Home' Trinidad and Tobago Guardian : November 24th 2013 Contents November 24, 2013 www.guardian.co.tt Sunday Guardian
FISHERMEN & FRIENDS OF THE SEA
Response to public statements made by
EMA, PETROTRIN AND bpTT
on proposed seismic survey in Gulf of Paria (19/11/13)
The following update is provided in keeping with FFOS' on-going commitment
to keep the public informed of Petrotrin's pending application to the
Environmental Management Authority (EMA) for a Certificate of Environmental
Clearance (CEC) to carry out oil/gas exploratory Seismic Surveys in Trinidad
and Tobago waters without first requiring an Environmental Impact
Assessment (EIA), as stipulated in the Environmental Act (2000).
According to the EMA, a CEC is issued prior to the start of a proposed activity
(in this case a Seismic Survey) if the EMA considers the activity to be
environmentally acceptable and providing it is carried out in accordance with
the conditions laid out in the Certificate.
"The EIA is an invaluable tool in planning and environmental management. It
may be used in the CEC process depending on the proposed activity" (Page 3,
EMA's Guide to the Application for a CEC).
The EIA is the process for identifying the likely effects on the environment and
society which result from carrying out the Seismic Survey and for conveying
this information to members of the public and those responsible for carrying
out the proposed activity. The use of the EIA facilitates public participation and
seeks to address and minimize potential adverse impacts. It identifies
environmental sensitivities and risks. It contributes to the formulation of
environmental management plans.
Some fifty-six (56) Seismic Surveys have been issued CECs by the EMA and
carried since 2000 without an EIA. So far this year, the EMA has already issued
three (3) CECs for Seismic Surveys and three more applications are pending
including Petrotin's (EMA Public Register, October, 2013). The EMA intends
to continue to issue environmental clearances without ElAs.
By failing to require ElAs the EMA prevents the applicant from having to collect
essential baseline environmental data before starting the Seismic Surveys,
during the Survey and after it is completed. Had the EMA required ElAs for
Seismic Surveys, Petrotrin might have been able to claim adherence to "the
highest standard of risk management".
According to the EMA's Practitioner's Guide for "Deciding Whether a Project
Must have an EIA", they must use "professional judgement" and it is "the
responsibility of the applicant" to show that "baseline conditions have not
changed significantly", since any previous EIA of a similar activity in the same
area (Managing Director, EMA, October 15th, 2006, Practitioner's Guide
002/2006). In the case of Seismic Surveys, there are no previous ElAs hence
no baseline - an even stronger case for requiring an EIA.
The EMA claims that the specific conditions of the CECs they issue make
provisions for minimizing the impacts posed to sea turtles and marine
mammals. The EMA also claims to be in the process of creating new
Guidelines for Seismic Surveys. Their objective is to use existing knowledge of
the nation's fisheries to better inform the CEC process.
Since they failed to require ElAs in the past, there is no documented evidence
of where, how much and what types of fish are being caught, and what the
impacts of previous specific Seismic Surveys have been on national fisheries
and particularly commercial fisheries, since only the landing sites and gross
quantities caught are intermittently documented by the Fisheries Division
(according to fishermen).
As a result, the EMA is not in a position now, nor will they be after the
Guidelines are written, to "ensure that offshore activities are conducted in a
regulated manner". Hence they would have failed to "uphold principles of
Further, by failing to require ElAs, the EMA has also deprived key stakeholders,
in this case the fisher folk, of participating in the statutory consultations which
are enshrined in the EIA process. Yet, bpTT has disingenuously described the
EMA's CEC process as "robust" and "rigorous".
Everyone is now fully aware of the grave concerns of fishermen forced,
precisely because of a lack of consultations, to have to come into the full
public gaze and demonstrate peacefully at the POS waterfront. They are
reporting up to 70% drop in catch; lasting months/years after the Seismic
Surveys are completed.
