Exercise Zephyr: evaluation report

The Department of Industry, Science and Resources is responsible for Australian Government resources policy. The Offshore Petroleum and Greenhouse Gas Storage Act 2006 (OPGGS Act) and associated regulations provide the legislative framework for the environmental, safety and resources management of the offshore petroleum industry in Commonwealth waters.

The Australian Government Crisis Management Framework (AGCMF) designates our department as the lead Australian Government agency for incidents involving an offshore petroleum facility in Commonwealth waters. The Minister for Resources is the lead Australian Government minister.

Under the OPGGS Act, if there is an escape of petroleum relating to a petroleum activity, the petroleum company involved (the titleholder) is responsible for:

• stopping and containing the spill
• remediating any environmental damage
• conducting environmental monitoring.

This approach is common for offshore oil and gas industries around the world. However, it is different to other emergency management processes in Australia, which are usually led by either:

• state or territory governments
• Australian Government agencies with responsibility for emergency response and reporting.

Following the Montara Commission of Inquiry, the Australian Government implemented the Offshore Petroleum Incident Coordination Framework in January 2015. The framework ensures an agreed Australian Government approach to coordination and communication in the rare event of an offshore petroleum incident. It activates the OPICC as the central point of coordination for significant incidents and sets out the roles and responsibilities of Australian Government agencies.

Where an incident poses threats of national or international significance, the government will coordinate a whole-of-government response and not convene the OPICC. Examples of such threats are:

• impacts on multiple jurisdictions
• implications for other nations
• multiple casualties
• economic impacts on other industry sectors, such as fisheries and tourism.

In a crisis, our department can expect significant help from the National Emergency Management Agency (NEMA). NEMA houses the National Situation Room, which coordinates situational awareness for all hazards.

In the event of an oil spill, we will help the National Situation Room establish situational awareness by liaising with:

• the titleholder
• relevant Australian Government agencies, including the National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA)
• the relevant state or territory.

Under the AGCMF, the Director General of NEMA or their delegate chairs the Australian Government Crisis and Recovery Committee and the National Coordination Mechanism. These committees ensure whole-of-government decision-making is timely, accurate and coordinated. The Deputy Secretary of the Department of Prime Minister and Cabinet (PM&C) and the General Manager of the Offshore Resources Branch in our department may choose to co-chair these committees.

Previous exercises

The department exercises its oil spill arrangements at least once every 2 years. Since the Offshore Petroleum Incident Coordination Framework was established, we have participated in:

• Exercise Westwind in 2015
• Exercise Ningaloo Challenge in 2017
• the department-run Oil Spill Response Exercise 2019.

The department also participated in the industry-led Exercise Drift-off in 2020, but the OPICC was not activated during that exercise.

The lessons we learned from these exercises have helped improve the framework. We have refined the role and function of the OPICC to avoid duplicating roles and responsibilities between whole-of-government crisis committees. The framework includes the specific responsibilities of the OPICC and participating agencies, and the circumstances that trigger those responsibilities.

The department-led sub-exercise to Exercise Zephyr tested and evaluated the plans, processes and capabilities of the OPICC and the department’s crisis management team. It simulated a coordinated response by the Australian Government, Western Australian Government and offshore petroleum industry to a significant offshore petroleum incident in Commonwealth waters.

The department set the following objectives for the sub-exercise, which we assessed against the performance of the OPICC and the department’s crisis management team:

1. Test the arrangements and processes in place for OPICC to successfully lead the Australian Government’s strategic response to a significant offshore petroleum incident in Commonwealth waters.
2. Improve OPICC member agencies’ awareness and understanding of incident response arrangements, and the roles of their respective agencies.
3. Test the arrangements and processes in place for the crisis management team to build and maintain internal situational awareness during a large-scale offshore petroleum incident.
4. Test the processes in place for the department to effectively communicate information regarding the incident to relevant external stakeholders (the public, departmental executive, OPICC agencies and the ministers’ office).
5. Test the processes in place for the crisis management team to successfully support the OPICC and its chair during a significant offshore petroleum incident.

An exercise steering committee managed the exercise and was responsible for high-level planning and coordination.

