Our changing climate is one of the greatest planetary challenges currently being faced, and which impacts all species. A warmer earth will have devastating consequences for global ecosystems and their inhabitants (including human beings), as well as our infrastructure. According to the World Economic Forum Global Risk Reports for 2023 and 2024, climate- related threats dominate the top 10 risks global populations will face over the next decade.

Given that the oceans cover more than 70% of the surface of our planet and absorb over 90% of all the excess heat that reaches that surface, the impact and consequences on our oceans and the marine life that inhabit them are huge and are being felt now.

A major step in mitigating “dangerous” human influence on the climate system is to change the world’s energy production from fossil fuels to cleaner, renewable energy. Offshore wind power is a growing part of this shift since it can be one of the most reliable and cost- effective large-scale energy sources available. However, the demand for offshore wind energy must not be met at the expense of the marine environment and its inhabitants.

Offshore wind (OSW) energy is the use of ‘wind farms’ constructed in the ocean (traditionally on fixed-bottom foundations in waters up to about 60 metres in depth) to harvest wind energy to generate electricity. Installing fixed-bottom offshore windfarms requires many high-impact procedures, which are often undertaken with little consideration of their effects on the delicately balanced ocean environment.

As wind farms move out to deeper waters, fixed-bottom foundations are not viable and a relatively new ‘floating foundation’ technology (floating offshore wind turbines or FOWT) is employed. Currently, the largest of these floating offshore windfarms contains only 11 x 8 MW turbines totaling 88 megawatts (MW) capacity. Current proposals for windfarms of this type in Australian waters are in the order of 2-3 gigawatts (GW – 2,000-3,000 MW), meaning hundreds or thousands of these FOWT. While the foundations float, they still anchored to the seabed by 3-4 chain mooring cables, along with an inter-array cable through which the electricity flows to a substation – meaning thousands of new obstacles in the ocean at a scale unprecedented in the world and with unknown impacts on marine life.

The marine realm is the largest component of the Earth’s system that stabilizes climate and support life on Earth and human well-being. However, the First World Ocean Assessment released in 2016 found that much of the ocean is now seriously degraded, with changes and losses in the structure, function and benefits from marine systems. In addition, the impact of multiple stressors on the ocean is projected to increase as the human population grows towards the expected 9 billion by 2050. (UNESCO)

With that in mind, Sea Shepherd Australia is prepared to support the use of technologies and methods of OSW construction and operation that avoid or at least minimise adverse impacts on marine life as well as birds and bats transiting the OSW areas. Noise-intensive installation methods such as pile-driving must be avoided. Since it is more effective to avoid an impact than to try to minimise or mitigate it, Sea Shepherd Australia supports the use of gravity-based foundations (GBF) where fixed-bottom foundations are used. GBF avoids noisy pile-driving altogether, while at the same time maximises local economic benefits as they can be manufactured locally.

Sea Shepherd Australia also urges more research into the impacts of floating offshore wind turbines before large scale projects are approved.

During site selection, a “precautionary approach”* must be taken when deciding whether the environmental risks are acceptable or not. The risks of an OSW project must always be regarded as not acceptable if they pose a significant adverse effect on the population levels of species occurring in or migrating through the proposed area. This is particularly so for nurseries and other sensitive marine locations. Hence, some areas of the oceans may not be suitable for any human development projects, due to specific sensitivity and/or importance for the life and survival of certain species.

Quantifying the impacts of a single wind project on marine and aviation animals is challenging. Understanding the cumulative impacts of multiple wind projects at full capacity, combined with other past, present, and reasonably foreseeable stressors operating over several decades is much more difficult. These cumulative impacts of multiple offshore windfarms (floating or fixed-bottom) have yet to be adequately determined. Given the number and size of offshore wind projects currently proposed in Australian waters, each of which would operate for 25+ years, developing effective mechanisms to deliver such assessments remains an urgent requirement for the immediate future. Comprehensive, independent, Australian research is needed before any approvals are granted.

Sea Shepherd Australia believes that it may be possible to plan, construct, operate and decommission offshore wind farms without significantly damaging the marine environment, if the precautionary approach is always followed, including the use of the best environmental techniques and mitigation methods. That said, there are some highly sensitive marine environments that should not be developed at all.

The oceans are the climate regulator of our planet and are key to our livable environment. The oceans produce over half of the world's oxygen and absorbs 50 times more carbon dioxide than our atmosphere, so it is imperative that they are protected and not put at risk via inappropriate development or become the new global industrial estate.

