance to offshore facilities, the Management of Greenhouse Gas Act was updated to include performance standards for offshore oil and gas production and drilling facilities (associated with production licenses) with annual GHG emissions >25,000 tonnes carbon dioxide equivalent (CO2e). Compliance is based on a reduction from absolute benchmark emission (2016 historical average emissions) with a phased in approach of 6% reduction in 2019 and 2% reduction per year until a total 12% reduction is reached in 2022 and maintained in subsequent years. Refer to Section 2.6 for more information about Husky’s White Rose air emissions and reporting requirements.

Other areas which have shown regular regulatory updates pertain to species at risk and special areas. Schedule 1 of the federal Species At Risk Act is updated regularly to reflect changes in species status. Since 2000, and even 2006, there have been several new Special Areas recognized in the eastern Newfoundland offshore. Although not all of these Special Areas have regulatory protection, their designation signifies recognized ecological and/or socioeconomic value and potential sensitivity to offshore activities. As part of annual EA updates, Husky reviews changes to species status (including the development of new recovery strategies or action plans) and changes to special areas designations to understand potential implications of its operations on these sensitive animals and habitat and ensure continued regulatory compliance. For more information on Special Areas and Species at Risk, refer to Sections 4.6 and 4.7, respectively.

In addition to these legislative updates, there have been numerous updates to environmental guidelines which apply to offshore operations (Table 1-2). The majority of these guidelines have been developed by the C-NLOPB to provide guidance for compliance with regulations made under the Accord Acts, although in some cases the guidelines have been developed by other regulatory agencies to help reduce adverse environmental effects associated with offshore operations.

Environmental regulatory changes are reviewed regularly and incorporated into operational plans and procedures, namely Husky’s Environmental Protection and Compliance Monitoring Plan on file with the C-NLOPB.



Table 1-2 Relevant Environmental Guidelines Updates Since 2006Relevant Guidelines Operational Changes to Project Relevance to this Assessment

C-NLOPB

Offshore Chemical Selection Guidelines for Drilling & Production Activities on Frontier Lands (NEB et al. 2009)

Further oversight and screening of chemicals used on the SeaRose FPSO.

Reduces potential effects on water quality.

Offshore Waste Treatment Guidelines (NEB et al. 2010)

Improvements in performance criteria for discharges including a reduction in a 30-day volume weighted average oil-in-water concentrations to not exceed 30 mg/L and a 24-hour average oil-in-water concentration in discharged water to not exceed 44 mg/L; and a reduction of residual oil concentration in drainage water, ballast water, bilge water, storage displacement water to 15 mg/L (instantaneous limit) from 40 mg/L (daily mean).

Reduced effects on water quality (Fish and Fish Habitat, Marine Birds, Marine Mammals and Sea Turtles).

Environmental Protection Plan Guidelines (C-NLOPB and CNSOPB 2011)

Assists operators in the development of an environmental protection plan (EPP).

Ensures operators have an EPP in place that will further reduce effects on the environment and all the associated VECs outlined in Section 4.0.

Compensation Guidelines Respecting Damages Relating to Offshore Petroleum Activity (C-NLOPB and CNSOPB 2017a)

Regulatory updates to introduce a revised polluter pay regime, strengthens the liability regime in relation to offshore petroleum activities.

Improved clarity on mitigation of effects to fisheries and other ocean users.

Drilling and Production Guidelines (C-NLOPB and CNSOPB 2017b)

Guidelines on the Drilling and Production Regulations. Includes details onManagement System requirements, applications for operating authorizations, safety plans and environmental protection plans.

Adds further transparency to the planned and accidental discharges related to drilling via annual environmental reporting.

Incident Reporting and Investigation Guideline (C-NLOPB and CNSOPB 2018)

Outlines responsibilities in the reporting and investigation of incidents.

Incidents and other events will be reported and investigated in accordance with these guidelines to ensure compliance with the Accord Acts.

Asset Design Life Extension Program Guideline for Offshore Canada-Newfoundland and Labrador (C-NLOPB 2019a)

Outlines C-NLOPB expectations for developing an Asset Design Life Extension Plan and maintain compliance with regulatory requirements while extending design life of an installation.

Requires assurance that equipment remains fit for purpose and all reasonable precautions continue to be taken to ensure safety and environmental protection.

Geophysical, Geological, Environmental and Geotechnical Program Guidelines (C-NLOPB 2019b)

Additional efforts for seabird and marine mammal monitoring.

Additional information to further validate the assessment of marine mammals and seabirds.

DFO

Statement of Canadian Practice with respect to the Mitigation of Seismic Sound in the Marine Environment (SOCP) (DFO 2007)

Specifies the mitigation requirements that must be met during the planning and conduct of marine seismic surveys, including vertical seismic profiles (VSPs) associated with development drilling, in order to minimize impacts on life in the oceans.

Further reduce potential effects on marine mammals.



Relevant Guidelines Operational Changes to Project Relevance to this Assessment

ECCC-CWS

Procedures for Handling and Documenting Stranded Birds Encountered on Infrastructure Offshore Atlantic Canada (ECCC 2017)

Guidance incorporated into Husky’s Seabird Handling Procedure

Potential reduction in impacts on birds and further verifications on EA prediction on seabirds.

Guidelines for effective Wildlife Response Plans. (DRAFT, ECCC 2020a)

Guidance incorporated into Husky’s Wildlife Response Plan

Guidelines for capture, transport, cleaning and rehabilitation of oiled wildlife. (DRAFT, ECCC 2020b)

Guidance incorporated into Husky’s Seabird Handling Procedure

Guidelines for establishing and operating treatment facilities for oiled wildlife. (DRAFT, ECCC 2020c)

Husky uses the Suncor Seabird Rehabilitation Facility, designed in conjunction with Tri-State Bird Rescue & Research. Husky also sponsors a third-party long-term rehabilitation facility. Husky will ensure that these facilities meet of exceed the expectations provided by the Guidelines.

Guidance and protocols for wildlife surveys for emergency response. (DRAFT, ECCC 2020d)

Guidance incorporated into Husky’s Wildlife Response Plan

ECCC-CWS standard for observers conducting seabird surveys at sea, and for trainers providing instruction on seabird survey methods. Addendum A (ECCC 2020e) to Eastern Canada Seabird’s at Sea (ECSAS) standardized protocol for pelagic seabird surveys from moving and stationary platforms. 2012. Canadian Wildlife Service Technical Report Series No. 515.

Guidance incorporated into Husky’s Wildlife Response Plan and Daily Seabird Observation Program.

Referenced throughout this EA Revalidation as Gjerdrum et al. 2012.

1.2 Proponent Contact

The contact for this WR ALE EA Revalidation report is:

Steve Bettles, Environmental Assurance SpecialistHusky Energy, Atlantic Region351 Water Street, St. John's, NL A1C 1C2 [email protected]



2.0 PROJECT DESCRIPTION

2.1 Temporal and Spatial Boundaries

The temporal boundaries extend the life of the White Rose Project beyond the previously assessed December 31, 2020 to an anticipated end of life of production at the end of 2036 with decommissioning and abandonment activities to follow (refer to Section 2.3 for detail on activities involved).

The “Project Area” is where routine Project activities will occur in any given year (LGL 2006, 2007) and represents the area directly disturbed by construction, installation, operation and related activities, including physical works and safety exclusion zone. Coordinates for the Project Area are provided in Table 2-1.

The “Study Area” is the area that could potentially be affected by project activities beyond the Project Area which considers modelling of drilling waste and produced water discharges, and spill trajectory modelling (LGL 2006, 2007).

The “Regional Area” remains unchanged from the original comprehensive study (Husky Oil Operations Limited 2000), which includes the Study Area and the Grand Banks ecosystem.

Figure 2-1 shows the Project Area and Study Area and Table 2-1 lists Study Area coordinates.



Figure 2-1 Project and Study Area

Table 2-1 Study Area CoordinatesLabel Longitude Latitude

A -42.00215 47.99227

B -42.00444 44.99906

C -46.98836 44.99760

D -47.00030 42.96468

E -49.47240 42.97325

F -49.48429 47.99227

2.2 Project Rationale and Objectives

The WR ALE project will allow the SeaRose FPSO to continue production operations fromthe existing White Rose and North Amethyst fields. The SeaRose FPSO will also serve as the processing, storage and offloading facility for the West White Rose Platform with the West White Rose field having a projected field life until 2036. The WR ALE represents a business opportunity for Husky as the field operator, and its co-venturer, Suncor allowing further development of White Rose resources, increasing the ultimate recoverable oil of the field, and extending the field life.



2.3 White Rose Asset Life Extension

The WR ALE involves the evaluation of the following equipment for extension of life:

All existing wells and subsea equipment located within North Amethyst, Southern, Northern, Central and South White Rose Extension drill centres;

Existing pipelines, umbilicals, risers and moorings; and,

Existing SeaRose FPSO facility which includes:

- Hull and marine systems;

- Topside process and utility systems; and,

- Turret systems.

In addition to ongoing annual integrity reviews, the WR ALE involves a detailed review of safety critical elements (SCEs) and supporting systems to ensure the SCE and their supporting systems will operate as per original design through the life extension period. Some of the critical areas of focus are:

Fatigue life of the hull, based on present actual conditions;

Turret and buoy ageing and fatigue life;

Obsolescence and the lack of available spares and/or vendor support;

The mooring chain wear and fatigue;

Mooring chain component degradation;

Flexible riser fatigue;

Subsea system ageing;

Well integrity Status;

Production systems (Piping and associated equipment);

Safety system reviews; and,

Integrated Controls and Safety Systems (ICSS), Fire and Gas System (FGS), Emergency Shut Down (ESD) (Obsolescence).

It is expected that life extension renewal work will include, but not be limited to:

The determination of fatigue sensitive areas within hull, topsides and turret and the remedial work required to maintain hull and overall structural integrity;



Repairs (coating or replacement) within hull spaces (ballast tanks) and on topsides primary and tertiary structures (Passive Fire Protection (PFP), handrails and tertiary supports);

Yearly turnarounds may have to be assessed and potentially extended to accommodate asset life extension scopes to avoid backlog resulting in extended or unplanned offstation(s);

Replacement of sections of piping systems which are approaching minimum wall thickness, including replacement of temporary repairs requiring shutdowns;

Upgrade of obsolete equipment which may cause business or safety impact (controls, electrical, mechanical, telecoms, etc.);

Upgrade of produced water caisson arrangement, coating of # 4 Port crude oil tank for produced water service, other significant management of changes required to meet future life of field expectations uptime targets (waste heat recovery unit/heating medium alternatives);

Dry-dock external hull survey and associated remedial work (ship side valves, propeller shaft, rudder bearings, impressed current cathodic protection and sacrificial anode replacement, chain inspection, anti-biofoul coating renewal);

Minimizing a maintenance backlog to within key performance indicators for planned and corrective work, considering also future shutdown requirements (pressure vessels, flare tip, hose reel and hawser). Systems which require significant maintenance effort may require upgrading (Liebherr cranes and stern discharge system);

Mooring line segment replacements as required;

Subsea control system upgrades;

Flexible riser replacements as required; and,

Accommodations refurbishment to improve ongoing quality of life onboard.

The original EA (Husky Oil Operations Limited 2000) assessed ongoing maintenance as part of the Project scope. No changes or updates to the decommissioning plan have been made since the original EA (Husky Oil Operations Limited 2000) and New Drill Centre EA (LGL 2006), with the exception that decommissioning schedule will not occur in 2020.

2.4 Logistics (Supply and Servicing)

The White Rose Comprehensive Study (Husky Oil Operations Limited 2000) determined there were no significant adverse residual effects associated with logistics for the Project. There is no anticipated change in the number of supply/standby vessels or helicopters assessed in the White Rose Comprehensive Study (Husky Oil Operations Limited 2000). Over the course of operations, Husky has implemented several initiatives to optimize vessel and helicopter transport (see Section 2.7). The residual environmental effects



assessment remains valid with respect to supply and servicing operations. Additional cumulative air emissions over the life of the Project to 2036 from supply and servicing is assessed in Section 2.6.

2.5 Waste Management

There are no anticipated changes in the discharges as assessed in the White Rose Comprehensive Study (Husky Oil Operations Limited 2000), the New Drill Centre EA (LGL 2006) and applicable EA updates. Husky is committed to an active program to manage the generation, reuse or recycling and disposal of “waste materials” generated by any of Husky’s Atlantic Region offshore or onshore operations. The overall context for Husky’s waste management program in the Atlantic Region is set by Husky’s Waste Management Plan which is on file with the C-NLOPB. Facility-specific waste management proceduresmay also be developed (eg. SeaRose FPSO). Waste streams are monitored regularly and reported annually to the C-NLOPB through environmental performance reporting.

2.6 Air Emissions

The main source of air emissions identified in the White Rose Comprehensive Study (Husky Oil Operations Limited 2000; see Section 4.3.2.13 for production phase emissions) have not and will not change throughout the life of the Project. However, it is noted that the cumulative amount of air emissions will increase over time with the extension of the project schedule to 2036.

The National Pollutant Release Inventory (NPRI) Program is regulated under the Canadian Environmental Protection Act, 1999 (CEPA), and each facility meeting specified reporting triggers to report their emissions to Environment and Climate Change Canada (ECCC) on an annual basis. An overview of criteria air contaminants (i.e. carbon monoxide (CO), nitrogen dioxide (NO2), sulphur dioxide (SO2), total particulate matter (TPM), particulate matter less than 10 and 2.5 microns in diameter (PM10, PM2.5), and volatile organic compounds (VOCs)) reported from the operation of the White Rose Project from 2011 to 2018 is presented in Table 2-2.

Table 2-2 White Rose Project Criteria Air Contaminant Emissions (NPRI Reporting) for2011 to 2018

YearAir Emissions (tonnes/year)

CO NO2 TPM PM10 PM2.5 VOC

2011 514 2444 139 139 139 217

2012 550 1995 161 161 161 194

2013 780 2618 232 232 232 249

2014 865 2734 261 261 260 260

2015 841 2676 253 253 253 254

2016 602 2567 168 167 167 436

2017 505 2782 130 130 130 422

2018 460 2417 122 121 121 411



Husky strives to minimize air emissions from all its operations to the maximum extent possible and has focused efforts on reducing greenhouse gas emissions from the production phase of its operations (refer to Section 2.7 for more information on Husky’s improvements regarding air emissions and reporting). The principal sources of GHG releases are emissions associated with power generation on the SeaRose FPSO. Table 2-3 shows historical GHG emissions (kt CO2e) from the SeaRose FPSO relative to other large industrial facilities in the province as reported through ECCC’s Greenhouse Gas Reporting Program data. Table 2-4 shows a more detailed account of GHG emissions data from 2018 for the SeaRose FPSO.

