Santos Offshore – Impact Assessment of Bird Deterrent Systems at Offshore WHP on Seabirds

1 Introduction It is apparent on a number of Santos’s offshore facilities that the increasingly large number of birds resting on the unmanned well head platforms (WHPs) have become a health and safety hazard. Presence of the birds introduces the risk of bird strike during helicopter operations (leading to potential helicopter crash and fatalities) as well as the build-up of large volumes of guano on the deck (causing loss of sight of helipad markings, increased risk of slips/trips/falls and biological waste hazards). As previously identified, a number of individual seabirds that have utilised the offshore platforms previously have encountered negative interactions with operations, primarily related to bird strike during helicopter operations. All of these events have been fatal for the individual seabird involved. Due to the health and safety risk to personnel and recurring bird strike events, Santos sought to actively mitigate this risk. Design studies were commissioned and following recommendations from subject matter experts, the installation and operation of a bird deterrent device incorporating a laser and noise emitting functionality were proposed to disperse resting seabirds. The objective of the bird deterrent device is twofold, firstly to mitigate risk to personnel from hazards discussed above and also to reduce/eliminate bird strike and impacts to individual seabirds. During this process and in consultation with the Department of Environment and Energy a Part 13 Permit (E2017-0141) was issued for the use of the bird deterrent device on the Reindeer WHP. Following successful operation and elimination of bird strike events and reduction in seabird use of the helideck area since installation, a mirrored installation on John Brookes WHP is proposed. As the current a Part 13 Permit (E2017-0141) only covers operation of bird deterrent device on the Reindeer WHP an updated application was submitted to the Department of Agriculture, Water and the Environment (DAWE) to include parallel use on John Brookes WHP. This document and associated information follow a request for further information on the application by DAWE. This impact assessment document therefore aims to assess the impact of the proposed bird deterrent system on seabirds which either have been recorded or have the potential to rest on the platform. Currently, the Reindeer and John Brookes WHPs provide a resting point for marine birds in the region. As the platforms are unmanned, there is no detailed information available on the behaviour of birds on the platform. However, ad hoc personnel observations, remote CCTV monitoring, the large accumulations of guano and regular maintenance reports confirm large number of birds present. There have been no reports of any nesting or breeding activity on the platform. 2 Bird Deterrent System The management strategy implemented for Reindeer platform includes the operation of a laser and noise emitting device (HyperSpike® Model: HS-14 RAHD) on the perimeter of the helideck. This device is currently installed and in operation on the Reindeer WHP with a current Part 13 Permit (E2017-0141). The management strategy implemented for John Brookes platform includes the installation and operation of a laser (optional) and noise emitting device on the perimeter of the helideck like that previously installed on the Reindeer platform. This device is not currently installed on the John Brookes WHP and installation is tentatively proposed for Q3 2020. Santos commissioned a basis of design study which included a detailed review of the available laser types and risks associated with the use of those lasers. Two classes of lasers were presented for selection. A class 2M laser, a low power laser operating at less than 1mW which is unlikely to cause eye damage due to accidental exposure; and a class 3B Laser, a medium power laser which operates between 5 and 499 mW and was noted as being powerful enough to cause eye damage, along with triggering requirements for registration with the Radiological Council of WA. The class 3B Laser was recommended for selection due to its effectiveness in bright sunlight compared to the Class 2M Laser, Santos selected the Class 2M due to the higher risks associated with the Class 3B laser. The noise emitting device (HyperSpike® Model: HS-14 RAHD) has a peak output of 148db @ 1m with a beam width of +/-12° (24° conical @ 2 kHz /-3 dB) and a stated maximum audible range of 1500m. A conservative noise impact survey was conducted and while primarily based on impact to human receptors although it is relevant to seabirds in this context. The laser and audio devices can be operated remotely, activated and controlled by operators in each respective facility Control Rooms. CCTV coverage allows operators to observe the effectiveness of the bird deterrent devices. The operating strategy is to manage the devices at the lowest audio setting to illicit a dispersion behaviour by the seabirds. This will further reduce potential injury to seabirds. The system can be set for either manual remote operations, or to activate and sweep automatically on a planned schedule. The bird deterrent system can be shut down and isolated remotely during helicopter approach by the pilot via the Pilot Activated Airfield Lighting Control (PAALC) interface. The PAALC is used as a remote means of halting the bird deterrent system via standard pilot operated systems already in use.

