IFAW Oceania office 6 Belmore Street Surry Hills NSW 2010 Australia Tel: +61 (0)2 9288 4900 Fax: +61 (0)2 9288 4901 Free call: 1800 00 IFAW (4329) Email: [email protected] IFAW submission: Senate Environment and Communications References Committee Inquiry into the potential environmental, social and economic impacts of BP's planned exploratory oil drilling project, and any future oil or gas production in the Great Australian Bight Submitted electronically, 24 March 2016 Summary 1. As one of the leading international animal welfare and conservation organisations, the International Fund for Animal Welfare (IFAW) works to save animals in crisis around the world. IFAW has a particular focus on the protection of marine mammals and works around the world to protect whales and dolphins (collectively known as cetaceans) from the many threats they face today. This includes protecting whale habitats in Australian waters from risks related to offshore petroleum. IFAW scientists have conducted research in Australia, including the first ever acoustic research voyage in the eastern Great Australian Bight (GAB). 2. This submission focuses primarily on item (a)(ii) of the terms of reference, the effect of a potential drilling accident on marine and coastal ecosystems, including whales and other cetacean populations. This submission also addresses item (c) scientific knowledge; item (d) capacity to respond to an oil spill; and item (e) other related matters, with reference to oil and gas exploration more generally in the GAB and risks from noise pollution from seismic surveying, and the transparency and accountability of the assessment and approvals system. 3. The GAB is home to at least 36 species of cetaceans (whales and dolphins) and three species of pinnipeds (seals and sea lions). The Australian Government has mapped Biologically Important Areas (BIAs) in the GAB for blue whales, southern right whales, sperm whales and the Australian sea lion, some of which overlap directly with or are in close proximity to BP’s proposed drilling area. A spill has the potential to impact: feeding areas and migratory routes for the endangered blue whale; the major calving nursery for endangered southern right whales in Australia; feeding grounds for sperm whales and other deep-diving species such as beaked whales; and feeding, breeding and haul out sites of the vulnerable Australian sea lion. 4. Potential effects on marine mammals include: hypothermia resulting in metabolic shock; toxic effects and secondary organ dysfunction due to ingestion of oil and exposure to toxic metals; lung disease and damage; gastrointestinal ulceration and haemorrhaging; eye and skin lesions; decreased body mass due to restricted diet; hypoadrenocorticism (low functioning of the adrenal gland which altered stress response); and stress due to oil exposure and behavioural changes. 5. The true extent of the impact on marine mammals from the Deepwater Horizon spill in the Gulf of Mexico is only just coming to light. Over 1,500 cetaceans, primarily bottlenose dolphins, have stranded since the Gulf of Mexico spill. The historical average in the affected region is six strandings per year. A high prevalence of lung disease has been identified in live bottlenose dolphins stranding in Louisiana, abnormalities consistent with adverse health effects previously documented in mammals following oil exposure. Since not all cetaceans that have died will wash ashore and be found, the number reported stranded is likely a fraction of the total number of cetaceans that have died. Scientists studying historical stranding rates in the Gulf of Mexico have estimated that the carcasses recovered after the Deepwater Horizon disaster represented only 2 percent of spill- related marine mammal deaths. Any large spill in the GAB will likely see similar impacts to cetacean species, in terms of lethal and sub-lethal injuries to whales, extended periods of disease and mortality, and whales being forced to relocate away from biologically important habitat. IFAW submission: Senate Environment & Communications Committee Inquiry – Oil & Gas in the GAB | page 1 of 9 6. Oil spill modelling commissioned by the Wilderness Society showed oil contamination could reach as far as Albany, WA or the Bass Strait to the east, depending on the season. In this context it is important to note that impacts to marine mammals could therefore extend far beyond those animals present in the GAB. For example, the Bremer Canyons off south-west WA, represent important feeding grounds for sperm whales and orcas. To the east, the Bonney Upwelling off the coast of eastern SA and western Victoria, represents one of only three feeding areas in Australian waters for blue whales. 14 other cetacean species have been recorded in this region as well. If a spill extended eastwards from the GAB it also has the potential to impact calving and nursing grounds of the south-eastern population of southern right whales, which is not currently recovering. 