ONO has deep concerns for the plight of the African Penguin with 2 massive surveys planned in their feeding grounds for 2019.
South Africa’s endangered African Penguin (Spheniscus demersus) has been shown to avoid its preferred feeding areas during seismic surveys, feeding further from the survey vessel when in operation (Pichegru et al. 2017). With a 70 % decline in their numbers since 2004 and commercial fishing changing and decreasing their fish stocks in the vicinity of their breeding colonies these seismic surveys pose a real risk of further increasing fish scarcity thereby increasing foraging ranges with implications for individual and population fitness for the African Penguin.
9 African Penguins stranded on KZN beaches in 2018.
For this and many more reasons ONO has placed an objection to the latest application for 2 surveys being operated concurrently:
Proposed speculative 2D and 3D seismic surveys off the South and West Coast of South Africa: Environmental Management Programme SLR project No: 720.16030.00005 refers.
This letter serves to lodge an objection to the proposed speculative two-dimensional (2D) seismic and three-dimensional (3D) seismic survey by Petroleum Geo-Services (Project Reference 720.16030.00005) off the Western and Southern coasts of South Africa.
SLR Consulting has a primary role in the mitigation which is crucial to limit changes in the climate system due to greenhouse gas emissions. The carbon-emission-cuts target set by the Paris Agreement to Combat Climate Change (2015), to which South Africa is a signatory, needs consideration in the desirability of this project. It may be argued that this is simply an application for reconnaissance, however, as a stakeholder, one has to assume that there is intension to extract. Any insistence on expanding and sustaining the use of fossil fuels is both socially and ecologically irresponsible and therefore unjustifiable, knowing the future effects to greenhouse gas emissions extraction will have not only on South Africa but globally. This EMP has not provided a sufficient evidentiary base to answer key questions around contributions to global warming and climate change and these need to be addressed, in terms of the expected gas barrel delivery measured for its increase in carbon emissions to South Africa’s peak, plateau and decline commitments to the global economy, as a matter of priority.
The objection is based on the following, inter alia:
Legislative and environmental requirements for offshore seismic surveys have changed radically due to their repeal, with the onset of Operation Phakisa, fostering quick oil and gas extraction. Greater effort therefore needs to be made to ensure that the provisions of the National Environmental Management Act and the provisions of the Constitution, along with the Law of the Sea Convention (LOSC Article 192), which stipulates that state laws and regulations must be “no less effective than international rules, regulations and procedures”. This EMP therefore should employ best environmental practice, apply the precautionary approach, and act in lieu of a proper environmental impact assessment to ensure that that potential key environmental issues and impacts that could result from the proposed project are identified.
To be included in the list of relevant international and national legislation and conventions:
In 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 any EMP. The IWC classes sound generated by seismic surveys as “acute” and a “critical factor when considering potential threat to cetacean populations”[i]. This EMP needs a higher survey endevour reflecting South Africa’s commitment to the aforesaid convention.
TIMING OF IMPACT
The recommended timing of the survey between January to end of May 2019 is lodged with the caveat of being ultimately dependent on a permit award date, availability of the survey vessel and the scheduling of 2D and 3D surveys to either coincide or not.
The timing of these surveys is critical for least possible impact on seasonal breeding, feeding, spawning and migrations. Nowacek et al (2013) concluded that the best way to mitigate negative impacts of seismic surveys on marine mammals is to separate them in time, space, or both. There should be no leeway given in the proposed temporal window of this survey, except to reduce the schedule duration, given the degree of threat due to the survey area overlapping spawning and migration routes.
ISSUES WITH USE OF ‘GENERIC’ EMP GUIDELINES
- This EMP states that “many of the issues associated with seismic surveys are generic in nature and have been assessed based on previous seismic survey programmes off the coast of South Africa and the Generic EMP prepared for seismic surveys in South Africa.” This treatment understates the compounding effects of multiple abiotic and biotic stressors associated when 2D and 3D surveys operate concurrently. A multiple survey interaction must be considered to clarify whether the interaction is synergistic, additive, or antagonistic.
