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It's not too late to have your voice! Our Club is opposes the submission and Environmental Plan. If you wish to oppose this plan, please have your say here:

The Club position and summary of the Environmental Plan can be seen below. Please feel free to use it if it can assist you in your submission.

All comments MUST be directly related to the Environmental Plan. Any comment containing objections to oil/gas/fossil fuels, reference to climate change, or asks questions WILL NOT BE CONSIDERED.


The Environmental Plan submitted for 3D Seismic Survey of the Otway and south west coast is flawed, does not take into account the risks to the ocean, ecosystem, tourism and the wider environment. In the modern day, there is no place for seismic surveys and my submission below will specifically detail a variety of reasons this Environmental Plan and survey should be rejected in its entirety.

· The Australian Government is currently developing National Anthropogenic Underwater Noise Guidelines. I think a moratorium should be in place on all applications for approval of environment plans until the national guidelines have been completed.

· The Operational Area and Environment that May be Affected overlaps Biologically Important Areas for EPBC listed species. Impacts and risks to all species is inconsistent with their respective Conservation Management Plans, which are designed to legally protect these species.

· There is no need for 3D seismic surveys of this nature. A Senate Inquiry recently heard that modelling the large amount of existing 2D data is possible. Other less destructive technologies are available for surveying, but the industry is not likely to take them up until it is required by Government law.

· Misrepresentation of the Bonney Upwelling and its connection to the valuable

feeding grounds in the Operating Area (OA). Bonney Upwelling is misrepresented by the applicant, with consideration not given to the entire area of productivity driven by the upwelling. The applicant has merely shown the surface ocean current affect from the upwelling. The entire Operating Area is part of the productive area, a major reason for the species that uniquely exist and feed here such as Blue Whales. Use of unrepresentative samples of the OA for assessing the presence of whales and birds. No assessment of the threat to the Short Fin Eel and its importance to Budj Bim UNESCO World Heritage site.

· Impacts and risks to the ecosystem. There are huge knowledge gaps on direct and indirect effects of seismic testing on all organisms, with many things assumed or not allowed for in this plan. Existing research has been misquoted and also ignored in the Plan. The survey area is home to feeding aggregations of species such as Blue Whales and their protection & management plans are not being applied here. Seismic threatens large populations of vulnerable, threatened and endangered birds, and that TGS has not assessed the risks accurately. An example of this is the Middle Island Penguin colony, no consultation and it is within immediate proximity of the survey area.

· Zooplankton (including krill) are not adequately evaluated. The cumulative impact of increased zooplankton mortality up to 1.2km from the seismic airgun, and subsequent impacts to higher order consumers have not been assessed.

· Flawed assumptions in the JASCO modelling which is used in the Environmental Plan. During data acquisition, the discharge interval is given as 18¾ metres for dual-source airguns or 12½ metres for triple-source airguns, corresponding to a 235dB discharge every 5 to 8 seconds. The data acquisition will occur continuously for 24hours a day, seven days per week, for up to 200 days per year, except for the time in which the survey vessel is changing direction in its “racetrack” pattern. Once a survey pattern commences, there is no respite from the noise until the total pattern is completed. The modelling submitted does not utilise data acquisition in the method, with less operational hours and a resulting huge difference to the total exposure.

· Noise Pollution: inadequate recognition that noise-induced damage is cumulative. Specific lack of information on exposure time and lengths of survey runs.

· Given large gaps in scientific knowledge, it is impossible to determine risks and impacts are of an “acceptable” level. Ecosystem-scale impacts have not been researched at all in the region. More research is needed, and a precautionary approach is required in the interim.

· No consideration of cumulative impacts of seismic blasting on marine species, including impacts to food webs and displacement of keystone species.

· Inadequate Risk Management Planning and Risk Mitigation. The risk management plan and mitigation are not appropriate for this survey. The plans should cover identification, assessment, mitigation, management and consequences to both-

1. Marine life and species, individually, and

2. Overall ecosystems, habitat and food chains.

Consideration of the flow-on impacts needs to be provided, with identification and assessment of the risks, impacts and consequences for-

a. The local region overall – communities, businesses, livelihoods, and jobs,

b. The social costs associated with such impacts and consequences.

c. Fishing and tourism in the short and long term need to be assessed.

TGS need to state accurately the risks of seismic surveys to the marine ecosystem within the Operating Area. The Environment Plan submitted by TGS is a deficient, inaccurate evaluation of the mounting scientific evidence about the destruction caused by seismic surveys. The Risk Management Plan and risk mitigation are not fit for purpose.

· Incomplete and inadequate community consultation. This Environmental Plan and consultation was not advertised broadly and many stakeholders, including myself have not had sufficient time to thoroughly consider every aspect of the Plan. An application of some 1,450 pages (with seven pages of references) that requires a response within 30 days is unreasonable, unfair, and unachievable to adequately assess to the capacity required for basic review (let alone thorough review).

· I call upon NOPSEMA to reject seismic surveys during the months when Sooty Shearwaters, Southern Blue Fin Tuna, Pygmy Blue Whales or Southern Right Whales are present in and around the survey area. These specific species are all of significant environmental, social and biological interest and value that cannot bear the risk to loose or be effected, this covers all months of the year and I therefore request this Environmental Plan is rejected, along with the project in its entirety.

· In summary, as put forward by the Clean Ocean Foundation, the EP should not be accepted by NOPSEMA in its current form because:

• TGS has not adequately evaluated impacts and risks;

• TGS has not demonstrated that the impacts and risks are of an acceptable level;

• TGS has not adequately demonstrated that the impacts and risks will be reduced to low as reasonably practicable; and

• TGS has not consulted with all relevant persons.

Area shaded in red is the operational area. Please note the green boundary area, listed as 'environment that may be affected'

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