1. • Coastal and offshore resource infrastructure development is occurring in a time of increasing
reliance on our coasts and oceans to provide ecosystem services to humans – ie food, air and
water.
• An already strained ecosystem is at an increased risk of not delivering these ecosystem
services to humans into the future due to factors such as climate change, population increase,
and pollution from the increasing globalisation of society and the economy.
• Without ecologically sustainable economic development and use of coastal and ocean energy
resources that provides an economic buffer in transitioning to renewable energy into the
future we cannot hope to adapt and minimise the impact of global and local environmental
change on society.
• The development of Environmental Plans provides for a risk-based approach to sustainability
and the complex relationship between people, resources and the natural world that ensures
industry is accountable for its actions in providing services to humans.
• Under the OPGGS Act 2006, the 2009 Environment Regulations follow the Principles of
Ecologically sustainable economic development (Reg 3). Where a petroleum activity is being
carried out (Reg 4(1)) an EP must be submitted.
1

2. • The 2 main components of an EP are:
- environmental assessment (planning phase); and
- implementation strategy (operational phase).
• The 2009 Regulations governing submission and acceptance of EP’s are consistent with
system-based approaches described in AS/NZS standards ISO 14001 Environmental
Management Systems and ISO 31000 Risk Management – Principles and Guidelines.
• An EP should capture:
- a description of the activity, environment, regulations, impacts and risks and
detail the impacts and risk of the activity. It should evaluate and demonstrate that impacts and
risks are acceptable and reduced to ALARP. It should define performance objectives
and standards and measurement criteria that capture performance and monitoring
requirements. It should include consultation, an implementation strategy and any additional
content required.
• The complexity of coastal and ocean resource development can be represented in Chevron’s
Wheatstone project, bringing ashore LNG from offshore wells and associated infrastructure.
• At every stage of exploration, construction and operation, environmental impacts have to be
managed and the potential for significant and often cumulative adverse effects mitigated
against.
• Drilling, installing equipment and production facilities, seismic surveying, pipe laying,
dredging, trenching, rock piling, or servicing and maintaining production infrastructure and its
use - they all have an existing or potential impact on the surrounding environment.
2

3. • This presentation will cover (see PowerPoint)
• The presentation focuses in particular on the regulatory environment and approvals process
in regard to preparation, assessment and acceptance of EP’s as in force plans.
• An EP has to demonstrate compliance with the criteria in Reg 11(1):
(1) The Regulator must accept the environment plan if there are reasonable grounds for
believing that the plan:
(a) is appropriate for the nature and scale of the activity or proposed use; and
(b) demonstrates that the environmental impacts and risks of the activity will be reduced
to as low as reasonably practicable; and
(c) demonstrates that the environmental impacts and risks of the activity will be of an
acceptable level; and
(d) provides for appropriate environmental performance objectives, environmental
performance standards and measurement criteria; and
(e) includes an appropriate implementation strategy and monitoring, recording and
reporting arrangements; and
(f) for the requirement mentioned in paragraph 16 (b) — demonstrates that:
(i) the operator has carried out the consultations required by Division 2.2A; and
(ii) the measures (if any) that the operator has adopted, or proposes to adopt,
because of the consultations are appropriate; and
(g) complies with the Act and the regulations.
3

4. • Also covered (see PowerPoint)
• In particular, the presentation covers the components of assurance and compliance and how
this relates to the need to demonstrate a risk-based approach to resource developments.
• Division 2.3 of the Environment Regulations outlines the EP development process in a
coherent and systematic way. This approach provides a strong link to risk management
systems developed by
• recognised bodies such as ISO and AS/NZS.
• EP environmental assessment: The environmental assessment component of an EP is
focused around a process to demonstrate that environmental impacts and risks are of an
acceptable level and ALARP.
• EP implementation strategy: The core elements are:
1. measures to ensure environmental performance objectives and environmental
standards are met
2. systems, practices and procedures to ensure impacts and risks are continuously
reduced to ALARP
3. chain of command, including roles and responsibilities
4. measures to ensure personnel are competent and trained
5. provisions for monitoring, auditing, management of non-conformance and review
6. provisions for the maintenance of accurate quantitative records of emissions and
discharges
7. an OSCP including emergency response and testing arrangements
8. provisions for ongoing consultation
4