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3 Bird species Bird behaviours, such as foraging effort nearby, roosting and migration will influence the length of time the birds stay on the platforms and the effect the bird deterrent system may have. Behaviours are considered to be largely species dependent. Seabird species previously identified on the platforms include: + Brown Booby + Silver Gull + Masked Booby + Roseate Tern + Crested Tern + Bridled Tern + Lesser Crested Tern + Brown (Common) Noddy + Australian Gannet The EPBC Act lists both threatened (vulnerable, endangered or critically endangered) and migratory species that are protected under Commonwealth Legislation. A review of these species’ lists identified 21 species of threatened and/or migratory birds which may be present in the regional area. A summary of these species is provided in Table 1, along with a description of their geographical distribution and preferred habitat.

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Table 1 EPBC listed Threatened and/or Migratory species in the Regional Area Species name Common Status Breeding and habitat use in the regional area Potential Impact Name WHP Assessment Interaction Calidris canutus Red Knot, Endangered Species or species habitat known to occur within area – the red knot has a global distribution and Very Refer to Knot an extremely large range. It breeds in the northern hemisphere and undertakes migrations to spend the Unlikely Section 4.1 boreal winter in Australasia. The species generally inhabits intertidal mudflats, sandflats and sandy beaches during the non-breeding season. Calidris ferruginea Curlew Critically Species or species habitat known to occur within area – The species breeding range is restricted Very Refer to Sandpiper endangered to the Russian Arctic. In the non-breeding period, the species occurs throughout Australia around the Unlikely Section 4.1 coast and is also found inland. The general habitat includes intertidal mudflats in sheltered coastal areas such as estuaries, bays, inlets and lagoons. Limosa lapponica Western Vulnerable Species or species habitat may occur within area – The bar tailed godwit has an extremely large Very Refer to baueri Alaskan Bar- global range. Breeding does not take place in Australia. During the non-breeding season, the species is Unlikely Section 4.1 tailed Godwit found in coastal areas of all Australian states. The species is known to occur mainly in coastal habitats, such as large intertidal sandflats, banks, mudflats, estuaries and coastal lagoons. Limosa lapponica Northern Critically Species or species habitat may occur within area – The bar tailed godwit has an extremely large Very Refer to menzbieri Siberian Bar- endangered global range. Breeding does not take place in Australia. During the non-breeding season, the species is Unlikely Section 4.1 tailed Godwit, found in coastal areas of all Australian states. The species is known to occur mainly in coastal habitats, such as large intertidal sandflats, banks, mudflats, estuaries and coastal lagoons. Macronectes Southern Endangered Species or species habitat may occur within area – Southern giant petrels are highly migratory Very Refer to giganteus Giant Petrel Migratory species with a large natural range. They occur in Antarctic to subtropical waters and breed on six Unlikely Section 4.1 subantarctic and Antarctic islands. It is not expected they will use the area for breeding or resting. Malurus White winged Vulnerable Species or species habitat likely to occur within area – the species inhabits and breeds on Barrow Very Refer to leucopterus Fairy wren Island, located approximately 100 km south-west of Reindeer and 40km south-east of John Brookes Unlikely Section 4.2 edouardi (Barrow platform. The subspecies occurs in a single contiguous breeding population. They are known to inhabit Island) grasslands and low shrublands with dense ground cover. It is considered unlikely the species will use the platform for breeding/nesting. Numenius Eastern Critically Species or species habitat known to occur within area – the species is found in all states of Australia, Very Refer to madagascariensis Curlew, Far endangered with a continuous distribution from Barrow Island and Dampier Archipelago through the Kimberley and Unlikely Section 4.1 Eastern along the Northern Territory, QLD and NSW coasts. The species nests in the northern hemisphere Curlew summer, and travel to Australia for the non-breeding season. In Australia, the species occur in sheltered coasts, especially estuaries, bays, harbours, inlets and coastal lagoons. Pezoporus Night Parrot Endangered Species or species habitat may occur within area – The distribution of the Night Parrot is very poorly Very Refer to occidentalis known. There are accepted historical records from remote arid and semi-arid inland regions of Western Unlikely Section 4.2 Australia, Northern Territory, South Australia and Queensland. The species inhabits Spinifex grasslands on stony or sandy terrain, shrublands, floodplains and creeks or other water bodies. It is considered unlikely the species will use the platform for breeding/nesting. Pterodroma mollis Soft- Vulnerable Species or species habitat may occur within area – this species is found over both temperate and Very Refer to plumaged sub‐Antarctic offshore waters. Breeding is believed to take place in very low numbers at Mastsuyker Unlikely Section 4.1 petrel Island, Tasmania (6 pairs) with the rest of the population breeding on two southern Australian sub- and 4.2 Antarctic islands and there is a general northerly dispersion after chicks fledge during May to June. Soft- plumaged petrels breed in burrows among rocks and tussocks. Rostratula australis Australian Endangered Species or species habitat may occur within area – the species generally inhabits shallow terrestrial Very Refer to painted snipe wetlands, including temporary and permanent lakes, swamps and claypans. It prefers habitats with a Unlikely Section 4.2 good cover of grasses, rushes and reeds, low scrub, open timber or samphire. The species is widespread and not considered to have a limited geographic distribution.

