2023 offshore greenhouse gas storage acreage release: nominated areas for comment

29th June 2023

Australian Department of Industry, Science and Resources

GHGacreage@industry.gov.au

Dear Sir/Madam,

2023 Offshore greenhouse gas storage acreage release: nominated areas for comment

As the peak body representing the interests of Tasmanian wild capture fishers, marine farmers and seafood processors, the Tasmanian Seafood Industry Council (TSIC) is pleased to make a submission to the Australian Department of Industry, Science and Resources regarding the 2023 offshore greenhouse gas storage acreage release: nominated areas for comment. The Tasmanian Seafood
Industry Council response is provided below.

Please feel free to contact me for more information.

Yours faithfully

Julian Harrington
Chief Executive TSIC

Tasmanian Seafood Industry Council
PO Box 878 SANDY BAY TAS 7006
P: 03 6224 2332 tsic@tsic.org.au www.tsic.org.au

Page | 1
_______________________________________________________________________________

Tasmanian Seafood Industry Council (TSIC)

Submission to
Department of Industry, Science and Resources
consultation on

2023 Offshore greenhouse gas storage acreage release:
nominated areas for comment

29th June 2023

Email: GHGacreage@industry.gov.au
_______________________________________________________________________________

Page | 2
Tasmanian Seafood Industry Council Submission on Offshore
Greenhouse Gas Storage Acreage Release

Introduction

Carbon capture and storage has the potential to reduce Australia’s greenhouse gas emissions from industrial processes including power plants, heavy industry, and hydrogen production. It is proposed to store greenhouse gases (GHG) in offshore areas around Australia. Companies interested in pursuing offshore GHG storage need to explore seabed geological formations across various acreage releases as part of their business and technical case development. For Tasmanians, The Bass Basin
(GHG23-9) is the most pertinent of these proposed acreage releases. This offshore area already hosts exploration activities and industrial infrastructure (T/RL 1, T/RL 2, T/RL 4, T/RL 5).

The Tasmanian Seafood Industry Council (TSIC) is the peak body representing the interests of wild capture fishers, marine farmers, and seafood processors in Tasmania. Tasmania dominates the
Australian seafood industry. In 2021, Tasmania produced 91,800 tonnes of seafood, over 30% of the country’s seafood harvest, which was valued at $1.18 billion (38% of the Australian seafood industry’s entire economic value)1. The seafood industry operates around Tasmania’s entire coastline and produces both wild-caught and farmed seafood species. For 2021, the key species for
Tasmania are farmed salmonids (65,800 t, $887.6 million), wild-caught southern rock lobster (891 t,
$73.6 million), wild-caught abalone (1,029 t, $61.2 million) and farmed shellfish (3,719 t, $43.1 million). Tasmania is also the home to many vessels participating in Commonwealth managed fishery, which is regulated by the Australian Fisheries Management Authority. Over 3,500 people are directly employed within the Tasmanian seafood industry, often in regional communities. 2

Different concerns for different stages of the process

There are three broad phases in the development of offshore carbon sequestration fields: exploration, equipment installation and active carbon sequestration. Both the exploratory and the installation phases have potential to disrupt fisheries in the area. It is unclear whether the active process of greenhouse gas storage will have an effect on adjacent fisheries. Specific at risk fisheries are considered later in this submission.

Exploration

Exploration of potential sequestration sites requires, amongst other approaches, the use of seismic surveys to map seabed geological formations. The extent of these surveys has yet to be advised, and
TSIC anticipates further consultation when there is more clarity around proposed survey activities.
TSIC has, through previous seismic exploration consultation processes, voiced concern about the

1
Fisheries and aquaculture statistics 2021 | DAFF
2
Seafood Industry Workforce Profile | TSIC

Page | 3
impact of seismic on all life-stages of key commercially targeted species, from eggs to larvae, juveniles to adults.