5. • The aim of this presentation (see PowerPoint)
• Specifically, the presentation’s objective relates to how to prepare an EP that covers off all the
content requirements while also being structured in such a way as to meet assessment
criteria.
• The regulatory process and elements provide a framework that allows operators to apply a
systematic approach to meeting the EP requirements of the Environment Regulations.
• The EP process step to “Describe” [sub-regulations 13(1) and (2)] applies to the elements
“activity” and “environment”. So, to meet the regulatory requirements, an EP must “Describe
the Activity” and “Describe the Environment” as laid out in the Environment Regulations.
5

6. • In considering EP’s feedback on the new regulatory arrangements for EP’s, and EP’s in
general was obtained by liaising with operator HSE specialists.
• The approach the regulator takes in administering the regulations was also considered
against content requirements to gain insight into how this approach impacts the activity
operator when preparing an EP.
• The EP process and key elements include:
1. Describe 4(1), 5, 6, 11(1) 13(1), 13(2), 13(5): Activity, Environment, Requirements,
Acceptable level(s)
2. Detail 4(1), 8(1), 13(3): Impacts and risks
3. Evaluate and demonstrate 4(1), 11(1),13(3), 13(3A), 14(3): Impacts and risks –
acceptable level(s), Impacts and risks - ALARP
4. Define 3(b), 4(1), 11(1), 13(4): Environmental performance objectives, Environmental
performance standards, Measurement criteria
5. Consultation 11(1), 11(8), 11A, 14(9), 16(b): Stakeholder consultation
6. Implementation strategy 14
7. Additional content requirements (Regulations 15, 16, 26, 26A, 26AA,26B, 29 &29A)
that must be reflected in an EP.
6

7. • Evidence of need covers off 4 key areas, these being (see PowerPoint).
• The Environment Regulations are:
1. objective-based, where general requirements are provided. The operator is
responsible for determining their approach to meeting these requirements;
2. risk-based, where a central part of the EP is the assessment and management of the
environmental impacts and risks of the activity;
3. performance-based, where appropriate environmental performance objectives and
environmental performance standards are in place that have measurement criteria to
determine if they are being met; and
4. system-based, where a structured risk management process is applied to developing
the EP which shows the continual and iterative steps that are followed to assess and
manage environmental impacts and risks effectively.
• The operator of an activity owns the EP. NOPSEMA’s role is one of assessing and deciding to
‘accept’ or ‘refuse to accept’ the operator’s EP and subsequently monitoring the operator’s
continued compliance with the EP.
7

8. • The object of the Environment Regulations, as set out in Regulation 3, is to ensure that
petroleum activities are carried out in a manner that is consistent with the principles of
ecologically sustainable
development; and in accordance with an EP that has appropriate environmental performance
objectives, standards and measurement criteria for determining whether the objectives and
standards
have been met.
• The context behind the evidence of need to address the complexities of EP preparation and
approaches to acceptance can be divided into 9 key points, these being (see PowerPoint).
8

9. • For an EP to be accepted, the operator must address the regulatory requirements in a way
that provides NOPSEMA with reasonable grounds to believe that the requirements have
been, or will be, met. This
should be supported by well-documented evidence.
• To determine if an EP meets the requirements, operators should consider:
1. Does the EP clearly demonstrate that the criteria in Regulation 11(1) have been
met?
2. Is the demonstration supported by adequately justified statements?
3. Are all statements made to support the demonstration sufficiently supported by
evidence or appropriate references, such that NOPSEMA can reasonably determine
their accuracy and reliability?
4. Is a clear basis provided for environmental performance objectives, environmental
performance standards and measurement criteria and are they appropriate to: the
protection of the affected environment, identified environmental impacts and risks and
their related control measures?
5. Are the environmental performance objectives and environmental performance
standards specific and measurable (e.g. S.M.A.R.T. - specific, measurable,
achievable, relevant, time-based)?
6. Is it clearly demonstrated how, when, where and why control measures will be
implemented, monitored and reported against?
7. Does the implementation strategy include the specific systems, practices and
procedures that describe how environmental performance will be measured over the
life of the activity?
8. Does the implementation strategy clearly demonstrate the systems that are in place
to implement, check and review activities (including management measures) in
compliance with the EP?
9

