Government of Newfoundland and Labrador Department of Natural Resources Office of the Minister

April 20, 2020

Honorable Seamus O’Regan Minister of Natural Resources Canada 580 Booth Street Ottawa, ON K1A 0E4

Dear Minister O’Regan:

I write in follow up to our ongoing discussions regarding the unprecedented challenges facing Atlantic Offshore Oil and Gas Industry during this COVID-19 pandemic.

On Friday, your government announced a commitment of $1.7 billion to address orphan wells in Alberta, Saskatchewan and British Columbia and the establishment of a $750 million emissions reduction fund, with a focus on methane. An allocation of $75 million was made to Newfoundland Labrador. While we support this initiative and appreciate this allocation, there are negligible issues relating to methane offshore and the conventional oil produced here represents one of the lowest carbon per barrel footprints in the world, an average of under 19 kg CO2 equivalent per bbl. Based on Hibernia alone, our largest producer, the footprint is 11.0 kg C02 equivalent per bbl in 2017. Furthermore, offshore operators confirmed in January that they are already fully compliant with Natural Resources Canada methane measures when they come into force.

We fully support the need to protect the environment and our approach offshore has been mirrored on the Norwegian model who continue to produce significant volumes of oil and gas. In fact, Norway’s production has steadily increased since 2012 due to the Norwegian government’s policy to stimulate exploration to direct tax payments. We, like Norway, seek to do so at the lowest carbon impact per barrel to displace higher carbon per barrel crude to fulfill ongoing world demand.

The importance of the oil industry to the economy of Newfoundland and Labrador cannot be overstated nor replaced by any other sector in our economy. A 2019 study by the provincial Department of Finance found that over the eight year period from 2010 to 2017, total (direct, indirect and induced) economic benefits related to the offshore petroleum industry in Newfoundland and Labrador accounted for nearly 30% of GDP, 13% of labour compensation and 10% of employment. In 2018, the latest available year for data, oil extraction alone is estimated to have directly accounted for approximately 18.5% of total provincial GDP. Budget 2019 estimated that the offshore would contribute $1.1 billion in royalties in 2019-20, making up 19% of total provincially sourced revenue. Further, it is a significant contributor to the revenues for the Government of Canada. Operations from Offshore oil companies have paid, through the tax allocation formula, approximately $2.1 billion in direct federal corporate income tax alone during the period 2000 to 2017.

To this end, the Province has invested approximately $190 million in recent years for the collection of seismic data offshore that reveals significant prospectivity. This has resulted in historic interest offshore, with over $4 billion in exploration work commitments over nine years which

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represents a significant opportunity to capture this foreign direct investment. This investment is at risk given the current environment.

Unfortunately, there have been significant delays in the issuance of exploration licenses these last several years resulting from the process change of responsibility for environmental assessment from the Canada Newfoundland and Labrador Offshore Petroleum Board (C-NLOPB) to the Canadian Environmental Assessment Agency. Due to this change, license issuance periods have increased from an average of one year to over 900 days. The implementation of the new Regional Assessment, scheduled for the end of May, is essential to addressing this delay, protecting the environment and ensuring the development of this important commodity.

Prior to the current pandemic, there were eight companies, pursuing Environmental Assessment to begin exploration programs. This year there were three exploration drilling programs planned by ExxonMobil, Equinor and CNOOC. CNOOC was forced to delay exploration drilling plans for this year due to rig location in Europe.

We have also seen changes in seasonal storage plans relating to both the West Aquarius and the Transocean Barents drill rigs currently operating in the offshore. Plans to store these rigs at the Bull Arm site upon completion of their current programs have been cancelled. It is our understanding that both rigs will now go to Norway upon completion of the current drill program where there is an exploration investment offered by the Norwegian government. ExxonMobil is reducing its exploration program and releasing the West Aquarius rig due to financial constraints and it will no longer be “cold stacked” at the Bull Arm site as previously planned. Plans for a thruster refit of the Transocean Barents at the Bull Arm Fabrication site upon completion of its current drill program where it was to be “warm stacked” have also been cancelled.

These revised plans create serious concerns with how the future exploration program may unfold. No single industry has the potential to put our province back on a path to economic self- sufficiency then its oil and gas industry and no single aspect of that industry is more vital to that goal than exploration.

Further, we are seeing decisions happening now by companies in our offshore that are going to have serious impacts on the Province’s economic recovery post pandemic. Given the size and scope of the offshore operations, these decisions have impacts ranging for years. For example:

• Hibernia has recently announced the suspension of the drilling program to offset decline in the offshore. • The Terra Nova FPSO refit scheduled for May is suspended. The production facility has been holding since December 2019, no longer producing and no clear line of site for production. • The decision gate 2 (DG2) for the Bay du Nord project scheduled for June 2020 is deferred. • The West White Rose Project has been deferred negatively affecting the Province’s economy in 2020 and delaying the important royalty revenue from that project. • CNOOC has suspended its exploration plans for 2020.

