Submission on seismic testing in NW Tas oceans

The members of the Tasmanian Climate Collective  (TCC) have come together to provide Public Comment regarding the Otway Basin 3D Multi-client Marine Seismic Survey proposal (1).

Before we make comments on the details in the plan, or lack thereof, we would like to register the David vs Goliath nature of this process. 

Like many community groups and individuals who object to the damage done to our shared marine environment by oil and gas companies, we are entirely volunteer run. Yet it is down to us to present the publicly available scientific evidence that seismic testing damages our marine environments in the midst of a biodiversity crisis - in our spare time.  

Meanwhile, powerful entities such as TGS and SLB-Schlumberger have teams of paid employees who produce vast amounts of documentation in support of their profit motivated case. 

We rely on NOPSEMA to demonstrate adherence to their stated purpose “To assure the protection of lives and the environment” in a way that will be defensible to current and future generations.

The proposal to conduct seismic blasting for oil and gas exploration in our oceans will cause direct harm to ocean ecosystems (2, 3). 

Seismic blasting is the stepping stone to fossil fuel extraction, whose continued polluting emissions are driving catastrophic climate change. Plans to continue exploration are incompatible with achieving the Paris target of limiting global warming 1.5 C and maintaining a safe planet for our kids and future generations. The proposal should be rejected outright.

Insufficient Detail in the EP

The Environment Plan (EP) submitted to NOPSEMA by TGS on behalf of the partnership with SLB-Schlumberger to conduct seismic blasting over 55,000 sq km of ocean between Victoria and Tasmania is lacking in sufficient detail on the impacts of seismic blasting on noted species in the area. In particular, details on what measures will be taken to avoid harming marine life, and enforceable measures to ensure that the key ecological features and threatened species in these areas will not be harmed. This EP needs to be refused outright as the impacts to our ocean environment and marine life have not been adequately considered, or measures to mitigate impact detailed.

Unacceptable impacts on pakana/palawa cultural resources

The proposed seismic survey has the potential to negatively impact on significant cultural sites and values across north-west Tasmania. The North-West tribe of Tasmanian Aboriginal people were a maritime people occupying the coastal strip and the islands off the west and north-west tip of lutriwita/Tasmania, with eight tribes within the north-west tribal grouping. These coastal areas continue to be important to the palawa/pakana people for seasonal yula (mutton bird or Short-tailed Shearwater) and other traditional shellfish harvesting and connection to country and traditional cultural practices.

Palawa/pakana culture, like so many other cultural and economic activities in north-west Tasmania, relies on a healthy marine environment. The Short-tailed Shearwater breed and feed their chicks throughout summer in Tasmania, flying long-distances off the coastline to gather food for their growing chicks, with krill the most important part of their diet. Krill and other small fish are known to be killed by seismic testing (2). Earlier this year a cold-water upwelling off western Tasmania saw local naturalists recording krill being washed up on beaches in large numbers from Strahan through to Marrawah on Tasmania’s west coast. These small creatures thrive in this proposed seismic testing area and underpin a healthy marine environment off Tasmania and Victoria.

Short-tailed shearwaters, as long-distance migratory birds, are under stress due to many other environmental factors, including increasing light pollution from activity within their range, and it is important that their food source is protected in their breeding grounds. Short-tailed Shearwaters are also a licensed commercial and recreationally harvested species, highly valued by the north-west Tasmanian community.

Unacceptable impacts on Tasmanian fishing communities

Tasmanian wild fisheries contribute significantly to our island identity and economic value. We have high-value markets for shellfish, crustaceans and scale fish and there are also almost 100,000 recreational fishers in Tasmania according to the Tasmanian Association of Recreational Fishing. The proposed seismic testing will impact on many of our local fisheries and reliant communities including the ports at Currie on King Island, Stanley, Strahan and other smaller harbours.

Objection to use of the SPA permit

We particularly object to the use of a Special Prospecting Authority (SPA) permit. We feel this undermines public confidence in this process, since it bypasses the usual bidding process which is overseen by the federal government. There is increasing public interest in the integrity of oil and gas exploration approval processes. As a community organisation deeply committed to careful scrutiny of industries and processes that harm people and places we love, TCC is compelled to encourage this public interest.

Research has shown that seismic blasting results in serious harm to a variety of marine life from deafening whales and disrupting their feeding and migration, damaging the ability of southern rock lobster to function and navigate, and causing mortality in small fish and zooplankton.  After seismic blasts, many zooplankton are found dead (2), as far away as 1.2 km from the blast site.

Unacceptable impacts on Cetaceans

The proposed start date for this operation is October 1 2023, and seismic blasting in the Operational Area (OA) taking place over summer would see seismic blasting over critical whale habitat and Biologically Important Areas (BIA), threatening EPBC listed species and critical feeding, calving and migration routes.

Allowing seismic blasting in these periods fails to protect these whale species from the impacts of seismic blasting. The measures described of having a person stand (marine fauna spotter) on a boat to spot whales, and reduce the scale of seismic blasting frequency if they are spotted is ineffective. Whales live below the ocean and below the field of view of a person standing on a boat. Many of the affected species can dive for prolonged periods of time, and will not be sighted if in the area below water. Seismic blasting during known periods of presence for these identified species will inevitably lead to harm, hearing loss and disruption in navigation, feeding and breeding activities of cetaceans in the area. At a minimum TGS/SLB must be required to have a plane spotting  and deep sea detection for cetaceans everyday seismic blasting is proposed to provide a 10km sighting zone.

Unacceptable impacts on Marine Parks

We are quite shocked that the OA for this 55000 sq km seismic blasting proposal includes large areas of the Zeehan Marine Park off the NW coast of Tasmania. The EP fails to address the ecological significance of this vast marine park and the species known to inhabit it.

This is an unacceptable level of impact on our marine parks, both from the immediate seismic blasting proposed within the Zeehan Marine Park, and the marine parks bordering the OA. Research has shown seismic blast noise travels over 100 km in the oceans, meaning the impact to marine life is well beyond the described zone in this EP.

Marine parks are established especially for the conservation of biodiversity under the World Conservation Union Guidelines. They act as a reference or baselines in scientific studies to assess the impact of other activities, like fishing or in this instance oil and gas exploration. It is completely unacceptable to undertake seismic testing that will impact a marine reserve.

Unacceptable risks to Environments that May Be Affected (EMBA)

The Environment that may Be Affected (EMBA) for this project shows vast areas would be harmed by any spills or incidents during proposed operations, as well as any time vessels are in the area preparing for seismic blasting, refuelling, resupplying or in transit. This includes 34 threatened and migratory species identified as having important habitat that overlaps with either the OA and/or the EMBA.

Despite the level of threat to many species and ecosystems, a detailed map of these threats is not available.

As stated in the 2021 Senate Report, Making waves: the impact of seismic testing on fisheries and the marine environment, “On 16 February 2021, the Australian Senate called on NOPSEMA to apply the precautionary principle when independently assessing the impacts of seismic testing and processing permit applications acknowledging the research gap surrounding the impacts of seismic testing on local communities and local industries that depend on healthy oceans and coastlines” (4). We call on NOPSEMA to apply this principle by rejecting the Otway Basin 3D Multi-client Marine Seismic Survey proposal.

References

(1) https://info.nopsema.gov.au/environment_plans/617/show_public

(2) https://www.nature.com/articles/s41559-017-0195

(3) https://www.nature.com/articles/s41598-019-55500-4

(4)https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Environment_and_Communications/SeismicTesting/Report