10. • The types of coastal and offshore construction activities requiring an EP may consist of:
1. Dredging – deepening shipping channels, sediment and rock piling for ports and
wharfs, marina’s, land reclamation
2. Trenching – burying pipelines into the seafloor, burying or overlaying coastal areas
such as beaches, intertidal areas, mangroves
3. Construction – infrastructure development for energy projects, wharfs, wells, pipes,
processing, transport etc
4. Production – various types of production including subsea, floating LNG, manned and
unmanned WHP’s etc
5. Seismic surveys -
• The environmental assessment component of an EP is focused around a process to
demonstrate that environmental impacts and risks are of an acceptable level and ALARP.
Environmental performance objectives and environmental performance standards, and their
measurement criteria, are defined and set respectively to ensure overall environmental
performance is maintained at the defined acceptable and ALARP levels.
• The implementation strategy core elements required to meet this are:
1. measures to ensure environmental performance objectives and environmental
standards are met
2. systems, practices and procedures to ensure impacts and risks are continuously
reduced to ALARP
3. chain of command, including roles and responsibilities
4. measures to ensure personnel are competent and trained
5. provisions for monitoring, auditing, management of non-conformance and review
6. provisions for the maintenance of accurate quantitative records of emissions and
discharges
7. an OSCP including emergency response and testing arrangements
8. provisions for ongoing consultation
10

11. • All these types of activities require preparation of an EP where although the context is
different, it has to meet the same assessment criteria.
• Unravelling the complexity of such arrangements regarding EP content and preparation will
assist in understanding how to simplify approaches to acceptance of an EP as an in force
plan.
• The Environment Regulations simply reflect the “plan – do – check – act” cycle that is the
basis of a systematic approach to environmental management. The Environment Regulations
provide a framework in which this basic process is conducted and are designed to ensure
appropriate and sufficient oversight. Consequently, the Environment Regulations provide the
basic process and critical steps against which operators need to demonstrate their
compliance with the regulatory requirements including the “plan – do – check – act” cycle.
11

12. • Requirements regarding the content of an EP appear relatively straight forward at first glance
and should include (see PowerPoint). The process for developing an EP can be described as
having two distinct components – the environmental assessment and the implementation
strategy.
12

13. • However, the manner in which an EP is prepared is not easily discernable and left to the
operator to decide. Neither the regulations nor the regulator outlines any specific
requirements as to the approach that should be taken in preparing or presenting the required
content.
• The key process steps (describe, detail, evaluate and demonstrate, define, consultation and
implementation strategy) that are provided for in the Environment Regulations for developing
an EP.
• The Environment Regulations also include the particular elements that these process steps
relate to, and which further describe the EP requirements of the Environment Regulations.
13

14. • The regulations do outline what an EP is assessed against, but bridging the gap between
required content and alignment with the regulations for assessment successfully depends on
how content is structured and presented. Here required content is covered in more detail and
then related to document preparation for assessment.
• Relevant Regulations Assessed Against are:
1. Activity: 4(1) (definition of activity), 5, 6, 11(1)(a), 13(1)(a-d)
2. Environment: 4(1) (definition of environment), 11(1)(a), 13(2) (a)(b)
3. Other legal requirements: 13(5) (a)(b), 11(1)(a)
4. Acceptable levels of impacts and risks: 11(1)(c) (also see section 3.6 “Evaluate and
Demonstrate: Impacts and Risks - Acceptable Level”)
5. Impacts and Risks: 4(1) (definition of environmental impact), 13(3)(a), 8(1)
6. Evaluate and demonstrate impacts and risks: 4(1) (definition of environmental
impact), 11(1)(c), 13(3)(b), 13(3A)(a)(b)
7. Evaluate and demonstrate impacts and risk are ALARP: 11 (1) (b), 14 (3)
8. Define Environmental Performance Objectives: 3(b)(i)(ii), 4(1) (definition of
environment, environmental performance, environmental performance objective and
recordable incident), 11(1)(d), 13 (4)(a)(b)(c)
9. Define Environmental Performance Standards: 3 (b)(i)(ii), 4(1) (definition of
environmental performance standard and recordable incident), 11(1)(d), 13
(4)(a)(b)(c)
10. Define Measreument Criteria: 3 (b)(i)(ii), 4(1) (definition of environmental
performance objective and environmental performance standard), 11(1)(d), 13
(4)(a)(b)(c)
11. Stakeholder Consultation: 11(1)(f), 11(8)(a)(vi), 11A, 14(9), 16(b)
12. Implementation Strategy: 14(1-10)
13. Additional Content Requirements: 15, 16, 26, 26A, 26AA & 26B, 29, 29A
14

