Is your activity occurring where it shouldn’t be?
Article published in the Regulator | Issue 2: 2017
Accurate and authoritative spatial information is essential. Without it, it’s difficult to ensure that spatial exclusion controls are effective and that petroleum activities only take place within the boundaries described in the accepted environment plan. Restrictions or exclusions from sensitive areas (e.g. areas recognised for their ecological or socio-economic values) are put in place to manage environmental impacts and risks for mobile offshore petroleum activities, such as seismic surveys.
Through its compliance monitoring, NOPSEMA has recently identified three areas that it believes warrant focused attention by titleholders when implementing spatial exclusion controls.
First, titleholders should be aware that spatial information may be sourced from various third-party providers, which may not all hold accurate or authoritative data. Titleholders should only use authoritative datasets, and their quality control processes should help identify this. This is particularly relevant for datasets of gazetted spatial boundaries, such as World Heritage areas and Commonwealth marine protected area zones within which petroleum activities are prohibited.
Second, titleholders should be aware of the location of their activity at all times. Maintaining this awareness is particularly important for activities implemented by a third party. Controls such as spatial data management systems should be used to enable the titleholder to track and record the location(s) of a petroleum activity relative to defined spatial exclusions in real time. This may help minimise human error and facilitate prompt action to avoid non-compliance.
Third, people with responsibilities for implementing the activity need to be aware of the exclusions, why they are in place and how to monitor compliance with them. This includes personnel and contractors, such as the vessel master, seismic master, seismic survey planners, and seismic source operators. Delivering appropriate training to these people will help ensure compliance with exclusion zones.
NOPSEMA’s environmental inspections will seek to confirm that titleholders have adequate measures in place to effectively implement spatial exclusion controls, particularly where exclusions are critical for ensuring that impacts and risks will be acceptable.