11. A1187821 - Email CGG To NOPSEMA Re OMR Meeting Re Marine Fauna Management

Written by Claude Haiku 4.5 from the extracted text on 16 May 2026. It can miss or misread redacted and scanned pages. Check the source before relying on it.

CGG Resources (CGG) sought postponement of a Meeting 3 discussion on commercial fisheries assessments while preparing Meeting 4 focused on marine mammal protections for what appears to be an offshore petroleum environment plan assessment. The correspondence reveals NOPSEMA's regulatory queries on several contentious items: the definition of "low numbers" for marine mammal thresholds and pre-survey monitoring protocols; application of 160 dB acoustic thresholds to pregnant females and calves; and whether cumulative 24-hour sound exposure levels require assessment alongside single-pulse levels. CGG proposed removing analysis on survey timing due to insufficient historical data (only 2012 records available). Key tension emerged over NOPSEMA's expectations for assessing all mitigation measures under ALARP (As Low As Reasonably Practicable) principles versus CGG's contention that extensive existing measures render further analysis "grossly disproportionate." CGG acknowledged detection capability limitations at night. The exchanges reflect regulatory negotiation on marine fauna protection adequacy within offshore petroleum safety case requirements.