15. • Perhaps a key aspect underpinning EP content is the requirement to demonstrate
consultation (see PowerPoint).
• The EP must include details of the consultation conducted during the development of the EP
[11(1)(f)] and also include a plan for ongoing consultation during the operational phase [14(9)].
1. The EP must demonstrate that the operator has carried out the required consultations
in the required manner [11(f)(i)].
2. The EP must demonstrate that the measures (if any) that the operator has adopted,
or proposes to adopt, as a result of the consultations are appropriate [11(f)(ii)].
3. For consultation in the course of preparing the EP, the operator must consult relevant
persons [11A].
4. The EP must contain a report on all consultations between the operator and a
relevant person [16(b)] and that report has specific requirements [16(b)(i-iv)].
5. The implementation strategy must contain a plan for appropriate consultation on an
ongoing basis with relevant stakeholders (Commonwealth, state or territory
authorities and other interested persons
6. or organisations) during the operational phase of the activity [14(9)].
7. Consultation in preparation of an EP may help inform the operator about what is
considered to be an ‘acceptable level’ of environmental impact and risk.
8. The consultation must be appropriate for the nature and scale of the activity in that all
persons whose functions, interests or activities may be affected by the activity must
be consulted.
15

16. • The operator should consider and provide a reasonable basis for determining who they
consider to be ‘relevant persons’ and define these in the EP. While “relevant person” is
described in the Environment
• Regulations, the operator must determine in the context of nature and scale of the activity,
which persons may be relevant and whose functions, interests or activities may be affected by
the activities
• to be carried out under the EP.
• Stakeholders can consist of any person, organisation, ethnic group or industry that may
potentially be adversely affected by an activity. Examples are:
1. Fishing industry
2. Aquaculture industry
3. Indigenous people
4. Conservation groups
5. Recreational user groups
6. Government (matters of national interest)
7. Public
8. Military
16

17. • Of particular importance is the requirement for consultation regarding development of an Oil
Spill Contingency Plan. Evidence of this consultation has to be shown in the preparation of an
EP.
• It is essential to liaise with those involved in implementing the National Plan, which is aligned
with MARPOL requirements for spill response, escalation, and a 3-tiered approach to dealing
with an unplanned event. This is covered in more detail later (see section 2.4.1, 2.4.2, 2.4.3).
• In cases where it is appropriate to the nature and scale of an activity, operators could
undertake consultation for a range of petroleum activities on a strategic basis. The submission
for each activity
would need to demonstrate that this action was appropriate and that each identified relevant
person had sufficient time and information to make an informed assessment of the potential
impacts of the
specific activity on their functions, interests or activities.
17

18. • When an activity has the potential to impact on matters of national interest a referral to the
Minister of Resources, Energy and Tourism has to be made for assessment. It is a
requirement under the Environmental Protection, Biodiversity and Conservation Act 1999 (see
PowerPoint).
18

19. • Assessments are made from (see PowerPoint).
• The EP must describe the regulatory and other requirements that apply to the activity and are
relevant to the environmental management of the activity. Requirements should be included
as part of the context of the activity to help understand the regulatory and other requirements
that may influence the way in which an activity is assessed and managed by the operator.
• Requirements include other approvals, legislative requirements or conditions that may apply
to the specific activity.
19

