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I am providing Public Comment regarding the Otway Basin 3D Multi-client Marine Seismic Survey proposal¹.

The proposal to conduct seismic blasting for oil and gas exploration in our oceans will cause direct harm to ocean ecosystems. As seismic blasting is the stepping stone to fossil fuel extraction, plans to continue exploration are incompatible with achieving the Paris target of limiting global warming to 1.5 C. The proposal should be rejected outright. 

The Environment Plan (EP) submitted to NOPSEMA 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 measured to mitigate impact detailed.

The proposal to conduct seismic blasting using Special Prospecting Authority (SPA) permits sidesteps the usual government bidding and decision making process, facilitating hasty and highly damaging oil and gas exploration proposals to progress rapidly through the regulatory approvals process.

The marine life of our south east oceans are unique and under increasing threat from the expansion of the offshore oil and gas industry, including through seismic blasting exploration such as this proposal. Evidence that seismic blasting harms marine life is growing. 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 dead², as far away as 1.2 kilometres from the blast site.

Impacts on whale species

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. Specifically;

• September through to December is the feeding period for the EPBC listed endangered blue whale in the OA, with January through to June being the peak feeding time for the blue whale. 
• September through to February is feeding time for the pygmy right whale in the OA.
• November through to May is the feeding period for the sei and minke whale in the OA.
• October is the calving period for the EPBC listed endangered southern right whale in this region, and they will be migrating through the OA and nominated area around these calving periods.

Throughout the year this area has a resident population of blue whales and a variety of species of whales present during their migration routes. Sperm whales that have been recorded in the deep water areas of the OA off the west coast of Tasmania, with the greatest number of sightings occurring in October and November. 

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 surface 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 must be required to have a plane spotting for cetaceans everyday seismic blasting is proposed to provide a 10km sighting zone.

Impacts on Marine Parks

The OA for this 55000 sq km seismic blasting proposal includes large areas of the Zeehan Marine Park off the north west coast of Tasmania. The EP fails to address the ecological significance of this vast marine park and the species known to inhabit it, and most importantly the impacts seismic blasting will have on the species known to be in the area during projected operational periods.

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 on marine life is well beyond the described zone in this EP. 

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. 

The EP must be refused based on the failure to provide adequate information in the form of a map outlining the RAMSAR areas, National Parks, State Marine Parks, Indigenous Protected Areas, Wilderness Zone, World Heritage Areas and Key Ecological Features. The entire footprint of the EMBA contains Biologically Important Areas for EPBC listed species and this must be provided for public consultation and comment. The current information provided on EMBA impacts is insufficient, NOPSEMA should enforce that the proponent supply clear, comprehensive and comprehensible information on these environmental areas of relevance to allow fully informed public comment on the EP. 

This seismic blasting proposal should be refused due to the impacts on marine life and our oceans. 

Regards

References

1 https://info.nopsema.gov.au/environment_plans/617/show_public
2 https://www.nature.com/articles/s41559-017-0195