Table 2-3 White Rose (SeaRose FPSO) Historical GHG Emissions Relative to NL Large Industry Facility GHG Emissions (2004-2017) (kt CO2e) based on ECCC Greenhouse Gas Emissions Reporting Program Data

‘04 ‘05 ‘06 ‘07 ‘08 ‘09 ‘10 ‘11 ‘12 ‘13 ‘14 ‘15 ‘16 ‘17White Rose (SeaRose

FPSO)- 136 960 646 561 479 437 394 374 514 549 535 446 418

Total Reported NL

Industrial Facilities

5388 5398 4975 5448 5289 4391 4560 4266 4417 4480 4807 4924 5193 5810

% SeaRoseFPSO to Provincial

Total Emissions

2.5 19.3 11.9 10.6 10.9 9.6 9.2 8.5 11.5 11.4 10.9 8.6 7.2

Source: Government of NL, Office of Climate Change 2019a

Table 2-4 Greenhouse Gas Emissions from White Rose (SeaRose FPSO) Reported for 2018 under the Provincial Management of Greenhouse Gas Act

FacilityGreenhouse Gas Emissions (tonnes)

CO2CH4

(CO2e)N2O

(CO2e) Total CO2e

White Rose (SeaRose FPSO) 328,916 21,750 3,089 353,755

Source: Government of NL, Office of Climate Change 2019b



2.7 Environmental Updates and Improvements

2.7.1 Project Improvements in Environmental Performance

Husky Energy is committed to continual improvement in its environmental performance and initiatives and has developed an Environmental Stewardship Program framework for Husky’s White Rose operations to demonstrate continual improvement in managing the environmental aspects of oil and gas production and drilling activities in the White Rose Field.

The environmental performance stewardship program focuses on five key areas:

1. Chemical Management – Minimize or eliminate where possible the discharge of chemicals to the environment

2. Waste Management – Manage the generation, reuse or recycling and disposal of “waste materials”

3. Environmental Incident Management – Mitigate risk of environmental incidents with a goal of zero incidents

4. Compliance Management – Meet, and where possible outperform, compliance targets with all relevant regulatory and corporate requirements

5. Emissions Management - Manage emissions through accurate quantification of emissions measurements and promotion of emissions awareness amongst employees and contractors

In each of these areas, a clear set of reasonable goals, objectives and targets have been developed based on sustainability and business planning within Husky’s operations. Active benchmarking and internal stewardship reporting are used to track performance indicators on a pre-determined timeline. Results are reported to the C NLOPB on an annual basis.

Highlights of technological and environmental performance improvements over the course of the White Rose Project to date are presented below.

Total Fluids Management

Several continuous improvement initiatives have been undertaken in drilling operations for White Rose. Husky’s Total Fluids Management (TFM) approach includes both chemical and mechanical initiatives to reduce the discharge volumes and overall environmental footprint from drilling operations. The TFM approach has facilitated a number of drilling fluid formulation changes and maintenance of the lowest effective concentration (LEC) theory in all mud and completion products along with operational procedural changes. Initiatives under the TFM approach include but are not limited to:

A continual focus on reduction of the LEC of synthetic-based oil to successfully reach well target depth



Replacement of completion wellbore cleaning fluid with an alternative product which demonstrated improved cleaning results and less harmful to the marine environment

Recovery and reuse or recycling of potassium formate brine during completion operations

Biocide Program Review

In 2006 Husky initiated a study to ascertain the LEC of biocide (e.g. glutaraldehyde) necessary to perform adequate biofouling in the SeaRose FPSO slops tanks while minimizing discharge to the environment (this initiative was expanded in 2007 to address the produced water system). In subsequent years, several biocide studies have been undertaken to test the effectiveness of various biocide products in neutralizing sessile and planktonic bacteria. Biocide usage continues to be monitored onboard the SeaRose FPSOto ensure chemical optimization.

Management of Atmospheric Emissions

Since the onset of production, Husky has made improvements in atmospheric emissions management. One of the key areas of focus has been the creation of a robust model for the quantification of greenhouse gas emissions. In 2008, Husky’s senior environmental engineer visited the SeaRose FPSO to collect data and model the emissions sources. The outcome of this is a SeaRose FPSO-specific model that is all inclusive even capturing small emission sources.

In 2020, Husky developed a Leak Detection and Repair (LDAR) program to identify and reduce fugitive emissions. This program exceeds the requirements of the Regulations Respecting Reduction in the Release of Methane and Certain Volatile Organic Compounds (Upstream Oil and Gas Sector) by proactively identifying, monitoring or repairing fugitive emissions from equipment with oil or gas service. Similarly, a halocarbon leak detection program has been established for air conditioning and refrigeration units to ensure that any leaks are repaired in a timely manner.

Development of a Corporate-wide Air Emission Reporting System

In 2006, Husky identified the need to create a corporate-wide Environmental Performance Reporting System (EPRS). In 2009, the air emissions phase was completed. The air emissions component of the 2008 National Pollutant Release Inventory (NPRI) and Statistics Canada’s 2008 greenhouse gas reporting were both completed corporate-wide using EPRS calculated data. Data are now collected both automatically and manually and input into EPRS. The main advantage to a corporate-wide EPRS is reporting consistency across all facilities and the ability to adapt and refine the system as new and improved emissions models become available. These changes can be reflected globally in one system as regulatory reporting requirements change.

Fuel Consumption Management During Supply and Servicing

In 2013, Husky implemented FuelTrax Fuel Management and Monitoring system to conserve fuel and reduce air emissions from its Atlantic operations. FuelTrax records fuel consumption from Offshore Supply Vessels (OSVs) and is designed to measure diesel



consumption per second. As a result, this potentially improves fuel consumption and emissions on transits between port and the offshore field.

Husky has focused on responsible fuel management utilizing the FuelTrax fuel monitoring system to measure and compile real time operational consumption. These operational profiles have led to a reduction in fleet daily consumption from 16.1 m³/day in 2013 to 11.2 m³/day in 2018.

Husky changed its offshore Atlantic fleet configuration in 2017. The Maersk Dispatcher and Atlantic Osprey were replaced with Atlantic Kingfisher and Skandi Vinland. The FuelTrax fuel monitoring system is operational on two vessels, the Green Pilot fuel monitoring system is operational on another and manual reporting is utilized on the remaining term charter vessel. Real-time recording of fuel burn has indicated areas where consumption can be reduced. This has resulted in a six-year average daily fleet fuel consumption reduction of 30%. The fuel management program is now part of normal operations.

In 2019, Husky approved a substitution of a Hybrid diesel electric power management design vessel for a convention power management vessel resulting is approximately a 4 m³/day reduction for a larger more capable vessel. In November 2020 Husky will transition to two vessels on long term charter and both vessels have diesel electric power management systems.

Additionally, several practices have been implemented to reduce fuel consumption, thus reducing air emissions. These include participating in flight sharing (reducing overall number of helicopter flights), effective material planning (to ensure no last-minutedeliveries, allowing supply vessels to travel at economical speeds), and reduction of engines in use by standby vessels during non-operational periods.

Produced Water Management

As described in the White Rose Comprehensive Study (Husky Oil Operations Limited 2000), topside facilities were expected to treat peak produced water of approximately 15,000 to 30,000 m³/d. Produced water was first discharged overboard from the SeaRose FPSO in March 2007. Over this operating period, the average rate of produced water discharges has been 7,897m³ (Figure 2-2). Between 2007 and 2019 there have been three exceedances each of the 24-hour average oil-in-water concentration and 30-day volume weighted average oil-in-water concentration in discharged produced water. Various improvements to the produced water management systems (including monitoring and treatment) have been implemented to help Husky achieve greater accuracy and efficiencies in compliance monitoring, and improved treatment efficiencies and environmental performance. A summary of key initiatives is provided below.



Figure 2-2 SeaRose FPSO Produced Water Discharge

In March 2007, the SeaRose began to process produced water. The initial small volumes presented considerable challenges for removing oil in water to levels below the compliance limits since the hydrocyclones were designed to perform with greater efficiency with larger volumes of produced water. “Off-spec water” (not meeting regulatory requirements for ocean discharge) was diverted to a cargo tank (4P) on the SeaRose FPSO for storage awaiting further treatment.

In 2008, Husky realized produced water volumes were being over-accounted for in their current monitoring and reporting system and implemented an automated system which provided more representative calculations of the actual amount of oil released in the produced water discharges. Also, in 2008, water clarifier trials were carried out in an attempt to improve the quality of produced water discharged from the SeaRose FPSO.The water clarifier worked by coalescing smaller oil droplets together to form larger droplets which are more easily separated from produced water within the produced water handling system. Trial results were positive, showing the clarifier was successful in reducing the amount of oil discharge in produced water; the clarifier has remained in use since the trial.

In 2009, the injection point for the water clarifier was relocated further upstream in the production system to allow for a greater reaction time and allow for further cleaning of the



produced water. Also, in 2009, an Advanced Sensors oil in water sensor was installed to the discharge line of the produced water system, allowing the control room operator to more accurately determine changing trends in produced water oil-in-water and to manage accordingly.

In 2011, Husky commissioned an environmental risk analysis (DeBlois 2011) to investigate the effect of increased produced water discharges at White Rose. Six alternative treatment simulations were performed, with varying concentrations of biocide added to the cargo tank #4, the addition of a clarifier, and the alternative of re-injection (with produced water being discharged only 17% of the time). The analysis indicated that overall environmental risk was reduced with reductions in biocide concentration to the cargo tank containing the produced water. Organic compounds in produced water (particularly those with higher molecular weight) had also substantially contributed to environmental risk (DeBlois 2011).

In 2012, an oil droplet analyzer was installed on a trial basis upstream and downstream of the hydrocyclones to determine oil droplet size distribution and investigate if the hydrocyclones could be optimized to enhance produced water treatment performance. However, in 2012 it was also noted that hydrocyclone performance had improved with an increase in water rate and oil droplet size.

In 2017, visual produced water checks by offshore laboratory technicians on the SeaRose FPSO were added to the produced water monitoring program, giving technicians the ability to check water quality more frequently between lab samples, resulting in earlier detection of “off-spec water”.

In 2018, Husky initiated the investigated the use of a new demulsifier in the production separators with the aim of gaining a more efficient separation of oil and water in the production process and reducing oil in water concentration in discharged produced water.

Solid Waste Reduction

Various solid waste reduction initiatives have been implemented thus far over the life of the White Rose Project including waste reduction initiatives undertaken by caterers (e.g. reduction of disposables use, change in product procurement to reduce packaging) and waste management contractor (e.g. processing of drilling muds to enhance removal of solids from liquids prior to disposal thereby reducing the volume of drill mud solids being transported and placed in engineering landfills).

Future Opportunities

Per the C-NLOPB Offshore Related Report Measures to Protect and Monitor Seabirds in Petroleum-Related Activity in the Canada-Newfoundland and Labrador Offshore Area1,Husky will investigate opportunities to reduce the horizontal transmission of safety lightingand flaring onboard the SeaRose FPSO.

1 https://www.cnlopb.ca/wp-content/uploads/news/measuresseabirds.pdf



2.7.2 Mitigation and Monitoring Program Updates

Mitigative measures identified in the White Rose Comprehensive Study (Husky Oil Operations Limited 2000) and New Drill Centre EA (LGL 2006) have since evolved due to an improved understanding of environmental effects and mitigation effectiveness, stakeholder feedback, and changes in regulatory requirements. Husky’s Environmental Protection and Compliance Monitoring Plan for the SeaRose FPSO describes environmental protection measures and compliance monitoring requirements for production operations. This document is reviewed at least every three years and updated accordingly to capture changes in mitigation and monitoring.

Husky’s Environmental Effects Monitoring (EEM) program is a field sampling program implemented every two years to assess potential effects from the White Rose Development on Fish and Fish Habitat. The original monitoring program was designed based on EA predictions in the White Rose Comprehensive Study (Husky Oil Operations Limited 2000), supporting modelling studies, and input from stakeholders, regulatory agencies and an expert advisory group. Program reports are reviewed after each EEM cycle, with program design modifications possible based on regulatory feedback. The EEM program has also been updated to examine predictions in the New Drill Centre EA (LGL 2006). To date, the EEM program has demonstrated that effects from the White Rose Development on Fish and Fish Habitat are within EA predictions. More detailed information on EEM results can be found in Section 4.2.

In addition to the White Rose EEM program and compliance monitoring, Husky conducts a seabird monitoring program as per the Eastern Canada Seabirds at Sea (ECSAS) protocol (Gjerdrum et al. 2012). This monitoring program is in addition to the stranded bird monitoring which was recommended in the White Rose Comprehensive Study (Husky Oil Operations Limited 2000) and which requires Husky to hold a scientific permit to collect dead migratory birds and capture, transfer or release live migratory birds that land on the SeaRose FPSO and vessels. Further detail on the seabird monitoring program and seabird handling is provided in Section 4.3.1.

Improvements in oil spill response planning since 2000 are discussed in Section 5.0.

2.7.3 Studies Conducted Since the Original White Rose Comprehensive Study

In addition to the New Drill Centre EA (LGL 2006) EA Addendum (LGL 2007), annual EA Reviews (Husky Energy 2008, 2009a, 2010, 2011a, 2012, 2013a, 2014, 2015, 2016,2017a, 2019a) and EEM reports (Husky Energy 2005, 2006, 2007, 2009b, 2011b, 2013b, 2017b) which are specific to the White Rose field, Husky has funded and/or participated in several studies which have contributed to improving the understanding of environmental effects from oil and gas production and effectiveness of mitigation. These include but are not limited to Environmental Studies Research Funds (ESRF) and the Program of Energy Research and Development (PERD) research projects. As a producing operator, Husky has contributed to ESRF studies since the mid-2000s and currently has representation on the management board. Examples of these relevant studies are listed below:

Source Apportionment of Volatile Organic Compounds and Aerosols on Sable Island (Gibson and Craig 2018);



Acoustic Monitoring Along Canada's East Coast: August 2015 to July 2017 (Delarue et al. 2018);

Effectiveness of Observers in Visually Detecting Dead Seabirds on the Open Ocean (Fifield et al. 2017);

Biodegradation of Naturally and Chemically Dispersed Crude Oils and Scotian Shelf Condensate from Atlantic Canada (National Research Council Canada and Centre for Offshore Oil, Gas and Energy Research 2015);

Refinement and Validation of Numerical Risk Assessment Models for use in Atlantic Canada (Niu and Lee 2013);

Biological Effects of Produced Water from Offshore Canadian Atlantic Oil and Gas Platforms on Various Life Stages of Marine Fish (Courtenay et al. 2013);

Effects of Offshore Oil and Gas Production on Air Quality in Canada’s East Coast Offshore Areas (Stantec 2013). This study by the Environmental Studies Research Fund (ESRF) addressed NOx emissions from offshore installations, including the SeaRose FPSO, and is relevant for the Multi-sector Air Pollutant Regulations.