20. • An Environmental Impact Statement has to be prepared that addresses the effects of the
activity or project. Key to an EIS is that it provides for alternatives and an opportunity for
public participation or consultation. Also key is that the Minister must refer the EIS to the
Environmental Protection Agency for assessment.
• Activities that have the potential to impact on sensitive areas may include:
1. Oil and Gas Exploration and production near MPA’s and Marine Park coral reefs,
deep ocean habitats, nursery grounds etc
2. Oil and Gas Exploration and production near whale migration routes
3. Oil and Gas Exploration and production near turtle nesting sites
4. Coastal processing facility development and associated wharf/port structure near
culturally significant sites
5. Coastal processing facility development and associated wharf/port structure near
MPA’s or marine parks
6. Operations near or in commercial fishing areas
7. Vessel or facility movement and / or subsea construction biofouling and introduced
marine pests or native invaders
20

21. • EP requirements could include amongst other things: relevant laws, codes, standards,
agreements, treaties, conventions or practices that apply to the jurisdiction that the activity
takes place in, or other
jurisdictions, that may be relevant to the activity.
• The description of requirements should not just be presented as a list of requirements, but
should provide details of which requirements are relevant to the specific activity in the EP and
how they apply to the activity. The description of requirements forms part of the context of the
activity and influences the assessment and management of the activity, and the development
of environmental performance objectives and environmental performance standards.
• These requirements should be taken into account in establishing, implementing and
maintaining environmental management of the activity. Requirements that are not relevant to
the environmental management of the activity do not need to be included.
21

22. • Commonwealth environmental regulatory reform is underway to streamline the approvals
process and provide for one application and assessment process, particularly in dealing with
biodiversity offsetting for mining and energy development.
• This will limit the burden on the proponent in preparing submissions for assessment and
referral for matters of national significance.
22

23. • Alongside commonwealth regulatory reform the WA EPA under the Environmental Protection
Act 1986 allows for environmental offsets to be incorporated into the EIA process as part of
preparation of an EIS for referral. ie activities potentially impacting on matters of national
significance can be ‘offset’.
23

24. • One of the most important features of an EP is the implementation strategy, which provides
assurance to the regulator that all necessary precautions have been taken to ensure that any
potential or existing impacts have been reduced to As Low As Reasonable Practicable
(ALARP). As a function of this strategy the proponent has to show in any referral that they are
able to manage such impacts.
• The implementation strategy includes specific requirements [Reg 14 (4-10)] that must be
addressed in the EP for the duration of the proposed activity. These include: chain of
command, responsibilities, training
and competence, monitoring, auditing, management of non-conformance and review of
environmental performance and the implementation strategy, quantitative records of
emissions and discharges, an OSCP, consultation and regulatory compliance.
• An OSCP must be included as a component of the implementation strategy. The OSCP must
contain specific emergency response and testing arrangements that are appropriate to the
impacts and risk of the activity under emergency conditions.
24

25. • The implementation strategy must provide for appropriate consultation with relevant
government agencies, relevant interested persons and organisations for the life of the activity
or five-year EP review period. (see section 3.11: Consultation)
• A critical element of this strategy is the Oil Spill Contingency Plan. Being a ‘operational’
document it provides the necessary detail that ensures compliance with EP assessment
criteria. An OSCP brings together a wide range of EP components, from EIA and baselines
studies where knowledge is lacking, to Zone of Potential Impact (ZPI) modelling and
responses to an unplanned event offshore and onshore.
• Provisions for periodic review of environmental performance and the effectiveness of the
implementation strategy should be detailed. This review cycle should allow the operator to
determine if the measures, systems, practices and procedures of the implementation strategy
have been effective in ensuring that performance objectives and environmental performance
standards have been met and that impacts and risks are consistently being managed to
acceptable levels and reduced to ALARP as defined in the EP.
25

26. • In preparing an OSCP consideration should be given to (see PowerPoint)
26

27. • Sources of spill events can be from activities where unplanned events occur, such as:
1. A collision, grounding or foundering
2. A well blowout
3. A pipeline incident
• Causes may be related to any number of events, but the circumstances surrounding them are
always viewed from a risk and safety assessment perspective. Irrespective of the source, the
impacts have a commonality about them that is directly related to the scale of the event.
• Right side of the slide shows the position of the Montara blowout and associated oil slick. Left
side shows vessel incidents and associated oil slicks. Circumstances surrounding the source
of the event interact with the nature of the environment and determine the scale of impact.
27

