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ONO Objects

These are many of the reasons ONO objects to how the EIA process has been handled for the Sasol / ENI proposed exploration for 2019 off the KZN coastline:

Draft EIA REPORT FOR EXPLORATION DRILLING WITHIN OFFSHORE BLOCK ER236, KZN, SOUTH AFRICA; ERM Ref: 0414229 pertains.

This letter serves to lodge an objection to the proposed exploration for the reasons listed below. It also serves to highlight numerous contentious issues with this DEIAR process. Our primary concern is that there is clear systemic injustice and fundamental flaws in the DEIAR process for this application, and as such ERM have failed to comply with the DEIAR requirements as set out in NEMA and the EIA Regulations and this is evident for the following reasons:

CONTEXTUAL CERTAINTIES NOT ESTABLISHED FOR EITHER THE SCOPING REPORT OR THE DRAFT ENVIRONMENTAL IMPACT ASSESSMENT REPORT

It can reasonably be argued that much contemporary baseline information against which the impact of the project can be weighed remains unavailable and accordingly it cannot be said that context has been properly established within the Draft Environmental Impact Assessment Report (DEIAR). Support for this submission is as follows.

  1. The DEIAR reports that baseline data of flora and fauna in “pelagic and demersal communities of the shelf edge, continental slope and upper and lower bathyal are largely unknown” (p80). This near-absence of baseline information on the deep living communities, coupled with the spatiotemporal complexity of the brightly lit, warm epipelagial, to the dimly lit, thermally variable mesopelagial, to the lightless, cold bathypelagial zones added to the ecological processes within each of these depth domains exhibiting high temporal variability on scales ranging from hours to years, makes assessing this complex ecosystem as a desk-top study completely inadequate.
  2. The exploration sites have neither been visited nor sampled and therefore baseline data remains unknown and the sea floor undisturbed, hence it is unfeasible for the DEIAR to conclude that impacts (of all phases of exploration) to the sea floor to be “negligible”. A proper impact assessment is only possible afterthe ROV study has been made of the sites, having been made public and undergone appropriate stakeholder engagement. This is a critical research needfor this application.
    1. The occurrence of deep-water corals in Block ER236 is undetermined and not is enough known about the coelacanth lifecycles and where they spend their time during their life stages (that is, between the juvenile stage and the adult stage) for the DEIAR to claim that their presence is “unlikely” in the drill sites. An argument from a lack of knowledge simply proves an insufficient investigation and not the veracity of their absence.
    2. Similarly statements that submerged prehistoric archaeological sites or material being present in the study area is “extremely unlikely” calls for the mitigation measure of not only impartial marine ecologists but also experienced archeologists, without competing financial interests, monitoring the discoveries of the ROV in real time.

PROCEDURAL ISSUES

  1. The Environmental Management Programme (EMPr) has been incorporated as a 30-page document into the DEIAR instead of being a stand-alone report as is required by the DEIAR Regulations.
  2. ERM claims that a review of the Draft EIA Report was available at the Port Shepstonelibrary, however it was under renovation and inaccessible at the time, leaving the whole of the KZN South Coast without access to the printed report.
  3. The Scoping Report was not completed in the designated time and should have been repeated, as is required by section 21 of the EIA Regulations (GNR982 of 4 December 2014, as amended). The regulation allows an existing scoping report to be used in certain circumstances. One of these is that a scoping report need not be undertaken again if the findings of the initial scoping report are still valid and the environmental context has not changed. Considering that the DEIAR claims the “areas of interest are unknown” potential gains and/or losses at the inter- and intra-species levels; changes in species abundances; loss of habitat; loss of physical connectivity between habitats, and ecosystems and the unknown impacts on seabed features as well as undiscovered species are unaccounted for. It follows that context has not been properly established by ERM, nor whether there have been changes within it. Due to these concerns I lodged an objection to the lack of follow-up Scoping Report at the Public Participation meeting with ENI and Sasol (9th October) and requested that the EIA be suspended pending the completion of a proper scoping procedure. This objection had 40 seconders whose signatures I attach.