Proceedings of the International Produced Water Conference: Environmental Risks and Advances in Mitigation Technologies (Lee and Neff 2011);

Environmental Risk Analysis for White Rose Produced Water: Quantification using the Environmental Impact Factor (EIF) (DeBlois 2011);

An Integrated Approach to Oil Spill Preparedness and Response (Newfoundland and Labrador Environmental Industry Association (NEIA) with Leslie Grattan & Associates and The Institute for the Advancement of Public Policy, Inc. 2010);

Effects of Sheens Associated with Offshore Oil and Gas Development on the Feather Microstructure of Pelagic Seabirds (O’Hara and Moradin 2010);

Modelling Seabird Oil Spill Mortality Using Flight and Swim Behaviour (Fifield et al. 2009a);

Offshore Seabird Monitoring Program (Fifield et al. 2009b);

Environmental Persistence of Drilling Mud and Fluid Discharges and Potential Impacts (Centre for Offshore Oil, Gas and Energy Research 2009);

Cuttings Treatment Technology Evaluation (Jacques Whitford Stantec Limited 2009);

A Rhodamine Dye Study of the Dispersion of Produced Water Discharged from the Terra Nova FPSO. Prepared for Petro-Canada, St. John’s, NL (Lorax Environmental 2006a); and,



Calibration and Validation of a Numerical Model of Produced Water Dispersion at the Terra Nova FPSO. Prepared for Petro-Canada, St. John’s, NL (Lorax Environmental 2006b).

3.0 STAKEHOLDER CONSULTATION AND ENGAGEMENT

As part of its on-going operations and activities associated with the White Rose Operations, Husky consults regularly with relevant individuals and stakeholders (One Ocean) through existing and relevant forums. (such as the One Ocean initiative) and conducts additional and specific engagements with applicable persons and groups if and as particular issues and requirements arise. Details on the purpose of this EA revalidation report was communicated to One Ocean and FFAW on February 20, 2020. No issues or concerns were raised.

4.0 ENVIRONMENTAL EFFECTS ASSESSMENT REVALIDATION

4.1 Overall Approach

The White Rose Comprehensive Study (Husky Oil Operations Limited 2000) provided a detailed overview of the existing (baseline) environment within and around the proposed Project Area and associated EA Study Area (nearshore and offshore environments). This description focused on relevant aspects of the existing physical, biological and socioeconomic environments in these areas, based on information available as of the time of comprehensive study development and submission.

The sections that follow provide a brief, summary update of that description of the existing environmental setting for the offshore Project Area and Study Area, including the relevant Valued Environmental Components (VECs) that were considered in the White Rose Comprehensive Study (Husky Oil Operations Limited 2000), and subsequent New Drill Centre EA (LGL 2006, 2007) namely:

Fish and Fish Habitat

Marine Birds

Marine Mammals and Sea Turtles

Fisheries

Detailed existing environment information and analysis are provided in the White Rose Comprehensive Study (Husky Oil Operations Limited 2000), New Drill Centre EA (LGL 2006, 2007), and subsequent amendments and updates (the most recent being 2019). The descriptions in this EA revalidation report do not repeat all the detailed information and analysis but focus on those environmental components which are considered particularly relevant to on-going environmental planning and management related to the Project, and especially, to the proposed modification of the timeline for the Project that is being addressed through this report.



In addition, two additional VECs have been considered in this EA revalidation report:

Special Areas

Species at Risk

As these VECs were not addressed in the previous EAs as stand-alone components, these sections are more detailed to serve as complete sections rather than updates to the previous EAs.

This EA revalidation provides an analysis and discussion of any implications of the proposed temporal extension of White Rose Project (see Chapter 2) in the context of the previous environmental effects analysis, associated mitigation, residual effects significance determinations, and thus the overall findings and conclusions of the previous EAs and associated updates. For each VEC, there is a summary of new relevant baseline information, the summary of the findings of the previous EAs, verifications of those EA findings, and conclusory statement of whether the previous EA finding(s) are still valid in light of the temporal changes to the project scope. Where relevant, the Environmental Effects Assessments tables for each VEC are reproduced here and based on the previous assessments related to the project (Husky Oil Operations Limited 2000; LGL 2006, 2007). The tables are slightly modified to incorporate only the production phase of the project andactivities considered ‘not applicable’ in previous assessments (Husky Oil Operations Limited 2000, LGL 2006) are not carried forward.

In the original EAs, several criteria were taken into account when evaluating the nature and extent of environmental effects. These criteria included:

Magnitude - nature and extent of the environmental effect for each activity;

Geographic extent - the area affected by the project;

Duration and frequency - how long and how often a project activity and/or environmental effect will occur;

Reversibility - the ability of a VEC to return to an equal, or improved condition, at the end of the project life cycle; and,

Ecological, socio-cultural and economic context - the current status of the area affected by the project in terms of existing environmental effects.

An effect was considered significant, not significant, or positive. A significant effect was defined as “having a high magnitude or medium magnitude for a duration of greater than one year and over a geographic extent greater than 100 km²”, where medium magnitude was defined as "affecting 10 to 25 percent of individuals in the affected area. Effects can be outright mortality, sublethal or exclusion due to disturbance", and high magnitude as "affecting more than 25 percent of individuals in the affected area. Effects can be outright mortality, sublethal or exclusion due to disturbance"2.

2 Low magnitude was defined as “Affecting 0 to 10 percent of individuals in the affected area”.



4.2 Fish and Fish Habitat

The overall presence, distribution and abundance of marine species and any important habitats in the Offshore Project and Study Areas are summarized in the White Rose Comprehensive Study (Husky Oil Operations Limited 2000), the New Drill Centre EA (LGL 2006), and subsequent amendments and updates (the most recent being 2019). Most of these reports include information on relevant life history characteristics. These species and habitat form the basis of the marine ecosystem, and support fisheries which have commercial, historical and recreational importance.

4.2.1 Summary of Key Updates for Fish and Fish Habitat

The biggest changes in the existing environment since the White Rose Comprehensive Study (Husky Oil Operations Limited 2000) has been an increased understanding of the shift in the population dynamics of many long-lived groundfish (Pedersen et al. 2017), invertebrate species such as shrimp and snow crab (Koen-Alonso et al. 2010; Dawe et al.2012; Nogueira et al. 2016) and primary production (Greene et al. 2013; Trenkel et al. 2014). Researchers have a better understanding in recent years of how the trophic and assemblage structure in the Project Area’s ecosystem has been changing as a result of anthropogenic (e.g. fishing, climate change) and environmental (e.g. water chemistry, temperature changes) disturbances (Frank et al. 2005; Koen-Alonso et al. 2010; Devine and Haedrich 2011; Dawe et al. 2012).

The most recent regime shift in the Northwest Atlantic occurred in the late 1980s to early 1990s, that lead to unfavourable conditions for groundfish species such as cod and redfish, and favourable conditions for invertebrate species such as shrimp and snow crab (deYoung et al. 2004; Koen-Alonso et al. 2010; Dawe et al. 2012). The eventual collapse of the groundfish stocks were attributed to fishing pressure and colder environmental conditions (Koen-Alonso et al. 2010; Nogueira et al. 2016; Pedersen et al. 2017) that favoured invertebrate species such as snow crab and shrimp (Dawe et al. 2012). For many invertebrates, the collapse of groundfish stocks and associated release from predation, further augmented their abundance (Dawe et al. 2012, Nogueira et al. 2016, Pedersen et al. 2017). Capelin, an important prey species along the Newfoundland Shelf, declined during this period due to changes in phytoplankton, nutrients, sea ice, and water temperatures, which forced species like cod to rely more heavily on lower quality prey such as shrimp (Buren et al. 2014; Mullowney and Rose 2014; Buren et al. 2019).

The new regime, dominated by invertebrates, was maintained along the Newfoundland Shelf despite a refocus of fishing effort toward shrimp and crab and a great reduction in groundfish fishing activity (deYoung et al. 2004; Pedersen et al. 2017). Currently, oceanographic conditions are shifting to favour groundfish, which is coinciding with reports from fishermen and scientists (Koen-Alonso et al. 2010; Templeman 2010; Dawe et al.2012) regarding associated declines in snow crab and signals that some groundfish species are showing signs of recovery (Pederson et al. 2017). These changes demonstrate the dynamic nature of the ecology of the Project Area and underscore the need for adaptive management in this climate sensitive ecosystem, particularly when climate effects in the northwest Atlantic are expected to be elevated relative to other areas (Greene et al. 2008).



4.2.2 Summary of Effects Analysis from Previous EAs

Table 4-1 lists the key interactions with production phase project activities assessed for Fish and Fish Habitat were related the presence of structures and marine discharges (Husky Oil Operations Limited 2000; LGL 2006). With the exception of the potential positive effects of the presence of project structures (reef and refuge effects), the residual effects of the various project activities associated with the development and production phases on fish and fish habitat were assessed as adverse but negligible to low in magnitude and determined to be not significant. (Husky Oil Operations Limited 2000; LGL 2006).

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4.2.3 Verification of EA Predictions

The White Rose EAs provided a review of available information on the potential effects of various project activities and then used weight-of-evidence and professional judgment to assess the overall effects of White Rose on fish and fish habitat (see Table 4-1). As noted in Section 4.2.2, residual effects of the various project activities on fish and fish habitat were assessed as adverse but negligible to low in magnitude. Overall, effects on fish and fish habitat were assessed as not significant. To verify EA predictions, Husky designed an Environmental Effects Monitoring (EEM) program that examined potential effects on two commercial fish species, and sediment and water quality, as components of fish habitat. Measured environmental variables, or tests, within each component (see Figure 4-1) were not all specifically addressed in the EAs. Environmental variables or tests were selected to provide warning of potential effects on fish and fish habitat (see the original EEM program design document (Husky Energy 2004) for details on variable and test selection).

Notes: BTEX: benzene, toluene, ethylbenzene, xylene; PAH: polycyclic aromatic hydrocarbons; TSS: total suspended solids

Figure 4-1 Measured Environmental Variables, or Tests, within EEM Program Components (from Husky Energy 2017b)



Like the EAs, the EEM program adopts a weight-of-evidence approach, here coupled with an analysis of results within the individual components to assess overall effects on fish and fish habitat. The EEM program was first approved for implementation by the C-NLOPB in July 2004, with Baseline Collections in 2000 and 2002. The program is currently conducted every two years. Eight collection and reporting cycles were conducted from 2004 to 2016 (the report on the 2018 cycle is not yet public). Program results are summarized below, with individual EEM reports available at www.cnlopb.ca/environment /projects/#whiterose. When specific predictions about the environmental variables or tests used in the EEM program were provided in the EAs, they are discussed below. Otherwise, a more general discussion is provided. Overall, EEM results have been consistent with the EA prediction of no significant effect on fish and fish habitat.

EEM Summary

There has been little evidence of effects of production operations on sediment physical and chemical characteristic, over and above the evidence of effects of drilling. The White Rose EAs predicted that development activities, through discharge of drill cuttings, would to alter sediment characteristics. The initial drill cuttings modelling study for White Rose (Hodgins and Hodgins 2000) indicated that cuttings and associated drill mud-on-cuttings could extend to approximately 9 km from source, with the highest deposition near source. To date, clear evidence of drilling-related alterations in sediment hydrocarbon and barium concentrations (the main constituents of drilling muds used at White Rose) have been noted in all EEM years (Figure 4-2). Weak evidence of drilling-related alterations have been noted for other sediment physical and chemical characteristics. Results have been consistent with drill cuttings model predictions. There has also been a decrease in alterations to sediments, potentially associated with the decline in drilling activity at the centre of the White Rose field since 20083. Low levels of BTEX or PAHs, which could have originated from production rather than drilling operations, were detected in sediments at 0 to 5% of stations in any given sampling year. In baseline, low level PAHs were detected at 2% of stations4. The baseline proportion has not been exceeded in any EEM year except in 2010 when low level PAHs were detected at 5% of (or 3) stations. These results provide little to no evidence of effects of production operations on sediments, nor do they indicate any accentuation of potential effects since the proportion of stations with detectable levels of PAHs or BTEX in subsequent EEM years range from 0 to 1% of stations. EEM results are consistent with EA predictions on effects of development drilling and production operations. Results indicate that drilling effects occurred within predicted levels, with little evidence of effects from production operations. The anticipated alterations to sediment characteristics were predicted to have no significant effect on fish and fish habitat.

3 Based on Section 4 of the 2016 EEM program report (Husky Energy 2019b), 8,632 metric tonnes of synthetic-based cuttings were discharged at the Central and Southern drill centres (combined) from 2003 to 2008; and 2,322 metric tonnes were discharged from 2009 to 2016.

4 Here and elsewhere, results are presented as percentages because the number of stations varied across years.



Figure 4-2 EEM Results Summary

A prediction specific to sediment toxicity was not provided in the White Rose EAs. Laboratory toxicity tests are a proxy for potential effects in-situ. From 2004 to 2016, only 2% and 5% of samples have been toxic to Microtox and Laboratory amphipods, respectively, and the association between these responses and project activities has seldom been clear (Figure 4-2). In 2008, sediments from 11 stations were classified as toxic to amphipods. All stations were near drill centres and those stations had elevated levels of drill mud constituents. In 2016, samples from two stations were toxic to Microtox, and drill mud constituents were elevated at those stations. Of the two 2016 stations, one was near an exploration well and the other was near a development well. None of the sediments showing toxic responses had detectable levels of BTEX or PAHs, which might result from produced water or other operational discharges. This further supports the argument that drilling, rather than production, has a greater influence on Sediment Quality. Overall, sediments at White Rose have been predominantly non-toxic. The majority of toxic samples were noted in 2008, with no increase in toxicity in subsequent EEM years. These results support the EA prediction of no significant effects on fish and fish habitat.

As was the case above, effects on benthic invertebrates were predicted to result primarily from development drilling rather than production operations. For benthic invertebrates, effects were predicted to be low to high in magnitude and medium duration within a few hundred metres of the drilling sites, and low in magnitude and short duration within 1 km2.Overall, effects on benthic invertebrates were predicted to be low in magnitude and short

2004 2005 2006 2008 2010 2012 2014 2016

Project effects, or potential project effects, within predicted levels Weak evidence of project effects, within predicted levelsEffect of note but with no clear association with the projectNo detectable effect

1

2

3

Particle size, organic carbon, metals other than barium, sulphur, sulphide, and ammonia were weakly affected in some EEM years.

Exceedances to EA predictions for benthic invertebrates were reported in earlier EEM years. However, a by-drill-centre examination of results indicated that the compounding effects of drill centres in close proximity led to an overestimated the spatial extent of effects (for details see Husky Energy 2011, or the Sediment Component Section, above).

No information is provided for the Water Quality Component prior to 2010 because that component was first implemented in 2010 subsequent to the release of produced water.