An exercise writing team developed and coordinated the exercise documentation and scenario.

Both the steering committee and writing team involved staff from:

• Western Australia Department of Transport
• Western Australia Department of Biodiversity, Conservation and Attractions
• AMOSC
• Pilbara Ports Authority
• NOPSEMA
• Department of Industry, Science and Resources.

The writing team also included staff from:

• the Western Australia Department of Primary Industries and Regional Development
• the petroleum titleholder.

Exercise Zephyr ran from Monday 22 August to Friday 26 August 2022. It simulated an offshore petroleum incident in Commonwealth waters, with the oil spreading into Western Australia’s state waters and impacting the shoreline of the Dampier Archipelago.

The simulated incident was classified as Level 3 under the National Plan for Maritime Environmental Emergencies. Incidents at this level are complex because of their size, duration, risk and response resource allocation. This could involve deploying subsea, marine, aviation, shoreline and oiled wildlife resources and equipment.

Day 1 – Monday 22 August

The exercise commenced at 1000 AEST. The manager of the titleholder (ACME Oil) was told by a member of its workforce about a loss of well control and an inability to halt the release of oil at its Stag facility. The titleholder reported the incident to NOPSEMA, which notified the department at 1400 AEST. The titleholder commenced simulated first-strike actions according to its accepted oil pollution emergency plan.

The titleholder estimated that 300 m³ of oil had been released. The reservoir was reported to be positively pressured. Using modelling based on this understanding, the titleholder estimated the oil would flow for 2 to 3 days until the pressure was released and the flow would stop naturally.

On the morning of day 1, the titleholder set up its incident management team in Perth, WA to work through the Stag facility oil pollution emergency plan. The titleholder also activated its contract with AMOSC and requested the following resources:

• 3 fixed-wing aerial dispersant capability aircraft
• 2 offshore containment and recovery strike teams (people and equipment)
• oiled wildlife response support
• shoreline clean-up and assessment survey team.

The WA Department of Transport established the Maritime Environmental Emergency Coordination Centre to:

• start conversations with the titleholder
• mobilise a liaison officer into the titleholder’s incident management team
• confirm if WA state waters may be impacted
• activate its own incident management team.

In the afternoon, the titleholder’s incident management team discussed their actions on day 1 and established objectives for the following day, which included:

• aviation planning for fixed-wing aerial dispersant and aerial observations
• planning for monitoring of short- and medium-term environmental effects
• establishing a financial tracking system
• establishing a log of people and equipment.

After receiving NOPSEMA’s notification that an incident had occurred, the General Manager of the department’s Offshore Resources Branch in Canberra notified OPICC members and established the department’s crisis management team. The team seconded a staff member from the department’s Communications Branch for the duration of the exercise. The crisis management team was made up of 3 sub-teams with different roles and responsibilities:

• media and communications
• OPICC liaison and support
• policy and situational awareness.

The department also deployed liaison officers into both the titleholder’s and WA Department of Transport’s incident management teams. We set up communication channels with NOPSEMA and discussed how often the department would receive situational briefings.

The department’s crisis management team simulated:

• providing briefing and talking points to the Minister for Resources
• drafting talking points for the department’s media team
• preparing for an OPICC meeting the next day.

Day 2 – Tuesday 23 August

On the morning of day 2, the crisis management team:

• gave department switchboard staff a script on the incident
• published a holding statement on industry.gov.au
• provided keywords to the department’s media team for media monitoring
• submitted a media holding statement to the minister’s office.

Before the first OPICC meeting in the afternoon, the crisis management team sent all OPICC members:

• the meeting agenda
• an overview of NOPSEMA’s powers during an offshore petroleum incident
• a background on oil spill response
• the most recent NOPSEMA situational brief.

The first OPICC meeting occurred at 1500 AEST and was attended by:

• the Department of Industry, Science and Resources, including the National Offshore Petroleum Titles Administrator
• Department of Infrastructure, Transport, Regional Development, Communications and the Arts
• Australian Maritime Safety Authority
• NOPSEMA
• Department of Prime Minister and Cabinet
• Emergency Management Australia
• Australian Border Force
• Department of Foreign Affairs and Trade (DFAT)
• Parks Australia
• Australian Fisheries Management Authority
• Geoscience Australia
• WA Department of Transport
• AMOSC
• the petroleum titleholder.