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Sternula nereis Australian Vulnerable Breeding known to occur within area - The species utilise a variety of habitats, including offshore, Very Refer to Fairy Tern estuarine or lacustrine islands, wetlands, beaches and splits. Fairy terns nest above the high-water mark Unlikely Section 4.2 often in clear view of the water and on sites where the substrate is sandy, and the vegetation is low and sparse. Some Fairy Terns breed in the Pilbara; however, many use the area as an overwintering location before migrating south to breed in the lower west coast and Houtman Abrolhos regions. Anous stolidus Common Migratory Species or species habitat likely to occur within area – the species occurs mainly in ocean off the Potential Refer to Noddy Queensland coast, but also occurs off the north-west and central Western Australian coast. Western Section 4.3. Australia has the largest numbers of Common Noddies – 74% of Australian population, with approximately 132,000 pairs migrating through area from the Houtman Abrolhos alone (Surman et al 2018). During the breeding season, the Common Noddy usually occurs on or near islands, on rocky islets and stacks with precipitous cliffs, or on shoals or cays of coral or sand. The birds may nest in bushes, saltbush, or other low vegetation. They may also nest on the ground on grass or bare rock and in the forks of tall trees. Common Noddies migrate north from the Houtman Abrolhos to the Monte Bello Islands and into the offshore areas north (Surman et al 2018). Apus pacificus Fork-tailed Migratory Species or species habitat likely to occur within area – the species breeds in Siberia and is a non- Very Refer to Swift breeding visitor to all states and territories of Australia. It is found scattered along the Pilbara coast and Unlikely Section 4.1 migrates between Australia and Indonesia. In Australia, they mostly occur over inland plains, above foothills or in coastal areas. They mostly occur over dry or open habitats, including riparian woodland and tea-tree swamps, low scrub, heathland or saltmarsh. The Fork-tailed Swift is almost exclusively aerial Ardenna carneipes Flesh-footed Migratory Species or species habitat may occur within area - the species is a trans equatorial migrant, with Very Refer to Shearwater known breeding colonies in the Southern Indian and south-western Pacific Oceans. They nest in Unlikely Section 4.2 colonies in burrows under trees or shrubs, however most feeding is conducted offshore over continental shelves. Ardenna pacifica Wedge-tailed Migratory Breeding known to occur within area – the species is a pelagic marine bird known from tropical and Very Refer to Shearwater subtropical waters. The Montebello, Lowendal and Barrow Islands and islands of the Dampier Unlikely Section 4.2 Archipelago are important nesting areas for the species. The species usually excavates burrows on flat or flattish areas with dense grassy and tussocky vegetation, but much depends on the nature of soil and terrain, as at some sites burrows are below the cover of trees and shrubs. Surman et al 2018, found WTS migrate north to the 90 East Ridge from Varanus Island for the short mid-April to early August nonbreeding period. They are a non-roosting bird. Calonectris Streaked Migratory Species or species habitat likely to occur within area – the species is a trans equatorial migrant and Very Refer to leucomelas Shearwater can be found over both pelagic and inshore waters. Breeding occurs in colonies on offshore islands in Unlikely Section 4.2 Japan, occupying burrows on forested hills (Source: The IUCN Red List of Threatened Species). Fregata ariel Lesser Migratory Species or species habitat known to occur within area – the species has a very large range, with Very Refer to Frigatebird major breeding populations found in tropical waters of the Indian and Pacific Ocean. The Lesser Unlikely Section 4.2 Frigatebird breeds on small remote tropical islands, in mangroves or bushes, or even bare ground (Source: The IUCN Red List of Threatened Species). In Western Australia approximately 1000 nest on Bedout Island (Fuller and Burbidge 1998). Fregata minor Great Migratory Species or species habitat may occur within area - Major breeding populations of the Great Very Refer to Frigatebird Frigatebird are found in tropical waters of the Pacific and Indian Ocean, as well as one population in the Unlikely Section 4.2 South Atlantic. The Great Frigatebird breeds on small remote tropical islands, in mangroves or bushes, or even bare ground (Source: The IUCN Red List of Threatened Species). The nearest breeding area is Ashmore Reef.