EEM YearResponse Variable

Sediment

Water ³

Commercial Fish

EEMComponent

Laboratory amphipod survival

Seawater physical and chemical characteristicsAmerican plaice and snowcrab metals and hydrocarbon body burden

American plaice and snow crab taste tests

Fish health indices on American plaice

Hydrocarbons

Barium

Other physical and chemical variables ¹

Benthic community structure ²

Bacterial luminescence (Microtox)



duration, with small areas experiencing low to high magnitude effects (Husky Oil Operations Limited (2000)). Exceedances to the EA prediction for benthic invertebrates were reported in earlier EEM years, with relatively high magnitude effects to greater distances than predicted. However, a by-drill-centre examination of results indicated that the compounding effects of drill centres in close proximity led to an overestimate of the spatial extent of effects (see Husky Energy 2011b for details). More recent EEM results indicate that effects are getting more localized, consistent with the decrease in drilling at the centre of the White Rose development, and consistent with the prediction that effects on benthos should be related primarily to development operations. Whether from development or production operations, effects on benthos have been consistent with EA predictions, and results support the assessment of no significant effect on fish and fish habitat

Whereas the Sediment Quality portion of the White Rose EEM program predominantly targets drilling effects, the Water Quality portion of the program targets potential effects of produced water and other liquid discharges on fish and fish habitat. Very localized and short duration alterations to water quality were anticipated as a result of project activity in the EAs. No project related change in overall water quality has been detected in any EEM years. There has been infrequent detection of some produced water constituents at some stations near the SeaRose FPSO, consistent with EA predictions. Low levels of BTEX or PAHs, which could have resulted from release of produced water, were noted at 6 to 11% of stations from 2012 to 2014 (occurrences were 11% in 2012, 6% in 2014 and 11% in 2016; and all stations were located at approximately 300 m from the SeaRose FPSO5). However, BTEX or PAHs also were detected at 15% of stations in 2000 (baseline). Therefore, any effect on water quality from project activity has been minor. There has also been no increase in detection of BTEX or PAHs at near-field stations from 2012 to 2014. Effects on water quality are consistent with the EA predictions and these effects were predicted to have no significant effect on fish and fish habitat.

The Commercial Fish portion of the White Rose EEM program targets indirect project effects through effects on habitat and direct effects through exposure to physical or chemical stressors. The White Rose EAs predicted that effects on fish resulting from project activities would be negligible. Results have been consistent with EA predictions. Taste tests on American plaice and snow crab have not revealed the presence of taint, and body burden assessment has not indicated tissue contamination in any EEM year. Finally, assessment of a variety of health indices for American plaice indicated that the health of this species has been similar between the White Rose Study Area and the Reference Areas.

All components of the White Rose EEM program are consistent with EA predictions and indicate no significant effect on fish and fish habitat. Effects of drilling operations on Sediment Quality have been clear. Any effect of production operations have been subtle. Other than the expected increase in effects on Sediment Quality at the beginning of drilling operations, there has been no accentuation of effects since approximately 2008; andrecent EEM results indicate an improvement (see Husky Energy 2017b). No temporal

5 Water collections were also performed in 2008 and 2010, after release of produced water. However, those two preliminary sampling programs did not include 300 m stations and no BTEX or PAHs were noted in those years.



trends were noted for other EEM components because there was little evidence that these were affected by project activity.

4.2.4 Implications of Project Extension

As indicated above, the effects of drilling operations on sediment quality are clear and any effects of production operations have been subtle. The project extension primarily relates to production operations as further development drilling within the existing drill centres will be limited as the West White Rose Platform comes online.

The modifications to the project relate only to the extension of the project life to 2036. This modification pertains to the operational phase. The evaluation criterion that is most affected by this modification is the predicted duration of effects since operational activities may extend to 2036.

The proposed modification to the project timeline do not result in any changes in the original environmental effects predictions, required mitigation or effects significance evaluations for Fish and Fish Habitat. The WR ALE is therefore not likely to result in a significant adverse environmental effect on Fish and Fish Habitat.

Furthermore, the continued execution of the EEM program will further validate the EA predictions and confirm that the temporal extension of the project will not result in new effects on Fish and Fish Habitat.

4.3 Marine Birds

Species that spend extended periods of time in the marine environment are considered marine birds, including seabirds, waterfowl and shorebirds. Certain migratory terrestrial birds may be also associated with coastal habitats or migrate nocturnally over marine waters. In the offshore environment of the Project Area and Study Area, seabirds are the most numerous marine birds, and are therefore the primary focus of this section. The White Rose Comprehensive Study (Husky Oil Operations Limited 2000) and Eastern Newfoundland Strategic Environmental Assessment (C-NLOPB 2014) summarized the distribution and abundance of marine-associated avifauna in the Offshore Study Area and described relevant life history characteristics, areas and times of particular significance to birds that are found within or in proximity to this region. Other existing and available sources such as the current Eastern Canadian Seabirds at Sea (ECSAS) dataset (up to 2017), records from the Atlantic Canada Shorebird Survey (ACSS), recent exploration drilling EISs for other offshore Newfoundland sites, and other available literature and datasets that provide additional information and insights on key species, times and locations.

As key components and indicators of ecosystem health, seabirds are often considered to be of high intrinsic ecological importance. Further, they are of socioeconomic importance in Newfoundland and Labrador both in terms of tourism and as a food source. A diverse assemblage of seabirds can be found in the marine waters off Eastern Newfoundland at all times of year, including gannets, phalaropes, large gulls, kittiwakes, terns, alcids (auks), jaegers and skuas, fulmars, petrels and shearwaters. Fifield et al. (2009b) explored seasonal trends in abundance of seabirds off eastern Canada and found that the largest concentration of seabirds in the offshore waters of the Study Area was from March to



August, while seabirds were least abundant in the area in September to October. Figure 4-3 summarizes the seasonal presence of seabirds in the Study Area (Nexen Energy,2018).

Figure 4-3 Seasonal Presence of Seabirds in Eastern Newfoundland Offshore Area

4.3.1 Summary of Key Updates for Marine Birds

A large and concerning trend in Marine Birds is the decline in populations. Most seabirds are long-lived species with low fecundity, delayed recruitment and relatively low rates of population growth, so the implications of reduced adult survival rates are long-lasting. Globally, seabird populations have declined, with some studies estimating a 69.7% decline between 1950 and 2010 (Paleczny et al. 2015) and 29% of species at some risk of extinction (Spatz et al. 2014).

More specifically, the trends for Northwest Atlantic seabird populations are mixed (DFO 2018a). Some general trends of Northwest Atlantic seabird populations from DFO (2018a)include:

Populations of the Alcidae family (e.g. Common Murres, Atlantic Puffins) have grown

Northern Gannet populations have grown since the 1970s

Populations of surface-feeding species (e.g. Black-legged Kittiwakes, Leach’s Storm-petrels) have decreased since the 1990s

Most species of seabirds in the Northwest Atlantic are of modest conservation concern

Jan Feb Mar Apr May Jun Jul Aug Oct Nov DecAtlantic PuffinBlack GuillemotBlack-legged KittiwakeCommon MurreCormorants (Great, Double-crested)DovekieFulmars and ShearwatersIvory Gull ¹Jaegers and SkuasLarge GullsNorthern GannettPhalaropesRazorbillStorm PetrelsTernsThick-billed MurreNotes: 1 Denotes species at risk

Absent in Study AreaScarce in Study AreaPresent in Study AreaCommon in Study AreaFlightless birds (dependent young and/or moulting adults) at sea, potentially in study area

Sep



Of particular concern in recent years is the decline of the Leach’s Storm-petrel populations in the Northwest Atlantic. While not a federally protected Species At Risk (SAR), the Leach’s Storm-petrel has recently been designated as Vulnerable by the International Union for Conservation of Nature (IUCN) due to population declines that are thought to be attributable to a number of factors including predation, ingestion of marine contaminants such as mercury, collisions and strandings due to attraction to lighted structures, andcontact with hydrocarbons (BirdLife International 2017). In Atlantic Canada, four of seven Leach’s Storm-petrel colonies have shown declines in recent years; the largest, Baccalieu Island, has declined by 42% between 1985 and 2013 (Wilhelm et al. 2019; Wilhelm et al.2015). The Leach’s Storm-petrel is known to be highly attracted to anthropogenic light sources and tracking studies have shown that they can make foraging trips of over 1000 km during the breeding season (Pollet et al. 2014), two factors which make this species particularly vulnerable to anthropogenic activities in the offshore environment. The Leach’s Storm-petrel is the species most frequently found stranded on platforms and vessels in and near the Study Area (Ellis et al. 2013; Baillie et al. 2005), with the vast majority of strandings occurring in September and October, following the departure of fledglings from nearby breeding colonies (Baillie et al. 2005).

Husky is required under the Migratory Birds Convention Act to retain a scientific permit to handle seabirds that are encountered on installations and vessels. A Seabird Handling Procedure was created in 2005 to provide offshore personnel with safe protocols for handling seabirds. The procedure was recently revised to incorporate ECCC-CWSguidance provided in the Procedures for Handling and Documenting Stranded Birds Encountered on Infrastructure Offshore Atlantic Canada (ECCC 2017). A requirement of this permit is to report annually to ECCC-CWS the number of encounters categorized as dead (oiled, disposed of at sea or sent ashore) or captured alive (as oiled and either died in care or sent ashore, or not oiled and released alive, died in care or sent ashore). Since 2007, twelve species of seabirds have been identified, totaling 789 encounters. Of these 789 encounters, 705 were Leach’s Storm-Petrels where 564 were captured and released following the ECCC (2017) storm-petrel handling protocol6. 129 were reported dead and 12 were sent ashore. On average 43 storm-petrels are captured and released annually.Terrestrial birds are also identified offshore and since 2007, there have been 17 species identified, including an American bittern, a peregrine falcon, snowy owls a night heron, a pine grosbeak, a ruby-crowned kinglet, a common redpoll, warblers and sparrows.

Along with recent updates regarding population trends, our understanding of marine bird population dynamics has advanced since 2000. A stronger correlation between oceanographic conditions and bird growth and reproductive success, with corresponding changes in seabird populations, means that population trends are a good indicator of change in marine ecosystems (Paleczny et al. 2015). For example, a positive relationship was found between Province-wide groundfish landings and the number of breeding Great Black-backed Gulls (Wilhelm et al. 2016).

Husky conducts seabird observations three-times daily from either the SeaRose FPSO,drilling platforms or supply vessels following the stationary platform methodology described in the Eastern Canada Seabirds at Sea protocol (Gjerdrum et al. 2012). Between 2006 and 2019, over 9600 observation periods resulted in 73,363 birds identified. However, not all observation periods resulted in birds being identified. In 2019, a total of

6 ECCC (2017) superseded Williams and Chardine (1999)



739 bird observations recorded 5310 individual birds. There were 223 observation periods in which no birds were observed. On 76 occasions, observations could not be made dueto weather-related visibility, whereas on 6 occasions observations were not made due to vessel activity or obstructions. The most frequently sighted bird was the Herring Gull (2189 sightings of individuals), followed by the Glaucous Gull (883 sightings of individuals) and the Northern Fulmar (637 sightings of individuals). Reports and data from this observation program are submitted annually to the C-NLOPB via Annual Environmental Data Summary Reports.


Table 4-2 lists the key interactions with production phase project activities assessed for Marine Birds. Key interactions were related to the presence of structures; lights and flares; marine discharges; and use of helicopters (Husky Oil Operations Limited 2000; LGL 2006). Residual effects were assessed as adverse but negligible to low (moderate for certain species, particularly Leach’s Storm-petrel) in magnitude, and were determined to be not significant.

Whi

te R

ose

Asse

t Life

Ext

ensi

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Envi

ronm

enta

l Ass

essm

ent R

eval

idat

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AR-H

SE-R

P-16

45, R

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Page

38

of 3

9

Tabl

e 4-

2VE

C E

ffect

s As

sess

men

t Sum

mar

y, M

arin

e B

irds

(Pro

duct

ion

Phas

e); m

odifi

ed fr

om H

usky

Oil

Ope

ratio

ns L

imite

d (2

000)

and

LG

L (2

006)

Proj

ect A

ctiv

ity

Pote

ntia

l Po

sitiv

e (P

) or

Neg

ativ

e (N

) En

viro

nmen

tal

Effe

ct

Miti

gatio

n

Eval

uatio

n C

riter

ia fo

r Ass

essi

ng E

nviro

nmen

tal E

ffect

s

Mag

nitu

deG

eogr

aphi

cEx

tent

Freq

uenc

yD

urat

ion

Rev

ersi

bilit

yC

onte

xt

Pres

ence

of S

truct

ures

Surfa

ce

Stru

ctur

esAt

tract

ion

(N);

Mor

talit

y (N

)

Rel

ease

Stra

nded

Bi

rds,

Adh

ere

to

Han

dlin

g Pr

otoc

ols

0-1

26

5R

2

Ligh

tsAt

tract

ion

(N)

Dai

ly s

yste

mat

ic

sear

ches

for d

ead/

st

rand

ed b

irds.

Rel

ease

Stra

nded

Bi

rds,

Adh

ere

to

Han

dlin

g Pr

otoc

ols

12

65

R2

Flar

esM

orta

lity

(N)

Min

imiz

e Fl

arin

g,

Parti

cula

rl y a

t nig

ht1

22

5R

a2

Dis

char

ges

Prod

uced

Wat

erEf

fect

s on

Hea

lth

(N)

Trea

tmen

t0

11

5R

2

Coo

ling

Wat

erEf

fect

s on

Hea

lth

(N)

Trea

tmen

t0

16

5R

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Dec

k D

rain

age

Effe

cts

on H

ealth

(N

)Tr

eatm

ent

01

25

R2

Bilg

e W

ater

Effe

cts

on H

ealth

(N

)Tr

eatm

ent

01

25

R2

Sani

tary

&

Dom

estic

Was

te

Nut

rient

s (P

); In

crea

sed

Pred

atio

n (N

)Pr

imar

y Tr

eatm

ent

12

65

R2

Atm

osph

eric

Dis

char

ges

Atm

osph

eric

Em

issi

ons

Effe

cts

on H

ealth

(N

)Eq

uipm

ent D

esig

n0

16

5R

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Traf

ficSu

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t Ves

sels

bD

istu

rban

ce (N

)Av

oid

Col

onie

s0

46

5R

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Hel

icop

ters

bD

istu

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ce (N

); M

orta

lity

(N)

Avoi

d C

olon

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& R

epea

ted

Ove

rflig

hts

of

Bird

Con

cent

ratio

ns1

44

5R

2

Noi

seFP

SOD

istu

rban

ce (N

)0

26

5R

2Su

ppor

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sels

Dis

turb

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(N)

Avoi

d C

olon

ies

04

65

R2

Hel

icop

ters

Dis

turb

ance

(N);

Mor

talit

y (N

)

Avoi

d C

olon

ies

& R

epea

ted

Ove

rflig

hts

of

Bird

Con

cent

ratio

ns1

44

5R

2

Whi

te R

ose

Asse

t Life

Ext

ensi

on

Envi

ronm

enta

l Ass

essm

ent R

eval

idat

ion

AR-H

SE-R

P-16

45, R

ev 3

Page

39

of 4

0

Mag

nitu

de

0=

Neg

ligib

le1

= Lo

w2

= M

ediu

m3

= H

igh

Freq

uenc

y1

= <

11 e

vent

s/ye

ar2

= 11

-50

even

ts/y

ear

3=

51-1

00 e

vent

s/ye

ar4

= 10

1-20

0 ev

ents

/yea

r5

= >

200

even

ts/y

ear

6=

Con

tinuo

us

Rev

ersi

bilit

yR

= R

ever

sibl

e (W

ill re

cove

r to

base

line)

I=

Irrev

ersi

ble

(Per

man

ent)

Geo

grap

hic

Exte

nt:

1=

< 1

km²

2=

1-10

km

²3

= 11

-100

km

²4

= 10

1-10

00 k

m²

5=

1001

-10,

000

km²

6=

> 10

,000

km

²

Dur

atio

n1

= <

1 m

onth

2=

1-12

mon

ths

3=

13-3

6 m

onth

s4

= 37

-72

mon

ths

5=

> 72

mon

ths

Con

text

(Eco

logi

cal/S

ocio

-cul

tura

l and

Eco

nom

ic)

1=

Rel

ativ

ely

pris

tine

area

or a

rea

not a

dver

sely

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cted

by

hum

an a

ctiv

ity2

= Ev

iden

ce o

f exi

stin

g ad

vers

e ef

fect

sN

A =

Not

App

licab

le

a=

Effe

cts

of in

divi

dual

s irr

ever

sibl

e, b

ut a

ny p

opul

atio

n ef

fect

s ar

e lik

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reve

rsib

leb

= Ef

fect

s of

noi

se c

onsi

dere

d he

re




As described in Section 4.3.1 appropriate programs and protocols for the collection and release of stranded seabirds have been implemented in accordance with the Environment and Climate Change Canada-Canadian Wildlife Service (ECCC-CWS). As part of these protocols and as required by the ECCC-CWS Scientific Permit, Husky has documentedand reported, on an annual basis, a summary of stranded and/or seabird handling occurrences. The information collected on bird encounters (i.e. 789 encounters reported between 2007 and 2019, of which 705 were storm-petrels with 129 reported dead) has not indicated any effects to seabirds above the predicted effects in the original EAs (Husky Oil Operations Limited 2000; LGL 2006) and the predicted low to moderate effects remain valid.