The OPICC chair (General Manager of the department’s Offshore Resources Branch) gave OPICC members an overview of the incident. The chair outlined the purpose and objectives of the meeting and reminded members of the role of the OPICC during a significant offshore petroleum incident.

Situational updates were then provided by:

• the titleholder
• WA Department of Transport
• NOPSEMA
• other Australian Government agencies that had been affected or were providing support beyind their usual activities.

The titleholder (ACME Energy) reported oil was still being released at 80 to 100 m³ per hour. As the well was positively pressured, the oil was expected to naturally stop flowing in 24 to 48 hours.

ACME reported that the oil slick was heading south-east and was expected to impact Rosemary Island in the Dampier Archipelago on Wednesday 24 August. ACME liaised with the WA Department of Transport on shoreline assessment teams and potential clean up. It also mobilised initial response operations including aerial and marine dispersant.

The WA Department of Transport reported they were working with ACME on media and public information about the incident and had started mobilising equipment. The WA Department of Transport and the titleholder incident management team also held their first Joint Strategic Coordination Committee meeting on day 2.

NOPSEMA confirmed that ACME's response activities were complying with its accepted oil pollution emergency plan and environment plan.

The OPICC meeting addressed all agenda items, mainly focusing on coordinating Australian Government messaging and requests for Australian Government assistance.

ACME flagged it may need to request Australian Government assistance for international emergency response personnel and equipment if the incident exceeded domestic response capabilities. The OPICC confirmed after the meeting that the government could provide this assistance.

ACME and DFAT requested that all public communications include the direction the oil was headed. This was to help ease concerns the oil may impact other nations.

The OPICC agencies’ focus on clear and coordinated government messaging highlighted the need to develop whole-of-government talking points and a situational brief. These documents would allow concise, consistent and up-to-date briefing and public messaging across government.

Day 3 – Wednesday 24 August

On the morning of day 3, oil stopped flowing from the rig. Over the previous 48 hours, approximately 4160 m³ of oil had been released from the facility. The worst-case estimate of the amount of oil washed ashore was 812 m³. The WA Department of Transport continued assessing shorelines and completed planning for vessel-based containment and recovery in state waters.

Reports of oiled wildlife came in throughout day 3. ACME prepared to carry out shoreline activities and oiled wildlife response to support the WA Department of Transport. ACME continued aerial dispersant and surveillance in Commonwealth waters and confirmed that oil was impacting state waters near the Dampier Archipelago.

In Canberra, the department’s crisis management team:

• gave updated talking points to the department’s media team
• responded to briefing requests
• fielded media enquiries
• drafted the whole-of-government talking points and situational brief for OPICC agencies to review and discuss the next day.

Day 4 – Thursday 25 August

On day 4, ACME and the WA Department of Transport determined there were no longer dispersible quantities of oil in Commonwealth waters. As a result, these organisations agreed it was no longer appropriate to use dispersants in state waters.

ACME shifted to supporting the WA Department of Transport with on-water containment and recovery, shoreline clean-up and oiled wildlife response. The Joint Strategic Coordination Committee also held its second meeting.

In Canberra, the department’s crisis management team updated the minister’s office and the department’s media team on the incident. They also prepared for the second and final OPICC meeting that afternoon. The team provided the following to OPICC members before the meeting:

• the meeting agenda
• the most recent NOPSEMA incident update
• the finalised whole-of-government situational brief and talking points.

At the OPICC meeting, members received situational updates from the titleholder, WA Department of Transport and NOPSEMA. Other Australian Government agencies that had been affected provided additional support beyond their usual activities.

ACME confirmed the 4 operational activities underway:

• marine containment operations in state waters
• aerial surveillance
• nearshore operations
• onshore operations.

The WA Department of Transport confirmed oiled wildlife, with 20 birds and 2 turtles being rehabilitated from oil effects. It also reported 20 dead birds and an unconfirmed number of dead fish.

The chair led a discussion on the whole-of-government talking points and situational brief. They also asked OPICC agencies to report any planned ministerial engagements.

