Managing scientific uncertainty in environmental impact assessments for seismic surveys
Article published in the Regulator | Issue 4: 2015
NOPSEMA has increased efforts to address scientific uncertainty in environmental impact assessments (EIA), with a particular focus on marine seismic surveys. This focus was a result of a number of environment plans submitted to NOPSEMA that failed to demonstrate acceptable levels of impact for proposed seismic activity in environmentally sensitive areas, which has also led to heightened stakeholder concern.
At a recent conference, NOPSEMA delivered a paper on scientific uncertainty, which broadly covered the sources of scientific uncertainty commonly identified during seismic environment plan assessments, the implications of this uncertainty and options to address. The nature of the scientific uncertainty identified is primarily a result of relevant information either missing from, or incorrectly applied, in the EIA process. Scientific uncertainty of this nature is commonly present at all stages of the EIA process, including the:
description of the environment, such as incomplete baseline data for key receptors
evaluation of impacts and risks, for example limited referencing of relevant peer-reviewed literature on biological effects
implementation strategy, such as the lack of validation of sound exposure predictions.
Scientific uncertainty in predictions of impact or effectiveness of controls resulting from sources such as those outlined are likely to limit a titleholder’s ability to demonstrate acceptable levels of impact. In such cases, this scientific uncertainty can result in the regulator needing to apply a precautionary approach in decision-making. As a result, titleholders will experience protracted assessment timeframes and additional conservatism in controls, including limiting the extent of seismic surveys. In some cases, failure to demonstrate that impacts will be of acceptable levels has resulted in NOPSEMA refusing to accept environment plans.
In order to address the challenges presented to titleholders by scientific uncertainty, NOPSEMA encourages the application of a thorough EIA process with scientifically sound application of the best available data. Where there is a genuine gap in data, there may be a need for the titleholder to take a precautionary approach in the consideration of controls, such as excluding sensitive locations and/or times of year, until such time that new scientific data becomes available.
As the entity ultimately responsible for environmental management of petroleum activities, the titleholder is best motivated and well placed to understand where data gaps are creating problems in terms of environmental approvals. NOPSEMA continues to encourage industry to work together to address these gaps collaboratively. For more detail, please refer to NOPSEMA’s Presentation - Implications of scientific uncertainty in seismic environmental impact assessments - Sept 2015 (PDF 524KB).