7. Given the relative paucity of scientific data on marine life in the GAB, impacts could in fact be more severe than our current knowledge suggests. IFAW welcomes BP’s investment in a collaborative research program for the GAB but believes no development should proceed until the research program has been completed and good baseline data collected. This would be particularly important in the context of measuring the impact of any spill should one occur. 8. IFAW has significant concerns about the capacity to respond to a major oil spill in the GAB. These relate to the both the proximity of equipment and the remoteness and harshness of GAB waters. BP estimates it could take up to 35 days to cap a blowout and 149 days to drill a relief well should capping not be successful. It should be noted that it took several attempts and nearly three months to cap the Deepwater Horizon well, which was located in waters as much as 1,500m shallower than the deepest locations in the proposed GAB site. 9. IFAW is also concerned about the capacity to successfully deploy mitigation responses, such as oil containment and recovery, in the harsh environment of the GAB, where high wave heights and wind speeds are common. If such methods are not feasible the only options remaining seem to be natural weathering or the use of dispersants. Either way, this would result in oil or chemicals, whose toxicity to GAB marine life is largely unknown, left to persist in the environment for considerable periods of time. 10. IFAW further questions whether BP or state agencies have access to sufficient man-power to successfully undertake manual cleaning across potentially hundreds of kilometres of remote and sparsely-populated coast in the event of oil reaching the shore. 11. It is important to note that BP’s oil exploration plans in the GAB are one of a number of proposals, albeit the most advanced. Exploration drilling, while having the potential to have catastrophic impacts on marine life, is by no means the only potentially harmful aspect of oil and gas exploration. The impacts of seismic testing, which introduces massive amounts of noise pollution into the marine environment should also be considered. IFAW is concerned that the amount of seismic surveying taking place in and proposed in the GAB could have cumulative impacts on whale species present in the GAB long before the impacts of any oil spill may be felt. 12. Since March 2014, offshore petroleum regulator, NOPSEMA, has been the sole assessor and approver of offshore oil and gas activities. There is no longer any ministerial accountability for such decisions and public access and transparency has been lost in the system. As a case in point, IFAW was forced to apply to the Administrative Appeals Tribunal for access to NOPSEMA assessment documents for a seismic survey approved in the eastern GAB. Only at the final hour before the AAT hearing was scheduled to begin did NOPSEMA relent, with access to the documents finally being provided 18 months after the decision was taken. 13. IFAW believes ministerial accountability and full public access and consultation should be restored to the approvals process. The areas in consideration are large areas of Australia’s marine environment, frequently highly sensitive areas, with high levels of endemic species and important habitat for threatened and iconic animals like whales. It is not appropriate that decisions about proposals that could have catastrophic impacts on such animals are taken without proper political accountability. IFAW submission: Senate Environment & Communications Committee Inquiry – Oil & Gas in the GAB | page 2 of 9 Introduction 14. As one of the leading international animal welfare and conservation organisations, the International Fund for Animal Welfare (IFAW) works to save animals in crisis around the world. IFAW focuses its work on improving the welfare of wild and domestic animals by reducing the commercial exploitation of animals, protecting wildlife habitats and assisting animals in distress. IFAW seeks to promote animal welfare and conservation policies that advance the well-being of both animals and people. 15. IFAW has a particular focus on the protection of marine mammals and works around the world to protect whales and dolphins (collectively known as cetaceans) from the many threats they face today, including commercial whaling, pollution (including noise pollution), ship strikes, entanglement and bycatch. In Australia, IFAW’s work has focused on whaling by Japan in the Southern Ocean, promoting and supporting cetacean research and protecting whale habitats in Australian waters, including from risks related to offshore petroleum. 16. IFAW has supported and conducted non-invasive cetacean research in Australia and around the world, including on the purpose-built cetacean research vessel, RV Song of the Whale, the construction of which was generously funded by IFAW supporters, and on other vessels of opportunity. Song of the Whale uses visual observations and sound to conduct whale research, having pioneered the use of passive acoustics (listening for the sounds whales and dolphins make) to survey for a range of whale and dolphin species.