28. • Impacts can be broadly defined as those occurring offshore and at sea and those that affect the coastline, whether
originating from offshore, coastal or onshore.
• Offshore: depending on the scale of the event it has the potential to affect entire food webs. For example the
Montara blowout cumulative impact on the environment was the size of the state of West Virginia. Over such broad
spatial scales Oil type, toxicity (PAH’s), viscosity, specific gravity, aging and weathering have significant implications
for the degree of temporal impact (impact over time) on localised offshore primary production and flora and fauna.
• Impacts of a major event include:
1. Transient fish, invertebrate, turtle and mammal populations can be smothered, gill fouled and/or ingest
weathered oil.
2. Consumption and accumulation up the food chain can occur – localised collapse of food web due to
inhibition of primary production because of photoinhibition and altered behaviour (phytoplankton and
zooplankton populations).
3. Deep ocean impacts from event aged fuel breakup and deposition to the deep ocean seafloor via the
carbon cycle.
4. Abundance in biogenic sediments and accumulation through benthic primary producer food chain in deep
ocean habitats – effect unknown.
5. Upwelling and re suspension due to seasonal cycling, long term disruption to food webs and trophic
structure across broad spatial scales.
28

29. • Onshore: impacts onshore are immediately more obvious and pronounced and can be initially
related to smothering of marine fauna and flora. Initial impact of uptake of toxic PAH’s on
aquatic health depends on the rate of weathering and type of organism. Ie filter feeder,
infauna, epibenthic, carnivore, herbivore and whether they are a bird, mammal, crustacean,
mollusc, echinoderm etc and the manner in which they reproduce (broadcast spawner,
brooder, etc).
• Different habitats will mediate an organisms response to an oil slick and may include:
1. Surf zone beaches – accumulation through successive tidal cycles, increased
breakup and aging, smothering and seeping into sub layers of sand.
2. Rocky coastline – topographically complex means accumulation of weathered oil is
more difficult to get rid of and effects may be long-lasting in this regard.
3. Mangroves – almost impossible to remove trapped oil without removing forest.
Breakdown may be faster though because of the nature of mangroves and
entrapment and binding up of sediment.
4. Harbour and other estuaries – ecologically very sensitive, especially if already heavily
modified due to anthropogenic activities. Oil can become trapped between tidal cycles
and never wash out, depending on degree of flushing.
• Long-term impacts include the sub-lethal and chronic effect of toxicity (PAH’s and endocrine
disruption), reproductive inhibition, and recruitment failure, population change and dislocation.
Often unintended consequences occur ie larval supply to other unaffected areas etc, or
nursery grounds for local populations wiped out, esp. fish.
29

30. • A key aspect of preparing an EP is to show how an activity will be monitored and how any
potential impact will be assessed. To meet this requirement it is essential that the risk
assessment process has been addressed in preparing the EP and that evidence of this has
been provided. Measurement criteria must be developed and standards also developed to
demonstrate compliance with the EP and its requirements.
• Some operators may integrate the preparation of an EP within an existing Environmental
Management System (EMS) and its certification or development under ISO14001.
• ISO 14001 is an internationally accepted standard that sets out how you can go about putting
in place an effective Environmental Management System (EMS). The standard is designed to
address the delicate balance between maintaining profitability and reducing environmental
impact; with the commitment of the entire organization, it can enable the achievement of both
objectives.
• What’s in ISO 14001:
1. General requirements
2. Environmental policy
3. Planning implementation and operation
4. Checking and corrective action
5. Management review
30

31. • The risk assessment process is in alignment with AS/NZS ISO31000 which replaces AS/NZS
4360. Risk assessment has to include identifying the risks, analysing likelihood and
consequence, prioritising the risks, and risk treatment.
• It is a requirement by NOPSEMA for environmental risk assessment to address both inherent
risk with no controls in place and to show that the post-treatment risk has been reduced to
tolerable or with additional controls in place to As Low As Reasonable Practicable (ALARP).
• A great software programme now available to achieve this is PHA Pro 8, which allows the
user to enter a risk matrix which is then linked to the spreadsheet used during a workshop.
31

