27 May 2022

REF: Marine Mammals – Inquiry

To whom it may concern,

On behalf of the EnerGeo Alliance, this document has been prepared in order to highlight information relating to one of the specific items under the call for evidence on marine mammals, specifically item 3: ‘Beyond whaling, what human behaviours are affecting whale populations and how?’, and item 4: ‘How effective are the global protections of marine mammals?’.

About the EnerGeo Alliance

Founded in 1971, the EnerGeo Alliance is a global trade association for the energy geoscience industry, the intersection where earth science and energy meet. Providing solutions to revolutionize the energy evolution, the EnerGeo Alliance and its member companies span more than 50 countries, representing onshore and offshore survey operators and acquisition companies, energy data and processing providers, energy companies, equipment and software manufacturers, industry suppliers, service providers, and consultancies. Together, our member companies are the gateway to the safe discovery, development, and delivery of mainstay sources of energy, alternative energy, and low-carbon energy solutions that meet our growing world’s needs.

Through reliable science- and data-based regulatory advocacy, credible resources and expertise, and future-focused leadership, the EnerGeo Alliance continuously works to develop and promote informed government policies that advance responsible energy exploration, production, and operations. As the global energy demand evolves, we believe that all policymakers and energy companies, providing mainstay, alternative, and low-carbon solutions, – should have access to reliable data and analysis to support their forward moving efforts.

Call for Evidence

The call for evidence notes that ocean noise, among a number of other anthropogenic hazards, has been identified as a potential issue that affects marine mammal populations and therefore evidence from relevant stakeholders regarding the extent of the issue and suitable protections is requested. We would like to highlight the work of the energy geoscience industry, and the environmental protection mechanisms implemented to mitigate disturbance to marine mammals.

Offshore energy geoscience activities

The work of member companies of the EnerGeo Alliance encompasses services of relevance to the broad spectrum of offshore energy developments, from hydrocarbon exploration to the development of the broad range of Offshore Renewable Energies (OREs); Carbon Capture, Utilization and Storage (CCUS); and hydrocarbon and hydrogen gas storage. Members undertake offshore geophysical surveys which provide critical data for understanding the subsurface, including for identifying hydrocarbon resources; identifying and monitoring carbon storage locations; or facilitating the design and planning of the safe location for critical infrastructure including wind turbine generators (WTGs), subsea cables and pipelines and more. The work of members has been critical in unlocking the potential of the not just the UKCS, but energy sectors globally. That work will remain a critical element of energy sector decarbonsation and evolution where government policy favours moving from hydrocarbon-based energy systems to lower carbon alternatives, including developing sectors such as marine minerals.

A wide range of geophysical technologies are applied, depending on the type of information required about the seabed and/or subsurface and the depth of geological features of interest. These can include, but are not limited to: high-resolution geophysical surveys (utilsing sidescan sonar, multibeam echosounders, sub-bottom profilers); magnetic and gravimetric surveys; controlled source electromagnetic (CSEM) surveys; compressed air source seismic surveys (2D, 3D and 4D monitor/life of field); and ocean bottom techniques.

Environmental stewardship

Many of the activities highlighted above produce underwater sound, with the potential to disturb marine life if not properly mitigated. A wide body of research has demonstrated that the impulsive sounds from industrial activities such as seismic surveys can elicit a range of short-term, transient behavioural responses in marine mammals. Geophysical surveys have been carried out globally for over 50 years with no long-term population-level impacts upon marine species or the environment. In many regions where extensive seismic surveying has occurred, such as the North Sea and United States Gulf of Mexico, marine mammal populations have concurrently thrived. Human safety and environmental stewardship are at the heart of all EnerGeo member operations.

Since their introduction in 1995, EnerGeo Alliance members have been implementing the Joint Nature Conservation Committee (JNCC) ‘Guidelines for minimising the risk of injury to marine mammals from geophysical surveys’[1] during the course of operations. These same guidelines form the basis of similar procedures in other areas of the world where geophysical exploration activities are commonplace, providing for a level of proactive management of any potential impacts on the marine environment, and marine mammals in particular. In areas where there is no formal guidance in place, the JNCC guidance is often used based on the recommendations of environmental impacts assessments (EIAs). Additionally, industry has developed and implemented best practice guidance based on similar principles to the JNCC, which are recommended to be followed during all geophysical exploration activities [2].

The UK has and continues to demonstrate leadership in relation to the scientific understanding of the potential impacts of underwater sound from industrial sources through the work of a broad range of agencies, research institutions (such as the National Physical Laboratory), and knowledge sharing such as the Underwater Sound Forum [3] convened by the UK Marine Science Coordination Committee [4]. That leadership is felt internationally, with contributions to groups such as Intersessional Correspondence Group on Underwater Noise (ICG-Noise), convened by OSPAR [5]. It is essential that the dialogue regarding the potential environmental impacts of underwater sound is science and evidence-based, and one that affords industry the opportunity to participate in order to continue to contribute expertise and to ensure there is an understanding of technology developments and the practicalities of complex marine operations which are essential to our energy systems, now and in the future. Industry, including the EnerGeo Alliance, has funded over $60 million in research via the Sound and Marine Life Joint Industry Programme (SML JIP). Founded in 2004, the SML JIP regularly funds independent studies that are published in peer reviewed literature. An extensive list of independently reviewed published literature supported by JIP funding is available here: https://gisserver.intertek.com/JIP/dmsJIP.php.

Summary

The EnerGeo Alliance appreciates the opportunity to provide comment on an important marine environmental issue relating to marine mammals. The energy geoscience industry continues to adhere to regulatory requirements in the UK and beyond, and plays an important role in furthering our understanding of the potential impacts of underwater sound on the marine environment. Members of the EnerGeo Alliance place great importance on environmental stewardship, in ensuring that operations are conducted in a responsible manner

We are at your disposal to provide any further information as may be appropriate.

Sincerely,

Dustin Van Liew

Vice President, Global Policy &Government Affairs

EnerGeo Alliance