CHANGES THAT AFFECT DECISION MAKING

  1. Cabinet has now approved the promulgation of twenty Marine Protected Areas (MPAs). Pertinent to the ENI/Sasol application is the promulgation of the extension of the iSimangaliso and Aliwal Shoal MPAs and two new MPAs, namely Tugela Banks and Protea Banks. Given that the scoping report, as originally approved in April 2018, no longer reflects the “current environmental context” it is clear that a new scoping report is required and the DEIAR process needs to be re-visited with this new environmental context in mind.
  2. In early September 2018 a resolution was proposed at the 67th International Whaling Commission (IWC) for the elimination of acoustic pollution that affects whales (of all 13 species and populations considered under the IWC). This resolution was passed by consensus with South Africa being one of the signatories. This is a real and internationally upheld obligation, which impacts the planning around sound mitigation for this DEIAR. The IWC classes anthropogenic sound “as either acute or chronic.  Acute noise such as seismic surveys or military sonar is high in intensity and short in duration. Chronic noise refers to low intensity but generally increased noise in the marine environment, for example from shipping and industrial activity.”[i]As such the scoping report and the DEIAR needs a higher survey effort reflecting South Africa’s commitment to the aforesaid convention.

CONTRADICTIONS

  1. Lack of consistency in time-frame application for the DEIAR impacts assessments renders them unreliable. Environmental and social impacts are measured only during the operation of exploration, whereas the No-Go Alternative projects impacts into the future beyond the project. This creates a complete lack of parity for any rational comparison of effects and makes the significant ratings therefore irrational and skewed.
  2. There is contradiction in the DEIAR around issues relating to bioavailability of NADFs (p190) stating they experience rapid biodegradation and yet they are harmless because they have a low bioavailability.

The DEIAR cites a ”Potential for short-term localised impacts on seafloor (benthic community) and water column biology due to chemicals and sediments in the water column and settling on the seafloor”. However there is research that shows that chronic intermittent exposure of species such as corals, shrimp, scallop, including larval stages of many species, to dilute concentrations of operational drilling wastes (characterized by tests as practically non-toxic) can affect growth, reproductive success and survival[ii],[iii].

CRITISISM OF THE OIL SPILL MODELLING

  1. This Oil Spill Modelling appears to only consider surface movement of oil and its impacts.
  2. There is no modelling for recurrent small spills. Small spills have immediate adverse biological effects and their recurrent nature is likely to affect marine ecosystem functioning[iv].
  3. There is no modelling for spills during transportation.
  4. The modeling is based in the assumption that the most significant damage will be on shoreline biota. Potential impacts to deep-sea communities from seabed through the water column are not taken into account.
  5. There is no follow up in the DEIAR to the peer reviewer’s suggestions or requests for clarification.
  6. The Oil Spill Modelling Report was vetted by an oceanographer with specialist knowledge of the offshore KwaZulu-Natal conditions and brings to light many deficiencies and under-representations of potential impact in the DEIAR.

This review also cites the real case study of the Katina P, which was laden with oil at the time of her sinking in 2 800 m depth, some 200 nautical miles off Maputo. This incident was selected for illustrative purposes and may not represent either the most severe case or the most likely results. It is, however, representative of a recent accident and has been investigated as to its consequent effects. It created a slick on the South African east coast from Kosi Bay to the Transkei.

This independent review finds:

  1. The Natal Pulse has not been taken into account.
    1. It may result in more variability than seasonal scenarios.
    2. The impact of onshore winds with slack currents could mean oil will get transported onshore.
  2. It is modelling general conditions.
  3. The coarse resolution of the HYCOM models means a loss of accuracy near the coast.
  4. No local content has been used to verify the model output.
  5. Previous studies of the site with respect to coastal oceanography are referred to but are not referenced.
  6. Due to there being no understanding of the science of currents in the area, the scientific interpretation is wrong.
  7. There is no validation to compare with measured data.
  8. The model has not taken mesoscale cyclonic circulations sufficiently into account.
  9. Importantly both the peer reviewer and this review question the spill quantity and why conservatively high rates were not used for the oil spill modelling.
  10. Temporal vagaries brush over the significance of the impacts for example.p3 of Annex D7: “Diesel would naturally degrade and evaporate on the shoreline over time.”
  11. The modelling needs to consider surface wind response, apart from currents,
  12. The possibility of oil getting entrained into Port St Johns Eddy, which makes shoreline oiling probable, has not been considered.