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Hydroprogne Caspian Tern Migratory Breeding known to occur within area – this species is widespread throughout Australia and occurs in Unlikely Refer to caspia both coastal areas (including islands) and inland habitats. They breed in small colonies throughout north‐ Section 4.3. west Australia, including on the islands of the Dampier Archipelago and the Montebello/ Lowendal Islands. Nests may be in the open, or among low or sparse vegetation, including herb field, tussocks, samphire or other prostrate sand-binding plants. They sometimes nest near bushes or other shelter such as large sticks, driftwood, piles of beach cast seagrass. Caspian Terns are sedentary and forage in inshore waters adjacent islands so are unlikely to be forage at WHPs. Onychoprion Bridled Tern Migratory Breeding known to occur within area – widespread around tropical and sub‐tropical regions of Potential Refer to anaethetus Australia, most common on offshore islands. Breeding populations exist on Ashmore Reef and islands Section 4.3. of the Kimberly region and the Montebello/Lowendal/Barrow Islands. Nests are usually found in rocky areas or on coral, concealed in crevices or caves up to 1.5 m deep, under rocks, among talus or coral rubble, on ledges of cliffs, or on the ground beneath low shrubs, roots of Pandanus, vines or among grasses. Migration of WA population appears to be to the north to Indonesian waters. Bridled Terns migrate to the Celebes Sea where they overwinter Surman et al 2018. Sterna dougallii Roseate Tern Migratory Breeding known to occur within area – the species inhabits a variety of habitats including beaches, Unlikely Refer to reefs and sandy/coral islands. The Roseate Tern forage offshore and inshore, often in association with Section 4.3. pelagic fish activity. Breeding mainly occurs off the coast of Western Australia and populations are located around Bedout Island, Lowendal Group, Montebello islands and Ashmore Reef. Little information is available about migratory movements or timing.

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4 Impact Assessment of bird deterrent activities on potentially vulnerable species The objective of the bird deterrent is to remove or significantly reduce bird presence on the platforms. This has been achieved through the installation of a laser and noise-emitting device on the perimeter of the Reindeer WHP helideck. Installation of this infrastructure will be mirrored on the John Brookes WHP although this is restricted to noise-emitting capability only and without utilising laser. The effect of the bird deterrent is assessed below for all species listed in Table 1, based on the preferred habitat, breeding location, geographical distribution and migratory characteristics of the species.