The modifications to the project relate only to the extension of the project life to 2036. The evaluation criterion that is most affected by this modification is the predicted duration of effects since operational activities may extend to 2036.

The proposed modification to the project timeline do not result in any changes in the original environmental effects predictions, required mitigation, or effects significance evaluations for Marine Birds. The WR ALE is therefore not likely to result in a significant adverse environmental effect on Marine Birds.

Furthermore, the continued execution of bird monitoring programs (see Section 2.7) will further validate the EA predictions and confirm that the temporal extension of the project will not result in new effects on Marine Birds.

Husky will commit to daily systematic monitoring and routine reporting for stranded birds to be undertaken on installations and support vessels, which will be developed in consultation with ECCC-CWS.

4.4 Marine Mammals and Sea Turtles

The waters off Eastern Newfoundland support a diverse assemblage of marine fauna that includes approximately 20 marine mammals and as many as five sea turtle species, many of which are considered to be at risk or otherwise of special conservation concern (Section 4.7).

The existing and available information indicates that marine mammal (cetacean) species that are known or considered likely to occur within the Project Area include a number of mysticetes (baleen whales) (Figure 4-4), odontocetes (toothed whales and porpoises) (Figure 4-5) and pinnipeds (seals) (Figure 4-6). These differ considerably in their likelihood of presence and in the particular locations and habitat types that they utilize and the times at which they occur in or pass through the region. Five sea turtle species have been documented in the Eastern Newfoundland offshore area (Figure 4-7), although only the leatherback and loggerhead sea turtles, occur with regularity. Key feeding grounds such as the Grand Banks are of particular importance to marine mammals and turtles, and several Ecologically or Biologically Sensitive Marine Areas (EBSAs) have been identified due in part to their known importance to a number of marine mammal species (Templeman



2007). Given that a number of these species have been designated as species at risk under the Species At Risk Act (SARA) or are otherwise considered to be of conservation concern, they are typically a key consideration in the EA review process for projects and activities off Eastern Newfoundland.

Figure 4-4 : Baleen Whale Observations



Figure 4-5 Toothed Whale Observations



Figure 4-6 Seal Observations



Figure 4-7 Sea Turtle Observations

4.4.1 Summary of Key Updates for Marine Mammals and Sea Turtles

There are a number of existing and available information sources that provide updated information on the characteristics, presence and spatial and temporal distribution of marine mammals and sea turtles in and around the proposed Project Area since the White Rose Comprehensive Study Report (Husky Oil Operations Limited 2000) and New Drill Centre EA (LGL 2006). Much of this is summarized in the Eastern Newfoundland Strategic Environmental Assessment (AMEC 2014, Section 4.2.3), and includes, for example, the current DFO marine mammal sightings database, Ocean Biogeographic Information System (OBIS), other available literature and available (published) marine mammal sightings data collected by operators working in the area.

Although detailed species and site-specific survey data are not available for the Project Area itself, and the available DFO and OBIS sightings databases include limited coverage and observations in this immediate area (Figure 4-4 through Figure 4-7), it is likely that this general region is used by some marine mammals and/or sea turtles throughout the year. Generally, baleen whales are present in the region throughout the year and most



abundant in the summer months; most species are migratory and absent from the region in winter, but common minke whale (Balaenoptera acutorostrata) and blue whale (Balaenoptera musculus) may occur in the area year-round. Most toothed whales are thought to be year-round residents of the area, with the exception of Risso’s (Grampus griseus) and common bottlenose (Tursiops truncatus) dolphins (present only in the summer months) and beluga (Delphinapterus leucas, a rare winter visitor). Sea turtles are most abundant in the area during the summer months and are absent between December and April.


Table 4-3 lists key interactions with production phase project activities assessed for Marine Mammals and Sea Turtles were related to disturbance from underwater construction and maintenance activities, the movement of ships and boats, and noise disturbance from drilling rigs, support vessels, helicopters and vertical seismic profiling (Husky Oil Operations Limited 2000; LGL 2006; Stantec 2018). Residual effects were assessed as adverse, but medium to moderate in magnitude and determined to be not significant.

Whi

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y, M

arin

e M

amm

als

and

Sea

Turt

les

(Pro

duct

ion

Phas

e); m

odifi

ed fr

om H

usky

O

ilO

pera

tions

Lim

ited

(200

0) a

nd L

GL

(200

6)

Proj

ect A

ctiv

ity

Pote

ntia

l Pos

itive

(P)

orN

egat

ive

(N)

Envi

ronm

enta

l Effe

ct

Miti

gatio

n

Eval

uatio

n C

riter

ia fo

r Ass

essi

ng E

nviro

nmen

tal E

ffect

s

Mag

nitu

deG

eogr

aphi

cEx

tent

Freq

uenc

yD

urat

ion

Rev

ersi

bilit

yC

onte

xt

Pres

ence

of S

truct

ures

Artif

icia

l Ree

f Effe

ctIn

crea

sed

Food

(P)

12

65

R2

Subs

ea S

truct

ures

Dis

turb

ance

(N)

02

65

R2

Und

erw

ater

M

aint

enan

ceD

istu

rban

ce (N

)1

11

1R

2

Dis

char

ges

Inje

ctio

n W

ater

Effe

cts

on H

ealth

(N)

Trea

tmen

t0

15

5R

2

Prod

uced

Wat

erEf

fect

s on

Hea

lth (N

)Tr

eatm

ent

01

55

R2

Coo

ling

Wat

erEf

fect

s on

Hea

lth (N

)Tr

eatm

ent

01

65

R2

Dec

k D

rain

age

Effe

cts

on H

ealth

(N)

Trea

tmen

t0

15

5R

2

Bilg

e W

ater

Effe

cts

on H

ealth

(N)

Trea

tmen

t0

15

5R

2

Sani

tary

and

Dom

estic

W

aste

wat

erEf

fect

s on

Hea

lth (N

)Pr

imar

y Tr

eatm

ent

01-

25

5R

2

Inte

ract

ions

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There have been no significant changes to SeaRose FPSO operations, including the presence and frequency of support vessels and helicopters as predicted in the WR Comprehensive Study and the New Drill Centres EA. Therefore, the original predictions relating to noise and interactions assessed as low remain valid.


The modifications to the project relate only to the extension of the project operations to 2036. With the exception of a longer duration of interactions with marine mammals and sea turtles, the proposed modification to the project timeline do not result in any changes in the original environmental effects predictions, required mitigation or effects significance evaluations for Marine Mammals and Sea Turtles. The WR ALE is therefore not likely to result in a significant adverse environmental effect on Marine Mammals and Sea Turtles.

4.5 Fisheries

Fisheries have been a key area of focus of the EA review in the White Rose Comprehensive Study (Husky Oil Operations Limited 2000), the New Drill Centre EA (LGL 2006) and subsequent EA updates. Accordingly, on-going project planning and implementation have likewise placed a high degree of emphasis on addressing the potential for interactions between White Rose Project components and activities and commercial fishing activity within and near the Project Area. The White Rose Comprehensive Study (Husky Oil Operations Limited 2000) and New Drill Centre EA (LGL 2006) included detailed descriptions of commercial fisheries in the region based on existing data sources and other information that was available as of the time of EA preparation and submission. This included fisheries landings statistics and geospatial data providing fisheries information. Commercial fisheries data are currently provided by Fisheries and Oceans Canada (DFO) Statistical Services in Ottawa, ON, including landing (weight and value) statistics and geospatial information on the location and timing of fishing activity. The DFO datasets record and report on domestic and foreign fish harvests that are landed in Canada.

The Project Area is located within the North Atlantic Fisheries Organization (NAFO) Unit Area 3Lt in Division 3L and is located just inside Canada’s 200 nautical mile limit (Figure 4-8).



Figure 4-8 NAFO Unit Area Within and Adjacent to the Study Area

4.5.1 Summary of Key Updates for Fisheries

Since the original EAs (Husky Oil Operations Limited 2000; LGL 2006), Husky has reviewed and incorporated, as applicable, updated fisheries data in subsequent EA updates, with the 2017 EA Update (Husky Energy 2017a) being the most recent EA update presenting commercial fisheries data. Domestic harvesting location data from 2013 to 2017 are shown for the Regional Area in the Jeanne d’Arc Basin Exploration Drilling Program Environmental Assessment Report (IAAC 2019). Also note that fisheries closure areas have also updated since the original assessment and the current fisheries closure areas are mapped and discussed in Section 4.6 (Special Areas).

The most recent fisheries data (up to 2017) available from DFO for this area indicates that approximately 10,169,720 tonnes of fish were landed in Canadian ports from 3L and 3N NAFO Unit Area in 2015. Fish landings from NAFO Division 3L and 3N in 2015 (all fishing enterprises, for fish landed in Canadian ports) were valued at nearly $53 million. The available data indicate that the fishery in this area is currently dominated by snow crab, with other species fished including roughhead grenadier, grey sole / witch flounder, Atlantic halibut, Northern shrimp, turbot / Greenland halibut, and others. The main gear types include crab pots and bottom otter trawls. Fishing activity occurs year-round but is concentrated primarily in the April-July period.



Fisheries mapping information is currently provided by DFO as an aggregated data set which gives a general indication of fishing areas (by species, gear types, fleet and other pre-determined categories and data classes) for individual grid “cells” that areapproximately 6 x 4 nautical miles in size. Figure 4-9 provides an indication of the overall geographic distribution of commercial fishing activity within and adjacent to the Project Area for the years 2013 up to 2017 (the most recent year for which data are available) within the grid square system described above. As illustrated, the Project Area itself occurs well outside the more intensive commercial fishing areas elsewhere on the Banks and along the shelf.

There are various regulatory jurisdictions that pertain to marine fish and fisheries within and around the Project Area and the various NAFO Divisions and Unit Areas that comprise the Eastern Newfoundland Offshore Area (Figure 4-10). While the Government of Canada has jurisdiction over fish stocks and fishing activities within the 200 nautical mile limit (EEZ) and for benthic invertebrates (such as crab) across the entire continental shelf, NAFO manages groundfish activities and other resources beyond that 200-mile limit.

The NAFO Regulatory Area (NRA) is approximately 2,707,895 km2 in size (or 41 percent of the total NAFO Convention Area) and comprises the part of the Northwest Atlantic high seas located adjacent to Canada’s 200-mile EEZ (AMEC 2014). Fishing activity in the NRA targets a range of species, including cod, redfish, Greenland halibut, shrimp, skates, and other finfish, and has an approximate landed value of $200 million annually across all members (NAFO 2017). As a result of the 2007 United Nations General Assembly (UNGA Res. 61/105, paragraph 83) request that Regional Fisheries Management Organizations regulate bottom fisheries, NAFO undertook an exercise to identify bottom fishing areas in the NRA, and in doing so, identified and mapped NAFO’s bottom fishing footprint in the area. The NAFO fisheries footprint is 120,048 km2 in size, and its location and relationship to the Project Area is illustrated in Figure 4-10.

A number of fisheries survey programs by government and/or industry also occur in parts of the Eastern Newfoundland Offshore Area, including DFO Multispecies Research Vessel (RV) Trawl Surveys, which comprise annual (spring and fall) standardized bottom-trawl surveys to collect information for managing and monitoring fish resources in the Newfoundland and Labrador Region.

There is also an annual Industry-DFO Collaborative Post-season Trap Survey for snow crab in NAFO Divisions 2J3KLOPs4R, which is conducted using commercial and modified snow crab traps at established trap stations starting in late August or early September after the commercial snow crab season has ended (Figure 4-11).

Given the White Rose Safety Zone, the Project Area does not contain or otherwise interact with other fisheries related activities off Eastern Newfoundland, including sealing areas, aquaculture operations, recreational fishing locations, or other human activities and components.



Figure 4-9 Fishing Activity within and adjacent to the Project Area



Figure 4-10 NAFO Fisheries Footprint



Figure 4-11 Crab/Halibut Survey Locations


Table 4-4 summarizes the key interactions with production phase project activities assessed for Fisheries were related to loss of access to fishing grounds, damage to gear or vessels, and biophysical effects of ongoing operations (e.g. tainting, effects on fish health and productivity, scaring and reduced catch) (Husky Oil Operations Limited 2000;LGL 2006). Residual effects were assessed as adverse, but negligible to low in magnitude and determined to be not significant.

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The White Rose EEM program provides an opportunity to monitor potential project-related effects on commercial fisheries with respect to biophysical effects on commercial fish species (American plaice and snow crab) and their habitat (water and sediment quality). Potential environmental effects are assessed on collected fish samples through several tests including body burden analysis for chemical contaminants, taint (taste test of the meat), and various health indices (e.g. haematology, histology of gill and liver, and Mixed Function Oxygenase (MFO)). Additional baseline information is collected on each species such as length, weight, and maturity stage.