Both the technical and independent review of this Oil Spill Modelling Report question whether appropriate methods have been used, whether the data was suitable and whether the findings and conclusions were adequately supported. In other words, the Oil Spill Modelling Report does not satisfy recognised good practice requirements.

An overarching framework providing guidance on initiating, designing and determining the scope of a post-incident monitoring programme must facilitate this DEIAR.

LACK OF DETAILED CONTINGENCY PLAN for SUBSEA AND SURFACE RELEASE

  1. An OSCP (Oil Spill Contingency Plan) must be made public during the DEIAR process, and not “prior to start of drilling” as stated, for proper stakeholder and I&AP engagement.
  2. Transparency is needed with regards to Oil Spill Response, Planning and Capacity necessary for public health and welfare as well as that of the marine and coastal environment. An annex to this DEIAR should include the blowout management protocol for the project. Included in this annex should be highlighted any deficit of technological expertise or resources or difficulty of effective co-ordination with all government or conservation agencies that have a statutory responsibility for some aspect of offshore oil and gas activities regarding incident management. The delegated National Incident Commander, along with the intended lines of responsibility for inter-agency efforts, should be made available for proper stakeholder and I&AP engagement. The citizens of South Africa need assurance that incident management is fully informed and has capacity to deal with the latest technology, practices and risks associated with, and due to, the different geological and ocean environments being explored, prior to commencement of drilling.
  3. There is significant concern over timeous response to a spill given the listed mitigations and rate of flow of the Agulhas current:
  4. The capping stack which is supposed to “significantly reduce spill period” will be shore-based, at least 50km away from the drill sites, and will pose a logistical problem due to its tonnage and size in terms of transport to the drill site. It will take time to reach a deep-sea blowout.
  5. The recommended emergency equipment and team “who will be mobilized immediately” are based in Saldanha Bay 990 nautical mmiles and 4.1 days away ( travelling at 10 knots).
    Based on these delays hundreds of kilometers of ocean could be fouled before proper response is in place.
  6. The DEIAR makes no mention of mitigation or contingency plans in the event of a fire or explosions. The Chevron Nigeria Limited explosion of January 2012 and the Gunashli oilfield disaster of December 2015 are indicators of the dire need for proper mitigation planning.
  7. There is no mention made of how the drill ships, pipelines and general infrastructure will respond to the environment in extreme weather. Some sources state that the general intensityof the weather and storms are to increase in the region in the future.Only one South African well has recently been drilled in depths greater than 500m and Total experienced problems with this Brulpadda 1AX prospect rig operation. A key reason for this is the extremely challenging metocean conditions particular to the very strong Agulhas current. The proposed wells in the proposal which forms that subject matter of this correspondence are nearly twice as deep as those of Total. With the oil and gas industries’ track record of pollution (ENI alone has reported Oil Spillage statistics of 4.89 million litres in operations between 2009 – 2017), it remains for ENI and Sasol to prove that the proposed offshore drilling will not result in any serious environmental harm.
  8. Sasol claims the probability of an oil spill occurring being less than 1% in their Consolidated Response to the Durban Community Questions of May 2018. According to Sasol’s risk assessments, please supply the full workings for the less than 1% probability for an oil spill on this project, stating the exact calculated probability percentage. Please provide the estimated return period and the probability of a full-bore rupture in a given year for this assessment. Which expected year of decommissioning these wells was used for this calculation?
  9. Whilst the report on financial provisions for decommissioning is appreciated, further proof of insurance safeguards against incidence management and a reasonable level of fiscal readiness for long term cleanup and reparation process, in the event of a major disaster must be made public. This was requested of Sasol on 17th of May 2018.

The developers have failed to give clear insight into their proposed OSCP to allow stakeholders and I&APs to engage on whether or not this plan provides sufficient protection to marine and coastal environments.

LACK OF DISPERSANT USE PLAN
The DEIAR suggests dispersants to mitigate any spill but it provides no guidelines, plan or choices for dispersant use.