- Due to the frequency and enormous extent of the multi-client surveys and exploration planned for 2019 the assumption that larger/more mobile and/or migratory animals will avoid and move away from seismic surveys needs serious revision. Accumulative effects need to be broadened to encompass neighbouring seismic and exploration applications. Highly precautionary limits on the amounts of annual and concurrent survey activities should be prescribed.
- The potential effects of the 2D and 3D surveys running concurrently have largely been brushed aside as “insignificant” by this EMP, minimizing the very real risk of displacement from feeding or breeding areas which could have far reaching effects not only for whole, and vulnerable, animal populations, but also on 8 fishing sectors and our food security. This demands a critical and more thorough review of any suspected risk.
- South Africa’s endangered African Penguin (Spheniscus demersus) has been shown to avoid its preferred feeding areas during seismic surveys, feeding further from the survey vessel when in operation (Pichegru et al. 2017). With a 70 % decline in their numbers since 2004 and commercial fishing changing and decreasing their fish stocks in the vicinity of their breeding colonies these seismic surveys pose a real risk of further increasing fish scarcity thereby increasing foraging ranges with implications for individual and population fitness for the African Penguin.
- Will a multi-beam bathymetric sonar survey be operating concurrently to either the 2D or 3D surveys?
- The danger of reflected sound off the surface of the sea has not been highlighted by this EMP. It is known to amplify kinetic and pressure effects and explains the anomalies of animals further away from the airguns being more affected at times.
- Seismic surveys are used for their high-power penetrative shock wave properties resulting in them being heard for thousands of kilometers away from the source if spread in a sound channel underwater. The recordings of autonomous acoustic seafloor recording systems of the US-NOAA on the central mid-Atlantic Ridge showed year-round recordings of airgun pulses with a dominance in summer from seismic surveys often taking place usually more than 3000 km away (Nieukirk et al. 2004). Low-frequency energy from seismic sounds may travel long distances through bottom sediments, re-entering the water far from the source (Richardson et al. 1995; McCauley & Hughes 2006). To repeatedly assign “insignificant” impact assessments to species due to the assumption that this widespread survey’s potential extent is “localized” is seriously misleading.
- The assumption that received airgun noise levels decrease with less and less impact on the exposed animals further from the noise source was overturned by Madsen et al(2006). They found high exposure levels at considerable ranges from the air-gun array and that received sound pressures and sound exposure levels may actually increase with ranges beyond 5 km range up to 12.6 km from source. They believe this high frequency acoustic by-product on marine mammals should not be dismissed lightly and that it poses the challenge of how to mitigate where animals can dive in and out of high exposure levels at considerable ranges from the air-gun array.
- Effects of air gun pulses on fish can range from serious injury at short ranges, where seismic noise has deafened fish with no recovery after 58 days[ii]. This damage was seen at exposure levels that might occur several kilometers away from the airguns. Also pertinent are increased stress signals[iii],[iv],[v],[vi]; disruption in schooling and migration[vii]; disruption of homing or orientation[viii]; decreased feeding efficiency[ix]; and reduced catch rates of 40-80% in areas more than 30 km from seismic surveys[x],[xi],[xii].
How close will seismic surveys be allowed to existing and recently approved MPAs? Buffer zones adjacent to MPAs should be proposed in order to protect marine biota inside the designated areas to mitigate mining reconnaisance.
EFFECTS TO FISHERIES
South African fish stocks are being exploited to their maximum capacity and are under threat from the impacts of ocean acidification and increasing sea temperatures therefore requiring protection, for both conservation and for those whose livelihoods are dependent on the ocean, such as fisherfolk.
- In the light of these challenges SLR needs to justify its low significance rating for the impact of airguns on fish eggs and larvae. The current seismic survey covers nearly 300 000 km2 in a currents moving on average between 2 – 5kms an hour potentially creating a massive destruction of zooplankton. McCauley et al (2017) warn of the ramifications for ocean ecosystem structure and health considering a significant component of zooplankton communities comprises the larval stages of many commercial fisheries species and healthy populations of fish, top predators and marine mammals are not possible without viable planktonic productivity. It begs the question of the sustainability of the ecosystem impacts of this operation.
