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

SEAFOOD INDUSTRY AUSTRALIA

Submission to the
2023 offshore greenhouse gas storage
acreage release: nominated areas consultation process

30 June 2023

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To the Department of Industry, Science and Resources
Submitted online on 30 June 2023

Seafood Industry Australia (SIA) is pleased to be able to provide a response to the 2023 Offshore
Greenhouse Gas Storage Acreage Release consultation process.

About SIA
SIA is the national peak-body representing the Australian seafood industry. With members from the wildcatch, aquaculture and post-harvest sector, including state, territory and sectorial associations, along with seafood businesses and producers. We are the voice of Australian seafood, providing consumers, government and other stakeholders with confident and united representation.
The Australian seafood industry plays a key role securing Australia’s food base, creating and maintaining jobs, boosting economic activity, and generating valuable export income for Australia and our regional communities. Currently valued at more than $3.15 billion [+3.5b in 2021/22 and forecast to rise to $3.6 billion in 2023/24] and directly supporting more than 17,000 Australian families (ABARES, 2021) and thousands more workers downstream in logistics and sales, the
Australian seafood industry accounts for 10 per cent of the national agricultural production.
Our Australian seafood industry delivers jobs and investment in rural and remote Australia, and puts more than 1.5 billion meals of quality, healthy, sustainable seafood on Australian families’ tables and is an important export industry.
Our mission is to Promote, Protect and Develop the Australian seafood industry on the national and international level. Our unity indicates that we love what we do, we stand by our products, and that our products are the best in the world.

Our Pledge
We are the Australian seafood industry, and we are committed to putting the best Australian seafood on your table now and for generations to come.
To ensure we do this in ways we are all proud of, we promise to:
• Actively care for Australia’s oceans and environment and work with others to do the same;
• Value our people, look after them and keep them safe;
• Respect the seafood we harvest and the wildlife we interact with;
• Be transparent and accountable for our actions;
• Engage with the community and listen to their concerns; and,
• Continually improve our practices.

This is our pledge to you.

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Introduction

SIA notes the Department’s advice that the seven areas currently under consideration for acreage bids are:

• Bonaparte Basin;
• Browse Basin;
• Northern Carnavon Basin;
• Perth Basin;
• Otway Basin;
• Bass Basin; and
• Gippsland Basin.

SIA also notes that all of these areas are historic Australian fishing grounds that contain productive and valuable fisheries with allocated fishing rights that are meant to be permanent, compensable, and tradable (a clear form of property right), not temporary, revocable privileges.

Insufficient resources and time for consultation to have integrity

A six-week consultation period is insufficient for SIA and its members to fully understand how offshore greenhouse gas storage activities could potentially impact on commercial fishing activities.

The fishing industry and industry associations are significantly challenged in trying to keep track of developments in the marine planning space with additional requests for submissions and consultation received daily. The industry lacks the capacity and resources to address so many case- by-case requests for consultation, which diminishes the opportunities for accountability and oversight of offshore development activities and detracts from the integrity of the consultation process.

SIA would highlight that it is incumbent on project developers to take adequate measures to ensure they are effectively consulting with affected fishers to ensure that development activities are carried out in a manner that does not interfere with navigation, fishing, and conservation of resources of the sea and seabed to a greater extent than is necessary. This would require additional resources and information to be provided to industry to enable a more thorough understanding of the issues.

This paper notes that a request for a time extension from an SIA member for this submission process was refused.

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Impacts of offshore developments on the fishing industry, food security and regional communities
Cumulative impacts
The fishing industry is facing an escalating level of cumulative marine spatial squeeze in commercial fishing areas as a result of competition for space from offshore windfarms, oil and gas exploration, oil and gas infrastructure, marine parks, native title, climate change, and other factors.

For example, the Commonwealth Trawl Sector and Shark Fisheries have lost 85 percent and the shark fishery 90 percent of the grounds once allocated to seafood production over the past 20 years and are struggling to remain viable. It is unknown to what extent these fisheries may be further impacted by offshore greenhouse gas storage exploration and operations and other offshore development projects. Some of the few fishing grounds that remain to these fisheries are now, it seems, facing proposed declaration for carbon storage release and yet there is no consideration of how this adds to the cumulative impacts on these fisheries.

State-based peak body members of SIA have also raised concerns regarding the potential impacts to the productivity of State-based fisheries associated with offshore development activities, such as:
• Installation and ongoing maintenance of pipelines between greenhouse gas storage sites and
the shoreline.
• Transiting vessels carrying materials and crew to work sites.
• Physical disruption to areas that are ecologically important for future recruitment of
commercially important species.

SIA also understands that productive scallop, shark and octopus fisheries in the Bass Basin and rock lobster fisheries are also likely to significantly overlap with greenhouse gas storage exploration and operations.

The current regulations give no indication about how marine planning decisions are likely to contribute to cumulative impacts on the fishing industry, and without that, it is impossible for developers or assessors to understand the wider context of planning decisions and help them to avoid unintended consequences and ensure the important values that remain are protected. These may include endangered species and ecosystems, or competing economic and social values that contribute to cumulative harmful impacts on the Australian fishing industry.