Installation

Installation of infrastructure to enable sequestration has potential to impact adjacent fisheries in a similar manner as currently occurs with oil drilling activities. TSIC anticipates further consultation when there is more clarity around proposed installation activities. Questions of immediate concern include:

 Will the installation process of drilling, seabed infrastructure placement and laying of pipelines
cause disturbance to the marine environment?

 Will fishers be displaced during and after (i.e., restrictions around pipelines) the installation
process?

Sequestration and storage

Although much is unknown about the sequestration and storage process, preliminary questions arising include:

 Will fishers be displaced during the storage process?

 How long could the storage process last?

 6-year permit period?

 Will there be permanent exclusion zones around installations?

 What are the risks of gas leakage?

 What are the subsequent risks to the marine environment if there are insidious or
catastrophic leakages?

 What obligations will operators have for the site post closure and are there timeframe limits on
this?

Cumulative Effects

There are known and unknown risks to the marine environment at each stage of the offshore carbon sequestration development process. What is not clear is whether these risks are cumulative. To date, research in the oil and gas sectors has focused on the direct effects of single standalone seismic activities or drilling activities on the marine environment and on marine species. TSIC has concerns that fish species already under duress from exploratory activities may be further stressed when exploration transitions into installation activities and from there into active sequestration.

Spatial Squeeze

Concomitant with concerns over the effects of exploring, installing, and operating an offshore carbon sequestration industry in the Bass Basin, is TSIC’s ongoing and oft-stated worry about the

Page | 4
impact of marine spatial squeeze on Tasmania’s and Australia’s seafood sector. Australia’s marine environment does not have an infinite ability to absorb evermore offshore infrastructure. Over the last 20 years, the Commonwealth Trawl Sector and Commonwealth Shark Fishery, which have a combined take of around 7,000 tonnes annually from the Bass Basin and Gippsland Basin, have seen huge reductions, between 85% (trawl fishery) and 90 % (shark fishery), in grounds allocated to seafood production.

TSIC notes the irony that Australia’s efforts to reduce the environmental impact of one industry could well have large and unintended consequences on the country’s well-managed and sustainable seafood sector. This is particularly germane given seafood is the world’s most sustainable protein,3 and that the carbon footprint of seafood production is significantly lower than terrestrial protein production.4

Tasmania’s commercial fishers operating in the Bass Basin

The proposed 2023 GHG acreage release in the Bass Basin potentially impacts Tasmania’s fishers working in either Tasmanian or Commonwealth managed fisheries. Our submission is limited to sites of specific interests to Tasmania’s fishers. We are refraining from commenting on or supporting regions that fall outside Tasmania’s interests.

Within Bass Strait’s Commonwealth waters there are two main commercial fisheries: the Bass Strait
Central Zone Scallop Fishery (BSCZSF) and the Southern and Eastern Scalefish and Shark Fishery
(SESSF). Primary target species for Tasmania’s scalefishers working in the SESSF is the gummy shark
(Mustelus antarcticus). The commercial scallop (Pectans fumatus) is the primary targeted species in the BSCZSF. Both fisheries encompass the proposed acreage release GHG23-9.

The Department of Natural Resources and Environment Tasmanian manages Tasmania’s Scallop and
Octopus fisheries. Within Bass Strait, the Tasmanian scallop fishery extends 3-20 nautical miles offshore, targeting the commercial scallop. The octopus fishery primarily operates off Tasmania’s north coast and in Bass Strait, and mainly targets pale octopus (Octopus pallidus), with other octopus species landed as by-catch.

Scallop Fishery

Species most at risk during seismic survey activities are those, like scallops, living in the sediments above the seabed. In 2010, a marine seismic survey in eastern Bass Strait was blamed for a significant scallop mortality event in the latter part of the same year. In a submission to the 2019
Senate Inquiry on the impact of seismic testing on fisheries and the marine environment, scientists from the Institute for Marine and Antarctic Studies reported that whilst seismic exposure did not cause immediate mass mortality, repeated seismic exposure significantly increased the risk of

3
What does the world eat? | Sustainable Fisheries UW
4
The environmental cost of animal source foods | Frontiers in Ecology and the Environment

Page | 5
mortality in scallops.5 Scallop physiology was severely compromised and showed no signs of recovery even four months after seismic exposure. Whereas scallops exhibited classical behaviours such as opening and closing valves, repositioning, “coughing” to clear the mantle during exposure, they also demonstrated non-classical behaviours; scallops were seen to respond to air gun signals with a flinch of the mantle and other stress-like activities.6 It is unclear whether such physiological effects would result in longer timeframe mortalities.