- The use of Fig 2.4 and 2.5 in App3.1 Fisheries is imprecise as it shows a data cut-off for the distribution of hake eggs (left) and larvae (right) off the West Coast of South Africa. The area of interest within the seismic operation is excluded and so the full extent of the effect on this biomass cannot be analysed and appears understated.
- A study, providing localized context, commissioned by the Namibian government revealed that an 84% decline in tuna catches (650 tonnes in 2013 from 4,046 tonnes in 2011) was a result of an increase in seismic exploration for oil and gas in the Orange River Basin driving tuna from their normal migratory routes[xiii].Further to this:
Engås et al(1996) stands as the most definitive study to document what has long been observed by fishermen: When seismic surveys are taking place, the fish leave[xiv].
- Potentially, from the annual South Africa squid catch data, there is a correlation between seismic surveys and drop in squid jig catches[xv].Squid (chokka, Loligo reynaudi)are short-lived species and there are serious concerns about the impact of low frequency seismic airgun sounds on squid, where squid can die or suffer severe organ damage. Consultant to the Responsible Fisheries Alliance, David Russell, warns that larvae and juveniles may also be more susceptible to the harm of underwater noise than adults, possibly jeopardizing the sustainability of populations[xvi].
Taking this into account all-inclusive seafood supply chain stakeholder engagement will be necessary, in all relevant languages, to secure the on-going functionality of these fishing sectors and to avoid devastating capital losses. Discussion around a compensation scheme and conditions of compensation is imperative.
OIL SPILL MITIGATION
SLR needs to justify its rating of the degree to which the impact of accidental oil spill during bunkering operations can be reversed and is fully reversible and cite where, in the history of marine oil spills, there has ever been an effective mechanical recovery of a marine oil spill.
An OSCP (Oil Spill Contingency Plan) must be made public during the EMP process.
Will dispersants be used to mitigate any spill? If so which dispersants will be utilized? An explanation of their chemical components, toxicity, and potential for bioaccumulation, ecological impacts through the water column and on the shoreline, and their specific function must be also provided.
INCORPORATING NEW MITIGATION TECHNOLOGIES INTO GUIDELINES FOR THIS APPLICATION
Given the limitations with suggested detection of marine animal presence around a sound source in this EMP, namely the ineffectiveness of marine mammal observer (MMO) surveillance in darkness, obstructed visibility (eg fog) and high sea states and that animals may not be vocalizing, so limiting the efficacy of PAM, greater effort is needed to assess the various technologies available for detecting marine animals in low-visibility conditions. Technologies that need to be explored include active acoustic monitoring (AAM), radio detection and ranging (RADAR), light detection and ranging (LIDAR), satellite, and spectral camera systems, especially infrared (IR).
If SLR is working towards implementing worldwide best practice mitigation proceduresMarine Vibroseis should be recommended as an alternative to seismic airguns. It is a quieter, less impactful alternative. Vibroseis has been used successfully in land-based seismic exploration for many years. Instead of a sharp onset, loud intense “shot”, Vibroseis uses the same energy but spread over a longer duration, thus eliminating the sharp rise time (sounds quickly increasing in loudness) and high peak pressure (volume or amplitude) of airguns – two characteristics of sound thought to be the most injurious to living tissues (Southall et al.2007).
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. Survey planning involving large sound sources should consider whether there are other vessels using similar sources along the coast, making it hard for animals to avoid exposure.
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.The proximity of these surveys to our environmentally significant areas – Protea Seamount, Brown Bank Corals and Complex, Child’s Bank, Benguela Muds, Dyer Island – 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. The results of this EMP should indicate cause for concern for the critically endangered, endangered and vulnerable species and their migration paths as well as the critically endangered, endangered and vulnerable species habitats that will be subjected to the bombardment of this operation. All the above reasons warrant questioning the lack of a precautionary approach and the impact significance ratings given by this EMP based on minimalbiological baseline data.
 International Whaling Commission, Environmental concerns: Anthropogenic Sound, viewed 5 Sept 2018, <
[ii] 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.
[iii] 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
[iv] 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
[v] Wysocki LE, Ladich F, Dittami J (2006). Noise, stress, and cortisol secretion in teleost fishes. Biological Conservation128, 501–8.