American plaice and snow crab were collected in the Study/Reference Areas in both baseline years 2000 and 2002 and since then have been collected from the White Rose Field in 2004, 2005, 2006, 2008, 2010, 2012, 2014, 2016, and 2018. Sampling typically occurs in the summer at both the Study and at three Reference Areas (southwest, northwest, and southeast).

A review of the EEM results to date confirms there continues to be little evidence that project-related sediment quality changes have affected American plaice and snow crab and results are within predictions made in the EIS. Neither species were deemed tainted (taste test) and plaice health indicators were similar between the White Rose Field (Study Area) and the more distant Reference Areas. In particular, results from the 2018 fish survey indicate there were not statistically significant differences in plaice mean gutted weight and crab size measurements (carapace width and claw height) between the Reference Areas and the Study Area. There was not a significant difference between immature and pre-spawning female plaice between the Reference Areas and the Study Area. As in previous EEM years, >C10-C21 and >C21-C32 range hydrocarbons were detected in plaice liver samples but further analysis did not detect any drill fluid or petroleum hydrocarbons. Plaice liver fat percent concentration of >C10-C21 hydrocarbons was higher in the Study Area than the Reference Areas. Concentrations of cadmium and selenium were lower in the Study Area than in the Reference Areas. Plaice liver concentrations of other frequently detected compounds did not vary between Reference Areas and Study Area. Metal concentrations in crab tissue were similar between Study and Reference Areas with a few notable observations. Boron, mercury, and arsenic concentrations were slightly higher in the Study Area than the Reference Areas. Taste tests did not indicate any foreign odour or taint to either the plaice or carb edible tissue samples. Fish health indication analysis did not detect any significant differences between the Reference Areas and Study Area. However, basal hyperplasia was present in more fish from the Study Area than the Reference Areas. For a summary of EEM results related to water and sediment quality, refer to Section 4.2.

In addition to the EEM program, other indicators of environmental effects on commercial fisheries would be claims brought forward to Husky for gear loss and/or damage. To date, there have been no fisheries compensation claims associated with spills or debris as defined in the Accords Acts. However, several claims have been settled associated with gear entanglement during towing activities (eg. icebergs, drilling rigs). Husky maintains relationships with fisheries stakeholders through regular communications and participation on the One Ocean Working Group (OOWG). An initiative of the OOWG was to develop a Risk Matrix to assess the need for a Fisheries Liaison Officer or Fisheries Guide Vessel during various towing activities to lower the risk of fixed fishing gear entanglement.



Husky has and will continue to work to minimize any interference with the established fishing industry operating in the Newfoundland offshore area. This is done through various means including but not necessarily limited to:

Advisories, when appropriate, of SeaRose FPSO movements/re-locations and major operational changes through Notices to Mariners and the CBC Fisheries Broadcast

Continued participation on the One Ocean Committee that brings together oil and fishing industry representatives to discuss plans and issues of mutual interest and concern

Implementation of the attributable damage compensation described in the Fisheries Damage Compensation Program (EC-M-99-X-PR-00026-001)

Establishment and enforcement of a safety zone system around the White Rose Development installations in consultation with Transport Canada, C-NLOPB, and DFO.


This proposed extension of the White Rose Project until 2036 does not change the results of the environmental effects assessment for this VEC. The proposed timeline extension does not result in any changes in the original environmental effects predictions, required mitigation or effects significance evaluations for Fisheries. The WR ALE is therefore not likely to result in a significant adverse environmental effect on Fisheries.

As noted in the previous EAs and updates, on-going coordination and effective and timely communication between offshore oil and gas operators and the fishing industry and other marine interests, including through the various processes and measures described above, remain the best means for ensuring that such activities are carried out in a safe and environmentally responsible manner, avoiding or reducing potential adverse interactions between offshore exploration programs and other users of the marine environment.

Furthermore, the EEM program will continue to be executed to further validate EA predictions and confirm that these temporal modifications will not have additional effects on Fisheries.



4.6 Special Areas

4.6.1 Summary of Key Updates for Special Areas

No designated special areas are within the Project Area, but various Special Areas are within the Study Area as shown in Table 4-5 and Figure 4-12. Routine Project activities are not predicted to interact with these special areas as none intersect the Project Area. Many of these special areas are located to the east of the Project Area outside of the Canadian EEZ. Two types of special areas (i.e., Snow Crab Exclusion Zones and NAFO Closures) are protected from fishing activities as outlined in Table 4-5. The nearest special area is the Snow Crab Exclusion Zone in 8Bx, which is approximately 25 km from the Project Area Figure 4-12).

Table 4-5 Special Areas within the Study AreaSpecial Areas Features and Rationale for Designation

CanadianNortheast Slope Ecologically and Biologically Significant Area (EBSA)

DFO has identified this area as having significant aggregations of fish species such as shrimp, Greenland halibut, Atlantic wolffish, northern wolffish, spotted wolffish, roughhead grenadier, witch flounder, American plaice, Atlantic cod, thorny skate, smooth skate, other fish species (including piscivores, planktivores and benthivores), sensitive benthic species (i.e., large gorgonian corals, sea pens, black corals, soft corals, sponges), bird species (i.e., common murre, thick-billed murre), and hooded seals (DFO 2019a; Wells et al. 2017).

Lilly Canyon-Carson Canyon EBSA

DFO has identified this winter feeding and refuge area for cetaceans and pinnipeds. The area hosts aggregations of fish species (i.e., snow crab, Greenland halibut, American plaice, redfish, roughhead grenadier, thorny skate, small benthivores, soft corals, sponges), seabirds (i.e., common murre, sooty shearwater), and mammals (i.e., blue whale, harp seals) (DFO 2019a; Wells et al. 2017).

Small Gorgonian Coral Significant Benthic Area (SiBA)

DFO has identified this area for aggregations of sea pens, sponges, small gorgonian corals, and large gorgonian corals that form habitat for other species (Kenchington et al. 2016).

Large Small Gorgonian Coral SiBA

Sea Pen SiBA

Sponge SiBA

Snow Crab Exclusion Zone in Crab Fishing Area 8Bx

Through the Canadian Fisheries Act, DFO prohibits snow crab fishing in Exclusion Zones, which are 0.5 or 1.0 nautical mile-wide corridors along the length of crab fishing area boundaries to delineate fishing areas and provide a refuge area for snow crab within NAFO 3LNO (DFO 2015; DFO 2019b)



Special Areas Features and Rationale for Designation

Critical Habitat for Northern Wolffish

The DFO recovery strategy for northern and spotted wolffish (Threatened under SARA) has identified critical habitat in areas where these species are known to occur. Critical habitat supports important functions and features (e.g. spawning, nursery, rearing, food supply, migration) necessary for survival or recovery(DFO 2018b, 2020b).

Critical Habitat for Spotted Wolffish

InternationalLarge Gorgonian Coral Vulnerable Marine Ecosystem (VME)

United Nations (UN) Food and Agricultural Organization (FAO) identifies benthic environments sensitive to disturbance and slow to recover. Portions of VMEs may be closed to bottom fishing activities (FAO 2019).

Sea Pen VME

Sponge VME

Tail of the Bank (1) NAFO Closure

Northwest Atlantic Fisheries Organization (NAFO) has restricted bottom contact fishing in high sponge and coral concentration areas (designated portions of VMEs) until December 31, 2020 (NAFO 2020). Closures within the NAFO Regulatory Area are enforced by DFO through the Canadian Fisheries Act to protect areas identified for high concentrations of corals, sponges and seamounts.

Flemish Pass/Eastern Canyon (2) NAFO Closure

Beothuk Knoll (3) NAFO Closure

Eastern Flemish Cap (4) NAFO Closure

Northeast Flemish Cap (5) NAFO Closure

Northwest Flemish Cap (10) NAFO Closure

Northwest Flemish Cap (11) NAFO Closure

Beothuk Knoll (13) NAFO Closure

Slopes of the Flemish Cap and Grand Bank CBD EBSA

The UN Convention on Biological Diversity (CBD) has identified this area as containing most of the aggregations of indicator species for VMEs in the NAFO Regulatory Area. This area includes NAFO closures to protect corals and sponges and a component of Greenland halibut fishery grounds in international waters as well as a high diversity of marine taxa, including Threatened and listed species, are found within the EBSA (CBD 2019).

Southeast Shoal and Adjacent Areas on the Tail of the Grand Banks CBD EBSA

The CBD identifies the Southeast Shoal as a shallow, relatively warm, sandy habitat supporting an offshore capelin-spawning ground, a nursery ground for yellowtail flounder and spawning areas for depleted American plaice, depleted Atlantic cod, and striped wolffish. The Tail of the Grand Banks hosts abundant forage fish and is an important feeding area for cetaceans, including humpback and fin whales, and is frequented by large numbers of seabirds (CBD 2019).



Figure 4-12 Special Areas


Although Special Areas was not a stand-alone VEC in previous EAs and updates, biological components associated with special areas (i.e., marine fish, birds, mammals, sea turtles or their habitats) were assessed and these conclusions build on those findings. There are no known prohibited activities such as those being proposed as part of the White Rose Project (including the WR ALE) within these special areas, with the Project having little or no potential to result in adverse environmental effects upon these areas. As described for the preceding biophysical VECs, the Project is not expected to result in any significant adverse effects upon marine fish, birds, mammals, sea turtles or their habitats. It will therefore not adversely affect the ecological features, processes and integrity of any marine or coastal areas, including the protected and sensitive areas that are part of this VEC. The implementation of the various environmental protection measures and procedures outlined throughout the previous EAs (Husky Oil 2000; LGL 2006), including those which are designed to avoid or reduce Project-related discharges and/or disturbances and their associated environmental effects, will also serve to help address any direct or indirect potential effects on protected and sensitive areas.




Ongoing monitoring with respect to fish and fish habitat and fisheries (EEM program) and marine birds have thus far provided no evidence of effects contradictory to previous EA predictions. These monitoring programs will continue through the WR ALE and will also serve to verify effects on Special Areas as applicable.


The modifications to the project relate only to the extension of the project life to 2036. Given the absence of Special Areas within the Project Area, the limited potential for effects of routine project activities to extend to Special Areas in the Study Area and ongoing monitoring programs undertaken by Husky which would identify if a change in predicted effects on marine fish and fish habitat and marine birds occurs, the WR ALE is not predicted to result in a significant environmental effect on Special Areas.

4.7 Species at Risk

In the previous EAs (Husky Oil 2000; LGL 2006), species at risk (SAR) were assessed within the applicable biological VECs (Fish, Birds, Mammals and Sea Turtles) rather than a stand-alone VEC. However, as SAR is one of the key items identified by the C-NLOPB for the scope of the EA revalidation (Table 1-1), it is discussed here as a stand-alone section. Updated listings of SAR within the Study Area are also provided in the EA Update Reports.

SARA provides for the protection of species at the national level to prevent extinction and extirpation, facilitate the recovery of endangered and threatened species, and to promote the management of other species to prevent them from becoming at risk in the future. Designations under SARA follow the recommendations and advice provided by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC).

There are currently a number of schedules associated with SARA. Species that have formal protection are listed on Schedule 1 of the Act, which includes the following potential designations:

Extirpated: A species that no longer exists in the wild in Canada, but exists elsewhere

Endangered: A species that is facing imminent extirpation or extinction

Threatened: A species that is likely to become endangered if nothing is done to reverse the factors leading to its extirpation or extinction

Special Concern: A species that may become threatened or endangered because of a combination of biological characteristics and identified threats.

Schedule 1 of SARA is the official federal list of species at risk in Canada. Once a species is listed, measures to protect and recover a listed species are established and implemented, including the development of a Recovery Strategy. Action Plans summarize the activities required to meet recovery strategy objectives and goals, and Management



Plans set goals and objectives for maintaining sustainable population levels of one or more species that are particularly sensitive to environmental factors.

4.7.1 Summary of Key Updates for Species at Risk

Although not assessed as a stand-alone VEC in previous EAs for the White Rose Project, maintaining a current account of Species at Risk and Species of Conservation Concern (assessed by COSEWIC) along with applicable recovery strategies, etc. has been a focus of EA updates, including as recently as the 2019 EA Update (Husky Energy 2019a). Table 4-6 provides a listing of species at risk and of conservation concern. Species that are not included below but that may rarely occur in the Project Area are the red knot, harlequin duck, and short-eared owl. These are largely shore-bound species but have been seen very rarely by surveys in offshore Newfoundland.

Table 4-6 Species at Risk or Otherwise of Special Conservation ConcernSpecies Status/Designation1, 2

Relevant Population (Where Applicable)Common Name Scientific Name

NL

ESA

SARA

CO

SEW

IC

FishAcadian redfish Sebastes fasciatus T Atlantic

American eel Anguilla rostrata V T

American plaice Hippoglossoides platessoides T Newfoundland and Labrador

Atlantic bluefin tuna Thunnus thynnus E

Atlantic cod Gadus morhua E Newfoundland and Labrador

Atlantic salmon Salmo salar

T South Newfoundland

SC Quebec Eastern North Shore

SC Quebec Western North Shore

E Anticosti Island

SC Inner St. Lawrence

SC Gaspe-Southern Gulf of St. Lawrence

E Eastern Cape Breton

E Nova Scotia Southern Upland

E Outer Bay of Fundy Population

Basking shark Cetorhinus maximus SC Atlantic

Common Lumpfish Cyclopterus lumpus T

Cusk Brosme E

Deepwater redfish Sebastes mentella T Northern

Northern wolffish Anarhichas denticulatus T T

Porbeagle Lamna nasus E

Roundnose grenadier Coryphaenoides rupestris E

Shortfin mako Isurus oxyrinchus E Atlantic

Smooth skate Malacoraja senta E Funk Island Deep



Species Status/Designation1, 2

Relevant Population (Where Applicable)Common Name Scientific Name

NL

ESA

SARA

CO

SEW

IC

DD Hopedale Chanel

DD Nose of the Grand Bank

SC Laurentian-Scotian

Spiny dogfish Squalus acanthias SC Atlantic

Spotted wolffish Anarhichas minor T T

Striped wolffish Anarhichas lupus SC SC

Thorny skate Amblyraja radiata SC

White hake Urophycis tenuis T Atlantic and NorthernGulf of St. Lawrence

White shark Carcharodon carcharias E E Atlantic (COSEWIC/SARA)

Winter Skate Leucoraja ocellata E Eastern Scotian Shelf – Newfoundland

BirdsIvory gull Pagophila eburnea E E E

Red-necked phalarope Phalaropus lobatus SC SC

Ross’s Gull Rhodostethia rosea T TRange listed on SARA as Manitoba,Nunavut. Identified in Labrador Sea

and N. Grand Banks 3.Marine Mammals

Beluga whale Delphinapterus leucas E E St. Lawrence Estuary (COSEWIC/SARA)

Blue whale Balaenoptera musculus E E Atlantic (COSEWIC/SARA)

Bowhead whale Balaena mysticetus SC Eastern Canada-West Greenland

Fin whale Balaenoptera physalus SC SC Atlantic (COSEWIC/SARA)

Harbour porpoise Phocoena SC Northwest Atlantic

Killer whale Orcinus orca SC Northwest Atlantic-Eastern Arctic

North Atlantic right whale Eubalaena glacialis E E

Northern bottlenose whale Hyperoodon ampullatusE E Scotian Shelf, (COSEWIC/SARA)

SC Davis Strait-Baffin Bay-Labrador Sea

Sowerby’s beaked whale Mesoplodon bidens SC SC

Sea Turtles

Leatherback sea turtle Dermochelys coriacea E E Atlantic (COSEWIC/SARA)

Loggerhead sea turtle Caretta caretta E E1 Data Deficient (DD), Vulnerable (V), Special Concern (SC), Threatened (T), Endangered (E)

(blank cells are considered to be not assessed)2 Multiple designations refer to multiple populations or sub-populations.3 Maftei, et al. 2015.