32. • Risk is defined as the ‘effect of uncertainty on objectives’ (AS/NZS ISO 31000:2009). The
objectives can be financial, health and safety, environmental and so on. The risk management
process involves the following steps, as given in ISO 31000:2009:
1. setting objectives and establishing the context of the risk assessment;
2. identifying the risks;
3. analysing the risks to determine the level of risk, which is defined as the combination
of the consequences and likelihood of the risk;
4. evaluating the risk, to decide if a risk is acceptable, tolerable or intolerable /
unacceptable;
5. treating the risks, focusing on those risks which are intolerable; and
6. monitoring and review, to continuously refine and improve the assessment and risk
treatments.
32

33. • A typical risk matrix against which activities are assessed consists of:
1. A scale of severity and associated consequences in terms of people, property and the
environment
2. A scale of the frequency of occurrence with associated definitions
3. The response matrix showing whether the risk is low/tolerable, medium/ALARP, or
high/intolerable
• Provisions for monitoring environmental performance and the implementation strategy against
performance standards and objectives identified through the risk assessment process
throughout the operational phase of the activity must be included. Monitoring should be
sufficient to identify deviation in environmental performance from the levels set in the EP. The
frequency and type of monitoring should be appropriate to the nature and scale of the activity.
33

34. • Monitoring programmes need to address both the potential for proximate operational
environmental impacts while providing assurance that in the event of a major spill or other
event the wider environment has been considered.
• A monitoring plan needs to take into account the potential for spills to come ashore, account
for lack of information by conducting baseline studies, and providing for ongoing monitoring. It
also has to consider that in the event of a spill a rapid response survey can be conducted both
in proximity to the spill and other areas where a spill is likely to come ashore.
• Real time monitoring is also crucial, especially in terms of met-ocean data, and modelling and
prediction of downstream events and impacts from a spill.
34

35. • Baseline studies and modelling requires careful consideration of sampling and survey design
to achieve a balance between reliability and cost.
• Before, After, Control, Impact designs optimise the opportunity to detect any potential
environmental impact, the details of which are the subject of an entirely separate seminar.
• Needless to say that the natural world is full of background ‘noise’, which can easily mask the
ability to detect impacts if sampling designs do not adequately account for this ‘noise’.
• The chance of false negatives is relatively high and requires rigorous power analysis and
testing to minimise or limit this from occurring should a result show no impact. ie there really
was NO impact!
• A complimentary sampling regime may involve real time integrated monitoring, which
provides a rigorous picture of an area over time but may have limited use spatially depending
on cost. However, it may be quite useful for operational monitoring.
35

36. • Advances in Radiotelemetry mean technology, hardware, and software is becoming available
to use remotely for real time monitoring in environments that are often difficult to work in.
• May involve time-lapse video of the seafloor and water column, sensors for sampling water
parameters, sea surface variables, seabed shifts and disturbance etc.
• Able to detect changes in habitat composition, community composition, fauna behaviour,
seawater nutrient levels, turbidity and current, seawater chemical composition etc.
36

37. • All arriving international vessels are required to manage their ballast water in accordance with
the Australian ballast water management requirements. The DAFF website provides further
information to assist operators comply with the requirements.
• A comprehensive set of domestic ballast water management arrangements are being
developed under the National System to complement the existing requirements for
international vessels. These arrangements will be consistent with the International Maritime
Organization’s International Convention for the Control and Management of Ships' Ballast
Water and Sediments, which Australia has signed subject to ratification.
• The risk of the petroleum production and exploration industry spreading marine pests is
highest when vessels, immersible equipment and infrastructure:
1. are heavily biofouled and organisms such as mussels, oysters, seaweeds and
seasquirts are visible
2. are moved to a new area after spending long periods either stationary or at low
speeds (including undergoing dockside upgrades)
3. have areas without antifouling coating or the coating is inappropriate for vessel use,
aged or worn.
37