The Minister responsible for fisheries recently gained permission from Cabinet
to set up a "high level, interdisciplinary" Committee (including The Energy
Chamber of Commerce) to "address the negative impact of seismic surveys on
the fishing industry" (Guardian Newspaper, 9th November, 2013).
Unfortunately, the proposed Committee is dominated by State and Corporate
interests (10 persons) with only 2 persons selected to represent the interests
of primary stakeholders - the fishermen, who have vast knowledge and expe-
rience of the sea.
Despite claims of having developed 'Draft National Compensation Guidelines to
Fishers from Seismic Operations', the State is not in a position to calculate
compensation accurately because there is simply no relevant data. The limited
data that we have seen reports major reductions in fish catch, water quality and
biodiversity as a result of several activities including land based pollution, over
fishing and unsustainable commercial fishing. Had the EMA required ElAs,
impacts arising from these other activities could have been better quantified and
the specific impacts of Seismic Surveys better distinguished. Additionally, the
cumulative Impacts of all our activities which affect the well-being of our Sea and
commercial fisheries would have been better understood.
Petrotrin disingenuously claims that in 2004, the "highest catch at Claxton bay
occurred during a Seismic Survey" carried out in the North Marine Area of the
Soldado Fields. They are of course referring to the one-time catch of fish that
managed to flee north from the Seismic activity they were conducting.
Petrotrin states that the sound from their Survey "will not exceed 250 decibels"
and refers the public to a 1996 Study (Dalen et al) which reports Seismic
Surveys have "little or no impact" on fish stock. However this contradicts a
more recent 'Report for the Norwegian Oil Association' which states "many
experiments show physical damage to fish (eggs, larvae and fry, as well as larger
fishes) will occur at a sound pressure level of around 230 dB". To understand
this, the same Report says "a threshold for human pain underwater is 202
decibels and direct damage is 222 decibels''(Ingebret Gausland, 2003).
Petrotrin also refers to a 2007 Study by 'Woodside' (an Australian oil/gas giant)
on Scott Reef in Australia, reporting "no significant impact on long-term fish
behaviour". However, the Commonwealth Fisheries Association, with the
support of industry around Australia, has lodged a nomination with the
Department of Sustainability, the Environment, Water, Population and
Communities, for marine seismic survey activities as a "key threatening
process" under the Environment Protection and Biodiversity Conservation Act
1999, saying "there is growing evidence that seismic surveys cause damage to
marine life, displacement from habitats (of fish) and disruption to breeding."
Nine species are listed that could become vulnerable or "more highly
endangered" including Black Jewfish, Scampi, Blue Warehou, Gemfish,
Orange Roughy, Arrow Squid, Bluefin tuna and the Loggerhead Turtle"
(Underwater noise, marine Noise Pollution, Australia, April, 2013).
Petrotrin claims in the Sunday Express (17/11/13) that Seismic Surveys
"cannot be compared to bombing", while bpTT calls it "pressured air pulses".
However, the CEC application by Petrotrin to the EMA indicates they intend to
use a 1500 psi (pounds per square inch) "airgun array" triggered off every 50
meters to generate a "seismic explosion" or shot (page 4, Project Description).
We calculate that over 30,000 of these "explosions" will be made during their
proposed Seismic Survey. Local fishermen who experience the impacts
directly, call it "Seismic Bombing".
FFOS shares bpTT's belief that there is "need to educate the public on the
seismic technology being used and measures already in place to minimise
environmental impacts" and accepts Petrotrin's "assurance" that it will "observe
all applicable laws imposed by the EMA". The ball is in the EMA's court.
FFOS shall stand firm on the side of fishermen, fish and the integrity of both
our oil/gas and fisheries sectors. We are prepared to sit on a fairly constituted
Cabinet appointed Committee if there is a moratorium on further Seismic
Surveys without ElAs while the Committee deliberates. We are however,
prepared to seek natural justice in the High Court if further caution is thrown
to the wind.
Forever yours in Sustainable and Inclusionary Development
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