4.1 Species with known breeding locations outside of Western Australia EPBC listed species which are known to breed outside of the region include the Red Knot, Curlew Sandpiper, Western Alaskan Bar-tailed Godwit, Northern Siberian Bar-tailed Godwit, Southern Giant Petrel, Eastern Curlew, Soft plumaged Petrel and Fork tailed Swift. These species are typically migrating birds and while there is no previous record of these species utilising the platforms, it is assumed that due to the physical presence of the structure there is potential for one or more of the species to use the platforms as a resting location only. Therefore, the largest impact on these species would be the removal of a resting location due to the bird deterrent activities. The removal of a resting location is not considered to have a significant impact on the species population for the following reasons: + These species have not been recorded utilising these offshore platforms as resting sites, therefore removing the WHPs as a potential resting location them will not negatively impact their migration and subsequent breeding activity. + The platforms have only been present in their current location since 2011 (Reindeer WHP) and 2004 (John Brookes WHP) and therefore have only recently become available to birds as a resting structure. It is unlikely to have altered bird behaviour on a generational or species-wide level. + Reindeer WHP: Alternative offshore resting locations are located nearby, with the nearest platforms being 10 NM (Wandoo platform) and 15 NM (Stag platform) from the Reindeer WHP. The nearest islands (Dampier Archipelago) are located approximately 30 NM from the Reindeer WHP. + John Brookes WHP: Alternative offshore resting locations are located nearby, with the nearest platforms being 17 NM (Wonnich platform – personnel access by vessel) and the nearest islands (Montebello Group and Barrow Island) are located approximately 22 NM from the John Brookes WHP respectively.

4.2 Species with distinct preferred breeding habitats Species whose preferred breeding and/or foraging habitats are significantly different to the habitat provided by the Reindeer and John Brookes WHPs are considered unlikely to rely on the platform as a refuge. This includes species who are known to excavate burrows during nesting season or to nest on soft substrate underneath trees and shrubs. + White-winged Fairy Wrens are known to specifically inhabit and breed on Barrow Island in a single contiguous breeding population. However, they are known to inhabit grasslands and low shrublands with dense ground cover. Very unlikely to interact with the WHPs. + Soft-plumaged Petrels breed in very low numbers at Mastsuyker Island, Tasmania (6 pairs) with the rest of the population breeding on two southern Australian sub-Antarctic islands. In addition, they are known to breed in burrows among rocks and tussocks. Soft-plumaged Petrels forage in open ocean environments well off the continental shelf and are very unlikely to interact with the WHPs. + Flesh-footed Shearwaters nest in colonies in burrows under trees or shrubs. However, most feeding is conducted offshore over continental shelves. This species migrates north from southern breeding areas before heading west into the tropical Indian Ocean from the Houtman Abrolhos (Powell 2009). Very unlikely to interact with the WHPs. + Wedge-tailed Shearwater: The Montebello, Lowendal and Barrow Islands and islands of the Dampier Archipelago are known important nesting areas for the species. However, the species usually excavates burrows on flat or flattish areas with dense grassy and tussocky vegetation or below the cover of trees and shrubs. Very unlikely to interact with the WHPs. + Streaked Shearwaters breed in colonies on offshore islands in Japan, occupying burrows on forested hills. Streaked Shearwaters do not approach structures or vessels. Very unlikely to interact with the WHPs.