  1. Which dispersants will be utilized? An explanation of their chemical components, toxicity, potential for bioaccumulation, ecological impacts through the water column and on the shoreline, and their specific function must be also provided.
  2. There are many situations where the net environmental benefits of chemical dispersion are not clear. The dispersant effects to local flora and fauna must be indicated for all potential choices of dispersant in order for regulators to confidently decide on dispersant use issues.
  3. The ability to provide timely and scientifically sound outcome and effects information is essential to support the regulators in their decision making role when approving the initial use of dispersants and whether to continue or cease their use during the incident.
  4. Predictive migrations maps of dispersants based on sound oceanographic and metrological science must be provided.
  5. Developers must provide proof of immediate availability of dispersants considering this is of primary importance in effecting recovery rates.

LACK OF ASSESSMENT OF ONSHORE ENVIRONMENT AND MITIGATION

Buried oil contaminants can resurface as the beach erodes. Buried oil must be removed through mechanical excavation. The DEIAR needs detailed modelling of cross-shore distribution of oil contaminants relating to beach morphodynamic terminology to help optimize beach cleanup planning.

LACK OF COST BENEFIT ANALYSIS

  1. A cost benefit analysis not been undertaken for the ENI/Sasol application and no explanation for this oversight has been provided. The consequences of a blow-out on the tourism, recreation and leisure industries may be significant yet the aspect of compensation to these sectors has not been dealt with at all.
  2. Without a cost benefit analysis ERM rates the significance of the economic toll a spill would have on livelihoods dependent on safe recreation at beaches, healthy habitats for wildlife, and industries such as tourism and fishing as ‘moderate’.
    1. ERM regards much subsistence, recreational and prawn trawl total fishing effort in KZN as “being unknown” or have not assigned the total catch a value. This effectively means that the pre-spill status of the KZN fishing sector and related businesses remains unmeasured, as would its economic losses by disruptions, loss of earnings plus the effects of negative publicity, persisting public perceptions and potential fishing and harvest bans.
      It remains for ERM to qualify their assessment associated with this degree of uncertainty, given their statement that Block ER236 “harbours the only commercial shallow-water prawn trawl fishery in the country and is thus of considerable socio-economic importance to KZN” and that spatial distribution of line-fishing effort (“the country’s third most important fishery in terms of total tons landed and economic value”) coincides with inshore areas of Block ER236”.
    2. Studies worldwide show that oil spills generate coastal impacts that can last many decades[v]. Oil-polluted beaches, mangroves and estuarine wetlands rely chiefly on anaerobic degrada­tion, which is slow. Below just 10–15 cm in beach sand and 2–3 cm in muddier sediments, oxy­gen levels plummet, and from these anoxic layers, pockets of oil can leach toxicants for decades.[vi]In addition to costs incurred by cleanup activities, serious economic losses can be experienced by tourism-dependent businesses, industries and individuals dependent on coastal resources. Considering that the KZN coastal area has a high amenity value, with between 49.7% and 61.3% of activities undertaken by foreign visitors in KZN[vii]being beach related, ERM again needs to justify a significance rating as moderate by producing a cost analysis and proper stakeholder engagement.

There is a failure by the DEIAR to deal adequately with cost benefit analysis in the event of a spill and the consequences thereof on private individuals, the commercial sector and on the ecosystem itself. The effect of a spill on climate change is not addressed at all. No reference is made to how these affected systems will be compensated in the event of an oil spill.

STAKEHOLDER ENGAGEMENT
This application’s public participation process has been shown to be deeply flawed and undemocratic:

  1. A major deficiency is, and has been, the failure of this DEIAR regime to consider ethnodiversity. Many of the I&APs do not speak English with the proficiency required to fully understand the literature to grasp the implications of the project and how to address these. This needs to be tackled retroactively with immediate effect as this process has been fundamentally exclusionary.

Producing a heavily précised DEIAR draft booklet in isiZulu (after repeated public requests for inclusivity at and after the first series of public meetings, during the scoping phase (Between 6 and 8 February 2018)), two weeks before comment submission, is both unfair and a recognition that the process was flawed.

