Part 1 of 2: Navigating Stakeholder Consultation in Offshore Oil & Gas: Balancing Inclusivity and Relevance

Stakeholder consultation is a cornerstone of Australia’s offshore environmental management framework. Under the Offshore Petroleum and Greenhouse Gas Storage (Environment) Regulations, titleholders must consult with all relevant persons—defined as individuals, organisations, or groups whose functions, interests, or activities may be affected by a proposed offshore activity (NOPSEMA, Consultation Guidelines). This obligation ensures transparency, builds trust, and informs the development of Environment Plans (EPs), which are rigorously assessed by the National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA) before any activity can proceed.

The Challenge: Volume vs. Relevance

While the intent is clear, meaningful engagement with those potentially impacted, the practical reality is more complex. Titleholders often adopt broad capture approaches, including outreach to environmental NGOs and community groups, to identify potentially affected parties. However, this inclusivity can create a volume-driven imbalance, in which high volumes of general-interest responses overshadow input from those with direct operational or cultural ties to the area.

This imbalance poses two risks:

• Dilution of critical input from directly affected stakeholders with substantive functions, interests or activities. Personal viewpoints and assumptions being presented as factual and science based.
• Extended timelines and resource strain, as companies navigate large volumes of feedback that may not materially influence risk management strategies.

Why Triaging Matters

To maintain integrity in the process, some degree of triage is necessary. Prioritising stakeholders with demonstrable functions, interest or activities in the specific area—such as Traditional Owners, commercial fishers, and government agencies—ensures that consultation remains fit for purpose. This approach aligns with recent court interpretations (e.g., Tipakalippa decision, 2022), which emphasise genuine engagement with those whose interests extend beyond general advocacy.

The Role of NGOs and Advocacy

Environmental NGOs play a vital role in raising awareness and promoting ocean health. Their input often reflects broader societal values and can influence policy evolution. However, it’s important to recognise that government assessments of EPs are rigorous, incorporating biodiversity, cultural heritage, and cumulative impact considerations under frameworks like the EPBC Act Program. These statutory processes are sometimes underestimated or dismissed in public discourse, yet they remain central to safeguarding marine ecosystems (NOPSEMA, Environment Plan decision making).

Striking the Balance

Effective consultation is not about limiting voices—it is about prioritising information from those most affected and best placed to inform outcomes.

Titleholders must:

• Map stakeholder influence and impact early in the planning phase.
• Assess, validate, and verify the information received.
• Document transparent criteria for identifying relevant persons.
• Maintain open channels for broader community input while focusing detailed engagement on those directly affected.

This balanced approach respects inclusivity without compromising the quality of environmental risk management. In an era of heightened scrutiny and climate urgency, getting this right is essential—not just for regulatory compliance, but for sustaining the industry’s social licence to operate.

References

• Department of Climate Change, Energy, the Environment and Water (DCCEEW): EPBC Act Offshore Petroleum Program.
• NOPSEMA Consultation Guidelines: Consultation and Communication Requirements for Environment Plan (May 2025).
• NOPSEMA Guidelines: Consultation with Commonwealth agencies with responsibilities in the marine area (Aug 2024).
• NOPSEMA Guidelines: Environment Plan decision making (Jan 2024).
• Offshore Petroleum and Greenhouse Gas Storage (Environment) Regulations 2009 – Australian Government.
• Tipakalippa v NOPSEMA & Santos [2022] FCAFC 193 – Federal Court of Australia.

Vicki Doidge, Projects Manager

Vicki is a seasoned professional with 19 years of invaluable experience across the oil and gas industry. With a diverse background, she has successfully navigated technical roles as an exploration geoscientist and GIS cartographer, as well as customer-facing sales and business development positions. Vicki’s specialisation lies in geoscience and engineering software technology, making her a sought-after expert in the Asia Pacific region 

Currently serving as a Project Manager at Klarite Pty Ltd, Vicki spearheads the delivery of exceptional environment plan and consultation services to our valued clients. Her dedication to ensuring effective communication and collaboration sets the foundation for successful projects and fosters positive working relationships. Her ability to bring diverse stakeholders together and provide a platform for all voices to be heard is instrumental in driving sustainable outcomes for our clients and the environment.