Inadequate marine animal protections.

This assessment is not based on current best knowledge for adequate marine mammal protections, this must be revised appropriately before approval. 

1. Mitigation measures are too focused on vertical seismic profiling (VSP) operations and auditory injuries. 

2. The Impact Assessment Agency (Agency) minimizes the actual duration of the proposed operations and potential spatio-temporal overlap with other concurrent projects. 

3. The agency fails to consider the impacts of anticipated drilling noise-induced displacements of individual animals and their population-level consequences. 

4. The Agency minimizes the importance of the project area for marine mammals. 

5. The assessment of cumulative effects is incomplete and ignores available tools to improve this evaluation.

6. The Agency fails to appreciate the importance of underwater noise in its assessment of habitat quality.

7. The assessment of impacts does not align with the Government of Canada's upcoming Ocean Noise Strategy for Canada.

8. The Agency fails to propose concrete actions to minimize and understand the cumulative effects of the proposed activities.