There has been a lack of proper response to stakeholder concerns, apart from my own already mentioned. A number of I&APs comments and questions from public meetings have not been properly captured or properly answered, therefore due process has not been followed:

  1. None of Fred Kockett’s questions of 6 Nov 2017 have been properly addressed.
  2. Many of Branch Chairman at WESSA, Paddy Norman’s questions at a public meeting were not noted and remain unanswered, in particular:
    1. He asks,“If a drilling program has ever been undertaken in similar conditions –of weather, depth, and seabed morphology”and“ Is the risk quantifiable?”
    2. He questions the“ ability of the drilling ship to handle extreme conditions, such as “freak waves” which occur on our coast remarkably frequently. ENI insist that their drilling ship can handle just about anything. However, that may not be comprehensively valid. A freak wave would lift the ship significantly, and this might put excessive strain on the drill string. More importantly, will the possible follow up work be equally robust. There is no justification for prospecting if consequent production activities are subject to unmanageable risk.”
    3. “It also needs to be pointed out that the continental shelf off KZN is unusually narrow and steep. The southern drill site is below a significant scarp. There may be a potential to trigger an underwater landslip, which could have disastrous consequences, not only on the natural environment, but also by generating a tsunami very close to our beaches. Although I doubt if anyone could quantify this risk, the potential damage and loss of life needs to be considered, not to mention the multi-national and financial implications.
    4. He requested information “on the destination of the product; since one of the justifications for this program is given as South Africa’s energy requirements / energy security, then South Africa should be the primary beneficiary from any production. The response was that SA would be able to purchase the product at the market rate. This scenario must be included in the cost/benefit assessment, since the primary local concern is the cost of importing fuel, and the justification for this program is to reduce that cost”

NEED AND DESIRABILITY OF THE PROJECT

South Africa’s Nationally Determined Contribution of C02currently fallsoutside of the fair share range. The higher order considerations as to future effects to greenhouse gas emissions and acceleration of global climate impact has been circumvented in this report via zero reporting on estimated end outputs. The DEIAR Summary of Project Activities that will result in Greenhouse Gas Emissions makes a mockery of this by suggesting that there will only be emissions generated by the vessels and helicopter. This DEIAR has not provided a sufficient evidentiary base to answer key questions around contributions to global warming and climate change by the proposed extraction of fossil fuels.

  1. An assessment of the potential end output of the project, i.e. the expected barrel delivery must be measured for its increase in carbon emissions to South Africa’s peak, plateau and decline commitments to the global economy. This DEIAR requires more rigorous expert judgment in evaluating holistic risks to climate change for the benefit of all, and should evaluate the option of not proceeding with further activity.

OPERATIONAL WASTE

  1. Key findings from the drill cutting modelling show the sediment layer at the wellhead itself being only 1m thickness getting thinner further away from the wellhead. The modelling also shows distribution effects of a 5 cm smothering layer of drill cutting sediment as close to 7 km2in a month. The global literature cites that discharges at similar depths may produce cuttings accumulations of up to 20m thickness within 100–500m of the well site and gradually get thinner away from the wellhead[viii]. There is no projection for the full length of the drilling operation, which goes on for an average of 54 days. This models’ temporal selection of a month seems prevaricative without a substantiation.

ROV surveys of 500m2around each site are inadequate and need to be therefore expanded to take into account the full footprint of the operation.

  1. Also the drill cutting modelling does not take into account further adverse effects on the wider marine environment from decommissioning and removal of the platform.
  • The DEIAR claims that the effects of smothering are “Fully Reversible”.  Given that smothering leads to mortality of deep water corals and that they are extremely slow growing organisms (hundreds of years old in many cases) please support the claim that the effect of coral death is fully reversible on any ecologically relevant timescale.[ix]
  • SEISMIC NOISE AND PRESSURE EMISSIONS SCOPED OUT

The Vertical Seismic Profiling, which involves airguns capable of inducing lethal and sublethal injury[x],[xi], hearing loss [xii],[xiii](temporary or permanent), masking of communication, physiological stress[xiv], [xv], [xvi], [xvii], acoustic resonance in air cavities, organ rupture, behavioural responses, avoidance of critical habitat areas, disruption in schooling and migration [xviii], disruption of homing or orientation[xix]; decreased feeding efficiency[xx];decompression sickness, and mass strandings[xxi], [xxii]for marine animals,  have been scoped out as a significant impact in the Summary of Underwater Noise Activities that may Disturb Marine Fauna. The mitigation of Vertical Seismic Profiling cannot simply be an issue of “short duration” and “limited to the survey area” since airguns produce high decibels and amplitudes of sound with high exposure levels travelling vast distances capable of causing immediate and significant acoustic trauma. Please assess the full scale of this acoustic footprint, especially in light of 3) ii. The use of airguns in a marine environment requires mitigation and no seismic activities should take place during the known breeding and migration periods of cetaceans and turtles.