38. • Risk can be reduced by incorporating practices that minimise the build up of biofouling into your routine
cleaning and maintenance programs. The 'National biofouling management guidance for the petroleum
production and exploration industry' document outlines practical recommendations for operators on
managing biofouling on petroleum related vessels, equipment and infrastructure. These
recommendations have been developed in conjunction with the petroleum production and exploration
industry and apply to the following vessel types:
1. offshore support vessels including utility support vessels, platform supply vessels and anchor
handling tug supply vessels
2. mobile offshore drilling units including jack-up units, drilling barges and semi-submersible ships
3. crew transfer vessels
4. diving support vessels
5. accommodation vessels
6. seismic survey vessels
7. landing craft
8. pipelay ships and barges
9. floating production, storage and offloading vessels (FPSO) and floating storage and offloading
vessels (FSO).
• Operators of oil tankers and gas carriers should refer to the 'National biofouling management guidelines
for commercial vessels' for guidance on managing biofouling. Operators of heavy lift vessels and
dredges (including rock dumping ships) should refer to the 'National biofouling management guidance
for non-trading vessels' for further information on managing biofouling. The 'National biofouling
management guidance for the petroleum production and exploration industry' also inlcudes information
on biofouling management of submersible equipment and infrastructure.
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39. • Monitoring programmes may consider:
1. Permanent sea surface sensors
2. Permanent satellites and GIS
3. Permanent seafloor sensors
4. Water column deployed and towed equipment
5. Periodic remote surveys
6. Periodic surveys
7. Predictive modelling
8. Structures, fouling and marine pest management
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40. • Key elements contributing to an EP need to be bought together in a coherent and succinct
manner for submission and assessment against the regulations and acceptance as an ‘in
force’ plan.
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41. • Key in preparing the EP structure is to provide evidence of assurance and compliance (see
PowerPoint).
• Provisions for management of non-conformance must also be detailed in the implementation
strategy.
• These provisions should allow sufficient information to be collected to fulfil regulatory
requirements for reporting of recordable and reportable incidents to the regulator and to
ensure that any corrective and preventative actions are implemented.
• Provisions for periodic review of environmental performance and the effectiveness of the
implementation strategy should be detailed.
• This review cycle should allow the operator to determine if the measures, systems, practices
and procedures of the implementation strategy have been effective in ensuring that
performance objectives and environmental performance standards have been met and that
impacts and risks are consistently being managed to acceptable levels and reduced to
ALARP as defined in the EP.
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42. • To recap on the regulations, the key to successful assessment is under division 2.2 and 2.3 of
the 2009 regulations (see PowerPoint). Key aspects related to successful assessment also
include:
1. The EP must include arrangements for recording, monitoring and reporting a
sufficient level of information to allow the operator to demonstrate to the regulator that
all of the environmental performance objectives and environmental performance
standards in the EP have been met.
2. Reporting arrangements must address reportable incidents, recordable incidents and
routine environmental performance reporting.
3. The EP must include details of all the reportable environmental incidents that may
arise from the proposed activity.
4. Intervals for environmental performance reporting in accordance with the Regulations
must be provided in the EP such that they can be agreed to by the regulator.
5. he EP must detail the arrangements put in place by the operator for notification of the
relevant state or territory minister of the commencement of drilling or seismic survey
activities if those activities may have an effect on a community in the activity
area.
6. The EP must contain a statement of the operator’s corporate environmental policy.
7. The EP must contain a report on consultations (see section 3.11: Consultation).
8. The EP must address the specific requirements for the discharge and testing of
produced formation water.
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43. • In bringing these elements together, the assessment criteria and regulations can be matched
against submission structure by following the Safety Case Approach to submissions and
approvals (see PowerPoint).
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44. 44

45. 45

46. • What does the future hold:
• Alignment with EMS ISO 14001 both from a regulator and operator perspective. Future
legislation and government policy objectives may seek to reflect this arrangement.
• Environmental impact is becoming an increasingly important issue across the globe, with
pressure to minimize that impact coming from a number of sources: local and national
governments, regulators, trade associations, customers, employees and shareholders. Social
pressures are also building up from the growing array of interested parties, such as
consumer, environmental and minority non-governmental organizations (NGOs), academia
and neighbours.
• So ISO 14001 is relevant to every organization, including:
1. Single site to large multi-national companies
2. High risk companies to low risk service organizations
3. Manufacturing, process and the service industries; including local governments
4. All industry sectors including public and private sectors
5. Original equipment manufacturers and their suppliers
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