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These decisions represent an estimated $6.2 billion of oil and gas industry expenditures that will not occur through to 2023.

The global nature of the industry operating offshore, the advance planning requirements for these projects and the existence of the global portfolios of these companies will all contribute to the challenges of recovering once they have made alternate investment decisions. These decisions made now, unless mitigated, will have lasting impacts that will be irreversible in the short to medium term and will be devastating to the Newfoundland and Labrador economy as well as hamper economic recovery nationally.

Given these concerns and the significant contribution of the industry to the economy, we submitted to you three priority areas for support of the industry. These proposals related to preserving and accelerating exploration offshore and helping to preserve the financial liquidity for industry. I cannot emphasize enough the urgency of this matter or the need for this Net Present Value positive investment. Our government appreciates and understands the need for the greening of the economy and will continue to invest in activities to achieve such environmental and economic balance. I submit that the world will require oil for decades to come and that supply from the province of Newfoundland and Labrador, one of the lowest carbon per barrel oil in the world, with strict environmental and safety requirements, is important.

The exploration well program would deliver significant positive economic value to Newfoundland and Labrador and Canada. As indicated and demonstrated in the EY study provided to your office, a single $100M exploration well that does not make a discovery drives almost double the national economic benefit, increases national GDP by $84M and creates 628 in annualized jobs (with almost 800 jobs created at peak employment). In addition to the national benefits, the Province of Newfoundland and Labrador would see an increase in economic benefit of $ 36 million, additional GDP of $ 54 million and approximately 370 jobs. In the very likely event that discoveries arise from this investment, a single 800 million barrel discovery could result in a $14.5B development project that would produce for 30 years and would have the potential to increase Canada’s annual GDP by $2.3B and support ~4,400 jobs. Newfoundland and Labrador as a province would see an economic benefit of $2.3 billion and an increase of 3,000 jobs and the NPV10 to the Federal government for such a discovery is $1.250B.

The re-implementation of the federal 10% Atlantic Investment Tax Credit (AITC) for a fixed period of time would provide a regional credit supporting capital investment in the Atlantic Canada offshore area. The AITC was phased out for oil and gas from 2012 through to 2016. Re-opening the AITC to the oil and gas sector in the Atlantic region would increase the economics of projects from both a net present value and internal rate of return analysis. A refundable credit could further support the short-term cash investments made in the sector without impacting the long-term costs associated with the program. The analysis provided by EY indicates that every $7M in value to the companies would leverage $100M in capital investment by those companies.

The introduction of 100% immediate deductibility of capital costs would enhance the accelerated write off provisions introduced in the 2018 Federal Fall Update and eliminate available for use rules (e.g. capital costs outside of Canadian Exploration Expenses would now be written off at

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100% in the year incurred.) The goal would be to incent companies to continue with capital plans by providing near term liquidity support and markedly improving the project’s economics.

These programs would support both the near term exploration as well as support near term capital investment by the companies which would help support the regional economy as well as maintain employment in the supply and service community.

Canada and Newfoundland and Labrador have the opportunity during an economic downturn to maintain and even accelerate investment in the Newfoundland and Labrador offshore and supply the global marketplace with Canada-Newfoundland and Labrador energy, produced with highest human rights, safety, and environmental standards, while providing a significant positive impact to the economy of both the province and country. We ask Canada to support Newfoundland and Labrador and benefit from these efforts.

The offshore oil and gas industry has yielded incredible economic activity and growth not only for the province but for the country. In Imagine the Potential, an economic impact study undertaken by NOIA, it estimates that based on the goals of Advance 2030, Newfoundland and Labrador would receive over $100 billion in taxes and royalties (a similar amount, based on historic results, would be accrued to Canada), 56,000 potential jobs in Newfoundland Labrador and 78,000 potential jobs in Canada – this from offshore oil that is 30% below the global average of GHG submissions.

Indeed, the environmentally responsible and committed green economy country of Norway is working to explore and develop its oil industry. We ask Canada to do the same and to support Newfoundland and Labrador in its efforts to supply the world, develop the economy and rise strongly from the impacts of Covid 19.

I am available at your convenience to continue to work toward a stronger economy.

Sincerely,

SIOBHAN COADY, MHA St. John’s West Minister

P.O. Box 8700, St. John’s, NL, Canada A1B 4J6 709 729 2920 709 729 0059 www.gov.nl.ca