  1. Mitigation should include the establishment of a hearing threshold-based safety zone based on the best available data during seismic survey activities. Cumulative acoustic limits should be established. These limits should be appropriately matched to the spatiotemporal scale and exposure rate of the risks to individuals and populations. Measurement of noise budget, such as those under consideration under the EU Marine Strategy Framework Directive (Tasker et al. 2010), should lead to limits on the source levels that are introduced on a regional scale, especially in areas where noise pollution is increasing.

The DEIAR has not considered the probability of recurring seismic surveys, the risks associated with compounded behavioural disturbance and how chronically-present sound could constitute a threat to populations by changing behaviour and distribution regularly at critical times and in critical areas.

Regulators and project proponents should establish communication for the duration of the survey with stranding networks and conservation organisations local to the survey to fully understand the potential effects of the survey on the greater marine environment and take further mitigatory action should stranding reports register adverse effects to unusual species or increased numbers.

MARINE PROTECTED AREAS BUFFER ZONES

The DEIAR should propose buffer zones adjacent to MPAs in order to protect marine biota inside the designated areas to mitigate mining impacts in the areas where evidence does not exist.

AIR POLLUTION

If gas must be flared, an accurate determination of the volume of gas flared, its emissions quantity and concentration must be made known.

CORRECTIONS
There is a species that is incorrectly classified according to the the IUCN red list in this report:
The leatherback turtle (Dermochelys coriacea(Southwest Indian Ocean subpopulation)) is Critically Endangered, not Vulnerable (that is the global status) as described.

The proximity of these potential wells to our environmentally significant areas – The Maputaland and St Lucia Marine Reserves, Tugela Banks, The Natal Bite with its crustacean trawl fisheries, Protea Banks, Aliwal Shoal and iSimangaliso Wetland Park World Heritage Site – poses a great risk to our marine commons and heritage, the economic importance of our fisheries, and leisure and tourism industries dependent on functional healthy oceans. All the above reasons warrant questioning the lack of a precautionary approach and the impact significance ratings given by this DEIAR, based on minimal data. The scoping report and the DEIAR have been shown to be neither comprehensive nor technically robust thereby not meeting its terms of reference or providing the required information for decision making. In light of this, it is requested that the application be withdrawn until the process can result in full consideration of all relevant information on the affected environment, of proposed alternatives and their impacts, and of the measures necessary to monitor and investigate residual effects.

I look forward to hearing from you

 

References

[1]Guastella, L. 2018. Review of Oil Spill modelling for ENI Proposed Exploration Drilling in Block ER236. Specialist report on the Environmental Impact Assessment for Proposed Exploration Drilling in Block ER 236, offshore of Kwa-Zulu Natal Coast of South Africa – Oil Spill Modelling Report, (Annexure D4). 9pp.

[i]International Whaling Committee, Anthropogenic Sound. Available at: < https://iwc.int/anthropogenic-sound> [Accessed 31 Oct 2018].

[ii]Cranford, P.J., Gordon, D.C. Jnr., Armsworthy, S.L., Lee, K., & Tremblay, G. H., 1999. Chronic toxicity and physical disturbance effects of water- and oil-based drilling fluids and some major constituents on adult sea scallops (Placopecten magellanicus). Marine Environmental Research, 48(3), 225-256.

[iii] Jargengren, J. Brooke, S., Jensen, H., 2017. Effects of drill cuttings on larvae of the cold-water coral Lophelia pertusa.Deep Sea Research Part II: Topical Studies in Oceanography, 137, 454-462.

[iv]Brussard, C. P. D., Beggah, S., Wick, L. Y., Wuerz, B. Weber, J., Arey, J.S., van der Burg, B., Jonas, A., Huisman, J. Roelof van der Meer, J., 2016. Immediate ecotoxicological effects of short-lived oil spills on marine. Nature Communications, 7 (11206).

[v]Schmidt, C. W., 2010. Between the Devil and the Deep Blue Sea. Environmental Health Perspectives, 118 (8).