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+ Night Parrots have been reported in remote and semi-arid inland regions, with their preferred habitat considered to be spinifex grasslands, stony or sandy terrain or salt flats. As these are restricted to the mainland, they are very unlikely to interact with the WHPs. + Australian Painted Snipes generally inhabit shallow terrestrial wetlands and prefer habitats with a good cover of grasses or shrubs. Very unlikely to interact with the WHPs. + Great Frigatebirds have known breeding populations in the Pacific and Indian Ocean, as well as one population in the South Atlantic. The Great Frigatebird breeds on small remote tropical islands, in mangroves or bushes, or even bare ground. Non roosting birds. Nearest colony at Ashmore Reef. Very unlikely to interact with the WHPs. + Lesser Frigatebirds: as Great Frigatebirds above. Nearest colony at Bedout Island 1000 pairs – (Fuller and Burbidge 1998). Operation of the bird deterrent system is not considered to have a significant impact on the local species population as none of the abovementioned preferred breeding habitats are present on Reindeer or John Brookes WHPs, and the platforms are therefore unlikely to have become a refuge or breeding site for these species. 4.3 Species known to nest in the Region under similar conditions Although nesting or breeding has not been observed at Reindeer or John Brookes WHPs, as a conservative measure Santos has conducted an impact assessment on species which could potentially breed on the platforms. The proposed bird deterrent systems are most likely to have an impact on breeding species, in particular on fledglings. This could have an impact on a species population if the species is geographically very limited in its distribution. Species are considered on a case-by-case basis in more detail below: + The Common Noddy can nest under a variety of different circumstances, including on bare rock and in the forks of tall trees. It is therefore considered feasible that nesting conditions are satisfied by the WHPs. The Common Noddy is one of the most numerous breeding species in Western Australia and represents approximately 74% of Australian population. Historically they have been known to nest on offshore facilities and have been recorded building nests on other WHPs and at manned FPSOs. The species is considered to be mostly stable in Australia and is not considered as a threatened species. For this reason, it is considered unlikely that the operation of bird deterrent systems on the WHPs will have a measurable impact on the species, even if nesting has occurred in isolated instances. + Caspian Terns breed in small colonies throughout north‐west Australia, including on the islands of the Dampier Archipelago and the Montebello/ Lowendal Islands. Nests may be in the open, or among low or sparse vegetation or other shelter. It is therefore considered feasible that nesting conditions are satisfied by the WHPs. However, the species has a widespread occurrence in both coastal and inland habitat within Australia, and is also known to breed in North America, Africa and Eurasia. For this reason, it is considered unlikely that the operation of bird deterrent systems on the WHPs will have a measurable impact on the species, even if nesting has occurred in isolated instances. + Bridled Terns are most common on offshore islands in tropical and sub-tropical regions of Australia, with known breeding populations on Ashmore Reef and the Montebello/Lowendal/Barrow Islands. Nests are usually found in rocky or concealed areas, such as under rocks, among coral rubble or on the ground beneath low shrubs. Due to the regional presence of breeding populations it is considered possible that favourable nesting conditions are satisfied by the WHPs. However, the species is widespread in Australia, with subspecies also widespread globally, although the population numbers are unknown. As the species is not listed as threatened, it is considered unlikely that the operation of bird deterrent systems on the WHPs will have a measurable impact on the species, even if nesting has occurred in isolated instances. Bridled Terns can roost in reasonable numbers usually on structures closer to the seas surface rather than on exposed helidecks (Surman per comms). + Roseate Terns in Australia breed mainly off the coast of Western Australia and Queensland, with known breeding populations located around Bedout Island, the Montebello islands and Ashmore Reef. Globally, the species occurs in North and South America, the eastern Atlantic coast and Asia. Due to the wide geographical spread of the species population and the fact that the species is not listed as threatened, it is considered unlikely that the operation of bird deterrent systems on the WHPs will have a measurable impact on the species, even if nesting has occurred in isolated instances. As mentioned in Section 4.1, the short duration of the presence of the platforms and the location of alternative nearby platforms/islands means that the bird nesting effort and behaviour would not be significantly affected on a generational or species-wide level (i.e. short term behavioural impact to a small proportion of the local population only).

