Presentation - Implications of scientific uncertainty in ......• Scientific uncertainty...

Implications of scientific uncertainty in environmental impact assessment of marine seismic surveys

Tim Carter, Environment Division APPEA HSE Conference 2015

The issue • Not providing a full account/analysis of impacts • Uncertainty not acknowledged or addressed • Results in:

– precautionary decision making – protracted assessment timeframes.

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Why the focus on seismic? • Scientific uncertainty particularly high for

underwater noise impacts – complex and paucity of data, not acknowledged

• Less developed in approach to evaluating impacts and addressing uncertainty

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• Titleholders case for acceptable impacts and risks is weakened.

Presenter

Presentation Notes

Seismic survey environment plans are less developed than environment plans for other activities in relation to acknowledging uncertainty and putting in place measures to address uncertainty. For example, environment plans for operations facilities evaluate the impacts and risks associated with PFW discharge. This discharge is long term and variable in nature and predictions of impact are made with best available information, but the prediction will carry uncertainty. This uncertainty is acknowledged and specific validation measures are put in place (e.g. in-situ environmental monitoring) to address uncertainty, ensure impacts remain within acceptable levels and inform adaptive management. Such validation measures can provide confidence to the regulator, industry and stakeholders in the face of uncertainty

Background

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• Increase in number of speculative, strategic seismic surveys

• A number of these proposed in particularly sensitive areas for whales and interacting with less studied, sensitive receptors

• Heightened stakeholder concern, expectation for information

• In response – a number of literature reviews underway on environmental effects of underwater noise.

Presenter

Presentation Notes

- Strategic surveys often cover large spatial scales and may occur over long timeframes, with flexibility in timing – presents some particular challenges Less studied, sensitive receptors may include groups such as commercially important fish and invertebrate species in shallow water, e.g. scallops and pearl oyster NOPSEMA facing more complaints, challenges to decision making and requests for information Stakeholders previously had access to large amounts of EIA information through EPBC referral process and opportunity for direct input through public comment period Information must now be sought directly from the titleholder Positive that literature review work is underway to document and understand current scientific knowledge base Hoped that this talk will highlight benefits of applying this knowledge more fully to EPs and addressing any key gaps identified that have relevance to EIA.

Sources of uncertainty

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Impacts and risks

Describe environment and activity

Implementation strategy

• Insufficient baseline environmental data

• Predictions of sound attenuation poorly supported

• Limited reference to data on ecological effects

• Effectiveness of controls

• Limited monitoring of ongoing performance

Presenter

Presentation Notes

Uncertainty commonly identified at all parts of EIA process Description of environment – uncertainty about level of fauna encounter or behaviour/life stage during survey period Sound predictions – broad extrapolation across airgun arrays and environmental conditions Impacts and risks – effects of underwater noise is a data poor topic and only a subset of available data is presented in EPs Controls proposed are often not well supported in terms of their effectiveness, e.g. buffer distance to sensitive feature proposed with a basis in broadly extrapolated and uncertain sound predictions Implementation strategy – presents opportunity to monitor and review effectiveness of controls and accuracy of predictions – very limited monitoring of this nature is currently proposed.

Implications of uncertainty

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Impacts and risks

Describe environment and activity


Predictions of impact

Demonstrate acceptability Titleholder

Regulator Evaluate evidence supporting predictions

Reasonably satisfied decision

Presenter

Presentation Notes

Blue arrow = spectrum of potential impact Orange circle = titleholders prediction of impact Green line = a theoretical acceptable level - In this theoretical example the titleholder has predicted that impacts will be of an acceptable level. NOPSEMA will critically evaluate the evidence base supporting the predictions of impact and the demonstration of acceptability Where sources of uncertainty (such as those identified on previous slide) are not acknowledged and addressed, NOPSEMA will place theoretical error bars around this prediction of impact If the worst case outcome is a potential unacceptable impact, NOPSEMA will make a not reasonably satisfied decision.

Broader implications of uncertainty • The Regulator:

– precautionary decision making

• Titleholders: – protracted assessment timeframes – additional controls or conservatism in controls – may limit data coverage (excising sensitive survey areas

and/or timeframes) – additional time/costs

• Stakeholders: – reduced confidence in industry. 7

Presenter

Presentation Notes

Titleholders typical response to a NOPSEMA request for further supporting information or modifications to an environment plan in order to demonstrate acceptability is to focus on controls – adding additional controls or increasing conservatism in existing controls This approach is not invalid – but may represent a missed opportunity to increase confidence in predictions A focus solely on controls has potential for reducing data coverage and increasing time and costs Stakeholder confidence reduced where they have claims or objections about adverse impacts and titleholders have a limited evidence base with which to respond/assess merits