Critical habitat for spotted and northern wolffish was proposed and delineated in 2018 (DFO 2018b), primarily along the northeast shelf and slopes of the Grand Banks (Figure 4-12). On February 27, 2020, DFO released the final version of the Recovery Strategy for Northern Wolffish (Anarhichas denticulatus) and Spotted Wolffish (Anarhichas minor), and



Management Plan for Atlantic Wolffish (Anarhichas lupus) in Canada (DFO 2020a), and a final Action Plan for the Northern Wolffish (Anarhichas denticulatus) and Spotted Wolffish (Anarhichas minor) in Canada (DFO 2020b). No overlap exists between the White Rose Project Area and the identified critical habitats.

On March 20, 2020, DFO released a final Action Plan for the Leatherback Sea Turtle (Dermochelys coriacea) in Atlantic Canada (DFO 2020c) and on May 11, 2020, DFO released a proposed Action Plan for the North Atlantic Right Whale (Eubalaena glacialis)in Canada (DFO 2020d) with a 60-day consultation period. Reviews of Species at Risk Action Plans and Management Plans and related responses are conducted via the CAPP Environment and Sustainability Committee.


The previous EAs (Husky Oil 2000; LGL 2006), assessed project effects on species at risk within the applicable biological VECs (e.g. Fish and Fish Habitat, Marine Birds, Marine Mammals and Sea Turtles). The conclusion from those VECs (as identified in Sections 4.2.2, 4.3.2, 4.4.2) was that the effects of the project were assessed to be not significant including for species at risk. Subsequent EA updates which have followed the New Drill Centre EA (LGL 2006) have reached similar conclusions with the potential environmental effects of project activities to be not significant. In addition, the mitigations listed elsewhere for those relevant VECs also apply to Species at Risk.


In addition to the annual EA updates associated with the New Drill Centre EA (LGL 2006), which review changes in species at risk designations and reassess the potential for project-related effects, ongoing monitoring (e.g. EEM, bird monitoring studies) provide additional verification of effects predictions of not significant effects.


This proposed extension of the White Rose Project until 2036 does not introduce new activities which would change potential interactions with species at risk. Annual EA reviews which require a focus on species at risk ensures that Husky understands applicable changes in species status and regulatory protections and ongoing monitoring programs provide an opportunity to monitor environmental changes which could affect species at risk. The WR ALE is therefore not likely to result in a significant adverse environmental effect on Species at Risk.



5.0 ACCIDENTAL EVENTS

Both the White Rose Comprehensive Study (Husky Oil 2000) and the New Drill Centre EA (LGL 2006, 2007) addressed the likelihood, control and effects of batch spills and blowouts that could potentially occur over the life of the project. Blowout frequencies were determined using either worldwide data or US Outer Continental Shelf (OCS) data foreither development drilling or production/workover activities; exploration data were not used. The WR Comprehensive Study also assessed the likelihood of platform related spills and spills associated with tanker offloading.

White Rose was expected to be developed using 10 to 14 oil producer wells, 2 to 3 gas injectors and 6 to 8 water injectors over a 12 to 14-year period. With the addition of up to four more drill centres in the New Drill Centre EA, an additional 30 development wells were expected to be drilled over four years.

During development drilling activities, the likelihood of an extremely large spill (>150,000 barrels (bbl)) associated with development drilling was assessed at 3.9 x 10-5 in the WR Comprehensive Study based on 2 spills occurring over 51,000 development wells drilled worldwide (Table 5-1). In the New Drill Centres EA, an additional 24,000 development wells has been drilled worldwide reducing the likelihood to 2.66 x 10-5 (2/75,000). Based on an exposure of 20 wells for White Rose and 30 wells for the New Drill Centres, the predicted spill frequencies were similar at 7.8 x 10-4 and 7.98 x 10-4, respectively. Spill frequencies for Large (>1000 bbl) and Very Large spills are presented in Table 5-1. In the WR Comprehensive study it was noted that no blowouts resulting in spills >1000 bbls had occurred since 1972. Approximately 16,000 development wells had been drilled in the US OCS, resulting in 39 blowouts; no oil was spilled in any of the blowouts. The frequency was presented as a worst-case.

Table 5-1 Spill Frequencies (Spills/Wells) Associated with Blowouts for Development Drilling

Large (>1000 bbl) Very Large (>10,000 bbl) Extremely Large (>150,000 bbl)

World - 7.8 x 10-5

(4/51,000 or 1/12,750)3.9 x 10-5

(2/51,000 or 1/25,500)

US OCS2.4 x 10-3

(39/16,000 or 1/410)a - -

White Rose Project 20 x 2.4 x 10-3 = 0.048 20 x 7.8 x 10-5 = 1.56 x 10-3 20 x 3.9 x 10-5 = 7.8 x 10-4

World5.0 x 10-5

(1/20,000)b5.33 x 10-5

(4/75,000)2.66 x 10-5

(2/75,000)

New Drill Centres 30 x 5.0 x 10-5 = 3.42 x 10-3 30 x 5.33 x 10-5 = 1.6 x 10-3 30 x 2.66 x 10-5 = 7.98 x 10-4

b - represents worldwide exploration and development drilled between 1994-1999.

a - only US OCS Data applied. No oil spilled in the 39 blowouts in 16,000 wells

New Drill Centres EA

Spill Size

White Rose Comp Study



The WR Comprehensive Study assessed frequency of blowouts occurring during production and well workovers. Rather than wells drilled, the data are normalized for the continuous operation of production with the exposure variable expressed in well-years.World-wide, two spills had occurred over 200,000 well-years, a frequency of 1.0 x 10-5

(Table 5-2). For White Rose, a total of 140 well-years was used to predict the frequency of extremely large spills associated with production/workover activities as 1.4 x 10-3 (140 x 1.0 x 10-5). Table 5-2 also presents frequencies for Large and Very Large spills.

Table 5-2 Spill Frequencies for Blowouts/Well-year associated with Production/WorkoverActivities

Platform exposure is defined as the count of the active number of wells each year (well-years) rather than a simple platform count. This allows for the assumption that platforms with a large number of producing wells has a higher potential for a spill than a platform with only one producing well (BOEM, 2018).

Platform spill statistics for the WR Comprehensive Study were derived from Anderson and LaBelle (1994) using spills from drilling and production platforms in the OS OCS between 1964 and 1992. Of the 9.1 billion (109) barrels (Bbbl) of crude produced, 11 large spills and 4 extremely large spills were reported. While Anderson and LaBelle (1994) reported spills per billion barrels produced, risk exposures for the WR Comprehensive Study were converted to spills/well-year using spills/well-year = spills/Bbbl x 7.9 x 10-5 (Petro-Canada, 1996) resulting in 3.6 x 10-6 and 1.3 x 10-5 spills/well-year for large and extremely large spills, respectively. For White Rose, 140 well-years resulted in a predicted platform spill frequency of 5.04 x 10-3 and 1.82 x 10-3 spills/well-year for large and extremely large spills, respectively. Spill frequencies for small to very large spills are in Table 5-3.

Table 5-3 Spill Frequencies (Spills/Well-year) Associated with Platform Activities

Large (>1000 bbl) Very Large (>10,000 bbl) Extremely Large (>150,000 bbl)

White Rose Comp Study World 2.5 x 10-5

(5 spills/200,000 well-years)1.0 x 10-5

(2 spills/200,000 well-years)

US OCS 6.5 x 10-5

(7/107,717 or 1/15,388)

White Rose Project 140 x 2.5 x 10-5 = 3.5 x 10-3 140 x 1.0 x 10-5 = 1.4 x 10-3

Spill Size

Small (1 - 49.9 bbl) Medium (50 - 999.9 bbl) Large (>1000 bbl) Very Large (>10,000 bbl)

US OCS 1.7 x 10-2

(1,857 spills/107,717 well-years) 8.0 x 10-4

(86 spills/107,717 well-years) 3.6 x 10-5 1.3 x 10-5

White Rose Project 140 x 1.7 x 10-2 = 2.38 140 x 8.0 x 10-4 = 1.12 x 10-1 140 x 3.6 x 10-5 = 5.04 x 10-3 140 x 1.3 x 10-5 = 1.82 x 10-3

US OCS 7.7 x 10-2 3.6 x 10-3 - -

New Drill Centres 30 x 7.7 x 10-2 = 2.31 30 x 3.6 x 10-3 = 1.08 x 10-1 - -

Spill Size

White Rose Comp Study

New Drill Centre EA



Spill frequencies were also determined for offloading crude to tankers. Total oil production from the White Rose Field was assessed at 250 million barrels of oil over a 13-year period.In the WR Comprehensive Study, large spill frequencies associated with offloading in the UK were 2.3 spills per billion barrels produced. Most of the spills occurred early in the industry’s history and improvements in offloading technology had reduced the number to 1.2 spills per billion barrels. As the SeaRose FPSO was to avail of the latest offloading technology, the spill frequency prediction for White Rose was 1.2 x 0.250 = 0.30 large spills (>1000bbls) over the course of the 13-year project.

Oil Spill Modelling and Spill Trajectories

Oil spill modelling was conducted for both the White Rose Comprehensive Study and the New Drill Centres EA to predict the fate and behaviour of an oil spill and help inform the assessment of potential environmental effects. Since then, various models have been used to predict the fate and behaviour of a White Rose oil spill (including batch diesel spills and blowouts), including the most recent modelling which was conducted to support the White Rose Extension Project Environmental Assessment (SL Ross 2012).

5.1 Summary of Effects Analysis from Previous EAs

Residual environmental effects from accidental spills were predicted to be significant for marine birds with a low probability of occurrence (Husky Oil 2000) (Table 5-4). The New Drill Centre EA (LGL 2006) also predicted significant effects from a spill for marine birds with a greater degree of scientific certainty. Effects on commercial fisheries were determined to be not significant in Husky Oil Operations Limited (2000). The assessment on fisheries was further elaborated in LGL (2006) and determined that economic effects on the fishery (caused by loss of access, gear damage, or changes in market value) couldbe considered significant but those damages could be mitigated with economic compensation which downgraded residual effects to a not significant rating.

Table 5-4 VEC Assessment Table for Accidental Events; modified from Husky OilOperations Limited (2000) and LGL (2006)

Significance of Predicted ResidualEnvironmental Effects

Likelihood

Oil Blowout/SpillsSignificance

RatingLevel of

ConfidenceProbability ofOccurrence

ScientificCertainty

Fish and Fish Habitat

Subsea blowout 7 day NS 3 1 3


Above-surface blowout 7 day NS 3 1 3

Batch Spill 800 m3 NS 3 1 3

Batch Spill 10,000 m3 NS 3 1 3


Marine Birds

Subsea blowout 7 day S 3 1 3

Subsea blowout 45 day S 3 1 3

Above-surface blowout 7 day S 3 1 3

Batch Spill 800 m3 S 3 1 3



Significance of Predicted ResidualEnvironmental Effects

Likelihood

Oil Blowout/SpillsSignificance

RatingLevel of

ConfidenceProbability ofOccurrence

ScientificCertainty

Batch Spill 10,000 m3 S 3 1 3

Batch Spill 30,000 m3 S 3 1 3

Marine Mammals




Batch Spill 800 m³ NS 2 1 2



Sea Turtles




Batch Spill 800 m3 NS 1 1 1



Residual Environmental Effects Significance Rating:S = Significant Adverse EffectNS = Not-significant EffectP = Positive EffectSignificance is defined as a medium or high Magnitude (2 or 3 rating) and duration greater than 1 year (3 or greater rating) and geographic extent > 100 km2 (4 or greater ratting)

Probability of Occurrence1 = Low2 = Medium3 = High

Level of Confidence in Impact Prediction1 = Low Level2 = Medium Level3 = High Level

Scientific Certainty: Based on Scientific Information and Statistical Analysis or Professional Judgement1 = Low Level2 = Medium Level3 = High LevelN/A = Not Applicable



5.2 Summary of Key Updates and Verification of Predictions

Recent worldwide statistics for blowout-related spills are presented by the US Bureau of Safety and Environmental Enforcement (BSEE, 2017). One development drilling blowout has occurred since the New Drill Centres EA; Montara, Australia, considered a very largespill at 29,600 bbls. Two exploration drilling blowouts have also occurred; Frada, Brazilcharacterized as large at 3,700 bbls, and Macondo, USA in a newly defined category gigantic at 4,250,000 bbls. Between 2000 and 2015, 14,444 development wells were drilled worldwide resulting in the probability of a very large being 6.9 x 10-5

(1/14,444)(BSEE, 2017) - an increase from 5.33 x 10-5 presented in Table 5-1.

Eight platform spills >1000 bbl were reported in the US OCS between 1972 and 2017 over a total of 274,768 well-years (BOEM, 2018). This represents a revised frequency of 2.9 x 10-5 spills/well-year – from 3.6 x 10-5 reported in Table 5-3.

Throughout the development and operation of the White Rose field, Husky has experienced 10 spills >1 bbl (7 small, 1 medium and 1 large). Six spills were synthetic based mud, two hydraulic oil and two crude. The two crude spills are discussed below.

On September 9, 2008 a newly installed dry-break coupling on the SeaRose FPSO offload hose parted while offloading crude oil to a shuttle tanker. The result was 28 bbl (4.47m³)of crude oil spilled to the marine environment.

The most significant accidental event was a 1572 bbl (250 m³) spill that occurred in 2018. On November 15, 2018, Husky Energy shut in production at the White Rose field due to operational safety concerns resulting from severe weather. Once the storm had passed and safety checks were completed, the process of resuming normal operations commenced on November 16th. The release took place during the re-start and an estimated 1,572 bbl (250 m³) of oil was released.

Extensive wildlife observation surveys were conducted up until November 28th with a total of 26 5nm x 5nm search grids completed (650nm², 2229km²). There were 34,374 seabirds observed over 13 days of observations. Black-legged kittiwakes accounted for 68% of the observations, Thick-billed murres 12%, Northern fulmar 10%, Common murre 4% and 17 other species accounting for the remaining 6% of the total observations. In total, 18 impacted birds were observed during the wildlife observation surveys, however it is recognized that the total number of impacted birds could be much greater based on seabird densities over the entire affected area, and that murres would be the species most impacted.

