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Great Australian Bight BP Oil Drilling Project

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Great Australian Bight BP Oil Drilling Project Submission to Senate Inquiry: Great Australian Bight BP Oil Drilling Project: Potential Impacts on Matters of National Environmental Significance within Modelled Oil Spill Impact Areas (Summer and Winter 2A Model Scenarios) Prepared by Dr David Ellis (BSc Hons PhD; Ecologist, Environmental Consultant and Founder at Stepping Stones Ecological Services) March 27, 2016 Table of Contents Table of Contents ..................................................................................................... 2 Executive Summary ................................................................................................ 4 Summer Oil Spill Scenario Key Findings ................................................................. 5 Winter Oil Spill Scenario Key Findings ................................................................... 7 Threatened Species Conservation Status Summary ........................................... 8 International Migratory Bird Agreements ............................................................. 8 Introduction ............................................................................................................ 11 Methods .................................................................................................................... 12 Protected Matters Search Tool Database Search and Criteria for Oil-Spill Model Selection ............................................................................................................. 12 Criteria for Inclusion/Exclusion of Threatened, Migratory and Marine Species in Analyses ...................................................................................................... 12 Likelihood of Occurrence, Habitat Assessment and Risk Assessment – Threatened Species ...................................................................................................... 16 Criteria for Inclusion/Exclusion of Commonwealth Threatened Ecological Communities .................................................................................................................. 16 Criteria for Inclusion/Exclusion of Commonwealth Marine Areas, Marine Regions and Marine Reserves .................................................................................. 16 Criteria for Inclusion/Exclusion of Commonwealth Heritage Places ......... 16 Criteria for Inclusion/Exclusion of Ramsar Sites .............................................. 17 Criteria for Inclusion/Exclusion of World Heritage Properties ................... 17 Criteria for Inclusion/Exclusion of National Heritage Properties ............... 17 Criteria for Inclusion/Exclusion of Nationally Important Wetlands .......... 17 Criteria for Inclusion/Exclusion of Key Ecological Features ......................... 17 International Migratory Bird Agreement Investigation ................................. 18 Results ....................................................................................................................... 19 Summer 2A Scenario ................................................................................................... 19 Results ....................................................................................................................... 43 Winter 2A Scenario ...................................................................................................... 43 Discussion ................................................................................................................ 72 References and Resources ................................................................................. 79 Appendices .............................................................................................................. 80 Appendix 1: Summer 2A Scenario Protected Matters Report ....................... 80 Appendix 2: Winter 2A Scenario Protected Matters Report .......................... 81 Executive Summary I am a research scientist who has completed a PhD project on biological time-keeping mechanisms in vertebrates and has since worked as an ecologist and environmental consultant in association with urban development and resource sector projects such as the Santos GLNG Project, Origin Energy APLNG Project, Wiggins Island Export Coal Terminal Project and Solomon Islands Sumitomo SMM Nickel Project. I have also worked as the Conservation and Land Management Project Manager and Volunteer Coordinator at Hanson Bay Wildlife Sanctuary at the western end of Kangaroo Island, South Australia. Recently, I have established a business which aims to strategically restore vegetated connections or corridors between remnant vegetation patches containing threatened fauna and flora species to facilitate future dispersal and long-term survival. I present this submission primarily from scientific, ecological and conservation perspectives. This document presents an analysis of the Matters of National Environmental Significance (MNES) that are relevant under the Commonwealth Environment Protection Biodiversity Conservation Act (1999) within BP’s proposed exploratory drilling areas and in extensive areas that may be impacted in the event of oil spills as modelled in the document entitled “Stochastic analysis of deep sea oil spill trajectories in the Great Australian Bight” (LeBreton 2015). The oil-spill modelling document presents scenarios that may arise in the event of oil spills of various magnitudes occurring during summer and winter seasons. My submission presents a conservative analysis of MNES that would be potentially, likely or known to be impacted in the event of summer and winter oil spills at the levels sufficient to result in closures to fisheries on health grounds – the summer and winter 2A oil spill models. MNES include Commonwealth Threatened Species, Migratory Species, Marine Species, Threatened Ecological Communities, Critical Habitats, Commonwealth Marine Areas, Marine Regions, Marine Reserves, Commonwealth Heritage Places, Ramsar sites, World Heritage Areas, National Heritage Areas, Nationally Important Wetlands and Key Ecological Features. International Migratory Bird Agreements are also relevant to a number of the threatened, migratory and marine bird species. The potential impacts of winter and summer oil spills (2A Scenarios) on these MNES categories are discussed in my submission. Proponents of developments and major projects that may undertake operations or develop infrastructure that have potential impacts on MNES must generally present a detailed risk assessment in the form of an Environmental Plan or Environment Impact Statement/Assessment to Commonwealth regulatory departments such as the Commonwealth Environment Department before projects are granted approval. Under many circumstances, major projects are only allowed to proceed with additional conditions or controlled actions when MNES represent an unavoidable constraint to a project. On October 1, 2015, BP submitted an Environment Plan to the National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA). Two versions of BP’s Environment Plan were prepared with the full version (containing confidential and technical information) being submitted to NOPSEMA and a Summary Environment Plan being made available to the public. BP’s Summary Environment Plan (BP 2015) did not present a thorough analysis of MNES that is typical and a requirement for of other major project proponents. My submission uses methodology and resources available to the general public, as well as my expertise as an ecological scientist and environmental consultant, to provide a draw attention to MNES that could realistically be impacted in the event of oil spills occurring in summer and winter. BP Has only presented minimalistic information on potential impacts in the immediate proposed drilling area and has not publically presented the results or potential impacts of an oil spill as my submission does. I, therefore do not present focus on the immediate drilling area but extend my analyses to all areas that could be impacted by an oil spill in winter and summer. The 2A oil spill scenarios modelled and upon which I base my studies on is not a worse-case scenario model and impacts described in this submission would be far more intense and widespread if volumes of oil were released that exceed those modelled by Lebreton’s (2015) 2A models. In addition to my analyses on MNES, I also draw attention to the fact that many migratory bird species are associated with International Migratory Bird Agreements such as JAMBA/CAMBA and RoKAMBA. I also raise concerns as a recreational fishing person who understands that an oil spill occurring in any season would have devastating and long-term consequences for recreational fishing, commercial fishing, aquaculture and businesses associated with these three industries. The key findings of my primary study focus are summarised as follows and further summarised in Table 1. Summer Oil Spill Scenario Key Findings There is a total of forty-six (46) Commonwealth listed Threatened Species that are either likely or known to occur within the potential affected area. This includes four (4) fishes, four (4) reptiles, thirty-one (31) birds and seven (7) mammals. Nineteen (19) of these species are confirmed to occur or known to have suitable habitat in the potential affected area. There is a total of eighty (80) Commonwealth listed Migratory Species that are either likely or known to occur within the within the potential affected area. This includes six (6) fishes, four (4) reptiles, fifty-nine (59) birds
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