[vi] 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 .
[vii] 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
[viii] 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,
[ix] 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.
[x] Engås A., Løkkeborg S., Ona E. and A.V. Soldal (1996). Effects of seismic shooting on local abundance and catch rates of cod (Gadus morhua)and haddock (Melanogrammus aeglefinus), Canadian Journal of Fisheries and Aquatic Sciences. 53, 2238-2249
[xi] McCauley R.D. (1994). Seismic surveys. In: Swan, J.M., Neff, J.M., Young, P.C. (Eds.). Environmental implications of offshore oil and gas development in Australia – The findings of an Independent Scientific Review.APEA, Sydney, Australia, p. 695.
[xii] Turnpenny, A. W. H. , Nedwell, J. R . 1994. The effects on marine fish, diving mammals and birds of underwater sound generated by seismic surveys. FARL Report Reference: FCR 089/94
[xiii] Shinovene, I. (2013) Govt fears tuna depletion as oil and gas exploration chase fish away [online]. Nambia: The Nambian, 25 November 2013). Available from:
[xiii]Engås, A., Løkkeborg, S., Ona, E. and Soldal, A.V., 1996. Effects of seismic shooting on local abundance and catch rates of cod (Gadus morhua) and haddock (Melanogrammus aeglefinus). Can. J. Fish. Aquat. Sc.53(10): 2238-2249
[xiii]Russell, D. 2018. Assessing the Impact of Seismic Surveys on South African Fisheries. p.98.Available from: <https;//rfalliance.org.za/wp-content/uploads/2018/10/Assessing-Impact-of-Seismic-Surveys-on-South-African-Fisheries-April-2018-1.pdf>
[xiii]Russell, D. 2018. Assessing the Impact of Seismic Surveys on South African Fisheries. p.99.Available from: <https;//rfalliance.org.za/wp-content/uploads/2018/10/Assessing-Impact-of-Seismic-Surveys-on-South-African-Fisheries-April-2018-1.pdf>
- Nowacek, D.P., Broker, K., Donovan, G., Gailey, G., Racca, R., Reeves, R.R., Vedenev, A.I., Weller, D.W. and Southall, B.L. 2013. Responsible Practices for Minimizing and Monitoring Environmental Impacts of Marine Seismic Surveys with an Emphasis on Marine Mammals. Aquatic Mammals39: 356–377.
- Pichegru, L., et al. (2017). “Avoidance of seismic survey activities by penguins.” Scientific Reports 7(16305): 8.
- Nieukirk, S. L., Mellinger, D. K., Moore, S. E., et al. 2012. Sounds from airguns and fin whales recorded in the mid-Atlantic Ocean, 1999–2009. Journal of the Acoustical Society of America, 131, 1102–12.
- Richardson, W.J., Greene, Jr., C.R., Malme, C.I., Thomson, D.H. 1995. Marine Mammals and Noise. Academic Press, San Diego.
- Madsen, P.T., Johnson, M., Miller, P.J.O., Aguilar Soto, N., Lynch, J., and Tyack, P. 2006. Quantitative measures of air-gun pulses recorded on sperm whales (Physeter macrocephalus) using acoustic tags during controlled exposure experiments. J. Acoust. Soc. Am.120: 2366–2379. doi:10.1121/1.2229287.
- Southall, B. L., et al. 2007. Marine mammal noise exposure criteria: initial scientific recommendations. Aquatic Mammals, 33 (4), 411-522.
- Tasker, M.L., Amundin M., Andre M., Hawkins A.D., Lang, W. Merck, T. Scholik-Schlomer, A. Teilman, J. Thomsen, F. Werner S. and Zakharia M., Marine Strategy Framework Directive: Task Group 11 Report: Underwater noise and other forms of energy, JRC Scientific and Technical Report No. EUR 24341 EN – 2010, European Commission and International Council for the Exploration of the Sea, Luxembourg, 2010
- McCauley, R. D., et al. (2017). “Widely used marine seismic survey air gun operations negatively impact zooplankton.” Nature Ecology & Evolution1(0195): 8