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4.4 Holistic assessment of potential impacts to individual seabirds on the WHPs from bird deterrent system 4.4.1 Physiological impacts The consequence of any physiological impacts to individual seabirds is considered negligible. These potential impacts include permanent impacts to hearing and burns/skin damage to individuals. The inherent design of the bird deterrent system mitigates significant potential impacts to the hearing of individuals. Avian hearing encompasses a narrower range of frequencies than human hearing; within that range, avian hearing is less sensitive than human hearing (Beason 2004). Controls include a variable volume control managed to a level to illicit a dispersion/deterrent response and variation in dispersion tracks. This operating philosophy aligns with a principle of applying lowest effective volume range and short intermittent noise events. This is paired with remote monitoring to measure effectiveness. This remote monitoring is undertaken by Santos personnel via CCTV of the existing bird deterrent device on Reindeer WHP, and has shown that when operated the seabird behaviour is to disperse from the top level of the WHP immediately, which further reduces the risk of prolonged exposure to noise. The sound level decreases and deteriorates with distance which further reduces the potential impact area and risk of hearing damage. The potential risk of burns/skin damage by the laser component of the bird deterrent system to individual seabirds is also considered low due to inherent design and operating functionality. The type of laser selected for use is of a power that will have minimum potential to cause damage to skin and eyes whilst remaining visual to the seabirds and effective. Santos commissioned a basis of design study which included a detailed review of the available laser types and risks associated with the use of those lasers. As discussed in Section 2 two classes of lasers were presented for selection and Santos selected the Class 2M due to the higher risks associated with the Class 3B laser. The selection of a low power laser means that it is unlikely to cause damage to the bird’s skin and retina. The laser design and installation ensured that the software limits the pan and tilt functionality and ensures that laser cannot lift beyond the horizontal plane. This ensures that the lasers are always pointed in a low downward angle and reduces the likelihood of contacting the bird’s eyes. The purpose of the laser is to illicit a threat reflex response by imitating movement and uses light arcing across the helicopter landing deck to achieve a deterring effect by operating in sweeping arcs on a continuously moving basis. Given this, if contact is made with an individual seabirds’ eye, this contact would by instantaneous and the light would immediately move out of the birds field of view. It is also noted that if the laser did contact a bird’s eye, this would prompt a reflex response to blink and would also prompt the bird move away. Note that it is not proposed to utilise the laser functionality at the John Brookes WHP and the laser function is only employed and in operation at the Reindeer WHP. 4.4.2 Behavioural impacts Potential behavioural impacts may include dispersion of seabirds from the WHPs to nearby areas such as other WHPs or islands for roosting/resting. Additionally, seabirds that are dispersed from the platform may be displaced from a small portion of seabird foraging habitat around the base of the WHPs as the structures are known to act as a fish attracting device. These potential impacts are considered negligible given the proximity of other nearby structures to rest/roost on, the abundance of foraging opportunities nearby and the decrease in dispersion efficiency of the bird deterrent system with distance which may still allow species to forage in the immediate vicinity of the WHP.

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5 Conclusion In conclusion, none of the bird species identified through a search of the EPBC Protected Matters database would be significantly impacted by the use of a bird deterrent system on the WHPs. Most species of birds are considered unlikely to breed on the platform, due to their geographical spread and preferred breeding habitats. In addition, there have been no reports of breeding or nesting birds on Santos platforms from regular maintenance personnel in at least five years of operations. Any breeding which may have occurred at the platform would therefore be considered an isolated incident. Bird deterrence from this platform would therefore not have a significant impact on the species population (i.e. is not expected to decrease local population size). Operation of the bird deterrent systems may have a short-term behavioural impact on seabirds utilising the WHPs as a resting place. Birds are currently using the platform as a resting structure and also potentially as a foraging location. The EP states Seabirds may be attracted to the Reindeer WHP due to increased feeding opportunities on pelagic fish. However, these behavioural changes are unlikely to alter population dynamics or significantly change the habitat use of birds. Due to the short duration of the presence of the platform, it is unlikely to have altered bird behaviour on a generational or species-wide level. Therefore, the bird deterrent system is considered to have a short-term behavioural impact only to a small proportion of local populations. The inherent design, functionality and operating philosophy of the bird deterrent system will mitigate potential physiological impacts to individual seabirds to a negligible level. The reduction in seabird numbers utilising the platform will in turn reduce the likelihood and frequency of bird strike events which will benefit individual seabirds.

6 References Beason, R.C. (2004). What can birds hear? USDA National Wildlife Research Center - Staff Publications. 78. http://digitalcommons.unl.edu/icwdm_usdanwrc/78

Fuller, F.J. and Burbidge, A.A. (1998). SEABIRD ISLANDS No. 239 Bedout Island, Pilbara Region, Western Australia. Corella 22(4) 113-115.

Powell, C.D.L. (2009). Foraging movements and the migration trajectory of Flesh-footed Shearwaters Puffinus carneipes from the south coast of Western Australia. Marine Ornithology 37: 115–120.

Surman C.A., Nicholson L.W. and Phillips R.A. (2018). Distribution and patterns of migration of a tropical seabird community in the Eastern Indian Ocean. J Ornithol 159: 867–877.

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