We consider that it would be appropriate and in fact, necessary, to establish benchmarks for conducting cumulative impact assessment of real and potential impacts of the proposed activities on the fishing industry. To assist this process, urgent research needs to be undertaken to facilitate the gathering of baseline data about the status of relevant fishing sectors in each region and focus on data relating to ‘tipping points’ and economic, social, and environmental consequences of spatial planning decisions on the fishing industry overall and for specific fisheries.

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Case example - cumulative impacts on the South-East trawl sector:
There are numerous parallel Australian Government processes impacting on the fishing industry in the South-East including:

1. Climate change and warming of water in this region, which is expected to have a significant
impact on fishery recruitment and supporting ecosystems.
2. The loss of more than one third of its operators in July 2023 as a result of a $23m buy-out of the
Commonwealth Trawl Sector (the fishery that most overlaps the Bass Basin and Gippsland Basin
proposals).
3. A review of the South-East’s Marine Park Network, with significant impacts expected on access.
4. Ongoing consultation processes and negotiations with 30 windfarm developers and fishing
stakeholders in the Gippsland Basin (the Gippsland Renewable Energy Zone) and areas in
Western Victoria.
5. Consultation between two marine seismic proponents in the Otway Basin.
6. Decommissioning consultation regarding more than 20 wellheads and 900km of pipeline with
two oil/gas proponents and the fishing industry in the Gippsland Basin.
7. Consultation with government agencies regarding proposed total allowable commercial catch
(TACC) rights and future management arrangements for State and Commonwealth managed
fisheries in this area.

Food security and regional communities

Responsibly harvested seafood is essential in providing food security at a time when land-based production is vulnerable to threats such as water scarcity, climate change, soil degradation, urbanisation, strict regulation, and public opposition to proposed developments. Further, Australian seafood has been shown to be a low carbon footprint form of protein with total emissions per kilogram of production (6.5 kgs CO2-e) well below that of alternatives such as beef (25.2 kgs CO2-e) and lamb (19.4 kgs CO2-e)1.

Loss of access to fishing grounds associated with offshore projects not only directly impacts commercial fisheries, but also has implications for regional areas where the seafood sector contributes to economic resilience, food supply, tourism, environmental health and social fabric. The unique species profile offered by fisheries in South-east Australia is favoured by many residents who prioritise supporting local over other factors such as price when choosing to purchase seafood sourced from the region.

The secure availability of locally caught good quality locally caught seafood is also highly valued by international and domestic tourists, who view seafood as an integral part of the coastal travel experience. This in turn contributes significantly to enhancing regional economies and creating employment opportunities.

1 Energy use and carbon emissions assessments in the Australian fishing and aquaculture sectors: Audit, self- assessment and guidance tools for footprint reduction, Fisheries Research and Development Corporation, Project
2020-089, 2021.

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Impacts of offshore greenhouse gas storage

Whilst SIA acknowledges that this consultation is limited to the release of areas for bidding, we nevertheless believe it is essential that the government consider possible future impacts on the assumption that some projects will become operational.

As this is an emerging industry, it is also essential that the fishing industry is provided with information that enables it to understand the process and the possible impacts.

We require further information about:

• The likely physical disturbance (temporary and permanent) to the marine environment that
the process of exploration, seismic testing, drilling, seabed infrastructure installation and
laying of pipelines is expected to cause.

• Temporary and permanent exclusion zones for fishers at sites during the exploration,
installation and operational stages.

• Exclusion zones for fishers around closed sites.

• Any physical disturbances that might occur as a result of the operation of offshore greenhouse
gas storage facilities.

• Any physical disturbances in the marine environment and on near shore land that may be
expected as a result of the operation of offshore greenhouse gas storage facilities.

• Whether any of the greenhouse gas storage areas are to be considered for implementation in
Commonwealth or State Marine Parks.

• How greenhouse gas products will be transported to sites and what are the risks to the marine
environment during this process.

• Contingency plans in case catastrophic failure of one of the greenhouse gas storage sites, how
this would be remediated and would compensation for affected fishers be factored into this
process?

• Risks of leakage from closed storage facilities and what are the subsequent risks to the marine
environment and marine users as a result of any such leakages?

• Will studies undertaken to understand and monitor potential short and long-term impacts on
marine life, including commercially important species?

• What obligations operators will have for monitoring and maintaining closed sites whether
time limits will be placed on their obligations.

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• Will applicants be required to provide scientific evidence and economic impact reports on the
potential adverse effects to commercial fishers and the marine environment for each of the
potential greenhouse gas storage sites?

These are just some of the initial questions that our members need answers to before they feel adequate consultation have been informed and genuine.

Thank you

SIA thanks the Department for providing the opportunity to comment and asks that the issues raised in this submission be considered.

I welcome the opportunity to discuss our submission with you further and can provide more details if needed.

Finally, I would like to thank you in advance for your support of the future of Australia’s seafood industry.

Yours sincerely,

Veronica Papacosta

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