Emergency Management Australia noted it could potentially merge its common operating picture software with the titleholders’ software. It could then give OPICC agencies access to the common operating picture to share situational awareness between OPICC members.

Exercise Zephyr ended after the second OPICC meeting.

The department is committed to improving the procedures and processes in the Offshore Petroleum Incident Coordination Framework. By exercising, reviewing and improving the framework, we ensure that we fulfil our role under the AGCMF.

Exercise Zephyr showed we have appropriate arrangements to lead the Australian Government’s strategic response to a significant offshore petroleum incident. OPICC was able to contribute to whole-of-government situational awareness and help fast-track emergency response equipment and personnel.

However, we identified several recommendations that we will use to improve the framework and the arrangements of the department’s crisis management team. This will ensure our strategic response to an offshore petroleum incident continues to align with the department’s role in the updated AGCMF.

Our recommendations were informed by data from the department’s crisis management team, which we collected by:

• observing the exercise
• revising written material (for example, briefs, media releases, talking points, meeting materials)
• daily debriefs with the crisis management team and liaison officers
• one-on-one interviews with crisis management team members after the exercise.

Data was collected for the OPICC portion of the exercise via:

• direct observation by Emergency Management Australia
• feedback from OPICC members in the scheduled OPICC debrief session
• direct observations from the OPICC Chair and the department’s attendees.

Objective 1

Test the arrangements and processes in place for OPICC to successfully lead the Australian Government’s strategic response to a significant offshore petroleum incident in Commonwealth waters.

Overall, we found the arrangements and processes in place were effective. However, OPICC’s approach to coordinated briefing and messaging could be strengthened.

Two meetings of the OPICC were held during Exercise Zephyr, with participation from several Australian Government agencies. After the first meeting, agencies agreed they needed consistent messaging and a single source of truth to brief their respective ministers offices and executive.

Ahead of the second meeting, the crisis management team, in consultation with OPICC agencies, developed a whole-of-government situational brief and talking points. These significantly improved OPICC agencies’ contribution to whole-of-government situational awareness and enabled coordinated messaging.

OPICC agencies noted the different functions of the whole-of-government and NOPSEMA situational briefs. They also noted that the intent of these documents should be clearly defined from the start of future OPICC meetings.

The situational brief from NOPSEMA provides the latest information on:

• the incident and its impacts
• the titleholder’s response actions
• any regulatory actions taken by NOPSEMA.

The whole-of-government situational brief should use the NOPSEMA brief as a source of truth and include information applicable to OPICC agencies and their relevant ministers’ office. Information in the whole-of-government brief should be categorised under headings such as ‘environment’ and ‘safety of personnel’ to clearly address the information needs of the Australian Government.

Templates for the whole-of-government brief and talking points should also contain information on topics that are likely to be raised in the event of an incident, such as the use of dispersants.

To improve shared situational awareness between OPICC members, Emergency Management Australia offered to merge their common operating picture software with the petroleum titleholder’s common operating picture software.  While we couldn’t test this during the exercise, the possibility and effectiveness of using this software during a offshore petroleum incident should be further investigated.

Objective 2

Improve OPICC member agencies’ awareness and understanding of incident response arrangements and the roles of their respective agencies.

Most OPICC agencies showed effective awareness and understanding of the response arrangements and the role of their agency during an offshore petroleum incident. However, competing priorities meant many OPICC agencies delegated meeting attendance to another staff member. This may have meant some attendees had limited knowledge and background on the purpose of the OPICC and how their agency could help.

OPICC meetings were held to:

• give strategic assistance to the titleholder’s operational response, such as fast-tracking international emergency response equipment and personnel into the country if required
• lead the Australian Government's crisis management actions and communications.

However, after the exercise, some participants were confused as to why:

• the industry participant was only included for part of the meeting
• the overarching purpose of the meetings was not always clear.

OPICC members suggested attendees would benefit from clearer information on the role and function of OPICC before the meeting.

Objective 3

Test the processes in place for the crisis management team to successfully support the OPICC and the OPICC Chair during a significant offshore petroleum incident.