TSIC members operating within the scallop fishery report that the scallop beds affected following the
2010 seismic survey have never properly recovered. TSIC and our members are extremely concerned that new seismic surveys within the proposed GHG23-9 acreage will have a similarly catastrophic effect. This is especially troubling given that Tasmanian and BCSZF scallop beds in
Western Bass Strait, which are the most abundant ever recorded, are also within the proposed Bass
Basin GHG23-9 acreage (see Figure 1).

Figure 1: There is a significant overlap between proposed Bass Basin release GHG23-9 (green), the Boags Marine Park Area
(dark blue) and known scallop beds in the BSCZSF and Tasmanian Scallop Fisheries. Fishing effort is indicated by colour, from yellow (lowest density beds) through red (most dense beds)
Insert shows Tasmanian scallop fishery.

5
IMAS submission to the Senate Inquiry on the impact of seismic testing on fisheries and the marine environment
6
Exposure to seismic air gun signals causes physiological harm and alters behavior in the scallop Pecten fumatus | PNAS

Page | 6
Octopus Fishery

As a benthic and relatively sessile species, octopus is potentially at risk from the waterborne and ground-borne energy of seismic surveys. Tank-based experimentation simulating seismic exposure has resulted in significant damage in several octopus species’. It is unclear whether similar phenomena would be seen in the field. The FRDC is currently funding field research into the effects of intense low frequency acoustic signals (as used in seismic surveys) on the development of eggs, hatching rates, competency of hatchlings and adult pale octopus including catch rates.7 Results are yet to be published. Anecdotally, Victorian commercial octopus fishers operating off Lakes Entrance have seen catch reductions of up to 80% in areas following seismic surveys.8

Shark Fishery

Sharks may also be susceptible to negative effects resulting from seismic surveys. Field studies of the presence of gummy and swell sharks released within acoustic relays in the Bass Strait showed a large decrease in sharks two days after release compared with control conditions (i.e., sharks moved away from the arrays).9 Whether this is a temporary displacement is unclear. Of particular concern is the significant reduction in gummy shark catch rates in the six months following the seismic survey.

Other Concerns

This greenhouse gas sequestration consultation is the latest submission and consultation request over recent months. Whilst there may be overlap between some submissions, each requires significant effort and input from TSIC and our members. Responding to consultation process is time consuming and necessary; for our members, completing submissions potentially affects current fishing activities in the interest of protecting future fishing activities. Similarly, TSIC’s employees and chief executive are required to spend many hours developing submissions reflecting our members’ concerns.

For this current submission we assume these are preliminary consultations. We expect and anticipate further consultation when there is more clarity around what the sequestration companies are doing. TSIC reserves the right to ask more questions at a later date.

TSIC position on proposed acreage releases in the Bass Basin

TSIC is extremely concerned with the significant overlap of the proposed GHG23-9 acreage release site and very important Bass Strait scallop, octopus, and shark fishing grounds. Exploration,

7
Examining the potential impacts of seismic surveys on Octopus and larval stages of Southern Rock Lobster |
FRDC
8
Victorian fishers say catch has dropped by 80 per cent since the start of seismic surveying | ABC News
9
Quantifying fish behaviour and commercial catch rates in relation to a marine seismic survey | ScienceDirect

Page | 7
installation and operational activities associated with off-shore carbon sequestration has too many known and unknown risks that could negatively impact Tasmania’s commercial fishers.

TSIC does not support any activity that could potentially impact these important fisheries.

TSIC does not support the inclusion of important fishing grounds within the Bass Basin acreage release.

Page | 8