I am providing Public Comment regarding the Otway Basin 3D Multi-client Marine Seismic Survey proposal.
I am writing to you as a relevant person who is concerned about the impacts of the proposed seismic blasting.
The impacts from the proposed project have not been reduced to Acceptable Levels. The Environment Plan (EP) submitted to NOPSEMA to conduct seismic blasting in the Otway Basin is lacking in sufficient detail on the impacts and measures to mitigate these impacts.
This seismic blasting will cause direct harm to the ocean ecosystem. It is lethal for marine life, impacting all levels of the food chain from zooplankton (1) to whales (2). Krill and zooplankton are cornerstone species that are the main source of food for many larger animals. Their eradication would cause a catastrophic chain reaction that would affect the entire marine ecosystem.
Seismic blasts impact the breeding, feeding, and migration of whales, making them vulnerable to errors in navigation and to predation. They can cause whales to experience temporary or permanent hearing loss, which impacts their navigation, communication, and search for food since they rely on echolocation.
Impacts to our ocean environment and marine life have not been adequately considered, and the measures to mitigate these impacts are not sufficient. The use of a marine fauna spotter to spot whales and reduce the scale of seismic blasting frequency if they are spotted is ineffective as many of the affected species can dive for prolonged periods of time, and will not be sighted if in the area below water. This does not stop the impact of causing mortality in small fish and zooplankton.
This EP will not protect local fishing industries. Seismic blasting is deadly for marine life and decimates seafood populations, causing mortality in small fish and reducing catch size (3). These stocks may take many years to recover. Seafood and fish stocks may take many years to recover, as has been the case in commercial scallop fisheries in Bass Strait (4).
There is an unacceptable level of risk to the local tourism industry. Local seafood and wildlife and recreational activities such as fishing are a massive part of the local marine tourism industries that will be affected by this seismic blasting.
The OA extends through whale Songline Country. Traditional owners, keepers of whale songlines, have stated that this and any other gas and oil projects within their traditional waters have no permission to proceed. The Southern Ocean Protection Embassy Collective’s Citizens Protection Declaration condemns all new and existing seismic testing and gas mining exploration approvals across the south west Victorian coastal waters covering Gunditjmara Sea Country.
The proposed project contravenes the OPGGS Act, as it interferes with fishing, marine conservation, and activities of other marine based industry. It also contravenes the EPBC Act* protecting threatened and migratory species, natural ecosystems and marine areas, as well as Article 32, Item 2 of the UN Declaration on the Rights of Indigenous Peoples.
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.
A Senate Inquiry into the use of seismic blasting to locate and drill for oil and gas under the seabed found opposition from coastal communities, weak regulation, and outdated science. No more seismic blasting should be done until there is an understanding of the broader impacts of seismic testing on marine ecosystems.
This seismic blasting proposal should be refused due to the unacceptable impacts noted above.
I am a frequent visitor to the Surf Coast and the Great Ocean Road. I consider the environmental, cultural and social impacts of seismic blasting in the Otway Basin unacceptable.
(1) McCauley, R, Day, R, Swadling, K, Fitzgibbon, Q, Watson, R and Semmens, J, 2017, ‘Widely used marine seismic survey air gun operations negatively impact zooplankton’, Nature Ecology & Evolution, vol. 1(7), (accessed June 2021).
(2) Weilgart, L. (2013). “A review of the impacts of seismic airgun surveys on marine life.” Submitted to the CBD Expert Workshop on Underwater Noise and its Impacts on Marine and Coastal Biodiversity, 25-27 February 2014, London, UK. Available at: http://www.cbd.int/doc/?meeting=MCBEM-2014-01
(3) ‘Seismic surveying reduces whiting catch rate by 99.5 per cent, research finds’, Rio Davis, https://amp.abc.net.au/article/12502930
(4) Submission to the senate inquiry: Impact of seismic testing on fisheries and the marine environment. 2019. IMAS Submission 34. Hobart: IMAS [online], https://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Environment_and_Communications/SeismicTesting/Public_Hearings (accessed June 2021)
*Environment Protection and Biodiversity Conservation Act 1999
Yours sincerely,
Peter Campbell