Also, a spill-specific environmental effects monitoring program was conducted by collecting sediment samples and water samples over the observed extent of the spill. Nooil was detected in any water sample. Hydrocarbons were detected in the immediate vicinity of the SWRX drill centre, however they were determined to have a similar signature to synthetic drill muds and were within the range of hydrocarbons determined in the 2018 EEM program conducted two months earlier (Husky, 2019b).

The WR Comprehensive Study and the New Drill Centres EA determined the significance of predicted residual environmental effects as Not-Significant Effect for 800m³ batch spills.The significance of predicted residual effects (Table 5-4) remain valid.



After Husky conducted an extensive investigation, several improvements were implemented as a result of this incident including:

Improved process on identifying and managing non-standard or infrequent operations conditions;

Revision of Adverse Weather Policy; and,

Enhanced oversight of critical activities.

All of these improvements will further reduce the likelihood of this type of incident from reoccurring.

Oil spill response capabilities have been significantly enhanced since the White Rose Comprehensive Study (Husky Oil Operations Limited 2000). In 2009, Husky, along with Suncor and Hibernia Management and Development Company (HMDC) jointly acquired a second large-scale offshore oil spill containment system which consists of a skimmer and self-inflating boom and is equivalent to the Norwegian Standard System. In 2013, Husky, Suncor and HMDC submitted a Net Environmental Benefits Analysis for the Use of Dispersants on the Grand Banks (NEBA) to the C-NLOPB in support of potential dispersant use in spill response. The NEBA concluded that dispersants could be effectively used within limited time-windows on all three crude types and that there could be a clear net environmental benefit to vulnerable seabird populations by removing oil from the sea surface. Husky has also confirmed with its vessel contractors that vessel-based spray application systems are feasible for offshore use.

In addition to its own equipment and contracted vessels for first response, Husky has mutual aid assistance from other operators (e.g. Suncor, HMDC, ExxonMobil), access to Eastern Canada Response Corporation (ECRC) for personnel and equipment for larger spill response operations, and access to global resources available through Oil Spill Response Limited (OSRL). Husky maintains an oiled-seabird treatment facility, along with a number of trained responders and a wildlife veterinarian. For longer-term rehabilitation, Husky sponsors a local rehabilitation facility.

Husky is committed to continuous improvement in all areas of its operations, including emergency response. New technologies and ideas are identified through participation in industry conferences and through relationships with service providers such as ECRC and OSRL. Examples of recent initiatives include:

The development of a risk assessment methodology for the use of dispersants as an oil spill response countermeasure;

The development and resourcing of a comprehensive Source Control Response Planusing best available technologies to cap a well blowout;

Re-testing the effectiveness of dispersant on White Rose crude oil;

Daily seabird observations performed by supply vessel crews, providing enhanced competencies of the vessel crews and improved capability for incident response;



Transitioned Husky’s response process to the internationally recognized and utilized Incident Command System; and,

Restructured contingency plans using a risk-based approach.

5.3 Implications of Project Extension

The temporal extension of field operations at White Rose will not affect oil fate and behaviour, or environmental effects. Although there was an accidental release in 2018, the residual environmental effects assessment of an oil spill from Project activities identified in the White Rose Comprehensive Study (Husky Oil Operations Limited 2000)and the New Drill Centre EA (LGL 2006) remain valid.

Husky’s objective is to have no spills of hydrocarbons or other unauthorized discharges to the marine environment. Husky has implemented environmental protection measures and safety critical element performance standards to reduce the risk of a spill. If an event occurs that results in the release of hydrocarbon product into the marine environment, response activities will be conducted in accordance with the Husky’s Oil Spill Response Plan on file with the C-NLOPB. This Oil Spill Response Plan is reviewed regularly by Husky and updated as applicable to account for improvements in response capabilities and equipment and regulatory updates. A Wildlife Response Plan has also been developed in conjunction with ECCC-CWS and is based on the Guidelines for EffectiveWildlife Response Plans (ECCC 2020c). Both the Oil Spill Response Plan and the Wildlife Response Plan are a requirement of an Operations Authorization and on file with the C-NLOPB.



6.0 CUMULATIVE EFFECTS

Cumulative effects (i.e., project-related residual effects in combination with residual effects of other past, present or likely foreseeable project and activities) were assessed in the White Rose Comprehensive Study (Husky Oil Operations Limited 2000) and the New Drill Centre EA (LGL 2006). These analyses considered cumulative effects of White Rose activities in combination with other existing offshore oil development on the Grand Banks (Hibernia, Terra Nova), other offshore exploration activity (seismic surveys and exploration drilling), commercial fisheries, marine transportation, and hunting activities (marine birds and seals). Since then, the Hebron Project has also been commissioned, with first oil achieved in 2017 and plans are being made to extend the West White Rose pool fordevelopment with a concrete wellhead platform, extending the life of the White Rose field. All of these oil development projects are expected to continue to at least 2030 or later. Another development project (Bay du Nord) has been proposed by Equinor Canada Ltd and its partner Husky, although this project is still undergoing environmental assessment and is located in the Flemish Pass, not the Jeanne d’Arc Basin.

The extension of the life of the White Rose Project will not introduce new sources of lighting, marine discharges, underwater sound, or additional vessel traffic; the type and magnitude of project-related residual effects are not predicted to change. Given that the WR ALE will not alter conditions related to cumulative effects for marine fish and fish habitat, marine mammals and sea turtles, marine birds, and fisheries from those previously assessed and determined not be significant, the cumulative environmental effects of the WR ALE are considered to be not significant for these VECs. In consideration of this determination, and, as noted in Section 4.7.4, the requirements for annual EA reviews which include consideration of species at risk and the feedback on environmental changes provided through ongoing monitoring programs, the WR ALE is not predicted to result in significant cumulative environmental effects on Species at Risk.

Given the absence of Special Areas within the Project Area, the limited potential for effects of routine project activities to extend to Special Areas in the Study Area and ongoing monitoring programs undertaken by Husky which would identify if a change in predicted effects on marine fish and fish habitat and marine birds occurs, the WR ALE is not predicted to result in significant cumulative effects on Special Areas.

Monitoring programs, which will continue throughout the life of the White Rose Project will continue to provide feedback on environmental changes and identify requirements for adaptive management as applicable. The White Rose EEM program aimed at the Fish and Fish Habitat VEC, for instance, has indicated that alterations in Sediment Quality were well correlated with the location of drilling activity; increased, as expected, with initial drilling, but have not increased in magnitude as drilling progressed. These results suggest limited cumulative effects of drilling on that VEC within the White Rose field. No temporal trends were noted for other components of the White Rose EEM program because there was little evidence that these were affected by project activity.



7.0 CONCLUSIONS

This EA revalidation provides an overview and analysis of a proposed modification to the temporal scope of the WR ALE project. As described in the preceding sections, the planned activities that would occur within this temporal extension are in keeping with the nature and scope of the activities as described, assessed and approved under the preceding EA review processes. Each of the environmental interactions, potential effects and associated mitigation measures (as reflected in previous White Rose EA filings) therefore remain applicable to the nature and scope of the planned activities and the expanded timeline described and assessed herein, including with regard to addressing any potential effects on species at risk and other marine biota and marine activities (including fisheries). Current mitigations will continue to be implemented in accordance with Husky’s commitments and obligations pursuant to the Project’s EA approvals and other applicable legislative and regulatory requirements.

Overall, the routine activities of the White Rose Project will result in localized disturbance in the marine environment throughout the operational life of the offshore production facility. The WR ALE is therefore not anticipated to displace or otherwise affect marine fish, birds, mammals, sea turtles, fisheries or other marine activities in such a way that causes negative and detectable effects to populations, species at risk or human activities in the region.

The proposed change to the timeline (extension of operations to 2036) does not result in any changes in the original environmental effects predictions, required mitigation or associated determinations related to environmental effects significance for any component of the environment.



8.0 REFERENCES

8.1 Relevant Environmental Assessment Documents

Husky Oil Operations Ltd., White Rose Comprehensive Study, October 2000, 1011p.

Husky Oil Operations Limited, White Rose Comprehensive Study Report, April 2001, 94p.

LGL Limited, September 2006, Husky White Rose Development Project: New Drill Centre Construction & Operations Program Environmental Assessment. LGL Rep. SA883. Rep. by LGL Limited, St. John’s, NL, for Husky Energy Inc., Calgary, AB. 299 p. + Appendices.

LGL Limited, January 2007, Husky White Rose Development Project: New Drill Centre Construction & Operations Program Environmental Assessment Addendum. LGL Rep. SA883a. Rep. by LGL Limited, St. John’s, NL, for Husky Energy Inc., Calgary, AB. 126 p. + Appendices.

Husky Energy, December 2012,White Rose Extension Project Environmental Assessment, , St. John’s, NL,

Husky Energy, July 2013, White Rose Extension Project: Consolidated Response to Review Comments on the White Rose Extension Project Environmental Assessment and Addendum, 226 p.

8.2 Cited References

AMEC Environment & Infrastructure. 2014. Eastern Newfoundland Strategic Environmental Assessment. Prepared for Canada-Newfoundland Offshore Petroleum Board. https://www.cnlopb.ca/sea/eastern/

Anderson, C.M. and R.P. LaBelle. 1994. Comparative Occurrence Rates for Offshore Spills. Spill Science & Technology Bulletin, 1(2): 131-141. Elsevier Sciences Ltd., Oxford, U.K.

Anderson, C.M. and R.P. LaBelle. 2000. Update of Comparative Occurrence Rates for Offshore Spills. Spill Science & Technology Bulletin, 6(5/6): 303-321. Elsevier Sciences Ltd., Oxford, U.K.

Baillie, S.M., G.J. Robertson, F.K. Wiese, and U.P. Williams. 2005. Seabird data collected by the Grand Banks offshore hydrocarbon industry 1999–2002: Results, limitations and suggestions for improvement. Canadian Wildlife Service Technical Report Series 434:1–47.

BirdLife International. 2017. Hydrobates leucorhous (amended version of assessment). The IUCN Red List of Threatened Species 2017: e.T22698511A119292983. Available online: http://dx.doi.org/10.2305/IUCN.UK.2017-3.RLTS.T22698511A119292983.en. Accessed February 2020.



Bird Studies Canada. 2020. Important Bird Areas of Canada Database. Port Rowan, Ontario: Bird Studies Canada. http://www.ibacanada.org

BOEM (Bureau of Ocean Energy Management). 2018. US Outer Continental Shelf Oil Spill Statistics. UCS Study BOEM 2018-006. http://www.boem.gov/renewable-energy/boem-2018-006.

BSEE (Bureau of Safety and Environmental Enforcement). 2017. Loss of Well Control Occurrence and Size Estimators, Phase I and II. Report Number ES201471/2.Prepared by ExproSoft AS. 201 pp. Available at: https://www.bsee.gov/sites/bsee.gov/files/tap-technical-assessment-program/765aa.pdf

Buren A.D., M. Koen-Alonso, P. Pepin, F.K. Mowbray, B.S. Nakashima, G.B. Stenson, N. Ollerhead, W.A. Montevecchi. 2014. Bottom-up regulation of capelin, a keystone forage species. PLoS ONE 9: e87589. https://doi.org/10.1371/journal.pone.0087589

Buren, A.D., H.M. Murphy, A.T. Adamack, G.K. Davoren, M. Koen-Alonso, W.A. Montevecchi, F.K. Mowbray, P. Pepin, P.M. Regular, D. Robert, G.A. Rose, G. Stenson, D. Varkey. 2019. The collapse and continued low productivity of a keystone forage species. Marine Ecology Progress Series 616: 155-170 https://doi.org/10.3354/meps12924.

CBD (United Nations Convention on Biological Diversity). 2019. COP 12 Decision XII/22. Marine and coastal biodiversity: ecologically or biologically significant marine areas (EBSAs). Available at: https://www.cbd.int/decision/cop/?id=13385

Centre for Offshore Oil, Gas and Energy Research and K. Lee. 2009. Environmental Persistence of Drilling Mud and Fluid Discharges and Potential Impacts.Environmental Studies Research Funds. Report 176. 36 pp.

C-NLOPB (Canada-Newfoundland and Labrador Offshore Petroleum Board) and CNSOPB (Canada Nova Scotia Offshore Petroleum Board). 2011. Environmental Protection Plan Guidelines. 30 pp.

C-NLOPB (Canada-Newfoundland and Labrador Offshore Petroleum Board) and CNSOPB (Canada Nova Scotia Offshore Petroleum Board). 2017a. Compensation Guidelines Respecting Damages Relating to Offshore Petroleum Activity. 20 pp.

C-NLOPB (Canada-Newfoundland and Labrador Offshore Petroleum Board) and CNSOPB (Canada Nova Scotia Offshore Petroleum Board). 2017b. Drilling and Production Guidelines. 147 pp.

C-NLOPB (Canada-Newfoundland and Labrador Offshore Petroleum Board) and CNSOPB (Canada Nova Scotia Offshore Petroleum Board). 2018. Incident Reporting and Investigation Guideline. 50 pp.

C-NLOPB (Canada-Newfoundland and Labrador Offshore Petroleum Board). 2019a.Asset Design Life Extension Program Guideline for Offshore Canada-Newfoundland and Labrador. 21 pp.



C-NLOPB (Canada-Newfoundland and Labrador Offshore Petroleum Board). 2019b.Geophysical, Geological, Environmental and Geotechnical Program Guidelines. 64 pp.

Courtenay, S., M. Lyons, M. Boudreau, L. Burridge and K. Lee. 2013. Biological Effects of Produced Water from Offshore Canadian Atlantic Oil and Gas Platforms on Various Life Stages of Marine Fish. Environmental Studies Research Funds. Report 196. 109pp.

Dawe, E.G., M. Koen-Alonso, D. Chabot, D. Stansbury, and D. Mullowney. 2012. Trophic interactions between key predatory fishes and crustaceans: Comparison of two Northwest Atlantic systems during a period of ecosystem change. Marine Ecology Progress Series, 469: 233-248.

DeBlois 2011. Environmental Risk Analysis for White Rose Produced Water: Quantification using the Environmental Impact Factor (EIF)

Delarue, J., K. Kowarski, E. Maxner, J. MacDonnell and B. Martin. 2018. Acoustic Monitoring Along Canada’s East Coast: August 2015 to July 2017. Environmental Studies Research Funds. Report 215. 204 pp.

Devine, J.A. and R.L. Haedrich. 2011. The role of environmental conditions and exploitation in determining dynamics of redfish (Sebastes species) in the Northwest Atlantic. Fisheries Oceanography, 20(1), pp.66-81.

deYoung, B., R. Harris, J. Alheit, G. Beaugrand, N. Mantua, and L. Shannon. 2004. Detecting regime shifts in the ocean: Data Considerations, 60(2-4): 143-164.

DFO (Fisheries and Oceans Canada). 2007. Statement of Canadian Practice with respect to the Mitigation of Seismic Sound in the Marine Environment

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