[vi]Wang, P., Briggs, T., 2013. Distribution of Surficial and Buried Oil Contaminants across Sandy Beaches along NW Florida and Alabama Coasts Following the Deepwater Horizon Oil Spill in 2010. Journal of Coastal Research. 291. 144-155.

[vii]Statistics of our Tourism Area Report, Tourism KwaZulu-Natal, Available at https://www.southafrica.to/provinces/KwazuluNatal/stats/kzn-tourism-stats-2015.pdf  > [Accessed 4 Oct 2018].

[viii]Pivel, M. A. G., Freitas, C. M. D. S., and Comba, J. L. D. 2009.  Modelling the discharge of cuttings and drilling fluids in a deep-water environment. Deep Sea Res. II 56, 12–21.

[ix]Prouty, N. G., Fisher, C. R., Demopoulos, A. W. J., Druffel, E. R. M., 2016. Growth rates and ages of deep-sea corals impacted by the Deepwater Horizon oil spill. Deep Sea Res. Part II Top. Stud. Oceanogr.

[x]McCauley, R. D., Fewtrell, J., and Popper, A. N. 2003. High intensity anthropogenic sound damages fish ears. Journal of the Acoustical Society of America.113, 638–642.

[xi]André, M., Johansson, T., Delory, E., van der Schaar, M., Morell, M. 2007. Foraging on squid, the sperm whale mid-range sonar. Journal of the Marine Biological Association UK87, 59–67.

[xii]André, M., Johansson, T., Delory, E., van der Schaar, M., Morell, M. 2007. Foraging on squid, the sperm whale mid-range sonar. Journal of the Marine Biological Association UK87, 59–67.

[xiii]McCauley, R. D., Fewtrell, J., and Popper, A. N. 2003. High intensity anthropogenic sound damages fish ears. Journal of the Acoustical Society of America.113, 638–642.

[xiv]Buscaino, F., Filiciotto, G., Buffa, G., Bellante, A., Di Stefano, V., Assenza, A., Fazio, F., Caola, G., Mazzola S., 2010, Impact of an acoustic stimulus on the motility and blood parameters in European sea bass (Dicentrarchus labrax L.)and gilthead sea bream (Sparus aurata L.)Marine Environmental Research.69, 136-142.

[xv]Graham A. L., Cooke S. J. (2008). The effects of noise disturbance from various recreational boating activities common to inland waters on the cardiac physiology of a freshwater fish, the largemouth bass(Micropterus salmoides). Aquat. Conserv. 18, 1315–1324.

[xvi]Wysocki, L. E., Ladich, F. Dittami, J. 2006. Noise, stress, and cortisol secretion in teleost fishes. Biological Conservation128, 501–8.

[xvii]Santulli A., Modica A., Messina C., Ceffa L., Curatolo A., Rivas G., et al. (1999). Biochemical responses of European seabass (Dicentrarchus labrax L.) to the stress induced by off shore experimental seismic prospecting. Marine Pollution Bulletin. 38, 1105–1114.

[xviii]Sarà, G., Dean, J., D’Amato, D., Buscaino, G., Oliveri, A., Genovese, S., et al. 2007. Effect of boat noise on the behaviour of bluefin tuna Thunnus thynnus in the Mediterranean. The Marine Ecology Progress Series. 331, 243–253

[xix]Simpson, S. D., Meekan, M. G., Larsen, N. J., McCauley, R. D., Jeffs, A. 2010. Behavioral plasticity in larval reef fish: orientation is influenced by recent acoustic experiences, Behavioral Ecology, 21, 5, 1098–1105.

[xx]Purser J., Radford A. N. (2011). Acoustic noise induces attention shifts and reduces foraging performance in three-spined sticklebacks (Gasterosteus aculeatus). PLoS One, 6, e17478.

[xxi]Hildebrand, J. 2006. Impacts of anthropogenic sound. 101-123 in: Ragen, T.J., Reynolds III, J.E., Perrin, W.F., Reeves, R.R., and Montgomery, S. 2006. Marine Mammal Research: Conservation beyond Crisis. Baltimore: Johns Hopkins.

[xxii]Gordon, J., D. Gillespie, J. Potter, A. Frantzis, M. Simmonds, R. Swift, D. Thompson, 2004. A Review of the Effects of Seismic Survey on Marine Mammals. Marine Technology Society Journal, 4, 14-32.

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