Summary

• Sea Shepherd Australia (SSAU) supports the scientific consensus regarding the impacts of human-induced climate change; the outcomes of the Paris Agreement; and the need for a rapid transition from fossil fuels to energy generated from renewable sources.

• SSAU fully recognises the adverse impacts of climate change on our oceans and the marine life that inhabit them. These impacts are being felt now and require urgent action.

• SSAU believes that all creatures have the same rights to an intrinsic quality of life on our shared planet.

• SSAU recognises the rise of offshore wind as a renewable energy source but believes this must not be at the expense of sustainability and protection of the surrounding marine environment.

• SSAU acknowledges that everything that humans do has an environmental footprint.

• SSAU understands that there are several methods of constructing offshore wind farms. Some methods are more destructive to the marine environment, while others are less.

• SSAU urges comprehensive, independent Australian research and the development of effective mechanisms to assess the cumulative impacts of large-scale offshore wind farms and floating offshore wind turbines.

• SSAU supports the methods of construction and operation of offshore wind farm that minimises adverse environmental impacts on marine life and birds, while at the same time provides local economic benefits.

• SSAU acknowledges that noise-intensive installation methods will harm marine life. To protect the surrounding marine environment of offshore wind farms, it is necessary to reduce this sound input into the ocean.

• SSAU acknowledges that it is more effective for marine life to avoid an impact than to minimise or mitigate it. SSAU therefore supports the use of “quiet foundation technologies” during construction of offshore wind farms and opposes noisy construction methods such as pile-driving.

• SSAU urges everyone involved in offshore wind developments to always adopt a precautionary approach when planning, constructing, operating and decommissioning offshore wind farms.

• SSAU urges regulation and enforcement of strong standards for construction and operation of OSW farms and to ensure that developers are aware of and follow these standards.

• SSAU also recognises that some areas in our oceans are too sensitive for human development and should therefore not be considered for offshore wind production or development of any kind.

This position summary was originally developed in November 2021 and has been updated three times based on new information and continued research. This version supersedes all others.

Why we have taken this position:

Sea Shepherd Australia starts from a position that our changing climate is one of the greatest planetary challenges currently being faced, and which impacts all species. After decades of absorbing more than 90% of the excess heat radiated back to the Earth’s surface, our oceans are now heating at an alarming rate**,*** – this presents a serious threat to all marine life, as well as land species, including humans. Our reliance on carbon emitting fossil fuels to provide energy to an increasing global population needs to change quickly.

Wind energy is an important renewable energy source and key to the transition away from fossil fuels. Offshore wind development allows for far larger capacity than land-based wind farms and is growing in popularity across the globe.

While we would rather see our oceans free from all industrial development, that is not to be and offshore wind is on its way to Australia whether we like it or not. Of the foundation construction methods currently available, the most common are highly detrimental to the marine inhabitants through the extreme noise generated through pile driving. This method of construction also generates constant vibrations through its operating life which are currently unquantified for large scale developments of the sizes being proposed.

If we are silent, these will be the methods employed. If we oppose all offshore wind development in total, our voice will be lost in the overwhelming noise of support from many quarters, including other environmental groups that support renewable energy but don’t consider the oceans – and those same construction methods will be employed.

Through our research and by adopting this position, we seek to influence the deployment of the foundation construction method that provides the least adverse impacts to the marine environment, and which also happens to provide the most local economic benefit through local construction opportunities. It also reduces ocean traffic and the carbon emissions that it generates.

We will also voice our opposition to development in marine environments considered too sensitive - even for the deployment of low noise options.

*The precautionary approach:
Principle 15 of the 1992 United Nations “Rio Declaration on Environment and Development” states that “where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation”. https://www.un.org/en/development/desa/population/migration/generalassembly/docs/globalcompact/A _CONF.151_26_Vol.I_Declaration.pdf

The precautionary approach, while introduced into the UN in 1992, is also enshrined within the principles of ecologically sustainable development in S 3A of the Environment Protection and Biodiversity Conservation (EPBC) Act 1999, and Chapter 6, Part 16 -Precautionary principle and other considerations in making decisions.

3A(b): if there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation.

**https://www.ipcc.ch/srocc/ Special Report on the Ocean and Cryosphere in a Changing Climate — (ipcc.ch)

***https://www.climate.gov/news-features/understanding-climate/climate-change-ocean-heat-content