Before the exercise, we developed templates and guides so the crisis management team could support the OPICC Chair and the effective running of OPICC meetings. These included:

• templates for meeting agendas, meeting notifications and invitations
• a contact list
• a guide to organising an OPICC meeting.

We found these resources were fit for purpose. However, the crisis management team found during the exercise that writing an OPICC chair brief and completing OPICC meeting minutes took a long time. The crisis management team suggested we develop templates for the OPICC chair brief and OPICC meeting minutes, which include pre-prepared background information.

Objective 4

Test the arrangements and processes in place for the crisis management team to build and maintain internal situational awareness during a large-scale offshore petroleum incident.

The crisis management team told us that allocating staff and responsibilities into 3 sub-teams worked well. Sub-teams were given a high-level description of their roles and responsibilities, which they could print and refer to throughout the exercise. The list was a useful reminder of each sub-team’s tasks and responsibilities, which could easily be forgotten in a high-pressure environment.

The crisis management team noted that a similar guide would be useful for the crisis management team lead role. During an actual incident, the crisis management team would likely be activated for several weeks, and the team lead may change during this time. A guide for this role would help maintain continuity.

The OPICC liaison and support sub-team monitored the OPICC inbox and tagged emails for the responsible sub-team to action. While this was an effective way of allocating and actioning tasks, the OPICC liaison and support team were not always available to monitor the inbox. Several crisis management team members suggested nominating extra staff to monitor the inbox and allocate tasks.

Crisis management team members also found they missed emails forwarded to their personal inbox, or flagged for ‘all to read’, due to the amount of inbox traffic. This impacted some team members’ situational awareness during the exercise.

Throughout the exercise, the crisis management team produced briefing documents and communications products. They also followed up on actions and items arising at OPICC meetings. The team completed most tasks on time and to a high standard.

However, the crisis management team determined that the template for the decisions and actions log was not fit for purpose. Instead, they developed a task tracker in which team logged major tasks, task status and the staff member responsible.

The task tracker improved awareness of the tasks and priorities for the crisis management team. However, there was sometimes duplication and inefficiency between sub-teams. The crisis management team suggested that an agile methodology may help share situational awareness and quickly clarify sub-team tasks and priorities.

Objective 5

Test the processes in place for the department to effectively communicate information regarding the incident to relevant external stakeholders (the public, departmental executive, OPICC agencies and the minister’s office).

During the exercise, the policy and situational awareness sub-team performed a PESTLE analysis. The analysis examined key political, economic, sociological, technological, legal and environmental factors relating to the incident. It was conducted on a white board near the crisis management team so members could see it and contribute at any time.

The analysis was a major source of situational awareness for crisis management team members when preparing communications products and briefings for the minister’s office and OPICC chair.

Throughout Exercise Zephyr, a staff member from the Communications Branch was seconded to the crisis management team in the Offshore Resources Branch. It was extremely valuable to have this staff member giving advice and directing communications products.

The crisis management team produced media and communications materials, including:

• articles for the intranet and department website (industry.gov.au)
• draft media releases and speeches for the minister's office
• scripts and talking points for the department's media team.

The team understood the products needed and their content. However, they were not always clear on the drafting, clearing and distribution processes for these products during a real incident, particularly between the crisis management team and the department’s media team.

For example, would developing a joint media release with another Australian Government department be done by the crisis management team or the department’s media team? It was also unclear if the crisis management team would monitor social media in a real incident or if the Communications Branch would do this.

Exercise Zephyr tested the processes and procedures of the OPICC and the department’s crisis management team during an offshore petroleum incident. It helped us identify areas for improvement. It also refreshed and improved participants’ knowledge of preparedness and response arrangements.

The department thanks:

• AMOSC, for initiating and planning Exercise Zephyr and inviting us to take part
• OPICC, for letting us station a liaison officer in the industry incident management team
• The WA Department of Transport, for collaborating on exercise design and letting us have a liaison officer in its incident management team.

The department is reviewing Australia’s oil spill preparedness and response framework. While the review is not directly linked to this exercise, lessons learned from Exercise Zephyr may inform the review in future.

The department will participate in future exercises to ensure the Australian Government, industry, and state and territory governments remain ready and capable to respond to an offshore petroleum incident.

Glossary