Options to reduce uncertainty

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Description of environment

Sound exposure predictions

increase in review of existing data

site specific predictions

increase in access/use of MMO data

horizontal and vertical

consult data custodians reconciling units

strategic baseline studies

validate received sound levels

Ecological effects Effectiveness of controls

increase in interrogation of existing data

ensure controls are truly adaptive

use of surrogates where supported

international reviews

seek expert peer review/advice

measures to test effectiveness

strategic research to build knowledge base

field validation

Presenter

Presentation Notes

Table represents a range of different options to reduce uncertainty but is by no means exhaustive. Highlights that a lot more can be done with existing data to support case for acceptability The focus of this talk is on what more can be done with existing data – however it remains that this is a very data poor topic Therefore – also a need to look at longer term, strategic initiatives to build knowledge base/reduce data gaps Such initiatives must be collaborative and outside of individual EPs and companies Industry collectively have unique insights on gaps in data that present issues for EIA Important that any research is appropriately targeted to address pertinent questions and meet end user needs (can it plug into EPs?) Also a need to educate stakeholders on current and evolving state of knowledge to increase confidence and reduce current misconceptions Why? Make case for acceptability stronger or easier to make.

Theoretical scenarios

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Scenario 1

Presenter

Presentation Notes

Scenario 1 = sound exposure to site-attached fish assemblage in the vertical Scenario 2 = sound exposure in the horizontal to an important whale habitat (migratory pathway, calving area etc.) Two particularly high risk scenarios but also relatively common.

Addressing uncertainty: Scenario 1

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Describe environment

Characterise sound

exposure

Evaluate impacts and risks


• Bathymetry • Benthic habitats • Fish assemblages

• Exposure level below array • Units • Cumulative exposure

• Peer reviewed literature • Unit consistency • Advice from SMEs

• Measures to ensure

Presenter

Presentation Notes

Scenario 1 = sound exposure to site-attached fish assemblage in the vertical Two common issues: Impact evaluation not adequately informed by description of environment Impact evaluation not adequately informed by characterisation of sound exposure Important to consider the purpose of information provided to describe environment or characterise sound exposure – what does it inform, support or justify? For description of environment: bathymetric data important to inform level of sound exposure to demersal fish (function of depth) benthic habitat description will inform type of fish assemblage, e.g. habitat with structure (coral reef or sponge garden) likely to support site attached fish assemblage – more vulnerable to sound exposure as less likely to flee approaching array fish assemblage description will inform their sensitivity – is it an isolated population? Hearing specialists? Etc. For characterisation of sound exposure: Important to inform comparison with relevant effects thresholds – ensure consistent units adequate characterisation of duration, extent and frequency of exposure Is cumulative exposure a relevant consideration?

Addressing uncertainty: Scenario 2

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Describe environment

Characterise sound

exposure

Evaluate impacts and risks


• Best available data on whale habitats

• Site and airgun specific sound predictions

• Ensure controls truly adaptive

• Sound exposure validation

Presenter

Presentation Notes

Scenario 2: sound exposure to important whale habitat in the horizontal Two common issues: No acknowledgement of uncertainty in the description of whale habitats – temporal or spatial aspects, with this uncertain information inappropriately used to limit application of controls. For example, only applying controls within particular boundaries when this boundary may not be entirely representative. The setting of a buffer zone between seismic survey area and a sensitive whale habitat when the size of the buffer is not adequately supported by predictions of sound (predictions carry high degree of uncertainty) Important to consider whether data on description of environment and predictions of sound attenuation are fit for purpose, i.e. do they carry sufficient certainty to directly inform or support controls. Where uncertainty around extent of whale habitats – ensure controls are truly adaptive and mitigation can be adjusted to suit level of interaction observed in real time by MFOs Where uncertainty around sound predictions – consider specific measures to reduce this uncertainty, e.g. site and airgun specific predictions or sound measurement to validate predictions and enable adaptive management. Decision making around what measures to implement is a balance between confidence in predictions and conservatism in controls

• Much more can be done to reduce scientific uncertainty: – better use of available data, i.e. scientifically robust

evidence base to support predictions – develop specific measures to validate predictions – collaborative efforts to fill critical knowledge gaps.

• Why?: – greater certainty and efficiency in approvals process – improved stakeholder confidence.

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Take home messages

Presenter

Presentation Notes

Not just about more data but the right data, used in the right way Consider the purpose of information within the EIA process – what does it inform, support and justify? Can help to guide the type and level of information required when you are conscious of its purpose Is the information/data fit for its specific intended purpose? Important to consider and acknowledge areas of uncertainty and address them Consider what gaps in information present the greatest issues for EIA and approvals and address them collaboratively through targeted research Why?: Stronger case for acceptability on first submission of EP Build social licence to operate.

Thank you

Presentation - Implications of scientific uncertainty in ......• Scientific uncertainty...

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